United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
&EPA Superfund
Record of Decision:
South Valley(SJ-6), NM
EPA/ROD/R06-88/041
September 1988
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REPORT DOCUMENTATION : » REPORT NO. 2.
PAGE i EPA/ROD/R06-88/041 i
4. Title and Subtitle
1 SUPERFUND RECORD OF DECISION
|outh Valley/ SJ-6, NM
H^nird Remedial Action
I 7. Author(s)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Wasnington, D.C. 20460
3. Recipient's Accession No
5. Report Date
09/30/88
6.
8. Performing Organization Rent. No
10. Proiect/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(0
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" JgA
w
'A/ROD/R09-88/022
th Valley/SJ-5, MM
ird Remedial Action
16. ABSTRACT (continued)
being addressed through remedial actions initiated by EPA in separate RODs. The primary
contaminants of concern affecting the ground water are VCCS including 1,1-DCE, FCE1 anil
TCE.
The selected remedial action for this site included removal and disposal of 100
yd^ of contaminated sediments at the base of the SJ-5 borehole; sealing abandoned
w-:lls; ground water .monitoring; ar.;l access restrictions. The estimated present -/orta
c st for' this remedial action is 24,000,000 with estimated ar.nu.il 0£M of S30D,CCO.
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RECORD OF DECISION
FOR
SAN JOSE 6 (SJ-6) SUPERFUND SITE
'SOUTH VALLEY
ALBUQUERQUE, NEW MEXICO
SEPTEMBER 1988
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
South Valley San Jose 6 (SJ-6) Superfund Site.
Albuquerque, New Mexico.
STATEMENT OF PURPOSE
This document describes the remedial action selected by the Environmental
Protection Agency (EPA) for the SJ-6 portion of the South Valley San Jose 6
Superfund site. It is developed 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 the National Contingency Plan (40 CFR Part 300).
The State of New Mexico has been consulted regarding this remedy. Although
the New Mexico Environmental Improvement Division initially objected to EPA's
proposal, they now support EPA's decision (Appendix A).
STATEMENT OF' BASIS
This decision is based upon the Administrative Record-for the South Valley
SJ-6 Superfund site. The attached index (Appendix B) identifies the items
comprising the Administrative Record.
Based upon the findings of the Remedial Investigation, Endangerment Assessment,
and Feasibility Study, EPA concludes that the trace concentrations of solvents
in the vicinity of SJ-6 do not pose a threat to public health or the environment,
This does not include solvent contamination directly beneath and emanating from
the USAF/General Electric and Edmunds Street properties. These sources of
contamination are being addressed by remedies described in Records of Decision
for the Edmunds Street Groundwater Operable Unit (6/28/88), in the Edmunds Street
Source Control Operable Unit (an anticipated 1st qtr/1989 decision), and in the
Former Air Force Plant 83/General Electric Record of Decision (9/38).
DESCRIPTION OF SELECTED REMEDIAL ACTION'
EPA has selected a remedy for SJ-6 consisting of cleaning and sealing abandoned
wells, groundwater monitoring for at least 30 years and access restrictions.
Groundwater monitoring will include installation of wells north and east of
the site, in the downgradient direction. The water supply lost as a result of
SJ-6 contamination has been replaced by the construction of a new municipal we.l 1
the Burton No. 4. This remedy selection is documented in a separate Record of
Decision (March, 1985).
To address concerns raised by the State of New Mexico regarding the permanence
and effectiveness of the selected remedy, this decision also provides for a
review of environmental conditions in the vicinity of SJ-6 after five years.
This should be a coordinated review to include data from the SJ-6 effort and
the efforts resulting from the above-referenced decisions. If remedial actions
for petroleum are implemented at this time, the hydraulic information collected
from these actions should also be integrated into the review.
i .
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DECLARATION (cont'd)
If Superfund contamination is found to exceed applicable or relevant and
appropriate standards, additional remediation, using Superfund authorities will
be assessed.
Consistent with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 as amended by the Superfund Amendments and Reauthorization
Act of 1986, and the National Contingency Plan, I have determined that the above
described SJ-6 remedial action will provide adequate protection of public health,
welfare, and the environment. This remedy attains Federal and State requirements
that are applicable or relevant and appropriate, and is cost-effective. It is
determined that this remedial approach is permanent and that alternative
treatment technologies have been considered to the maximum extent practicable.
The State of New Mexico has been consulted and supports the SJ-6 remedial
action if the proposed remedies for the adjoining USAF/GE portion of the South
Valley San Jose 6 site are implemented. If any significant adverse trends are
detected during groundwater monitoring, the impact to public health will be
reevaluated and, if necessary, future action will be considered.
Dafte A Robert E. Layfcbn Jr., P.E,
Regional Administrator
11 .
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SAN JOSE 6 (SJ-6) SUPERFUND SITE
ALBUQUERQUE, NEW MEXICO
SEPTEMBER, 1988
EXECUTIVE SUMMARY
The San Jose 6 (SJ-6) Superfund Site is located at the southern margin of
Albuquerque, New Mexico (Fig. 1). The site encompasses six industrial
facilities and the surrounding areas, within about 1 square mile radius (Fig.
2). Land use is primarily industrial and agricultural as well as residential.
SJ-6 is a municipal well in which chlorinated solvents were detected in 1981.
The site was subsequently listed on the National Priorities List in 1983
'as the State of New Mexico's top priority.
The six industrial facilities were identified as being potentially
responsible for contributing to and/or being the source of contaminants
detected in Municipal well SJ-6. These six potentially responsible parties
(PRPs) are the United States Air Force (former Air Force plant No. 83),
now occupied by General Electric; Chevron, U.S.A.; Texaco; Whitfield Tank
Lines; the Edmunds Street property owners; and Duke City Distributing.
Chlorinated solvents have been detected at the USAF/GE facility and at
the Edmunds Street property. The other four properties may be sources
of petroleum contamination.
Based on the findings of the Remedial Investigation, and pending actions
to be implemented for source control, the Environmental Protection Agency
(EPA) concludes that a significant health threat is not posed by the
residual contaminants detected in areas surrounding the PRP facilities.
However, to mitigate a potential degradation of the Albuquerque drinking
water supply, EPA has determined that it is necessary to seal abandoned wells
in this industrial vicinity. This action precludes a direct and primary
route for contaminant migration from shallower zones to the deep aquifers
that supply municipal water. Sealing abandoned wells will also support the
Wellhead Protection Program that is currently in the planning stages by the
City of Albuquerque. To ensure protection of public health, groundwater
monitoring will be performed within the current site boundaries as well
as north and east of the site, in the downgradient direction. Access
restrictions will also be imposed through the State Engineers office
(Section 72-12-1; New Mexico statutes). These restrictions will'impact
the construction of new wells in the area. They will consist of construction
techniques to prevent cross-contamination between water-bearing zones and
completion depths will be below approximately 200-250 ft.
This remedy complies with the Comprehensive Environmental Response,
Compensation and Liability Act 1980 (CERCLA) as amended by the Superfund
Amendments and Reauthorization Act (1986) SARA, and the National Contingency
Plan.
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TABLE OF CONTENTS Page
DECLARATION FOR THE RECORD OF DECISION i
EXECUTIVE SUMMARY ill
I. SITE LOCATION AND DESCRIPTION 1
II. SITE HISTORY 4
III. ENFORCEMENT HISTORY 5
IV. COMMUNITY RELATIONS HISTORY 5
V. SCOPE OF RESPONSE ACTION WITHIN SITE STRATEGY 6
VI. SITE CHARACTERISTICS - REMEDIAL
INVESTIGATION RESULTS ' 6
A. Geologic Setting 6
B. Physical Characteristic
and Extent of Contamination 7
C. Petroleum Exclusion 10
D. Potential Impacts of the Site
on Human Health and the Environment 11
VII. ALTERNATIVES EVALUATION 12
A. Description of Alternatives ; . 12
B. Evaulation Criteria 13
C. Evaluation of Alternatives 20
VIII. SELECTED REMEDY 24
A. Rationale 24
B. Documentation of Significant Changes 25
C Operation and Maintenance . 25
D Future Actions 25
IX. APPENDICES
A. State of New Mexico Response
B. Administrative Record Index
C. Responsiveness Summary
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FIGURES Page
1. Regional Location 2
2. Site Specific Location 3
3. Cross-Section 8
TABLES
1. Applicable or Relevant and Appropriate
Laws and Regulations 14
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Summary of Remedial Alternatives for the
San Jose 6 (SJ-6) Superfund Site
Albuquerque, New Mexico
I. SITE LOCATION AND DESCRIPTION
The San Jose (SJ-6) Superfund site lies within about 1 square mile on the
southern margin of Albuquerque, New Mexico (Figure 1), immediately north of
an area known as the South Valley. Because chlorinated solvents were detected
in groundwater discharged from SJ-6, the Superfund investigation centered
around the well. The total site is comprised of the SJ-6 well and six industrial
facilities in this square mile that were investigated by the Environmental
Protection Agency (EPA). The EPA studies for this decision were focused on
determining the sources and extent of contaminants detected in SJ-6. The
EPA studies were conducted in the general vicinity surrounding, rath-er than
on, the six facilities. Each of the six facilities conducted their own
investigations on their sites under EPA guidance.
Land use is essentially industrial and agricultural with interspersed open land.
Residential areas lie immediately north of the site. The western two-thirds of
the study area is essentially flat and lies about 4950 f&et above mean sea< level
(MSL). Alluvial fan deposits to the east cause a sharp ipse in topography, to
about 5010 feet MSL.
There are three municipal water supply wells in the area -that are currently
out of service. These are the San Jose well No. 3 (SJ-3), the San Jose well
No. 9 (SJ-9), and SJ-6. SJ-3 is out of service due to mechanical problems
and SJ-9 has never been equipped or used. SJ-6, which EPA has replaced witn
a new municipal well, has been out of service since 1980 due to groundwater
contamination. The only wells known to be in active use are for light industrial
or domestic purposes (ESI-1, A-2, and BC-2). There are two known domestic wells
north of the site.
The six major industrial facilities involved in site investigations at tne site
are General Electric (formerly Air Force Plant 83), Chevron, Texaco, Duke City,
Whitfield, and the Edmunds Street property (Figure 2). The owners of tnese
properties have been identified as being potentially responsible for
contamination of soil and groundwater in the vicinity of SJ-6.
Activities in the area are primarily industrial and agricultural. Solvents have
been used' for manufacturing in the plant that GE now owns since 1948. Petroleum
products are handled at the Chevron and Texaco facilities. Also, -a 6-inch
petroleum products pipeline enters the Chevron property from the south,
approximately parallel to Broadway. Secondary lines branch from this trunk to
the east, towards the airport. The Duke City operation consists of handling and
repackaging petroleum and related automotive products. At the Whitfield property
tank trucks were refueled, cleaned, and repaired. Various chemicals, including
chlorinated solvents, were repackaged and shipped from the Edmunds Street
property for approximately the past 20 years.
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SUPERFUND STUDY AREA
10 MILES
FIGURE 1
SUPERFUND STUDY AR
LOCATION MAP
SJ-6 SUPERFUND SITE
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II. SITE HISTORY
By the 1940's, industrial development had begun in the South Valley area.
The manufacturing of metal parts started around 1948. By the 1960's,
organic chemicals were being handled. Presently, petroleum fuels and
various chlorinated organics are stored, handled, or used within the
study area.
Groundwater contamination was first suspected in 1978 when foul tastes and
odors were noted in groundwater from a private well on the Edmunds property.
Subsequent sampling showed that volatile organic compounds (VOC's) including
1,1-dichloroethane (1,1-DCA), 1,1-Dichloroethene (1,1-DCE), Trichloroethane
(TCA), Perqhloroethene (PCE), and 1,1,1-Trichloroethene (1,1,1-TCE) were
present in three municipal wells (Miles No. 1 (M-l), SJ-3, and SJ-6).
Well M-l was returned to service in 1981 after it was resampled and found
to be contaminant free. Well. SJ-3 had mechanical problems that prevented
its return to service. Because low levels of solvents continued to be detected
in groundwater from SJ-6, this well, which was put into service in the early
1960's, has been out of service since 1980. It was contamination in groundwater
from SJ-6 fiat led to extensive studies of the site.
Studies have been1
(NMEID), the EPA,
performed by the New Mexico Environmental Improvement Division
and the potentially responsible parties.
NMEID collected background data on the study area uses, and collected soil andl
groundwater data.- These studies formed the basis for subsequent EPA activities^
Because1of the potential threat to the Albuquerque municipal water supply, this
site was designated as the State's highest priority and thus made eligible for
study in 1982 under the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA).
EPA conducted two phases of site characterization work, one in 1984 and 1985
(Phase I) and additional studies from November 1985 to April 1987 (Phase II).
The initial study was broad-based. Information was gathered on soils, the
vadose zone, surface water, sewers, drains, and groundwater. Details of tnis
broad-based investigation can be found in the Phase I South Valley Remedial
Investigation Report (1985). As a result of the initial EPA studies, the
subsequent investigations (1985-1987) were directed towards examining
groundwater quality and the hydrogeologic systems. During this second phase of
study, extremely low detection limits were developed for groundwater analyses to
accurately define the potential cancer risks at the site. Details of this study
can be found in the SJ-6 Superfund Site Remedial Investigation Report (May, 1933)
EPA also, completed studies in 1984 to evaluate remedial measures to address the
loss of SJ-6 water capacity. These studies resulted in a decision to
replace SJ-6 with a new municipal well, the Burton No. 4. This well
was put into service in July, 1988.
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PRP investigations were done under EPA review but the results are not consistently
comparable between individual PRP and EPA studies. This is due to differing
field methods, analytical techniques, and investigation objectives. Comparable
PRP data were used for the EPA May 1988 analysis and reports.
All of the previously mentioned reports are available for review at the admin-
istrative record repositories and are identified in the Administrative Record
Index found in Appendix B. Investigations at the Edmunds Street facilities are
continuing and should be complete in December 1988.
III. ENFORCEMENT HISTORY
Following the listing of the SJ-6 South Valley Superfund site on the National
Priorities List, EPA entered into negotiations with present and former owners
and/or operators of the six industrial properties. These negotiations resulted
in a September 1984 agreement for investigations of the six properties. Invest-
igations took place in 1984 and 1985 and were followed by a report on the results
at each property. Further work was deemed necessary at two properties, Former
Air Force Plant 83 (now the GE facility) and the Edmunds Street property.
The additional work for both properties was completed in 1988 although all
negotiations have not been received. Reports detailing results of this additional
work are in different stages. The report for Former Air Force Plant 83 became
available in August 1988. The results of the work at the Edmunds Street
property has been split into two parts. The first portion dealing with groundwater
became available in June 1988 and was followed by a Record of Decision on a
contaminant plume moving east from the Edmunds Street property. The second
part, dealing with contaminant sources, should be available in November 1988.
Subsequent Records of Decision will be developed based on the results of both
the Air Force and Edmunds Street reports. These decisions should be reached
in September and December 1988, respectively.
IV. COMMUNITY RELATIONS HISTORY
Due to the possibility of contamination of the entire San Jose Well field, trie
South Valley site has received extensive media attention. However, because
of the heavily industrialized nature of the site and the lack of exposure to
contaminants, citizen concern has been limited to the immediate area.
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.
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On July 6, 1988, EPA issued a press release and the Proposed Plan fact
sheet for the SJ-6 segment. The press release was mailed to all news
organizations in the Albuquerque area while the fact sheet was mailed to
142 residents and local officials. Extra copies of the fact sheet were
provided to the three local repositories for distribution and display.
In accordance with CERCLA, Section 117, the press release and the fact
sheet announced the comment period which began July 11, 1988, and ended
September 2, 1988. A public meeting was held on July 21, 1988, in
Albuquerque. Approximately 100 people from the area attended the meeting
raising questions and 'making comments regarding the proposed plan. The
Responsiveness Summary which outlines these comments as well as EPA's reply
is included as Appendix C.
V. SCOPE OF RESPONSE ACTION WITHIN SITE STRATEGY
The scope of the SJ-6 Investigation, as discussed in Section II Site History,
was to determine the source and extent of contaminants in groundwater that
supplied SJ-6. This response action addresses only conditions in the general
vicinity surrounding the PRP properties. It is not intended to address the
principal threats at the site. Through remedial actions being initiated by
EPA, notably the USAF/GE and the Edmunds St. decisions,the sources and
emanating plumes of contamination will be addressed. These remedies are
or will be described in separate documents. They are the Edmunds St. Ground-
water Operable Unit (6/28/88), the Edmunds Street Source Control Operable
Unit (12/88), and the Former Air Force Plant 83/ General Electric Record of
Decision (9/88).
This remedial action is being selected in consideration of the other anticipated
remedial actions as well as the completed EPA remedial action of replacing
SJ-6 with a new municipal well.
VI. SITE CHARACTERISTICS - REMEDIAL INVESTIGATION RESULTS
GEOLOGIC SETTING
The study area lies within the Albuquerque Basin of central New Mexico.
This Basin forms the middle section of the Rio Grande Valley, which extends
north into Colorado and south into Texas, and is part of the Rio Grande
Rift Belt. The rift consists of north-south interconnected structural
basins, bordered on the east and west by uplifted fault blocks. Valley-fill
sediment's in the study area are composed of gravel, sand, silt, and clay,
including alluvial fan and flood-plain deposits. As stated in Section I,
the western portion of the site is essentially flat and is about 4950 ft.
MSL. Except for the Edmunds Street facility, all the PRP properties lie in
the western segment. To the east, where the Edmunds property is located,
the topography rises sharply to about 5010 ft. due to the presence of alluvial
fan deposits.
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PHYSICAL CHARACTERISTICS AND EXTENT OF CONTAMINATION
There are five geologic units that generally correspond to hydrogeologic
zones identified beneath the study area (Figure 3):
1. A Shallow Zone (approximately 0-35 ft)
2. A Silty Clay Aquitard (approximately 25-40 ft)
3. Alluvial Fan Deposits (approximately 0-120 ft)
4. An Intermediate Zone and (approximately 40-110 ft)
5. A Deep Zone (approximately 100 ft - several thousand ft)
These units appear to be dipping towards the east. Their associated geol-ogic
and hydraulic characteristics are briefly described below. The potential
for migration and extent of contamination are also discussed.
Shallow Zone
The shallow groundwater producing zone, ranging in depth from 0 to 35 ft,
is composed of fluvial sand and gravel deposited by the Rio Grande. This
zone forms the surface layer of the western two-thirds of the study area.
These sediments grade into alluvial fan deposits to the east. The Shallow
Zone is unsaturated for about half of its thickness. The gradient can be
determined only on a very local scale. However, for the square mile area
it is highly variable and is daily and seasonally influenced, making flow
direction for the overall site unpredictable. The vertical hydraulic
conductivity ranges from 0.016 ft/day to 0.91 ft/day while the horizontal
conductivity averages 210 ft/day.
Contamination in the Shallow Zone is concentrated beneath the Chevron,
Texaco and GE properties. Total VOC accumulation is generally below 1000
ppb (parts per billion) but locally as high as 8598 ppb. Volatiles in the
Shallow Zone are primarily petroleum compounds, except for the solvents
detected beneath GE. Semi-volatile (pentachlorophenol) and inorganic
concentrations are highest beneath Chevron. The presence of these compounds
coincides with, and is probably caused by, the high petroleum concentrations.
Because of the variable hydraulic gradient, the direction of contaminant
migration can only be locally defined. For the total site, pathways cannot
be conclusively determined.
Silty Clay Aquitard
This aquitard, descriptively named, is composed of silty clay, ,is approximately
15 feet in thickness, and is generally continuous in the western two thirds
of the site. It interfingers with alluvial fan deposits and becomes discontinuous
to the east. It is also discontinuous to the south of GE. .The aquitard is
saturated and has a low vertical hydraulic conductivity averaging 8 x 10
ft/day.
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Contaminants generally migrate slowly through the aquitard.
However, discontinuities to the south of GE and laterally to the east
provide a more direct, and probably more rapid, contaminant route to the
Intermediate Zone. Groundwater samples were not collected from this zone.
Alluvial Fan Deposits
The topography rises about 50 ft from the Rio Grande floodplain towards the
Sandia Mountains, to the east. Erosion of the Sandia Mountains has resulted
in the deposition of alluvial fan sediments on the eastern margin of the
site. The Alluvial Fan deposits are composed of gravel, sand, silt and
clay. They extend from ground surface to a depth ranging from 75-120 ft.
The hydraulic characteristics of these deposits are unknown, but because of
the coarse-grained nature of the sediments they most likely have a high
hydraulic conductivity. Except for the lowermost parts, they are largely
unsaturated. The Edmunds Street property sits directly on these deposits.
Intermediate Zone
The Intermediate Zone consists of coarse-grained elastics that were deposited
by channel action. The top of this aquifer ranges from about 30 ft below ; '
the surface in the west to about 50 ft below the surface to the east, dipping'
towards the alluvial fan deposits. The bottom of the zone is about 110 ft
below the the surface. The hydraulic gradient is to the east and the
hydraulic conductivity averages about 99 ft/day.
Groundwater analyses from 1987 show that, with respect to chlorinated solvents,
groundwater meets Federal and State numerical criteria for drinking water
and groundwater, respectively, in the general vicinity of SJ-6. Groundwater
does not meet these criteria beneath and in plumes emanating from the PR?
properties. The Federal health criteria (an acceptable risk range of 10"4
to 10"7 or 1 in 10,000 to 1 in 10,000,000 excess cancer cases) are also rnet
in the vicinity of SJ-6. EPA sampled a total of 32 Intermediate Zone r.onitonm
wells, in the vicinity of SJ-6 as well as on the PRP properties. In 22 of
these wells, chlorinated solvents were below all State and Federal numerical
criteria. In two of the 32 wells, all criteria were met but the State
health standard (an acceptable risk of 10~5 or 1 in 100,000 excess cancer
cases). The remaining 8 wells are associated with contaminants PRP properties.
Although below numerical criteria, the concentrations of 5 ppb and 3 ppb of
1,1-Dichloroethene in groundwater from these two wells cause the State
health criteria of 10~5 to be exceeded. High concentrations (8700 ppo
benzene) of petroleum product were detected in a well immediately north of
the Edmunds Street property, adjacent to an eastward trending branch of a
petroleum products pipeline. Solvents and petroleum do not appear to be
comingled in the Intermediate Zone, forming fairly distinct contaminant
plumes.
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10
The two nearest residential wells are about 1 block northeast of the site,
and are thought to be screened in the Intermediate Zone. These wells were
sampled in 1988 and contamination is below State and Federal numerical
criteria and Federal health criteria. The State 1CT5 criteria is exceeded
in one well which is used solely for irrigation. The drinking and household
water source for these individuals is the municipal water system. Several
of the municipal water wells in the area, although contaminants had been
detected in 1981, have been sampled approximately nine times through 1988,
and no contaminants were detected. Recent sampling (1988) of municipal
well SJ-1, SJ-6, and some PRP wells also show decreasing solvent
concentrations, indicating trends of improvement.
Deep Zone
The Deep Zone consists primarily of fine-grained sand but is laterally and
vertically heterogeneous. The Intermediate and Deep Zones, although hydraulically
connected, were defined separately to emphasize the differences in lithology,
primarily grain size and hydraulic characteristics. The Deep Zone is directly
connected to the deeper aquifer that provides municipal water for the city
of Albuquerque. The average horizontal conductivity in the upper parts of
the Deep Zone (100 - 240 ft) is 17 ft/day and at the depth of SJ-6 (180-912
ft) it is 6.4 ft/day. Flow in the Deep Zone is currently towards tne: east.
Contaminants, other than those associated with PRP plumes, were not detected
in groundwater from the upper parts of the Deep Zone. In groundwater discharged
from SJ-6, 1,1-dichloroethene was detected that exceeds the State numerical
criteria by 3 ppb and the Federal criteria by 1 ppb. The Federal health
standard is met but the State 10"5 health criteria is exceeded.
Arsenic, which occurs naturally in the groundwater, contributes substantially
to the total health threat.
The chlorinated solvents that were detected very likely do not represent
contamination of the aquifer, but a local phenomena. SJ-6 was completed in
1963 and was near the end of its design life in 1981. Over this 20-year
period, about 100 ft of sediment accumulated at the base of SJ-6, as typically
occurs in sandy environments. Contaminants appear to have travelled down
the SJ-6 borehole and adsorbed to this sediment. It now seems to be acting
as a secondary source.
A more detailed description of the analytical results can be found in the
Phase II SJ-6 South Valley Remedial Investigation Report (1988).
PETROLEUM EXCLUSION
Section 101(14) and 101(33) of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 excludes petroleum from consideration
as a hazardous pollutant under the Federal Superfund program. EPA's studies
found significant levels of petroleum contamination in the Shallow and
Intermediate Zones. The City of Albuquerque and the State of New Mexico may
have legal authority that is absent'at the Federal level to address this
type of contamination. The information regarding petroleum contamination
has, therefore, been turned over to State and City governments.
-------
11
Hazardous substances-that can be legally addressed under Superfund were
not found to exceed health levels in the groundwater contaminated by petroleum.
Therefore, petroleum contamination must be addressed solely by State and
local authorities. The problems are being investigated under the jurisdiction
of the Underground Storage Tank Trust Fund and the New Mexico Uater Quality
Criteria (Part I, Section 203).
POTENTIAL IMPACTS OF THE SITE ON HUMAN HEALTH AND THE ENVIRONMENT
Groundwater, on which the health assessment focused, is the primary media
of concern in the vicinity of SJ-6. The potential risk from the site was
comprehensively evaluated using the maximum reported contaminant concentrations
from 1985 and 1987 groundwater data. The risk assessment shows that there
are no exceedances of Federal health criteria and local exceedances
of State health criteria. The lower bound for the Federal criteria is
10~4 which means that an individual will have a cancer risk of 1 case in
10,000 people, and the State criteria is 1 case in 100,000 for 10"D.
Because of source control and contaminant plume remediation being implemented
through other EPA actions, EPA anticipates that the low concentrations
present at the site will be well below this criteria within a 70-year period,
more likely within 5 years. It does not appear that the public will- be
exposed to any of these contaminants over a 70-year period and the risk
posed by the compounds is negligible.
Chlorinated solvents in groundwater are below State and Federal numerical
criteria in the vicinity of SJ-6. In 1987, 8 ppb of 1,1-dichloroethene
were detected in groundwater from SJ-6 (State standard-5 ppb; Federal standard-
7 ppb). This concentration and naturally occurring arsenic cause the New Nexico
10~5 health criteri.a to be exceeded. The chlorinated solvents detected
in SJ-6. most likely do not represent groundwater comtamination, but contamination
of sediments at the base of the well.
The Federal health standards are also met in the areas surrounding SJ-6,
but the State health standard of no more than 1 in 100,000 (10~5^ excess
cancer cases is exceeded in groundwater from two Intermediate Zone monitoring
wells. The 1,1-DCE and arsenic detected in SJ-6 cause the New Mexico 10~5
health criteria to be violated. One residential well located northeast of
the site, although below all other criteria, also exceeds the State health
standard. Due to the above reasons, these contaminants do not appear to
pose a significant health threat.
-------
12
VII. ALTERNATIVE EVALUATION
DESCRIPTION OF ALTERNATIVES
In conformance with the National Contingency Plan, initial remedial approaches
were screened to determine the most appropriate treatment methods and systems
for dealing with groundwater contamination at the site (see the SJ-6 Superfund
Site Feasibility Study (1988) for details of this evaluation). EPA anticipates
that source control and groundwater remediation will be implemented through
Enforcement initiatives. These anticipated actions were considered during
development of the groundwater remediation alternatives. They also formed
the basis for definition of hPA's target area in the vicinity of SJ-6.
From screening of the initial remedial alternatives, eight were selected
for detailed analysis. Of these eight, six utilize the same treatment
processes but the rate and configuration of pumping wells and the discharge
option for treated water are varied. As previously mentioned, these alternatives
deal only with groundwater contamination in the vicinity of SJ-6. Each is
summarized below:
Alternative 1 - No Action
1 ' ' ' ' ' ' .-.,,.,.-. t
This alternative consists of monitoring groundwater during and following
implementation of source control and groundwater remediation by the PRPs.
The No-Action alternative is included to evaluate the present degree of
threat to public health and the environment and as a comparison to other
alternatives. Included in the No-Action alternative is groundwater monitoring
for 30 years and access restrictions to the Shallow and Intermediate Zones.
Access restrictions will most likely consist of well construction methods
that prevent cross-contamination of zones and screened intervals that are
below the top of the Deep Zone. It includes monitoring well constr:ction
and groundwater analyses. The cost of this alternative is approxi tely
$1.7 mil 1 ion.
Alternative 2 - Sealing Abandoned Wells, Groundwater Monitoring,
and Access Restrictions
This alternative consists of cleaning out and sealing abandoned
wells that are acting as conduits for contaminant migration. Even though
contaminants at low concentrations migrate vertically to underlying zones
through the sediments themselves, conditions in SJ-6 suggest that the
fastest and primary route for contaminant migration is through abandoned
wells at the site. Sixteen abandoned wells have been identified but it is
not clear if they are all acting as conduits. These wells will be evaluated
as part of remedial design. Two wells that have a greater potential to act
as conduits are SJ-6 and a well located on the USAF/GE property. At the
base of SJ-6, about 100 ft of sediment have accumulated. Contaminants have
very likely adsorbed to these sediments. As part of this alternative,
these sediments w.ill be removed. If after sediment removal, additional
testing shows that contamination above standard persists, this contamintion
will be further evaluated. The integrity of other abandoned wells will oe
checked before they are sealed.
-------
13
Groundwater quality will be monitored during and after implementation of
remedial action, for a 30 year period. Access restrictions regarding well
construction specifications and depth of completion will also be imposed
through the State Engineer's office. These will apply only to the
construction of new wells in the area and will not affect existing
wells. Monitoring wells will be installed in close proximity to the existing
residential wells to ensure protection of the public health. Access restrictions
will not prevent the use of groundwater in the area. They will ensure that
wells are constructed to prevent cross-contamination of zones and that they
are completed at a great enough depth to prevent exposure to any contaminants,
whether they be petroleum or chlorinated solvents. The cost for this alternative
is about $4 mill ion.
Alternatives 3 through 8 - Pump and Treat Alternatives
These alternatives involve the use of extraction wells for groundwater
containment and collection with groundwater treatment using conventional
technologies. Pumping alternatives would create a vertical hydraulic gradient
that would draw petroleum from the Shallow Zone to the deeper zones. To
prevent degradation .of the deeper zones by petroleum, it would be necessary
to remove floating petroleum product found in the Shallow Zone. To do
this, a separator would be used followed by an adsorption system to filter
any residue. Air stripping would remove volatiles, the emissions of
which would be passed through an activated carbon filter.
Semi-volatiles can be removed using aqueous phase carbon absorption followed
by an oxidizing process with a greensand filter to remove metals. Discnarge
of treated groundwater would be either to surface water or to the city
water supply system.
The primary differences between the alternatives are in pumping rate, config-
uration of wells, and point of discharge. Recovery in the Shallow Zone
could be done with either a-number of small wells or a trench. Recovery in
the Deep Zone could 'be done by pumping SJ-6 or installing new deep wells
for extraction.
EVALUATION CRITERIA
To ensure compliance with Section 121(a) through (d) of the CERCLA, the
following nine factors were considered in selecting a remedy for the SJ-6
portion of the site.
1. Consistency with other Environmental Laws (ARARs).
In determining appropriate remedial actions at the SJ-6 site, consideration
was given to the requirements of other Federal and State environmental
laws, in addition to CERCLA as amended by SARA. Primary consideration was
given to attaining applicable or relevant and appropriate regulations (ARARs
required by Federal and State government. These are listed in Table 1.
Not all Federal and State environmental laws and regulations are applicable
to each Superfund response action.
-------
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17
The most significant decision-making criteria were the Safe Drinking Water
Act Primary Drinking Water Standards, the New Mexico Part 3-103 Groundwater
Standards, and the New Mexico Part 1-101 UU Toxic Pollutant Criteria.
The 1-101 UU criteria mandates that any water contaminant or combination of
listed water pollutants that creates a lifetime risk of more than one cancer
per 100,000 exposed persons is a toxic pollutant. Compounds at the SJ-6
site that create this level of risk are 1,1-dichloroethene, benzene, and
arsenic. The benzene is associated solely with petroleum. The numerical
criteria for these compounds are as follows:
Safe Drinking Water Act
1,1-DCE 7 parts per billion
Benzene 5 parts per billion
Arsenic 50 parts per billion
New Mexico Water Quality
Criteria
5 parts per billion
JO parts per billion
100 parts per billion
2. Reduction of Toxicity, Mobility or Volume
The degree to which alternatives employ treatment that reduces
toxicity, mobility, or volume were assessed. Relevant
factors Were:
o The treatment processes the remedies employ and materials
they will treat;
o The amount of hazardous materials that will be destroyed;
o The degree of expected reduction in toxicity, mobility
and volume;
o The degree to which the treatment is irreversible;
o The residuals that will remain following treatment,
considering the persistence, toxicity, mobility, and
propensity for bioaccumulation of such hazardous substances
and their constituents.
3. Short-term Effectiveness
The short-term effectiveness of alternatives was assessed,
considering appropriate factors among the following:
o Magnitude of reduction of existing risks;
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18
o Short-term risks that might be posed to the community, workers,
or the environment during implementation of an alternative,
including potential threats to human health and the environment
associated with excavation, transportation, and redisposal or
containment;
o Time until full protection is achieved.
4. Long-term Effectiveness and Permanence.
Alternatives were assessed for the long-term effectiveness and
permanence they afford along with the degree of certainty that
the remedy will prove successful. Factors considered were:
o Magnitude of residual ri'sks in terms of amounts and concen-
trations of waste remaining following implementation of a
remedial action, considering the persistence, toxicity,
mobility, and propensity to bioaccumulate such hazardous
substances;
o Type and degree of long-term management required, including
monitoring and operation and maintenance;
o Potential for exposure of human and environmental receptors
to remaining waste considering the potential threat to human
health and the environment associated with excavation,
transportation, redisposal, or containment;
o Long-term reliability of the engineering and institutional
controls, including uncertainties associated with land
disposal of untreated wastes and residuals;
o Potential need for replacement of the remedy.
5. Implementability.
The ease or difficulty of implementing the alternatives were
assessed by considering the following types of factors:
o Degree of difficulty associated with constructing the technology;
o Expected operational reliability of the'technologies;
o Need to coordinate with and obtain necessary approvals and
permits (e.g., NPDES, Dredge and Fill Permits for off-site
actions) from other offices and agencies;
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19 ,'i
o Availability of necessary equipment and specialists;!
o Available capacity and location of needed treatment,, storage,
and disposal services.
6. Cost.
The costs that were assessed include the following:
o Capital cost;
o Operation and maintenance costs;
o Net present value of capital and 0 & M costs;
o Potential future remedial action costs.
7. Community Acceptance.
This assessment considered:
o Components of the alternatives that the community supports;
o Features of the alternatives about which the community has
reservations;
o Elements of the alternatives which the community strongly opposes.
8. State Acceptance.
'Evaluation factors included assessments of:
o Components of the alternatives the State supports;
o Features of the alternatives about which the State has
reservations;
o Elements of the alternatives under consideration that the
State strongly opposes.
9. Overall Protection of Human Health and the Environment.
Following analysis of the remedial options against individual
evaluation criterion, the alternatives were assessed from the
standpoint of whether they provide adequate protection of human
health and the environment considering the multiple criteria.
EPA is also directed by SARA to give preference to remedial actions that
utilize treatment to remove contaminants from the environment. Off-site
transport and disposal without treatment is the least preferred option
where practicable treatment technologies are available.
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EVALUATION OF ALTERNATIVES
In the vicinity of SJ-6, all Federal and State Numerical criteria are met
with the three previously described exceptions. All Federal health
criteria are also met. The three exceptions to these statements are:
Federal numerical criteria are exceeded in SJ-6 by 3 ppb of 1,1-DCE and the
State health criteria is slightly exceeded in two Intermediate Zone
monitoring wells.
The contaminants detected in SJ-6 are not viewed as an aquifer contamination
problem for the reasons discussed in the Physical Characteristics and Extent
of Contamination section of Part VI - SITE CHARACTERISTICS. Although the
New Mexico health standard is locally exceeded in these two wells, the 22
wells that are below all State and Federal standards show that this is a
local problem. This will be dealt with in other decisions regarding the
site. Arsenic detected in SJ-6 is naturally occurring in groundwater of
this region. Because it is naturally occurring, arsenic is not considered
to be a Superfund contaminant in this instance. The City is aware of and
plans for this problem.
This evaluation intends only to address conditions in the vicinity of'SJ-5.
It does not intend to address the principal threats at the site, which are
the sources on, and the associated groundwater plumes emanating from, the
PRP properties. The principal threats are being addressed in separate
decisions. These decisions are the Edmunds Street Groundwater Operable
Unit (6/28/88), the Edmunds Street Source Control Operable Unit (!s.t qtr/39),
and the Former Air Force Plant 83/ General Electric Record of Decision
(9/38).
To ensure compliance with Section 121 (a) through (d) of CERCLA, the
following nine criteria were considered in selecting a remedy for the
SJ-6 portion of the site:
1. Applicable or Relevant and Appropriate State and Federal
Standards (ARARs) '. ~
a. No Action. This option would leave a "halo" of groundwater
contamination at the base of the SJ-6 well which would not
meet the New Mexico 10~5 health criteria for arsenic and
solvents. It is possible that natural attenuation would
eventually result in attainment of standards but this would
take several years.
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21
b. Sealing Abandoned Wells, Groundwater Monitoring, Access
Restrictions.This would include the excavation and disposal
of sediments at the base of the SJ-6 borehole which EPA nas
judged to be the source of elevated solvent contamination.
This remedy would therefore attain all applicable or relevant
and appropriate standards.
c. Pump and Treat Alternatives. All of these remedies would
eventually cleanse the aquifer near SJ-6 to meet standards.
However, active pumping from the SJ-6 well and vicinity could
interfere with attainment of standards by the pumping systems
proposed for the GE/USAF and Edmunds Street portions of the
site.
2. Reduction of Toxicity, Mobility, and Volume
a. No Action. Because the major sources of contamination will be
removed by decisions for other areas of the site,
residual contamination will become virtually nondetectable.
Through natural attenuation, the toxicity, volume, and
consequently the mobility will be reduced. This alternative
would not prevent the vertical migration and accumulation of
contaminants through boreholes. In this alternative petroleum
contamination is not addressed.
b. Seal ing Abandoned Wells, etc. Toxicity and volume as well
as mobility would be reduced with this alternative. The
potential threat to the deeper zones, which supply drinking
water to the city of Albuquerque, would be prevented. This
alternative would have the added benefit in the short-term of
preventing vertical migration from the Shallow Zone to deeper
aquifers. Groundwater monitoring would also be performed to
ensure remedy effectiveness.
c. Pump and Treat Alternatives. All of these alternatives
would effectively reduce toxicity, mobility, and volume of
contaminated groundwater by creating a hydraulic capture zone
and implementing groundwater treatment. Since contaminants are
currently below numerical standards, these actions would quickly
remediate residual solvents.
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22
3. Short-Term Effectiveness
a. No Action. Since solvent contamination is currently below standards
in the vicinity of SJ-6, or is being otherwise addressed, the No-Action
alternative would be effective in the short term. In this
alternative, as in all others, groundwater monitoring would ensure
the effectiveness of the remedy.
b. Sealing Abandoned Wells,etc., would be as effective as the No-Action
alternative in the short-term since construction of this remedy
would not begin for at least eighteen months. This time is required
for development of design plans and bid specifications.
c. Pump and Treat alternatives would have the same short-term
effectiveness as the No-Action for the same reasons as Alternative 2,
Sealing Abandoned Wells.
4. Long-Term Effectiveness
a. No Action. Although natural attenuation wo,uld reduce existing
levels of contamination, abandoned and open "boreholes would
remain a potential, conduit for future pollution. This option
is judged the least effective in the long-term.
b. Seal ing Abandoned Hells. This alternative is judged most effective
in the long term because it would:
i. restrict pathways for future contamination through boreholes,
ii. remove contaminant-bearing sediments that may act as a
continuing source of contamination, and,
iii. encourage and be consistent with future State and City
well-head and aquifer protection programs.
c. Pump and Treat Alternatives would, similar to the '//ell-Sealing
option, be effective near SJ-6.
5. Im'plementabil ity
a. No Action. This criterion is not applicable for the No Action
remedy described in this Record of Decision.
b. Sealing Abandoned Wells. Technology to implement this remedy
is readily available and is highly implementable. State and
Local systems to protect the aquifer in the future are not yet
in place but are judged to be feasible based on well-head
protection programs in other parts of the country.
c. Pump and. Treat Remedies. Conventional method's and equipment
are readily available for all of the pump and treat remedies.
The technologies are straight-forward and easily implemented.
Trenching for groundwater recovery from the Shallow Zone
would present problems due to the difficulty of obtaining
the required physical access.
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23
6. Cost
Cost evaluation1, detailed in the Feasibility Study for this Record of Decision,
are summarized below ($ millions):
a. No Action
Capital Costs Annual 0 & M Total Present Worth
$0.4
$0.3
$1.7
b. Uell Sealing, etc. $0.9
c. Pump 6 Treat alts. $19.0 - $33.0
7. Community Acceptance
$0.3 $4.0
$1.6 - $2.3 $43.0 - $ $69.0
Because the South Valley San Jose site is complex in terms of the kinds of
contaminants, hydrogeology, and numbers of potentially responsible parties,
-there was a good deal of public confusion attendant to EPA's proposal for the
SJ-6 site remedy. There also was confusion regarding the impact of the
petroleum exclusion. The public see*ms to believe that contaminants were
present above standards andlare pervasive throughout the site area, despite
EPA's data to the contrary.! Owners of residential wells stated that their
water was not fit for consumption because it looked, tasted and smelled foul,
you could see a brown layer in it, and it caused health problems for their
children.
To ensure the public was fully involved and informed, EPA extended the SJ-6
comment period from the required 21 days to over 50 days. Tnis added time
allowed the remedy for the GE/USAF portion of the site to be presented and
explained as a necessary component of overall site remediation. It also
allowed for two public meetings and a workshop to be held regarding the site
and a public workshop regarding the availability of Technical Assistance
Grants to be held.
All comments and questions received during the public comment period are
answered in writing in the Responsiveness Summary. This document will oe
disseminated to all interested parties. It is likely, however, that many
local residents will continue to believe that EPA is "walking away" from the
pollution problems in the San Jose area. Follow-up information bulletins ana
public workshops will therefore be offered to inform residents o'f the progress
of remediation.
8. State Acceptance
The Environmental Improvement Division has been a principal reviewer of all
studies and evaluations conducted at this site. At the July 21, 1983 public
meeting, representatives of the EID announced that they strongly objected to
EPA's proposed remedy. After*review and discussion of the viability of options
and EPA's public proposal regarding the GE/USAF site, the EID has modified
their position.
In a letter dated September 13, 1988, the EID indicated that the proposed ,
remedy for SJ-6 might be supported pending a review of the final decision for
the GE/USAF portion of the site. f
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24
9. Overall Protection of Human Health and the Environment.
a. No Action. While solvent contamination is not now a threat, the 16
abandoned and open boreholes near SJ-6 pose a threat to the environment
and the health of water users.
b. Sealing Abandoned Wells, etc. This remedy would provide longterm
protection to the environment and human health because contaminants
at the base of SJ-6 will be removed and physical (i.e. plugging) as
well as institutional controls will be put in place.
c. Pump and Treat Alternatives. At most, these alternatives would
equal the protection provided by sealing, abandoned wells and groundwater
monitoring. Based on EPA's most recent sampling event (1987), groundwater
is below all numerical criteria for contaminants. It is also below
all Federal health criteria. There are two exceedances of the State
Health criteria. In view of these very localized, very low concentrations,
the State health criteria will not be exceeded for any length of
time. There will be no added benefit to implementing a pump
and treat alternative'.
VIII. SELECTED REM8DY: SEALING ABANDONED WELLS, GROUNDUATER MONITORING
AND ACCESS RESTRICTIONS
RATIONALE
This remedy was considered superior to the No Action alternative
because:
1. It provides for removal of contaminants at the base of the
well which may serve as a source of contamination for drinking
water supplies.
2. It greatly reduces the possibility that existing well well
become future conduits of pollution to drinking water supplies.
3. It provides for long-term monitoring to ensure that the physical
measures undertaken and institutional controls enacted do, in
fact, work as expected.
The pumping and treatment remedies were rejected over the selected
remedy for the following reasons:
1. They would result in negligible decreases in site contamination
in the vicinity of SJ-6 over the plugging remedy at far greater
cost ($4 million compared to $70 million).
2. Pumping water from SJ-6 could cau.se needless interference with
pumping regimes for treatment efforts at the GE/USAF and Edmunds
street properties.
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25
The expenditure of additional funds to implement a pump and treat remedy at
the SJ-6 site would not result in significant additional protection of human
health or the environment. Sealing abandoned wells, groundwater monitoring,
and assessing conditions after 5 years will protect public health and the
environment. The State concurs with this remedy if the other site decisions
are implemented.
DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes to this Record of Decision were necessary from the
Proposed Plan of July 1988.
OPERATION AND MAINTENANCE (0 & M)
The need for future operation and maintenance will be minimal since source
control remediation-will be implemented through other actions. These
actions are outlined in the respective Records of Decision for the
Edmunds Street Property and the USAF/GE facility. Site operation and maintenance
will include groundwater monitoring, any repair of monitoring wells that may
be required, and periodic site inspections. Operation and maintenance will
be the responsibility of the State of New Mexico 1 year after the remedy is
implemented.
FUTURE ACTIONS
A Design Review Committee wil be created within 90 days after this Record
of Decision is signed. This committee will include representatives of EPA,
NMEID, the City of Albuquerque, arid involved private parties. Its function
will be as a groundwater management team, to ensure that remedial designs
and action at the San Jose site are hydraulically integrated. At the very
least, this committee will make certain that respective actions do not
negatively impact each other. The statutory authority for the respective
actions will rest with the appropriate regulatory body.
The proposed remedial action for the site is considered permanent. However,
If there are significant increases in concentrations of contaminants previously
detected at the site, appropriate actions will be assessed.
SCHEDULE
Approved remedial action (sign ROD) September 1988
Start remedial design January 1989
Complete design July 1989
Start remedial action August 1989
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APPENDIX A
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Post Office Box 968 OARSE" SABBUTHEPS
Santa Fe. Naw Mexico 87504-0888 Governor
' ' Carla Muth
ENVIRONMENTAL IMPROVEMENT DIVISION s.er.tan,
Michael J~. Burkha
Richard Mitzelfelt - . -
11 I Director
HEALTH **> ENVIRONMENT
September 30, 1988
Mr. Allyn Davis, Director (6H)
Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region VI
1445 Ross Avenue
Dallas, Texas 75202-2733
Dear Mr. Davis:
While various details still need to be resolved during Remedial
Design, EID concurs with the conceptual remedy outlined in the
draft Record of Decision for the San Jose 6 Operable Unit of the
San Jose Superfund site. This concurrence is conditional o'n the
timely implementation of the remedy selected in the CE/USAF
Record of Decision. As with other individual remedies selected
for operable units at the San Jose site, the San Jose 6 remedy
alone does not address all potential threats to public health.
However, this remedy will play a part in the overall strategy to
do so.
Creation of a Design Review Committee, mandated in the San Jose 6
Record of Decision, will ensure that this and other remedies at
the San Jose site are coordinated to achieve site cleanup, In
addition, a review by EPA of environmental conditions and
Superfund remedies after five years is also required under this
Record of Decision, EID will work with EPA to evaluate
additional remedial actions if ground-water contamination above
standards is identified at this time.
Sincerely,
Richard Mitzelfelt
Director
EQUAL OPPORTUNITY EMPLOYE*
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APPENDIX B
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SAN JOSE WELL £6
SOUTH VALLEY SUPERFUND SITE
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
This Community Relations Responsiveness Summary has been prepared to provide
written responses to comments submitted regarding the proposed plan of action
at San Jose Well #6 portion of the South Valley hazardous waste site. The
summary is divided into two sections:
I. Background of Community Involvement
Due to the possibility of contamination of the entire San Jose Wellfiela.
the South Valley site has received extensive media attention.
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.
The press release and Proposed Plan fact sheet announcing the public
comment period and public meeting were distributed on July 6, 1933.
The comment period began on July 11, 1988 and was extended until
September 2, 1988. A public meeting was held for tne area residents
and local officials on. July 21, 1983 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 100 people from the area
attended the meeting, and 25 residents made oral statements or
asked questions. Eight written comments or questions were received.
Section II: Summary of Major Comments Received.
During the public comment period, there were comments/questions 'oral
and written) regarding several issues. These are summarized on 'he
following pages.
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Responsiveness Summary
SJ-6 South Valley
1. Comment:
Response
2. Comment:
Response
EPA failed to consider CERCLA §118 which requires that a
high priority be given to drinking water supplies. A
drinking water supply is contaminated and drinking water
wells have been closed.
EPA disagrees. Incorrect. The vulnerability of this
aquifer system and its importance as a resource is
documented in the Phase I Remedial Investigation (RI)
report. The primary goal of the Phase II remedial
investigation was quantification of the potential threat
to groundwater resources. EPA has given this aquifer
system the highest priority possible by viewing it as a
sole-source system.
SJ-6 is the only well that remains out of service due to
contamination. Concentrations in this well nave decreased
50% since 1981. The standard for 1, 1-DCE was exceeded, o'y
3 parts per billion (ppb) in the last sampling event, but
this most likely does not indicate groundwater contamination.
It appears to be the result of conditions in the wellbore.
All other municipal wells within or in close proximity to
the site have been recently sampled and are of drinking
water quality.
EPA has fully met the requirements of CERCLA §118.
EPA has violated CERCLA §121 cleanup standards in its
selection of an alternative which will not comply with
applicable state standards, specifically New Mexico
Water Quality Criteria (NMWQC) Regulations 3-103. A, 3,
and C and 1-101.UU.
EPA disagrees. The selected remedy will meet all numerical
standards of 3-103 A,B, and C. The New Mexico Environmental
Improvement Division (NMEID) 1-101.U.U. criteria defines
as acceptable a maximum, excess cancer risk of 1 in 100,000
cases. This standard is locally being exceeded but the
excess cancer risk falls within EPA's acceptable range
of 1 in 10,000 cases. EPA has carefully considered the
impact of these local State criteria exceedances within
the overall site strategy. Source control and remediation
in other EPA initiated actions will rapidly allow attenuation
of these areas. These do not pose a public health threat.
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Uithin the overall site strategy, comprehensive
remediation of sources and contamination emanating from
the sources is being undertaken.
Comment: EPA's cost analysis is problematic in that it does not
include costs for procuring alternate water supplies nor
does it consider the value of treated groundwater. Costs
for the required 5 year review of Superfund sites at
which hazardous wastes remain onsite are also not included.
Response: EPA, with consultation from the City of Albuquerque and
NMEID, designed and constructed a new municipal well to
replace SJ-6 at a cost of $1 million. The new well, the
Burton No. 4, has a greater capacity than the abandoned
San Jose 6 well and is more than adequate to replace tne
lost water supply.
The statutory 5-year review is required only at sites
where contaminants remain above health-based standards.
This is not the situation at the SJ-6 site. Costs for
the proposed alternative include quarterly sampling of 21
monitoring wells, quarterly sampling for 4 wells near
sewers, and analysis of 500 samples for a 30-year period.
Any changes in site conditions will no doubt be detected
with this samp! ing- approach. In addition, to address
concerns expressed by the state, a review of
environmental data will be conducted after the first 5
years have elapsed.
Comments: There is an invalid presumption that petroleum
remediation will not be undertaken, resulting in excess
cost and time estimates for petroleum remediation vs.
solvents.
Response: This is incorrect. The cost analysis addresses petroleur,-
related contamination as it pertains to, or interferes
with, various engineering aspects of remediation. Weignted
averages of contaminant concentrations were used in order
to deemphasize high concentrations of petroleum. Since
petroleum would be withdrawn as a result of any active
remediation, the treatment system had to be designed
accordingly. Time for remediation had to be estimated in
the same way. This is a realistic approach to the site
and does not overestimate the impact of petroleum on
remediation.
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Comment: EPA's proposal for access restrictions to groundwater use
and deed notices violates CERCLA's general requirements
and is legally questionable.
Response: This is incorrect. EPA is meeting the preference for
treatment and reduction of contaminants in the comprehensive
site approach.
Remediation and source control is being implemented in
several of the site subelements that will impact conditions
over the entire area.
' Access restrictions, which will consist of well construction
to prevent cross-contamination and completion at depths
at least greater than 200 ft. would be implemented under
any alternative except No-Action. The primary reason for
these restrictions is prevention of borehole migration
and any potential exposure until source control is effective.
These restrictions will be implemented through the State
Engineers office permitting procedure (Section 72-12-1
of New Mexico Statutes) that ,is required for installation
and use of all wells. The restrictions will not cause
water resources to be lost.
Comment: EPA has misapplied CERCLAs petroleum exclusion
and has refused to consider comingled contaminants.
Response: There do not appear to be any comingled contaminants at
the site. The language of the petroleum exclusion is
clear. Under Superfund, EPA can treat comingled
contamination. If, at some point, only petroleum is
being withdrawn from the groundwater system and treated,
EPA can no longer fund this Remediation, ijnder these
circumstances, EPA will not treat the petroleum
contamination back to the source.
Comment: EPA has failed to withdraw the outstanding RCRA 3013
Administrative Orders. EPA's ambivalence and failure to
withdraw these orders has hurt the State's enforcement
efforts.
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8. Comment:
Response: This is incorrect. EPA has received one informal
request to withdraw the RCRA 3013 Orders, These orders
require an entity to conduct investigations for suspected
contamination. This was an oral request from Wr. Pete
Maggiore of the EID UST program on 9/1/88, to release
Duke City Distributing from its order. EPA responded
that releasing Duke City would be no problem if NMEID
Superfund concurrence was obtained. In all other prior
conversations EID has requested that EPA retain these
orders to aid their enforcement efforts.
The public comment period for the San Jose 6 proposed
plan should be extended until after a decision on the
GE/USAF property is reached. If the GE/USAF remedy is
unacceptable, this will allow no time for comment on SJ-6.
Response: EPA disagrees. Degree of remediation is not negotiated
with responsible parties and each Record of Decision that
EPA signs must comply with all provisions of the
Superfund law. The comment period for SJ-6 was purposely
extend from the required 21 days to over 50 days to
endure the proposed remedies for both portions of the
site were before the public at the same time.
Comment: The proposed plan will not prevent the migration of contam-
inants horizontally or vertically.
Response: Sealing abandoned wells will significantly reduce downward
migration of water through abandoned wells. Abandoned
wells should be sealed as a matter of practice.
10. Comment
Flow rates documented in the RI make
additional municipal and private well
threatened.
it obvious that
s are imminently
Response: EPA disagrees. Flow rates in the RI 'are for groundwater
only. They do not account for movement of contaminants
in the groundwater. Data from the Edmund's Street study
document the eastern margin of the plume as being just
east of 1-25. Sampling of nearby municipal wells (1988)
show that these wells are not contaminated.
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11. Comment:
Response
12. Comment:
The deepest (and among the most troubling) contamination
at the site is not even mentioned in the proposed plan.
The RI determined that water pumped from SJ-6 remains
unfit for human consumption because of contaminated
groundwater drawn from the bottom of the screened zone.
EPA disagrees. All deep wells with the exception of
SJ-6 show no evidence of contamination. Contaminants
have apparently adsorbed to the 100 ft of accumulated
sediment at the base of SJ-6. These sediments are
most likely acting as a secondary source rather than the
deep zone being regionally contaminated.
Solvent concentrations in groundwater from SJ-6 have
decreased from 1981 to 1988 by 50%, supporting this
interpretation.
The selected remedy calls for removal of these sediments
from SJ-6 and if appropriate, other abandoned wells. If
contaminant concentrations are above ARARS after sediment
removal and appropriate testing, this situation will be
reevaluated.
The scope and goals of additional groundwater monitoring
efforts must be more clearly defined in the ROD.
Response: EPA disagrees. The selected remedy calls for monitoring
groundwater downgradient of the site. Design details are
not included in conceptual remedy selection.
13. Comment:
Alternatives to plugging valuable municipal wells have
not been evaluated.
Response: It is good practice to plug abandoned wells or seal
wells temporarily while they are out of service. Exactly
how the wells will be sealed is a design parameter.
14. Comment:
Response
The San Jose 6 Proposed Plan is not sufficiently
protective of public health. Not all routes of exposure
are evaluated and1the clean up level should be 10"5 for
individual chemicals.
EPA h'as established an acceptable cancer risk range between
10"4 to 10"7. The San Jose 6 site falls within this
range and meets all numerical State and Federal standards.
The proposed plan is protective of public health and the
vital groundwater resources of the area.
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15. Comment:
Response
Inhalation of VOC's from water can be a significant route
of exposure but there is no standardized risk exposure
model to estimate uptake of volatile organics from
bathing or showering. If showering scenerio was
considered, the excess cancer risk would be increased
marginally. For example, a 1E~5 excess cancer risk was
to be increased to a 2E~5.
The Remedial investigation did not identify or fully
explore other potential contaminant sources, especially
illegal dumping, sewer leakage, and petroleum sources.
Specific facilities such as Jencor, the Atchison, Topeka,
and Santa Fe Railroad (ATSF), and the Chevron facility
should be investigated.
EPA disagrees. All likely sources in the area have been
identified. Any areas that' require further study are
being investigated. Illegal dumping at what is known as
the Yale Landfill has undergone preliminary investigation
by the EPA and a follow-up is being done by the State.
This landfill is downgradient of the site and is not a
likely source for it.
Sewer leakage was investigated and detection of
contaminants was sporadic and insignificant. EPA
proposes to install monitoring1wel1s in close proximity to
specific sewers to ensure that they are not leaking.
The Jencor facility has been studied and found not to be
a source.
ATS&F as well as Chevron are involved in separate studies
with EPA and the State.
The organic contaminants detected in SJ-6 prior to 1931
included organic solvents and petroleum products.
Petroleum as a source of contamination to SJ-6 should not
be ignored.
Response: 1980 data indicate only that contaminants were present
but give no concentrations. Current data do not indicate
that petroleum has contaminated SJ-6.
16. Comment:
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7
17. Comment:
EPA has not defined its use of the terms "organic
solvents" and "petroleum products". "Organic Solvents"
appears to be restricted to chlorinated volatile organic
compounds while "petroleum products" are characterized by
organics such as benzene, toluene, ethyl benzene, and
xylene. Since petroleum contains organic solvents as
well as chlorinated solvents this delineation is
artificial and arbitrary.
Response: EPA disagrees. The use of these terms is defined on page
4-36 of the RI and App. A of the FS. It is clear that EPA
recognizes specific chlorinated .compounds as petroleum
additi ves.
18. Comment:
The RI report incorrectly refers to the SV-10 drainage
area as a "waste pit". It was actually constructed to
control drainage. EPA also inaccurately states that
organic chemicals- and solvents were used (rather than
repackaged) at the Edmunds site, and that spent solvents
were shipped there for disposal (rather than shipped to
an out-of-State recycling facility).
Response
EPA disagrees with this statement
indicates that drum washwater was
EPA's information
disposed of in the pit
19. Comment:
The RI states that Van Waters and Rogers (VWR) nandled
spent solvents from customers for subsequent disposal by
a waste-transportation company.
The RI report omits reference to two wells, one at
Chevron and one at Duke City, which were taken out of
service in 1961 due to taste and odor problems.
Response: EPA is aware of these wells but has no data regarding them.
20. Comment
Response
The shallow aquitard and related shallow aquifer does not
exist anywhere in the eastern portion of the SJ-6 area.
The aquitard should be considered as occurring on an
isolated basis rather than as an really extensive
aquitard that is discontinuous only at the Edmunds Street
site.
EPA agrees that the shallow aquitard does not extend to
the most eastern margin of the site, as depicted i'n
Figure 4-2 of the RI report. The aquitard does appear to
be continuous in the central and western segments of the
site. A discontinuity is also depicted south of GE.
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21. Comment:
Response:
22. Comment:
Response
23. Comment:
8
The depth of the clay aquitard in D-l and D-2 does not
correlate to depths in the rest of the area. EPA must
describe the structural features responsible for the
elevation differences.
EPA disagrees. The clay aquitard (as well as the intermediate
and deep strata), are eastward dipping beds. The top of
t!.is unit is most likely an erosional surface. This is a
normal stratigraphic feature and does not require a
structural change to explain it. Comparison of maps for
the aquitard, the Intermediate, and the Deep Zones clearly
show this.
Based on boring logs, the intermediate and deep zones are
separated by a fine-grained unit composed predominantly
of silt and clay in contradiction to EPA's statement that
the intermediate and deep zones are in direct connection.
EPA disagrees. The intermediate and deep zones are not
separated by a continuous aquitard. EPA acknowledges the
presence of interstratified fine-grained sand and silt.
These laminae present local reductions in permeability
but they cannot be correlated across the site. The direct
Hydraulic connection is we!1-supported'by the similarity
of major ion chemistry in groundwater from the intermediate
and deep zones (pg. 5-17, RI report).
The map showing the Shallow Zone water table surface was
constructed using the same Intermediate wells as the
Intermediate Water table map. This is an obvious problem.
Response: This is a graphical error. Data used to construct the
Shallow Zone map were from shallow wells. The data with
the correct base map was mailed to the repositories.
24. Comment:
EPA's calculation of the estimated migration distance for
site contaminants is based on the highest groundwater
velocity for the Intermediate Zone rather than the average
velocity. The EPA estimate is based on an unrealistic
assumption of "no retardation". Retardation would reduce
EPA's calculated migration distance by a factor of 3 to 5.
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Response;
25. Comment:
EPA developed the most conservative scenario, or fastest.
rate for potential contaminant transport (pg. 5-16, RI
report). The calculated velocities are based on groundwater
movement alone and EPA acknowledges these qualifying
parameters on pg. 5-15 to 5-16 of the RI.
Eastern contaminant migration began as a result of off-
site pumping, not solely as as result of well SJ-6 being
taken out of service.
Response: EPA acknowledges this fact on pg. 5-3 of the RI report.
26. Comment:
Response:
27. Comment:
EPA has not presented any factual data to support the
conclusion (pg. 5-3) that shallow zone contaminants may ;
have been "hydraulically contained" at the site.
It is stated in the report that contaminants were either
transported through'the aquifer and/or hydraulically
contained at the site. There are also indications that
eastward and northerly transport is occurring. As a
result, the direction of contaminant flow in the shallow
zone is inconclusive (pg. 5-;9).
i
EPA states that contaminants originating from the study ,1
area may soon reach the closest downgradient supply wells;
(Well M-l and the 3 golf course wells). The term "soon"
should not be used in a scientific report. There is no
evidence to support a southeast flow component toward^
the golf course wells.
Response: The flow rate of 2.3 ft/day was defined and qualified as
being conservative, or fast. This results in a potential
of about 5900 ft. of groundwater migration between 1981
and 1987 (pg. 4-30).
A southeast flow component has been hypothesized due to
heavy pumping of the golf-course wells. The actual
transport rate appears to be about 1100 ft. over a 10 year
period.
28. Comment:
EPA has not assessed the impact of compounds identified
as laboratory contaminants and their effect on selecting
Remedial Alternatives.
Response: Incorrect. All lab contaminants are flagged as such tn the
report. These compounds are not -the contaminants on which
decisions were based.
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10
29. Comment:
The presence of semi-volatile compounds in the SJ-6 area
appears to be inconsistent with EPA's description of the
sources.
Response: EPA disagrees. Semi-volatiles appear to be originating
from a different source. The AT&SF facility is the
most likely origin and is being investigated. Semi-volatiles
are slightly concentrated only beneath Chevron, probably
due to partioning in petroleum.
30. Comment:
Heptachlor epoxide was detected and resulted in an
unacceptable level of risk. This compound is not known
to be associated with any of the six identified source
areas.
Response: Heptachlor epoxide, a pesticide that is persistent in the
environment, was detected only once in surface water of
the AMAFCA channel. This is an isolated occurrence of a
'contaminant that very likely originated from an
upgradient surface runoff source.
31. Comment:
EPA failed to adequately address the interactions
between ,the aquifer zones. EPA should have jintegrated
contamiriant assessments of the Shallow and Intermediate
Zones, and the subsequent eastward extent of this
contamination within the Intermediate,'Zone.'
Response: EPA disagrees. Groundwater flows from the Shallow Zone
to the lower part of alluvial fan .deposit to the east as
well as vertically through the aquitard. The Intermediate
Zone is recharged with inflow from the alluvial fan deposits
and the Shallow Zone. (pg. 4-25 to 4-28)
The eastern-most monitoring wells, aside from those at
the Edmunds site, show substantial decreases in contaminant
concentrations. These decreases indicate the plume margins.
32. Comment:
Concentrations of VOC's in the intermediate aquifer
increase to the east because contaminants originate in
the western source area (i.e. GE, Duke City, Texaco,
Chevron, and Whitfield Trucking). Contaminants orginate
in the Shallow Zone, migrating to the east and downward
into and through the intermediate zone (Shidler, McBroom,
Gates and Lucas comments).
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11
Response: EPA disagrees. This logic also contradicts the previous
comment (p. 10; para 3 of Shidle, McBroom, Gates, and
Lucas commentsjthat there is no vertical gradient within
the intermediate zone.
33. Comment:
Response:
34. Comment:
Response;
35. Comment:
Response;
Concentration maps of individual contaminants should have
been made to examine area! trends. Contours of VOC's
around 1-4 abruptly end east of the Chevron property in
the Intermediate Zone. The conclusion is that a plume of
dissolved contaminants is traveling eastward but the area
of contamination has not been defined.
There are many graphical techniques to display data and
EPA agrees that a water table map can be useful.
However, the text concisely describes and correlates
area! trends.
The VOC's detected in 1-4 ara petroleum products. This
problem was referred to NMEID for investigation in a
separate study. Neither NMEID oe EPA currently know the
extent of this plume.
The report does not correlate the VOC's found in soils
with VOC's found in groundwater. the limits of soil
contamination are not adequately defined on most PRP
properties.
EPA disagrees. It is obvious from-Figures 4-16 through
4-21, maps showing contaminant concentrations in the
unsaturated and saturated soil zones, that soil and
groundwater contamination were correlated to the extent
practical. The only area where soil data is incomplete
is on the Edmunds Street property.
A justification should be provided for the 5 ppb cutoff
to determine whether laboratory contaminants were
present, especially acetone, methylene chloride, toluene,
and 2-butanone. To determine the absence or presence of
laboratory artifacts the necessary dilutions must be
considered.
The 5 ppb cutoff is in accordance with EPA/CLP criteria
for the low detection limits used at the SJ-6 site.
Laboratory QA/QC show that regardless, these compounds
are not the contaminants on which decisions have been
based. Even if lab contaminants were present, 'it would
not cause these elevated readings of chlorinated solvents,
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36. Comment:
Response:
12
EPA did not examine the combined data sets from Phase I
and Phase II investigations and did not analyze the
representativeness of the 1987 data.
Incorrect. EPA did examine both data sets for trends and
for representativeness. Shallow Zone data from 1985 were
considered to be most representative and were therefore
included in the body of the RI report. Data from 1985
and 1987 are included in the appendices.
Elevated VOC concentrations in HL-1 indicated on pg. 5-20
are based on one unconfirmed analysis in 1987. Unless
the 1987 data were confirmed, groundwater in the vicinity
of HL-1 must be considered uncontaminated.
Response: The 1987 data are validated by EPA's QA/QC analysis.
These data show groundwater contamination in samples
collected from HL-1.
37. Comment:
38. Comment
Totaling VOC levels and contouring them as shown on Section
4 figures is inappropriate and cannot be used to interpret
the occurrence of contaminants.
Response: EPA used figures in conjunction with data tables to
convey this information. To contour each contaminant in
this case would be confusing and would not be a concise
presentation format.
39. Comment:
There is insufficient coverage to draw any concentration
contours for semivolatile compounds in the Deep Zone.
Response: EPA disagrees.
appropriate.
The contour lines are dashed where
40. Comment
EPA's approach to Assessment and Source Identification of
SJ-6 contamination is fundamentally flawed. This is
primarily with respect to the influence created by pumping
SJ-6.
Response: EPA disagrees. The flow regimes and contaminant transport
attributed to SJ-6, before and after pumping at SJ-6 was
discontinued have been reasonably documented.
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41. Comment:
Response
42. Comment:
13
The United States Geological Survey modeled the Albuquerque-
BeTen Basin using the Regional Aquifer - System Analysis
(RASA). Results of this model show that at the Regional
Scale and on a refined scale, well SJ-6 did not capture
groundwater from beneath the Edmunds Street site.
EPA disagrees. According to the USGS this system is
intended for use on a Regional Scale only. No conclusions
regarding the capture zone of SJ-6 can be drawn from it.
The refined modeling effort retained the original upper
layer which is the upper 200 ft., the zone of interest.
This scale is too coarse for any local interpretation.
The vertical leakage through boreholes is also not considered
Historical data and water quality data indicate
groundwater flow at Edmunds Street was eastward in early
1970's, based on maps from 1960 and 1978. The statement
that "downgradient migration began after 1981 when well
SJ-6 was taken out of service" is not substantiated by
Fig. 208.
EPA disagrees with this interpretation. This figure is
for a Regional area and was never intended to
substantiate the local conditions generated by pumping
SJ-6. EPA's data show that hydraulic responses were
measured in all areas of the Superfund site.
The presence of petroleum fuel products in Well 1-4
indicates that a source to the west should be suspected
of contaminating SJ-6, rather than a source to the
southeast.
Response: EPA disagrees. The source of petroleum in 1-4 is very
likely the pipeline immediately adjacent to 1-4.
Response;
43. Comment:
44. Comment:
Response;
The SJ-6 aquifer test overestimates the zone of
influence. The pump test data and analysis do not
support the conclusion that the SJ-6 capture zone extends
to all areas of the South Valley site.
Data .presented in Table K-4 (RI) indicate that pumping
SJ-6 hydraulically influences a zone beyond the boundaries
of the SJ-6 Superfund,site. The hydraulic radius of
influence and zone of contaminant capture do not coincide
because of the sloping water table in the Deep Zone.
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14
Simplifying assumptions required for modeling in
conjunction with the complexity of the SJ-6 Superfund
site preclude an absolute definition of the capture zone.
The data strongly indicate that the zone of capture
extends beneath and beyond the 6 PRP properties.
EPA's sequence for degradation of pechloroethylene to
evaluate the occurrence of biological degration is flawed
because it does not consider the data or the underlying
assumptions for this process.
Response: This discussion in the RI report (p. 5-26) is general in
nature. It indicates only that biological degradation
does not appear to be significant at the site.
45. Comment:
46. Comment:
Nowhere in the report has the analytical data used to
determine the perchloroethene (PCE)/Trichloroethene (TCE^
ratio in SJ-6 been identified or presented. The 1984
data in Appendix 0 do not result in the ratio found in
Table 5-5.
Response: Incorrect. The SJ-6 analytical data from 1981-1987 can
be found in Table 4-23. The 1987 sampling results in
the 0.43 PCE/TCE ratio are noted on Table 5-5.
47. Comment:
With the exception of the -1984 data, data for SJ-6 are not
included in Appendix 0.
Response: Correct. These data are included in Appendix K, 1987
SJ-6 Pump Test and Sampling Technical Memorandum.
Analytical data collected by parties other than EPA are
also included in Table 5.5.
48. Comment:
The City of Albuquerque believes that the recommended
alternative for partial migration control to address
groundwater contamination at San Jose 6 and vicinity is
unacceptable. The recommended alternative will have an
adverse health impact on the citizens of Albuquerque.
Response: EPA disagrees. Groundwater monitoring will ensure
protection of the public health.
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15
49. Comment:
Response;
50. Comment:
Response;
51. Comment:
Response:
Restricting evaluation and comments for eight
alternatives which resulted from the seven years of study
to only 60 days is inappropriate.
EPA disagrees. The required 21-day comment period was
extended to allow greater public participation. All
reports produced prior to 1988 was sent to the repositories
as it was finalized. The Remedial Investigation Report
was mailed to the repository in May. These are the critical
data and interpretation documents. The Feasibility Study
was in the repositories by July 7, 1988, allowing 2 weeks
for review prior to the public meeting and 5 weeks after
the meeting.
The City staff have reviewed the rules which regulate
remediation of groundwater contamination under Superfund
and disagree that law dictates the recommended action is
the most appropriate solution.
EPA disagrees. In the vicinity of SJ-6, all Federal and
State numerical criteria are met, excluding contamination
associated with PRP properties. All Federal health
criteria are met. There are 2 slight exceedances of
State health criteria which probably do not represent
statistically significant problems.
Remediation of the sources and emanating contaminant
plumes is being addressed in separate Records of Decision.
There is no added protection of public health to be
gained by pumping and treating groundwater in this area.
Current statements by EPA appear to contradict previous
statements. San Jose Number 6 was initially established
as the number one Superfund site for the State of New
Mexico because of the presence of surplus CERCLA -
eligible contaminants in a deep aquifer and public water
supply. To obtain this status, it was determined that
the presence of these compounds was a significant health
hazard. Now the EPA says that the health hazard posed by
these contaminants is minimal.
This is incorrect. Sites are listed on the National
Priority List (NPL) to determine if a health threat exists
based on preliminary information, The preliminary information
for a site indicates only that a potential health threat
exists and that the situation requires further study.
EPA has studied the site and has determined that in the
general vicinity surrounding SJ-6 (excluding PRPs and
associated contamination) that there is a minimal health
threat.
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16
52. Comment: The City and State contend that during the interval of
time the tPA has been studying this project, the
contamination has spread to further threaten other city
wells. Tests in the last six months have shown the
presence of chlorinated solvents in San Jose Well Number l,
We forese'e contamination and possible loss of additional
public arid private wells due to contamination of SJ-6
and vicinity.
Response: EPA disagrees. Groundwater from San Jose Well Number l
was sampled in August 1988 and data show that contaminants
have decreased to trace levels, less than .5 ppb.
53. Comment: EPAs decision is based on cost.
Response: Incorrect. EPAs decision is based on a technical
evaluation of conditions at the site. Cost is a factor
only when alternatives are equally protective. The less
expensive remedy is typically selected.
54. Comment: The City of Albuquerque requests that New Mexico EID be
made the lead in the Remediation of SJ-6 and vicinity.
This request is made because NMEID is familiar with local
needs and will be more responsive to the citizens.
Response: The lead agency for a site is determined when a site is
placed on the National Priority List. This site was
placed on the NPL in 1983.
55. Comment:
Response;
56. Comment:
EPA should have consulted wi'th City and State officials
before proposing a remedy publicly.
EPA did do this. The New Mexico Environmental Improvement
Division and Albuquerque public works staff.were fully
involved and consulted by EPA in the formulation of
remedies^
EPA has used a health-risk guideline presented in EPAs
Guidance on Feasibility Studies that considers one
additional cancer case per 10,000 exposed individuals as.
acceptable. This guideline was meant to be applied only
when numerical standards for compounds do not exist. The
State and Federal Numerical Standards for site contaminants
should apply. The State does not consider the 1 in
10,000 standard as acceptable.
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17
Response): This statement is incorrect. All State and Federal
1 n-umerical criteria were considered. Contaminants at the
, site, with the exception of PRP contamination, fall below
these numerical criteria.
)
/ As an additional decision-making tool, EPA established a
10"4 to 10"7 acceptable risk range, documented in the
Feasibility Study Guidance. The cumulative effect of
contaminants at the site was calculated using the methods
established in EPA's Public Health Evaluation Manual.
The cumulative effect of contaminants at the site fall
with the 10"4 to 10*7 Risk Range. The cumulative effective
slightly exceeds the State Health criteria of 10"5 in
groundwater from 2 out of 22 wells in the vicinity of SJ-6
in the Intermediate Zone. There are no exceedances,
other than associated with PRPs, in the Shallow and Deep
Zones.
57. Comment:
Response;
58. Comment:
Response;
NMEID considers EPA's claims that health risks posed by
Superfund Compounds at the site are within acceptable
health health limits and that petroleum contamination is
pervasive as false.
EPA disagrees. With the exception of PRP-associated
problems, Superfund contaminants are below numerical
criteria and Federal health-based criteria. In the vicinity
of SJ-6 there are two locations where State health-based
criteria are slightly exceeded.
With respect to petroleum, contamination in the Shallow
Zone is pervasive. Contamination in the Intermediate
Zone is detected only at one well but is highly concentrated
Solvent contamination is evident'in the residential area
north of the site. The smell in the water is horrendous.
If EPA could smell the water, they would understand why
so many people are at the public meeting.
EPA is aware that traces of solvent contamination have
been detected in residential wells. These residents use
municipal water for drinking and household purposes. The
wells in question were sampled; compounds detected are
below Federal health criteria. The State health criteria
is slightly exceeded in one well that is used solely for
irrigation. EPA plans to install monitoring wells in
this direction to ensure protection of the public health.
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18
59. Comment;
Response:
61,
EPA suspects that the strong odor mentioned is due to
diesel or petroleum problems. These are currently being
investigated by NMEID and the City of Albuquerque.
EPA has described the solvent contamination as being low
risk, yet pollutants in San Jose 6 are above drinking
water standards at 812 ft. Monitoring wells do not go
past 310 ft. The extent of contamination is not
adequately defined.
EPA agrees that contaminants in SJ-6 are above drinking
water standards. 1,1-DCE was present at 8 ppb, the
standard is 5 ppb. This is very likely a situation
caused by the condition of the well itself and not a
regional groundwater problem. Over the years,
contaminants have flowed down the borehole, adhering to
about 100 ft. of sediment at the base. These sediments
will be removed to prevent them from continuing to act as
a secondary source. If concentrations remain above
standards after sediment removal and appropriate testing,
the situation will be reevaluated.
EPA has no reason to suspect contamination at depth. The
'deep monitoring wells are contaminant-free, excluding the
one associated with PRP contamination, and the nearby
municipal wells are also clean.
The local citizens and Southwest Research Institute are
circulating a petition demanding cleanup of the
groundwater and involvement of the local people. It will
be sent to EPA by the close of the comment period.
Response: Through EPA and NMEID initiatives, the groundwater is
being remediated.
EPA welcomes and requests involvement by the local
citizens.
The above-mentioned petition was not received by EPA.
Comment: There used to be a dump near this site that could be
causing part of this problem.
Response: EPA is aware of a dump called the Yale Municipal Landfill
that is east of the SJ-6 site. This former dump is being
investigated by the EPA. It is not suspected of
contributing contaminants to the SJ-6 site because water
flows towards it from SJ-6 rather than from the landfill
towards SJ-6.
60. Comment:
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19
62. Comment:
Response:
63. Comment:
Response;
64.
Comment:
The EPA cleanup should Include areas where residential
wells are located. EPA should reimburse residents for
the cost of replacing private wells that have been con-
taminated.
EPA is going to monitor groundwater in close proximity to
the residential wells to the northeast. EPA will only
provide an alternate water supply in cases where wells
are contaminated and an alternate water supply is not
available. In this instance, groundwater contaminants
are below all State and Federal Numerical criteria. They
are below all Federal health criteria and exceed slightly
the State health criteria.
The residents use municipal water for drinking and
household use. EPA does not consider replacing these
wells necessary.
As a representative of the Economic Opportunity Board,
we request that the next meeting be held at the East
San Jose Community Center. It is available at low cost,
is less crowded, and not as inconvenient as a meeting
held at the Radisson Hotel.
I
EPA apologizes for the inconvenience but as the note! is
.25 mi. from the site, it seemed a fairly convenient
location for the meeting. The cost of the room and
audio/visual equipment for the SJ-6 meeting at the
Radisson was $85.00. A comparable charge for a meeting
at the Community Center would have exceeded $250.00.
The next meetings were held at the East San Jose Community
Center.
San Jose Well Number 6 is not in the South Valley area of
Albuquerque; it is in the San Jose area of Alouquerque.
Response: EPA appreciates the clarification and apologizes for the
error. The location of the site was described in the
initial package submitted to EPA as being in the South Valley.
65. Comment:
The groundwater contamination in the vicinity of SJ-6 is
so severe that it's causing children to break out with
hives and get sick. The contamination floats on the
water.
Response: EPA has no data to indicate any contaminant concentrations
except petroleum, that would cause health problems. To
ensure that the public health is protected, EPA will
monitor in close proximity to these residential wells.
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: «
66. Comment:
20
The citizens of the Mountainview area, south of
Albuquerque, have explosives in the groundwater. The
basic remedy has been to bring City water to
Mountainview. Now the citizens will have petroleum and
solvents instead of explosives.
Response: EPA does not anticipate that the City water supply will
be contaminated with any of these compounds.
67. Comment:
If these contaminants were located in a prestigious,
wealthy community of the Northeast Heights or among the
country club luxury residences, can EPA claim that this
identical position would be taken?
Response: Yes
68. Comment
69.
There is no cleanup in the partial migration plan. It is
allowing dilution over three to five generations to do
the work that a pumping system could do in a much shorter
time period.
Response: Superfund contaminants in groundwater that require
remediation are being addressed through other EPA
decisions. In the area that the SJ-6 decision addresses,
Remediation is not required.
Comment: EPA says a lot of people are on city water but that is not
the case. There are a lot of people on Williams Street
that use we!1 water.
Response: EPA surveyed the San Jose area in 1987. Although
domestic wells were noted, EPA was told by the residents
that they use city water. As there is apparent confusion
in this area, EPA will re-evaluate the number and use of
domestic wells before monitoring wells are installed.
70. Comment:
domestic wells before monitoring weiib are iribLdi ieu.
This will allow EPA to install monitoring wells in the
most strategic position.
The site boundaries should be extended to cover the
residential wells to the northeast. There are Superfund
contaminants in these wells.
Response: The site boundaries were initially drawn to delineate an
area of investigation. Contaminants that can reasonably
be associated with the Superfund site will be addressed.
As previously stated, monitoring wells will be placed in
close proximity to these residential wells.
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71. Comment:
Response;
21
The EPA's proposed cleanup of the San Jose site seems to
fit-the pattern that has been established at other sites
around the country. EPA has continued to favor
containment and/or disposal remedies despite the clear
language in SARA. This language calls for cleanups that
are protective of human health by employing permanent
solutions to the maximum extent practicable.
EPA disagrees. Through decisions for other segments of
this site (the Edmunds Street decisions and the USAF/GE
decision), EPA is initiating treatment that reduces the
mobility, toxicity, and volume of contaminants. The SJ-6
decision will prevent contaminants from entering the
drinking water supply through abandoned wells. Rroundwater
monitoring will ensure that the combination of remedies
is effective, protective of public health, and the
environment.
EPAs unrealistic schedule commitments are a major
contributor to the present dilemma between EPA and NMEID.
EPA is making a desperate effort to meet the
Congressional mandate that EPA select remedies at a
specified number of sites by September 30 of this year.
Unfortunately, San Jose is on this list of sites for
which EPA has planned to have a remedy selected by
September 30 of this year. This remedy selection should
be postponed until the USAF/GE remedy is selected.
Response: This site was scheduled 2 years ago, when defining the
necessary investigations and analysis, for a September
1988 decision. This is an internal EPA schedule. EPA is
unaware of the list that is being referenced.
Each of the remedies must comply with Superfund statute,
therefore, which remedy is selected first is inconsequentia"
72. Comment:
73. Comment:
When a location was selected for the replacement well
(Burton No. 4), it was moved to a more distant location
because the first location was thought to be too close to
the contaminants. EPA felt that groundwater contamination
would put a new well at the initial location selection
out of service within 30 years.
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22
Response: Knowledge of the site has been refined. The hydrogeology
and groundwater quality were unknowns at the time a new
well location was being selected. EPA desired a very
safe, very conservative location for the new well.
Since that time, the hydrogeology and groundwater quality
have been defined. EPA would now have more information
on which to base a well location selection.
74. Comment:
What happened to the $700,000 remedy and $70,000/yr
operation and maintenance cost of 3 years ago for SJ-6?
According to the fact sheet, it will now cost between $4
million to $70 million to remediate the site.
Response: The treatment requirements and alternatives evaluated are
very different than the previous study.
It was at the City and State's request three years ago,
that SJ-6 be replaced rather than pumping the groundwater
and treating it. As the costs for each alternative were
comparable, EPA opted to replace the well.
75. Comment:
Response:
76. Comment:
In the fact sheet of July 1988 it is stated that pumping
of San Jose 6 drew and intermingled compounds that have
been handled in the area for the past 40 to 50 years.
Petroleum and industrial chemicals are referenced. The
Remedy Selection criteria then states that EPA cannot
clean up petroleum unless it is mixed with hazardous waste,
This is poor wording in the Fact Sheet. In fact,
petroleum and chlorinated solvents do not appear to be
comingled except in the Shallow Zone beneath Chevron.
The pentachlorophenol is presently below EPA action
levels. The source of this pentachloroph'enol is
not likely to be Chevron. In the most recent sampling
event (dune 1988), no PCP was detected beneath Chevron.
The'Source for this contamination is currently being
investigated.
Unlike the EPA, the Underground Storage Tank Program is
making Chevron and Texaco define the extent of their
contamination. The cleanup will be done to numerical
standards.
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23
Response: EPA has reasonably determined the eastern extent of
contamination. Further refinement is necessary north of
USAF/GE.
The New Mexico Water Quality criteria specify that
groundwater will either achieve numerical criteria or
the 10~5 cumulative health criteria, whichever is more
stringent. EPAs experience shows that the 10"5 criteria
is more stringent. If this criteria is not consistently
applied, it is not an ARAR.
77. Comment:
Response;
EPA discounted risk attributable to PRP contamination
overestimated risk attributed to petroleum.
and
78. Comment:
Response;
79. Comment:
This is incorrect. Risk was evaluated using the highest
concentration of any given compound detected in a
specific zone. This includes data collected from wells
on PRP properties. A conservative or worst-case,
evaluation of risk results from this approach.
EPA should explain in detail the procedure and authority
that they intend to use when imposing deed restrictions.
Citizens want to keep their wells and use water from that
area.
Deed restrictions will be implemented through the State
Engineer's Office. For new well installations, they most
likely will consist of specific well design requirements
to prevent cross-contamination of zones. The shallowest
depth at which wells can be completed will also be
specified to prevent potential exposure.
EPA plans to install monitoring wells in close proximity
to existing domestic wells. Unless contaminants are
detected in the new monitoring wells, the existing wells
will not be affected by access restrictions.
The availability of Technical Assistance grants should be
mentioned.
Response: Correct. The Technical Assistance grants allows a group
to hire an expert to interpret and evaluate EPA studies
for the public. Information on them is available through
Ms. Ellen Greeney at (214) 655-6720.
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