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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY b 5
WASHINGTON. D.C. 20460
OFFICE OF
THE INSPECTOR GENERAL
SEP 27
MEMORANDUM
SUBJECT:
FROM:
TO:
Final Report No. EISGG9-14-0013-0400041
Review of Selma Pressure Treating Site RI/FS
Gordon C. Milbourn III, Directon*^ / /»
Technical Assistance Staff ^C^**^^^-
Technical Assistance Staff
Daniel W. McGovern
Regional Administrator
EPA Region 9
Enclosed is a final report based on our review of the Selma
Pressure Treating Superfund Site RI/FS. Thank you for the
comments you provided on September 24, 1990 on the draft report.
Our response to your comments is included as an attachment to our
final report, along with your memorandum of September 24.
Any questions on the details of the final report can be
referred to Joe Italiano of my staff at FTS 475-7772.
We appreciate the time and effort of your Region 9 staff
that enabled us to complete the final report.
Enclosures
cc: Truman R. Beeler
Gerald Clifford
David Roberts
WASHINGTON, O.C. 20460
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REVIEW OF
SELMA PRESSURE TREATING SUPERFUND SITE
SELMA, CALIFORNIA
BY
ENGINEERING AND SCIENCE UNIT
TECHNICAL ASSISTANCE STAFF
OFFICE OF THE INSPECTOR GENERAL
SEPTEMBER 1990
Report NO. E1SGG9-14-0013-0400041
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I. PURPOSE AND SCOPE
The Engineering and Science Unit (ESU) of the Office of the
Inspector General is responsible.for examining Remedial
Investigations (RI's) and Feasibility Studies (FS's) for Remedial
Actions as directed by Section lll(k) of the Superfund Amendments
and Reauthorization Act of 1986 (SARA).
ESU selected the Selma Pressure Treating (SPT) site which is
located in Selma, California, for review. The objective of the
review was to determine if there is an adequate technical basis
for the selected remedy as documented in the Record of Decision
(ROD).
To address this issue, ESU staff met with U.S. Environmental
Protection Agency (EPA) Region 9 program staff and made a visit
to the SPT site in Selma, California, in April 1989. The
disruption of Region 9 program office activities due to the San
Francisco earthquake in October 1989 contributed to delays in
completing the ESU review. We obtained additional technical
information from Region 9 in April 1990.
The findings of this report are based on discussions with
Region 9 staff and review of the following documents:
1. Guidance for Conducting Remedial Investigations and
Feasibility Studies under the Comprehensive
Environmental Response, Compensation and Liability Act
(CERCLA), USEPA, Preliminary Review Draft, October
1987.
2. Final Remedial investigation report for the Selma
Pressure Treating Site, Selma, California, March 21,
1988, Camp Dresser and McKee (COM) Incorporated.
3. Draft Feasibility study report for the Selma Pressure
Treating Site, Selma California, June 3, 1988, Camp
Dresser and McKee Incorporated.
4. Record of Decision for the Selma Pressure Treating
Company Superfund site, September 1988, U.S. EPA
Region 9.
5. Responsiveness Summary for the Feasibility Study, Selma
Pressure Treating Company (Undated).
6. Draft Solidification/Stabilization Treatability Studies
for Selma Pressure Treating Site, March 1989, Roy F.
Weston, incorporated.
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7. Draft Pre-Reroedial Design Soil Boring Report for the
Selma Pressure Treating Site, June 21, 1989, TES II-
Team, Science Applications International Corporation
and CDM Federal Programs Corporation.
8. Solidification/Stabilization Treatability studies for
Selma Pressure Treating Site, Fresno, California,
August, 1989, Roy F. Weston, Incorporated.
9. Hydrogeological Report, Selma Pressure Treating Site,
Selma, California, January 1990, Roy F. Weston,
Incorporated.
10. Addendum to Final Hydrogeological Report, Selma
Pressure Treating Site, February 1990.
II. CONCLUSIONS
The following are ESU's conclusions for the issue
identified in Section I of this report.
Was there an adequate technical basis for the
selected remedy as documented in the ROD?
There was not an adequate technical basis for the selected
remedy documented in the ROD for the following reasons:
1. Too few soil samples were taken to confidently
calculate the amount of contaminated soil requiring
remediation.
2. Solidification/stabilization treatability test results
were not available until after the ROD was signed and
the results to date have been inconclusive. The August
1989 Treatability Study Report concluded that the
solidification/stabilization technologies have
limitations in applications to areas containing high
concentrations of metals, pentachlorophenol (PCP) and
other organics.
3. Additional wells in the shallow, intermediate and deep
aquifer north and northwest of the SPT site are needed
in order to determine if there is an off-site source of
groundwater contamination that would require off-site
soil remediation.
Both EPA and the State have acknowledged that additional
work is required at the SPT site and that it may result in a
change to the chosen remedy included in the ROD.
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Despite the deficiencies identified in this review which
relate to meeting the requirements of SARA, we recognize Region 9
staff for completing the SPT RI/FS in accordance with applicable
EFA guidance.
III. SITE LOCATION AND DESCRIPTION
The SPT site is located about 15 miles south of Fresno and
adjacent to the southern city limits of Selma. (The site is
shown on the map in Attachment A.) The entrance to the site is
located at the intersection of Dockery Avenue and Golden State
Boulevard (Old Highway 99). The SPT site comprises roughly 18
acres, including a three to four acre wood treatment facility and
14 acres of adjacent vineyards that were used for site drainage.
Selma is situated in the center of the San Joaquin Valley. The
area contains many vineyards where grapes are grown to make
raisins and wine.
SPT is located in a transition zone between agricultural,
residential, and industrial areas. The site is zoned for heavy
industrial use. Urban residential areas lie to the
north, and scattered suburban dwellings surround the site.
Roughly 12 residences and businesses are located within a 1/4
mile radius of the SPT site.
Drainage canals and irrigation ditches flow over the
essentially flat terrain to the southwest. This network of
canals and ditches supplies surface water for agricultural use.
The Consolidated Irrigation District provides the majority of the
irrigation water supply in the area.
The surface water irrigation supply is supplemented by
groundwater resources in the vicinity of the site which also
supply the necessary domestic water for the surrounding
communities and the scattered residences. The regional
groundwater gradient in the vicinity of the site is to the
southwest. EPA has classified the groundwater resources in the
area of the SPT site as a Sole-Source Aquifer under the Safe
Drinking Water Act. Under EPA's Groundwater Protection Strategy
(1989) the aquifer in the SPT area has been classified as a Class
IIA current drinking water source with other beneficial uses.
The climate for the site consists of hot summers and mild
winters. The maximum temperatures are generally around 100°F in
July, with the minimum temperature of 35°F in January. Average
annual precipitation in the area is less than 10 inches. The
total annual class A pan evaporation rate in the Selma area is
approximately 100 inches. The monthly evaporation losses range
from two inches per month during the winter to 18 inches per
month during the summer.
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IV. SITE HISTORY ANDCONTAMINANTS
Treatment of lumber products has been ongoing at the SPT
site since 1942. The original wood treatment facility covered
approximately 3 1/2 acres. In 1961, the treatment operation was
taken over by Gerald Petery, the son of the original owner, and
his wife, Mary Ann Petery (now Schuessler). A summary of the
operating history of the Potentially Responsible Parties (PRP'S)
is as follows:
DATES
1961 - 1969
1970
1971 - 1977
1977 - 1981
4/81 - 1982
2/82 - present
OWNERS
Gerald Petery and Mary Ann Petery operated
the facility as individuals.
Gerald Petery and Mary Ann Petery
incorporated as Selma Pressure Treating
Company, which was responsible for operating
the facility.
Selma Leasing Company was organized and owned
by Gerald Petery. Selma Leasing Company
became the owner of the land upon which SPT
operated.
Gerald Petery sold his interest in SPT to
Mary Ann Schuessler (formerly Petery). Mary
Ann Schuessler became the sole owner,
president, and operator of SPT.
SPT filed for bankruptcy and First Interstate
Bank as trustee took over the operation.
SPT's trustee sold wood treating assets to
saw Mill Properties, Inc., which operates the
facility as Selma Treating Company.
The wood-preserving process originally employed at the SPT
site involved dipping wood into a mixture of PCP and oil, and
then drying the wood in open racks to let the excess liquid drip
off. A new facility was built in 1965, and SPT changed to a
pressure treating process which consisted of conditioning the
wood and then impregnating it with chemical preservatives.
Prior to 1982, discharge practices included: (1) runoff into
drainage and percolation ditches, (2) drainage into dry wells,
(3) spillage onto open ground, (4) placement into an unlined pond
and sludge pit, and (5) discharges to the adjacent vineyards.
These wastes were generated from spent distillation fluids and
sludge.
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The current Selma Treating Company wood treating operations
are regulated by California Waste Discharge Order No. 78-171,
which precludes discharges to areas having hydraulic continuity
with groundwater. When Selma Treating Company began operations,
the California Regional Water Quality Control Board required
installation of drip pads, berms around the site, and runoff
containment to prevent ongoing contamination.
Based on the history of processes utilized at the site,
several site-related contaminants have been identified as
follows:
1. The metals arsenic, chromium and copper.
2. PCP and its associated degradation and impurity
products; for example, chlorinated dibenzodioxin,
chlorinated dibenzofuran and trichlorophenols.
3. Hydrocarbon contaminants from the use of diesel fuel as
a carrier; for example, the volatiles benzene, toluene
and xylene, and polycyclic aromatic hydrocarbons, such
as naphthalene and pyrene.
These site-related contaminants are a potential threat to
public health and welfare. For example, PCP has been
demonstrated to be toxic to aquatic organisms, animals and
humans. Arsenic exposure has been demonstrated to increase
incidence of human lung and skin cancer. Acute exposure to high
concentrations of either arsenic or PCP can be fatal. Excessive
exposure to trivalent chromium results in acute central nervous
system and liver disturbances. Hexavalent chromium is suspected
of being a human carcinogen.
Between 1971 and 1981, the Regional water Quality Control
Board regulated the discharges from SPT, under a Waste Discharge
Requirements Order. On January 6, 1981, a former SPT employee
notified EPA's Air and Hazardous Materials Division of SPT waste
disposal methods that allegedly caused direct contamination of
the soil and groundwater at the site. This call prompted an
Uncontrolled Hazardous Waste Site Investigation on January 13,
1981 in accordance with Section 3007 of the Resource Conservation
and Recovery Act, by EPA's Field Investigation Team, the
California Department of Health Services, and the Regional Water
Quality Control Board. This inspection raised concerns about the
potential for groundwater contamination from the site. As a
result, SPT was required to modify its operation to minimize the
potential for contamination. The State and EPA then conducted
initial site investigation activities to assess contamination
problems.
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SPT filed for Chapter 11 protection under the Bankruptcy Act
on April 13, 1981. On May 21, 1981 SPT submitted to EPA a
chronology of waste management activities conducted at the site
from 1965 to 1981. The letter identified areas of waste
disposal, including an effluent pond, sludge pit, dry wells and
two pipelines. The two pipelines reportedly have carried
effluent from the site to two discharge points located off-site,
where the effluent was discharged. The discharge points were
located at the intersection of Dockery Avenue and Highway 99, as
well as a point located west of the SPT facility at Highway 99.
In August of 1983, EPA ranked the site using the Hazardous
Ranking System. The ranking for the site indicated that the
release of hazardous substances from the site may present a
danger to human health and the environment. Based on this
information the site was placed on the Superfund National
Priorities List of hazardous waste sites in September 1983. The
Hazardous Hanking System score was 43.83, and the site was listed
as number 195.
Field activities for the RI/FS began in April 1986. A final
RI report was issued for the site in March 1988, followed by a
draft FS report in June 1988. The RI/FS determined that there
was soil and groundwater contamination present at the site and
that soil and groundwater remediation was necessary. PRP's were
not involved in development of the RI/FS. Technical discussions
with PRP'S have been limited to formal comments on the RI/FS and
related meetings. Region 9 issued a ROD for the SPT site on
September 24, 1988 that provided a permanent remedy for soil and
groundwater contamination.
Soil Contamination
Of the contaminants identified previously, arsenic and
dioxin/furan are present in concentrations above the established
remediation goals for the SPT site. Based on the RI/FS, the
maximum concentration of 4,120 mg/kg of arsenic was found in the
surface soil at the waste sludge pit. The established cleanup
goal for arsenic is 33 mg/kg.
Based on the RI/FS, the maximum concentration of
dioxin/furan was 2,317 ng/g in the surface soil at the southeast
disposal area. The cleanup goal for dioxin/furan was established
at 1 ng/g.
Groundwater Contamination
Based on the RI/FS the only contaminant in groundwater found
to be present above the cleanup goals at the SPT site was
chromium. A maximum concentration of 8,710 ug/1 total chromium
was found in the groundwater at the SPT site. The cleanup goal
for total chromium was established at 50 ug/1.
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V. FINDINGS AND DISCUSSION
The findings discussed below are based on ESU's review of
the documents listed in Section I of this report, and discussions
with Region 9 staff.
Was there an adequate technical basis for the selected
remedy as documented in the ROD?
The recommended remedial alternative in the ROD included
several activities. Soils contaminated beyond the cleanup goals
were to be excavated, mixed with a fixative agent to solidify and
stabilize them, and then returned to the excavated areas. The
fixed and stabilized soils were to be covered with a Resource
Conservation and Recovery Act cap and monitored for a period of
approximately 30 years. Long-term access and land use
restrictions were to be implemented for the fixed and stabilized
soil areas.
Contaminated groundwater was to be extracted and treated
using precipitation, coagulation, and flocculation processes to
remove chromium so that it meets applicable drinking water
standards. Treated groundwater was to be disposed of by
reinjection into the aquifer or by off-site disposal as
appropriate. Groundwater was to be monitored to verify
contaminant removal, and short-term institutional controls, to
prevent use of contaminated groundwater, were to be implemented
until remediation is complete.
The ROD estimated a cost of $11,280,000 for the selected
remedial action.
Soil Contamination
The RI/FS did not provide enough technical information to
support the chosen remedy documented in the ROD. Too few soil
samples were taken to confidently calculate the amount of
contaminated soil requiring remediation. The Draft FS report
contained estimates for 16,100 cubic yards of soil that were
above the cleanup goals and would require remediation. This
compares to 23,335 cubic yards of soil requiring remediation
estimated in the Draft Pre-Remedial Design Soil Boring Report,
which was completed a year later.
Solidification/stabilization treatability test results were
not available until after the ROD was signed and the results to
date have been inconclusive. The August 1989 Solidification/
stabilization Treatability Study Report concludes that
solidification/stabilization technologies "appear to be possible11
for immobilization of the metallic contaminants at the SPT site.
The report concludes that the technologies have limitations in
application to areas containing high concentrations of metals,
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PCP and other organics. The report recommends that pilot scale
tests be conducted at the site using representative samples and
that the treated samples be monitored for quality of leachate and
permeability under actual site conditions. It is ESU's
conclusion that more work must be done to determine if the remedy
documented in the ROD is actually a viable alternative for soil
remediation at this site.
Groundwater Contamination
The RI/FS did not generate enough technical information to
support the chosen remedy documented in the ROD. It is ESU's
opinion that additional wells in the shallow, intermediate and
deep aquifer north and northwest of the SPT site are necessary to
establish background levels of groundwater quality and to
determine if there are other sources of contamination.
Studies at another site, upgradient from the SPT site,
indicate the possibility of potential sources of contamination
that were not properly considered in the RI/PS. Selma Ag Supply
had a Site Investigation that documented arsenic, chromium and
copper contamination in the soils at this site. These are the
same contaminants that are of concern at the SPT site where
groundwater contaminated with chromium is of greatest concern.
The Site Investigation report for Selma Ag Supply recommends
further investigation of the site to determine the extent of
contamination.
If it is determined that there is another source of
groundwater contamination upgradient from the SPT site, then that
would indicate the need for additional off-site soil remediation
prior to groundwater remediation. It is ESU's conclusion that
two more clusters of wells north and northwest of the SPT site
(see site map in Attachment A) will provide the information
needed to determine if additional off-site soil remediation is
necessary.
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Selma Pressure Treating Site RI/FS Review
Response to Region 9 Comments on Draft Report
We are in receipt of comments from the Regional
Administrator, Region 9, dated September 24, 1990 on the OIG
draft report, Selma Pressure Treating (SPT) Site RI/FS Review.
The Region's memorandum provided comments on each of the three
key findings in the OIG draft report.
As a result of the comments, in the final report we have
deleted the reference to the Selma Electroplating site as a
possible contributor to groundwater contamination in the vicinity
of the SPT site. Although it would appear that contamination
from Selma Electroplating would not be likely to reach the
vicinity of the SPT site, the Region may still wish to
investigate further to be certain.
Regarding Selma Ag supply, the Responsiveness Summary for
the Feasibility Study summarizes the Site Investigation (SI)
conducted by EPA. It indicates that Selma Ag Supply is located
approximately 300 feet to the northwest of the SPT site. Surface
soil samples collected at the site showed elevated chromium
levels up to 90 mg/kg, although the source of the chromium
contamination is not known. Further, the SI recommends that
additional investigations be conducted at the Selma Ag Supply
site to determine the lateral and vertical extent of soil
contamination and obtain data on nearby groundwater quality.
As Region 9 has indicated, the upgradient wells sampled
during the Selma RI/FS were near the northeast corner of the SPT
site and thus did not represent groundwater conditions along the
entire northern boundary of the site. It is ESU's conclusion
that there is no information in Region 9's comments that would
preclude the possibility of off site sources of contaminated
groundwater especially in the vicinity northwest of the SPT site.
ESU believes the Region should investigate this further prior to
proceeding with groundwater remediation.
There are three typographical errors in the attachment to
Region 9's September 24, 1990 memorandum. On the first page
under number 2, the second sentence should read "...aquifer north
and northwest of the site...". In the final paragraph on page
one, second sentence and in the first paragraph on page two,
first sentence, it should read "...Selma Pressure Treating...".
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UNITED STATES
ENVIRONMENTAL PROTECTION ACCNCT
REGIONAL ADMINISTRATOR
1235 MISSION STREET
SAN FRANCISCO, CA M103
1*0 (on 9:
Arizona
California
Nevada
Pacific Islands
September 24, 1990
MEMORANDUM
SUBJECT!
FROM:
TO:
Draft Report No. E1SGG9-14-0013-XXXX
Review of Selma Pressure Treating Site RI/FS
Daniel W. McGovern
Regional Administrator, Region 9
Gordon C. Milbourn III, Director
Technical Assistance Staff (A-109)
Thank you for the opportunity to review the subject draft
report prepared by the Engineering and Science Unit of the Office
of the Inspector General. Staff of our Hazardous Waste
Management Division have provided the attached comments for your
consideration in preparing a final report.
Should you have questions on the attached, Mike Schulz and
Rich Hennecke, our Region's audit follow-up coordinators, would
be pleased to assist you. Mike can be reached at FTS 556-6196,
and Rich is at FTS 556-6397.
Attachment
10
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Selma Pressure Treating Site RI/FS Review
DIG Draft Report No. E1SGG9-14-0013-XXXX
The above-titled draft audit report concludes that, "There
was not an adequate technical basis for the selected remedy as
documented in the [Record of Decision] ROD." The following basis
for this conclusion is offered by the draft report:
1. Too few soil samples were taken to confidently
calculate the amount of contaminated soil requiring
remediation.
2. Solidification/stabilization treatability test
results were not available until after the ROD was
signed and the results to date have been incon-
clusive. The August 1990 Treatability Study Report
concluded that the solidification/stabilization
technologies have limitations in applications to
areas containing high concentrations of metals,
pentachlorophenol (PCP), and other organics.
3. Additional wells in the shallow, intermediate and
deep aquifer north and northeast of the site are
needed to determine if there is an off-site source
of groundwater contamination that would require
off-site remediation.
Region 9 Response - Too FewSoil Samples
The soil samples that were taken during the Remedial
Investigation/Feasibility Study (RI/FS) were adequate to identify
the presence, characteristics, and levels of contaminants on the
site and to estimate (within -30%,+50%) the volume of soil which
would require remediation. It was recognized in the ROD that
further pre-design soil sampling would be required to better
define the concentrations and locations of contaminants. This
additional characterization has had no effect on the remedy
selection made when the ROD was signed.
During the development of the Remedial Design (RD) and the
Remedial Action (RA), it is not uncommon that further information
is available which adds or subtracts from the areas or quantities
which require remediation. For example, the pre-RD soil sampling
for Selma Pressure Testing (SPT) increased the projected soil
quantity requiring treatment from the 16,000 cubic yards
estimated in the RI/FS to 23,000 cubic yards, subsequent
discussions with the State led to a change in the site-specific
soil attenuation factor for arsenic. This resulted in a change
in the arsenic cleanup goal from 0.5 ppm to 5.0 ppm and a
reduction in the quantity of soil to be treated to approximately
10,000 cubic yards.
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Region 9 Response - Treatabilitv Study Results Not Available
Until After the ROD
The policy on conducting treatability studies before the ROD
was not formally established at the time the Selma Pressure
Testing RI/FS was being completed. The draft policy recommending
treatability studies before issuing the ROD may have been out for
review, but it was not generally implemented at that time. The
guidance to perform treatability studies during the RI/FS is now
being followed by Region 9.
The concern stated in the draft audit report about the
applicability of solidification/stabilization technology to the
Selma soil cleanup may now appear to be reasonable. The
treatability studies to date have not clearly demonstrated that
pentachlorophenol (PCP) can successfully be treated to achieve
the site cleanup goals. The treatment of metals does appear to
be appropriate to meet the respective cleanup goals. However, at
the time of the ROD, there were EPA publications that recommended
the use of this technology for both organic and inorganic wastes
(for example, see The Superfund Innovative Technology Evaluation
Program. EPA/540/5-88/003).
We have been working with the Office of Research and
Development (ORD) in Cincinnati to have a Superfund Innovative
Technology Evaluation (SITE) demonstration project of the
solidification/stabilization technology done on the Selma site.
The demonstration is scheduled to start in October 1990. Also,
investigations have been initiated to evaluate alternative
treatments for PCP in the Selma soils if the selected remedy is
not successful.
Region 9 Response - More Wells Needed to Determine if there are
Off-Site Sources of Groundwater Contamination
The potential sources of groundwater contamination which
were identified in the draft audit report, Selma Ag Supply and
Selma Electroplating, are located north of the SPT site. The
groundwater gradient in the area is in a south-southwest
direction. The up-gradient wells which were sampled during the
RI/FS did not show any significant levels of PCP, arsenic,
chromium, or copper. The up-gradient wells were near the
northeast corner of the SPT site and thus did not represent
groundwater conditions along the whole northern boundary of the
site. However, the evaluation of the groundwater data developed
during the RI/FS seemed to clearly identify the high
concentrations of soil contaminations as the on-site sources of
chromium in the groundwater.
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_ 3 -
It was recognized that additional pre-RD hydrogeological
work would be required to better define the extent of the
contamination and the hydrostratigraphic characteristics of the
site. Although the Site Investigation Reports for Selma AG and
Selma Electroplating recommended further investigation, the
additional information developed from the post-ROD
hydrogeological study did not present any further evidence of
off-site sources of chromium contamination.
Relative to Selroa Electroplating, one would not expect
contamination from that site to reach the SPT site. Selma
Electroplating is located approximately 1.4 miles northwest of
SPT (see figure 1). The groundwater gradient in the area is
generally in the southwesterly direction. Thus, any
contamination from Selma Electroplating would tend to be going
away from the SPT site.
Selma Ag, at the request of the California Regional Water
Quality Control Board (RWQCB), sampled the soil from a sump area
which collects site runoff water and cleanup water from washing
fertilizer mixing equipment. The soil was tested in July 1990
for arsenic, chromium, and copper, as well as the constituents in
various pesticides (Alaclor, Deldrin, Endrin, Lindane, Parathion,
Malathion, and Diazinon). The pesticides analyses showed
non-detect. The metals analyses were as follows (mg/kg):
SUMP BACKGROUND
As 4.8 2.5
Cr 4.7 6.4
Cu 17.8 6.3
The above information would tend to indicate that Selma Ag is not
a likely source of off-site contamination.
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Fiom: SELMA QUADRANGLE
CALIFORNIA
7.5 MINUTE SERIES (TOPOGRAPHY.
. IC/4 JtLMA i$ ai.AOHANC-1
Selma Pressure
Treating Site
ite Location Map
FIG 1
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