PB96-964511
EPA/ROD/R09-96/154
December 1996
EPA Superfund
Record of Decision:
McColl Superfund Site,
(Groundwater O.U.), Fullerton, CA
5/15/1996
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SFUND RECORDS CTR
1654-06956
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
RECORD OF DECISION
GROUNDWATER OPERABLE UNIT
MCCOLL SUPERFUND SITE
FULLERTON, CALIFORNIA
May 9, 1996
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TABLE OF CONTENTS
Page
SITE NAME AND LOCATION 1
STATEMENT OF BASIS AND PURPOSE 1
ASSESSMENT OF THE SITE . 1
DESCRIPTION OF THE REMEDY 1
STATUTORY DETERMINATIONS 2
DECISION SUMMARY 2
I. SITE LOCATION AND DESCRIPTION 3
A, Site Name and Location . . 3
B. Site Description . . , 3
C. Land and Water Use ......... 3
D. Regional Topography 6
E, Hydrology , 6
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 7
A. Source Remedy (Operable Unit) 7
B. Groundwater Investigation Conducted by Agencies . 7
C. RI/FS Performed by McColl Site Group (MSG) under US EPA Order . 9
III. HIGHLIGHTS OF COMMUNITY INVOLVEMENT 10
IV. SCOPE AND ROLE OF THE RESPONSE ACTION 10
V. SUMMARY OF SITE CHARACTERISTICS (GROUNDWATER) 11
A. Groundwater 11
Organics (not including THT compounds) 12
Tetrahvdrothiophene (THT) Compounds 12
Inorganic Compounds 12
B. Data Validation 13
VI. SUMMARY OF SITE RISKS 13
Selection of Chemicals of Potential Concern 13
Toxicitv Assessment 15
Exposure Assessment 16
Risk Characterization 17
Uncertainty 19
Conclusions 19
VII. DESCRIPTION OF ALTERNATIVES 19
A. Alternative #1 20
B. Alternative #2 20
C. Alternative #3 20
D. Alternative #4 21
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 21
A. Protection of Human Health and The Environment 21
B. Compliance With ARARS 21
C. Long-Term Effectiveness and Permanence 22
TOC-i
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D. Reduction of Toxicity, Mobility, or Volume Through Treatment .... 22
E. Short-Term Effectiveness 22
F, Implementability 23
G. Cost 23
H. State Acceptance 23
I. Community Acceptance 24
IX. SELECTED REMEDY 24
X. STATUTORY DETERMINATIONS 25
A. Protection of Public and the Environment 25
B. Attainment of ARARS 25
C. Cost-Effectiveness 25
D. Use of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent
Practicable 25
E. Preference for Treatment as a Principal Element 26
F. Documentation of Significant Changes 26
LIST OF FIGURES
FIGURE 1 SITE LOCATION MAP 4
FIGURE 2 MCCOLL SITE 5
FIGURE 3 CAP AND SLURRY WALL FOR SOURCE OPERABLE UNIT REMEDY 8
ATTACHMENT A
ATTACHMENT B
ATTACHMENT C
LIST OF ATTACHMENTS
ADMINISTRATIVE RECORD INDEX
PUBLIC MEETING COMMENTS
RESPONSIVENESS SUMMARY
TOC-ii
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LIST OF ACRONYMS
ARARs
CERCLA
COPC
CSF
DCA
DISC
E&E
EPA
EPCs
FS
GAC
HEAST
HI
IAC
MCLs
MCLGs
MDLs
MSG
NCP
NPL
O&M
OTC
ppb
PRG
RAO
RCRA
RfDs
Rl
RME
ROD
SARA
SVOCs
THTs
VOCs
Applicable or relevant and appropriate requirements
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980
Chemicals of potential concern
Cancer slope factors
Dichloroethane
Department of Toxic Substances Control
Ecology and Environment
Environmental Protection Agency
Exposure point concentrations
Feasibility Study
granular activated carbon
Health Effects Assessment Summary Tables
Hazard index
Interagency Committee
Maximum Contaminant Levels
Maximum Contaminant Level Goals
Method detection limits
micrograms per liter
McColl Site Group
National Oil and Hazardous Substances Pollution Contingency Plan
National Priorities List
Operation and maintenance
Odor threshold concentration
Parts per billion
Preliminary remediation goal
Remedial Action Objective
Resource Conservation and Recovery Act
Reference doses
Remedial Investigation
Reasonable maximum exposure
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
Semi-volatile organic compounds
Tetrahydrothiophene compounds
Volatile organic compounds
TOC-iii
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DECLARATION FOR THE GROUNDWATER OPERABLE UNIT
RECORD OF DECISION
SITE NAME AND LOCATION
McColl Site
2650 Rosecrans Avenue
'Fullerton, CA 92633
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the groundwater operable unit remedial action selected
for the McColl Site in the City of Fullerton, County of Orange, California. This remedial action
was chosen in accordance with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) (42 CFR § 9601 etseq.). and, to the extent practicable, with
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR § 300 et
seq.). The attached Administrative Record Index (Attachment A) identifies the documents upon
which the decision is based. The State of California has commented in support of the selected
remedy,
ASSESSMENT OF THE SITE
If the actual or threatened releases of hazardous substances from the Site are not addressed by
implementing the remedial response action selected in this ROD, the Site may present an
imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
EPA has selected Alternative #3 as presented in the Feasibility Study Report, Groundwater
Operable Unit, McColl Superfund Site (EPA, February 1996) as the groundwater operable unit
remedy for the McColl Site. The remedial action for groundwater is designed to work in
conjunction with the remedial action for the McColl waste sumps, which includes capping of the
sumps and construction of subsurface slurry walls around the sumps. The waste sump remedy
will significantly reduce infiltration of site surface water and precipitation, thus reducing the
potential for the sumps to impact groundwater in the future. The selected remedy for the
contaminated groundwater operable unit for the McColl Site includes evaluation, design, and
construction of infiltration controls to significantly (order of magnitude) reduce surface water
infiltration from baseline estimates. These engineered controls will be implemented outside of
the waste sump area. Measures/controls for consideration during design may include some or
all of the following:
• Onsite management of surface water running onto the site property.
• Lining existing major drainage channels with low permeability materials.
• Grading or modifying (through placement of low permeability soils) areas
adjacent to, but outside of the planned closure containment system.
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• Groundwater monitoring (including additional wells) to demonstrate that
the infiltration controls are effectively preventing further migration of site
contaminants to and throughout the regional aquifer.
• EPA or the relevant State agency will implement offsite institutional controls
as a contingency measure. If at the five year review the regional aquifer
beyond the current site boundary is found (in more than one offsite well)
to contain site-specific contaminants above State or Federal Maximum
'Contaminant Levels (MCLs)1 or above the recommended (3.6 parts per
billion (ppb)) or revised preliminary remediation goal (PRG) for
tetrahydrothiophene (THT) compounds, offsite institutional controls will be
implemented.
• Site maintenance and security until final operation and maintenance (O&M)
plans take effect under the source operable unit remedy.
The groundwater remedy is intended to work in conjunction with the source remedy, and
together will achieve the anticipated goal of protection of groundwater resources.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment as required by section
121 of CERCLA. The selected remedial action, when complete, shall comply with applicable or
relevant and appropriate environmental standards established under Federal and State
environmental laws. The selected remedy is cost-effective and considered permanent treatment
technologies to the maximum extent practicable. Because the source operable unit remedy2
will result in hazardous substances remaining onsite above health-based levels, a review will be
conducted within five years after commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment.
DECISION SUMMARY
This Decision Summary provides an overview of the problems posed by the McColl Site
groundwater operable unit. It also includes a description of the remedial alternatives considered
and the analysis of these alternatives against the criteria set forth in the NCR. The Decision
Summary explains the rationale for the remedy selection and how the selected remedy satisfies
the statutory requirements of CERCLA.
1 If both a Federal and a State of California MCL exist for a particular compound, the lower of the two MCLs is applied.
2 The June 1993 Record of Decision presents the source operable unit remedial action, which consists of a
closure/containment system remedy for the twelve waste sumps.
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I. SITE LOCATION AND DESCRIPTION
A. Site Name and Location
McColl Superfund Site
2650 Rosecrans Avenue
Fullerton, California 92633
B. Site Description
The McColl Superfund Site (the "Site") is located in Orange County, California on the northwest
edge of the City of Fullerton closely bordering the City of Buena Park (Figure 1). The 22 acre
Site was the location of 12 disposal pits operated by Eli McColl from 1942 to 1946 (Figure 2).
During the operation of the disposal pits various oil refining companies disposed of refinery
waste, predominantly spent sulfuric acid catalyst.
The predominant type of waste at the site is a hard black (asphaltic) waste with smaller volumes
of viscous waste, contaminated drilling mud, and soils. The hard and viscous waste is
characterized as having a low pH, high sulfur content, high concentrations of organic sulfur
compounds, aromatic hydrocarbons and aliphatic hydrocarbons.
The Los Coyotes Country Club Golf Course was built in 1956/1957, with a portion of the course
overlying the covered waste sump area referred to as the Los Coyotes area. That portion of the
golf course is currently closed. The McAuley LCX Corporation purchased the Los Coyotes
Country Club in December 1980. The Ramparts area of the site was never developed. A
housing tract borders the site immediately to the east and southeast. The Ralph B. Clark
Regional (County) Park is adjacent to the west of the site boundary. The southern boundary of
the site is the Los Coyotes golf course. The northern boundary is Rosecrans Avenue. All of the
sumps are currently covered by overburden of varying thickness.
C. Land and Water Use
Use around the site is predominantly residential with some developed and undeveloped open
space. The residential use throughout the area is single family homes on approximately quarter
acre lots. The residences are valued in the $200,000 to $300,000 range. Site demographics are
dominated by older European-American professionals with families or retirees. There has been
an increase of Asian professionals (predominantly Korean) with young families throughout the
late 1980s and 1990s.
Surface water flows from the upper reaches of the hills across the site from north to south. The
largest of these drainage areas runs from the West Coyote Hills area to the north, into a drainage
channel under Rosecrans and onto the site. Once onsite, this channel drains to the low-lying
area to the north and west of the Los Coyotes waste pit area. Surface water from the Ramparts
portion of the site and the eastern side of the Los Coyotes waste pits drains into a channel at
the boundary of the southeastern portion of site and then into the regional surface water
collection system.
Groundwater near the site is not currently used for public water supply. The nearest municipal
well (Coyote Well 12A) is located at the corner of Gilbert and Pioneer, 3,000 feet crossgradient
from the site.
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Figure I: Site Location Map
Pioneer
FULLERTON
CALIFORNIA
LOS ANGELES
J96-024.ed Me 4 7
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Figure 2:
McColl Site Map Showing Locations of Monitoring Wells
v./ '•
*>: * Los Coyotes
& / Sumps
LEGEND
Perched Monitor Wells
• Regional Monitor Wells
- Site Boundary
J96-024.ed Me 4 3
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D. Regional Topography
As described in the Final Remedial Investigation Report, Groundwater Operable Unit, McColl Site
(ENVIRON, December 1995), the site is located on the lower portion of the south side of the east-
west trending West Coyote Hills at a median elevation of approximately 300 feet above mean sea
level.
E. Hydrology
The regional hydrology consists of the near-surface sediment of the Pleistocene La Habra
Formation. Beneath the relatively fine-grained La Habra Formation sediments are the coarser
sandy gravels and gravelly sands of the Coyote Hills Formation. The sedimentary units dip
approximately 10 degrees to the southwest.
Groundwater beneath the site is found in multiple shallow perched units and in the regional
aquifer approximately 160 to 200 feet below the Site ground surface. The shallow perched units
have been designated during the Remedial Investigation alphabetically from the shallowest to the
deepest.
The shallowest perched groundwater unit is the "A" unit. The lower permeability layer of natural
soils which underlies the "A11 unit surfaces onsite in the vicinity of the Los Coyotes portion of the
site. The "A" unit does not directly intersect with the regional aquifer near the site. The "A" unit
is monitored by the following monitoring wells: P-2S and P-3S.
The "B" unit originates in the central portion of the site. The surface of the "B11 unit low
permeability layer is approximately 50 feet below the bottom of the Los Coyotes Sumps. The "B"
unit is perched to the north of the southern McColl site boundary. Approximately five hundred
feet south of the site, the "B" clay packet dips to the saturated interval of the "C" flow unit. The
"B" unit is monitored by the following wells: P-21, P-41, P-5S, P-51, P-6S, and P-10D.
The "C" unit originates in the upper (northern or upland) portions of the site. The surface of the
"C" unit low permeability layer lies approximately 50 feet below the bottom of the Ramparts
sumps/pits and 150 feet below the Los Coyotes portion of the site. Because of the
characteristics of the subsurface conditions, the "C11 zone is perched in the northern portion of
the Site and is part of the regional aquifer in the southern portion of the site and to the south of
the site. The "C" unit has been found to intersect the regional aquifer in the vicinity of well
P-2D(R), at the southern site boundary. The wells that monitor the perched portion of the "C" unit
are: W-6A and W-8A. The wells that monitor the "C" portion of the regional aquifer are: P-2D(R),
P-3D, P-4D, P-5L, P-6D, P-9D, and P-10L
A deeper "D" unit lies largely within the regional aquifer beneath the site. The "D" unit is
monitored by the following wells: W-4, W-8B, W-9B, W-9C, W-10B, P-1D, and P-5D.
The gradient of the regional aquifer ("D" flow unit) is estimated to be approximately 0.0077
feet/feet beneath the McColl Site. Groundwater within the "A", "B", and "C11 flow units is
seasonally recharged by surface infiltration at or near the site and along buried coarse-grained
sediments of current or historical drainage swales along the western and eastern boundaries of
the site.
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Two municipal production wells were identified within seven thousand feet of the site during the
Remedial Investigation (ENVIRON, December 1995). The closer of the two is the Coyote 12A
Well. The "D" flow unit may have some equivalency to the shallowest screened interval of the
Coyote 12A well However, the Coyote 12A well is located three thousand feet cross-gradient
to the site (ENVIRON, December 1995),
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Source Remedy (Operable Unit)
The McColl Site was added to the Superfund National Priorities List (NPL) in 1982.
Historically the source operable unit has been the subject of multiple investigations, pilot tests,
and proposed remedies. A complete description of these can be found in the June 1993 ROD
(US EPA) and the Final Full Scale Demonstration Test Report (US EPA, with contributions from
ICF, Morrison Knudson, June 1995).
The McColl Site waste sumps are currently managed under the contingency remedy outlined in
the June 1993 ROD. The remedy for the waste sumps is a Resource Conservation and Recovery
Act (RCRA) equivalent cap(s) with subsurface barriers and monitoring. The current design
includes a closure system consisting of two RCRA equivalent caps and slurry walls (Figure 3).
The slurry walls are planned to extend a minimum of 3 feet below the bottom of the deepest
sump and to completely surround the waste. The design of this final remedy is scheduled for
completion in December 1996.
B. Groundwater Investigation Conducted by Agencies
The following information is a brief summary of the historical groundwater investigations that have
been conducted at the McColl Site.
Groundwater sampling/testing and investigations have been conducted at the McColl Site by
various contractors to the State of California and EPA since 1981. More recently, the McColl Site
Group (MSG) tasked ENVIRON to perform a Remedial Investigation/Feasibility Study (RI/FS).
Beginning in 1981, the California Department of Health Services (DOHS), now the California
Department of Toxic Substances Control (DTSC), started the first investigation of groundwater
with the installation of one monitoring well (Well A-13). A groundwater sample collected from
monitoring well A-13 in 1981 was found to contain sulfate, arsenic, t-butanol, and exhibited a pH
of 2.8 (CH2M Hill, 1987). From 1981 to the start of the MSG RI/FS, a total of 22 monitoring wells
were installed at and near the McColl Site to investigate the nature and extent of groundwater
contamination. Five wells were screened at depths of less than 110 feet below ground surface
(bgs), and seventeen wells were screened at depths ranging from 216 to 320 feet bgs.
Subsequently, seven of these wells were abandoned. The table below presents a history of the
well installation/abandonment program that was completed at the McColl Site prior to
commencement of the MSG RI/FS.
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Figure 3:
Cap and Slurry Wall for Source Operable Unit Remedy
Subsurface Barrier Wall
Note: Shaded area represents
extent of cap
J96-024MC2 6
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WELL INSTALLATIONS AND ABANDONMENTS PRIOR TO MSG RI/FS
McCOLL SITE
Installer
DISC, Caltrans,
ARB, SCAQMD
DOHS
Radian
DISC
CH2M Hill
Ecology and
Environment
Date
1981
1981
1982
1983/1984
1987
June 1989
Scope
In Ramparts area, 12 boreholes were drilled, including
six in sumps, five in adjacent soils, and one in
background. Analyses were for pH, sulfates, and
heavy metals.
In Ramparts area, monitoring well A-1 3 was installed
and a groundwater sample was collected. Analyses
were for pH, sulfate and organic compounds.
Three deep wells (depths of 232 to 273 feet) were
installed. Well W-2 was located north of Ramparts
area. Wells W-1 and W-3 were located south and
southeast of the Los Coyotes areas. Wells W-1 and
W-2 were later abandoned in 1 991 . The well head of
well W-3 was covered during repaving of its street
location.
Four deep monitoring wells (W-4, W-5, W-6B, and
W-8B) and two shallow wells 9W-6A and W-8A) were
installed. Wells were first sampled in 1987. Wells W-5
and W-6B has since been abandoned.
Six deep monitoring wells (P-1D through P-6D), and
three shallow wells (P-3S, P-5S, and P-6S) were
installed during an expanded groundwater
assessment. Wells were sampled for organic and
inorganic parameters. Well P-2D was replaced by
Well P-2D(R) because Well P-2D had been damaged
during installation.
Three deep upgradient wells (W-9B, W-9C, and
W-1 OB) were installed.
Between June 1989 and December 1992, EPA performed routine groundwater quality monitoring.
All sampling and testing of groundwater under this program followed a detailed sampling and
analysis plan and data validation was performed.
C. RI/FS Performed by McColl Site Group (MSG) under US EPA Order
As a part of the EPA order issued to the four oil companies in August of 1993, EPA directed the
oil companies, now called MSG, to complete the RI/FS for groundwater. The investigation
supplemented the data from the existing 14 wells installed by EPA and the State. The
investigation was conducted in two phases. At the completion of phase II of the investigation,
MSG had installed nine additional wells. Following evaluation of the phase II results, EPA and
MSG agreed that one additional well would be required. The RI/FS included four rounds of
groundwater sampling and analysis and aquifer testing. A baseline risk assessment was
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performed by ICF, contractor to EPA. MSG submitted the Draft Remedial Investigation Report
to EPA on October 13, 1995. The Final Remedial Investigation Report was submitted on
December 29,1995. The Draft Feasibility Study Report was submitted on December 5,1995. The
Final Feasibility Study Report was revised by EPA based on the original draft and issued on
February 7, 1996.
III. HIGHLIGHTS OF COMMUNITY INVOLVEMENT
The public participation requirements of Sections 113(k)(2)(B)(i-v) and 117 of CERCLA have been
satisfied in the remedy selection process.
While the community has historically had very strong, organized, and vocal opinions regarding
the remedy selection process on the source operable unit, there has been less interest regarding
groundwater as there are not any municipal or private wells impacted and results have generally
indicated minimal impact on the regional aquifer. EPA has continued to provide fact sheets
(10+) as updates on new groundwater information and to make itself available to answer
questions regarding groundwater.
EPA has also regularly met with the local regulatory agencies and provided them with information
on the groundwater investigation and proposed plan through the McColl Site Interagency
Committee (IAC). The IAC consists of State regulatory, local regulatory, political, and community
representatives. The IAC meetings have been held on a monthly or bimonthly basis since the
1980s.
Consistent with requirements of CERCLA and the NCP, EPA has conducted the following
community relations activities. Recently, EPA issued the August 1995 Fact Sheet to summarize
the results of the Remedial Investigation. In February 1996, EPA issued a Proposed Plan Fact
Sheet. An announcement of the proposed plan, public comment period, date, and location of
the public meeting was printed in the Orange County Register on February 25,1996. EPA issued
a press release on the first day of the public comment period (March 6,1996). EPA briefed the
IAC on the proposed plan on the day of the public meeting. On March 14, 1996, a public
meeting was held at Parks Junior High School and was attended by approximately 10 community
members, representatives of the State agencies, local agencies, McAuley LCX representatives,
and MSG representatives. All of the community represented at the meeting that chose to publicly
comment were in favor of the proposed plan.
Responses to local community comments made at the public meeting are presented in
Attachment B. Details of the community involvement activities and responses to public
comments received from the State and MSG are presented in the Responsiveness Summary
(Attachment C).
IV. SCOPE AND ROLE OF THE RESPONSE ACTION
The planned construction of the closure and containment system over the source waste sumps
should serve to reduce long-term contamination of shallow or deeper groundwater at the site.
However, based on the results of the EPA Baseline Risk Assessment for the McColl Superfund
Site Groundwater Operable Unit (ICF, November 1995), residual contamination in the shallow
groundwater exceeds Federal and California standards for drinking water and may present an
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imminent and substantial endangerment to human health if not addressed. The appropriate
response for the shallow water takes into account the important fact that perched groundwater
is not present in sufficient volume to serve as an exclusive source of future water supply.
V. SUMMARY OF SITE CHARACTERISTICS (GROUNDWATER)
In August of 1993, EPA ordered the McColl Site Group to complete the Rl and to perform the
Feasibility Study. As>part of the completion of the Rl, MSG installed ten new monitoring wells.
These new wells, along with the previously installed wells, totalled 24 monitoring wells. The
results of three quarters of sampling performed during the MSG Rl were used for the Baseline
Risk Assessment for the Groundwater Operable Unit. No known natural resource concerns exist
for the site groundwater. As a result, an ecological assessment was not performed.
A.
Groundwater
Initial (phase I) efforts of the MSG Rl focused on the characterization of perched groundwater.
Unfortunately, the cone penetrometer technology that was used did not reach the depth required
to characterize deeper perched zones. Data were, however, collected from perched wells that
had been installed and locations for new monitoring wells were selected based on these results
along with the limited cone penetrometer data. The results for the groundwater monitoring are
summarized in the following sections. Groundwater investigation results indicate that while
contaminants from the waste sumps are present in perched water, they do not appear to result
in contamination of the regional groundwater. A comprehensive list of the compounds of
potential concern as presented and evaluated in the baseline risk assessment for the
groundwater operable unit is presented below:
THIOPHENES
Tetrahydrothiophene
2-methyltetrahydrothiophene
3-methyltetrahydrothlophene
VOCs
Acetone
Benzene
2-butanone
Carbon Disulfide
Chloroform
1,2-dichloroethane
Ethylbenzene
2-hexanone
Methylene Chloride
Toluene
Xylenes (total)
SVOCs
Bis(2-ethylhexyl)phthalate
Butylbenzylphthalate
Dimethylphthalate
Di-n-butylphthalate
Isophorone
2-Methylphenol
Nitrobenzene
Phenol
Pyrene
INORGANICS
Aluminum
Arsenic
Barium
Beryllium3
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Thallium
Vanadium
Zinc
VOCs = Volatile Organic Compounds
SVOCs = Semi-volatile Organic Compounds
Although beryllium was not Identified in waste and sump samples (CH2M Hill, 1987), beryllium was selected as a
COPC for the risk assessment because it was positively detected in at least one groundwater sample. The existence of
beryllium in groundwater may be associated with the leachability of chemicals in vadose zone soils due to the low pH
in groundwater.
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Organics (not including THT compounds)
The two VOCs detected above MCLs in the groundwater system are benzene and, at low
concentrations, 1,2-dichloroethane (1,2-DCA). Semi-volatile organic compounds were not
consistently detected in the groundwater or were determined to be laboratory contaminants.
Benzene concentrations have equaled or exceeded (up to 470 ppb) the State MCL of 1 ppb in
the "B" flow unit. Benzene in the perched "C" well W-6A ranged from 500 to 800 ppb. 1,2-DCA
concentrations exceeded the State MCL of 0.5 ppb in one "B" flow unit well (P-5I) and one "C"
flow unit well (P-5L) and the results were as low as 1 and 2 ppb.
Tetrahvdrothiophene (THT) Compounds
THT compounds, including tetrahydrothiophene, 2-methyltetrahydrothiophene, 3-
methyltetrahydrothiophene, were detected in several monitoring wells during the sampling
program. THT compounds have a very low odor threshold (50 percent of the population can
detect at 0.6 ppb) and readily degrade water to less than aesthetically acceptable conditions.
THT compounds have been detected regularly in the perched "A", "BV'C11 and the regional "C"
units. THT compounds have not been detected in the "D" unit; however, additional monitoring
will be required to confirm the absence of THTs in the "D" unit southwest (downgradient) of the
site.
Concentrations of THT compounds in the perched units have ranged as high as 43,000 ppb
(W-6A). Approximately five hundred feet downgradient of the Los Coyotes sump area, THT
compounds are detected in portions of the "B" and "C" flow units (Wells P-1 OD and P-1 OL at
1,490 and 190 ppb, respectively). It is suspected that the rate of migration is limited by the
seasonal saturation and natural attenuation in the perched units. This migration of site
contaminants (THTs) from the perched to the regional aquifer indicates a possible pathway exists
for other organics found in the perched units. However, it is also important to point out that there
are regional "C" wells downgradient of the site and sump areas that have no detected THT
compounds, such as Well P-9D.
Inorganic Compounds
Concentrations of inorganics in the onsite perched groundwater exceed background
concentrations calculated for the regional aquifer. However, it is important to note that the
source waste in the waste pits at the McColl Site does not contain elevated inorganics (with the
exception of sulfur dioxide). The waste is acidic and as liquid (water) comes into contact with
the waste, the water also becomes acidic. The presence of these higher concentrations of
inorganics in perched groundwater samples may be attributed to the preferential teachability of
inorganics in the vadose zone soils from contact with acidic perched water.
Four inorganic compounds occur above background concentrations or state MCLs: arsenic,
beryllium, chromium, and manganese. Arsenic is ubiquitous at low concentrations in
groundwater at the site. Evaluation of "D" flow unit background wells indicate a background
concentration of 9.7 ppb. The State and Federal MCL is 50 ppb and has been slightly exceeded
in perched well P-2I. The higher concentrations of arsenic occur in wells with low pH and
concentrations significantly decrease off-site once the pH rises to natural levels downgradient of
the site.
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Background "D" flow unit wells indicate a concentration for beryllium of 8,3 ppb. This
background concentration exceeds the State MCL of 4 ppb for beryllium. Dissolved beryllium
was detected above the state MCL in three on-site wells (P-21, P-41, W-6A) of the twenty-four
wells. Beryllium concentrations exceeding the State MCL ranged from 5.7 to 90 ppb.
The "D" flow unit background wells indicate a background concentration for chromium of 3.2 ppb.
Dissolved chromium was detected above the State MCL of 50 ppb in perched wells P-41 and W-
6A. Chromium concentrations in these wells ranged from 67.8 to 424 ppb, and the water in these
wells had a low pH.
Manganese was measured at a background concentration of 4,300 ppb. Manganese has been
found to occur at concentration as high as 30,100 to 41,700 ppb in perched wells with low pH.
Concentrations of manganese are closer to background in wells in the regional aquifer. There
is no MCL for manganese. However, the Federal secondary drinking water standard for
manganese is 50 ppb.
B. Data Validation
Data validation of analytical results was performed in accordance with procedures outlined in the
Quality Assurance Project Plan prepared by ENVIRON for MSG.
VI. SUMMARY OF SITE RISKS
The Baseline Risk Assessment for the Groundwater Operable Unit was completed in November
1995 by an EPA contractor (ICF). The purpose of the Risk Assessment was to evaluate the
public health and environmental risks posed by contaminants detected in groundwater at the site.
The wells screened in both the perched and regional aquifer were evaluated in the Risk
Assessment. A separate baseline public health evaluation for the source/soil waste sumps was
performed in May 1992 (ICF).
The Baseline Risk Assessment for the Groundwater Operable Unit and this ROD recognize that
the perched portion of each individual flow zone would not yield sufficient volume of water for
potential exposures. This ROD also recognizes that the perched zones are of potential concern
because it has been demonstrated by the presence of THT compounds in the regional aquifer
wells that contaminants found in shallower zones can migrate into the regional aquifer.
The following sections on risk assessment are presented in the Executive Summary of the
Baseline Risk Assessment for the Groundwater Operable Unit (ICF, November 1995):
Selection of Chemicals of Potential Concern
Groundwater data obtained from the three most recent quarterly groundwater sampling events
were identified as the most appropriate database to evaluate current site conditions. The
sampling events occurred in September 1994, January 1995, and April 1995 (ENVIRON, 1995a,
1995b, and 1995c).
A screening analysis was conducted to determine the areas of groundwater within each zone that
may have the highest concentrations of chemicals. It was assumed that a well(s) in each flow
unit represents the center of any potential plume migrating from the Site. The manner in which
the wells were selected to represent chemical concentrations in each flow unit is designed to be
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conservative, by selecting narrow areas in which the highest concentrations are observed. The
analysis consisted of comparing the maximum chemical concentrations in each individual well
with the most conservative chemical-specific Federal or California MCL4 and a chemical-specific
tap water PRG, as summarized by EPA Region IX (EPA, 1995a). Individual wells or a group of
wells was selected based on the frequency of detection of chemicals, the toxicity of the
chemicals detected, and the ratios of the maximum chemical concentration to the MCLs and tap
water PRGs.
Individual wells were selected to represent groundwater in the "A" and "D" flow units, and
groundwater in the perched and regional "C" flow units. Two separate wells were selected to
represent the "B" flow unit primarily because of different chemical constituents. The wells
selected as a result of this screening evaluation are presented below.
AQUIFER
perched
perched
perched
regional
regional
FLOW UNIT ZONE
A
B
C
C
D
WELL
P-3S
P-2I & P-6S
W-6A
P-5L
W-4
Chemicals of potential concern (COPCs) were selected if organic and inorganic chemicals were
detected in at least one sample above their respective method detection limits (MDLs). Detected
chemicals (from the wells identified based on the results of the screening analysis) were selected
to represent the chemicals that are attributable to the Site and that are of greatest concern from
a health risk standpoint (i.e., the COPCs). Of the inorganics, iron, magnesium, potassium, and
sodium were eliminated as COPCs because they are considered essential nutrients. Inorganic
chemicals that are present at naturally occurring levels may also be eliminated from the risk
assessment. Groundwater data collected from three off-site upgradient wells were used to
represent background. However, given that these wells are screened in the "D" flow unit of the
regional aquifer, a comparison can only be made for groundwater data that were also collected
from wells screened in the "D" flow unit (i.e., well W-4). Based on an analysis of groundwater
data, it is unclear whether the inorganics detected in the "D" flow unit are natural or
anthropogenic in origin. Consequently, with the exception of the essential nutrients, inorganics
detected in at least one sample above the MDL from well W-4 were selected as COPCs. A
comprehensive list of COPCs evaluated in this risk assessment is presented below.
If both a Federal and a California MCL exist for a particular compound, the lower of the two MCLs was used in the
screening analysis. For instance, benzene has a Federal and a California MCL of 5 and 1 /ig/L, respectively. In this
scenario, the California MCL was used in the screening evaluation.
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THIOPHENES
Tetrahydrothiophene
2-methyrtetrahydrothiophene
3-methyltetrahydrothiophene
VOCs
Acetone
Benzene
2-butanone
Carbon Disulfide
Chloroform
1 ,2-dichloroethane
Ethylbenzene
2-hexanone
Methylene Chloride
Toluene
Xylenes (total)
SVOCs
Bis(2-ethylhexyl)phthalate
Butylbenzylphthalate
Dimethylphthalate
Di-n-butylphthalate
Isophorone
2-Methylphenol
Nitrobenzene
Phenol
Pyrene
INORGANICS
Aluminum
Arsenic
Barium
Beryllium5
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Thallium
Vanadium
Zinc
vuus = Volatile Organic Compounds
SVOCs = Semi-volatile Organic Compounds
Toxicity Assessment
For each of the COPCs identified for this risk assessment, relevant toxicity criteria were identified
from EPA's Integrated Risk Information System (IRIS) database (EPA, 1995b). When not available
on IRIS, the Health Effects Assessment Summary Tables (HEAST) (EPA, 1994) and EPA's
Region IX Preliminary Remediation Goals (PRGs) (EPA 1995a) were consulted. If no values could
be identified from either source, the chemical was not evaluated quantitatively. COPCs that lack
agency-derived toxicity criteria include the thiophene-based compounds. In addition, there are
no available toxicity values for evaluating dermal (uptake) exposures. For this risk assessment,
oral cancer slope factors (CSFs) and reference doses (RfDs) were used to evaluate dermal
exposures.
Regulatory toxicity criteria that have been developed by Cal/EPA were also used and separately
evaluated in this risk assessment. When Cal/EPA toxicity values were not available, EPA values
were used. Cal/EPA has not derived RfDs or RfCs, and therefore an evaluation of potential risks
was only conducted for chemicals that are classified as carcinogens.
Of the chemicals identified as being COPCs at the McColl Site, 11 are considered to be known
or suspected human carcinogens. Two chemicals are known human carcinogens based on
sufficient evidence in human studies (Group A). One chemical is considered to be a probable
human carcinogen based on limited evidence in human studies (Group B1). Eight chemicals are
considered probable human carcinogens based on sufficient evidence in animal studies
(Group B2). A list of carcinogenic COPCs is summarized below.
Although beryllium was not identified in waste and sump samples (CH2M Hill, 1987), beryllium was selected as a
COPC for this risk assessment because it was positively detected in at least one groundwater sample. The existence of
beryllium in groundwater may be associated with the teachability of chemicals in vadose zone soils due to the low pH
in groundwater.
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Group A
Arsenic
Benzene
Group B1
Cadmium
Group B2
Beryllium
Bis(2-ethylhexyl)phthalate
Butylbenzylphthalate
Chloroform
1,2-DCA
Isophorone
Methylene Chloride
Lead
Exposure Assessment
The McColl Site is located in an area zoned for single family residences. Residential homes are
located adjacent to the Site on the east and south boundaries with the nearest home located
approximately 200 feet from the sumps. It is assumed that no future residential development will
occur on the McColl Site sumps and that the surrounding areas are likely to continue to support
residential homes. Based on the current and expected future uses of the McColl Site, residential
adults and children living in the vicinity of the Site represent potential exposed populations.
Groundwater is not currently used as a source of potable water within the McColl Site. Water
for adjacent communities is supplied by the local water district through a municipal distribution
system. No shallow domestic wells are known to exist in the vicinity of the Site and irrigation
water is supplied by the City of Buena Park. Therefore, no complete exposure pathways for
chemicals in groundwater exist under current land use scenarios. However, potential future uses
of the surrounding areas may result in the development and use of private and municipal water
supply wells,
Based on an evaluation of current and future conditions at the McColl Site, the following
exposure pathways were identified and evaluated for this risk assessment:
• incidental ingestion and dermal absorption of chemicals in groundwater; and
• inhalation of chemicals released from groundwater during domestic uses.
To quantify human health risks, exposure point concentrations (EPCs) of the chemicals in
groundwater appropriate to each specific exposure pathway at each appropriate receptor
location were developed. Potential exposures to groundwater were estimated based on
chemicals already existing in groundwater, as observed in the selected set of onsite wells. No
groundwater transport or contaminant leaching modeling was performed for this risk assessment.
Furthermore, it was assumed that the chemical concentrations are unlikely to increase or
decrease in the future. Concentrations of volatile chemicals in air released from potable water
were conservatively estimated using EPA's default volatilization constant (0.5 mg/m3/mg/L)
(EPA, 1991b).
Average concentrations from the three groundwater sampling rounds were used to represent the
EPCs from the wells identified from the screening analysis. EPCs representing background were
developed based on the arithmetic average of data collected from three off-site wells over three
quarters. Potential risks were evaluated based on doses that were estimated both for a
reasonable maximum exposure (RME) estimate and a more probable estimate of exposure.
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Risk Characterization
EPA has established an acceptable range of risk (1 x 10~6 to 1 x 10"4 excess cancer risks) for
known or suspected carcinogens at Superfund sites. If the calculated risks exceed 1 x 10"4
excess cancer risks, then remediation is usually required. For noncarcinogenic effects, a hazard
index (HI) in excess of 1 generally indicates an unacceptable condition requiring remediation
(EPA, 1992b).
The results of the risk assessment indicate that with the exception of the RME exposures for well
W-4 (flow unit D), the carcinogenic risks associated with the regional aquifer are below or within
the acceptable range of 1 x 10"6 and 1 x 10"4. The average and RME risks for well P-5L (flow unit
C) are below 1 x 10"6. The RME cancer risks associated with well W-4 are 3 x 10"4 and 1 x 10"4
for adults and children, respectively, and are slightly above the target risk of 1 x 10"4. Arsenic
is the primary chemical contributor to the overall risks. However, the concentrations of arsenic
observed in well W-4 are below the MCL
The potential risks associated with chemicals detected in background wells were also estimated.
As indicated above, the only available site-specific background data are for the D flow zone.
Under an average exposure scenario, the total background risks are below or within the
acceptable range of 1 x 10"6 and 1 x 10"4, On the other hand, the estimated RME cancer risks
attributed to chemicals detected in background wells are 2 x 10"4 and 1 x 10"4 for adults and
children, respectively, and are primarily associated with the ingestion of beryllium. Although the
RME risks are slightly above the target risk range, the RME background risks are comparable to
the estimated risks associated with regional well W-4. A summary of the total carcinogenic risks
associated with the selected wells screened in the regional aquifer, including background wells,
is provided below. The estimated risks using Cal/EPA CSFs are presented in parentheses.
SUMMARY OF TOTAL CARCINOGENIC RISKS (REGIONAL AQUIFER)
Flow Unit (Well)
C (P-5L)
D (W-4)
D (background wells)
Average Risk
Adult
2X10"7 (2x1(T7)
5 X 10"5 (5 x 10"5)
4X 10'5 (5x 10'5)
RME Risk
Adult
7X1CT7 (1 xKT6)
2X1(r4(3x1(r4)
2X 10"4 (2x 10"4)
Average Risk
Child
2 X 10'7 (3 x 10'7)
8X10"5(8x10'5)
7 X 10"5 (8 x 10"5)
RME Risk
Child
3 X 10"7 (5 x 10'7)
1 X 10"4 (1 x 1CT4)
1 X 10-4 (1 x 1CT4)
The lowest and highest estimated risk values for individual wells screened in the perched flow
zones are 6 x 10 and 4 x 10"3. The lowest risk is associated with chemicals detected in well
P-3S (flow zone A) for adult receptors under an average exposure scenario. The highest
estimated risk corresponds to chemicals detected in well W-6A (flow unit C) for child receptors
under an RME exposure scenario. The primary exposure pathway contributing to the overall
risks is from ingestion of groundwater. Arsenic in well P-3S and beryllium in well W-6A are the
primary chemicals responsible for the majority of the risks.
The potential noncarcinogenic effects associated with the exposure pathways evaluated above
were combined in the same manner as was done for the carcinogenic effects to yield total
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Site His. Of the three potentially complete exposure pathways evaluated, ingestion of
groundwater contributes most to overall noncarcinogenic health effects.
The noncarcinogenic His associated with regional well P-5L are below the target HI level of 1.
Conversely, the noncarcinogenic His associated with regional well W-4 are slightly above the
target HI level and are primarily associated with arsenic. However, as stated above, the
concentrations of arsenic observed in well W-4 are below the MCL The His associated with
background wells are slightly above the target level and are primarily attributed to manganese.
A summary of the cumulative noncarcinogenic His is provided below.
SUMMARY OF TOTAL NONCARCINOGENIC HAZARD INDEX (REGIONAL AQUIFER)
Flow Unit (Well)
C (P-5L)
D (W-4)
D (background wells)
Average HI
Adult
0.3
1
0.9
RMEHI
Adult
0.4
2
1
Average HI
Child
0.6
3
2
RME HI
Child
0.9
4
3
The lowest and highest noncarcinogenic His associated with wells screened in the shallow zones
are 0.4 (P-3S) and 300 (W-6A). Analogous to the carcinogenic risks, the lowest and highest His
correspond to adult receptors for an average exposure scenario and to children under a RME
exposure scenario, respectively. The ingestion of manganese is the primary chemical and
exposure pathway contributing to the overall total HI from well W-6A.
Incremental risks may be estimated by subtracting background carcinogenic risks and
noncarcinogenic His from the total carcinogenic and noncarcinogenic chemical- and pathways-
specific risks. If the incremental risks exceed the target risk ranges, it is possible that these risks
are associated with site-related activities rather than ambient conditions. In the case of arsenic,
the incremental cancer risks are above the target risk level for the RME adult exposure scenario
and the incremental His are above the target range for the average and RME child exposure
scenario. However, the concentrations of arsenic detected in background wells and well W-4 are
below the arsenic MCL of 50
Analytical data from samples obtained during test pumping of Coyote municipal well 12A show
that manganese was also detected slightly above the Federal secondary drinking water standard.
Given that manganese was detected in samples collected from a crossgradient municipal well,
it is possible that manganese detected in onsite groundwater wells in the perched and regional
zones is naturally occurring. However, it should be noted that the concentrations of manganese,
specifically in well W-6A, are several orders of magnitude greater than the Federal secondary
drinking water standard, the levels in Coyote Well 12A, and the three upgradient background
wells.
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Uncertainty
There are numerous sources of uncertainty associated with the methodologies and data used
in this risk assessment that tend to limit the confidence in the resulting quantitative estimates of
carcinogenic risks and non-carcinogenic hazards. Uncertainty is unavoidable in quantifying
health risks, and many parameters are not well known (toxicity values) or contain significant
variability. Thus, it is expected that the risks are conservative at least to some degree.
Therefore, actual risks may be lower than those estimated for both the more probable average
and RME cases.
Conclusions
In summary, given the inherent uncertainties, the exposures that are most likely to pose excess
carcinogenic risks and noncarcinogenic hazard effects at the McColl Site are those experienced
by residential receptors who are exposed to COPCs in groundwater by incidental ingestion. The
chemicals that contribute most to these excess carcinogenic risks include arsenic and beryllium
in wells screened in the perched aquifer. Arsenic was identified as a COPC in soil samples
collected from the Site, whereas beryllium was not. The concentrations of beryllium in
groundwater may be attributed to the leachability of naturally-occurring chemicals in the vadose
zone due to the low pH in groundwater.
It is unlikely that locally perched groundwater would be classified as a potable source because
perched groundwater is not present in sufficient volume to serve as an exclusive source of future
water supply. However, it is important to evaluate the potential health risks of perched
groundwater because it is possible that some areas of the perched zones are hydraulically
connected to the deeper regional aquifer which serves as a potential drinking water source.
Carcinogenic risks associated with wells screened in the deeper regional aquifer are within and
are slightly above (RME scenario) the established risk range (1 x 10"4 to 1 x 10~6). In addition,
noncarcinogenic hazard effects may occur from groundwater ingestion of chemicals detected in
wells screened in the regional aquifer. However, the concentrations of the risk-driving chemicals
in the regional wells are either below the corresponding MCL (arsenic) or appear to be within
background levels (manganese).
The potential risks associated with thiophene-based compounds could not be assessed
quantitatively because of the lack of EPA-verified toxicity criteria. The odor threshold
concentration (OTC) for THT, which is the concentration at which 50 percent of the population
can detect an odor, is 0.6 ppb or 0.0018 mg/m3. In comparison to most chemicals, THT can be
detected at relatively low concentrations.
VII. DESCRIPTION OF ALTERNATIVES
This section will describe four alternatives that EPA has evaluated in selecting the final cleanup
plan for the Site. The four alternatives were evaluated and compared to the nine criteria required
by the NCP (40 CFR § 300.430(e)(9)) in the Feasibility Study Report, Groundwater Operable Unit,
McColl Site (EPA, February 1996). The nine criteria are described in greater detail in Part VIII of
this decision document, entitled Summary of Comparative Analysis of Alternatives.
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The Draft Feasibility Study (ENVIRON) and the work leading up to the Draft was provided
by MSG to EPA. EPA revised portions of the MSG text and finalized the document on
February 7, 1996.
The general Remedial Action Objective (RAO) for groundwater at the site is long-term protection
of potable groundwater for public health purposes and to ensure its current and future beneficial
use as a source of drinking water supply.
A. Alternative #1
The NCP requires that a no-action alternative be considered at every site. The no-action
alternative usually serves primarily as a point of comparison to other alternatives; however, in this
case it was considered. There are no costs, except monitoring, associated with this alternative.
B. Alternative #2
Institutional controls that would limit future use of groundwater in the vicinity of the site would
prevent non-natural migration of waste from the perched to the regional aquifer. Under this
alternative. EPA or a Responsible Party would negotiate limitations on the use of groundwater
beneath the adjacent properties with the owners.
Implementation of offsite institutional controls would require determination of an appropriate PRG
for THTs upon which to base the lateral extent of controls required or recommended. EPA
recommends 3.6 ppb as the PRG for total THT compounds. This is based on an MSG analysis
of domestic use performed during the Rl. It is anticipated that affected properties outside the
current site property boundaries could include adjacent residential properties along Tiffany and
Fairgreen, the golf course property adjacent to the southern boundary, and possibly Island Drive
residential properties.
While there are no capital costs associated with this alternative there are costs associated with
conducting negotiations and many adjacent property owners may be reluctant to agree to the
limitations. The costs of this alternative are estimated at $744,000 to $1,934,000 in addition to
the monitoring costs.
C. Alternative #3
This is the alternative selected in this decision document. Modifications to the selected
alternative are outlined in Section X, Statutory Determinations, Documentation of Significant
Changes (page 26). This alternative would include evaluation, design, and construction of
infiltration controls to significantly (order of magnitude) reduce surface water infiltration from
baseline estimates. Measures/controls for consideration during design may include some or all
of the following:
• Onsite management of surface water running onto the site property;
• Lining existing major drainage channels with low permeability materials;
• Grading or modifying (through placement of low permeability soils) areas adjacent
to, but outside of the planned closure containment system;
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Groundwater monitoring (including additional wells) to demonstrate that the
infiltration controls are effectively preventing further migration of site contaminants
to and throughout the regional aquifer; and
Site maintenance and security until final O&M plans take effect under the source
operable unit remedy.
The groundwater remedy (Alternative #3) is intended to work in conjunction with the source
remedy, and together will achieve the anticipated goal of protection of groundwater resources.
There would be a capital cost of $744,000 to $1,934,000 for this alternative in addition to the
monitoring costs. The likely net present value would range between $2,294,000 and $3,484,000.
D. Alternative #4
This alternative would extract water from the deeper aquifer and treat this water at the site
surface. It was assumed that granular activated carbon (GAC) would be used to treat water;
however, additional treatability studies would have to be performed to determine efficacy. The
treated water would be reused as irrigation water, discharged to surface water, or reinjected into
the groundwater through wells. This alternative would also include groundwater monitoring. The
rate of extraction was estimated at 6 gpm and the groundwater would be drawn from existing
monitoring wells.
The total estimated capital costs for this alternative range from $1,648,000 to $2,904,000. The
annual operation and maintenance costs would be $383,000 plus additional monitoring wells and
monitoring. The net present value is estimated to be $5,707,000 to $6,963,000.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In the Feasibility Study, alternatives were developed assuming that alternative #3 may include
components of #2 and that #4 may include components of #3 and #2. In the presentation of
alternatives for comparative purposes each alternative is evaluated based on its own merits.
A. Protection of Human Health and The Environment
Overall protection of human health and the environment addresses whether an alternative
provides adequate protection from exposure to contamination and describes how risks for the
exposure pathways are eliminated or reduced.
Because there are no current exposure pathways and concentrations of contaminants in the
regional aquifer fall within the acceptable risk range, all of the alternatives are sufficiently
protective of human health.
B. Compliance With ARARS
The primary applicable or relevant and appropriate requirements (ARARs) that have been
identified for the groundwater at the McColl site are the federal MCLs and non-zero Maximum
Contaminant Level Goal (MCLGs) as promulgated and applied under the Safe Drinking Water Act
and State MCLs. Chemicals of concern in the regional aquifer either already meet MCLs, have
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background concentrations above MCLs, or appear as localized occurrences. Chemicals of
concern have been detected in perched groundwater at concentration exceeding MCLs. The
perched groundwater would provide insufficient yield to be used as a sole source of groundwater
and as a result is not considered to be subject to the MCLs as ARARs. It should be noted that
the migration of site contaminants (THTs) from the perched to the regional aquifer indicates a
possible pathway for future contaminant migration.
For the purpose of comparing alternatives, all of the alternatives generally comply with ARARs.
When evaluating relevant environmental law it is important to recognize that the limited
contamination of the regional aquifer by THTs affects the secondary water quality standards of
taste and odor. Secondary standards are "to be considered" in the evaluation process. In
comparing alternatives in light of THT contamination, all of the alternatives, with the exception of
the no-action, would serve to prevent further migration of THTs in the regional aquifer.
EPA recommends that all of the interested agencies and parties work to determine an
appropriate site-specific concentration for evaluation of THTs. EPA recommends, based on an
analysis of domestic use performed during the Rl, that a PRG concentration of 3.6 ppb total THTs
be used for the five year review in evaluating the effectiveness of the remedy in the regional
aquifer
C. Long-Term Effectiveness and Permanence
Long term effectiveness and permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time.
Alternatives 3 and 4 are considered more permanent and effective than alternatives 1 and to a
lesser degree 2, due simply to the fact that they would serve to prevent future contamination of
the regional aquifer and would therefore be most protective overtime. Alternative 3 is considered
more effective than Alternative 4 because it would not generate treatment residuals or require
constant energy and resources which have secondary environmental effects.
D. Reduction of Toxictty, Mobility, or Volume Through Treatment
Reduction of toxicity, mobility, or volume through treatment refers to the preference for a remedy
that uses treatment to reduce health hazards, contaminant migration, or the quantity of
contaminants at the site.
While Alternative 4 is the only alternative to consider treatment, the volume of contaminants
treated is expected to be very low. The volume of groundwater extracted is estimated at 6 gpm
and would contain contaminants in the parts per billion range. The treatment process would
generate residuals and require frequent maintenance.
E. Short-Term Effectiveness
Short-term effectiveness refers to the period of time needed to complete the remedy and to
prevent adverse impacts on human health and the environment that may be posed during
construction and implementation of the remedy. Since a complete health and safety plan would
be implemented prior to the construction of the remedies, short-term adverse impacts during
construction of the remedies would be minimized.
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All of the alternatives could be implemented in a reasonable timeframe. Alternative 4 would likely
take the longest to implement and would have to consider a site-specific remediation goal for
THTs. Alternatives 3 and 4 would provide the maximum short-term effectiveness in reducing the
THTs in the regional aquifer.
Alternatives 1 and 2 present the minimum short-term impacts of the alternatives considered.
Short-term impacts associated with Alternative 3 are limited to the risk posed to workers working
with heavy equipment during the construction of the infiltration controls; there are no foreseeable
risks to the community. Alternative 4 has some short-term risks for workers and possibly some
risks associated with operation of construction equipment in the community.
F. Implementability
Implementability refers to the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the selected remedy. It also includes
coordination of Federal, State, and local governments during cleanup of the site.
With the exception of the no further action Alternative (#1), Alternative #3 would be the easiest
to implement. Alternative #3 can be directly integrated with the construction of the closure and
containment system and may not require any complex negotiations regarding institutional
controls (Alternative #2) or permits (or coordination) for operation of treatment system
(Alternative #4). Alternatives #2 and #4 would also require significant additional community
involvement which can complicate the implementation process.
G. Cost
This criterion examines the estimated costs for each remedial alternative. For comparison, capital
costs and annual O&M costs are used to calculate a total net present worth cost for each
alternative.
Costs between alternatives 1, 2 and 3 compare well. All of these three include annual monitoring
($139,000). All alternatives would include at least one additional monitoring well ($146,400), and
Alternative #4 would include $77,900 for monitoring of extraction wells. The costs of conducting
the negotiations under alternative #2 are not assessed but could be significant. Alternative #4
alone would have total estimated capital costs ranging from $1,648,000 to $2,904,000, annual
operation and maintenance costs would be $383,000 plus additional monitoring wells and
monitoring, and the net present value is estimated to be $5,707,000 to $6,963,000.
In the Feasibility Study, alternatives were developed assuming that alternative #3 may include
components of #2 and that #4 may include components of #3 and #2. In the presentation of
alternatives for comparative purposes each alternative is evaluated based on its own merits.
H. State Acceptance
The State of California has commented in support of the remedy selected with the comment that
offsite institutional controls should be considered in addition to the infiltration controls. EPA has
addressed this concern by requiring that offsite institutional controls be implemented at the five
year review in the event that the regional aquifer beyond the current site boundary is found (in
more than one offsite well) to contain site-specific contaminants above State or Federal MCLs
or the above the recommended or revised PRG for THTs.
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I. Community Acceptance
The community has supported the selected remedy during the comment period of the public
meeting. No specific written comments were received during the public comment period. The
public meeting comments are provided in Attachment B.
IX. SELECTED REMEDY
EPA has selected Alternative #3 as the remedy for the McColl Superfund Site. The selected
remedy for contaminated groundwater at the McColl Site consists of:
• Evaluation, design, and construction of infiltration controls to significantly (order
of magnitude) reduce surface water infiltration from baseline estimates.
Measures/controls for consideration during design may include some or all of the
following:
Onsite management of surface water running onto the site property.
Lining existing major drainage channels with low permeability materials.
Grading or modifying (through placement of low permeability soils) areas
adjacent to, but outside of the planned closure containment system.
Groundwater monitoring to demonstrate that the infiltration controls are
effectively preventing further migration of site contaminants to the regional
aquifer (in excess of Federal or State MCLs or the site-specific PRG for
THTs).
Institutional controls at the five year review in the event that the regional
aquifer beyond the current site boundary is found (in more than one offsite
well) to contain site specific contaminants above State or Federal MCLs or
above the recommended or revised PRG for THTs.
Site Maintenance and Security until final O&M plans take effect under the
source operable unit remedy.
Implementation of this remedy will prevent the spread of groundwater contamination and reduce
the possibility of future contamination of the regional aquifer, thereby reducing any future risk of
exposure to contaminated groundwater. These controls will remain in-place in perpetuity along
with the closure and containment system. Because the source operable unit remedy does result
in hazardous substances remaining on the site above health-based levels, the groundwater
remedy five year review shall apply coincident with the source remedy five year review. Based
on an estimated construction completion of 1997, the initial five year review will occur in 2002.
The decision to select Alternative 3 as the remedy is based on a comparative analysis of the
alternatives presented above and provides the best balance of trade-offs with respect to the nine
evaluation criteria.
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A long-term groundwater monitoring program shall be implemented to evaluate the effectiveness
of the infiltration controls and to demonstrate continued achievement of Federal or State MCLs
and the proposed (3.6 ppb) or revised PRG for total THTs.
X. STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment as required by
Section 121 of CERCLA. The selected remedial action, when complete, shall comply with
applicable or relevant and appropriate environmental standards established under Federal and
State environmental laws. The selected remedy is cost-effective and considered permanent
treatment technologies to the maximum extent practicable. The following sections discuss how
the selected remedy for the McColl groundwater contamination operable unit meets these
statutory requirements.
A. Protection of Public and the Environment
Prevention of further future degradation of the regional aquifer from site contaminants will protect
the aquifer as an important natural resource and prevent any future unacceptable exposures from
site contaminants via groundwater usage. The implementation of this remedy will not create any
short-term risks to the community nor any negative cross-media impacts.
B. Attainment of ARARS
All ARARs will be met by the selected remedy. The selected remedy will maintain compliance
with chemical-specific ARARs by reducing migration of contaminants to the regional aquifer.
There are no action specific or location specific ARARs.
C. Cost-Effectiveness
EPA believes the selected remedy is cost-effective and addresses the contaminated groundwater
within a reasonable period of time. The selected remedy fulfills the nine criteria of the NCP and
provides overall effectiveness in relation to its cost.
Alternative #3 has a capital cost of approximately $744,000 to $1,934,000 and an approximate
annual O&M cost of $146,000. The net present value is $2,294,000 to $3,484,000 based on an
assumed 20-year project life.
D. Use of Permanent Solutions and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent Practicable
The primary rationale for selection of Alternative #3, the preferred alternative, is that it provides
the best balance of long-term effectiveness versus cost, and it is relatively easy to implement.
The selected remedy was evaluated against treatment technologies that were determined to be
less cost effective. EPA has determined that the selected remedy provides the best balance of
long-term effectiveness and permanence; reduction of toxicity, mobility, and volume through
treatment; short-term effectiveness; implementability; and cost effectiveness. The selected
remedy has also been accepted by the State and community.
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E. Preference for Treatment as a Principal Element
While contaminants in the groundwater will not be extracted and treated, it is important to point
out that natural degradation processes will be closely monitored. EPA considered treatment as
an alternative in the evaluation process and determined that it was not cost-effective or
implementable when compared with the preferred alternative.
F. Documentation of Significant Changes
EPA considered institutional controls as a part of its description of all remedial actions in the
GWFS. However, for the purposes of conducting the comparative analysis, in the GWFS, EPA
evaluated each remedial alternative individually (versus cumulatively). Accordingly, because the
Proposed Plan fact sheet is based on the comparative analysis, it only discussed infiltration
controls without institutional controls for Alternative 3.
Consistent with the GWFS, EPA has incorporated institutional controls in the final remedy as a
contingency measure for the regional aquifer. Specifically, institutional controls shall be
considered at the five year review if the regional aquifer beyond the current site boundary is
found (in more than one offsite well) to contain site-specific contaminants above State or Federal
MCLs or above the recommended (3.6 ppb) or revised PRG for total THTs. Institutional controls
were included primarily to address State concerns.
Keith A. Takata
Director, Superfund Division
U.S. EPA, Region IX
Date
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REFERENCES
ENVIRON, 1995. Final Remedial Investigation Report, Groundwater Operable Unit, McColl Site,
Fullerton, California. December.
ICF, 1995, Final Baseline Risk Assessment for the McColl Superfund Site Groundwater Operable
Unit, Fullerton, California. November.
ICF, 1996. Feasibility Study Report, Groundwater Operable Unit, McColl Site, Fullerton, California,
February.
US EPA, 1993. Source Operable Unit Record of Decision. June.
US EPA, 1995. Final Full Scale Demonstration Test Report, McColl Site. June.
REFERENCES FOR RISK ASSESSMENT
CH2M Hill, 1987. Field Report. Various Tasks to Supplement the Previous RI/FS. Prepared for
EPA, Hazardous Site Control Division. Contract No. 68-01-7251.
ENVIRON, 1995a. Quarterly Groundwater Monitoring Report. First Quarter Sampling Period
(19941. March.
ENVIRON, 1995b. Quarterly Groundwater Monitoring Report. Second Quarter Sampling Period
(1995). April
ENVIRON, 1995c. Quarterly Groundwater Monitoring Report. Third Quarter Sampling Period
(1995). July.
EPA (U.S. Environmental Protection Agency). 1989a. Risk Assessment Guidance for Superfund.
Volume lt Human Health Evaluation Manual (Part A), Interim Final. EPA 540/1 -89/002.
December.
EPA, 1989b. Exposure Factors Handbook. Office of Health and Environmental Assessment,
Office of Research and Development. EPA/600/8-89/043. July.
EPA, 1991 a. Human Health Evaluation Manual Supplemental Guidance: "Standard Default
Exposure Factors." Office of Solid Waste and Emergency Response. OSWER Directive
9285.6-03. March.
EPA, 1991b. Risk Assessment Guidance for Superfund. Volume I: Human Health Evaluation
Manual. Part B, Development of Risk-based preliminary Remediation Goals. Office of
Emergency and Remedial Response. OSWER Directive 9285.7-Olb. December.
EPA, 1992a. Guidelines for Exposure Assessment. Federal Register, Volume 57, No. 104. May.
EPA, 1992b. Code of Federal Regulations (40 CFR) Part 300 - National Oil and Hazardous
Substances Pollution Contingency Plan, Subpart E - Hazardous Substance Response
c:\on-disk\rorty_m\rod_1.wp5 27 05/08/96
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EPA, 1994. Health Effects Assessment Summary Tables (HEAST). Prepared by Office of Health
and Environmental Assessment, Environmental Assessment and Criteria Office, Cincinnati,
Ohio, for the Office of Solid Waste and Emergency Response, Office of Emergency and
Remedial Response, Washington, D.C. FY-1993.
EPA, 1995a. "Region IX Preliminary Remediation Goals (PRGS)", September.
EPA, 1995b. "Integrated Risk Information System (IRIS)11. Environmental Criteria and Assessment
Office, Cincinnati, Ohio. September.
ICF (ICF Technology, Inc.). 1992a. Baseline Public Health Evaluation, McColl Superfund Site.
Prepared for U.S. EPA, Region IX. May.
ICF1992b. Public Health Evaluation of Remedial Alternatives (PHERA). McColl Superfund Site.
Prepared for U.S. EPA, Region IX. May.
ICF 1995. "Risk Assessment Revised Work Plan and Cost Estimate, McColl Superfund Site."
June 22.
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ATTACHMENT B
MARCH 14, 1996
PUBLIC MEETING COMMENTS
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Mr. Felter:
Mr. Bushey:
Mr. Felter:
Mr. Bennett:
I hereby declare the comment period open.
comment on the proposed plan?
Would anyone like to
Mr. Felter:
Mr. Siegel:
Mr. Felter:
Mr. Olquin:
Mr. Felter:
Yes. My name is Dave Bushey, B-u-s-h-e-y. I live at 1819 Fairgreen Drive
in Fullerton. And I agree with your plan as proposed. And I thank you for
all your work.
Thank you. Do we have any other comments?
Yes. My name is Chuck Bennett, B-e-n-n-e-t-t. I'm a resident of Fullerton
and part of the FHCA. I would like to make the comment that the selection
of #3 or #1 would have been the fastest alternatives at implementation.
And I'm pleased to see that the Agency has chosen one of the prompter
remedial plans for the groundwater.
And I think -- my sense of the community is that they are supportive of
either #1 or #3 as the choices.
Thank you. Yes, sir?
My name is Gene Siegel, S-i-e-g-e-l. I live at 2617 Tiffany Place. Looking
over four alternatives, I would agree with EPA that Alternative #3 does
make the most sense. From looking at the factors of overall protection,
long-term effectiveness, cost effectiveness, and short-term risk, if you look
at all four of those factors, they seem to be the best overall of all the
alternatives.
Thank you. Do I have another comment?
Yes. It's Alex Richard Olquin, 0-l-q-u-i-n. My address is 1506 Baronet
Place, City of Fullerton. I'm a member of FHCA. I agree with Alternative
#3.
There is a concern I have regarding down the road that long-term
maintenance and monitoring, that diligence is served. And that I would
hope that in the issuing of the rod, that an explanation would be made and
comments given by US EPA regarding that MSG will stand by and monitor
the wells and that we will not have problems hereafter, once the 30-year
period is over or maintenance of the cap and implementation of their
orders.
Thank you. I've just been reminded that several times this evening during
this period the initials FHCA have been used. For the record, that stands
for the "Fullerton Hills Community Association."
Do I have any other comments?
All right. Well, hearing no others, I officially conclude the official comment
period and turn the meeting over to Mike and Brian for general questions.
Thank you.
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ATTACHMENT C
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
FOR THE
GROUNDWATER OPERABLE UNIT
PROPOSED PLAN
MCCOLL SUPERFUND SITE
FULLERTON, CALIFORNIA
May?, 1996
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IX
75 HAWTHORNE STREET
SAN FRANCISCO, CALIFORNIA 94105
ICF TECHNOLOGY, INC.
1800 HARRISON STREET
OAKLAND, CALIFORNIA 94612
Contract No. 68-W9-0059
Work Assignment No. 59-18-9L04
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McColl Site Responsiveness Summary 5/96
Table of Contents
TABLE OF CONTENTS
I. OVERVIEW 1-1
II. HISTORY OF COMMUNITY INVOLVEMENT 11-1
III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES 111-1
Exhibit A Proposed Plan Fact Sheet
Exhibit B March 14, 1996 Public Meeting Transcript
Exhibit C Public Comments
Exhibit D Written Comments from the State of California and McColl Site Group
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McColl Site Responsiveness Summary 5/96
Section I
Overview
I. OVERVIEW
On March 6, 1996, the U.S. Environmental Protection Agency (EPA) issued a Proposed Plan
stating EPA's preference for the groundwater cleanup alternative for the McColl Superfund Site
in Fullerton, California. EPA's preferred remedy is Additional Infiltration Reduction Measures
(Alternative #3 presented in the Feasibility Study Report, Groundwater Operable Unit, McColl
Superfund Site (EPA, February 1996)). Under this alternative, engineered controls would be used
to reduce the infiltration of site surface water and thereby reduce the migration of perched
contaminated groundwater to the regional aquifer. The controls could include lining of major
drainage channels, reduction of infiltration through grading or placing low permeability materials
outside of channels, and onsite management of surface water running onto the site. This
alternative also includes long-term groundwater monitoring. A 30-day public comment period
followed the issuance of the Proposed Plan. This Responsiveness Summary is a written
summary of the comments EPA received during the public comment period and EPA's responses
to these comments. After consideration of the public comments and review of the administrative
record, EPA has selected Additional Infiltration Reduction Measures. This final remedy is
embodied in the Record of Decision (ROD).
All of the community's responses to the Proposed Plan were in favor of the selected remedy,
Alternative #3. The oil company PRPs, the McColl Site Group (MSG), support the selection of
Alternative #3 with some exceptions and comments that are presented in Section 3 of this
Responsiveness Summary. The State of California, Department of Toxic Substances Control
(DTSC), has commented in support of Alternative #3. The DTSC has some comments on the
Proposed Plan that are presented in Section 3 of this Responsiveness Summary.
1-1
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McColl Site Responsiveness Summary 5/96
Section II
History of Community Involvement
II. HISTORY OF COMMUNITY INVOLVEMENT
Community members have been involved with the McColl Superfund Site since the beginning of the
investigation process. Agencies initiated investigations at the Site as a result of odor and health
complaints received from residents beginning in July 1978. Community concern increased gradually
through 1980. The Efforts of Campaign for Economic Democracy (CED), a statewide consumer and
environmental organization, and a speech given to residents by Lois Gibbs, president of the Love Canal
Homeowners Association, focused media attention on the Site and heightened community awareness
about McColl. Due to the increasing community concerns and potential border zone property
determinations, the California Department of Health Services (DHS), now the Department of Toxic
Substances Control (DTSC), organized a public hearing in the fall of 1980.
Individual members of the community continued to be involved in discussions and decisions related to
the Site through 1984, when EPA and DHS announced that the Site would be remediated using the
excavation and redisposal alternative. Community comments received at the first public hearing indicated
strong community support for this decision. Following the California State Court injunction blocking the
State from implementing the remedy, some community members expressed increasing frustration at
delays in the cleanup process. This frustration led to the formation of the McColl Action Group. This
neighborhood committee participated actively in decisions related to the Site from 1985 through 1991.
EPA and DHS were often invited to make presentations to the group. The group subsequently disbanded
in 1991. Another community group, the Fullerton Hills Community Association (FHCA), was founded in
1991. This group has had input into site-related decisions.
Elected officials also have expressed interest in the Site, most notably former Congressman Dannemeyer.
All elected officials in the area are on the mailing list for the Site, and receive all information related to site
activities. Starting in 1986, EPA and DTSC have held regular meetings as part of the Interagency
Committee. The committee is comprised of the following agencies: EPA, DTSC, the City of Fullerton,
South Coast Air Quality Management District, City of Buena Park, Orange County Environmental Health,
California Regional Water Quality Control Board, California Department of Health Services' Drinking Water
Branch, and California Environmental Protection Agency's Office of Environmental Health Hazard
Assessment.
Community participation has focused on the source operable unit, and there has been limited community
participation in groundwater issues.
The alternatives considered for protection of groundwater are described in the Proposed Plan Fact Sheet
included in Exhibit A. No written comments from the community were received during the public comment
period. All community comments that were made during the Public Meeting held on March 14,1996 were
in support of the selected remedy. Written comments on the Proposed Plan were received from MSG and
DTSC. Both MSG and DTSC support the selection of Alternative #3. EPA has taken community concerns
into account in selecting the remedy. EPA believes the selected remedy is protective of human health
11-1
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McColl Site Responsiveness Summary 5/96
Section II
History of Community Involvement
and the environment, will be completed in a reasonable amount of time with low risk to the community,
and is cost-effective.
Throughout the remedial process, EPA and DTSC have continued to conduct a variety of community
relations activities. Activities have included public meetings, small group meetings, regular mailings to
community members, a toll-free information line, an on-site open house, and regular contact with the
media to provide information.
EPA and DTSC will continue to work closely with the community throughout the entire remediation
process to keep residents informed of progress at the Site. EPA and DTSC will monitor community
interests and concerns, and will conduct community relations activities as needed to address those
concerns.
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McColl Site Responsiveness Summary 5/96
Section III
Summary and Response to Local Community Comments,
Summary and Response to State and PRP Comments
III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
AND AGENCY RESPONSES
PART I - SUMMARY AND RESPONSE TO LOCAL COMMUNITY COMMENTS
The local community expressed its support of the proposed remedial action at the public hearing on the
proposed plan held on March 14,1996. No written comments on the proposed plan were received from
the community. EPA acknowledges and appreciates the input of the local community.
The public hearing had two components. The first part of the evening was a brief summary of the status
of the closure and containment system (source operable unit). There were some questions from the
audience, with responses from EPA. Those questions and answers will not be repeated here, but appear
in the transcript of the hearing. A copy of the hearing transcript is attached to the Responsiveness
Summary as Exhibit B.
The second part of the hearing was devoted to the groundwater proposed plan and was designed to
receive public comments on the proposed plan. Four people representing neighborhood residents spoke
in support of the proposed plan. Because all comments from the local community were in support of the
proposed plan, no EPA responses are given here. As previously stated, no written comments were
received from the local community during the public comment period. The public comments are
presented as Exhibit C.
PART II - SUMMARY AND RESPONSE TO STATE AND PRP COMMENTS
Written comments on the proposed plan were received from the State of California (DTSC) and the MSG.
Both parties support the selection of Alternative #3, with some comments.
A. State of California, Department of Toxic Substances Control
The State of California's comments, dated March 29,1996, are presented here in their entirety in standard
print. EPA responses are in italics. The complete letter is presented in Exhibit D.
The California Department of Toxic Substances Control (DTSC) has reviewed the United States
Environmental Protection Agency's (U.S. EPA) Proposed Plan (Plan) for the Ground Water
Operable Unit at the McColl hazardous waste site. U.S. EPA issued the Plan on February 27,
1996 in the form of a fact sheet titled 'EPA McColl Superfund Site; February 1996.
The DTSC has been given the opportunity to review and provide comments to U.S. EPA on draft
and final versions of the various documents U.S. EPA used in developing the Plan. The
documents reviewed included those of the remedial investigation, feasibility study (GWFS), and
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McColl Site Responsiveness Summary 5/96
Section III
Summary and Response to Local Community Comments,
Summary and Response to State and PRP Comments
the baseline risk assessment, which were prepared by either U.S. EPA's contractor or the McColl
Site Group, the responsible parties. Also reviewed were the applicable or relevant and
appropriate requirements (ARARs), and the nine criteria analysis, both of which were included in
the GWFS. (A formal alternatives risk assessment document was not prepared). Individuals
reviewing the Plan and the various support documents include Dr. William Vance and' Dr. David
Chan of the Office of Environmental Health Hazard Assessment, Ms. Kathleen Considine of
DISC'S Geological Services Unit and Ms. Caroline Rudolph, DISC'S project manager for the
McColl Site.
The DISC'S comments and concerns regarding the Plan are derived from review of the draft and
final documents along with that of the Plan. The Department's comments on the Plan are as
follows, with Ms. Considine's comments (related to the GWFS) provided as an attachment to
further clarify DTSC's primary concern with the presently proposed Plan:
Proposed Plan
Conceptually, U.S. EPA's Plan of infiltration reduction and long-term monitoring appears to be
realistic and implementable considering the minimal contamination currently found within the
existing monitoring system. The Plan, denoted as Alternative 3 in the fact sheet, does lack an
element of the alternative as it was previously described in the GWFS: that of institutional
controls. Institutional controls are a means of ensuring the efficiency and integrity of the long-term
monitoring system. DTSC recommends that U.S. EPA's final Plan include at a minimum the
contingency of placing appropriate institutional controls if data review of the completed long-term
monitoring system (i.e., including the additional one or two wells proposed as part of the Plan)
indicate that such controls are needed.
Response; EPA agrees that institutional controls should be a part of Alternative #3. The EPA Record of
Decision states, *EPA or the relevant state agency will implement institutional controls as a contingency
measure. Specifically, if at the five year review the regional aquifer beyond the current site boundary is
found (in more than one offsite well) to contain site-specific contaminants above State or Federal Maximum
Contaminant Levels (MCLs) or above the recommended (3.6 parts per billion (ppb)) or revised preliminary
remediation goal (PRO) for tetrahydrothiophene (THT) compounds, institutional controls will be
implemented.*
Ms. Considine's Memorandum:
As requested, I have reviewed the document Feasibility Study Report, Groundwater Operable Unit,
McColl Site (GWFS), dated February 7, 1996. The GWFS was prepared by ICF Technology
Incorporated (ICF) for the United States Environmental Protection Agency (U.S. EPA). The GWFS
presents the remedial alternatives for contaminated groundwater at the McColl Site.
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McColl Site Responsiveness Summary 5/96
Section III
Summary and Response to Local Community Comments,
Summary and Response to State and PRP Comments
CONCLUSIONS & RECOMMENDATIONS
The chosen Remedial Alternative 3 (RA 3) involves source controls, groundwater monitoring,
infiltration reduction measures, and institutional controls, according to the discussion on page
6-23 of the GWFS. The GWFS then makes the statement on page 6-41 that " ...Remedial
Alternative 3 would be the easiest to implement, in the event that the required area of institutional
control is reduced or eliminated with remedial action.9 The RA 3, as presented to the public
makes no mention at all of institutional controls. I strongly recommend that institutional controls
be retained as part of RA 3.
The reason why institutional controls should be retained is a follows. The total horizontal and
vertical extent of contamination has not been determined off-site in the down-gradient direction.
Additional groundwater monitoring wells are proposed to resolve this issue and the area of
institutional controls cannot be adequately defined at this time. A reduction in contaminant levels
is expected after the source control and infiltration reduction measures are in place. However,
since the Orange County groundwater basin is non-adjudicated, without institutional controls there
is no control on the possible installation and pumping of a private well(s) in the site vicinity. This
could change the groundwater flow direction and gradient and potentially pull more contamination
from the site.
Response: As stated above, EPA agrees with the State, and has retained institutional controls in the
Record of Decision as a contingency measure. (See page 6-38 of the GWFS which provides that, "While
institutional controls are included as pan of Remedial Alternative 3, the size of the area where institutional
controls may need to be implemented may be significantly reduced or become not necessary.*)
B. The McColl Site Group
The MSG's written comments, dated April 5, 1996, are presented in their entirety in Exhibit D. Many of
MSG's comments do not pertain to Alternative #3 of the Proposed Plan and EPA does not necessarily
concur with those comments. However, this Responsiveness Summary applies only to Alternative #3 of
the Proposed Plan, therefore only those MSG comments that are applicable to Alternative #3 are
presented here in standard print. EPA responses are in italics.
The purpose of this letter is to provide the formal comments of the McColl Site Group ("MSG")
regarding the Remedial Investigation (Rl), Feasibility Study (FS), Risk Assessment (RA), and EPA's
Proposed Plan for the Groundwater Operable Unit at the McColl Site in Fullerton, California.
These comments are prepared in response to the U.S. EPA Public Comment Period which
extends to April 5, 1996.
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McColl Site Responsiveness Summary 5/96
Section ill
Summary and Response to Local Community Comments,
Summary and Response to State and PRP Comments
In response to Administrative Order 93-21, MSG has conducted routine groundwater monitoring
as part of a groundwater investigation which was begun by EPA in 1989. Based upon that
investigation, as well as the Remedial Investigation Report completed by MSG, the Risk
Assessment completed by EPA, and the Feasibility Study that was initiated by MSG and
subsequently completed by EPA, EPA has proposed a remedial action plan which has identified
Alternative #3 (described in the Feasibility Study Report) as the preferred alternative. MSG
supports the selection of Alternative #3 of the Feasibility Study Report. The following points
summarize the results of the overall groundwater program and clarify certain aspects of the
proposed alternative that should be reflected in the Record of Decision.
• EPA has raised concerns regarding potential difficulties in negotiating institutional controls
with adjacent landowners. However, institutional controls should be considered for the
McColl Site and the area immediately south of the site within the golf course property
where implementation hurdles should not pose a significant problem.
Response: EPA maintains that it may be difficult to negotiate institutional controls in residential areas south
of the Ramparts sumps (i.e., along Tiffany and Fairgreen Drive). As previously stated, EPA has retained
institutional controls as a contingency measure. At this time, there are insufficient data available to
determine whether institutional controls are necessary and, if so, the scope and extent of such controls.
Completion of the surface remedy, RCRA-equivalent cover, and subsurface barrier wall
system will significantly reduce the potential for the sumps to impact groundwater in the
future. Although construction of the surface remedy will provide the primary means of
reducing groundwater contaminants, MSG supports the additional infiltration controls
described in Alternative #3, with the exception of the use of imported low permeability
materials outside of drainage ditches and redirection of surface water running onto the
property.
Response: EPA concurs that imported low permeability materials outside of drainage ditches may not be
necessary. The groundwater remedy is intended to work in conjunction with the source remedy, and
together will achieve the anticipated goal of protection of groundwater resources.
• Continued monitoring and installation of up to two new monitoring wells in the regional
aquifer, lining of retention ponds and primary drainage ditches, and reduction of
infiltration through surface grading is appropriate for the site. Use of imported low
permeability materials outside of drainage ditches and redirection of surface water
running onto the property would not provide significant benefits relative to the cost of
implementing these actions. Accordingly, use of low permeability materials and
redirection of surface water should be eliminated from further consideration in the remedy.
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McColl Site Responsiveness Summary 5/96
Section II!
Summary and Response to Local Community Comments,
Summary and Response to State and PRP Comments
Response; EPA agrees that the use of imported low permeability materials would not provide significant
reduction in infiltration relative to the cost of purchase and placement of low permeability materials.
Redirection of surface water may be addressed by onsite management of surface water running onto the
property,
EPA has chosen to identify Operable Unit #1 for groundwater separately from Operable
Unit #2 for the surface remedy. However, it is important that the remedial design for
Operable Unit #1 be integrated into the design for Operable Unit #2. If EPA does not
facilitate timely integration of these designs, the cost and schedule for both remedies will
be adversely impacted.
Response: EPA agrees that the groundwater remedy is intended to work in conjunction with the source
remedy, and together will achieve the anticipated goal of protection of groundwater resources. EPA
intends to facilitate integration of these designs.
Comment #3: Under U.S. EPA's detailed analysis of the remedial alternative "Institutional
Controls" (Alternative #2), U.S. EPA states that "long term institutional control may be
constrained by the priorities of the enforcing agency." U.S. EPA further states in the FS
that institutional controls are "potentially difficult to implement in that it involves the often
complex subject of water rights and negotiations with private property owners." The
administration of limited Institutional Controls is a viable remedial element for both
Alternative #3 and for the remedial strategy outlined to address THT compounds
described in Appendix A of the FS report. Institutional controls would be useful, for
example, to assure that cross-contamination between flow units does not occur due to
well construction activities. Institutional controls are expected to be necessary only for
the McColl Site and a portion of the Los Coyotes Country Club property. Because only
two separate parcels are involved, implementation problems are not anticipated.
Response; EPA maintains that it may be difficult to negotiate institutional controls in residential areas south
of the Ramparts sumps (i.e., along Tiffany and Fairgreen Drive). EPA agrees that institutional controls
should be a part of Alternative #3. The EPA Record of Decision states, 'EPA or the relevant state agency
will implement institutional controls as a contingency measure. Specifically, if at the five year review the
regional aquifer beyond the current site boundary is found (in more than one offsite well) to contain site-
specific contaminants above State or Federal Maximum Contaminant Levels (MCLs) or above the
recommended (3.6 parts per billion (ppb)) or revised preliminary remediation goal (PRG) for
tetrahydrothiophene (THT) compounds, institutional controls will be implemented.9 At this time, there are
insufficient data available for the Los Coyotes Country Club property to determine whether institutional
controls are necessary andf if so, the scope and extent of such controls.
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McColI Site Responsiveness Summary 5/96
Section Hi
Summary and Response to Local Community Comments,
Summary and Response to State and PRP Comments
Comment #4: The Fate and Transport Study of THT Compounds (ENVIRON, December
18, 1995) indicates that THT compounds are being degraded, probably as a result of
biologically mediated processes. Additionally, the limited infiltration controls proposed in
Alternative #3 and the remedial action selected for Operable Unit #1 should effectively
isolate the THT compounds within the sump areas from groundwater. Given the
degradation of THT compounds in groundwater and the isolation of the sump areas form
groundwater, the existing concentrations of THT compounds in groundwater are not likely
to be a permanent condition.
Response: EPA agrees that, at the McColI Site, it appears that THT compounds are degrading as a result
of biologically-mediated processes.
II-6
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EXHIBIT A
PROPOSED PLAN FACT SHEET
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S> EPA Me Coll Super fund Site
Fuf/erton, California
February 1996
KPA announces proposed plan for contaminated groundwater at the McColl Superfund Site
The US EPA, in cooperation with the McColl Site
Group (MSG), comprised of Shell, Unocal, Arco, and
Texaco), has completed the Feasibility Study Report
for groundwater1 under the McColl site. EPA evalu-
ated four alternatives to address the limited ground-
water contamination found under the McColl waste
sumps (pits). EPA recommends the following alter-
native (Alternative 3) which includes:
• Reducing groundwater infiltration by lining major
drainage channels
• Redirecting water running onto the site
• Reducing infiltration in onsite areas which will be
outside the future closure and containment system
for the waste sumps
• Adding one or two new monitoring wells to
confirm the contaminants generated by the site do
not (unreasonably) extend beyond the current
monitoring network.
This plan would reduce the possibility of contaminated
shallow (not usable) groundwater migrating to the re-
gional (usable) groundwater. Although the regional
groundwater beneath the site is not currently used. US
EPA and the State of California consider the protec-
tion of current and future water supplies essential to
the health and welfare of the community.
OPPORTUNITIES FOR PUBLIC INVOLVEMENT
COMMUNITY MEETING
You are invited to attend a community meeting,
EPA will present its preferred alternative for
addressing groundwater contamination as well as
the other alternatives. Questions and comments
will also be taken at this time.
DATE: March 14, 1996
TIME: 7:00 pm
PLACE: Parks Junior High
Music Room, Room 126
1710 Rosecrans
Fullerton, CA 92633
PUBLIC COMMENT PERIOD
EPA will begin a 30 day public comment period on
March 6th, and requests your comments on the
preferred alternative as well as the other
groundwater alternatives for the site. Written
comments are to be post-marked no later than
April 5, 1996, and should be submitted to:
Michael Montgomery
Remedial Project Manager
US. EPA
75 Hawthorne Street, MS: H-6-1
San Francisco, CA 94105
1 Groundwater - Underground water that fills pores in soil or openings in rocks to the point of saturation. Where groundwater occurs in
significant quantity, it can be used as a water source.
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BACKGROUND
Beneath the McColl waste sumps are a series of
tilted or slightly slanted layers of soils and clays.
Some of the soil layers are more permeable to water
than the clay layers. The McColl site has multiple
clay layers with low permeability. These layers
retard and spread the contaminated groundwater,
preventing it from migrating downward from the
perched zones. Perched water refers to a body of
groundwater above the main or regional aquifer2.
Water in the regional aquifer, which lies approxi-
mately 160 to 200 feet below the surface of the
ground, stores and transmits more water than the
contaminated perched zones. Previous groundwater
investigations have found contaminants in several
perched groundwater zones beneath the McColl site.
In 1994 the groundwater investigation was expanded
to determine if contaminants had migrated beyond
the perched zones to the deeper regional aquifer and
if the potential exists for the migration of
contaminants to the regional aquifer. As part of the
investigation, eight new monitoring wells were
installed in the fall of 1994 and one well was
installed in the summer of 1995. These wells, along
with 15 pre-existing wells, form the current network
of 24 monitoring wells for the site. These 24 wells
W-9B
.••W-9C
W-10B
Rosecrans Avenue
Ralph B. Clark
Regional Park
I McColl Ramparts^
I P-1D Site Sumps
' Los Coyotes
I Sumps ^
LEGEND
(5) Perched Monitor Wells
• Regional Monitor Wells
— — - Site Boundary
0 100 200
Scale in Feet
Figure I
McColl Site Map Showing Locations of Monitoring Wells
2 Aquifer - An underground formation of material such as sand or gravel that can store or supply water to wells and springs.
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monitor shallow perched zones of groundwater (10
wells) and groundwater in the deeper regional .
aquifer (14 wells) (see Figure 1 for the locations of
these wells). The groundwater investigation was
completed by MSG.
U.S. EPA recently selected the contingency remedy
of closure and containment for the waste
sumps. This decision was made in September of
1995 and included significant community
involvement.
Since our last Groundwater Fact Sheet (August
1995), EPA has approved the Final Remedial
Investigation Report and the Final Feasibility Study
Report. The following information is a general
summary of the findings presented in those
documents.
GROUNDWATER INVESTIGATION
Groundwater investigation results indicate that while
contaminants are entering the perched groundwater,
they do not appear to result in significant
contamination of the regional aquifer. Only very
low concentrations of tetrahydrothiophenes (THTs),
which cause the water to taste and smell bad, appear
to have reached a limited portion of the regional
aquifer.
The perched groundwater is not considered usable
because there is not enough water to supply a
regularly used well. The regional aquifer is
potentially usable although it is not currently used
near the site. The City of Fullerton provides
municipal water to all residents near the site. Your
household tap water is not affected by contaminants
in the groundwater under the McColl site. The
water supply well nearest to the site is the City of
Fullerton's well named "Coyote 12a," which is
located approximately 3,000 feet to the southeast of
the site.
TABLE 1
PERCHED AND REGIONAL GROUNDWATER ORGANIC ANALYTICAL RESULTS
Contaminants Detected Above Drinking Water
Perched Well
Maximum Concentration
Contaminant (ppb)
Benzene 800 (Well W-6A)
1 ,2-Dichloroethane 2 (Well P-51)
Standards
Regional Well
Maximum Concentration
(Ppb)
NA
2 (Well P-5L)
California Drinking
Water Standards
(Ppb)
1
0.5
Pollutants That Smell and Taste Bad
2-Methyltetrahydrothiophene 43,000 (Well-6A)
3-Methyltetrahydrothiophene 3 1 ,000 (Well-6A)
Tetrahydrothiophene 17,000 (Well-6A)
NA = Not applicable
140 (Well P-5L)
140 (Well P-IOL)
ISO (Well P-IOL)
NA
NA
NA
ppb • parts per billion; a volume unit of measure.
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PERCHED GROUNDWATER
PUBLIC HEALTH RISK ASSESSMENT
The results of the Remedial Investigation Report
confirm the presence of McColl site contaminants in
the perched groundwater zones which underlie the
site. Organic (carbon-based) contaminants include
benzene, ethylbenzene, toluene, 1,2-dichloroethane
(1,2-DCA), 2-hexanone, total xylenes, phenol, and
pyrene.
Other McColl site organic contaminants called THTs
have migrated from the site to the perched
groundwater. Most residents recall from field tests
conducted last year the pungent smell of THTs,
which can be detected by the human nose at
concentrations as low as one part per billion. These
contaminants, while not a concern based on
available toxicological data, can render water
unusable by making it taste and smell bad. (See
Table 1 for concentrations detected).
In addition, inorganic contaminants are found in the
perched water immediately downgradient of the
sumps. These inorganics (also known as metals) are
most likely a result of the acidic water from the
waste sumps drawing, or "leaching", the metals out
of the native soils below the sumps. The impact of
these metals is likely to be limited to the area
directly beneath the waste sumps and is not likely to
pose a significant threat to the regional aquifer.
REGIONAL AQUIFER
McColl site contaminants (excluding the THTs) are
not present in the usable portion of the regional
aquifer. Some THTs may have reached the upper
(usable) portions of the regional aquifer and
additional monitoring wells will be installed to
confirm the limited extent of the THT contamination
(see Table 1).
EPA completed an evaluation of the public health
risks associated with the perched and regional
groundwater. Perched groundwater falls within the
range of risks that warrant EPA action. The majority
of the calculated risk associated with the perched
water is a result of the inorganics, which occur as a
result of the acidic nature of the McColl waste.
The regional groundwater presents a much lower
risk than the perched groundwater. EPA decided to
go forward with the Feasibility Study, due to the
concerns associated with:
• The risks calculated for the perched water
• The possibility of exceeding state or federal
drinking water standards in the regional aquifer
in the future
• The possibility of exceeding water quality
standards for taste and odor in the regional
aquifer.
FEASIBILITY STUDY
The purpose of the McColl Groundwater Feasibility
Study was to develop and screen potential cleanup
alternatives based on the type and extent of
contamination found during the investigation. A
range of four alternatives was considered to address
perched and regional groundwater contamination.
-------
Each alternative was developed to meet the general
objectives of:
• Reducing the potential generation and migration
of McColl waste constituents in the shallower
perched water beneath the site at levels which
could migrate and cause an unacceptable risk in
the regional groundwater
• Preventing human exposure to all contaminants
at concentrations that could pose a health
concern, and reduce the potential beneficial use
of regional groundwater
The four alternatives were evaluated in the
Feasibility Study against nine criteria (see Figure 2).
EPA performed a comparative analysis of the four
alternatives using the results of each individual
criterion. The alternatives and a summary of the
detailed analysis are described below and presented
in the table.
ALTERNATIVES CONSIDERED
Alternative #1: NO-ACTION
EPA considered the no-action alternative. The no-
action alternative would include the present level of
groundwater monitoring but would otherwise take
no action.
The no-action alternative would meet the criteria of
not exceeding drinking water standards and being
protective of public health, based on the current
data, and assuming the perched groundwater is not
usable. The no-action alternative is easy to
implement. No significant difficulties are
anticipated in constructing or implementing the
groundwater monitoring system associated with this
alternative. Alternative 1 is relatively inexpensive
but would not be as effective as other options in
assuring that the regional aquifer is protected from
site contaminants. The cost for the no-action
alternative would be $1.5 million based on 20 years
of groundwater monitoring.
Alternative #2: INSTITUTIONAL CONTROLS
Institutional controls would preclude the use of
groundwater beneath the site for drinking water
supply purposes. This alternative relies upon
successful negotiations for water rights with
property owners adjacent to the site and would
include groundwater monitoring. The goal of these
controls would be to prevent the migration of
perched contaminated groundwater into the regional
aquifer that could result from access through wells
in the regional or perched aquifer (not addressed by
the no-action alternative).
This alternative would meet the criteria of not
exceeding drinking water standards and being
protective of public health, assuming the perched
groundwater is not usable. The long-term
effectiveness of this alternative is limited as it is
based on water rights agreements with property
owners. Since the outcome of negotiations cannot
be predicted, it is difficult to estimate if the
alternative is easy to implement. There are also
regulatory agency concerns on whether any future
institutional controls could actually be enforced. It
is also difficult to estimate the costs of this
alternative. However, it would be more expensive
than the no-action alternative ($1.5 million) and
could cost more than Alternative #3.
Alternative #3: ADDITIONAL
INFILTRATION REDUCTION
MEASURES
Alternative #3 would include engineered controls
that would reduce the infiltration of surface
water and thereby reduce the migration of perched
contaminated groundwater to the regional aquifer.
This reduction would include lining of drainage
channels, reduction of infiltration through grading or
-------
placing low permeability materials outside of
channels, redirection of surface water running onto
the property and groundwater monitoring.
This is EPA's preferred alternative. It is more
permanent and effective than Alternatives #1 and #2
because it would reduce risk associated with the
perched groundwater and the possibility of shallow
contaminated water migrating to the regional aquifer
through natural or man-made pathways. In addition,
Alternative #3 would be simpler to implement
because it can be designed and constructed in
conjunction with the planned waste pit closure and
containment system. It is a more cost effective
alternative when compared to the extraction and
treatment option. The cost for this alternative, based
on an estimate of 20 years of operation, is $2 to $3
million.
Alternative #4 EXTRACTION AND
TREATMENT
Alternative #4 would extract water from the deeper
aquifer and treat this water at the site surface. The
treated water would be reused (e.g., as irrigation
water), discharged to the sewer system, discharged
to surface water via storm drain systems, or
reinjected into the ground through wells. This
alternative would also include groundwater
monitoring.
This alternative, although effective, would produce
residuals from the treatment system and would be
more difficult to implement than other alternatives.
Alternative #4 is the most costly of the alternatives
and would take the longest to implement. While
Alternative #4 would treat the extracted water, the
volume of treated material is expected to be small as
would the overall reduction of contamination in
groundwater. The cost for this alternative is $5 to
$7 million, based on 20 years of operation.
Figure 2
SELECTING A CLEAN-UP REMEDY
The U.S. EPA uses nine criteria to evaluate alternatives for cleaning up a hazardous waste site. The nine criteria
are as follows:
1) Overall Protection of Human Health and the Environment
Addresses whether a remedy provides adequate protection of human health
and the environment and describes how risks are eliminated, reduced, or
controlled through treatment, engineering controls, or institutional controls.
2) Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs)
Addresses whether a remedy will met all ARARs or federal and state
environmental statutes and/or provide grounds for invoking a waiver.
-------
3) Long-term Effectiveness
Refers to the ability of a remedy to maintain reliable protection of human
health and the environment over time, once clean-up goals have been met.
4) Reduction of Toxicity, Mobility, and Volume and Treatment
Refers to the anticipated ability of a remedy to reduce the toxicity, mobility,
and volume of the hazardous components present at the site.
5) Cost
Evaluates the estimated capital and operation and maintenance costs of each
alternative.
6) Short-term Effectiveness
Addresses the period of time needed to complete the remedy, and any adverse
impacts on human health and the environment that may be posed during the
construction and implementation period, until the clean-up goals are achieved.
7) Implementability
Refers to the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to carry out a particular option.
8) State Acceptance
Indicates whether, based on its review of the information, the state concurs
with, opposes, or has no comment on the preferred alternative.
9) Community Acceptance
Indicates whether community concerns are addressed by the remedy and whether
the community has a preference for a remedy. Although public comment is an
important part of the final decision, EPA is compelled by law to balance
community concerns with all of the previously mentioned criteria.
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For More Information
Documents for the McColl Superfund Site are located
in the information repository at:
Fullerton Public Library
Local History Room
353 W. Commonwealth Avenue
Fullerton, CA 92633
(714) 738-6333
Hours:
Monday - Thursday
Friday
Saturday
Sunday
10am- 9pm
10am- 6pm
10am- 5 pm
Closed
If you have questions about the Superfund cleanup
at McColl, please call or write EPA's Community
Relations Coordinator for the site:
Fraser Felter, Community Relations Coordinator
U.S. EPA, Region 9
75 Hawthorne Street (H-l-1)
San Francisco, CA 94105
(415)744-2181
You may also call EPA's toll-free Superfund hotline
and leave a message. Your call will be returned.
The hotline number is: (800) 231-3075
Important McColl Superfund Site Telephone Numbers
McColl Security Office
California EPA Public Participation Section
U.S. EPA Media Contact: Paula Bruin
(714)523-5310
(916)445-9543
(415)744-1587
United States Environmental Protection Agency
Region 9
75 Hawthorne Street (H-1-1)
San Francisco, CA 94105
Attn: Fraser Felter
Official Business
Penalty for Private Use,
$300
PRESORTED
FIRST CLASS MAIL
U.S. POSTAGE PAID
U.S. EPA
Permit No. G-35
Printed on Recycled Paper
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EXHIBIT B
MARCH 14,1996
PUBLIC MEETING TRANSCRIPT
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McColl Siiperfund Site
Multi-Page7
Transcript of Proceedings, 3-14-9(
Date:
Commenced at:
Concluded at:
Place:
Reporter:
McCOLL SUPERFUND SITE
GROUNDWATER PROPOSED PLAN
Thursday, March 14, 1996
7:10 p.m.
8:20 p.m.
Parks Junior High
Music Room, Room 126
1710 Rosecrans
Fullerton, CA 92633
Elizabeth Volz
M & M CERTIFIED COl^RT REPORTERS
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McColl Superfund Site
Multi-Page7
Transcript of Proceedings, 3-14-9<
Page
APPEARANCES
MIKE MONTGOMERY, Team Leader, us EPA
BRIAN SWARTHOUT, Project Manager, us EPA
FRASER FELTER, community Relations
Coordinator, us EPA
NATALIE GILMOUR, community Relations Coordinator,
ICF Technology, Inc.
LINDA LEQUIRE, Administrative Assistant for
Congressman Royce
Page 3
i Fullerton, California, Thursday, March 14, 1996
2
3 MR. MONTGOMERY: Can I ask folks to sit down,
4 please. We are going to get started.
5 Let's see if I can get some people to sit
6 down here. We are going to get started, it's about 7:10
7 and we're starting at 7:00 o'clock. Which means, that we
8 started ten minutes ago.
9 We are going to dim the lights so everybody
10 can fall asleep. Hopefully, people won't fall asleep.
11 And I think we will be able to run this meeting pretty
12 quickly. Hopefully, we'll get done fairly quickly. I'll
13 try to keep my comments brief.
14 The agenda, I'm going to go through a quick
15 introduction, sort of give some recent background on the
16 site.
17 My name is Mike Montgomery, by the way. I'm
18 a Team Leader and a Project Manager for the McColl Site
19 Team. I've been working on the McColl site project now
20 for a little over two years. And I'll do some
21 introductions.
22 Actually, if you could now raise your hands '.
23 because it's dark. I'll just do it real quick: Fraser
24 Felter with Community Relations; Al Hendricker with Shell;
25 Brian Swarthout is the other us EPA Project Manager
Page 4
1 that will be presenting tonight; Linda Lequire is in the
2 third row. she's from Congressman Royce's office; and
3 Mr. McAuley here from the McAuley LCX corporation, owner
4 of the golf course; and Caroline Rudolph with the State of
5 California; and some other folks that work with her that
6 you may be familiar, Bill Vance, Steve Gaytan.
7 Okay. So with that, we'll get started with
8 the introduction. I'm going to go over some recent
9 history. Brian is going to talk briefly about the
10 closure — status of the closure and containment system
11 design. I'm going to go through a brief description of
12 EPA's proposed plan for the groundwater contamination, and
13 talk about the alternatives that we considered.
14 And then we're going to have a brief period
is that's required by regulation that we allow people the
6 opportunity to comment on our proposed plan. And when we
17 get to that, if people could state their name and make
8 their comment with regards to what they think about our
9 plan for the groundwater contamination. And we'll have a
20 period for general questions after that for people that
21 have genera] questions.
22 We'll also have a short period after Brian's
23 talk on the status of the closure and construction for
24 people that have questions about that. But we may have to
25 cut that short, so that we can get on through the whole
Page 5,
1 agenda. But I think that we will probably be able to get '
2 through this fairly quickly. We have a small group
3 tonight and a lot of people who are familiar and know a
4 lot about the site already, so we won't have to do a lot !
5 of background. {
6 Recent history on the McColl site: I
7 Everybody is familiar with back in September we made a !
8 decision to go directly to the construction of a closure •
9 and containment system for the waste pits at the McColl i
10 site. Shortly after that decision we amended our i
11 Enforcement Order with the McColl Site Group, which is a
12 collection of oil companies that EPA has performing the i
13 work, and we will - in the process of amending that
14 order, they have been now performing the design for that
15 closure and containment system. And Brian will talk a
16 little bit more about that.
17 We also have sent a letter to a part of the
is government that has been found by the courts to be
19 involved with the disposal at the site. It happened
20 during the war years, World War n. And we've recently
21 sent a letter to both the McColl Site Group companies and
22 the government to ask them to come to the table and
23 participate in negotiations with EPA for the actual
24 construction and the long-term maintenance of that closure
25 and containment system for the sumps.
M & M CERTIFIED COURT REPORTERS
Page 2 - Page 5
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Transcript of Proceedings, 3-14-96
Multi-Page7
McColl Superfund Site
Page 6
i We've gotten responses back from both
2 groups, and we're in the process of considering how to
3 proceed, whether or not to do the negotiations, or whether
4 or not to use the Order Authority that we've used to do
5 the work up to the current date, and do the construction
6 and the maintenance under that.
7 We should have some information out to the
8 community in the next month or two as to how we are going
9 to proceed on that front. We're also in the process of
10 finalizing an agreement with the McAuley LCX corporation,
11 the owners of the golf course, to release them from
12 liability at the site.
13 And we've received comments from the McColl
14 Site Group on that agreement. And we've also received
15 responses from the McAuley LCX counsel responding to
16 comments that were raised by the oil companies. We're in
17 the process of considering both of those and deciding how
18 to move forward on that agreement between the us
19 Government and McAuley LCX corporation.
20 So that's a brief summary of what's been
21 happening recently. In terms of various talks, there has
22 also been support for an action towards having Orange
23 County put the Ramparts portion of the property up for
24 sale. And if there are any questions during the general
25 comments or question period, we might have Linda - she's
Page?
i been working on that. Linda, if you wouldn't mind
2 answering questions with regards to the status of the sale
3 on the Ramparts property. And EPA has been providing
4 letters to the county to assure them of the various things
5 and the status of that transfer.
6 So with that, Brian, why don't you come up
7 and give your talk on the closure and containment system?
8 MR. SWARTHOUT: okay. As Mike said, my name is
9 Brian Swarthout. I work for us EPA. And I'm the Project
10 Manager for the closure system operable unit or the
11 source-operable unit. I'm just going to be giving a quick
12 overview of the status of what's going on with the closure
13 system. As Mike said, Til also be taking a few
14 questions.
15 We want to keep the questions kind of short,
16 because the purpose of the meeting is for the groundwater
17 proposed plan. We will be here after the meeting to
18 answer more questions. And we'll be having additional
19 meetings at a later date in the coming months to talk
20 specifically about the closure system and what's - I
21 guess just further meetings for the status of the closure
22 system.
23 I want to say that we're very happy because
24 the schedule - or the design for the closure system is
25 currently on schedule. In fact, we received the
Page 8
1 conceptual design from the McColl Site Group or the oil
2 companies on March 4th. And we are currently working on
3 commenting on that design.
4 The draft conceptual design contains two
5 components. The first component is a cap. And the cap is
6 going to be — there will be two separate caps. One cap
7 will be over the Los Coyotes area. It's shown here in the
8 pink (Slide #2). The second cap will be here over at the
9 Ramparts area (Slide #2).
o The cap in the Los Coyotes area is going to
1 be approximately — excuse me, approximately five feet
2 thick. The cap in the Ramparts area is going to be a
3 lighter cap. It's going to be approximately three feet
4 thick. This cap is significantly thinner than caps that
5
6
were proposed in the past. As a result, we won't have to
be constructing any retaining walls adjacent to or along
7 this area adjacent to the homes in the Ramparts area.
8 MR. FELTER: Brian, may I interrupt for a moment?
9 Should someone in the audience be a little
o concerned if their house is not shown on the map?
MR. SWARTHOUT: Right. This was brought up
earlier. This figure obviously - well, not obviously.
But this figure is an earlier figure that we used. It's
just kind of a generalized schematic. But you can see
that there are some houses missing here (indicating) and
Page 9
i some houses missing here (indicating). That is just
2 because this is an earlier figure.
3 There was no intention to leave those houses
4 off for any particular reason or that the houses will all
5 have to be removed or anything like that. Those were just
6 left off from an earlier figure. And all the subsequent
7 figures, and the more detailed figures, actually show this
8 area and those houses are in place.
9 So as I said, there are going to be two
10 caps: One in the Los Coyotes area, one in the Ramparts
11 area. Another component of the caps will also be a
12 gas-collection system. So this gas-collection system will
13 be constructed under the cap and will be used for the
14 collection and treatment of the gases that come from the
15 sumps.
16 The second component of the closure system
17 is a soil bentonite slurry wall. And bentonite - what
18 that basically means is they are going to be mixing soil
19 with bentonite, which bentonite is a type of clay. And
20 this will cause the slurry wall to have a low
21 permeability, and it will be used for containing gas and
22 the waste at the site.
23 And there will be two slurry walls or soil
24 bentonite slurry walls. One is — they're shown here with
25 the red lines (Slide #2). So there will be one all the
Page 6 - Page 9
M & M CERTIFIED COURT REPORTERS
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McColl Superfund Site
Multi-Page7
Transcript of Proceedings, 3-14-96
Page 10
1 way around the Los Coyotes area, and one slurry wall all
2 the way around the Ramparts area.
3 The slurry walls will be constructed under
4 the ground surface. So when the construction is complete,
5 the slurry wall will be flush with the ground surface.
6 They will not be sticking up above the ground surface.
7 The slurry walls will he approximately anywhere from 19 to
8 39 feet below the ground surface.
9 And the reason that we chose this particular
10 closure system, the cap in conjunction with the slurry
11 wall was that: One, this system will be good for keeping
12 waste and gas inside the sumps. And it will also be good
13 for keeping water out of the sumps. And Mike will talk a
14 little bit about that with the groundwater - with the
15 groundwater portion.
16 As I said, we're currently reviewing the
17 conceptual design. Our comments are due to the McColl
18 Site Group on April 1st. And the design will actually be
19 finalized on December, December 4th of this year. And
20 soon thereafter construction will begin at the site.
21 As part of the construction, we will
probably — or MSG will require access to the backyards of
23 some of the houses that are in this area that are directly
24 adjacent to the site. In addition, MSG will be also
25 offering some of the residents in this area or the
Page 11
1 residents in this area (indicating), temporary, voluntary
2 relocation as part of the construction.
3 The other thing that I was going to talk
4 about tonight is the compatibility studies that are going
5 on. Currently, MSG is performing a series of
6 compatibility studies. And the compatibility studies are
7 going to be used to test the compatibility of the waste
8 that is currently at the site with - to test the
9 compatibility of waste with the materials that are going
10 to be used as part of the closure system. This is the
11 slurry walls, the sand, the liner — there's going to be a
12 plastic liner that's going to be used as part of the cap.
13 Those tests will be testing the compatibility of the waste
14 with those components. And we will be receiving the
15 results of those tests from MSG in July of this year. So
16 that's one of the current things that is going on at this
17 time.
18 So at that, I'll take a few questions and
19 then we'll move on.
20 UNIDENTIFIED SPEAKER: why is there a difference
21 in the thickness in the two caps?
22 MR. SWARTHOUT: The cap in the Los Coyotes area is
23 thicker so that it can accommodate the golf course. The
24 cap in the Ramparts area is thinner because there won't be
25 a need for the golf course. The final vegetative layer
Page 12
i won't need to be as thick. And, also, there is a lot of
2 drilling mud in the lower Ramparts area which won't
3 accommodate a thicker cap. But primarily it's for the
4 golf course.
5 UNIDENTIFIED SPEAKER: what is the depth of the
6 benzene contamination plume?
7 MR. SWARTHOUT: okay. Mike is going to talk
8 specifically about the groundwater plume and the
9 groundwater contamination during the rest of the meeting,
10 so he can address that question. So are there any other
11 questions?
12 Then I'll just turn it over to Mike. Turn
13 the mike over to Mike.
14 MR. MONTGOMERY: That question is actually an
15 excellent segue into what I'm going to talk about, which
16 is in the culmination of the 15 years of placing and
17 monitoring wells, and monitoring water quality data at the
18 McColl site, and what we've learned over the number of
19 years. And most important, most recently with the
20 placement of a number of additional wells off site, is
21 that there doesn't appear to be a significant amount of
22 groundwater contamination at the McColl site.
23 It's important, also, for people to
24 understand that the water that you receive in your home
25 comes from a municipal water system which is served by
Page 13
1 wells which are not in the vicinity of the site. In fact,
2 there are not a lot of - the nearest municipal well is
3 quite a distance, and it's actually cross gradient from
4 the site.
5 I want to talk about gradient, it's the
6 direction the groundwater flows. And the arrows here
7 indicate the direction that the groundwater flows
8 (Slide #3). And the nearest municipal well is about a
9 quarter of a mile over this way (indicating) or 3000 feet
10 this way (indicating). So it's important that people
11 recognize that this is not - immediately in the adjacent
12 area there are not any municipal wells.
13 The groundwater contamination at the McColl
14 site — you can see here that 26 wells have been placed
15 over the years. And we've monitored some of these wells
16 historically back into the 80s. Some of them have just
17 been recently placed at this site.
18 Our understanding of the site, our
19 conceptual understanding of the site - and, Brian, can
20 you flip to the next one over here on the left, looks kind
21 of like this. You know, what we've done over the last
22 recent few years is we put in a lot more wells and we've
23 done a lot of borings.
24 And over there against the wall are some of
25 the actual drawings that were done by hydrologists working
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1 for the McColl Site Group that show the detailed layers of
2 these low permeability clays where the water that comes
3 through the site sort of hangs out on top of it. We call
4 it "perched water." It's not down in this deeper regional
5 aquifer, which is about 200 feet down.
6 And what we found, in general, is that this
7 "perched water" which comes from the area around the sumps
8 is contaminated. And it's, you know - it's got benzene
9 and DCA (1,2-Dichloroethane). So this shows the perched
10 water quality data (Slide #5). If you can read that, you
11 have better sight than I do.
12 This shows the regional water quality data
13 (Slide #5). And, generally, what you see is that in areas
14 in perched water, for these compounds, which would be of a
15 concern, if you were to drink it for your whole life, they
16 exceed these drinking water standards. You don't
17 generally see those in regional wells. This DCA doesn't
18 exceed the drinking water standards in this case.
19 But what we found is that DCA is generally
20 not found at the site. That was an exception. And what
21 we are showing here is the highest concentrations that we
22 found. We have got reams of data that shows that there
23 has been no contaminants detected in that regional aquifer
24 for a number of wells.
25 Now, what we do see is that we have fairly
Page 15
1 high concentrations of those Tetrahydrothiophenes, which
2 everybody is familiar with, not only because it's the
3 longest sounding chemical but because it smells really
4 bad. And everybody is familiar with it because it's the
5 smell that you smell when you smell the McColl site, for
6 those of you that live in the neighborhood. And it's
7 generally these compounds.
8 And what we have found is that the
9 tetrahydrothiophenes have actually reached the regional
10 aquifer in some wells. They're not in other wells. And
11 so what we - you know, generally, all the water quality
12 data tells us is that we have got shallow contamination.
13 But this regional aquifer hasn't been affected by the
14 site, with the exception of a few areas where we have
15 these compounds which would make the water taste or smell
16 bad.
17 And so with that information, we went
18 forward and developed a feasibility study. We looked at
19 different options for how we can assure that this regional
20 aquifer stays clean. That's really the Agency's
21 objective.
22 So we considered four alternatives. And
23 these are all fairly simple, straightforward alternatives
24 relative to the very large and complex alternatives that
25 were considered in the past on the sumps themselves.
Page 16
.j And this is just for addressing that groundwater
2 contamination.
3 The first one is no further action. And if
4 we did that, we'd basically just continue to monitor the
5 situation.
6 And the next one is institutional controls.
7 When we do monitoring and we ask for those properties that
8 are adjacent to the site, but off of the site, that may
9 have contamination hi that regional aquifer, we would go
[0 to them and negotiate agreements and restrictions on the
1 use of their water. And that would be basically a way to
2 assure that that water didn't get used — that regional
i3 groundwater didn't get used.
4 Alternative #3, which is the alternative
5 that we're proposing, is long-term monitoring of the wells
6 and a reduction of infiltration of site" surface water in
7 order to reduce concentrations of contaminants in the
8 perched water, and therefore to protect that regional
9 aquifer from future contamination.
20
i
So what we're really concerned about is that
there is not a lot of risks posed by the site. You know,
22 right now we don't have a big plume of contamination in
23 that regional aquifer. So from our perspective, the best
.4 thing we can do is try to prevent the situation from
25 getting any worse, which we don't expect that it would.
Page 17
i But, you know, we look at this alternative,
2 and I'll get into it a little bit later, it's a
3 cost-effective, preventative measure to assure that we
4 protect that regional aquifer.
5 Alternative #4 is groundwater extraction and
6 treatment. A really common way to address groundwater
7 contamination is groundwater extraction and treatment systems.
8 That would involve groundwater monitoring. But we would
9 also hook up some of these monitoring wells with permanent
10 pumps.
11 We'd have to dig trenches and pump the water
12 back to the site. We would build a small treatment unit,
13 and we'd treat that water in that treatment unit and
14 discharge it to the city sewer system or to a pond or
15 something like that.
16 The amount of water that would be extracted
17 would be very small, because we don't have a large area of
18 contamination that we would want to draw out of the
19 ground. The volume would be about six gallons per minute,
20 a little bit more or less. And your garden hose on full
21 blast is about four gallons, four to five gallons per
22 minute. So think of it as a little bit more water than
23 your garden hose can produce on a full stream.
24 Can I get the other slide over here?
25 So what we did, to go through this fairly
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i quickly, and I know this looks like a pretty tedious 1
2 chart, and it can be a pretty tedious analysis system. 2
3 And most of you know the nine criteria because you've been 3
4 drug through the nine criteria a couple of times 4
5 (Slide #7). 5
6 These two, "State Acceptance" and "Community 6
7 Acceptance," this is really why we're out here talking to 7
8 you. We are going through a formal public comment period 8
9 to hear what people think about these alternatives. 9
10 State Acceptance, Caroline's here, they have 10
11 also been intimately involved in the process. Feel free 11
12 to comment if you want to ask them about their feelings 12
13 about the current proposed plan that EPA has. 13
14 I'll go through these real quickly. Overall 14
15 protection of human health and the environment and 15
16 compliance with ARARs. You can kind of group these 16
17 together. And, because we don't have significant 17
18 contamination in that regional aquifer there's really not 18
19 a big concern in terms of protection of public health. 19
20 In terms of compliance with ARARS, because 20
21 we haven't exceeded the federal drinking water standards, 21
with the exception of that one data point, which we 22
23 showed, there doesn't appear to be an exceedence of any 23
24 federal drinking or State drinking water standards in that 24
25 regional aquifer either. 25
Page !<,
Now, granted, we do have the shallow
contamination. But those lenses of water occur in very
thin lenses. If you were to put a well in there, you
wouldn't be able to pump enough water to use those shallow
perched contaminated units. And so therefore, that's not
really a significant concern of the Agency.
What we're concerned about is this regional
aquifer which people use down in the groundwater basin and
which someone might want to use in the future. So there
is not a lot of difference between these alternatives with
regards to those two criteria. Long-term effectiveness is
where you begin to see some differences between
alternatives.
The no-action alternative, you wouldn't
really do anything. So you wouldn't have any real
long-term effectiveness realized. Alternative #2, it
would provide some long-term effectiveness in that you
would assure, by negotiating these agreements, that nobody
would be using this water in the future.
We see Alternative #3 as having a fairly
high long-term effectiveness because you are going to put
these controls in. And over time they would serve to
reduce the concentrations of contaminants in that perched
aquifer. And over time they would prevent contaminants
from spreading to the regional aquifer if that were to
Page 20
i occur.
2 Also, with Remedial Alternative #4, that
3 would have a fairly high result too. That "Reduction of
4 Toxicity, Mobility, & Volume," that's sort of how much of
5 this stuff are you really going to treat? How much of
6 these chemicals are you going to reduce and eliminate?
7 None of the alternatives, none of these
8 first three consider any treatment. Alternative #4 does
9 consider treatment. But you have to consider that it's a
10 very small amount of water that we're treating. And then
1 the water that we're treating has very low concentrations
2 of contaminants.
3 So you could operate that extraction
4 treatment system for years and really only effectively
5
6
7
8
9
treat a couple of pounds of chemicals. Which you have got
to ask yourself when we get into the cost-effectiveness
standpoint, "Is it really worth all that effort?"
Minimization of short-term - cost
effectiveness, I almost jumped over it. Cost
20 effectiveness, Alternative #1, doing nothing, is real
21 cheap.
22 Remedial Alternative #2 is very difficult to
23 gauge how expensive that could be. Negotiating these
:4 agreements with adjacent properties could be complex; it
25 could be very simple. It's kind of hard to gauge.
Page 21
1 Putting restrictions on properties, some people might say,
2 "Well, it's no big deal. I'm not going to use the water.
3 I have got city water." It may be a bigger deal to other
4 folks.
5 Cost effectiveness in terms of Remedial
6 Alternative #3, it's going to be relatively cheap.
7 Alternative #1 is about $1.5 million for monitoring.
8 Alternative #2 is about maybe $2 to $3 million.
9 Alternative #3 is about $2 to $3 million. Alternative #4
10 is about $5 to $7 million. So #4 is quite a bit more
11 expensive than #2 and #3, because all of them include
12 monitoring.
13 Really, Remedial Alternative #2 is kind of
14 hard to gauge because you don't know how much money you
15 are going to spend on legal fees and doing the
16 negotiations.
n Alternative #3 roughly comes out to
18 somewhere between three-quarters to half a million dollars
19 of actual construction costs. The balance of it is
20 monitoring. And so what we are really proposing is, in
21 fact, something that's going to cost potentially less than
22 a $1 million and, yet, it could result in some long-term
23 benefit in terms of reducing the amount of contaminants
24 that could go to the regional aquifer.
25 So I think from a cost-effectiveness
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1 standpoint when you consider these two together, that's 1
2 really why we have selected Remedial Alternative #3.
3 Short-term risk. None of these alternatives
4 would pose any risk to the community. What you see
5 reflected here is risk to workers, the workers that you 5
6 are going to have digging trenches and using large 6
7 equipment. 7
8 One advantage of Remedial Alternative #3 is 8
9 that we are going to be working way outside the sumps. We 9
10 are going to be working in that drainage area over behind 10
11 Los Coyotes. You can't even really see it from the 11
12 residences along Tiffany or Fairgreen. 12
13 Lining that drainage area, since that is a 13
14 low-lying area where a lot of water ponds and settles 14
15 during high precipitation events would reduce infiltration 15
16 of water into the subsurface in the areas outside of the 16
n cap such as that drainage area, and if it's necessary in n
18 areas that are not low-lying areas. But I think we will 18
19 be able to effectively do it just by addressing those 19
20 low-lying areas. 20
21 And, then, there's really more short-term 21
22 risk associated with #4. You are going to have people 22
23 constantly going out to the site dealing with the 23
24 treatment system. You are going to have to lay piping and 24
25 do trenching. Some of that trenching and piping may have 25
Page 23
to go out into the streets along Fairgreen or on to the
golf course. So you are going to have, at least, the
interaction of workers and the community, which can
sometimes cause hard feelings. For instance, it can be a
nuisance to the residents to have trucks out in their
neighborhood parked in front of their house. And that
would come with this Remedial Alternative #4.
Implementability. Again, Alternative #1,
the monitoring, would be fairly easy.
Alternative #2, doing these negotiations,
deciding who you talk to, who you don't, could be a little
bit complex. We're not really sure what to do if people
don't agree to restrictions on the use of the water.
Remedial Alternative #3 would be really easy
to implement. We could take these plans to reduce
infiltration, integrate them right into the design that
Brian talked about, and do the construction at the same
time. And so this work could be performed in conjunction
with the design and the construction of the closure and
containment system. Which from an implementability
standpoint would be real easy for us to do. And it would
get it done fairly quickly, as quickly as other source
work would be done.
Remedial Alternative #4, implementability,
we'd have to get permits. We'd have to site the treatment
Page 24
J system. We'd have to get permits for the water that we
2 treat. We'd have to dig the trenches. It's fairly
3 complex to do it relative to these other alternatives.
4 It's easy to do; EPA has built extraction and treatment
5 systems, and so have the McColl Site Group partners at
6 different sites. But relative to the other alternatives
7 it's not quite as easy.
8 That's it. That's the overview. So, again,
9 Remedial Alternative #3 here is our preferred alternative.
0 One thing that we recognize is that there may be some need
to incorporate some institutional controls further down
the line if, in fact, this didn't seem to be effective.
However, we sort of separated these out. So
when you comment, please feel free to comment on any of
these or any combination of these that you feel may be an
1
2
3
4
5
6 effective option for the site.
7 We've talked about them individually, but
8 they can be combined. And if there's any specific
9 questions about combining them - yeah?
20 UNIDENTIFIED SPEAKER: why is there no option for
i bioremediation?
22 MR. MONTGOMERY: I'll repeat the question. The
23 question is: Why is there no option for removal and
bioremediation?
UNIDENTIFIED SPEAKER: Removal and bioremediation.
Page 25
1 MR. MONTGOMERY: AS an in-situ technology or as an
2 ex-situ treatment system?
3 UNIDENTIFIED SPEAKER: Either-or.
4 MR. MONTGOMERY: okay. Well, we haven't really
5 decided if we were to do the extraction and treatment
6 system, what type of treatment would work best. So I
7 think that we've talked about various options for a type
8 of treatment system once you get the water up to the
9 surface of the site.
10 UNIDENTIFIED SPEAKER: I mean, the material itself
11 is relatively close to the surface, isn't it?
12 UNIDENTIFIED SPEAKER: oh, you are talking about
13 for the sumps, not for the groundwater?
14 UNIDENTIFIED SPEAKER: Well, that's - I'm talking
15 about getting the contaminated material out and also
16 getting to the groundwater too as part of it.
17 MR. MONTGOMERY: FOF the Source.
18 UNIDENTIFIED SPEAKER: It's a long-term way to get
19 rid of the waste.
20 MR. MONTGOMERY: For the waste pits themselves.
21 One of the reasons why we haven't considered
22 bioremediation is that this is a sulfuric acid waste.
It's a very low pH waste. And you would have to
effectively neutralize it before you could bioremediate
25 it. Because in general, the pH of this waste is
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I fairly low, it's very acidic. And you would have to go
2 through a neutralization — well, first you would have to
3 excavate it.
4 We did a trial excavation at the site a
5 number of years ago. We found that excavating this waste
6 is very difficult to do. At a minimum, you have to do it
7 inside of an enclosure. And the time required to excavate
8 all the waste inside of an enclosure involves a lot of
9 time and a lot of money.
10 And I think that the residents who live near
11 the site also felt very strongly about the excavation and
12 enclosure at the time that we were considering it. So
13 there's a number of steps to consider in these processes.
14 You know, hioremediation would be a very good technology
is if, in fact, excavation were simpler for the sumps
16 themselves — were simpler and more cost effective,
i? and then the subsequent neutralization of that prior to
18 the bioremediation were, in fact, easy and effective and
19 cost effective.
20 And so - I mean, that's just my cut on
2 i those technologies and how they would or would not be
22 applied to the sources shown. We've already decided on a
23 remedy for the sumps themselves, and that's a closure and
24 containment system.
25 MS. GILMOUR: can we get people's names, also, if
Page 27;
i you are giving a formal comment. j
2 MR. MONTGOMERY: Well, right now we're not really j
3 in the formal comment portion for the groundwater. As j
4 soon as we get these questions out, if they are
5 clarification questions, then we'll stop and we'll have
6 the formal comment period. Fraser has a mike and he'll j
7 walk around and people can comment. And I'll sit down, j
8 because you are not really addressing your comments to me;
9 you are addressing them to the recorder.
10 UNIDENTIFIED SPEAKER: Do you have any idea when
11 you will start — and use your imagination, any idea at
12 all when you think this whole project will be completed?
13 MR. MONTGOMERY: Brian, do you want me to go ahead
14 and answer that, the construction?
15 MR. SWARTHOUT: Sure.
16 MR. MONTGOMERY: The construction of the closure
17 and containment system should start sometime early next
18 year. So January, February, March. The design will be
19 completed in December. And that construction is scheduled
20 to take anywhere from ten months to a year, maybe a little
21 bit more than a year. So, roughly, two years.
22 UNIDENTIFIED SPEAKER: It could be completed in
23 two years?
24 MR. MONTGOMERY: Done.
25 UNIDENTIFIED SPEAKER: You were talking about...
Page 28
1 MR. MONTGOMERY: with some additional stuff. Like
2 I think, with the golf course, it may take some additional
3 time to do the landscaping and to sod it.
4 UNIDENTIFIED SPEAKER: That's COSmetic.
5 UNIDENTIFIED SPEAKER: You were talking about
6 permits and things of that nature and getting approvals.
7 EPA is the government, if you can't get permits, then nobody
8 can get permits.
9 MR. MONTGOMERY: There are other governments. I
10 think if you talk to any local businessman in Orange _
11 County they'll probably tell you there are too many
12 government regulations. But you are basically correct.
13
UNIDENTIFIED SPEAKER: Let's be done with this.
14 This has been going on for over 15 years.
15 MR. MONTGOMERY: Right. We see that as an
16 advantage to our option in that we wouldn't have to get
17 any permits to do this.
18 UNIDENTIFIED SPEAKER: Good.
19 MR. MONTGOMERY: But if you are going to discharge
20 water, we don't actually have to get a permit, but we
21 might ask the oil companies to get a permit from the local
22 Regional Water Quality Control Board just so that the
23 Regional Board knows that if we were to do an extraction
24 option, that they would know that we were pumping water
25 into a creek or something like that.
Page 29
i But, you know, we can under Superfund
2 authority not get permits. We have to comply with them,
3 but we don't necessarily have to get them all the time.
4 So that's a good question.
5 MR. BENNETT: Mike, one comment this year, your
6 visual aids have really improved over the last year or so.
7 They are really, compared to a couple years ago,
8 impressive.
9 I have a real comment, a question. Brian
10 talked about the cap design and you are doing the
11 underground water. They come together on that area just
12 north of Los Coyotes. Could you comment on some of the
13 design thinking that put the wall out there and how that
14 combines with Alternative #3. You know — do you
15 understand the question? Could you give us a little bit
16 more thinking that went into putting the wall out there?
17 How are you going to worry about the pooled water that's
18 going to be on top of it?
19 MR. MONTGOMERY: Yeah, it's more philosophy.
20 Okay? People can generally see this.
21 The sump caps are going to be here and here
22 (indicating), right (Slide #3)? And everybody knows this
23 is all on a hillside. You have a lot of up-land area
24 here, right? And it's undeveloped. And it could become
25 developed. And if it were to become developed, you would
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1 have even more run off from this up-land area. And that
2 water runs from the up-land area under Rosecrans in a
3 culvert right about there (indicating) and on to the site.
4 And it eventually runs on to the golf course (Slide #3).
s And so you have a large area here that in
6 the winter season gets a lot of water. And you get
1 standing water. And you actually get a creek out there
8 during high-rain events. So philosophically, Chuck — you
9 have to listen to my answer if you ask a question. It's a
10 rule. We would line this area along here (Slide #3)
11 (indicating). Potentially look at diverting the water
12 that runs onto the site in really high-peak events, if
13 that makes sense. But for the most part, we just want to
14 keep this water from ponding up in here and getting into
is the shallow perched units and moving solubilized
16 contamination, which is contaminants, not the hard, gooey
17 waste stuff that comes to the surface. But like sugar in
18 your tea when you stir it up, dissolves in water. The
19 chemicals that are in the tar do that to some degree.
20 They get into the water — you understand
21 these processes, but I'm generally answering the question
22 for everybody. They get into the water and that water
23 flows down. And sometimes those contaminants adsorb or
24 attach themselves to clean soil particles underneath the
25 pits themselves. And so you will get 40, maybe 30 feet
Page 31
1 underneath the bottom of that black, gooey stuff. And
2 you'll have soil that looks clean but smells bad.
3 And if you introduce — if you allow this
4 water to continue to filter through that area, it will
5 over time release these chemicals from those soil
6 particles and get back into the water and potentially go
7 down to the regional aquifer.
8 So, philosophically, the notion here is that
9 we are just going to dry out that whole area underneath
10 the sumps themselves, not let any water get in there so
11 that none of the waste that's down there, not the black,
12 gooey stuff but the absorbed low concentration
13 contaminants, gets into that regional aquifer. That's the
14 philosophical approach to that alternative.
15 UNIDENTIFIED SPEAKER: can I ask another one?
16 MR. MONTGOMERY: Yes, feel free.
17 UNIDENTIFIED SPEAKER: Even though the benzene
18 hasn't reached the aquifer yet, because it doesn't move as
19 fast as some of the other contaminants, right, so will it
20 reach it in 20 years even if you contain it as you
21 propose?
22 MR. MONTGOMERY: well, one thing that I think we
23 can consider here is that the waste has already been out
24 here for 50 years. And so we've had the sumps out there
25 generally in an unlined and uncapped condition for the
.4 last 50 years.
2 So I would expect that the potential
3 migration rates that would occur at the site, we would see
4 that migration of those contaminants. And benzene moves
5 fairly quickly relative to some of these other
6 contaminants.
7 So we would expect to see it. It also
8 degrades very quickly. And the spreading effect of these
9 perched units may have done a lot to effectively
10 allow dispersion and really just an overall dilution of
11 the concentrations of the benzene and the higher end
12 chemicals that would be of concern.
13 UNIDENTIFIED SPEAKER: But part of this is perched
14 and part of it isn't, right? So part of it -
15 MR. MONTGOMERY: No. The water is perched before
16 it reaches the regional aquifer. It has to go through a
n couple of lenses. That's kind of a simplified diagram
18 (Slide #4). And I think if you can take a second and go
19 back and look at these charts back here, you can see those
20 tan layers are all lower permeability layers that the
water has to go through before it gets to that regional
21
22
23
aquifer.
So no matter what part of the site the water
24 goes through, it's got to go through some of those layers.
25 And that takes time and spreads it out and dilutes it and
Page 32 Page 33
i disperses it.
2 UNIDENTIFIED SPEAKER: Mike, can you state it
3 clearly? I'm confused, and there might be other people
4 too. Basically, you are going to issue a ROD (Record of
5 Decision) regarding groundwater that says, since you've
6 chosen Alternative #3, you follow the ROD or the solid
7 waste that is put on the cap. Is that what it is?
8 There's no real enforcement? There's nothing going on
9 other than what you are saying to follow the resolution
10 that you've decided already?
11 MR. MONTGOMERY: No. I think we will have to
12 after the remedy selection process, which is after this
13 public comment period which is going to end on April the
14 5th, so if you have comments that you want to give us in
15 writing and not here tonight, if you are bashful, or you
16 just want to put it in writing what it is you have to say,
17 send that to us before April 5th, and we will address
18 those comments in our Record of Decision. Most of you all
19 know that process, because you have commented before on
20 the decisions.
21 But then we would make the decision and then
22 we would potentially issue an order or negotiate that.
23 But we — the advantage of this one is that we integrate
24 it right into the design work. So if there was an order,
25 we just say, "Hey, do this stuff right along with the
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1 other stuff you are doing." Or if we were negotiating it,
2 then we would put it all on the table and negotiate it.
3 UNIDENTIFIED SPEAKER: So your Record of Decision
4 is to follow through with Alternative #3?
5 MR. MONTGOMERY: Right.
6 UNIDENTIFIED SPEAKER: Can you, therefore, speed
7 up the process at all by -
8 MR. MONTGOMERY: We can speed up Alternative #3 so
9 that it's integrated into that design. I have confidence
10 we can speed it up so that it's integrated into that
11 design and done with the closure and containment system.
12 So we can do a conceptual - Brian just said
13 we just got the conceptual. If we get the remedy
14 selection soon, we can do it. And I think that in
15 general, the Me Coll Site Group has felt that this is an
16 acceptable alternative. So from a son of precedential
17 standpoint I think we have got a good alternative in that
18 all the parties agree. EPA, assuming the community agrees,
19 MSG generally agrees that it's a good plan, or it's my
20 understanding at this point that they do.
21 Then I think they would be open to
22 integrating it into the ongoing work. We could get an
23 enforcement mechanism out there if we needed to do that,
24 and have it done by December when the design is going to
25 be done.
Page 3:
i UNIDENTIFIED SPEAKER: what would there be to
2 enforce?
3 MR. MONTGOMERY: Well, it would be an additional
4 scope. It would be a little extra work. We would be
5 tacking a little extra work on the work that we already
6 have in the order. And there's still a question out there
7 right now as to how we are going to do the construction
8 from an enforcement standpoint. 1 covered a little bit —
9 UNIDENTIFIED SPEAKER: who's going to pay the
10 bills?
11 MR. MONTGOMERY: It's just a question of whether
12 or not we negotiate an agreement or whether or not we use
13 an order like we've used.
14 MS. GILMOUR: would you please repeat the
is question?
16 MR. MONTGOMERY: I'm sorry. I said I was going
17 to do that and I didn't. Sorry.
is The last question was: How are we going to
19 get this work done from an enforcement standpoint and when
20 is it going to get done?
21 Okay. We can go to the official comment
22 portion. I'm going to sit down. Fraser is going to stand
23 up. If you could state your name, spell it if it's a
24 difficult spelling. And what else was I supposed to say?
25 MR. FELTER: You're taking all my lines.
Page 36
1 MR. MONTGOMERY: Sorry.
2 MR. FELTER: can you hear me? *
3 All right. This is the officially required
4 public comment period for this proposed plan for the
5 groundwater at this McColl site. The way this works is as
6 Mike had described. You are invited to comment and we
7 will be receiving those comments. The transcriptionist
8 will take it down. Again, she would appreciate you
9 spelling your name if it's an unusual spelling, and also
10 your address if possible.
11 We will not respond this evening to your
12 statements unless there is some matter of fact that is
13 misstated. For instance, if someone says "black" is
14 "white,* Mike or Brian will correct that. But that's the
15 only time we will respond.
16 The responses to your comments this evening
n then will be incorporated in an official responsiveness
is summary, and that will be filed as pan of the
19 administrative record.
20 Any questions as far as the process this
21 evening? All right. I hereby declare the comment period
22 open. Would anyone like to comment on the proposed plan?
23 Yes, Mr. Bushey?
24 [Public comments begin.]
25 MR. BUSHEY: My name is Dave Bushey, B-u-s-h-e-y.
Page 37
1 I live at 1819 Fairgreen Drive in Fullerton. And 1 agree
2 with your plan as proposed. And I thank you for all your
3 work.
4 MR. FELTER: Thank you.
5 Do we have any other comments? Yes,
6 Mr. Bennett?
7 MR. BENNETT: My name is Chuck Bennett,
8 B-e-n-n-e-t-t. I'm a resident of Fullerton and part of
9 the FHCA. I would like to make the comment that the
10 selection of #3 or #1 would have been the fastest
11 alternatives at implementation. And I'm pleased to see
12 that the Agency has chosen one of the prompter remedial
13 plans for the groundwater.
14 And I think — my sense of the community is
15 that they are supportive of either #1 or #3 as the
16 choices.
n MR. FELTER: Thank you.
18 Yes, sir?
19 MR. SOEOEL: My name is Gene Siegel, S-i-e-g-e-l.
20 I live at 2617 Tiffany Place.
21 Looking over the four alternatives, I would
22 agree with EPA that Alternative #3 does make the most
23 sense. From looking at the factors of overall protection,
24 long-term effectiveness, cost effectiveness, and
25 short-term risk, if you look at all four of those factors, j
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i they seem to be the best overall of all the alternatives
2 MR.FELTER: Thank you.
3 Do I have another comment? Yes, Mr. Olquin?
4 MR. OLQUIN: it's Alex Richard Olquin,
5 O-1-q-u-i-n. My address is 1506 Baronet Place, City of
6 Fullerton. I'm a member of FHCA. I agree with
7 Alternative #3.
8 There is a concern I have regarding down the
9 road that long-term maintenance and monitoring, that
10 diligence is served. And that I would hope that in the
11 issuing of the ROD, that an explanation would be made and
12 comments given by US EPA regarding that MSG will stand by
13 and monitor the wells and that we will not have problems
14 hereafter, once the 30-year period is over or maintenance
is of the cap and implementation of their orders.
16 MR. FELTER: Thank you.
17 I've just been reminded that several times
18 this evening during this period the initials "FHCA" have
19 been used. For the record, that stands for the "Fullerton
20 Hills Community Association."
21 Do I have any other comments?
22 All right. Well, hearing no others, I
23 officially conclude the official comment period and turn
24 the meeting over to Mike and Brian for general questions.
25 Thank you.
Page 39
i [End of public comments.]
2 MR. MONTGOMERY: Thanks, Fraser.
3 So are there any other general questions
4 about the site status?
5 UNIDENTIFIED SPEAKER: I'm from Newport Beach and
6 the reason I came here is that I feel if it gets
7 contaminated into everybody's water, it's real difficult
8 to reverse it once it happens. And you are playing with
9 something - you're talking about $1, $2, $3 million, but
10 it's a big, big issue.
11 So what are you going to do when it gets
12 dangerous? How do you know when it gets dangerous?
13 MR. MONTGOMERY: That's a good question. The
14 important thing to keep in mind is that under the
15 Superfund program, we have a five-year review period. And
16 we go back every five years and review the remedies that
17 we select. They're not often changed.
is But in the case of groundwater remedies,
19 they are quite often modified. And there would be an
20 opportunity to modify this decision during that five-year
21 review period.
22 And I think that we're real concerned. And
23 I think we have taken quite a long time to make
24 sure that we can make a decision like this. You know, it
25 almost takes a longer time to make a decision not to do a
Page 40
•i lot than it takes to make a decision to do a whole lot,
2 because we've got to say with confidence that we don't
3 think it's a real significant problem.
4 Now, built into these plans is $1.5 million
5 of monitoring that's intended to go into perpetuity.
6 UNIDENTIFIED SPEAKER: But it is Superfund, SO
7 it's not benign. It's a big deal.
8 MR. MONTGOMERY: it's a fairly big deal. But I
9 think what you have also got to take into account is that
10 even though there is a hundred thousand cubic yards of
i i waste out here, this is not the type of waste that often
12 serves as being a real problem for groundwater
13 contamination. That's a real generalization.
14
15
6
7
8
9
20
21 even though Superfund, you know, it's a big deal, and I
22 can tell you the reason it's a big deal is because of the] 22
23 hundred thousand cubic yards of waste that's at the site.
14 UNIDENTIFIED SPEAKER: That's why it's one of the
25 top five sites in the United States.
But in any community you have got leaking
underground storage tanks that have pure product that go
into regional aquifers where the water is real shallow.
You know, that could potentially pose a greater threat
than the McColl site as we know it. And it hasn't been
investigated yet.
So you have to weigh all these risks. And
Page 41
1 MR. MONTGOMERY: But just because you have got
2 this big source, doesn't mean that you automatically have
3 a big groundwater contamination problem. You know —
4 that's why you spend a lot of time investigating it.
5 Gene Siegel had his hand up, I'm sorry.
6 MR. SIEGEL: As I indicated earlier, I'm in favor
7 of Alternative #3. But just as a question, #2, you
8 indicated that there are negotiations. And naturally as
9 well, some people are going to be curious about that
10 (inaudible) point of view (inaudible) EPA is going to pay
11 everybody $100,000 to put a well in their backyard, you
12 may have everybody go into Alternative #2. So that needs
13 some clarification.
14 MR. MONTGOMERY: well, I think that at the time
15 that we talked about this Alternative (#2), we would be
16 talking about — EPA would prefer not to implement these
17 remedies. And we're going to ask the McColl Site Group
18 and quite possibly the section of the government that's
19 found liable to implement the remedies, and so there would
20 be negotiations.
21 And we would have to address the fact that,
hey, maybe some people are going to say, "No way, I'm not
23 going to do this unless you give me a whole bunch of
24 money." Then we have to put a price tag on it and say,
25 "Well, what's it worth?" And this is difficult. I mean,
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i that's son of the problem with that Alternative (#2).
2 There's different ways to approach it. But
3 you know, do you want to have people have to deal with
4 restrictions on their deeds or how you enforce it with
5 time? You know, unless you have a deed restriction — if
6 you don't have a deed restriction then you are son of
7 going on a hand shake and a promise.
8 And that's great for the residents that live
9 there now or whoever lives next to the site, but what
10 about in 50 years or 100 years? There's a lot of
11 hypothetical questions you can get into with that
12 particular option.
13 One of the reasons why we didn't pick it
14 also is that the Regional Board doesn't particularly like
15 it. And the Orange County Water District, they both said
16 that they weren't particularly fond of it.
i? And it may be something that would be
is considered in a five-year review period. If you find
19 that, in fact, the concentrations of the regional aquifer
20 are getting worse or a little bit worse or they are not
21 getting any better, you might go out there and say, "Hey,
22 let's talk to the people that live next to the site, the
23 people that own property near the site to try and get them
24 to agree with us not to put any wells in." The likelihood
25 that people are going to put wells in is real low.
Page 43
i UNIDENTIFIED SPEAKER: That's the question I
2 asked. Obviously, Alternative #3 makes sense. If you
3 look at - if you weigh the factors of high, medium and
4 low — you could put a point value of high, medium and
5 low. And the important fact is it comes up better than
6 the other alternatives.
7 But your assumption is predicated on that
8 fact that there are no wells in the area. And that's why
9 #2 is there to stop people from having wells. I don't
10 foresee putting wells there. I'm not sure anyone would
11 since you have the ability to get water from Fullerton.
12 But how do you restrict somebody -- let's
13 say you have ten people in the area who want to put a well
14 in. Is there going to be some restrictions because they
15 put a well in? Aren't they going to be pulling up
16 contaminants?
17 MR. MONTGOMERY: Legally we can't. Legally you
18 can't. Legally people have the right to their — there's
19 a legal term for them. But, basically, your property line
20 goes down. And it includes all that stuff down there. So
21 if you really want to put a well in; you can do it.
22 It wouldn't make any sense for a residential
23 person living in that community to want to put a well in.
24 You are already served.by water. It would only cost you
25 more money to install a well and operate a well.
Page 44
1 UNIDENTIFIED SPEAKER: So why have #2, because
2 Alternative #2 only pertains to — you know, negotiating
3 people not to have a well. Other than that, #2 and #1
4 seem to be the same.
5 MR. MONTGOMERY: They're real similar. The only
6 difference is the agreement not to put the well in.
7 Next question?
8 UNIDENTIFIED SPEAKER: Well, within the City Of
9 Buena Park they would have to go through the city to get
10 permits, and that would be overlooked — that would take a
11 look at that for one.
12 The most obvious one is Mr. McAuley who
13 would like to have water out of the ground, then he
14 wouldn't have to pay the city to water the golf course.
15 But that would be - because he would be using more water
16 than any single resident within the whole area. But, you
17 know, he would still have to go through the city for
is permits even though it's his property.
19 MR. MONTGOMERY: A well permit.
20 UNIDENTIFIED SPEAKER: A well permit, plus the
21 State.
22 MR. MONTGOMERY: Would they deny the permit, do
23 you think?
24 UNIDENTIFIED SPEAKER: it all depends on what
25 happens.
Page 45
1 MR. BENNETT: Mike, I think one of the aspects you
2 didn't raise is that in the groundwater study that's been
3 done, there's been a very intense risk assessment of the
4 conuminated water in both the amounts of contaminants and
5 the levels. And they have not been found to be a terrible
6 risk -1 don't know what the right term is. But they are
7 not deemed particularly risky. The figures have been very
8 low in terms of risk.
9 And that's why the method of control is not
10 as extreme as, for instance, if there were high levels of
11 known carcinogens, that you'd say, "Well, we do have to
12 pump and treat," or something like that. So that's one
13 aspect of it. I think that's important.
14 MR. MONTGOMERY: sure, okay.
15 Go ahead, Richard.
16 MR. OLQUIN: i had a question for you, Mike.
17 Something that has been troubling me for a while with
18 regards -1 know that there is a legal side of this
19 involvement or branch of the government. Currently MSO is
20 on the site doing the work.
21 Now, in regards to both the groundwater,
22 plus implementation of the cap, even though MSG is doing
23 the work now, if at a later time it's ruled in court that
24 culpability falls onto the government, in essence, the oil
25 companies then seek reimbursement from the government.
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i What's going to happen to us if there is a problem 15
2 years from now as opposed to 30, and it's found that no
3 longer is it the case that MSG is found to have any
4 responsibilities as far as financially helping us with the
5 situation?
6 MR. MONTGOMERY: it's my understanding in the
7 process of that ruling that they're going to go through an
8 allocation hearing process, and then a judge is going to
9 determine a relative percentage of responsibility. And
10 that allocation and the ruling could subsequently be
11 appealed.
12 And sol think what you '11 find is that the
13 parties are going to be arguing over whether or not the
14 ruling is fair. And then there will be allocations,
15 interim allocations. But what you won't find, because
16 this particular judge has already ruled that the McColl
17 Site Group Companies are responsible parties, they will
is not be let off the hook.
19 In other words, the judge is not likely to
20 say, "I was wrong about my ruling about this group of
21 people being responsible and now this group of people is
22 responsible." He's going to throw all those people into a
23 pot and say, "Well, you know, you're responsible for "X"
24 percent and you're responsible for "Y" percent." And then
25 somebody is going to appeal it.
Page 47
i So the fact of the matter is that a lot of
2 money is going to change hands between these parties. But
3 in the meantime, you know, we'll continue to do the work;
4 we'll continue to ask the McColl Site Group to do the
5 work.
6 UNIDENTIFIED SPEAKER: what I was asking more was,
7 if there's a problem down the road?
8 MR. MONTGOMERY: Like 15, 20 years?
9 MR. BENNETT: Yeah. We live in earthquake
10 country. If it cracks open and falls on the heads of
11 government, are we suddenly going to have to fight the 100
12 pound gorilla?
13 MR. MONTGOMERY: who knows in 15, 20 years, is
14 there going to be a Superfund?
15 MR. SIEGEL: I think he answered the question. I
16 just don't think it was understood, your answer.
17 What happens is (inaudible).
18 COURT REPORTER: Excuse me, I cannot hear you.
19 Can you please use the microphone?
20 MR. MONTGOMERY: can you use the microphone?
21 MR. SIEGEL: Basically, you have a situation here
22 where the courts are going to determine that there's
23 multiple defendants in the case. The multiple defendants
24 are the McColl Site Group, maybe McAuley, it may be the
25 government. Whatever it is, it's multiple defendants.
Page 48
,i The court will then determine the percentage
2 of liability. That is what the McColl Site Group probably
3 has done by bringing the government into a federal case.
4 They want some declaratory relief. They want the court to
5 determine the rights and responsibilities of the parties.
6 They want some indemnification, money back.
7 They want contributions, some money back.
8 They want the court to determine the percentage of
9 liability; how much percent they have to pay, how much
10 percent the government has to pay.
11 When the court make its ruling, whatever
12 that ruling is, and after all the appeals, there will be a
13 determination of 100 percent liability. But it may be
14 prorated, 53/47, 60/40, some number, so that if something
15 occurs down the road, there is still a judgment.
16 And down the road, whoever's percentage of
17 liability is their percentage, then they'll have to absorb
is their share. And if they pay 100 percent, they can go
19 after the other party for a contribution for that 50, 60
20 or 40 percent. And that's reciprocal back and forth,
21 whether it's the McColl Site Group or the government or
22 some other entity.
23 So whatever decision is made now, is the |
24 decision forever. You just won't have to relitigate it i
25 later on. You won't have to worry about relitigating it j
Page 49
1 theoretically because there will be a final determination
2 now in the present court hearing.
3 MR. MONTGOMERY: It helps to have a judge in the
4 neighborhood. I couldn't have done that.
5 But basically, I think another aspect of
6 that question is who is going to be managing the
7 contractor? Who's going to be responsible for going out
8 there and doing the inspection and checking the wells?
9 And the answer to that is we haven't really found out yet.
10 We don't really know yet. That's an issue.
11 MR. SIEGEL: And that's a big problem whether it's
12 the private sector or public sector, whether it's the
13 government or MSG, different rules apply. And if the
14 government controls the hiring of the contractor, that
15 could take years because of the different bidding
16 processes and the different things that have to be done.
17 If the McColl Site Group does that, they can
is handle it differently, and it can be done a lot faster.
19 So, hopefully, I think the public here, if there is any
20 comment to be made, I think the community here would
21 rather have the McColl Site Group retain the contract,
22 because it will be a lot faster. It's a different bidding
23 process. They can handle it a lot faster than going
24 through the government bidding. At least, that's my
25 understanding of the difference.
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I UNIDENTIFIED SPEAKER: (Inaudible).
2 MR. MONTGOMERY: Operations and maintenance, did I
3 say "O" and "M"? Operations and maintenance.
4 UNIDENTIFIED SPEAKER: I get a feeling from the
5 comment from the gentleman from Newport Beach that he's
0 not real sure that the community here feels comfortable.
7 In other words, are we taking the short route out to the
8 detriment of the entire county?
9 And you may want to go through how many
10 wells have been dug and tested, and the fact that the
11 majority of the wells, the vast majority of the wells,
12 show absolutely nothing, and that the amount of waste
13 that has been found is extremely small. And that that
14 amount has not been going up. In fact, there's been some
15 cases going down or almost nondetectable.
16 UNIDENTIFIED SPEAKER: can I make a comment? A
17 plume can be like this (indicating). A plume is a
is pyramid, inverted pyramid. You see nothing at the
beginning, and then all of a sudden you have got a lot.
20 MR. MONTGOMERY: I don't exactly follow you. I
21 mean, you know, it might be — you know, if you want to
talk specifically about the hydrology of the site and you
23 want to take a second. Marina West with the Orange County
24 Water District, who is sitting behind you with the
25 glasses, has studied these maps. She knows the subsurface
Page 51
1 very well. Melitta Rorty is here with ICF. Both of them
2 are hydrologists, and both are very familiar with the
3 subsurface at the site.
4 We've put a lot of wells out there. We have
5 done a lot of analytical work and I think we have a pretty
6 good handle on it.
7 Feel free to investigate that work. It will
8 be good to know that somebody besides us has read it.
9 UNIDENTIFIED SPEAKER: Mike, we've been a little
10 bit — there haven't been very many groundwater meetings
11 in the last couple of months. And I think at the last
12 kinds of ones we were discussing the fourth quarter
13 monitoring results. And at the time the levels of
14 contamination that were seen, the low levels, were
is declining in most wells I believe.
16 Is there a plan to continue that kind of
17 monitoring or an abridged version of monitoring or is that
18 going to be incorporated in the general monitoring of the
19 site?
20 MR. MONTGOMERY: we're going to continue to do
21 that monitoring. We might modify the monitoring plan a
22 little bit. And I think we are going to put one, quite
23 possibly two more wells further out here (Slide #3).
24 Because we are concerned that this well, P-10L, which is
25 in the upper portion of the regional aquifer has got some
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 52
of these Tetrahydrothiophenes in the 100 to 200 range. 1
And we'd really like to see a clean or a 2
very close to clean well in that regional aquifer out 3
here, so that we can definitively say - and maybe a 4
couple of them. I think it has been pointed out to 5
complement these other clean wells that are in the 6
regional aquifer to assure that we are not missing the 7
plume. 8
In fact, we have got a clean well in the 9
regional aquifer, and the plume is going off over here or 10
is going off over here (indicating), between our 11
monitoring points. 12
And in this case, at the moment, we have got 13
two or three in that regional aquifer. And we'd like to 14
get a few more out here. 15
And if that shows something totally 16
different, then I don't want to be back up here saying we 17
made a big mistake. Okay. 18
Thank you all for coming tonight. We'll 19
hang around for a little while afterwards if you want to 20
ask any questions. 21
Linda, do you want to give a little 22
two-minute update on the status of the property transfer? 23
MS. LEQUIRE: well, real briefly. The property in 24
question is the Rampart property. We're continuing to 25
Page 53
work with the County of Orange to get it on the Board of
Supervisors' agenda, so it can move forward. But in the
meantime, it actually is moving forward. There's a lot
of work being done between a lot of attorneys. The
attorneys representing Mr. McAuley, representing the
County of Orange and representing MSG.
But from all indications, I've had the
opportunity to talk to all the supervisors' offices. They
know that it's going to be coming forward, hopefully, in
the next couple of weeks to them. And I think it looks
real positive. I have felt that way for sometime. And I
do think that we have a real good opportunity to resolve
the Rampart property - ownership of the Rampart
property.
MR. MONTGOMERY: Great. Thank you.
Thanks everyone.
(END OF PROCEEDINGS.)
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EXHIBIT C
MARCH 14,1996
PUBLIC MEETING COMMENTS
-------
-------
Mr. Felter:
Mr. Bushey:
Mr. Felter:
Mr. Bennett:
I hereby declare the comment period open. Would anyone like to
comment on the proposed plan?
Yes. My name is Dave Bushey, B-u-s-h-e-y. I live at 1819 Fairgreen Drive
in Fullerton. And I agree with your plan as proposed. And I thank you for
all your work.
Thank you. Do we have any other comments?
Yes. My name is Chuck Bennett, B-e-n-n-e-t-t. I'm a resident of Fullerton
and part of the FHCA. I would like to make the comment that the selection
of #3 or #1 would have been the fastest alternatives at implementation.
And I'm pleased to see that the Agency has chosen one of the prompter
remedial plans for the groundwater.
And I think - my sense of the community is that they are supportive of
either #1 or #3 as the choices.
Mr. Felter:
Mr. Siegel:
Thank you. Yes, sir?
My name is Gene Siegel, S-i-e-g-e-l. I live at 2617 Tiffany Place. Looking
over four alternatives, I would agree with EPA that Alternative #3 does
make the most sense. From looking at the factors of overall protection,
long-term effectiveness, cost effectiveness, and short-term risk, if you look
at all four of those factors, they seem to be the best overall of all the
alternatives.
Mr. Felter:
Mr. Olquin:
Thank you. Do I have another comment?
Yes. It's Alex Richard Olquin, 0-l-q-u-i-n. My address is 1506 Baronet
Place, City of Fullerton. I'm a member of FHCA. I agree with Alternative
#3.
There is a concern I have regarding down the road that long-term
maintenance and monitoring, that diligence is served. And that I would
hope that in the issuing of the rod, that an explanation would be made and
comments given by US EPA regarding that MSG will stand by and monitor
the wells and that we will not have problems hereafter, once the 30-year
period is over or maintenance of the cap and implementation of their
orders.
-------
Mr. Felter: Thank you. I've just been reminded that several times this evening during
this period the initials FHCA have been used. For the record, that stands
for the "Fullerton Hills Community Association.11
Do I have any other comments?
All right. Well, hearing no others, I officially conclude the official comment
period and turn the meeting over to Mike and Brian for general questions.
Thank you.
-------
EXHIBIT D
WRITTEN COMMENTS FROM STATE OF
CALIFORNIA AND
MCCOLL SITE GROUP
-------
-------
TATE OF CALJfORNlA—CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY
PETE WILSON. Governor
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
400 P STREET. 4TH FLOOR
P.O. BOX 800
SACRAMENTO, CA 95812-OftOO
(916) 322-8046
March 29, 1996
Pott-lf Fax Note
Mr. Michael Montgomery
Remedial Project Manager
U.S. Environmental Protection Agenc
Hazardous Material Division
75 Hawthorne Street, MS: H-6-1
San Francisco, CA 94105.
MCCOLL GROUND WATER OPERABLE UNIT PROPOSED PLAN
Dear Mr* Montgomery:
The California Department of-Toxic Substances Control (DTSC)
has reviewed the United States Environmental Protection Agency's
(U.S. EPA) Proposed Plan (Plan) for the Ground Water Operable
Unit at the McColl hazardous waste site. U.S. EPA issued the
Plan on February 27, 1996 in the form of a fact sheet titled "EPA
announces proposed plan for contaminated groundwater at the
McColl Super fund Site" t February 1996.
The DTSC has been given the opportunity to review and
provide comments to U.S. EPA on draft and final versions of the
various documents U.S. EPA used in developing the Plan. The
documents reviewed included those of the remedial investigation,
feasibility study (GWFS), and the baseline risk assessment, which
were prepared by either U.S. EPAvs contractor or the McColl Site
Group, the responsible parties. Also reviewed were the
applicable or relevant and appropriate requirements (ARARs), and
the nine criteria analysis, both of which were included in the
GWFS. (A formal alternatives risk assessment document was not
prepared). Individuals reviewing the Plan and the various
support documents include Dr. William Vance and Dr. David Chan of
the Office of Environmental Health Hazard Assessment,
Ms. Kathleen Considine of DTSC's Geological Services Unit and
Ms. Caroline Rudolph, DTSC's project manager for the McColl Site.
The DTSC9s comments and concerns regarding the Plan are
derived from review of the draft and final documents along with
that of the Plan. The Department's comments on the Plan are as
follows, with Ms. Considinevs comments (related to the GWFS)
provided as an attachment to further clarify DTSC's primary
concern with the presently proposed Plan:
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Mr. Michael Montgomery
March 29, 1996
Page 2
Proposed Plan
Conceptually, U.S. EPA's Plan of infiltration reduction and
long-term monitoring appears to be realistic and implementable
considering the minimal contamination currently found within the
existing monitoring system. The Plan, denoted as Alternative 3
in the fact sheet, does lack an element of the alternative as it
was previously described in the GWFS: that of institutional
controls. Institutional controls are a means of ensuring the
efficiency and integrity of the long-term monitoring system.
DISC recommends that U.S. EPA's final Plan include at a minimum
the contingency of placing appropriate institutional controls if
data review of the completed long-term monitoring system (i.e.,
including the additional one or two wells proposed as part of the
Plan) indicates that such controls are needed.
If you have any questions regarding the DTSC's comments and
concerns regarding the Plan please contact me at (916) 324-2857.
Sincerely,
Caroline Rudolph
Sr. Hazardous Substances Scientist
Special Projects Branch
Enclosure
cc: Mr. Robert Holub
Santa Ana Regional Water Quality Control -Board
• 3737 Main Street, Suite 500
Riverside, California 92501-3339
Ms. Marina West
Orange County Water District
P.O. Box 8300
Fountain Valley, California 92728-8300
Mr. Lynton BaJcer
California Air Resources Board
P.O. Box 2815
Sacramento, California 95812-2815
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STATE OF CALIFORNIA— CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY
PETE WILSON. Gownpr
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
400 P STREET. 4TH FLOOR
P.O. BOX 806
SACRAMENTO. CA 9581 2-0806
MEMORANDUM
To:
Caroline Rudolph
Site Mitigation Division
301 Capitol Mall, Second Floor
Mail: P.O. Box 806
Sacramento, California 958 12-0806
From:
Kathleen Considine ,
Site Mitigation Branch
Geologic Services Unit
301 Capitol Mall, Fourth Floor
Mail: P,O. Box 806
Sacramento, California 95812-0806
Date: March 2 1,1 996
Subject: McCoil Final Groundwater Feasibility Study
Reviewed by: Marie McCrink, RG, CHG
Geologic Services Unit
INTRODUCTION
As requested, I have reviewed the document Feasibility Study Report, Groundwater Operable
Unit, McCoil Site (GWFS), dated February 7,1996. The GWFS was prepared by ICF
Technology Incorporated (ICF) for the United States Environmental Protection Agency (U.S.
EPA). The GWFS presents the remedial alternatives for contaminated groundwater at the
McCoil Site.
CONCLUSIONS & RECOMMENDATIONS
The chosen Remedial Alternative 3 (RA 3) involves source controls, groundwater monitoring,
infiltration reduction measures, and institutional controls, according to the discussion on page 6-
23 of the GWFS. The GWFS then makes the statement on page 6-41 that" ...Remedial
Alternative 3 would be the easiest to implement, in the event that the required area of
institutional control is reduced or eliminated with remedial action." The RA 3, as presented 10
the public makes no mention at all of institutional controls. 1 strongly recommend that
institutional controls be retained as part of RA 3.
o
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Caroline Rudolph
March 21,1996
Page 2
The reason why institutional controls should be retained is as follows. The total horizontal and
vertical extent of contamination has not been determined off-site in the down-gradient direction.
Additional groundwater monitoring wells are proposed to resolve this issue and the area of
institutional control cannot be adequately defined at this time- A reduction in contaminant levels
is expected after the source control and infiltration reduction measures are in place. However,
since the Orange County groundwater basin is non-adjudicated, .without institutional controls •"
there is no control on the possible installation and pumping of a private well(s) in the site
vicinity. This could changfc the groundwater flow direction and gradient and potentially pull
more contamination from the site*
If you have any questions concerning this memorandum, please call Kathleen Considine at (916)
323-3586 or CALNET 8-473-3586.
cc: Richard McJunkin, CEG., Chief
Geologic Services Unit
Site Mitigation Program
Robert Holub
Regional Water Quality Control Board, Region 8
3737 Main Street, Suite 500
Riverside, California 92501-3339
TOTPL P.04
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April 5, 1996
Serial No: EPA/MSG-033
U.S. Environmental Protection Agency
Region IX
Attn: Michael Montgomery
75 Hawthorne Street
San Francisco, CA 94105
Subject:.
Comments Provided by McCoIl Site Group
During U.S. Environmental Protection Agency (U.S.EPA)
Public Comment Period, Groundwater Operable Unit,
McCoIl Site, Fullerton, California
Dear Mr. Montgomery:
The purpose of this letter is to provide the formal comments of the McCoIl Site Group
("MSG") regarding the Remedial Investigation (RI), Feasibility Study (FS), Risk
Assessment (RA), and EPA's Proposed Plan for the Groundwater Operable Unit at the
McCoIl Site in Fullerton, California. These comments are prepared in response to the
U.S.EPA Public Comment Period which extends to April 5, 1996.
In response to Administrative Order 93-21, MSG has conducted routine groundwater
monitoring as part of a groundwater investigation which was begun by EPA in 1989.
Based upon that investigation, as well as the Remedial Investigation Report completed
by MSG, the Risk Assessment completed by EPA, and the Feasibility Study that was
initiated by MSG and subsequently completed by EPA, EPA has proposed a remedial
action plan which has identified Alternative #3 (described in the Feasibility Study
Report) as the preferred alternative. MSG supports the selection of Alternative #3 of
the Feasibility Study Report. The following points summarize the results of the overall
groundwater program and clarify certain aspects of the proposed alternative 'that should
be reflected in the Record of Decision.
Results of the groundwater monitoring conducted by both the EPA and
MSG, the Remedial Investigation, the Risk Assessment, and the Feasibility
Study Report, all indicate that adverse impacts to groundwater from waste
sumps at the McCoIl site are minimal.
215 East Orangethorpe Avenue • Suite 304 • Fullerton, California 92632 • 714/665-7391
The McCoIl Site Group is composed of: Shell Oil Company. ARCO. Phillips Petroleum, Texaco and UNOCAL
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Mr. Michael Montgomery -2- April 5, 1996
The health risk assessment was based upon the assumption that perched
groundwater would be used as drinking water. However, given that these
perched zones have no potential for use as drinking water, that assumption
was unnecessarily conservative.
EPA has raised concerns regarding potential difficulties in negotiating
institutional controls with adjacent landowners. However, institutional
controls should be considered for the McColl site and the area immediately
south of the site within the golf course property where implementation
hurdles should not pose a significant problem.
Completion of the surface remedy, RCRA-equivalent cover and sub-surface
barrier wall system, will significantly reduce the potential for the sumps to
impact groundwater in the future. Although construction of the surface
remedy will provide the primary means of reducing groundwater
contaminants, MSG supports the additional infiltration controls described
in Alternative #3, with the exception of the use of imported low
permeability materials outside of drainage ditches and redirection of
surface water running onto the property.
Continued monitoring and installation of up to two new monitoring wells in
the regional aquifer, lining of retention ponds and primary drainage
ditches, and reduction of infiltration through surface grading is appropriate
for the site. Use of imported low permeability materials outside of
drainage ditches and redirection of surface water running onto the property
would not provide significant benefits relative to the cost of implementing
these actions. Accordingly, use of low permeability materials and
redirection of surface water should be eliminated from further
consideration in the remedy.
EPA has chosen to identify Operable Unit #1 for groundwater separately
from Operable Unit #2 for the surface remedy. However, it is important
that the remedial design for Operable Unit #1 be integrated into the
design for Operable Unit #2. If EPA does not facilitate timely integration
of these designs, the cost and schedule for both remedies will be adversely
impacted.
Well W-6A is screened within the largely unsaturated and perched portion
of the "C" sand/silt packet. As such, groundwater retrieved from well W-
6A is not considered to be representative of the continuously saturated
portion of the "C" flow unit.
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Mr. Michael Montgomery -3- April 5, 1996
The "C" flow unit located within the La Habra Formation is not considered
to be a significant part of the regional ground water system. As stated in
the 1967 Department of Water Resources report Progress Report on
Groundwater Geology of the Coastal Plain of Orange County, the shallower
water-bearing deposits of the La Habra Formation consist of semiperched
aquifers of limited extent. The limited recharge area and the lack of
continuity of the coarse-grained deposits of the "C" flow unit indicate the
extent of the t!C"flow unit limited, and not anticipated to be regional in
nature.
The presence of THT compounds in the "D" flow unit has not been verified
by the quarterly monitoring program. THT was semi-quantified (0.6 ug/L
"J" qualified) in one sample from well P-1D upgradient of the sumps;
however, THT was not detected in the duplicate sample and was detected
in quality control samples. These results indicate that this detection of
THT was not valid. THT has not been detected in any "C"flow unit wells
with the exception of wells P-5L and P-10L. The underlying "D" flow unit
well P-5D indicates that the THT compounds detected in well P-5L have
not migrated downward at this location. A "D" flow unit well is proposed
to be constructed near well P-10L to confirm that THT compounds have
not migrated downward at this location.
Groundwater extraction (Alternative #4 of the Feasibility Study) does not
meaningfully reduce the toxicity, mobility, or volume of chemicals of
concern in the regional aquifer in comparison to the No Further Action
alternative, since data indicates constituents are naturally attenuated before
reaching the regional aquifer. Groundwater extraction could increase flow
velocities, and create downward hydraulic gradients between groundwater
flow units which, in fact, could result in increased mobility. Furthermore,
groundwater extraction would not be effective in reducing the
concentrations of the chemicals of concern to below background levels or
in addressing their concentrations at the source areas. Finally, treatment
residuals would be generated that would require further off-site waste
treatment and/or disposal.
The benefits of groundwater extraction (described in Alternative #4) are
overstated in the FS report. In particular, Alternative #4 will not
meaningfully increase long-term effectiveness, meaningfully reduce toxicity
and mobility or volume through treatment or enhance compliance with
ARARs.
MSG and U.S.EPA have developed a very productive and cooperative working
relationship which has resulted in effective resolutions to significant issues regarding the
RI, FS, and RA. The following specific comments are provided to give EPA additional
feedback.
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Mr. Michael Montgomery -4- April 5, 1996
Comment #1:
Performance of the health risk assessment on "unusable" perched
groundwater continues to be inappropriate since no pathway for health risk
exists, and any action by EPA on the basis of these risks is not warranted.
Assuming the "unusable" groundwater is "usable" for purposes of exposure
compromises the technical integrity of the risk assessment. Additionally,
this approach could mislead the public regarding potential risks posed by
the Site.
Comment #2:
MSG explained the inappropriateness of designating State Water
Resources Control Board (SWRCB) Resolutions 68-16, 88-63 and 92-49 as
applicable or relevant and appropriate requirements (ARARs) in its letter
to EPA dated January 23, 1996. The reasons set forth in that letter that
these Resolutions cannot be designated as ARARs still stand. MSG
understands that U.S.EPA intends to choose Alternative #3 as the remedy
for the McColl site and that the Resolutions will not be designated as
ARARs or TBCs for Alternative #3 in the Record of Decision (ROD).
MSG agrees that the Resolutions are not applicable to Alternative #3 and
therefore should not be designated as ARARs or TBCs in the ROD.
In addition, it is important that EPA and other administrative agencies understand
why the Resolutions cannot be designated as ARARs for any of the other
alternatives either. As explained in that letter, EPA's own guidance
provides that a state law or regulation "must be applicable to all
circumstances covered by the requirement" to be considered as a potential
ARAR. EPA, CERCLA Compliance With State Requirements (December
1989). In other words, a state requirement that does not apply generally
cannot be designated as an ARAR for a Superfund site. Because SWRCB
Resolution 92-49 is not being applied consistently in California at this time,
it cannot be designated as an ARAR for the McColl site.
As it is currently adopted by the SWRCB, Section G of SWRCB Resolution 92-49
requires that groundwater be restored to background levels, unless background
levels are determined not to be achievable, in which case groundwater must
remediated to meet local basin plan objectives. Resolution 92-49 does not allow
deviation from background levels or basin plan objectives under any circumstance.
Recognizing that there are situations where it is not technically or economically
feasible to restore groundwater to background levels or even to basin plan
objectives, the SWRCB has proposed an amendment to Resolution 92-49 that
would establish a containment zone strategy for sites where it is determined to be
technically or economically infeasible to meet the requirements of Resolution 92-
49. Within the containment zone, groundwater remediation would not be
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Mr. Michael Montgomery -5- April 5, 1996
required; instead, remedial efforts would be focused on containment rather
than restoration in that area.
The proposed amendments have not been formally adopted by SWRCB, but the
SWRCB has established an informal policy that allows Regional Water Quality
Control Boards (RWQCBs) to exercise individual discretion to implement
containment zone strategies. MSG is aware of the following sites within
California, where a containment zone strategy has been applied by the RWQCB
responsible for overseeing groundwater remediation, despite the fact Resolution
92-49, as currently promulgated, does not authorize such a approach. MSG has
not conducted a survey of all RWQCBs within the State; accordingly, this list of
containment zone sites should not be considered to be comprehensive.
Clorox Corporation, Oakland, California. The RWQCB adopted a
containment zone for a groundwater plume involving mercury. The
mercury was present at concentrations well in excess of the
Maximum Concentration Limit (MCL) and extended to off-site
properties. Although the groundwater in this area meets the quality
to be classified MUN under Resolution 88-63, it is not a current
source of groundwater municipal supply. A containment zone was
adopted providing for long term monitoring of this groundwater
plume.
Varian and Unysis sites, South San Francisco Bay Area.
Containment zones were adopted at both of these sites involving
chlorinated solvents in groundwater. Groundwater in these cases is
classified as MUN and sits overtop potable water supply aquifers.
The containment zones required long term monitoring of
groundwater quality in zones where concentrations were well above
MCLs. The monitoring programs were designed to ensure that
there is no significant migration of VOCs from the affected
groundwater zones to the deeper water supply aquifers. Remedial
activities beyond monitoring and natural attenuation were
apparently not required.
San Francisco Airport. Several containment zones have been
approved at San Francisco Airport involving hydrocarbons, metals,
and solvents. Separate containment zones were adopted depending
on the point of discharge of the groundwater to the bay or deeper
aquifer units. These containment zones provide for the long term
monitoring of groundwater where concentrations of hazardous
substances are many times in excess of MCLs.
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Mr. Michael Montgomery -6- April 5, 1996
Xerox Corporation in Irvine, California. This site involved
contamination of shallow groundwater by chlorinated solvents. The
site was remediated by a two-phase vapor extraction system to a
point that concentrations reached an asymptote but did not
materially lower with further remedial efforts. As a result, the
Santa Ana RWQCB approved a closure of the remedial activities
and removal of all remediation equipment. Long term groundwater
monitoring was required with action levels for further remediation
set in the range of approximately 1 ppm for several VOCs. The
action level concentrations in this "containment zone" are
approximately 200 times the MCL. Groundwater in the affected
zone would be classified MUN under criteria outlined in Resolution
88-63. The approach that adopted at this site appears to be the
equivalent of the containment zone as outlined under the proposed
amendments to Resolution 92-49.
Clearly, implementation of Resolution 92-49 is in a state of flux in the State of
California. RWQCBs currently have broad discretion to apply a containment
zone approach or to follow the strict requirements set forth in Resolution 92-49.
As a result, Resolution 92-49 is not being applied consistently throughout
California. Under the statutory requirements of CERCLA and EPA's own
guidance, Resolution 92-49 cannot be designated as an ARAR.
Moreover, as a practical matter, EPA has not been consistent in its designation of
SWRCB Resolutions 68-16, 88-63 and 92-49 as ARARs or "To Be Considered"
(TBC) criteria. MSG reviewed several of the Feasibility Studies (FS) and
Records of Decisions (ROD) prepared since 1992 for EPA-lead sites in California
with groundwater contamination. Attached is a list of the sites reviewed and a
summary of how the SWRCB Resolutions were applied at those sites. Of the 16
sites reviewed, SWRCB Resolution 92-49 was designated as an ARAR at only 2
sites and as a TBC at only one site. At no other site was SWRCB Resolution 92-
49 designated as an ARAR or TBC.
SWRCB Resolution 68-16 was designated as ARAR at 9 sites, but in all cases the
FS or ROD specified that Resolution 68-16 was being applied as an action-
specific ARAR applicable only to the discharge of treated groundwater. At 3
sites, SWRCB Resolution 68-16 was designated as a TBC, rather than an ARAR,
for the same limited purpose. At none of the sites was SWRCB Resolution 68-16
applied as an ARAR to set cleanup levels. Clearly, EPA has taken a flexible
approach to its designation of SWRCB Resolutions in the past. At one site, the
FS even reported that "EPA does not agree [with the RWQCB] that Resolution
68-16 is an ARAR."
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Mr. Michael Montgomery -7- April 5, 1996
Application of SWRCB Resolution 92-49 is currently in a state of transition; that
resolution cannot now be designated as an ARAR for the McColl site. In
conformance with statutory requirements and EPA's own guidance, Resolution 92-
49 should be redesignated as a TBC criteria or eliminated from consideration.
Moreover, as demonstrated by a review of other sites, EPA has clear flexibility to
designate SWRCB Resolutions 68-16 and 88-63 as TBCs as well or to eliminate
from the process entirely. To allow EPA and local agencies maximum flexibility
to evaluate ground water issues that may arise at the McColl site in the future, all
of the SWRCB Resolutions should be designated as TBC criteria or eliminated
from further consideration altogether.
Comment #3:
Under U.S.EPA's detailed analysis of the remedial alternative "Institutional
Controls" (Alternative #2), U.S.EPA states that "longterm institutional
control may be constrained by the priorities of the enforcing agency."
U.S.EPA farther states in the FS that institutional controls are "potentially
difficult to implement in that it involves the often complex subject of water
rights and negotiations with private property owners." The administration
of limited Institutional Controls is a viable remedial element for both
Alternative #3 and for the remedial strategy outlined to address THT
compounds described in Appendix A of the FS report. Institutional
controls would be useful, for example, to assure that cross-contamination
between flow units does not occur due to well construction activities.
Institutional controls are expected to be necessary only for the McColl site
and a portion of the Los Coyotes Country Club property. Because only
two separate parcels are involved, implementation problems are not
anticipated.
Comment #4
The Fate and Transport Study of THT Compounds (ENVIRON December
18,1995) indicates that THT compounds are being degraded, probably as a
result of biologically mediated processes. Additionally, the limited
infiltration controls proposed in Alternative #3 and the remedial action
selected for Operable Unit #1 should effectively isolate the THT
compounds within the sump areas from groundwater. Given the
degradation of THT compounds in groundwater and the isolation of the
sump areas from groundwater, the existing concentrations of THT
compounds in groundwater are not likely to be a permanent condition.
The comments provided in this letter provide further support for the conceptual
hydrogeologic model of the site developed in the RI and the selection of Remedial
Alternative #3, which is described in detail in the FS.
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Mr. Michael Montgomery -8- April 5, 1996
MSG has previously submitted comments to EPA on various deliverables during the
remedial investigation activities performed under the Administrative Order 93-21.
Although MSG is providing supplemental comments in this letter, the absence of
comments restating previous comments made to EPA should not be interpreted as an
indication MSG has abandoned any prior comments or positions. On the contrary, MSG
hereby reiterates its prior comments and provides this response to summarize key issues.
Yours truly,
A.T. Hendricker, Project Coordi
McColl Site Group
ATH\SLM:lf
p:\lAmccoll\03-4575d\public.com
Attachment
cc: State of California
Department of Toxic Substances Control
Caroline Rudolph (3)
Parsons Engineering Science
Ken Fredianelli
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ATTACHMENTTO MSG COMMENTS ON PROPOSED PLAN
FOR GROUND WATER REMEDIATION AT THE MCCOLL SITE
April 5,1996
Summary of EPA-lead Sites (1992-present)
Lawrence Livermore National Laboratory Site 300
Interim Record of Decision, September 1995.
Resolution 68-16 was designated as an action-specific ARAR for the discharge of
treated ground water only. Resolution 92-49 was not designated as an ARAR or
TBC.
Moffett Pederal Airfield - Operable Unit 5
FS Report prepared for Department of the Navy by PRC Environmental Management,
Inc., June 1, 1995.
Resolutions 68-16 and 92-49 were both designated as an action-specific ARARs to
be applied to remedial actions that discharge treated water to surface water.
Resolution 68-16 was not designated as a chemical-specific ARAR to be used to
set cleanup goals for the contaminated aquifers. Section G of Resolution 92-49
was designated as a chemical-specific ARAR applicable to setting cleanup levels.
Section G requires cleanup to background levels, unless background levels are not
attainable, in which case cleanup levels must:
1. Be consistent with maximum benefit to the people of the state;
2. Not unreasonably affect present and anticipated beneficial use of
such water; and
3. Not result in water quality less than that prescribed in the Water
Quality Control Plans and Policies adopted by the State and
Regional Water Boards.
Muscov Plum Operable Unit
RI/FS Report prepared for EPA by URS Consultants, Inc., December 1994.
Neither Resolution 92-49 nor Resolution 68-16 were designated as chemical-
specific ARARs. Resolution 68-16 was designated as an action-specific ARAR "to
the extent that treated water is reinjected into the aquifer/1 In other words,
Resolution 68-16 was applied to the site to develop a reinjection standard, not to
set cleanup levels.
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Fort Ord Superfund Site
Record of Decision, November 1994
Resolution 68-16 "is applicable to recharge of the treated water.11 Resolution 92-
49 was not designated as an ARAR or TBC.
United Heckathorn Superfund Site
FS Report prepared for EPA, July 1994.
"The SFBRWQCB has identified Resolution 68-16 as a potential ARAR for the
United Heckathorn Site. Although EPA does not agree that Resolution 68-16 is
an ARAR, EPA and the State of California agree that achieving the water quality
criteria identified above would meet the requirements of 68-16, regardless of
whether or not it is an ARAR." Resolution 92-49 was not designated as an
ARAR or TBC.
Aircraft Control and Warning Site
Record of Decision, December 1993.
"Resolution 68-16, the water anti-degradation policy, is a State ARAR for the
establishment of numerical limits for the reinjection of treated ground water into
clean areas (i.e.,high quality waters) of the aquifer, i.e.,outside of the
contaminated plume." Resolution 92-49 was not designated as an ARAR or TBC.
Tracy Defense Depot
Record of Decision, August 1993.
Resolution 92-49 was designated as a TBC.
George Air Force Base
FS Report prepared by International Technology Corporation, August 1993.
Resolution 68-16 was designated as an action-specific ARAR, but 92-49 was not
designated as an ARAR or TBC. The Report states that Resolution 68-16 applies
to activities that produce waste and result in a discharges to waters of the State.
Presumably, therefore, Resolution 68-16 was applied as a treatment standard. A
two-step balancing approach was established to implement 68-16: (1) determine if
a degradation may be allowed, and (2) establish the discharge that will meet the
objectives of 68-16.
10
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Brown & Bryant Superfund Site
RI/FS Report prepared by EPA, May 28, 1993.
State Resolution 68-16 was designated as an ARAR, but the contaminated aquifer
was determined not to be a potential source of drinking water under state or
federal law. As a result, EPA stated that Resolution 68-16 would only be
applicable to reinjection standards. Moreover, EPA determined that compliance
with Maximum Contaminant Levels (MCLs) under the Safe Drinking Water Act
would satisfy Resolution 68-16. Resolution 92-49 was not designated as an ARAR
or TBC.
Baldwin Park Operable Unit
FS Report prepared for EPA by CH2M Hill, April 2, 1993.
Resolution 68-16 was designated as an action-specific ARAR "for remedial actions
involving the recharge or reinjection of treated water into the basin." Resolution
92-49 was not designated as an ARAR or TBC.
Riverbank Army Ammunition Plant
FS Report prepared by U.S. Army by Weston Managers/Designers/Consultants, March
1993.
Resolution 68-16 was not designated as an ARAR because it is a "proactive
mandate rather than a retroactive mandate." Resolution 68-16 was designated as
a TBC. Resolution 92-49 was not designated as an ARAR or TBC.
Norton Air Force Base
FS Report prepared by Department of the Air Force. February 1993.
Resolution 68-16 was designated as a TBC for the discharge of treated
groundwater to surface water or reinjection into the aquifer. Resolution 92-49
was not designated as an ARAR or TBC.
DDRW-Tracv Operable Unit No. 1
FS Report prepared for U.S. Army Corps of Engineers by Woodward-Clyde Consultants,
December 1992.
Resolutions 68-16, 88-63 and 92-49 were all designated as ARARs.
11
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Glendale Study Area - South Operable Unit
FS Report prepared for EPA and City of Los Angeles by James M. Montgomery, August
1992.
Neither Resolution 68-16 nor 92-49 was designated an ARAR or TBC.
Sacramento Army Deport - Burn Pits
FS Report prepared for U.S. Corps of Engineers by Kleinfelder, Inc., May 15,1992.
Resolution 68-16 was designated as a TBC. Resolution 92-49 was not designated
as an ARAR or TBC.
Iron Mountain Mine
RI/FS Report prepared for EPA by CH2M Hill, February 1992.
Neither Resolution 68-16 nor Resolution 92-49 was designated as an ARAR.
12
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