United States
Environmental Protection
Agency
                         Office of
                         Emergency and
                         Remedial Response
EPA/ROD/R06-88/037
June 1988
$EPA    Superfund
           Record of Decision:
                                  PROTECTION
                                   AGENCY

                                 DALLAS, TEXAS
                                   UN
South Valley/Edmunds Street, NM

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50272-101
 REPORT DOCUMENTATION
       PAGE
1. REPORT NO.
    EPA/ROD/R06-88/037
                                      3. Recipient^ Acwaaion No.
 4. Title end Subtitle
  SUPERFUND RECORD OF DECISION
  South Valley/Edmunds Street, NM
  Second Remedial Action
                                      5. Report Date

                                            6/28/88
 7. Author(a)
                                                            8. Performing Organization RepL No.
 9. Performing Organization Name and Address
                                                            10. Project/Taak/Work Unit No.
                                                            11. Contract^) or Grant(G) No.

                                                            (C)

                                                            (G)
 12. Sponsoring Organization Name and Addrea*
   U.S.  Environmental Protection Agency
   401 M Street,  S.W.
   Washington, D.C.   20460
                                      13. Type of Report 4 Penod Covered

                                          800/000
                                                            14.
 15. Supplementary Notea
 16. Abstract (Limit: 200 words)
  The South Valley/Edmunds Street site is a  large area in the southern part
 of the  City  of Albuquerque,  New Mexico,  surrounding  the municipal water wel
 known as San Jose 6.   Within this large area  are a number of industrial
 properties owned and  operated by different  groups and individuals.   This
 remedial action addresses the Edmunds Street  Ground  Water operable  unit of
 the South Valley site;  the Edmunds  Street property is located in the
 southeastern corner of the site.  The focus of this  operable unit is the
 area around  the monitoring well SV-10,  referred to as the drainage  pit area
 on the  Edmunds Street property.  This area  -_s the low spot  of the property
 and receives much of  the property drainage.   Analyses of this area  have
 shown significant levels of  industrial solvents in the soil,  and a  plume of
 contaminated ground water starting  at the drainage pit area and extending t
 the east.  The ground water  source  will be  treated as a sole-source aquifer
 because there are no  alternate sources available to  the City of Albuquerque
 The contaminated ground water currently poses a direct threat to
 Albuquerque's water supply by moving  toward the city's well fields.   The
 primary contaminants  of concern affecting the ground water  include  VOCs sue
 as PCE  and TCE.
 (See Attached Sheet)	
 17. Document Analyeia a. Descriptor*
   Record of Decision
   South Valley/Edmunds Street, NM
   Second Remedial  Action
   Contaminated Media:  gw
   Key Contaminants:  VOCs  (PCE, TCE)
   b. kJenliftera/Opao-Ended Terrne
   c. COSAT1 FMd/Group
 1«. AvailabiWy SUMmerM
                         19. Security Claaa (Thl» Report)
                               None
                                               20. Security Q*M (TW« Pig*)
                                               	None	
21. No. of Pagm
    43
                                                                      22. Price
(See ANS»-Z3».18)
                                 SM Instruction* on Rtvtm
                                               OPTIONAL FORM 272 (4-77)
                                               (Formerly NTIS-3S)
                                               Department of Commerce

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	DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT


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 * GPO.  ,9830- 381-526(3393)                                                                        OPTIONAL FORM 272 BACK (4-77)

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EPA/ROD/R06-88/037
South Valley/Edmunds Street, NM
Second Remedial Action

16.  ABSTRACT  (continued)


 The selected remedial action for this site includes: ground water pump
and treatment using air stripping (packed tower aeration) with reinjecticn
of the treated water into the aquifer through infiltration galleries; and
ground water and air monitoring.  The present worth cost for this remedial
action is $874,000, with present worth O&M costs estimated at $280,200.

PERFORMANCE STANDARDS OR GOALS:  The contaminated ground water will be
treated to a PCE level of 20 ug/1 as required by the New Mexico Water
Quality Control Commission regulations, and to the MCL for TCE of 5 ug/1
as required by the Safe Drinking Water Act.

INSTITUTIONAL CONTROLS:  Not applicable.

KEYWORDS:  Aeration; Air Stripping;  Containment; Extraction; Ground Water;
Ground Water Monitoring; Ground Water Treatment; MCLs; Onsite Discharge;
Onsite Treatment; PCE; Plume Management; Safe Drinking Water Act;
Sole-Source Aquifer; State Criteria; TCE; Treatment Technology; VOCs.

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      1   UNITED  STATES  ENVIRONMENTAL  PROTECTION  AGENCY
      /
\	
 V    ^.-'                               REGION VI
                               1445 ROSS AVENUE. SUITE 1200

                                 DALLAS. TEXAS 7S202
                    DECLARATION  FOR  THE  RECORD  OF  DECISION


SITE NAME AND  LOCATION

South  Valley site,  Edmunds  Street Groundwater  Operable  Unit
Albuquerque, New  Mexico

STATEMENT OF PURPOSE

This decision  document outlines the selected remedial action for the
Ednunds Street  Groundwater  Operable Unit  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), and to  the  extent practicable,  the  National Oil and
Hazardous Substance Pollution Contingency Plan, 40  CFR  Part 300, November
20, 1985.

The State of New Mexico (through the New Mexico Environmental  Improvement
Division) has  been provided an  opportunity to  comment on the technology and
degree of treatment proposed by the Record of  Decision.


STATEMENT OF BASIS

This decision  is based on the administrative record for the South Valley
site, Edmunds  Street Groundwater Operable Unit (see Attachment 7).  The
attached index  identifies the items which comprise  the  administrative
record.

DESCRIPTION OF  THE REMEDY

Upon review of  the information  contained  in the administrative record, it
is EPA's judgement that recovery of the plume  of contaminated groundwater
moving east from the Edmunds Street property with a well system and the
treatment of the recovered  water with a packed aeration column appears to
best serve both statutory and selection criteria  in relation to the other
solutions evaluated.  The selected remedy would also include monitoring of
both groundwater, treated water and ambient air to  ensure  the effectiveness
of the remedy.  A detailed  description of the  remedy and an explanation of
how it meets statutory requirements is contained  in the attached "Summary
of Remedial Alternative Selection."  This is only the first operable unit
for the Edmunds Street portion  of the South Valley  site.   The  selected
remedy is not  intended to be the final  remedy  for this  property.
Additional remedial measures will be specified in subsequent Records of
Decision which may  affect the remedy selected  in  this Record of Decision.

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DECLARATION

The remedy described above is protective of human health and the environment,
attains applicable or relevant and appropriate Federal and State requirements
and is cost-effective compared to equally protective alternatives.  This
remedy satisfies the preference for treatment that reduces toxicity, mobility
or volume as a principle element.  Finally, it is determined that this
solution utilizes permanent solutions and alternative technologies to the
maximum extent practicable.

The State of New Mexico has been consulted on the selection of remedy for
the South Valley Edmunds Street Groundwater Operable Unit and the concurrence
of the New Mexico Environmental Improvement Division has been requested.
                                .
        DateRobert E. Layton Jr.,'P.E.,
                                Regional  Administrator

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Edmunds Street Groundwater Operable Unit
South Valley Site
Record of Decision Concurrences

The Edmunds Street Groundwater Operable Unit Record of Decision has been
reviewed and I concur:
Allyn M. Dav^s, Director
Hazardous Waste Management Division (6H)
 /   l
Robert E. HannesschTarfer, P.E., Chief
Superfund Enfor^emenlTBranch (6H-E)
Larry D. Wright1, Chief   ^
Superfund Enforcement Section (6H-EE)
Bennett Stokes
Office of Regional Counsel (6C-H)
Timothy K. UKderwoo
RPM, Superfund Enforcement Section (6H-EE)

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                       SUMMARY  OF  REMEDIAL ALTERNATIVE SELECTION

                         South  Valley,  Albuquerque, New Mexico
                        Edmunds Street  Groundwater Operable Unit

      Site Location  and Description

      The Edmunds Street  property is a portion of the South Valley Superfund
      site in Albuquerque,  New Mexico.  The South Valley Superfund site 1s an
      area surrounding  the  City of Albuquerque Municipal Water Well known as
      San Jose 6, near  the  intersection of Broadway and Woodward Road in
      southern Albuquerque.  The  Edmunds Street property is located at 3301
      Edmunds Street.   Figure  1 below  shows the larger South Valley site with
      the Edmunds Street  property 1n the southeastern corner of the site.
      Figure 2 on the next  page shows  the Edmunds Street property 1n more
      detail.
STUDY
(AREA   .!r.nn-
  NEW  MEXICO'   :'
                                        APPROXIMATE fpUNOANT SUPEMFUNO STUOT AftSA
                                                                         FIOUKI 1
                                                                         SUPEMFUNO STUOT ANEA
                                                                         Vl»SU»fl»UHOS«i

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          FIGURE
2.  LOCATIONS  OF  MONITORING WELLS AND SUPPLY  WELLS     '

         3301  EDMUNDS  STREET PROPERTY                  LiatttB
                                                                  9U - OCSWNATCS

                                                                  AMD UILLE*. INC. MOMITOWMa

                                                                  WELL


                                                                  •V - OOMNATU NMOO

                                                                          WELL
                                                                  I - OCSIONATCS CPA

                                                                  VOMTOMNQ WELL


                                                                  ML - OeStONATES XLA

                                                                  MOMTONNQ WELL


                                                                  * - OCSMNATU SU'IT WELL
                                                           1-1
                                                              OM-110
                                                           •
                                                          OM-lt
                        100
                             too
Figure 2  above  shows the various potential  sources of contamination
within the  Edmunds  Street property.  This  document concerns only one of
them, the area  surrounding the monitoring  well  labeled SV-10.  The area
around SV-10  1s called the drainage pit  area.   This area 1s a low spot on
the property  and much of the drainage  for  the  property flows to this
spot.  Significant  levels of Industrial  solvents have been found when
soil samples  from this drainage pit have been  analysed In laboratories.

An Investigation Into the contamination  problems at the Edmunds Street
property  resulted in the Installation  of the groundwater monitoring wells
shown in  Figure 2.   One of the results of  the  Investigation was the
discovery of  a  plume of contaminated groundwater starting at the drainage
pit area  and  extending to the east.

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The drainage pit itself, other potential sources of contamination within
the Edmunds Street property, and groundwater contamination in other areas
will be handled through later decision documents.  This is only the first
phase of remediation for the Edmunds Street property.  The selected
remedy may be incorporated into or superceeded by the remedy for source
control and groundwater remediation made in the subsequent Record of
Decision for this property.

Current Site Status

After the existence of the plume of contaminated groundwater was
discovered, a separate investigation was launched to discover the nature
and extent of the groundwater plume.  As the more detailed map in Figure
3 shows, additional  groundwater monitoring wells were drilled along the

                    Figure  3
                                                            £5S«srM.•«*••.:
                                                                »*lf». •».•<» .4 «.
 GH-3
       GM-4
             •W.5
             U1-7V-   GM-9D ^
                     -
                    v-io
             HL-1
                                      T-l
                                          ,«-US

                                           CN-liD
                                     •GM-12
                                                               , W-14S

                                                               'GH-14D
GM-15S

GH-15D
                                             MONFTORING WELL LOCATIONS

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 eastward path of the groundwatar plume to define its boundaries.   Water
 samples were taken from the wells and analyzed to determine  what
 chemicals were present and at  what levels.

 Table  1 shows the contaminants that were found in the  groundwater
 monitoring well  samples and the levels at which they were  detected.  As
 can  be seen from the Table, most of the contaminants found were
 industrial  solvents.  As this  data shows, the  concentration  of the
 contaminants falls as  the plume moves to the east.   The major concern at
 the  moment  is the threat to the water supply for the City  of Albuquerque.
 Major  wells fields that produce water for the  City  are in  the migration
 pathway of  the contaminant  plume.   The nearest well  in the migration
 pathway is  Miles  Well  II,  less  than one mile to the  northeast.

 Site Risks

 This Record  of Decision is  concerned  with a single  contaminated media,
 groundwater.   It  Is, therefore,  the groundwater route of exposure which
 is of  greatest concern.  Table  1  presents those contaminants found in the
 groundwater.  There  are no  current  groundwater users for the contaminated
 water  in  the  contaminant  plume  of  concern, hut there is a City of
 Albuquerque  water  supply  well  in  the  path of the plume migration.  The
 level of  contaminants  appears  to  be to  low for toxic effects, but there
 is risk  associated with chronic  carcinogenic effects of 2  x  10-2 .
 Attachment  1  shows the  calculations involved in reaching this number.

 Enforcement  Analysis

There is  a  list of several  potentially  responsible parties (PRPs) for the
 property  on  which  this  groundwater  contamination originates.  These
 include  past  and  present  owners  and operators  of the or^erty.  The
primary  PRPs  for  the purposes of  this  document are  Van .^cers and
Rodgers,  the  current operator,  and  AmeriGas, the property owner.  These
two PRPs  have expressed willingness to  implement the selected remedy.
Negotiations  will  be conducted  in  an  attempt to memorialize agreement for
PRP conduct  of the Remedial Action  under terms of a  Consent Order.

Community Relations

There has been some  media  interest  in  the overall South Valley Superfund
 site, hut the interest  fron individual  citizens has  been low.  Notice to
potentially  affected persons and  the  public was provided through a press
 release  on May 10, 1988 accompanied by a direct mailing to individuals
 and groups on the  site  mailing  list.   The mailing included a fact sheet
describing  the site  problem, alternatives for  cleanup  and  the oroposed
 plan for  remediation.   The  public  comment period on  the rernecr.il
 alternatives  ran  from  May  16 to  June  17, 1988.  A public meerng on
 remedy  selection  was held  in Albuquerque on May 26,  1988.  The response

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 to  significant  comments  or cn'ticisns submitted  during  the  public meeting
 and  during  the  comment  period  are  presented  in the  Responsiveness Summary
 at  the  end  of this  document.

 Operable  Units

 The  South Valley  site has  been  divided  into  four  operable units.  These
 are  Ednunds  Street  Groundwater,  Edmunds  Street Source Control, Air
 Force/GE  Source Control, and the overall  Offsite  portion.   The division
 of the  site  into  these parts follows  from the nature of  the site.  The
 South Valley site is a large area  surrounding the City well  San Jose *6.
 Within  this  larger  area  are a  number  of  industrial  properties owned and
 operated by  different groups and individuals.  Each of the  two source
 control operable  units will deal with a  single industrial property that
 through the  investigation  process  has been shown  to have contamination
 that needs  to be  corrected.  The overall  Offsite  operable unit is
 intended to  deal with the  site  as  a whole, leading  to a decision about
 the  larger  groundwater problem  that caused this area to become a
 Superfund site, while the  source control  operable units eliminate the
 sources of  groundwater contamination.

 The  fourth operable unit,  the Edmunds Groundwater operable  unit which is
 the  subject of this document, deals with  a specific problem which does
 not  appear to directly affect the  larger  South Valley problem.  The Edmunds
 groundwater problem does start within the Edmunds Street property, however,
 and needs to be dealt with during  resolution of the greater South Valley
 Superfund site problems.   The overall Offsite operable unit and the two
 source control  operable units should be  resolved within three months,
 following completion of reports detailing additional investigations in
 the  individual  industrial  properties and  the overall site.

 Alternatives Evaluation

 The alternatives seek to eliminate the single route of contamination of
 issue for this Record of Decision, groundwater.  The source of the
 contamination will be handled through a  separate decision document.  As
 stated in the Declaration, this is only  a first action concerning this
 property and is not the final  groundwater related remedial  action.

This decision will be limited to the specific groundwater plume moving to
 the east as previously described.  Any other groundwater contamination
originating from the same  source will be considered in a separate document.
 The groundwater source in  question, the  Santa Fe formation will  be treated
 as a sole source aquifer.  It is the source for drinking water for the City
of Albuquerque and no alternate source is available.  The Santa Fe Formation
consists of unconsolidated sands,  gravels, silts and clays  to an approximate
 2000 foot depth.  The contaminant  plume  appears to be currently contained
above a lower permeability layer found at approximately 180 feet in depth.
However, in borings farther in the direction of migration,  the lower permea-
bility layer cannot be found.  One purpose of this effort will be to halt
migration of the plume before it moves beyond the lower permeability layer
 and deeper into the aquifer.  The  contaminant plume poses a direct threat
 to the water supply for the City of Albuquerque.  The contaminant plume
 is moving toward the City  well  fields, with well  Miles #1 the nearest well

-------
threatened.  Time  for  implementation  is  short,  "'heoretical calculations
show  that  the contaninants could  have already  reached Miles #1, though
sampling of the well shows that  it  has not yet  been contaminated.

Of the decision elements listed  above, time  poses the greatest
constraints on the selection of  remedy.  Any remedy selected will  have to
halt  migration of  the  contaminant plume  within  a very short period of
time.  Given the constraints just discussed, the screening process
rapidly eliminated in-situ treatment  as  an option as it would involve too
long  a period of implementation.  Extraction and treatment remained as
the only viable alternative.

Alternatives

Each  alternative was evaluated on the following criteria:

1.  Short-term effectiveness:  Protection of human health and the
environment during construction and implementation.

2.  Long-term effectiveness and permanence:  Effectiveness after
construction and implementation is complete.

3.  Reduction of toxicity, mobility,  or  volume:  Anticipated performance
of the specified treatment technologies,

4.  Implementability:  Technical and  administrative feasibility of
alternatives and the availability of  required resources.

5.  Cost:  Cost of construction and operation and maintenance.

6.  Compliance with ARARs:  Compliance with ap-.^cable or r^evant and
appropriate standards  (abbreviated as ARARs) f- ••?. existing  ;ws and
regulations.  These are standards or  regulations that either do apply
or at least should be considered when looking at an alternative.

7.  Overall protection of human health and environment:  How the
alternative as a whole protects and maintains protection of human health
and the environment.

8.  State acceptance:  The State's preferences  or concerns about the
alternatives.

9.  Community acceptance:  The community's preferences or concerns about
the alternatives.

All of the alternatives with the  exception of no action  require the
extraction and treatment of the  contaminated groundwater to existing
standards.  This automatically meets  the requirements for both  short

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 and  long-term  effectiveness  and  permanence.   The  water  will  he  treated  to
 ARAR  standards  meeting  the criteria  for  reduction  of  toxicity,  mobility,
 and  volume  and  compliance with ARARs  through  the  removal  of  the contaminants
 from  the  groundwater.   This  reduces  the  comparison  of the alternatives  to
 implementability, cost,  overall  protection and  State  and  Community
 acceptance  criteria.

 The basic alternatives  and their  components are:

 1.  No Action:  No action would  he taken.  The  site would  remain in  its
 current condition.  The  plume of  contaminated groundwater  would  continue
 to migrate  toward the City of Albuquerque wells.

 2.  Recovery:   All of these  alternatives involve the  extraction  of ground-
 water through pumping wells  screened  in the portion of  the aquifer contaminated.
 The extraction  wells are planned  to be 8-inch diameter  wells with steel
 casing having stainless  steel screens.  The screens will be  positioned  in
 the upper portion of the aquifer  to recover the contaminated groundwater.
 Preliminary design calls for wells capable of yielding  50  to 100 gallons
 per minute  (gpm).  The pumping system will be designed  with  sufficient
 wells and pumping capacity to recover the contaminated  groundwater coming
 from the Edmunds Street  property  above the limits deemed necessary to
 protect human health and the environment.  These limits are discussed
 more fully  in the Statuatory Determinations Section of  this  summary.

 Preliminary des }ns indicate that two wells located north  and south of
 the monitoring well  cluster  GM11  should be sufficient when pumping at a
 combined rate of 75 gpm.  Actual   rates of pumping and the  adequacy of two
wells will be determined during remedial design and once the system is in
 place and its performance can be  monitored.

 2-A.  Groundwater Extraction Wei  i System:  This option  would use pumping
wells alone to contain and recover the contaminated groundwater.

 2-B.  Well System and Partial Slurry Wall:  This option would combine a
pumping well system with a slurry wall in front of the  migrating plume
 slowing further migration.

2-C.  Well System and Complete Slurry Wall:  This option would combine a
pumping well system and a slurry  wall that completely surrounded the area
of contaminated groundwater.

3.  Treatment of Contaminated Grpundwater:  Once the contaminated
 groundwater was recovered it would be treated by one of the following methods.

 3-A.  Treatment with Packed Column Aeration.

 3-8.  Treatment with Carbon Adsorption.

 3-C.  Treatment at a Publically Owned Treatment Works (POTW).

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                                     10
4.  Discharge:  Once  the  water  has  heen  treated,  the  treated water must
he  handled.   Two options  were examined.

4-A.  Surface discharge.

4-B.  Restoration of  water to the aquifer  through  infiltration galleries.

Comparative Analysis  of Alternatives

The following is a description  of the analysis of  the various alternatives
using the remaining criteria for comparison.

        Implement-    Cost    Overall       State      Community
         ability            Protection  Acceptance   Acceptance


1           +          +

2-A         ++•»•+             +

2-B         -          -        +•           +             +

2-C         -          -        +           +             +

3-A         +          +        +           +             +

3-B         +          -        +           +             +

3-C         -          +        +

4-A         +          +        +

4-B         +          -        +           +             +
 + being a favorable evaluation
 - being a negative evaluation

Implementability - All of the options use proven readily available
techniques.  The slurry wall options (2-B and C) face difficulties due to
the presence of an interstate highway and a petroleum pipeline in the
area of construction as well as doubts about construction at 180 foot
plus depths.  The City POTW desires to reserve its available treatment
capacity, therefore the use of its plants for the POTW treatment option
(3-C) was eliminated.

Cost - Using a 10 year project life, a cost comparison was developed for
each of the three parts of the alternatives:  extraction, treatment, and
discharge.  More extensive cost information is presented in Attachment 2.
All the extraction options involve pumping wells and a collection system
estimated at $615,000.  A partial slurry wall would cost $1,923,336.
Costs for a full slurry wall could not be developed as engineering costs
for design and construction could not be estimated.  Packed tower aeration

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                                     11


 was  estimated to cost $20b,200.   Carbon Adsorption was estimated at
 $708,500 mainly due to higher operation and maintenance costs.   Discharge
 of  the  treated water to the surface was estimated at $27,000.
 Using  infiltration galleries was  estimated  at  $54,000.

 Overall  Protection - No action offers  no  protection.  Packed tower
 aeration and carbon adsorption both would treat  to the same  groundwater
 standards.   The air release associated with packed tower aeration poses
 no estimated health threats.  The  threat  of the  contaminated carbon  from
 carbon  adsorption  varies  depending on  the method of disposing of  the
 spent carbon.   Discharged water would  be  of similar quality  in  either
 discharge method.

 State and Community Acceptance - Preservation  of useable water  is
 preferred giving infiltration  a higher level of  acceptance than  discharge
 to the  surface.  Infiltration  would also eliminate concerns of  downstream
 users of surface waters.

 Selected Remedy

 The selected  remedy consists of the following  parts:   containment and
 collection of  the  contaminated groundwater  through the  use of an
 extraction well  system, treatment  of the recovered groundwater  through
 packed  tower aeration,  and  return  of the treated  water  to the aquifer
 through  infiltration  galleries.

 The risk  level  attained at  completion  of the response  action is discussed
 in the  following Statutory  Determinations section.

 No action was  rejected  as  it did nothing to mitigate the potential
 impacts  of the  contaminated  groundwater.  Of the  collection options,
 pumping  alone was  selected  since a  system of pumping wells alone is
 capable  of containing and  recovering the contaminated  groundwater.  This
 eliminates the  need  for construction of slurry walls with the associated
 risks of  exposure  during  construction  and implementation difficulties.
 Packed tower aeration was  selected  for the  treatment method due to
 greater  ease of operation and  lower operation  and  maintenance costs over
 carbon adsorption.   Reinfiltration  of  the treated  water was chosen over
 surface  discharge  due to  a  desire  to preserve  the  water  that could be
 lost through evaporation  during surface discharge  and  the beneficial
 effects  of recycling  the  treated water through the  contaminated area of
 the aquifer.  The  additional benefits  include  the  flushing action of the
 recycled water  and  the  containment  and  retreatment  of  any water exiting
 the treatment system  above  standards for cleanup.

 Statutory Determinations

Under Section  121  of  CERCLA, the selected remedy  must  satisfy certain
 statutory requirements  specified within that section.  This section will
 discuss  each of these requirements  one at a time.   The  selected remedy must:

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                                      12

 1.  Be protective of hunan health and the environnent.

 2.  Attain ARARs

 3.  Be cost-effective

 4.  Utilize permanent solutions and  alternative treatment technologies or
 resource recovery technologies to the maximum extent practicable.

 5.  Address whether the preference for treatment that reduces toxicity,
 mobility, or volume as a principle element is satisfied.

 The first statutory requirement, that the selected remedy be protective
 of human health and the environment  can be examined through examination
 of the two pathways for exposure, ingestion of contaminated groundwater
 and inhalation of volatilized contaminants.  The first of these will  be
 addressed through the goals for treatment of the contaminated
 groundwater.  The treatment goals will be based primarily on two
 criteria, maximum contaminant levels (MCLs) developed under the Safe
 Drinking Act and the State of New Mexico Water Quality Control  Commission
 (NMWQCC) Regulations for discharges  onto or below the surface of the
 ground whichever of the two is more  stringent.  These goals are given in
 Table 2.
                                  TABLE 2

    Contaminant                 Cleanup Goal          *Regulation
                            in part-per-billion
Carbon Tetrachloride
Chloroform
1,2 Dichloroethane
Trans-1,2 Oichloroethene
1,1 Dichloroethene
Methylene Chloride
Tetrachloroethene
1,1,1-Trichloroethane
Trichloroethene
Acetone
5
100
5
70**
5
100
-20
60
-5
-
MCI
NMWQCC
MCL
MCLG
NMWQCC
NMWQCC
-NMWQCC
NMWQCC
-MCL
-
 * MCL - for the maximum contaminant under the Safe Drinking Water Act
   NMUQCC - for the New Mexico discharge regulations
** This standard is a maximum contaminant limit goal (MCLG)

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                                     13
 This  leads  directly  to  the  discussion  of  applicable  or  relevant  and
 appropriate requirements  (ARARs),  the  second  statutory  determination.   The
 two regulations mentioned above are  the primary  standards  involved  for
 groundwater.  There  is  a third  NMWQCC  standard that  may apply.   It  is
 General  Provision  1-101.UU  which  calls for control  of  "toxic
 pollutant"(s) which  would create a lifetime cancer risk of more  than one
 cancer per  100,000 exposed  persons.  Attachment  1 shows the  lifetime
 cancer risk  posed  by contaminants  detected in the contaminated
 groundwater.  Attachment 1  also indicates those  contaminants which are
 included  in  the NMWQCC  list of  toxic pollutants.  Water being
 reinfiltrated will need to  meet this standard.   In addition  to these
 groundwater  regulations, the use of  packed tower aeration also involved
 compliance  with air  regulations.  Air  dispersion modeling using  two EPA
 certified models,  ISC and Valley,  was  done to determine air  impacts.
 There appears to be  no  significant health impacts associated with use of
 packed tower aeration.  Calculations of these impacts are shown  in
 Attachment  3.  The two  air  ARARs most  applicable are the Clean Air Act
 and the Ambient Air  Quality Standards  and Air Quality Control Regulations
 for Albuquerque/Sernalillo  County.  The emission rate from the packed
 tower aeration system is well below the regulated rates  from both of
 these sets of air regulations.   The calculations are shown in Attachment 4.
 A full list of all ARARs considered can be found in Attachment 5.

 The third criteria,  cost effectiveness, is met by the selected remedy.
 Packed tower aeration is the most  cost effective of the treatment methods
 which are protective of human health.  The fourth criteria,  permanence,
 fan be related to the recovery  and treatment of the contaminated
 groundwater.  The selected  remedy  will restore the contaminated water to
 a fully useable condition and the  will restore the treated water to the
 aquifer.

 The final criteria is the preference for treatment that  reduces toxicity,
mobility, or volume  as a principle element.  The selected remedy stops
migration of the contaminated groundwater plume and treats the
 contaminated groundwater to  reduce its toxicity.  This  eliminates the
 primary route of exposure to the public.  The air exposure associated
with the selected remedy has been  examined and appears  to pose no
 significant threat to human  health.

 Significant Changes  in the  Selected Alternative

There was no change  in the  recommended alternative presented to the public
during the public comment period and at the public meeting and that
 recommended alternative is  the  selected remedy.

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                             3301  EDMUNDS  STREET
                         SOUTH  VALLEY  SUPERFUND SITE
                 COMMUNITY  RELATIONS  RESPONSIVENESS  SUMMARY
This Community Relations  Responsiveness  S unnary  has  been  prepared  to
provide written responses to comments  submitted  regarding the proposed plan
of action at 3301 Edmunds Street,  South  Valley hazardous  waste site.  The
summary is divided  into two sections:

Section I:  Background of Comnunity  Involvement  and  Concerns.  This section
provides a brief history  of community  interest and concerns raised during
the renedial planning activities at  South Valley.
Section II:  Summary of Major Comments Received.  The  -^rrv^ts  (both oral
and written) are summarized and EPA's responses are provide-,:.

I.  Background of Community involvement

    Due to the possibility of contamination of the entire San Jose
    Wellfield, the South Valley site has received extensive media attention.
    However, because of the heavily industrialized nature of the site area
    and the lack of exposure, citizen concern has been very limited.

    Although no citizen groups have been formed to deal specifically with
    the problems posed by the South Valley site, several groups have
    expressed a general interest regarding overall environmental concerns in
    the Albuquerque area.  NO specific interest has been not°d  involving the
    Edmunds Street property.

II.  Summary of Major Comments Received

     The press release and Proposed Plan fact sheet announcing the public
     comment period and public meeting were distributed on May  13, 1988.
     The comment period began on May 16, 1938 and was extended until June
     17, 1988.  A public meeting was held for the area residents and local
     officials on May 26, 1988 at  the Radisson Hotel.  The purpose of this
     meeting was to explain the results of the remedial  investigation and
     to outline the various alternatives presented  in  the feasibility
     study.  Approximately 43 people from the area attended the meeting, and
     5 residents made oral statements or asked questions.  No written comments
     or questions were received.

     Overall, the residents and local officials do  not oppose  the proposed
     remedy.  During the public comment period,  there  were comments/questions
     regarding the following:

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 Question  1:   What  about contanination  outside the area described  in  this
 operable  unit?

 Response:  This  is  only the first  of several  operable  units.   There  will be
 future  meetings  and comment periods  on  other  portions  of  the  larger
 South Valley  site.   Results of  other remedial  investigations  and  cleanup
 plans will he available to  the  public  in  the  next few  months.   Those who
 attended  the  public meeting and  registered  or  made  comments daring the
 public  comment period  were  added to  the mailing  list and  will  receive indi-
 vidual  notices concerning these  additional  operable units.

 Question  2:   Do you [EPA] have  a list of  the  compounds  that you have
 identified as contaminants  in the  area?

 Response:  Yes, the list is  included in the reports at  the public
 repositories, specifically  in Table  1 of  "Feasibility  Study for Plume
 Stabilization and Extracted  Ground-Water  At 3301  Edmunds  Street, Albuquerque,
 New Mexico."

 Question  3:  Do you  have any preliminary  technical data involving the
 efficiency of the two  proposed methods, the air  stripping process or carbon
 adsorption?

 Response:  Yes, there  is information available through  the USEPA Office of
 Drinking Water on the  efficiency of  air stripping for  the majority of
 compounds that we found at  the site.  No  individual studies were done using
 waste from this site.   Once  the cleanup decision  is made, such a study will
 be performed as a part  of the design process.

 Question 4:  Are copies of  the  remedial investigation  and feasibility study
 available?

 Response:  Yes, they are available at the four repositories in New Mexico
which are listed in  the fact sheet and at the  EPA offices in Dallas.

 Question  5:  The estimate for cleanup time  in  the proposed plan was  five
years.  Is this a realistic  estimate?

Response:  The five year time is a minimum.   Groundwater  contamination
 generally takes a long  time  to clean up.  EPA  does  not  wish to understate
 the cleanup time.

Question 6:  Availability of the documents  seems  to be  a  problem,
 particularly at the  Albuquerque  Public Library.   Is this  the only
 repository?

 Response:  No, there are two others  in Albuquerque, the University of New
Mexico  Library, and  the City County  Building.  A  check  will be made  at the
Albuquerque Public  Library  to see  if there  was a  problem  in availability of
 the documents.

-------
Question 7:  Are there any contaninants that would not he removed that are
found on the Edmunds Street  properties?

Response:  No.  It is a requirement that all of the contaminants that are
found in the groundwater be  removed to levels that are below those set by
the Safe Drinking Water Act  or the New Mexico Water Control  Commission
Regulations.

Question 8:  This method [the air stripping method] would release
contaminants into the air.   Is there any data available to tne public on
the estimated amount of contamination to be released?

Response:  Yes.  One of the  documents in the public repositories titled,
"Air Dispersion Modeling Analysis For A Packed Aeration Column, Van
Waters & Rogers, Inc., Edmunds Street Site, Albuquerque, New Mexico"
involves an air model that was used to predict the levels of contamination
that could be expected if the air stripping method is used^

Question 9:  Will  you also be monitoring air quality i'f that method [air
stripping] is used?

Response:  Yes, we would not use the air stripping method unless we could
monitor for air quality.  Regular air monitoring will be required to ensure
that the air stripping method is operating properly.

Question 10:  Given the fact that the City of Albuquerque is under sanction
for violations of the Clean  Air Act, has the proposal for air stripping been
cleared through the City?

Response:  The City is under sanction for violations of the carbon monoxide
standards.  The contaninants associated with this cleanup would have no
effect on this situation.  Use of the air stripper falls within the standards
set by the Albuquerque/Sernalillo County air regulations and the Clean Air
Act.

Question 11:  Did you consider the cumulative effects of operating the air
stripper?

Response:  Yes, we examined  both the short-term effects and long-term effects
of air releases during use of the stripper and found that they would not
pose a health threat either  to workers onsite or nearby residents.

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               ATTACHMENT ONE
           CARINOGENIC RISK FROH
CHRONIC EXPOSURE TO CONTAMINATED GROUNDWATER

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                                  A-l
  Carcinogenic Risk From Chronic Exposure to Contaminated Groundwater


  The following calculations involve the use of certain standard assumptions,
  These assumptions include the following:  Consumption of 2 liters of
  water a day for 70 years at a body weight of 70 kilograms.  The values
  used for the concentrations of contaminants are a combination of values
  for two wells.  Most of the concentrations come from a samp! • from
  monitoring well GM-9, the monitoring well within the plume having the
  highest level of contamination.  However, this well  does not contain all
  of the contaminants of concern.  For those that did  not appear in the
  sample from GM-9, values were taken from a sample for well GM-1.

  The calculations were done as follows:
  concentration       2 liters     cancer potency
  of contaminant   x    3ayx      factor                   increased
(part per million)	     »   lifetime cancer risk

                70 kilograms body weight


  It should be noted that there are no cancer potency factors for
  trans 1,2 dichloroethene, 1,1,1 trlchloroethane, or acetone.
  Contaminant           Concentration         Cancer Potency      Risk
                      (part per billion)         Factor
Chloroform
1,2 Oichloroethane
1,1 Dichloroethene
Methylene Chloride
Tetrachloroethene
Trichloroethene
7.7
26
910
440
4400-
1400-
8.1 x 10-2
9.1 x 10-2
0.6
7.5 x 10-3
5.1 x 10-2
1.1 x 10-2
1.8 x 10-5
6.8 x 10-5
1.6 x 10-2
9.4 x 10-5
6.4 x 10-3
4.4 x 10-4
                                                      total    2.3 x 10-2

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 ATTACHMENT 2



COST ESTIMATES

-------
 Cost Estimates
                                    A-2
 The cost estimates below were  calculated  assuming  that  installation  costs
 would  he 1.5 tines the capital  costs,  that  engineering  costs  would he
 twenty percent  of the capital  costs,  that the  project would  have  a ten
 year life and  the calculations  used  a  7%  discounted  rate.
 Extraction  wells  and  pumps

 capital  costs                                50,000
 pipelines                                   100,000
 installation & engineering                  255,000
 operation & maintenance
  materials & power at  15,000/year
  labor  at  15,000/year                      210,000

 Partial  Slurry Wall

 capital  costs                            1,680,000
 engineering                                 336,000
 savings  from reduced pumping                -92,664

 Complete Slurry Wall
total   615,600
total 1,923,000
No calculation was done for this option.  The figure for the
partial slurry wall can be used as a minimum.  In addition to
those costs would be an unknown additional cost for further
investigation of the confining layer into which the wall would
he based and subsequent greater extent of the slurry wall.

Paoced Aeration Column

capital costs                                50,000
 peration and maintenance                    70,200*
 retaliation and engineering                 85,000

Carbon Adsorption Unit

capital costs                               150,000
sand filters                                 50,000
installaiton and engineering                340,000
operation and maintenance at 24,000/year    240,000

Surface Discharge

pipe                                         10,000
installation and engineering                 17,000

Infiltration Galleries

capital costs                                20,000
installation and engineering                 34,000
total   205,200
total  780,000
total   27,000
total   54,000

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ATTACHMENT 3

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Health Impacts From Packed Tower Aeration

The calculations that follow on the health impacts of packed tower aeration
are based on the air dispersion nodeling detailed in the report entitled,
"Air Dispersion Modeling Analysis for a Packed Aeration Column, Van Water and
Rogers, Inc., Edmunds Street Site, Albuquerque, New Mexico."  Three models were
used in this report.  The calculations below are based on the one known as
Valley, the more conservative of the models for complex terrain.  In addition,
two conservative assumptions were made.  The first involved the quality of
the water entering the column.  The level  of contaminants in the incoming water
is expected to rise for approximately two years and to then begin to decline.
The peak predicted contaminant values were used for the calculation even though
this condition will be short-lived.  The second conservative assumption involved
the use of summer inversion meterological  conditions.  This is the worse case
for valley conditions and was used even though this condition will not occur
for most of the year.  Finally, the values used to calculate exposures for the
two nearest residential areas came from points between the proposed tower
location and the residential area.  This gives higher levels than would occur
at the actual locations.  The Kirtland Addition is 1500 meters north/northeast
of the column location so the 1373 meter value was used.  The houses along
Wesmeco are 850 meters northwest of the site, so the 686 meter value was used.
The Table that follows shows that even with these combined conservative
conditions, the risk posed by the aeration column is very small.

-------
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-------
ATTACHMENT 4

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                                 ATTACHMENT  4
 The Clean Air  Act  limits air emission  from  hydrocarbon  sources to  100 tons
 per year.  Using the estimated worst quality  of  water expected to  enter the
 aeration column  (1628  total micrograms per  liter contaminants) and a 100
 gallon per minute  flow rate of water,  the following  calculation was
 performed for  annual emissions:

 8400 hours     4500 gallons     1628 ug     1  g.     1  Ib.     3.785 liter
 	  x  	  x  	  x  —  x  	  x  	
   year            hour          liter       10      454 g       gallon

 »513 pounds per year or 0.25 tons per  year.

 The Ambient Air Quality Standards and  Air Quality Control Regulations for
 Albuquerque/Bernalillo County have a maximum concentration of 100 ug/nr
 in ambient air for non-methane hydrocarbons.   The air modeling using the
 VALLEY model showed the maximum Impact would occur north/northeast of the
 column at a distance of 229 meters.

 Chemical                       Concentration in micrograms per cubic meter

                                 10.7  meter stack          13.7 meter stack
 benzene                                  0.00076                   0.00075
 chloroform                               0.00092                   0.00091
 trans-1,2 dichloroethene                 0.00089                   0.00088
 1,1-dichloroethene                       0.02886                   0.02859
 tetrachloroethene                        0.09446                   0.09355
 1.1,1 trlchloroethene                    0.00997                   0.00988
 1.2 dichloroethane                       0.00997                   0.00988
 acetone                                  0.00249                   0.00247
totals                                   0.14832                   0.14691

The total concentrations are well below the 100 ug/m3 required under the
Albuquerque/ BernaHllo County air regulations.

-------
ATTACHMENT 5

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          ATTACHMENT 6



STATE OF NEW MEXICO CONCURRENCE

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                                         Post Office Box 968
                                   Santa fe. New Mexico 87504-0968
        I  I
NC» MO.C:
HEALTH wo ENVIRONMENT
                                         Michael JrBur*hBrs .  _
                                             Director - ' •'- -'  :   I  •
                                ^eo-;> Sec-e;a->
'•> • 7
 •
         June 27, 1988
         Allyn Davis, Director (6H)
         Hazardous Waste Management Division
         U.S. EPA, Region VI
         1445 Ross Ave.
         Dallas, TX  75202-2733

         Dear Mr. Davis:

         EID concurs with the remedy proposed by EPA for the Edmunds Street
         Groundwater Operable Unit of the South Valley Superfund site, with
         the understanding that this decision relates only to the plume of
         contaminated ground water that extends eastward from the 3301 Edmunds
         Street property in Albuquerque.  Your staff has done excellent work
         on this project.

         We stress that this operable unit concerns only a small part of the
         site and only a part of the Edmunds Street property.  As we discussed
         with your staff on June 15, selection implementation of a comprehensive
         remedy for the South Valley site demands multi-agency coordination.  _
         EID trusts EPA, the lead agency for this site, to provide the necessary
         coordination and to work with the rest of us toward a viable remedy.
         EID also expects EPA to follow through with past commitments to define
         the extent of contamination by CERCLA wastes to the north and east,
         during remedial design if necessary.
         Kirkland'L. Jones
     /  Deputy Director
                «,x
         KLJ:lr
                                                                       PRCT5.CTJON
                                                                         AObNCY

                                                                      DALLAS, TEXAS
                                  EQUAL

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                                                             f
        ATTACHMENT 7



ADMINISTRATIVE RECORD INDEX

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