United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
&EPA Superfund
Record of Decision:
South Valley (PL-83), NM
EPA/ROD/R06-88/043
September 1988
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40272- 101
REPORT DOCUMENTATION ' ^««m- ^pA/ROD/R06_88/043 «•
B'^ERF5W*RECORD OF DECISION
outh Valley (PL-83), NM
.irst Remedial Action
7. Authors)
9. Performing Organization Name and Address
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
• Washington, D.C. 20460
3. Recipient's Accession No.
*• RWl5'/88
6.
8. Performing Organization Rept. No
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
S
pKn
1C. Abstract (Limit: 200 words)
The Former Air Force Plant 83/General Electric Operable Unit (PL-83) is a portion of
the South Valley Superfund site in Albuquerque, New Mexico. The South Valley Superfund
site is an area surrounding the City of Albuquerque Municipal Water Well known as San
Jose No. 6. The General Electric (GE) property is located in the western portion of the
site. The South Valley site is situated in an industrial area, but there are residences
immediately north of the GE property. The GE property has been the site of
manufacturing operations since 1948 when the Eidal Manufacturing Company had a welding
operation onsite. In 1951 the Atomic Energy Commission, through American Car Foundry,
took over the property and conducted machining of metal parts, plating, welding, and
other activities. This continued until 1967 when the Air Force took over the property
and converted the plant into an aircraft engine manufacturing plant operated by General'
Electric. The plant was sold to General Electric in 1983, and currently produces
aircraft engine parts. The contaminants which caused the listing of the South Valley
site on tne NPL consisted mainly of industrial solvents. Investigations into the GE
property were conducted in 1984, 1985, 1987, and 1988 by the Air Force under a
Memorandum of Understanding with EPA. The GE property is heavily built up, with the
majority of the site paved or covered with buildings. As a military contracting
(See Attacned Sheet)
South Valley (PL-83), NM
First Remedial Action
Contaminated Media: gw, soil
Key Contaminants: metals, VOCs (PCE!
b. Identifiers/Open-Ended Terms
:. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
71
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77
(Formerly NTIS-35)
Department of Commerce
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A/ROD/R06-88/043
South Valley (PL-83), NM
First Remedial Action
16. ABSTRACT (continued)
facility/ access to the plant is tightly controlled and there is no regular access other
than by employees. Three areas of contamination have been identified at the site: four
hazardous waste storage areas which were used for chemical storage, the north parking
lot (a former dirt parking lot which was sprayed with oil as a dust control measure),
and the DWB-2 area which contains methylene chloride and freon contamination. The
volume of contaminated soils is estimated to be 36,000 yd3. In addition to soil
contamination, ground water contamination occurs at depths of up to 160 feet. The
primary contaminants of concern affecting the ground water and soil are VOCs including
PCE, and metals.
The selected remedial action for this site includes: installation of soil vapor
extraction wells; extraction of soil vapor under vacuum; decontamination of effluent air
through a carbon adsorption system; further sampling and definition of soil
contamination; installation of ground water extraction wells in both the shallow aquifer
and the deeper zone; treatment of extracted ground water with air stripping followed by
carbon adsorption and reinjection of treated water into the aquifers (chemical or
physical treatment of ground water will occur where metal concentrations exceed
background or ARARs); and further definition of ground water contamination through
installation and sampling of additional monitoring wells. The estimated present worth
iost for soil remediation is $1,820,000. No figures are given in the ROD for the ground
ater remedial action.
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
1445 ROSS AVENUE, SUITE 1200
DALLAS, TEXAS 75202
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Former Air Force Plant 83/General Electric Operable Unit, South
Valley Superfund site, Albuquerque, New Mexico
STATEMENT OF PURPOSE
This decision document outlines the selected remedial action for the
Former Air Force Plant 83/General Electric operable unit of the
South Valley Superfund site 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); the National Oil and Hazardous Substance
Pollution Contingency Plan, 40 CFR Part 300, November 20, 1985.
The State of New Mexico (through the New Mexico Environmental
Improvement Division) has been provided with notice and an
opportunity to review and comment on the remedial investigation and
feasibility study, along with EPA's proposed remedial action, and an
opportunity to review and to comment on the Record of Decision
including without limitation, the technology and degree of treatment
therein. The response from the New Mexico Environmental Improvement
Division can be found in Attachment 1 of the accompanying Summary
of Remedial Alternative Selection.
STATEMENT OF BASIS
This decision is based on the administrative record for the Former
Air Force Plant 83/General Electric Operable Unit for the South
Valley Superfund site. The index of the administrative record found
in Attachment 2 of the Summary of Remedial Alternative Selection
identifies the items which comprise the administrative record.
DESCRIPTION OF THE REMEDY
Upon review of the information contained in the administrative
record, it is EPA's judgment that soil vapor extraction of soils
from the surface down to the water table in the areas known as
Hazardous Waste Storage Areas 1, 3 and 4 as indicated in Figures 1.
and 2 of this Declaration appears to meet statutory requirements and
to best satisfy the selection criteria and appropriate guidance in
relation to the other solutions evaluated for soils. Further defini-
tion of the extent of contamination north of Hazardous Waste Storage
Areas 3 and 4 and south of Hazardous Waste Storage Area 1 is required
Groundwater in the shallow groundwater zone, that above the clay
aquitard appearing at approximately 30 feet below ground surface,
and groundwater to a depth of 160 feet below ground level, will be
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recovered through the use of extraction wells and brought to the
surface for treatment. The lateral extent of contamination requiring
recovery is estimated in Figures 3 and 4. There are two areas in
which the lateral extent of contamination must be further defined
through the installation and sampling of additional monitoring wells.
These are the northern extent of contamination in the shallow zone
.as shown in Figure 3 and the eastern extent of contamination in the
aquifer below the shallow zone downgradient of the southeastern
portion of the General Electric property as shown in Figure 4. The
areas of potential contamination in Figures 3 and 4 are not intended
to limit the areas in which additional groundwater sampling may be
necessary. In addition to these two areas, wells in the intermediate
zone beneath the Chevron property will be resampled during remedial
design to confirm the level on contaminants found in sampling during
1987 upon which the eastern extent of groundwater recovery is
dependent. Groundwater recovered will be treated with a combination
of air stripping followed by carbon adsorption. The effluent air
from the air stripping process will also be passed through a carbon
adsorption system for removal of contaminants. The carbon from both
systems will be taken to an offsite facility for regeneration of the
carbon and destruction of the contaminants. ^^
The selected remedy also includes the monitoring of the area ground«Wrf«
both during and after completion of remediation to ensure the
effectiveness of the selected remedy. A more detailed description
of the remedy and an explanation of how it meets statutory
requirements is contained in the "Summary of Remedial Alternative
Selection" which follows this Declaration. The remedial action will
be reviewed every five years after its initiation to assure that
human health and the environment are being protected by the remedial
action being implemented.
DECLARATION
The remedy described above is protective of human health and the
environment, attains applicable or relevant and appropriate Federal
and State requirements and is cost-effective compared to the other
alternatives examined. This remedy satisifies the statutory preferenc
for treatment that reduces toxicity, mobility or volume as a principal
element. Finally, it has been determined that this remedy utilizes
permanent solutions and alternative technologies to the maximum
extent practi cable
I* tt
DaTi Robert E. Laytoi/ Jr . '? .E . ,
Regional Administrator
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TABLE OF CONTENTS
DECLARATION FOR THE RECORD OF DECISION i
LIST OF TABLES viii
LIST OF FIGURES viii
»
LIST OF ATTACHMENTS viii
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION 1
SITE HISTORY 2
ENFORCEMENT ANALYSIS 3
COMMUNITY RELATIONS 3
SCOPE AND ROLE OF THIS OPERABLE UNIT 4
SITE CHARACTERISTICS 4
SITE RISKS 5
DESCRIPTION OF ALTERNATIVES 8
COMPARATIVE ANALYSIS OF ALTERNATIVES 10
SELECTED REMEDY 16
STATUTORY DETERMINATIONS 17
RESPONSIVENESS SUMMARY 17
VI 1
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LIST OF TABLES
Table One - Analysis of Criteria for Selection of 14
Remedy for Soils
Table Two - Estimated Costs 15
LIST OF FIGURES - DECLARATION
Figure One - Soil Vapor Extraction Area (South) iii
Figure Two - Soil Vapor Extraction Area (North) iv
Figure Three - Shallow Zone Groundwater v
Figure Four - Intermediate Zone Ground water vi
LIST OF FIGURES - SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
Figure Five - South Valley Site Map 1
Figure Six - Areas Investigated On General Electric Property 2
Figure Seven - Site Stratigraphy 6
LIST OF ATTACHMENTS
Attachment 1 - State of New Mexico Response
Attachment 2 - Administrative Record Index
Attachment 3 - Responsiveness Summary
Attachment 4 - ARARs
Attachment 5 - Summary of Analytical Results
Attachment 6 - Groundwater Standards
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RECORD OF DECISION
FORMER AIR FORCE PLANT 83/GENERAL ELECTRIC
SOUTH VALLEY SUPERFUND SITE
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION SIX
SEPTEMBER 1988
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
South Valley, Albuquerque, New Mexico
Former Air Force Plant 83/General Electric Operable Unit
Site Location and De s c r i p t i o n
The General Electric property (GE) is a portion of the South Valley
Superfund site in Albuquerque, New Mexico. The South Valley
Superfund site is an area surrounding the City of Albuquerque
Municipal Water Well known as San Jose 6, near the intersection of
Broadway and Woodward Road in southern Albuquerque. The GE
property is located at 336 Woodward Road, S.E. Figure 5 below
shows the larger South Valley site with the GE property in the
western portion of the site. Figure 6 on the next page shows the
GE property in nore detail.
Figure Five
PRPProfWttM
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The South Valley site is located in an industrial area, but there
are residences immediately north of GE. Figure 6 shows the various
potential sources of contamination within the GE property. The
investigation also included the investigation of contamination in
the groundwater under the property.
Site History
GE was investigated as a potential source of the contamination
which appeared in the municipal well SJ-6. The property has bee"n
the site of manufacturing operations since 1948 when the Eidal Manufac-
turing Company had a welding operation onsite. In 1951 the Atomic
Energy Commission, through American Car Foundry, took over the .property
and conducted machining of metal parts, plating, welding and other
activities. This continued until 1967 when the Air Force took over
the property and converted the plant into an aircraft engine manufac-
which was operated by General Electric. The plant,
Force Plant 83 was sold to General Electric in 1983 and
turing plant
known as Air
still produces aircraft engine parts.
The contaminants which caused the listing of the South Valley site
on the NPL consisted mainly of industrial solvents. The investigation
into the site focused on six industrial properties near the contaminated
municipal well, of which GE was one. A first round of investigation
was conducted into the GE property in 1984 and 1985. The results of
this investigation prompted a second round of investigation which
was conducted in 1987 and 1988. All of the investigations into the
GE property have been conducted by the Air Force under a Memorandum
of Understanding with EPA.
Figure 6
FORMER USAf PLANT NO. 83
GENERAL ELECTRIC ALBUQUERQUE PLANT
(SAM
•rroiioft MAM
LOT
LMIMO
I HAZARDOUS WAtTI AMAt
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Enforcement Analysis
There is a list of several potentially responsible parties (PRPs)
for the property on which this operable unit is located. These
include past and present owners and operators of tre property.
Primarily these are the Eidal Manufacturing Company, the United
States Department of Energy, American Car Foundry, Dew Chemical,
the United States Air Force and General Electric. All of the.
Superfund work on the General Electric property to da:e has been
conducted by the Air Force.
Community Relations
Due to the possibility of contamination within the Sen Jose
Wellfield, which serves as a major source of water for the City of
Albuquerque, the site has received extensive media attention.
However, because of the heavily industrialized nature f 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 spe:ifical1y
with the problems posed by the South Valley site, several groups
have expressed a general interest regarding overall environmental
concerns in the Albuquerque area.
On August 23,' 1988, EPA issued.a press release and the P-oposed Plan
fact sheet. The press release was mailed to all news organizations
in the Albuquerque area, while the fact sheet was mailed to approx-
imately 150 local 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 Augus: 23, 1988.
The comment period was originally to end September 16, 19-c,8, but the
U.S. Air Force failed to deliver the feasibility study t:> the public
repositories until September 1, 1988. The public comment :eriod was
extended until September 23, 1988 and notices of the charg? in the
comment period were mailed to area residents and local o*"f cials.
A workshop was held September 1, 1988, for area residents -n a local
community center to explain the results of the remedial investigation
and feasibility study and to discuss the proposed plan. Approximately
60 people attended this meeting. The official public meeting to
receive public comment was held on September 13, 1988. Approximately
45 people attended this meeting. The Responsiveness Summary which
outlines the comments received and EPA's responses is included in
Attachment 3.
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Scope and Role of This Operable Unit
This operable unit is one of four currently underway for the South
Valley Superfund Site. These four operable units are Edmunds Street
Groundwater, Edmunds Street Source Control, Former Air Force Plant
83/GE, and the overall SO-6 operable unit. The division of the site
into these parts follows from the nature of the site. The South
Valley site is a large area surrounding the municipal well San Jose
#6. Within this larger area are a number of industrial properties
owned and operated by different groups and individuals. Each of the
two source control operable units deals with a single industrial
property that, through the investigation process, has been shown to
have CERCLA actionable contamination that needs to be corrected.
The SJ-6 operable unit is intended to deal with the site as a whole,
leading to a decision about the larger groundwater problem that
caused this area to become a Superfund site, while the source control
operable units eliminate the sources of groundwater contamination,
including plumes of contamination that can be traced directly to a
particular property. The Former Air Force Plant 83/GE operable unit
is one of these source control operable units.
Site Characteristics
The GE property is heavily built up. Most of the site is paved and
those areas which do not contain buildings frequently have
underlying or overhead utility conduits. As a military contracting
facility, access to the plant is tightly controlled and there is no
regular access other than by employees.
The areas investigated as potential contaminant sources are shown in
Figure 2. These areas are: former hazardous waste storage areas
one through four (HWSA #1, etc.), the north parking lot, and the
DWB-2 area. The former hazardous waste storage areas were once used
for chemical storage. The north parking lot was once a dirt parking
lot. Before the area was paved, it was sprayed with oil as a dust
control measure. The DWB-2 area was added to the list of potential
source areas when methylene chloride'and freon were found during the
installation of a groundwater monitoring well in this location.
The remedial investigation uncovered scattered evidence of volatile
organic chemical contamination in soils in all of the investigated
areas. However, the primary locations of volatile organic chemicals
were in the southern end of the plant near HWSA #1 and in the north-
west corner of the plant near HWSAs #3 and #4. A thin layer of
semivolatile contamination was found in what appears to be fill
material in HWSA #1. Petroleum was found in soils in the north
parking lot and in HWSA #3. A summary on analytical results from
site samples can be found in Attachment 5.
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In addition to- contaminant sources, groundwater beneath the plant
Figure 7. Of primary interest is the silty clay aquitard at 25 to
40 feet below the surface. This clay aquitard appears to divide
groundwater above 30 feet in depth from the deeper water bearing
zones. This dividing layer is absent in the southeast corner of the
site.
The shallow groundwater zone (surface to 30 feet) is composed of
fluvial sand and gravel. It is unsaturated for about half of its
thickness and has a variable gradient. Groundwater flow above 30
feet is generally south across the site towards the southeastern
corner of the property. The deeper zones can be divided into an
intermediate zone (40 to 110 feet) and a deep zone (110 to several
thousand feet). The intermediate zone consists of coarse-grained
elastics that were deposited by channel action. The deep zone con-
sists of primarily finegrained sand but is laterally and vertically
heterogeneous. The intermediate and deep zones, although hydrauli-
cally connected, were defined separately to emphasize the differences
in lithology, primarily grain size and hydraul-ic characteristics.
A't depths below 30 feet, groundwater flow is generally west to east.
In the shallow groundwater zone, contamination by volatile organic
solvents, isophorone, and metals was found. The indications of
metals contamination comes from sampling conducted in 1985 and 1987.
The resulting metals analyses were not consistent among sampling
rounds. The actual presence or absence of metals contamination will
have to be confirmed by further sampling during remedial design.
The levels of organic contaminants are particularly significant in
the far southern and far northwestern ends of the property. Below
the shallow zone, contamination is concentrated above the 146 foot
zone. Only one well near the southeastern end of the property, DMW-2
showed contamination in the 140 to 160 depth range. The eastern
extent of contamination varies along the property boundary. Figures
3 and 4 illustrate these areas of contamination. The eastern boundar
of contamination in the intermediate zone will be confirmed through
sampling of new and existing wells during remedial design. Analytica
results are summarized in Attachment 5.
Site Risks
Current site risks from soils are limited by the nature of current
operations. The property is for the most part paved or covered by
buildings. Direct access to soils is limited. In addition, the
population which could currently be exposed is limited to workers
who are not normally outdoors. There is no public access to the
plant as this is a defense installation and security at the facility
is tight. Current risks from inhalation either from soil gases or
dust are also limited for the reasons given above.
Groundwater is the City of Albuquerque's primary drinking water
source. Most of the area residents are connected to the municipal
drinking water system. As far as is currently known there are only
three wells near the South Valley site which draw water from the 50
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to 100 foot zone. None of these are currently used as a drinking
water supply. One 1s used by a construction business, one is used
for irrigation purposes and the third was used for drinking water,
but the owner is. now connected to the municipal water system. The
municipal water system draws from the lower portion of the deep
groundwater zone.
When potential risks at the site were evaluated it was conservatively
assumed that the plant property would be developed into a residential
area. It was also assumed that water from both the above 30 foot
zone and from the 30 to 160 foot zone would be used for domestic
purposes.
Risk from site soils seems very limited. The shallow soils up to
depths of two feet did not pose a significant risk either through
ingestion of volatile or semi-volati1e organic contaminated soils.
Analysis of possible inhalation of contaminants based on soil gases
both from shallow or greater depth soils did not show significant
potential for risk.
Estimates of risk posed by the contamination in groundwater did show
areas requiring remediation to depths of up to 160 feet. Use of
Federal and State standards gives a projection of contaminated
groundwater requiring remediation as shown in Figure 3 for the shallow
groundwater and Figure 4 for the groundwater up to the 160 foot
depth. Prominent among the standards requiring this remediation is
the New Mexico Water Quality Control Commission (NMWQCC) regulation
3-103.A and the associated definition of the term "toxic pollutant"
found in NMWQCC regulation Section 1-101.UU. The regulation in
question states that if more than one water contaminant affecting
human health is present, the toxic pollutant criteria of Section
1-101.UU for the combination of contaminants shall apply. This
involves the use of combined risk from contaminants which are on the
toxic pollutant list included in Section 1-101.UU and that the com-
bined risk shall not exceed a level of excess lifetime risk of more
than one cancer per 100,000 exposed persons. The primary contaminants
of concern for carcinogenic effects include 1,1 dichloroethene,
isophorone, and tetrachloroethene. A sample of the calculation
necessary to determine combined risk and the individual standards
for chemical of concern at the South Valley Superfund Site can be
found in Attachment 6.
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Description of Alternatives
The following are alternatives that were examined for use in
remediation of the contaminated areas. These are separated into
methods for soils and for water.
SOILS
As the soils appear to pose no direct risk through exposure, the
focus of remedial actions was elimination of volatile organic
contaminants contributing to groundwater contamination.
1) No Action - No action would be taken to remediate the
contaminated soils. This options is included as a baseline for
comparison with the active cleanup alternatives.
2) Soil Vapor Extraction - Vapor extraction consists of injection of
fresh air into the subsurface and recovery of the -air through air-
recovery wells operated under a vacuum. Volatile contaminants
contained in the material through which the air passed will
move into the vapor phase. The air containing the contaminants i
then drawn out through the air-recovery wells. The air is then run
through activated carbon for removal of the contaminants from the
air. The clean air is released and the activated carbon is regen-
erated offsite.
3) Incineration - The contaminated soils would be excavated and
incinerated in a RCRA approved offsite or mobile onsite incinerator.
Organic contaminants would be destroyed during combustion within the
incinerator.
4) Soil Flushing - The purpose of soil flushing is to intermittently
or conti nuously f 1ush the soil with water until water percolating
through the flushing area is at or below a proposed cleanup level.
The water is applied through sprinklers or distribution pipes. The
applied water is allowed to percolate through the soil and collected
with extraction wells. The collected water is then treated.
Insoluble compounds are removed through the use of surfactants or
additives in the flushing water. Which additives are used depends
on the contaminants whose removal is desired.
5) Soil Aeration - Soil aeration works through providing sufficient
contact between contaminated soils and air to allow volatile
compounds to vaporize. Soils would be excavated and fed into a soil
dryer. Volatile compounds would be volatilized from the soil in J^^
dryer. The air from the dryer would then be treated in a three s^f
process for the removal of particulates and organic vapors. Treated
soils would be returned to the excavation sites.
6) Stabilization - Chemical fixation/stabi1ization mixes waste witn
a binder material to immobilize the contaminants. Fixation involves
a chemical reaction between one or more of the waste components with
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a solid matrix, either one existing in the waste or one added as
part of the fixation process. Stabilization involves physically
trapping the contaminants without a chemical reaction. It does not
reduce the toxicity of the material but reduces the mobility of the
contami nants.
7) RCRA Co.ver - The purpose of this method is to limit the
infiltration of stormwater through sue soils by constructing an
impermeable cover over the site. This cover would consist of a low
permeability clay or geotextile and a drainage net over a synthetic
liner. This would in turn be topped with fill material and topsoil.
The topsoil would be seeded to promote vegetation to control erosion.
8) Off-site disposal - Under this alternative all soils determined
to contain chemicals of concern, would be excavated, transferred
into trucks, and then transported to and disposed of-in a RCRA
approved 1andfi11 .
GROUNDWATER
Groundwater remediation is focused on elimination of organic
contaminants that pose a carcinogenic risk like 1,1 dichloroethene.
1) Groundwater Extraction - This involves bringing groundwater to
the surface through extracti on water we!'s for treatment.
*
a) Groundwater Treatment/Air Stripping - This groundwater treatment
method operates by mixing water contamirated with volatile compounds
with air allowing the volatile chemicals to evaporate into the air.
The air is collected as it leaves the treatment unit and passed
through a filter where the contaminants are collected.
b) Groundwater Treatment/Carbon Adsorption - This net hod passes
contaminated water through activated cartnn where the contaminants
are adsorbed onto the carbon. The contan nated carbon is then taken
to an offsite regeneration facility.
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10
Comparative Analysis of Alternatives
Each alternative was evaluated on the following criteria:
1. Short-term effectiveness: Pr.cection of human health and the
environment during construction and implementation.
2. Long-term effectiveness and permanence: Ability of a remedy to
amintain reliable protection of human health and the environment
over time, after construction and implementation are complete.
3. Reduction of toxicity, mobility, or volume: Anticipated
performance of the specified treatment technologies.
4. Impl ementabi 1 i ty : Technical and administrative feasibility of
alternatives and the availability of required resources.
5. Cost: Cost of construction and operation and maintenance.
6. Compliance with ARARs: Compliance with applicable or re
and appropriate standards (ARARs) from existing laws and
regulations. These are standards or regulations that either do
apply or at least should be considered when looking at an
al ternati ve .
7. Overall protection of human health and environment: How the
alternative as a whole protects and maintains protection of human
health and the environment.
8. State Acceptance: The State's preferences or concerns about the
al ternati ves .
9. Community acceptance: The community's preferences or concerns
about the alternatives.
The following paragraphs will examine each of the alternatives for
these criteria. For comparative purposes, satisfaction of the
criteria will be rated as low, moderate or high. These "ratings"
are summarized in Table 1.
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11
First the methods for remediating the volatile organic contaminants
in soils will be examined. Then groundwater remedial methods will
be discussed.
Short-term effectiveness - The idea of short-term effectiveness
involves the protection of human health and the environment during
the cleanup. The no action alternative meets this criteria since it
doesn't involve any remediation which might result in disturbance of
soils. The vapor extraction method meets this criteria since it
does not disturb the contaminated soils to any great extent. The
volatile chemicals in the soil have no chance to escape and expose
the workers or the public. Soil flushing meets this criteria for
similar reasons; the contaminated material is not disturbed so there
is little opportunity for the contaminants to escape. Four of the
alternatives, incineration, soil aeration, offsite disposal and
stabilization fail this criteria a.s they require that the soils be
excavated or at least disturbed during the treatment process. While
the soil is being excavated or mixed, the volatile chemicals in the
soil will have the opportunity to escape exposing both the workers
and the public. The RCRA cover alternative would involve some minor
soils work during its installation and would provide limited opportu-
nity for escape of the volatile chemicals in the soil.
Long-term Effectiveness and Permanence - When the alternatives are
exami ned for how effective and permanent they will be after the
remediation is complete, no action fails as it does nothing to
improve site conditions. Stabilization will be vulnerable to break
down of the stabilized materials over time and the contaminants will
be only contained, not destroyed. Similar problems exist with the
RCRA cap and the Offsite Disposal options. The contaminants would
still be present and should the integrity of the landfill or cap be
breached in some manner, the material would be subject to the effects
of the environment. The remaining alternatives provide better long-
term effectiveness. Vapor extraction, soil aeration and soil
flushing remove contaminants from the soils for further treatment.
Incineration would involve destruction of the organic contaminants
in the incineration process.
Reduction of toxicity, mobility, or volume - No action does nothing
to permanently reduce the toxicity, mobility or volu">e of the
contaminated material. Off-site landfill disposal and the RCRA cap
will reduce mobility through increased isolation of the contaminants
from the environment, but will not actually reduce their inherent
capacity for migration. Stabilization would also reduce mobility thr
protection from water infiltration, but would not reduce the contam-
inants' toxicity and would increase the volume of material. Incinera
would provide for reduction of all three of the desired criteria
through destruction of the organic contaminants. Vapor extraction,
soil flushing and soil aeration would also reduce toxicity, mobility
and volume provided the carbon used in the second stage of treatment
is regenerated.
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12
Imp!ementabi1ity - No action is easily implementable as it does not
involve doing anything. The other technologies have been used at
other sites and involve methods that could be applied at GE. There
are some physic?! limitations. The site contains a heavy
concentration of buildings and buried utilities. These would
significantly impede the excavation of soils required for the soil
aeration, offsite disposal and incineration methods. They would
also obstruct the distribution of water for the soil flushing
option. Vacuum extraction could reach into areas containing
utilities and under buildings to the extent of the effective radius
of the air-extraction wells. The RCRA cap option would not extend
under the existing buildings. While soil flushing is a possible
method of remediation, an effective chemical flushing agent has not
been demonstrated for this site.
Compliance with ARARs - ARAR Compliance is dependent upon which
alternative is being discussed as the ARARs vary with the type of
remediation. Generally, ARARs relating to soil cleanup standards
are not applicable as the threat from soil is primary as a source of
contamination found in drinking water, not a direct threat from t
soils themselves. One primary ARAR is the so called "land ban"
restricting the land disposal of hazardous wastes without prior
treatment to specified levels. The soil aeration, stabilization,
and offsite disposal options would have to meet the standards for
the solvents and metals contained in the soils removed and treated.
The land ban regulations would not apply to the in situ options.
The ARARs for the groundwater treatment options would primarily be
those involving levels of contamination which require treatment and
those involving release of the water after treatment. As both of
the treatment options call for reinjection of the treated water
these would primarily.be the maximum contaminant limits (MCLs) from
the Safe Drinking Water Act and the NMWQCC regulations for discharge
to the ground. A more complete list of ARARs can be found in
Attachment 4.
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no
13
Overall Protection of Human Health and the Environment - The nu
ac'tion alternative does not address present or potential public health
or environmental concerns. The object is to prevent exposure to the
site contaminants. This can best be accomplished through permanent
destruction of the contaminants. The offsite disposal, stabilization
and RCRA cover options do not do this. The incineration and soil
aeration alternatives do offer permanent destruction, but present
the possibility of escape of volatile contaminants during implementa-
tion. Soil flushing and vapor extraction provide for removal of
the volatile contaminants from the soil and the subsequent permanent
destruction of the volatile contaminants without the exposure to the
public caused by the remedies requiring excavation.
State Acceptance - State preferences are expressed in Table One. In
general the State prefers remedies which result in permanent
solutions. Four of the alternatives (no action, landfilling, RCRA
cover, and stabilization) do not satisfy this preference.
Incineration would only satisfy it for organic contaminants and does
not appear to be cost effective. Soil flushing would result in
transferring contamination to groundwater prior to collection
contrary to the State's policy of groundwater protection. Soil
vapor extraction and aeration in the view of the State appear to be
both cost effective and permanent solutions.
Community Acceptance - There has been little comment from, the
community on the soil remediation methods or about the selected method
of groundwater treatment. Most of the public concerns have centered
on the extent of groundwater remediation both in terms of depth and
in the distance east of the property boundary at which groundwater
would be recovered. The Responsiveness Summary found in Attachment
1 gives a more complete summary of public comment.
Cost - Table 2 shows comparative costs for each of the alternatives.
In addition to the discussion above a similar examination is necessary
for groundwater remediation methods. All of the cleanup methods
considered in the final analysis involved the use of groundwater
extraction wells with treatment of contaminated water at the surface.
This limits discussion of the alternatives to the effectiveness of
the two treatment methods, air stripping and carbon adsorption.
Both of these methods can be effective for treating volatile organic
contaminants. However, not all of the contaminants are sufficiently
volatile to be treated with air stripping alone. If air stripping
is selected as the method for remediation a backup carbon adsorption
step will be necessary. Carbon adsorption alone should be capable
of removal of the contaminants, but as the lone method of remediation
it would have to be monitored carefully and the chance for break-
through of contaminants would.be increased.
-------
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15
TABLE TWO
COMPARATIVE COSTS
FOR SOIL REMEDIATION ALTERNATIVES
OFFSITE DISPOSAL $ 16,697,000
STABILIZATION $ 5,309,320
RCRA COVER $ 8,022,100
VACUUM EXTRACTION $ 1,820,000
SOIL FLUSHING $ 44,734,000
INCINERATION $ 29,476,000
SOIL AERATION $ 19,846,000
NOTE: Based on 36,000 cubic ,yards of material treated using costs from
Appendix A, Volume VI, of the Remedial Investigation/Feasibility
Study, Former Air Force Plant 83, August 1988.
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16
Selected Remedy
The selected remedy for the site has two main portions, soil
remediation and groundwater remediation. The method selected for
soil remediation is soil vapor extraction for soils down to the water
table. Effluent air from vapor extraction will have contaminants remo\
by a carbon adsorption system. The areas requiring soil remediation
are shown in Figure 1 and 2. Two areas will need further definition
of contamination prior to final selection of areas requiring remediatii
These are on the northern property boundary where contamination
extends off of the property north of Hazardous Waste Storage Area #4
and on the southern boundary of the property where contamination may
extend south off of the property near Hazardous Waste Storage Area
#1. For groundwater remediation the selected remedy is extraction
of contaminated groundwater- and treatment with air stripping followed
by carbon adsorption. Carbon from both the water and air treatment
systems will be regenerated offsite. Once treatment is completed,
the treated water will be reinjected into the aquifer. For groundwate
containing metals above background levels and exceeding applicable
or relevant and appropriate regulations, appropriate physical and
chemical treatment methods must be applied prior to reinjection o
the treated water to reduce the level of metals to the levels requr
by State and Federal regulations.
The precise location of extraction wells will be determined during
remedial design, but separate extraction systems will be required
for shallow groundwater and for the deeper zone. The extraction-
systems must recover the contaminated groundwater in the shallow
aquifer at both the northern and southern ends of the property, and
must in the intermediate zone be sufficient to capture the
contaminated groundwater indicated in Figure 4 to a depth of at least
160 feet. Should sampling of the intermediate wells beneath the
Chevron property during remedial design show contaminant levels
requiring active remediation the area of such remediation may be
extended further to the east. Two areas will require further d e f i n i t i
of groundwater contamination during remedial design through installati
and sampling of additional monitoring wells. These are the extent
of shallow zone contamination north of the property and, should the
clay aquitard be discovered to be absent during this investigation,
the extent of contamination in the deeper zones as well, and the
eastward depth and extent of contamination downgrade en.t of monitoring
well DMW 2 below the shallow zone. Coordination of the groundwater
recovery system selected within this document with other remedial
activities will be an important function of the system design and
the party implementing the selected remedy is required to provide^
representative in discussions to promote such coordination.
Soils treatment will continue until the vapor extraction system
ceases to produce volatile contaminants and will be followed by
sampling to confirm soil remediation. Water extraction will
continue until the levels of contaminants in the water fall be>ow
State and Federal regulatory standards.
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17
Statutory Determinations
The selected remedy, is protective of human health and the
environment through the elimination of present and future risks
posed by the site. The elimination of the volatile organic
contaminants present in the site soils in the areas of Hazardous
Waste Storage Areas 1, 3 and 4 and the recovery and treatment of
contaminated groundwater under and near the site will result in the
elimination of the current threat from the site. Future risks from
the site will also be reduced through the same methods described
above.
The selected remedy for soils invokes few ARARS as it will be done
in situ and will create no unacceptable short-term risks during its
construction and impoementation. Because of this the soil remedy
does not have any requirements under regulations governing the handling
or disposal of solid or hazardous wastes which it has to meet. The
level of treatment in the selected remedy for groundwater does meet
the standards for water set by maximum contaminant limits under the
Safe Drinking Water Act and for discharge to the ground under NMWQCC
regulations. As the treated water will be reinjected there are no
requirements for discharge to be met other than those already mentioned
The selected remedy is cost-effective when its components are compared
to the other alternatives evaluated.
The selected remedy was picked from among the alternatives evaluated
by the nine criteria as discussed in the section entitled Comparative
Analysis of Alternatives. The selected remedy provides for the
removal of organic contaminants which are serving as a source for
the contamination found in the groundwater. The method selected is
effective in both the short and long-term as it minimizes potential
exposure to volatile contaminants during remediation while providing
for permanent destruction of the contaminants so removed. The tech-
nologies selected for the removal of contaminants from site soils
and from the groundwater treated as part of the selected remedy
provide for the permanent destruction of the organic contaminants
removed through regeneration of the carbon used for collection,
thereby reducing their mobility, toxicity and volume and meeting the
preference for treatment as a principle element of the selected
remedy.
Responsiveness Summary
The responsiveness summary for this site can be found in Attachment
3.
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ATTACHMENT ONE
STATE OF NEW MEXICO RESPONSE
TO RECORD OF DECISION
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.LI.
HEALTH ** ENVIRONMENT
« ~ma
Pott OffiCt BOX BOB
S.rt. P.. Nv* Miweo 87504-0838
WWWNMWTALWPMVIMWTBVWON
3ev«mei
C4rlt
Ilchmrd
Director
30 / X988
, Director (6H)
Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region VZ
1445 Roe. Avenue
Dallas, Texa. 75202-2733
Dear Mr. Daviet
concur, with the remedy
*-«-- *••» >TTO»» n^
part of the
etrategy to
coordinated to achieve .it. cleanup,
Sincerely,
Richard Mittelfelt
Dirtctor
wncU«
other re»edie. are
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ATTACHMENT TUO
ADMINISTRATIVE RECORD INDEX
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ATTACHMENT THREE
RESPONSIVENESS SUMMARY
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FORMER.AIR FORCE PLANT 83/GENERAL ELECTRIC
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 Former Air Force Plant 83/General Electric
South Valley hazardous waste site. The summary is divided into two-
sections :
Section I: Background of Community Involvemen.t and Concerns. This
section provides a brief history of community interest and concerns
raised during the remedial planning activities at South Valley.
Section II: Summary of Major Comments Received. The comments (both
oral and wri tten) are summarized and EPA's responses are provided.
I. Background of Community Involvement
Due to the possibility of contamination of the San Jose
Wellfield, the South Valley site has received extensive media
attention. However, because of the heavily industrialized
nature of the site area and the lack of exposure, citizen
concern was, until recently, very limited.
During 1988, specific interest in the site increased and
numerous news articles as.well as editorials appeared in the
daily press. Citizen awareness and concern for the site
conditions peaked during the public meeting on the San Jose Well
#6 operable uni t.
Although no citizen groups have been formed to deal specifically
with the problems posed by the South Valley site, several groups
have expressed a keen interest in the overall environment in the
Albuquerque area.
11. Summary of Major Comments Received
The press release and Proposed Plan fact sheet announcing the
public comment period and public meeting were distributed on
August 23, 1988. The public comment period was extended fron
the originally" announced closing date of September 16 to
September 23, 1988 when the Air Force failed to submit the
feasibility study to the repositories on time. A public work
shop was held September 1, 1988 to discuss the results of the
remedial investigation and the proposed plan for cleanup and was
followed by a formal public meeting on September 13, 1988.
Approximately 45 people from the area attended the formal
meeting, and 13 individuals made oral statements or asked
questions. Written comments were also submitted by two of tne
attendees .
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No comments were received relating to soil remediation or method
of groundwater treatment. Most of the comments received instead
concentrated on the area! extent of groundwater remediation.
During the public comment period, there were comments/questions
regarding the following:
Comment 1: Additional monitoring is needed to determine the
extent of groundwater contamination to the north of General
Electri c.
Response: The proposed plan calls for additional monitoring
north of the General Electric property to determine the northern
extent of contamination in the shallow groundwater zone.
Comment 2: Additional monitoring is needed to determine the
extent of groundwater contamination northeast of the entire
South Valley site.
Response: This comment lies outside the scope of this operable
unit and is instead a part of the SJ-6 operable unit. A response
to this comment is made in the Responsiveness Summary for that
operable unit. Groundwater monitoring is planned for the area
northeast of the site as part of the selected alternative for
the SJ-6 operable unit.
Comment 3: Remedy selection at the General Electric property is
premature as there is insufficient information on extent of
groundwater contamination.
Response: 31 monitoring wells have been installed on the General
Electric property and multiple rounds of sampling have been done.
In addition, information from investigations conducted by other
parties on other nearby properties as well as from the investiga-
tion conducted by EPA on adjacent property is available. While
the desire for additional information remains, as is indicated
by the additional groundwater monitoring required by the selected
remedy, sufficient information is available to select a remedy.
Comment 4: The comment period for the proposed plan should be
extended as the time for review and comment was not long enough.
A press release on the proposed plan and the proposed plan itself
were released on August 23, 1988, a month before the close of
the public comment period on September 23, 1988. The Remedial
Investigation report had been placed in the three public reposi-
tories the preceeding week. As stated in Section II of the
introduction to this responsiveness summary, the Air Force
in submitting the feasibility study and it did n-ot become
available in the repositories until September 1, 1988. This was
still three weeks prior to the close of public comment. A
public workshop was held on September 1, 1988, to explain the
proposed plan and a public meeting was held on September 13,
1988 to receive public comment. EPA believes that adequate
time anH nnnortunitv was allowed for public comment.
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Comment 5: - Additional details are needed on the proposed plan.
A letter containing additional details of the proposed plan was
sent to all who requested them on September 19, 1988. It should
be noted that many of the requests for details on the proposed
plan are not available at this time. The proposed plan is only
a conceptual remedy. The more specific details of the remedy
will developed during the remedial design which follows remedy
selection.
Comment 6: If there is no danger posed by site soils, why are
you [EPA] spending money to clean them up?
While the soils themselves do not appear to pose a direct threat
to human health through contact, ingestion or inhalation from
contamination with organic chemicals, they may be serving as a
source of contamination to the groundwater. It is to eliminate
this source of contamination that soil remediation is required
in the selected remedy.
Comment 7: Have laboratory studies [animal studies] been run
using material from the site?
Response: No. The information on risk from the chemicals found
on the site comes from research done outside this investigation.
Comment 8: The money spent on public meetings should instead be
spent for local educational efforts. *" c
Response: EPA is required by the law under which the Superfund
program operates to hold a public meeting at or near the location
of the site regarding a proposed plan if there is sufficient
interest in the site to warrant'such a meeting. The law does
provide for technical assistance grants to aid a citizens group
who may be effected by a Superfund site.
Comment 9: Information provided to the public should be bi-
1i ngual .
Response: This was the first such request received for this
site. Arrangements will be made for Spanish translation of
future materi als.
Comment 10: Is EPA going to clean up the site or force the Air
Force to?
Response: All of the potentially responsible parties for the
site will receive notice letters asking for performance of the
selected remedy once remedy selection has been made. Following
receipt the Superfund law mandates a 120 day moratorium on any
Superfund activities at the site. If agreement with potentially
responsible parties can be reached during this moratorium, a
legally binding agreement will be signed by EPA and the Respondent
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for implementation of the selected remedy. Should no agreement
be reached during the special notice moratorium, EPA has the
options of pursuit of implementation of the selected remedy
through litigation under the Superfund law or use of funds from
the trust fund established by the Superfund law followed by
recovery of costs through litigation. The decision on which
optio to pursue will be dependent on conditions following the
moratorium period.
Comment 11: EPA should use community groups to distribute
information or develop a local advisory committee to disperse
i nformation .
Response: EPA is open to any suggestions on how information might
be more effectively distributed. Information relating to this
site is available locally at the Main Branch of the Albuquerque
Public Library, the City/County Building, and the library at the
University of New Mexico.
Comment 12: The feasibility study did not arrive on time (prior
to the September 1, 1988 meeting). Reports are needed earlier.
Response: The Air Force did not submit the feasibility study
report on time. This is why the September 1, 1988 meeting was
not the official public meeting for the site. While EPA felt an
obligation to be present at the previously announced date,
September 1, 1988, we did not believe it fair to hold the official
public meeting with so little time available for review of the
feasibility study. This is why EPA came to Albuquerque a second
time, September 13, 1988, to hold the official public meeting.
Comment 13: Was the sampling data from the Lente and Jaramillo
wells considered?
Response: The information from the Lente and Jaramillo wells
available at the time of the preparation of the Air Force report
was considered and can be found on pages 104 and 105 of Volume VI
of the Remedial Investigation and Feasibility Study report. EPA
is aware of the detection of contaminants in these two wells.
The Record of Decision for SJ-6 does include the installation of
additional monitoring wells in the area where these wells are
located. Present information indicates that the contaminants in
the wells are below the standards for the individual
contaminants and exceed the New Mexico criteria for combined
carcinogenic effects in only the Jaramaillo well which is not a
drinking water source.
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Comment 14.:. "Lack of additional groundwater quality data from
offsite areas northwest of the site make interpretation of the
1985 and 1988 data difficult.
Response: This comment is correct insofar as additional
groundwater monitoring is needed north of the property to
further define contamination north of the property and to give
additional information on groundwater flow directions. Such
additional monitoring is called for in the proposed plan.
However, sufficient information does exist on the presence and
type of contamination to determine that groundwater remediation
in the shallow groundwater zone at the north end of the property
is necessary. The decrease in concentrations of contaminants
between the 1985 sampling and the 1988 sampling were not
sufficient to eliminate the need for remediation. The problem
of the change in metals content of the samples taken in different
sampling events is more troublesome, but can be resolved with
resampling during remedial design.
Comment 15: Vertical migration of contaminants from the shallow
groundwater zone to the intermediate and from the intermediate
to the deep zones is clearly not understood.
Response: While not excluding the possibility of migration through
other routes, it appears that much of the vertical migration from
the shallow to the intermediate zone in this area is through the
area where the clay aquitard is absent. Another possibility is
migration down boreholes as mentioned in the SJ-6 proposed plan.
It should be noted that three of the boreholes given in EPA's SJ-6
report as potential routes of contaminant migration are on the
General Electric property. These are the two water wells associ-
ated with the water towers at the General Electric property and
an abandoned well 81 that is located on the east side of the
property south of Woodward Road.
As for contamination in the deep zone, sample data shows contami-
nation beneath the GE property extending below 140 feet in only
one well, DMW-2. This is immediatly downgradient of the area in
which the aquitard between the shallow and intermediate zones is
missing. As there is no barrier to migration between the shallow
and intermediate zones this would seem to be direct vertical
movement.
Comment 16: Data show a clear plume of volatile organic
compounds emanating from the north end of the site toward the
private wells to the east. Flatness of the shallow aquifer
water table may not limit flow to a southerly direction through
the site; some contamination in the shallow zone at the north
end of the property may be migrating into the intermediate zone
and travelling east-northeast.
Response: Groundwater flow in the far northern part of the
property may not conform completely to the southerly flow seen
in the other parts of the property. However, examination of
shallow monitoring well analytical results, particularly wells SN
-------
13, SMW-14 and SMW-18, does not support there being an easterly
component to contaminant migration. As for northerly flow the
response to comment #1 explains that additional monitoring to
the north of the property is required by the Record of Decision.
Comment 17: Volatile organic compounds from the shallow zone
are [found] in the intermediate zone and "certainly evidence
shows that they [VOCs found in the shallow zone] are in the
deep zone."
Response: It is the migration of shallow contaminants to the
intermediate zone which requires the remediation of the shallow
zone. Further discussion of the routes of migration can be found
in the response to Comment 15. The only evidence of deep
contamination was in well DMW-2 at 140 to 160 feet in depth.
This contamination is immediatly down gradient of the southern
end of General Electric and remediation as well as further
monitoring in this area is part of the selected remedy.
Comment 18: The City of Albuquerque has determined that 25
residences in the area do not receive bills from the City Water
Department.
Response: EPA looks forward to receiving the results of the
City's inquiries into the source of drinking water for these
residences and will take those results into account when
planning additional sampling and monitoring.
Comment 19: Analysis of health risks must take into account the
full extent of the contaminant plume and the possible
synergistic effects of combinations of VOCs that individually
are below drinking water standards or remedial criteria as per
NMWQCC Regulation Section 3-103. This generic standard must be
incorporated into the list of ARARs.
Response: The New Mexico regulation regarding the additnve
effects of "toxic pollutant"s as defined by the NMWQCC
regulations was taken into account and the quoted regulation was
among those considered as part of the ARARs list.
Comment 20: Remedial actions should bring toxic pollutants to
below regulatory levels to insure that contaminant levels will
not exceed drinking water standards in future years.
Response: The selected remedy will require treatment of the
extracted groundwater to levels required by State and Federal
standards, including the "toxic pollutant" criteria mentioned
the response to comment #19, where this is technologically
feasi ble .
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Comment 21: EPA has a statutory responsibility to permanently
reduce 'contamination throughout the aquifer, not just in part of
it.
Response: The intent of the combined activities of EPA in the
South Valley Superfund site area is to provide protection for all
of those who are effected by contamination in the aquifer
originating from this site. The effort to eliminate contaminant
sources, limit further migration from one groundwater zone to
another, to recover and treat contaminated groundwater and to
provide for a substitute source of drinking water for the lost
City of Albuquerque water well provides for such protection both
short and long-term.
Comment 22: The decisions on the operable units are being made
in the wrong order; the decision on the GE site should be made
first, then the decision on the SJ-6 operable unit.
Response: Each of the operable units of the South Valley site
is part of a greater whole. However, the decisions on the SJ-6
operable unit and on the Former Air Force Plant 83/General
Electric operable unit are being made at the same time. This
will allow full knowledge of what is contained in the GE decision
when the SJ-6 decision is made. EPA believes that all concerns
about contamination will be addressed through the combination of
the remedies selected in the Records of Decision for the South
Valley site. Any additional concern that the remedy selected as
part of the General 'Electric Record of Decision might be changed
during negotiations is without basis. Negotiations will be for
implementation of the remedy already selected not on the remedy
itself.
Comment 23: EPA is failing to meet its obligations under
Sections 121 and 118 of CERCLA as indicated in the September 1,
1988 letter from the State of New Mexico to EPA.
Response: The referenced letter discusses the "strong preference
for-active remedial alternatives for contaminated water supplies
in §118 and §121". Active remediation is proposed for both
soils and groundwater.
Comment 24: Additional outreach and education of local
residents is needed. The reports are too technical for the
local residents.
Response: Tw-o meetings were held in Albuquerque (September 1 and
September 13, 1988) for discussion of the site investigation and
the proposed plan. In addition, the Superfund Amendments and
Reauthorization Act of 1986 added a provision which allows a
citizens' group to hire an advisor using grant funds. One of
the possible uses of a technical advisor would be to review data
and documents and "educate the citizens about the nature and
extent of contamination as well as possible solutions. A public
workshop on the grant program was held in Albuquerque on May 19,
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8
1988, and announcements were mailed to all of the people on the
mailing list for the South Valley site.
Comment 25: Why is EPA leaving the site and abandoning the
local residents?
Response: EPA is neither leaving nor abandoning the local
residents. An entire series of actions has been and will be
taken to correct problems associated with the South Valley
Superfund site. These include the remedial efforts proposed for
the GE property, the replacement of well SJ-6 with Burton #4,
planned cleanup actions at the Edmunds Street property, and the
elimination of abandoned boreholes serving as conduits for
contaminant migration. Nor are these short term activities. In
particular, the groundwater cleanup efforts may be time consuming
requiring many years of continued involvement by EPA. Monitoring
will be done to assess the effectiveness of the remedy as it is
implemented to judge its effectiveness and further action will
be taken if necessary beyond that in the selected remedy. It is
explicitly stated in the Records of Decision for SJ-6 and
General Electric that there will be an official review of the
remedies*after five years.
Comment 26t£ There is not sufficient integration between various
portions -of 'the site.
Response: Though the site has been divided into portions for
greater ease in handling the multiple problems at this site, EPA
still considers South Valley to be a single Superfund site.
Both of the project managers at EPA involved with the South
Valley site work closely together to insure that the aspects of
the project are integrated. This will be further demonstrated
with the formation of a workgroup to coordinate.design of the
selected alternatives once final decisions are made on
remedi ati on .
Comment 27: How can benzene used as a solvent be distinguished
from benzene from petroleum products?
Response: In areas where solvent contamination is found EPA
does not try to make such a distinction. It is only in areas
with known floating petroleum products that EPA attributes
dissolved benzene to petroleum contamination.
Comment 28: The lateral and vertical extent of contamination is
not known .
Response: The response to comments 1 and 2 relate to this
comment. There are two areas where the selected remedy calls
for additional monitoring to define lateral extent of
contamination. However, these efforts involve only two portions
of the contaminant boundaries. The lateral extent of most of
the area requiring extraction and treatment of groundwater has
been defined. As for vertical extent, only one well shows
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contamination at the .160 foot depth and this well is in one of
the areas in which additional monitoring is called for.
Comment 29: What about the contamination that appears in SJ-6 at
a depth of 812 feet?
Response: This comment relates more directly to the SJ-6
selected remedy, but quoting from the Responsiveness Summary for
that decision:
"SJ-6 was completed in 1963 and was near the end of its design
life in 1981. Over this 20 year period, about 100 feet of
sediment accumulated at the base of Well SJ-6. The cement seal
from the surface to the gravel pack also decomposed, providing a
rapid and direct conduit from the Intermediate Zone, where
contaminant concentrations are highest, down the borehole of
SJ-6. This problem was most, serious when SJ-6 was in use because
of the strong gradient that pumping this high volume municipal
well created. It is most likely that contaminants in the Inter-
mediate Zone were forcibly pulled fro'm the sources towards SJ-6
during well use. While the gradient is still in the same
direction due to municipal pumping, the wells are further away
and do not have nearly the hydraulic influence on the site as SJ-
6. This interpretation is supported by the decreasing
contaminant concentrations in the vicinity of and in SJ-6. The.
sediment at the base of SJ-6, however, became contaminated
during this period and is acting as a secondary source."
Comment 30: Exactly what monitoring to the north and east of
the site will be performed?
Response: Exact placement of monitoring wells is a function of
remedial design. Responses to comments 1 and 2 give the areas
in which additional monitoring is expected to the north and
east. No geographic limitation has been placed on additional
monitoring in the shallow zone north of GE as defining the limit
of groundwater needing remediation is the purpose of such
moni tori ng.
Comment 31: SJ-6 "target zones" limited the response at GE to
the shallow aquifer.
Response: The purpose of target zones was to defin'e the extent
of the SJ-6 remedial investigation and feasibility study as
separated from the GE work, not as a definition of remediation.
This is evident in both the depth of the work at GE which did
investigate the shallow, intermediate and deep zones and for
whi'ch actual remediation of both the shallow, intermediate and
upper deep zones is indicated in the proposed plan and selected
remedy for the GE property.
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10
Comment 32:. When will the additional monitoring north and east
of the site be done, when will the results be available and who
will do the work?'
Response: The when and who portions of this question cannot be
answered directly at this time. The answer depends on the
response to the notice letters from EPA to those potentially
responsible for the contamination. The law requires that when-
ever practicable EPA offer potentially responsible parties the
opportunity to implement the selected remedy. The law also
establishes a 120-day waiting period for negotiation between EPA
and potentially responsible parties for implementation of the
selected remedy. Once an agreement has been reached for perfor-
mance of the work under the supervision of EPA, installation of
the monitoring wells should follow within about one year for
work performed during remedial design and within the following
year for work performed as part of remedial action. The results
will be available immediately upon the receipt by EPA of the
final analysis of the samples.
Comment 33: Private water wells are not monitoring wells and
should not be the only wells used for monitoring.
Response: Private water wells normally have only a limited
usefulness as monitoring wells. Wells designed and installed
for the purpose of groundwater monitoring will be used for
gathering data in the areas in which additional monitoring is
required. Private wells can and will be used to gather some
information such as water level readings and as gross indicators
of areas of possible contamination.
Comment 34: There needs to be a binding agreement between EPA
and the Air Force on remediation at GE.
Response: EPA does not negotiate remedies, only their
implementation. Remedies are always selected prior to the
negotiation of implementation with a potentially responsible
party. EPA will notify all potentially responsible parties not
just the Air Force. For further detail see Comment 10.
Comment 35: The plume moving north and east of the South Valley
site will result in loss of aquifer potential and public and
pri vate we!1 suppli es .
Response: This question relates more closely to the SJ-6
remedy, but EPA has agreed as part of that remedy and part of
the one selected for GE to expand the monitoring well network
that exists in the area north and east of the site. The
remedies selected for the various portions of the South Valley^
site should prevent any further contamination of City or private
wells. This does not mean that the time necessary for
correction of contamination that may have been taking place over
the past 40 years will be short.
-------
11
Comment 36: The diagram of contamination in the intermediate
groundwater zone [shown as part of the public meeting] does not
reach SJ-6.
Response: No it does not. The diagram represents conditions in
1987 and 1988 not those from the period when SJ-6 was in use.
Comment 37: Risk for groundwater should be reevaluated based on
the water actually being used.
Response: This is how the risk was calculated. All of the risk
calculations were done assuming direct consumption of the
contaminated water.
Comment 38: Please provide a written response to the comments.
Response: A written response is always provided to comments
received during a comment period for remedy selection.
Comment 39: Why wasn't a comprehensive approach taken to this
site with EPA using the Superfund to do all the work and then
cost recovering against potentially responsible parties?
Response: The six industrial properties all had viable present
or past owners and or operators at the time of the initiation of
the Superfund investigation. These properties were also only
suspected sources for contamination, not known sources. In
cases where viable potentially responsible parties are available
to do investigatory work, EPA attempts to require those
potentially responsible for a problem to do the investigation
and later to do cleanup in order to preserve the money in the
Superfund for those sites where viable potentially responsible
parties are not available. Superfund monies were used in areas
outside the potential source properties.
Comment 40: Is it EPA's position that the water from SJ-6 is
not polluted?
Response: No that is not EPA's position. Remediation of well SJ
6 has been proposed as part of the SJ-6 proposed plan.
Comment 41: Why are the documents available for review labeled
draft documents?
Response: The documents will not be finalized until after the
public, EPA and the New Mexico Environmental Improvement
Division have had opportunity to provide final comments. In
this way the documents can reflect issues raised during the
public comment period.
-------
12
Comment 42: Are private well owners going to be compensated [if
their wells are plugged]?
Response: None of the selected remedies calls for plugging
active private wells.
Comment 43: Property owners should be required to notify anyone
who works within the plant about the possibility of soil
contamination.
Response: General Electric is aware of the results of the
investigation into its property and bears the responsibility of
the safety of its employees.
Comment 44: Who is going to evaluate the impact of one of these
actions on the others and has that person been appointed yet?
Response: Impact of one remediation effort on the others was
considered during remedy selection. During design of these
alternatives, a work group will be set up to coordinate the
efforts of all of the groundwater remedial activities in the
area of the South Valley site.
Comment 45: Additional monitoring under this proposed plan must
determine the relationship between contaminated groundwater
emanating from this property and the contamination detected in .
two private wells to the northeast and one municipal to the
north.
Response: The combination of additional monitoring proposed as
part of the selected remedy for the General Electric property
and that in the SJ-6 Record of Decision should supply this
information. For additional information see Comments 1, 2 and
32.
Comment 46: Chlorinated solvents which have been found in
groundwater beneath the GE/USAF property may be present above
State standards as far east as the central portion of the Chevron
property. Before design of a groundwater extraction system is
initiated, all intermediate and deep monitoring wells east of
the GE/USAF property must be resampled. If the resulting data
shows that these wells do not define the horizontal and vertical
extent of contamination above standards, additional monitoring
wells must be installed until the plume is defined. Only then
can an effective remedy be designed and implemented.
Response: Contamination in the monitoring wells in the central
portion of the Chevron property is below the standards for the
individual chemicals. The NMWQCC regulation Section 3-103A
requires that when more than one "toxic pollutant" as defined in
NMWQCC Regulation 1-101.UU, is present that their combined risk
above 1x10-5 be considered. The goal of Superfund action is to
reduce contamination in the aquifer below this standard.
-------
13
Contamination in these wells is already within the 10-5 order of
magnitude. The degree to which contamination is above the
1x10-5 level is almost wholly dependent upon the concentration
of 1,1 dichloroethene. As has already been stated, the
concentration of this chemical is below its numerical standard.
The proposed plan does call for cleanup of that area of the
groundwater zone to a depth of 160 feet immediately upgradient of
Chevron and east of General Electric. With the elimination of
both the soil sources of the contamination and the more greatly
contaminated water upgradient, any threat from the chloronated
solvents now found in the central portion of the Chevron property
should rapidly be eliminated. Monitoring will be performed
during the remedial effort to judge its effectiveness and the
remedy will be subject to the five year review mentioned in the
response to Comment 25. If at the time of the review it is
found that the remedial effort selected has not been effective in
reducing contaminant levels under the Chevron property, then the
remedy will be reevaluated and active treatment of the contami-
nation in this area may be initiated. The remedy will also be
reevaluated should the sampling during remedial design fail to
confirm the eastern extent of groundwater requiring recovery and
the area of groundwater recovery may be extended to the east.
-------
ATTACHMENT FOUR
ANALYSIS OF APPLICABLE OR
RELCVANT AND APPROPRIATE STANDARDS
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-------
ATTACHMENT FIVE
SUMMARY OF ANALYTICAL RESULTS
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or JMALYTICAL HESULTS of IMMGAKIC
PtRAHCTEBS DETECTED AT COMCEXTBATIQHS EXCEEPIN6 »VEUfi£
REGIONAL BACKGROUND LEVELS
Pirimtttr
No. of
No. of S*«p1es
Containing PcrMMttr
»bov« Btekoround LtvtU
Concentration
Haqao (ao/teal
(»o/ka> (1)
HWSA *V.
Arsenic
CadBiM
Mercury
HWSA *3:
Arsenic
Cad»iu«
Soloniua
24
24
24
12
12
12
HMA »4:
Art wile
Iron
Mercury
M
M
34
11
6
2
S
4
«
21
II
5
1
24
<10.0 - 3«.0
<2.0 - 7.S
-------
FROM HHSA *1 ANALYZED^
Chemical
Volatile Organic*:
Chloroethene vinyl ether
Ethylbenzene
Methylene Chloride
Tetrachloroethene
Toluene
Trlchlorofluoromethane
Xylenes
Base Neutral Compounds:
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)f1uoranthene
Benzo(k)f1uoranthene
Chrysene
Fluorene
Fluoranthene
Naphthalene
Phenanthrene
' Pyrene
Number Number
of Positive
Samples IDs
Sample Range
Low High
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
1
10
7
2
8
10
10
1
4
4
1
3
3
4
1
4
1
3
5
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
ww ^
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
0.27
0.43
7.20
0.14
0.62
0.30
0.63
0.75
2.10
3.90
2.10
6.90
6.70
3.30
0.45
3.50
0.70
0.95
4.60
Sample
Mean
0.27
0.38
5.61
0.14
0.32
0.18
0.53
1. All viluM
2 BOL means Below Detection Limit.
••
'" ........ " "
(1464C-8)
-------
SUMMARY OP THE DISTRIBUTIONS OF TOTAL VOLATILE ORGANIC COMPOUNDS
Depth
Interval
(ft)
0-2
2-4
4-6
6-8
8-10
10-12
12-14
14-16
16-18
18-20
-
Nunbtr
of
Samples
0
6
3
3
0
3
2
4
0
3
DETECTED IN
Number
of
Detections
0
3
0
2
0
0
0
2
0
3
SOILS IN HWSA fl
MIX 1 M«
Concentration
(ejg/fcg)
0
8.57
0
8.S8
0
0
0
3.24
0
7.21
Mean
Concentration
(ng/kg)(1)
0
3.46
0
8.28
0
0
0
2.28
0
4.80
FOOTNOTES:
(1) The sueplt Man 1s calculated only froei tht samples 1n which these
compounds were detected, not tht total nueJbtr of sables.
(2) The following cc«pounds were tht only VOCs detected:
trlchlorofluoroatthant, toluene, ethyl benzine, xylents. Mthylene
chloride, tetrachloroethyline and chlorotthyl vinyl ethtr.
(3) This tablt contains data froei borings 4 through 15.
(4) Duplicate) sables were averaged and considered as one staple.
(1464C-9)
-------
SUMMARY OF THE DISTRIBUTION OF BASE NEUTRAL COMPOUNDS
DETECTED IN SOIL SAMPLES COLLECTED IN HHSA »1
Depth Concentration
Interval of Total Polycycllc
Boring No. (ft) Aroaatlc Hydrocarbons
SAB009 18-20 5.21 »g/kg
SAB010 2-4 31.07 Kg/kg
SAB011 6-8 20.85 eg/kg
SAB013 12-14 10.4 eg/kg
SAB014 0-2 2.29 ig/kg
FOOTNOTES:
1. Thtst art tht only saapUs 1n which bast ntutral compounds wtrt
dtttcttd, and all bast ntutrals dtttcttd vtrt PAMs.
(1464C-10)
-------
NUMMARY QF ANALYTICAL RESULTS OF ORGANIC
COMPOUNDS DETECTED IN SOILS IN HHSA *2. HHSA f.
THE NORTH PARKING LOT AND THE AREA
ADJACENT TQ HELL DMB-2
HHSA »4.
ChtaUal
Numbtr Numtotr
of Posit
Sanplts IDs
6
6
6
12
36
36
36
36
36
36
36
HHSA f2:
Chloroform
Mtthyltnt Chlorldt
Trlchlorof1uoromtthant
HHSA f3:
Htthyltnt Chloride
HHSA 14:
Chl orof om
Ethylbtnztnt
l,1-01chlorotthtnt
Methylint Chlorldt
Tolutnt
Tr1 chl orof 1 uoromtthant
Xylints
North Parking Lot:
Bromomtthant 56
Chloromtthant 56
Chl orof om 56
Mtthylint Chlorldt 56
Total Pttroltu* Hydrocarbons 27
Aria Adjactnt to H«\l OM8-2:
HtthylMM Chlorldt 6
Tr1chlorofluoroatthant 6
FQQTMQTES!
1. All valuts 1n mg/kg.
2. BOL ntans btlow ditictlon I1«1t.
3. Tht samp It ntan 1s calculattd only fro* tht swells 1n «h1ch tht compound
was ditictid, not tht total nuabir of sa^lts.
4. OupHcatt samples wtri avtragtd and consldtrtd as ont saoplt.
vt Saapl* Rangt Samplt
Loll HW Mt4n
1
4
1
10
4
2
1
24
4
10
2
8
10
2
11
11
1
1
BOL -
BOL -
BOL •
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
BOL -
0.35
7.40
1.50
0.65
0.23
0.37
o.n
3.30
0.35
1.20
0.53
0.18
0.21
0.10
0.61
446.00
8.20
1.20
0.35
2.03
1.50
0.18
0.16
0.36
0.11
0.80
0.19
0.43
0.52
0.15
0.13
0.10
0.21
84.55
3.20
1.20
(1464C-U)
-------
Aluminum
Barium
Boron
Cadmium
Copp«r
Iron
Hagntslua
Mangantst
St1tn1u«
Z1nc
SJOSH1
0.21
0.06
0.26
0.04
<0.03
0.12
5.8
0.01
0.05
0.19
SJOSM2
<0.2
0.05
.22
.01
0.
0.
<0.03
0.25
4.8
0.03
-------
SUMMARY OF ANALYTICAL RESULTS QP SEDIMENT SAMPLES
FROM THE SAN JOSE DRAIN
Inorganics; SJOSD1 S3DSD2 SJDSD3 Av^faq* Background l^yffly (3)
Aluminum 1,800 6,500 7,000 30,000-70,000
Arsenic 31EJ* 64EJ* 71E3* 4-10
Barium 24 120 120 300 - 1500
Boron 7.5 16 16 LT 20 - 50
Cidratua <2 2.5* 3* 0.01 - 2.0
-------
SUMMARY OF INORGANIC RESULTS FOR SOIL SAMPLES
COLLECTED IN THE NORTH SECTQP
Element
Average
Background
Levelsd)
Number
of
Samples
Maximum
Concentration
tmmmmmmmmmmmm
Number
of
Detections
"*""""*"**••••*•••
Mean
Concentration^)
Aluminum 30,000-70,000 104
Antimony LT 1 104
Arsenic 4-10 104
Barlua 300-1500 104
Beryllium LT 1-1.5 104
Boron LT 20-50 104
Cadmium 0.01-2.0(3) 104
Chromium 30-70 104
Copptr LT 1-150 104
Iron 1000-20,000 104
Lead 10-200 104
Magnesium 2000-50,000 104
Manganese LT 2-500 104
Mercury 0.032-0.13 104
Molybdenum LT 3 104
Nickel LT 5-20 104
Selenlua LT 0.1-0.3 104
Silicon 270,000-350,000 104
Silver 0.7(3) 104
Thallium 0.1-0.8(3) 104
Vanadium 30-100 104
Zinc 28-45 104
40,000
NO
133 *
360
1.0
73 *
15 *
27
29
30,000 *
130
26.000
550 *
0.29 *
6.5 •
65 '
120 •
570
NO
NO
53
310 *
HA
HA
77
HA
HA
101
48
HA
HA
104
HA
HA
104
5
1
23
55
HA
HA
HA
HA
104
NA
NA
39.1 *
NA
NA
19.2
4.6 *
NA
NA
8758
NA
NA
144.6
0.10
6.5 *
10.5
37.0 *
NA
NA
NA
NA
20.9
FOOTNOTES:
1. All values 1n mg/kg (pom).
2. This table prtsents data for samples collected from borings 16-40 and 44-70.
3. Sample depths ranged fro* 0-2 to 16-18 ft below grade: sample locations are
shown 1n Figure 11-15 of the Remedial Investigation Report.
4. LT means less than.
5. * Indicates that this value exceeds average background levels.
6. NA means not applicable because the maximum] concentration detected of this
element did not exceed average background levels and Is therefore not further
evaluated.
(1) Source: Shacklttte and Boerngen (1984), unless otherwise specified. Average
background levels are for central New Mexico soils.
(2) The sample mean 1s calculated only from tht samples 1n which the element was
detected, not the total number of samples.
(3) Source: AdrUno (1986).
(1464C-5)
-------
^jjainjir TiioiwnTf m\\n FOR
-------
ATTACHMENT SIX
GROUNDWATER STANDARDS
-------
GROUNDWATER STANDARDS
Groundwater standards for regulation of the specific contaminants
can be found in the Safe Drinking Act and the New Mexico Water Quality
Control Commision Regulations for Discharges Onto or Below the
Surface of the Ground. However, the controlling factor in setting
standards for the Former Air Force Plant 83/General Electric portion
of the South Valley site is neither of these. It is instead New
Mexico Groundwater Control Commission (NMWQCC) Regulation Section 3-
103A which says in part "... If more than one water contaminant
affecting human health is present, the toxic pollutant criteria of
Section 1-101.UU for the combination of contaminants or the Human
Health Standard of Section 3-103.A for each contaminant shall apply,
whichever is more stringent." Section 1-101.UU says in part:
Any water contaminant or cocbination of the water contaninants in the
list below creating a lifetime risk of acre than one cancer per 100,000
exposed persons is a toxic pollutant.
acrolein
acrylooitrile
aldria
benzene
benzidine
carbon tetrachloride
chlordane
chlorinated benzenes
•onochlorobenzene
hexachlorobenzcne
pentachlorobcnzene
1,2,4,5-tetrachlorobenzene
chlorinated ethanes
1,2-dicaloroethane
hexachloroethane
1,1,2,2-tetrachloroethane
1,1,1-trichloroethane
1,1,2-trichloroethane
chlorinated phenols
2,4-dichloropnenol
2,4,5-trichloropheaol
2,4,6-trichlorophenol
chloroalkyl ethers
bis (2-chloroethyl) ether
bis (2-chloroisopropyl) ether
bis (chloromethyl) ether
chloroform
DDT
dichlorobenzene
dicblorobenzidine
1,1-dichloroethylene
dichloropropenes
dieldrin
2,4-dinitrotoluene
diphenylhydrazine
-------
eadosulfaa
•adria
cthylbcnzcac
halonetaaacs
broaodichloroMtaaa*
brraoactaaae
chloroa«taaa«
dichlorodifluoroacthaa*
dicaloroaethaat
tribro«o«ctaaa«
trichlo rof luo ro«« thaa*
acptacalor
hcxaehlorobutadica*
hczacalococycloatxaa* CHCH)
alpaa-HCH
btta-HCH
ttcaaical HCH
htxachlorocyclop«atadica«
isophorea*
aitcobcazcac
aitropacaol* .
2,4-diaitro-o-crt«ol
diaitropa«aolt
aitrosaaiao
H-oitro«oditthyla«in«
X-aicresodiactaylaaia*
K-aitcosodibutylaaia«
N*aitrosodipaeaylaaia«
N-aitro»opyrrolidin«
p*atacaloroph«aol
phcaoL
pataalatt csttrs
dibucyl phtaalatt
di-2-ethyLh«xyl pheaalat*
dittayl phtaalat*
diocthyl phtaalatt
polycb.loriaat*d bipacayls (PCB'i)
polyaueleac aromatic hydrocarboas (PAH)
aatarac«a«
3 ,4-b«azofluoraath«a«
b«aze(k) fluoraathcac
fluoraataca*
fluorta*
ph«aaathr*a«
pyrca*
tetracalococtaylca*
toluca*
toxaphcat
t ri cal o ro« thy 1 ea«
vinyl chloride
xylenes
o-xyiene
m-xylene
p-xylene
1,1-dichloroethane
ethylene dibromide (EDB)
cis-1,2-dichloroethylene
trans-1,2-dichloroethylene
naphthalene
1-methylnaphthalene
2-methylnaphthalene
benzo-a-pyrene
-------
The carcinogenic risk from chronic exposure to contaminated
groundwater can be calculated using certain standard assumptions.-
These assumptions include the following:; Consumption of 2 liters
of water a day for 70 years at a body weight of 70 kilograms. The
values used for the concentrations of contaminants are a combination
of values for the two wells. Concentrations of contaminants come
from a sample of the water under consideration.
The calculations are
Concentration
of contaminant
(part per mi 1 1 ion )
done
2
X
as fol 1 ows :
1 Hers
day x
cancer
potency
factor
increased
lifetime
cancer ri sk
70 kilogram body weight
This calculation would be done for each contaminant using cancer
potency factors from the Environmental Protection Agency's Cancer
Assessment Group. These factors are a measure of the potential of
the chemicals carcinogenic properties and are available through the
Integrated Risk Information System (IRIS). The individual
calculated increased lifetime cancer risks would then be added to
give a combined risk. It is this combined risk to which NMWQCC
Section 3-103.A would apply for.combined effects.
------- |