United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-89/029
December 1988
Superfund
Record of Decision
IBM (San Jose), CA
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R09-89/029
3. Recipient* Acceeeion Ho.
4. TltteendSuMMe
SUPERFUND RECORD OF DECISION
IBM (San Jose Plant),. CA
First Remedial Action - Final
3. Report Date
12/15/88
w«hor<«)
8. Performing OrganizMlon Rept No.
V. Performing Ora«Wi»tlori Name and AAlreee
10. Pro|ecttTiak/Work UnN No.
11. Corilnct(C) or GramtC) No.
(C)
12. Sponoartng Organization Name and Addreeo
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D^C. 20460
13. Type of Report A Period Covered
800/000
14.
15.
IS. Abe»act (Limit 200 word*)
International Business Machines ..(IBM) has owned and operated a facility that
manufactures data processing machines in Santa Teresa Basin in San Jose, .California. IBM
has operated the facility since December 1956 using organic chemicals including TCA.
acetone, xylene, and petroleum naphthas. The organics have been handled and stored
onsite in drums, and above-ground and underground tanks. In addition, waste organic
solvents were stored in concrete or steel underground tanks or drums; however, the
concrete tanks were designed only to store organic wastes. In October 1980, while
excavating tanks in Tank Farm No. 1, IBM discovered soil contaminated with organics.
Futhermore, investigations in November 1981 revealed extensive ground water
contamination. The ground water plume extends more than three miles northwest and is
more than 180 feet in depth. Fourteen active or potentially active water supply wells
are downgradient to the plume; however none of these public wells have been found to
contain VOCs above State and Federal drinking water standards< Nineteen so.urces of soil
and ground water contamination have been identified including tank overflows, spillage
from drum handling, and tank and pipeline fitting failures. Activities to prevent
further solvent migration from the IBM source areas have been conducted including
removing underground storage tanks which were replaced with above-ground tanks, and
(See Attached Sheet)
CA
17. Document Analyaia a, Deecrlptora
Record of Decision - IBM (San Jose Plant),
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (xylenes, TCA), Organics
b. Montfflora/Open-Endad Terme
e. COSATI Reid/Group
AvallapURy Statement
19. S*curttyCliM(Tnl«R»port)
None
20. Security CUM (TW« P»g»)
None
21. No. ol Page*
145
22. Prica
(See ANS4-Z39.18)
Sa» Instruction* an /bum**
OPTIONAL FORM 272 (4-77)
(ForrmHy NTIS-35)
Department o( Commerce
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
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16. Abstract Include a brief (200 words or less) factual summary of the most significant Information contained In the report If the
report contains a significant bibliography or literature survey, mention It here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terma
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GPO 1983 0 - 381 -526 (8393) OPTIONAL FORM 272 BACK
(4-77)
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EPA/ROD/R09-89/029
IBM (San Jose Plant), CA
First Remedial Action - Final .
16. Abstract (Continued)
excavating more than 23/000 yd3 of contaminated soil. Interim remedial measures begun
in November 1982 to clean up the plume have included off- and onsite ground water
extraction with discharge of untreated ground water to storm drains. The primary
contaminates of concern affecting the soil and ground water are VOCs including TCA,
toluene, and xylenes; and other organics. •
The selected remedial action for this site includes onsite soil vapor extraction;
onsite shallow and deep ground water, and offsite deep ground water pumping and
treatment using air stripping, followed by onsite discharge of treated ground water to
the aquifer and offsite discharge to surface water after the reuse capacity of the
aquifer is exhausted. Remedial action costs for this remedy were not provided.
-------
RECORD OF DECISION
International Business Machines
San Jose, CA
December 1988
-------
TABLE OF CONTENTS
Part 1 - Declaration
Part 2 - California Regional Water Quality Control Board
Staff Report
Part 3 - California Regional Water Quality Control Board Site
Cleanup Requirements Order
Part 4 - Responsiveness Summary
Part 5 - Administrative Record Index
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PART 1
DECLARATION
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RECORD OF DECISION
DECLARATION
SITE NAME AND LOCATION;
International Business Machines
San Jose, CA
STATEMENT OF BASIS AND PURPOSE
This document serves as EPA concurrence with the remedial
action for the International Business Machines (IBM) site, as ap-
proved by the California Regional Water Quality control Board,
San Francisco Bay Region (RWQCB). The RWQCB approved this
remedial action in cbnformance with: Sections 13000 and 13304
of the California Water Code, State of California Health and
Safety Code Section 25356.1, CERCLA, as amended by SARA, and the
National Contingency Plan.
This EPA concurrence with the State's selection of remedy is
based upon the RWQCB's Staff Report, the Remedial Action Plan,
the Site Cleanup Requirements Order, the Responsiveness Summary,
and the Administrative Record for this site. The attached index
lists the items comprising the Administrative Record.
DESCRIPTION OF REMEDIAL ACTION
The selected remedy provides for final cleanup requirements
related to onsite soils and groundwater, and offsite groundwater
contamination. IBM has conducted interim remedial activities un-
der RWQCB orders since 1984. The major components of the final
selected remedy include:
o Onsite soil vapor extraction
o Onsite shallow and deep groundwater extraction and treatr
ment with airstripping
o Offsite deep groundwater extraction and air stripping
with nozzles into storm drains
o Onsite recharge of treated groundwater to maximum extent
feasible . • ...
o Discharge to surface water under NPDES permit of any
treated groundwater remaining after reuse capacity ex-
hausted .
DECLARATION - - ' -
EPA concurs with the remedy selected by the RWQCB for the
IBM site.
The selected remedy is protective of human health and the
environment, attains Federal and state requirements that are ap-
plicable or relevant and appropriate to the remedial action, and
is cost effective. This remedy satisfies the statutory
preference for remedies that reduce toxicity, mobility, and/or
-------
volume as a principal element. It also utilizes permanent solu-
tions to the maximum extent practicable. The 5-year facility
review provision has been included as part of the RWQCB Site
Cleanup Requirements Order.
Date
LO
iniel W. McGovern
Regional Administrator
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PART 2
STAFF REPORT
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Hit Me. 2189.803KIAA)
REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
INTERNAL MEMO
TO: Steven R. Ritchie, Executive Officer FROM: Belinda A. Alien
DATE: September 27, 1988 SIGNATURE: /s/Belinda A. Allen
SUBJECT: DRAFT REMEDIAL ACTION PLAN FOR
INTERNATIONAL BUSINESS MACHINES,
SAN JOSE FACILITY
The purpose of this staff report is to provide the basis for, and a description of, the draft final
remedial action plan for the International Business Machines (IBM) site. Tentative Orders for IBM's
Site Cleanup Requirements (SCR) and a NPDES permit are based on this staff report
This staff report k organized as follows: 1) Background; 2) Plan Development; 3) Plan Description; 4)
Recommendations.
BACKGROUND
International Business Machines (IBM) operates and owns a facility that manufactures data processing
machines, including disks and mass storage systems at 5600 Cottle Road in the City of San Jose, Santa
Clara County (Figure 1). Construction of the facility began in 1955 on land previously used for
agricultural purposes. The facility has been in operation since December 1956. IBM used organk
•bemicals such as 1,1,1-trichloroethane (TCA). Freon 11, Freon 12, Freon 113, isopropyl alcohol (IPA),
ylene, acetone, petroleum naphthas and others. Organic chemicals have been handled and stored in
oottles, drums, above ground tanks, and under ground tanks.
Waste organic solvents were conveyed from, in some cases, intermediate waste sumps and stored in
concrete or steel underground tanks (1000 or 6000 gallons) or in 55 gallon drums. The concrete tanks
were designed to only store inorganic wastes, but-organic chemical wastes were also stored in the
concrete tanks.
Release Discovery
In October 1980, the discharger discovered TCA, petroleum naphtha and zylenes in soil during
excavation of tanks in Tank Farm No. 1. The same month, the discharger confirmed that a release of
chemicals had occurred and reported the release to Regional Board staff. Chemical analyses indicated
that the soil in the source area contained up to 110 pot of TCA, 16.00&ppm petroleum naphtha, and
1,100 ppm xylenes. Inr November 1981. additional investigation revealed extensive ground water
pollution. At that time a comprehensive she-wide investigation program was initiated, as requested by
Regional Board staff. Other sources of pollution were found, including a significant source of Freon
113. IBM was required to def:ne the extent of all pollution, both in the soil and ground water, for
each source. IBM has since identified at least nineteen sources, but has not yet fully identified the
location of three sources of chenr -*ls. IBM determined that the releases to soil and groundwater were
due to tank and pipeline fitting failures, tank and sump overflows, spillage from drum handling, and
other releases.
^continues
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DRAFT REMEDIAL ACTION PLAN FOR Page 2 ,
INTERNATIONAL BUSINESS MACHINES, September 27, 1988
SAN JOSE FACILITY
Geology
A geologic study was conducted on both the Santa Teresa Basin, where the facility is located, and the
San Jose Plain, which is located downgradfent of the Santa Teresa Basin. These are both sub-basins
of the Santa Clara Basin. Edenvale Gap, located between Oak Hill and Edenvale Ridge is the
geographic boundary and hydraulic connection between the Santa Teresa Basin and San Jose Plain
(Figure 2).
The geology in the vicinity of the facility consists of alluvium extending below the ground surface to
bedrock, a depth of more than 400 feet. "Hm alluvial formation generally contains more than five
silty clay layers which vary from a few feet to more than 30 feet in thickness separating more than
six aquifers. These aquifers are referred to as A. B, C. P. E. F, and G aquifers, with A being the
most shallow.
The general depths of these aquifers below ground surface are as follows: A occurs between 20 to 50
feet, B lies between SO and 95 feet, C is between 90 and 125 feet and D is between 140 and 160 feet,
E is between 170 and 205 feet, F is between 230 and 260 feet, and G is between 270 and 275 feet.
In some locations, these individual aquifers merge. Also, these aquifer depths are very general; a
major portion of the facility lies above the top of the A aquifer by only 15 to 25 feet
The Edenvale Gap appears to be primarily merged BC and D aquifers (Figure 3). The San Jose Plain
geology is similar to the Santa Teresa Basin, with the difference that aquifer zones are-less continuous
and thicker and the alluvium may be more than 750 feet thick to bedrock in some areas of the sub-
basin.
Santa Teresa Basin acts as a forebay area. As a forebay area, the sub-basin recharges water through
the Edenvale Gap into the San Jose Plain. Groundwater flop's northwesterly from the site towards
Edenvale Gap and downward from the shallow to deep aquifers. Continued pumping, for water
supply and ground water remediation, combined with less efficient induced recharge from ponds and
low rainfall, has contributed to overdraft conditions in the Santa Teresa Basin. The overdraft
condition has caused declines in groundwater levels. Lowered ground water levels in the B aquifer
have caused the B aquifer to change from a confined to a semi-confined aquifer in some areas.
Remedial Investigation
IBM has installed more than 300 monitoring and extraction wells to aid in plume
characterization, source control, and remediation. The plume of chemicab from the site
measures more than three miles in length extending northwesterly from the discharger's facility
past the intersection of Monterey Road and Capitol Expressway (Figure 4) and is more than 180
feet in depth. In the plume area known as the Defined Area (Figure 2), the plume is laterally
defined to 3 ppb. This area extends to near the intersection of Monterey Road and Capitol
Expressway north of which is an area referred to as the Undefined Area. In a few wells in the
Undefined Area TCA and Freon 113 have been detecte- in private and municipal wells at
levels up to 2.8 ppb Freon 113 and up to 3.3 ppb TCA. These results, antf f.he direction of
ground water flow in this area, suggest that the plume extt ids significantly beyond the Defined
Area. IBM is the only identified or known responsible party associated with the defined area of
the plume, which extends from the facility northerly to the Edenvale Gap. —-
The issue of whether or not further plume definition was necessary beyond the intersection of
Monterey Road and Capitol Expressway was brought to the Board in Order No. 84-90 on December
18, 1984. The Regional Board found in Order No. 84-90, Finding 11 and the State Board supported
this finding in Order WQ No.86-8. IH.a.. that the degradation in the Undefined Area would not
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DRAFT REMEDIAL ACTION PLAN FOR Page 3
INTERNATIONAL BUSINESS MACHINES, September 27. 1988
SAN JOSE FACILITY
unreasonably affect beneficial uses and no further remediation was consistent with the maximum
benefit to the people of the State; therefore, further plume definition was not required. However, the
Regional Board did find that if additional data, methods of data evaluation, geological information,
revised health guidance, or other issues which may impact the Regional Board's finding that beneficial
uses were not unreasonably affected were developed, then the Board may consider altering that
finding in the future.
IBM has identified several wells in the Defined Region which could be or have been potential
conduits. These potential conduits may have transmitted chemicals to deeper aquifers. These wells
have been properly destroyed, are scheduled for destruction, or cannot be located. Some wells cannot
be found because they ar» under buildings, oarkint lots or streets, or are buried with no evidence of
their location.
Migration Control and Source Removal
Activities tc prevent further solvent migration from the IBM source areas include removal of the
solvent sto: .^e tanks, excavation of soil containing pollutants and extraction of groundwater
containing pollutants. IBM has removed more than 23,000 cubic yards of soil from the source areas
on site. Starting in 1981 and continuing to 1985, the underground tanks were replaced with above
ground storage tanks on the site. By September 1980, most of the underground solvent tanks were
removed and replaced in above ground concrete vaults which allow for visual inspection to detect
leakage. The vaults are also coated to prevent leakage into surrounding soil. Additionally, the shallow
concrete trenches comprising the underground conveyance network have been substantially replaced
with coated trenches or tunnels.
.nterim remedial measures to cleanup the plume have included off site and onsite groundwater
extraction since November 1982. The discharger has installed and currently operates a three
tiered groundwater extraction well system composed of more than 13 extraction wells located
throughout the plume. Laterally, the plume is hydraulically controlled. Operation of the
extraction wells has minimized further plume migration, slightly reduced the size of the plume,
and reduced solvent concentrations within the plume. However, localized areas of higher
pollutant concentrations within the plume may contribute to further interaquifer transfer via
leaky aquitards and potential conduits.
Due to declining groondwater level effects oa interim remediation, the Regional Board allowed IBM
to reduce extraction as ordered in Regional Board Order No. 88-45 which amends Order No. 84-90.
Groundwater extraction was reduced by about 73% from 8,900 acre feet/year to 2,400 acre feet/year
and nine of the thirteen extraction wells were akat down to save about €,500 acre feet/year of
groundwater.
The extracted groundwater has been discharged under NPDES Permits in Order No. 83-37 and No.
83-39. primarily without treatment to storm drains leading to Canoas Creek which is
tributary to Guadalupe River and flows into the south San Francisco Bay. Recharge from Canoas
Creek may occur to a. slight degree. Pollutan.* are found at nondetectable levels, which are less than
1 ppb for each TCA and Freon 113, at the confluence of Guadalupe River and Canoas Creek.
Guadalupe River provides significant recharge TO groundwater aquifers along its length.
WaterSupolv Well Imnaets -«-
ourteen water supply wells are known to exist as active or potentially active wells down gradi-
ent within the defined plume area (Figure 5). Three active water supply wells are known to
exist within 300 feet of the defined area plume boundaries. Two public drinking water supply
wells (Great Oaks Wells No. 2 and 8) have been affected by the IBM plume and were found to
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DRAFT REMEDIAL ACTION PLAN FOR Page 4
INTERNATIONAL BUSINESS MACHINES. September 27. 1988
SAN JOSE FACILITY
contain volatile organic chemicals (VOC'S). The- VOC concentrations in the Great Oaks well
have been below current DHS drinking water action levels and federal drinking water standards.
In January 1983, Great Oaks Water Company decided to stop regular service from Well No. 2
and Well No. 8, which was a standby well, and had not been used as a drinking water source
since May 1983. Great Oaks Well No. 2 is now intermittently used as a standby well during
peaks in water demand. A third well. Great Oaks well No. 14. was also found to contain low
levels of VOC's, but Well No. 14 was an inactive irrigaticn well which had not been used for
drinking water supply and has subsequently been destroyed.
la the past five yean, only five private wells were found to contain more than an average of 11
ppb Freon or TCA. In one of the five wells. «he highest levels of VOCs (430 ppb Freon 113
and 140 ppb TCA in 1983), were all below th« Department of Healtu Services drinking water
action levels. Use of this well for drinking water was discontinued in May 1983. As a result ©f
clean-up measures undertaken by IBM; this well currently contains 20 ppb Freon 113 and 9.0
ppb TCA; nine drinking water wells monitored in the plume area have oondetected concentre^
tions at less than 0.5 ppb detection limits; four drinking water wells contain no more than 1.0
ppb of Freon and 0.4 ppb TCA. Eight water supply wells have been taken out of service and
destroyed since the investigation began.
The discharger has submitted a report containing a study oT the effects of diicfl-.^in . volatile
organic chemicals to Canoas Creek on grouadwaters which may be recharged by the creek.
Drinking water wells located about 2800 feet westerly of Canoas Creek were found to contain
groundwater with a maximum of 2.4 ppb TCA which does not affect beneficial use. The
connection, if any, between the IBM discharge and the occurrence of chemicals in these wells is
not known. San Jose Water Company plans to operate these wells on a standby, basis once Snell
pipeline water is available to She water company. No additional investigation of Canoas Creer
recharge is planned due to the very low concentrations of chemicals currently being discharges
into the creek by IBM and the insignificance of recharge in Canoas Creek.
Governmental Regulation of Investigation and Remediation
In October 1984. the United States Environmental Protection Agency (EPA) proposed that the IBM
site be placed on the federal Superfund list. Pursuant to the South Bay Multi-Site Cooperative
Agreement, as subsequently amended, catered into in May 2* 1985, by the Board, EPA and DHS, the
Board has been acting as the lead regulatory agency. DHS and EPA have reviewed and commented
on the comprehensive plan. During the almost four years that the IBM site was a proposed
CERCLA site, investigation and cleanup was regulated based on CERCLA requirements. Siaee
June 2J, J988, the IBM site has been proposed to become J JtCRA lite and be dropped from
cottsiderttion as a CERCLA site, la the event the IBM site becomes t RCRA site, the Regional
Board will continue to regulate the remediation and enforce under CERCLA as amended by
SARA.
The Board adopted Waste Discharge Requirements in Order No. 84-90 on December 18, 1984 for the
discharger's interim site remediation. The State Board adopted Order No. WQ 86-8 which clarified
the Regional Board Order and responded to appeals on Order No. 84-90. Order No. 84-90 was
amended on March 16. 1988 by Regional Board Order No. 88-45. The State Board adopted
Resolution No. 88-88 on July 21. 1988 in response to the issue of waste and unreasonable use of
groundwater from remediation activities. This Site Cleanup Requirement Order rescinds Order No.
84-90 and 88-45. This Order sets tasks and submittal dates for final site remedJatSoa.
On July 21. 1988. the State Board adopted Resolution No. 18-88 which required that IBM as
Fairchild remediation plans must result in beneficial use of, or treatment and recharge to tkfe
Santa Teresa Basin, of a significant amount of extracted groundwater. If ase of recharge of
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DRAFT REMEDIAL ACTION PLAN FOR Page 5
INTERNATIONAL BUSINESS MACHINES. September 27, 1988
SAN JOSE FACILITY
gnificant amounts is not proposed, IBM shall fully justify reasons for not using or recharging
the groundwater. The justification must also demonstrate why continued pumping is necessary
from the standpoints of public health, protection of potential and present beneficial uses,
maintaining high quality water, and providing the maximum benefit to the people of the State.
FLAN DEVELOPMENT
Development of the remedial action plan was based on federal and state regulations, policy and
guidance for remedial action plans and feasibility studies. The purpose of the plan was to provide a
conceptual framework for remedial design of additional remediation activities by IBM and to establish
remediation levels.
IBM submitted a comprehensive plan as required by Regional Board Order No. 84-90 and State Board
Order WQ No. 86-8. This comprehensive plan is also consistent with the Health and Safety Code
requirements for a final remedial action plan (RAP) and the National Contingency Plan (NCP)
requirements for a remedial investigation and feasibility study (RI/FS).
The comprehensive plan was reviewed by the staffs of the Regional Board, Department of Health
Services, and the United States Environmental Protection Agency (BPA).
.This comprehensive plan contains a proposed final remedial-action plan, proposed remediation
levels, a remediation alternatives evaluation, water conservation plan, contingency plans for
abort term sub-basin management and a public health evaluation. The objectives for the
selected draft remedial action plan are to 1) protect public health and the environment, 2) attain
Appropriate and relevant, and applicable regulations (ARARs), 3) be cost-effective, 4) utilize
Hermanent solutions and alternative treatment technologies to the maximum extent possible Tor
short term effectiveness, 5) implementable, 6) acceptable based on State regulations, policies,
and guidance, 7) reduce toxicity, mobility, or volume as a principal element of the draft
remedial action plan, and 8) addresses the concerns of the public.
Alternatives Evaluation .
As required by the Health and Safety Code Section 25356.1. CERCLA as amended by SARA, and
Regional Board guidance, the draft RAP was developed from an evaluation of six alternative plans.
Each plan would provide different levels of remediation at various costs.
The objectives of each alternative were:
I - No further remediation
2 - Protection of beneficial uses
3 - Aquifer protection
4 - Aquifer protection with a safety factor
5 - Restore to background quality
6 - Aquifer protection with safety factor assuming van Jon in groundwater levels.
The discharger has based its evaluation of remediation -Uernatives and remediation levels on the
Hazard Index concept. Since each chemical detected in the soil and groundwater has its own
toxicUy characteristics, the Hazard Index approach allows for dec;
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DRAFT REMEDIAL ACTION PLAN FOR Page 6
INTERNATIONAL BUSINESS MACHINES, September 27, 1988
SAN JOSE FACILITY
The NCHI is calculated as shown below using denominator values as listed in Table 3.
n
(actual concentration of each chemical in oob)
(each chemical's Table 3 concentration in ppb)
i- 1
For example:
ppb TCA ppb Frwn 113 ppb 1.1-DCE ppb TCI
........... + .................... « ............. * .......... * ,(( • BCMI
200 ppb TCA 1«;000 ppb froon 113 « m 1.1-OCf 52 ppb TC£
The CHI is similarly calculated as shown using denominator values as listed in Table 4.
n
factual concentration of each chemical in nob)
(each chemical's Table 4 concentration in ppb)
i- 1
A NCHI value greater than 1.0 indicates that health effects may occur due to long term exposure. A
CHI value greater than 1.0 indicates a possible additional one in a million cancer risk from drinking
two liters of water directly from the aquifer for .70 years. This risk is in addition to the every day
one in four risk of contracting cancer. Department of Health* Services (DHS) and the EPA have also
reviewed the discharger's proposed use of Hazard Indices and found that the indices appear to be
justified for drinking water based on available data. These values may increase or decrease l_jed sa
possible future changes in action levels or other'safe drinking water standards for these pollutants.
Alternatives one through five were based on stable basin groundwater conditions. Alternative 6 h
comprised of three contingency plans each of which would be implemented depending on changing
basin conditions.
Alt.
If tmbtr Actifrp fttfOMdiftiioo £»w•! Covt
I No further cleaaup |SM,000/yr
3 Operate M fraoBdwiter Acairr* driakiaf • •>•!• $1,760,000
extraction walk far
10;
93,630,000
extraction v*Uf for !•*•!• fai UM aquifer*, phis
•bout 10 yean.
Operate up to 66 (round Achtara on* fourth or . ~ ' $14,400,000
water extraction well*, MM th»a UM driakiac plut
traat aad r*ch«m vater Wr«I* ia UM $3 JUOjOOO/fT
fTouadvater ia *«oBd« far •quifen.
•bout 30 ymn.
K« fMdbU op^oe Total rvmor*] of
touad for thi* «*•. chemiralt from aoQ
•ad (rouadvkter.
Operate op to M Achtor* OM fourth or ""^,100^00 to
(roundvtter extraction MM of UM driakiac llS.TOO.OOO
v«lb, trmt, MUM mad water lrr*b la UM ptut
r*ch%r(« grouadwater for aquifer. f 1,700,000/fr
•bout 30 jr«»Tf. Coataias to
S eoBtiafvacr plaai to $3,300,000/yr
fwpoad to chaafiac
frouDdwater [
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INTERNATIONAL BUSINESS MACHINES. September 27, 1988
SAN JCSE FACILITY
The technical report "Draft Comprehensive Plan* dated June 1987, Draft Supplement Comprehensive
Plan' dated April 29, 1988. and revisions to the reports contain a more detailed description and
evaluation of these alternatives.
IBM initially proposed Alternative 4 until it was determined that changing groundwater basin
conditions were contributing to overdraft, as a result of reduced rainfall, increased water supply and
remediation groundwater extraction, and reduced artificial recharge. The overdraft conditions posed
technical difficulties, i.e., groundwater may not be consistently available, for continued and expanded
groundwater extraction and cleanup required by Alternative 4. Therefore, IBM proposed Alternative
6 after it was evaluated in the IBM report "Draft Supplement Comprehensive Plan* dated April 29,
1988, amended July 25. 1988.
Alternative 6, as described and proposed in the draft Supplement, does not completely meet staff
concerns. As a result, the plan described in this staff report is t modification of the Alternative 6
plan proposed by IBM. The differences between the two plans are described later in this report
PUBLIC INVOLVEMENT
There has been active public involvement throughout the whole process of devloping the remediation
plans. All Regional Board orders which called for, or modified,the cleanup plans have been adopted at
public hearings (Regional Board in December 1984 and March 1988; State Board in March and June
1986 and again in February and June 1988). In preparation for adoption of the final Remedial Action
Plans the Regional Board took the following actions to involve the public in determining aacceptable
alternatives and in the final decision-making:
a. Sent out three fact sheets to over 1300 persons each mailing. These persons
included adjacent neighbors within 300 feet of IBM, local government officials
both appointed and elected, the water utilities utilizing the groundwater, and
those interested individuals that responded to several newspaper advertisements
announcing the RI/FS process and decision-making.
b. The Board staff held a night-time public workshop in August in the vicinity @f
the IBM facilities.
c. The Board conducted a>public hearing in San Jose to receive testimony on the
RI/FS and Remedial Action Plan.
d. The tentative remediation plan was widely distributed twice — once in August
with over a 30 day comment period — and again in October (with responses to
comments from the first distribution). ~
e. The Administrative Record has been available to the public since the
announcement of the tentative remediation pl-n. The draft and amended
versions of the remediation plan have been available to the public in the Santa
Teresa Public Library in the vicinity of IBM since December 1986 as well as
available in other libraries since August. Additionally, the plans and files of the
Regional Board, to include the proposed and amended remediation plans, have
been open to the public at all times since the initial discovery anTooard action.
f. The Final Remedial Action Plan (RI/FS) will be adopted by the Board in a
public hearing where final comments on the Plan and Board staff response may
be offered by the interested public.
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DRAFT REMEDIAL ACTION PLAN FOR Ptge 8
INTERNATIONAL BUSINESS MACHINES. September 27. 1988
SAN JOSE FACILITY
RECOMMENDED PLAN
This draft remedial action plan (RAP) is meant to be a comprehensive plan which addresses all
aspects of soil and groundwater remediation, treatment, discharge, and reclamation. This describes
how the draft plan would be implemented as recommended by staff and how the draft plan meets the '
objectives for protection of public health and the environment, attaining appropriate, relevant, and
applicable regulations (ARARs), being cost effective, utilizing permanent solutions, and reducing
toxicity, mobility, and volume. '
Plan Description
The draft RAP is composed of three contingency plane
1) Remedial Action Plan, which is • contingency plan,.for stable basin conditions.
2) Contingency 1 for rising groundwater levels and improving basin conditions.
3) Contingency 2 for falling groundwater levels and declining basin conditions.
As discussed below, these contingency plans are similar with the exceptions that under increased
overdraft conditions DO additional extraction wells would be installed and full scale recharge may not
be implemented. This plan may need to be modified in the future based on manage ;nt of the basin
and on the inherent uncertainties of yearly rainfall amounts and based on the performance evaluation
to be conducted every five years after this order is adopted. Remediation levels for soil aad
groundwater may be attained within ten to twenty, years:
Remedial design and initial implementation of the draft RAP would be dependent upon results
studies to be conducted during the year following RAP approval. These studies would evaluate:
1- Irrigation, cooling tower use, and lake storage use seasonal patterns.
2 - Santa Teresa Basin conditions as a result of increased recharge pond efficiency and reduction
of groundwater withdrawals in the nib-basin. " . .
3 • Pilot study of in-sirv soil aeration and full scale project feasibility.
4 - Air stripper pilot plam and treatabflity of IBM polluted groundwater.
Implementation of the draft remedial action plan, as modified, would require:
Installation of additional groundwater extraction wells in the A aquifer. These wells would
help prevent further migration of high chemical concentration! from She A aquifer and «©
accelerate remediation of groundwater saturated areas of the A aquifer. Remediation levels in
the A aquifer would be to drinking water health criteria, standards, or action levels for each
chemical, as listed in Table 2. . . ~ - .
Completion of pilot studies for in-situ soil aeration to determine the feasibility of full scale
projects to remediate vnsatnrated soils in release areas on the IBM property. The goal for soil
remediation is 1 ppm of chemicals in the soil depending upon technical feasibility which will
be determinec during pilot studies for soil cleanup. Some of the chemicals in the soil *nay not
be removed as efficiently, or at all compared to other chemicals. Therefore, a remediation goal
r rather than a level is recc .mended. —w-
Installation of additional extraction wells in the B and possibly deeper aquifers. The purpo-
of the B wells would be to prevent further lateral and downward migration of pollutan
However, use of the B extraction wells may be limited due to the overdraft condition of the
sub-basin. As a modification of the IBM proposal, staff recommend the discharger prevent
migration of the 0.25 NCHI and 1.0 CHI plumes. Extraction from deep aquifer wells need not
occur unless water levels in the B aquifer are so low as to prevent migration control.
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INTERNATIONAL BUSINESS MACHINES, September 27, 1988
SAN JOSE FACILITY
Remediation levels in the B and deeper aquifers would be 0.25 NCHI and 1.0 CHI as well as
one fourth the noncarcinogen drinking water action level or health criteria for each chemical
and the one in one million risk concentration for each carcinogen, as listed in Table 2.
The recommended draft remedial action plan does not provide for remediation below
remediation levels of 0.25 NCHI. IBM provided a sensitivity analysis of the costs and
impacts of remediating down to 0.1 NCHI which showed increased costs of about 73%
more than the cost for remediation to 0.2S NCHI and would require extracting large
volumes of groundwater to remove small amounts of chemicals. The possibility exists
that the final remediation plan will be more efficient and rapid than expected. If that is
the case, additional cleanup may be appropriate for Regional Board consideration at a
later date to comply with the State Board policy to maintain tne high quality of waters
in the State of California.
Sequential shut down for off site extraction wells once remediation goals have been achieved
and maintained at each monitoring and extraction well. In accordance with State Board Order
No. 86-90 the Regional Board will base its decision on an evaluation of monitoring data
obtained after temporary shutdown of extraction wells prior to permanent abandonment of
extraction wells. Monitoring after final abandonmec rf the wells will determine the effects
on chemical migration due to natural groundwater flow.
Reclamation of the extracted groundwater by recharge into shallow aquifers and reuse by IBM.
This reclamation of groundwater is necessary to help aid the remediation of the shallow
aquifers. The amount of groundwater reused by IBM for irrigation, cooling tower makeup
flow, and fire water storage would be offset by a decrease in pumping of water supply wells
owned by IBM. Recharge of the groundwater after treatment would occur via injection wells.
The treated groundwater would be injected in the A and B aquifers npgradient of the IBM
plume to aid in groundwater remediation (Figure 6). Recharge pilot studies will be conducted
to determine the feasibility of and provide remedial design for a full scale recharge. A
. goal of optimized groundwater reuse and recharge is proposed to be 100% of the total
amount of groundwater extracted from both on and off site extraction wells. However,
IBM has stated that if water quality or quantity is not sufficient enough during Contin-
gency 2 (falling groundwater levels) basin conditions, reuse may prove infeasible.
. Treatment of the polluted groundwater by two types of treatment. One type of treatment
would be air stripping of groundwater from long and short term extraction in the A aquifer,
both on and off site, and from long term extraction in the B aquifer on site. Depending OB
the basin conditions, two air strippers may be constructed. One air stripper would be wsed
solely for the highly polluted groundwater from on site release areas. The quality of this
groundwater may be highly variable and treated effluent quality may not be consistent.
However, a level of 5 ppb for each chemical is proposed for discharges to the storm drain.
The other air stripper would only be used for the less polluted groundwater except when
overdraft conditions are present, then it would also treat groundwater from the release areas
unless the other air stripper has already been constructed. Treatmr ;t of less polluted
,, -; groundwater would provide groundwater containing 1 ppb total VOCs on the average and a
maximum of 5 ppb total VOCs. This is the treated groundwater which would be used for
recharge and reuse.
The second type of treatment is nozzle discharge of polluted groundwater into manholes. This
treatment consists of forcing the extracted groundwater flowing in a large diameter pipe
through a narrow diameter pipe in a manhole. Aeration of the polluted groundwater occurs
due to the increased turbulence produced by the nozzle and the distance that the treated
groundwater falls in the manhole to continue its journey down the storm drain. Nozzle
treatment has been found to remove up to 50% of VOC concentrations. Staff consider nozzle
treatment to be best available treatment which is economically achievable (BATEA) of the
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INTERNATIONAL BUSINESS MACHINES, September 27, 1988
SAN JOSE FACILITY
groundwater from the 8 tod deeper aquifers off lite, due to economic feasibility, protectk
of the environment, limited operation time, and siting constraints. Additionally, use of nozzle
allows for increased flexibility in implementation of the RAP. Groundwater extraction rates
will vary according to the number of extraction wells in operation. As basin conditions
permit, additional extraction wells may be installed along with nozzle treatment without the
considerable delay associated with construction of conventional treatment systems and
pipelines. Aiso, as remediation levels are met, extraction wells would be temporarily shut
down and discharge flow would decrease.
Untreated groundwater will be discharged to storm drains leading to Canoas Creek on an
interim basis. Until the treatment systems are in operation, long term discharges from
aquifer remediation will be untreated. Short term discharges re«ult from monitoring well
sample collection and aquifer testing. The, purge water from sample collection will be
untreated for B and deeper aquifer monitoring wells. This untreated water will be
discharged to the storm drain nearest to the monitoring well. Prior to treatment system
operation, the purge water from the A aquifer will be collected and either treated with
the existing small treatment system on site or diluted with cleaner groundwater prior to
discharge.
Maior Differences Between IBM Proposal and L ' ft RAP
The technical reports submitted by IBM contain its proposal for • draft RAP and feasibility study.
IBM's proposal is conceptually acceptable with some exceptions. The draft RAP, as explained above,
is a modification of the IBM proposal. There are major differences between the two plans, as
summarized below:
Staff recommend that IBM control vertical and lateral migration of the 0.25 NCHI and .
CHI plume boundaries during Contingency 2 conditions. IBM does aot propose vertieal
migration control of concentrations above remediation levels during any of the contingeeey
conditions.
Staff propose full scale recharge and reuse during Contingency 2 basin conditions. IBM
proposes only pilot scale recharge and reuse only if significant quantities of groundwater ere
being extracted. ......
Staff propose extraction and piezometer well cluster installation at the location of the
leading edge of the plume above remediation levels if necessary. IBM does not propose
installation of the B aquifer extraction wells nnless non-contingency 2 conditions exist.
Additionally, IBM proposes piezometer installation only if necessary. Staff find that
piezometer installation and monitoring of extraction well capture zones are always
necessary to confirm capture areas.
In order .to assure that significant concentrations of chemicals do not pass through the
Ldenvale Cap, which could impact down gradient drinking water wells and users, staff
proposes the following additional measures of compliance:
a. Concentration limits be added for chemicals in the groundwater in the Cap.
Thes limits are 30 ppb for Freon and TCA and 0.6 ppb for
b. The groundwater in the Cap be monitored with an tctive pumping well to L~'?
assure representative sampling of water passing through the Gap.
If remediation costs increase or decrease from the expected costs, the Board should consider
whether or not to raise or lower remediation levels. IBM proposes that remediation levels only
be raised if justified based on cost and technical feasibility.
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DRAFT REMEDIAL ACTION PLAN FOR Page 11
INTERNATIONAL BUSINESS MACHINES. September 27. 1988
SAN JOSE FACILITY
Ground water reuse goals have been raised from 50 to 100%.
Remedial Action Objective^
The draft RAP would provide remediation of the aquifer in order to meet the following
objectives:
Objective 1 - Protection of Public Health and the Environment
The draft RAP remedy is protective of human health and the environment by preventing further
vertical or horizontal migration of chemical concentrations above remediation levels in the shallow
aquifer and by treating the extracted groundwater prior to disposal. It also prevents migration of
chemicals above remediation levels into the deeper drinking water aquifer and Canoas Creek. By
stopping the migration of chemicals and treating the extracted groundwater, potential threats to She
environment posed by allowing chemicals to enter Canoas Creek, Guadalupe River, and the local
aquifers are reduced.
Objective 2 - Comply with Applicable or Relevant and Appropriate Regulations
The draft RAP will meet all substantive ARARs for the shallow and deep groundwater aquifers. The
numerical limits that apply to the shallow and deep aquifers are listed in Tables 1 and 2. •
One major ARAR is the State Board Resolution 68-16 "Statement of Policy with Respec* to
Maintaining High Quality of Waters in California*. This1 policy requires that any change in water
quality must be consistent with maximum public benefit and not unreasonably affect beneficial uses.
The proposed remediation levels, based on currently available information, are acceptable at this eite
given that the limited degradation would not exceed any established water quality policies, the water
quality is well below applicable health criteria, and degradation has already occurred and would
not unreasonably affect beneficial uses. -
If new information indicates remediation levels cannot be reasonably attained or can be reasonably
surpassed, the Board will decide if further final remediation actions beyond those completed to attais
remediation levels shall be implemented at this lite based, to a significant degree, on the information
developed from draft RAP implementation. If changes in health criteria, administrative requirement,
site conditions, or remediation efficiency occur, the discharger will submit an evaluation of Che
effects of these changes on remediation levels.
Objective 3 - Cost Effectiveness
This draft RAP is cost effective based on an evaluation of costs for the entire draft RAP, including
Croundwater and soil remediation, reclamation, and soil and groundwater treatment
Objective 4 - Utilizes Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable.
The draft RAP meets the SARA preference for permanent solutions to the maximum extent
practicable. It will remove the chemicals form the soil and groundwater and will eliminate the
threat to human health and the environment _,-
Objective 5 - Reduces Toxicity. Mobility, and Volume
The draft RAP focuses on treatment of the groundwater to specified remediation levels. This
treatment technology will reduce the toxicity of the chemicals by reducing their concentrations
aad rendering them harmless. Mobility is reduced by use of the groundwater extraction system.
preventing the further spread of the plumes. Also, by extracting and treating the shallow
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DRAFT REMEDIAL ACTION PLAN FOR Page 12
INTERNATIONAL BUSINESS MACHINES, September 27, 1988
SAN JOSE FACILITY
groundwater, it is expected that the volumes of the plumes will be reduced.
Objective 6 - Meets Public Acceptance
The modified draft RAP should meet public acceptance based upon the comments received and
changes made in the RAP as recommended for the October 19 Board meeting. The public has
has had access to and been involved in the decision-making process during the entire process.
While not all public comments could be accommodated in the recommended alternative, it is
believed that public acceptance will be met with the proposed plan.
IMPACTS RESULTING FKOM DRAFT RAP IMPLEMENTATION
Implementation of this draft RAP will impact the public and environment as described below.
One impact will be to residential roads and property. Pipes, nozzles, and possibly manholes will need
to be installed in localized areas near the extraction wells. Additional extraction and monitoring wells
would be installed on private property, once property owners grant access. This proposed off site
construction may interfere with traffic flow and residents in the area. This interference would last
for the construction time necessary for each treatment unit and pipe to be installed.
A second impact will be redistribution of chemicals from the gronndwater to the air, surface waters
of landfills. The proposed aeration treatment without activated carbon air scrubbers would transfer
dilute concentrations of chemicals from the groundwater to the air. If scrubbers are used (the
anticipated cleanup costs include use of scrubbers), then the spent carbon most likely would be
distributed to either landfills or to incinerators for chemical breakdown. Trace concentrations or
pollutants from Guadalupe River may recharge aquifers and may flow into the southern portion
the San Francisco Bay. Due to the large amount of time necessary for complete implementation
the proposed plan, discharge of pollutants will continue for the next 10 to 20 yean.
A third impact would be that low chemical concentrations will remain in the aquifer and affect water
supply wells (Figure 5A). Chemical concentrations in the downgradient water supply wells,
especially wells in the undefined area, may increase, although it is not expected. Even minimal
increases should not impact beneficial uses and will still be protective of human health.
A fourth impact may result due to aquifer injection of treated grousdwater. There is the potential
that wells previously unaffected by the IBM pollution would be affected by the injected groundwater
(Figure 6 ). The amount of water recharged may be limited to reduce this impact
RECOMMENDATION
1 - The draft RAP as described in this report should be found acceptable based on the Health and
Safety Code Section 25356.1.
2 - The draft RAP should be considered to meet Section 121 of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA) as an equivalent to a feasibility
study and found to be protective of human health and the environmer'^ attains Applicable or
Relevant and Appropriate Requirements (ARARs), is cost effective, utilizes permanent
solutions and alternative treatment technologies and resource recovery technologies to the
maximum extent possible, and reduces toxicity, mobility, and VoTume of pollutants and
addresses the concerns of the public.
Concur. _ V _ __ Concur
Wil Bruhns, Section Leader Steverf I. Morse, Division Chief
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FIGURE 1 - SITE LOCATION
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Art* Location*
FIGURE 2 - EDENVALE
AREA AM) DEFINED AREA LOCATIONS.
-------
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SAMTA OARA AMD COWTE VALLEYS
GEOLOGIC CROSSECT,ON FROM EDE^ALE CAP TO COYOTE
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FIGURE «l - IBM PLUME LOCAT
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FIC4JRE 5 - GREAT OAKS WATER COMPANY VCLL LOCATIONS
AND PRIVATE VCLL LOCATIONS IN DEFINED AREA
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O Ptwioutfy
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San Jose. California
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FIGURE 5A - SAN JOSE VJ^TER COfPANY
IN T>F VfOEFI^CD AP.FA
PRIVATE WELLS
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FIGIKE 6 - PROPOSED RECHARGE AREA IN RELATION TO GREAT OAKS HATER WELLS
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PART 3
SITE CLEANUP REQUIREMENTS ORDER
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CALIFORNIA REGIONAL'WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
ORDER NO. 88-157
SITE CLEANUP REQUIREMENTS FOR:
INTERNATIONAL BUSINESS MACHINES
SAN JOSE
SANTA CLARA COUNTY
The California Regional Water Quality Control Board, San Francisco Bay
Region (hereinafter called the Regional Board) finds that:
1. International Business Machines (IBM), hereinafter called the
discharger, operates and owns a facility that manufactures data
processing machines, including disk drives and ma-ss storage systems,
at 5600 Cottle Road in the City of San Jose, Santa Clara County
(Attachment 1). Construction of the facility began in 1955 on land
previously used for agricultural purposes. The facility has been in
operation since December 1956.
2. The Regional Board adopted Waste Discharge Requirements in Order No.
84-90 on December 18, 1984 for the discharger's interim site
remediation. The State Water Resources Control Board (hereinafter
State Board) adopted Order No. WQ 86-8 which clarified the Regional
Board Order and responded to appeals on Order No. 84-90. Order No.
84-90 was amended on March 16, 1988 by Regional Board Order No. 88-45.
This Site Cleanup Requirement Order rescinds Orders No. 84-90 and 88-
45. This Order sets tasks and submittal dates for final site
remediation to be consistent with the Health and* Safety Code and the
National Contingency Plan.
3. At the facility, organic chemicals are and have been handled and
stored in bottles, drums, above ground tanks, and under ground tanks.
The discharger uses organic chemicals such as 1,1,1-trichloroethane
(TCA), Freon 11, Freon 12, Freon 113, isopropyl alcohol (IPA), xylene,
acetone, petroleum naphthas and other organic chemicals during the
disk manufacturing process.
4. In October 1980, the discharger discovered TCA, petroleum naphtha and
xylenes in soil during excavation of underground tanks and after
confirming that a release of chemicals had occurred, reported the
release to Regional Board staff. In November 1981, additional
investigation revealed extensive ground water pollution^?and a
BMSCR10/21/88 -1-
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ORDER No. 88-157
'comprehensive, sice-wide investigation program was initiated as
requested by Regional Board staff. Other releases of chemicals from
the discharger were found, including a significant release of Freon
113. The discharger determined that the releases to soil and
groundwater were due to tank and pipeline fitting failures, tank and
sump overflows, spillage from drum handling, and other releases.
5. Groundwater investigation was conducted by the discharger in both the
Santa Teresa Basin, where the facility is located, and the San Jose
ri-ir., which 's located northerly and downgradient of the Santa Teresa
Basin (Attachment 2). Groundwater overdraft conditions are present in
the Santa Teresa Basin. Edenvale Gap, located between Oak Hill and
Edenvale Ridge is the geographic boundary and hydraulic connection
• between the Santa Teresa Basin and the San Jose Plain. The geology in
the vicinity of the facility consists of alluvium extending below the
ground surface to bedrock, a depth of more than 400 feet. The
groundwater flows northwesterly from the site towards Edenvale Gap.
The San Jose Plain geology consists of aquifer zones which are less
continuous and thicker than the Santa Teresa Basin. The San Jose
Plain alluvium may be more than 750 feet thick from the ground surface
to bedrock.
6. The plume of volatile chemical organic chemicals laterally extends
from the discharger's property to beyond Edenvale Gap. The area of
the plume, known as the defined area, is defined to 3 ppb each of TCA
and Freon 113 and extends from the discharger's property to near the
intersection of Monterey Roau and Capitol Expressway. Downgradient of
the defined area and northerly of Edenvale Gap is the area referred to
as the undefined area. No monitoring wells have been installed in the
undefined area. Geologic information for the undefined area was
obtained from well logs for water supply wells located in the
undefined area. . TCA and Freon 113 have been detected in private and
municipal wells located in the undefined area at levels up to 2.8 ppb
Freon 113 and up to 3.3 ppb TCA. These results, and the direction of
groundwater flow in this area, suggest that the plume extends
significantly beyond the defined area. Pursuant to the Health and
Safety Code Sections 25356.1 (d) and 25356.3 (c), the discharger is
the only identified or known responsible party associated with the
defined area of the plume, which extends from the facility northerly
to the Edenvale Gap.
7. The Regional Board found in Order No. 84-90, Finding 11 and the State
Board, supported this finding in Order WQ No. 86-8, III.a., that the
degradation in the undefi-.ed area would not unreasonably affect
beneficial uses and no further remediation was consistent with the
IBMSCR10/21/88 -2-
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ORDER No. 88-157
maximum benefit Co che people of the Scate; therefore, further plume
definition was not required based on available information.
8. Fourteen water supply wells are known to exist as active or
potentially active wells down gradient within the defined plume area.
Three active, wells are known to exist within 300 feet of the defined
area plume boundary of 1 ppb Freon 113. Some of these public and
private drinking water supply wells have been affected by che
discharger's plume and are found to contain volatile organic chemicals
(VOC's) below Departmenc of Health Services drinking water action
levels and Federal drinking water standards. In January 1983, one
water supplier stopped regular service from its water supply wells and
drinking water supply from some private wells was discontinued even
though the highest levels"of VOC's were below the Department of Health
Services (DHS) Drinking Water Action Levels. Currently, as a result
of clean-up measures undertaken by the discharger, nine drinking water
wells monitored in the plume area have nondetectable concentrations at
less than. 0.5 ppb detection limits pnd four drinking water wells
contain no more than 1.0 ppb of Freon and 0.4, ppb TCA. One well
contains 20 ppb Freon and 9.0 ppb TCA. The remaining water supply
wells are not accessible for monitoring by the discharger. None of
the defined area water supply wells which are currently monitored
contain more than 0.1 ppb 1.1-DCE. Eight water: supply wells have been
taken out of service and destroyed since the investigation began.
9. The discharger has installed more than 300 monitoring and extraction
wells to aid in plume characterization, source control, and cleanup.
At this time; the plume appears to be present in several aquifers and
-is adequately defined vertically. The plume measures more than three
miles in length extending northwesterly from the discharger's property
boundary past the intersection of Monterey Road and Capitol Expressway
(Attachment 2) and is more than 180 feet in depth. Laterally, the
plume is currently under significant hydraulic control. However,
chemicals continue to migrate from shallow aquifers to deep aquifers
which increases the concentrations of chemicals in the deeper
aquifers.
10. The discharger may be required to perform 'additional plume
characterization if monitoring results indicate that 'potential
conduits may have transmitted chemicals to deeper aquifers. The
discharger has identified several wells in the defined area which
could be . and have been potential commits. These wells have been
properly destroyed, are scheduled for destruction, or cannot be
located.
IBMSCR10/21/88 -3-
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ORDER No. 88-157
Plan (NCP) requirements for a remedial investigation and feasibility
study (RI/FS). This comprehensive plan contains a proposed final
remediation plan, proposed remediation levels, a remediation
alternatives evaluation, water conservation plan, contingency plans
for short term sub-basin management, and a public health evaluation.
The final remediation plan is conceptual and provides a basis for
remedial design.
16. Pursuant to the South Bay Multi-Site Cooperative Agreement and the
South Bay uround Water contamination amercement. Agreement, entered
into on May 2, 1985, (as subsequently amended), by the Regional Board,
EPA and DHS, the Regional Board has been acting as the lead regulatory
agency. DHS and EPA have reviewed and commented on the draft
comprehensive plan submitted by the discharger. The initial draft
comprehensive plan and its revisions have been available for public
review from December 1, 1986. During the time that the IBM site was a
proposed NPL site, investigation and cleanup was regulated based on
CERCLA and Health and Safety Code requirements. Since June 21, 1988,
the IBM site has been proposed to become a RCRA site and be dropped
from consideration' as a NPL site. The Regional Board will continue to
regulate the discharger's remediation and enforce under. CERCLA as
amended by SARA.
17. The discharger evaluated six alternative cleanup plans: 1) monitoring
only, 2) protection of beneficial uses at drinking water supply wells,
3) protection of beneficial uses within the aquifer, 4) aquifer
protection with a safety factor (assuming stable groundwater levels 5)
remediation to background levels, and 6) aquifer protection with
safety factor (contingency plans based on. variable groundwater
levels). Based on the alternatives evaluated, the discharger
recommended alternative 6, as a final remedial action plan. The
. objectives of the plan are: 1) protect public health and the
environment, 2) be technically feasible and 3) be cost-effective. The
discharger proposes to continue grouitduater remediation off site to
concentrations below health-based drinking water criteria. The
discharger's proposed plan, as modified by this Order, is adequate to
comply with the Specifications, Prohibitions, and Provisions of this
Order.
18. On July 21, 1988, the State Board adopted Resolution No. 88*88 which
required that IBM and Fairchild remediation plans must result in
beneficial use of, or recharge to the Santa Teresa Basin, of a
significant amount of extracted groundwater. If use or recharge of
significant amounts is not proposed for the per-'od after January 31,
1989, the discharger must fully justify reasons for not using or
_. recharging the groundwater. The justification must also -'^aonstrate
IBMSCR10/21/88 -5-
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ORDER No. 88-157
why continued pumping is necessary from Che standpoints of public
health, protection of potential and present beneficial uses,
maintaining high quality water, and providing the maximum benefit to
the people of the State.
19. The discharger has evaluated the feasibility of reusing the
groundwater resulting from the remediation activities. The discharger
proposes to reuse the groundwater on site for shallov aquifer
recharge, irrigation, and cooling tower witer makeup flow and will
optimize the reuse with a goal of reusing 100% of the total flow from
on and off site. If an opportunity for additional reuse occurs, the
discharger will evaluate that potential reuse based on the conditions
set forth under the California Water Code Section 13550. The
discharger proposes to treat off site groundwater by nozzles with no
additional use prior to discharge to storm drains leading to Canoas
Creek which flows into Guadalupe River to recharge shallow aquifers.
Groundwater extraction and reuse may need to be modified in the future
based on management of the basin and on the inherent uncertainties of
yearly rainfall amounts and based on the performance evaluation to be
conducted every five years after this order is adopted. Use of the
treated groundwater for irrigation and recharge via injection wells
shall be regulated pursuant to another Regional Board order. '.
The Regional Board intends to strongly encourage, and require to the
extent allowed by lav, the maximum reuse of extracted groundwater
feasible either by the discharger or other public or private water
users. Groundwater extracted from the Edenvale Gap should receive the
highest priority of all offsite extraction for reuse consideration. .
20. The discharger has based its evaluation of remediation alternatives
and remediation levels on the Hazard Index concept. Hazard Indices
have been calculated for both possible noncarcinogenic effects (NCHI)
and possible carcinogenic effects (CHI). A NCHI value less than 1.0
indicates that all of the 'chemicals of interest found in B and deeper
drinking water aquifers are present at concentrations equal to or
below their relevant drinking water criteria. A CHI value of 1.0
indicates a maximum possible one in a million cancer risk from
- drinking two liters of water directly from the aquifer for 70 years.
Department of Health Services (DHS) and the EPA have reviewed the
discharger's proposed use of Hazard Indices and found that the indices
appear to be justified for drinking water based on available data.
These values may increase or decrease based on possible future changes
in action levels or other safe drinking water standards for these
pollutants.
IBMSCR10/21/88 -6-
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ORDER No. 88-157
From a public health threat perspective, the primary exposure route
from the discharger's contamination is through ingestion of
contaminated water. Based upon 1986 data, the maximum cancer risk due
to potential consumption of untreated water from the A-aquifer zone is
approximately 8 x 10"^ which a CHI of 80.0. This calculation assumes
a worst case scenario in which a person weighing 70 kilograms drinks 2
liters of water daily directly from the A-aquifer zone in the IBM site
over a 70 year period. Similarly, the contamination associated with
non-carcinogen adverse health effects in the A-Aquifer zone on-site
significantly exceed relevant drinking water criteria, with a maximum
NCHI of 71.3. The A-aquifer zone does not currently supply drinking
water and IBM installed institutional controls to prevent future
exposure to A-aquifer zone water. Contamination on-site migrating
downward to the lower" drinking water aquifer warrants A-aquifer
remediation.
21. On October 28, 1968, the State Board adopted Resolution No. 68-16,
"Statement of Policy with Respect to Maintaining High Quality Water*
in California". .This policy calls for maintaining the existing high,
quality of State waters unless it is demonstrated that any change
would be consistent with the maximum public benefit and not
unreasonably affect beneficial uses. This is based on a Legislative
finding, contained in Section 13000, California Water Code, which
states in. part that it is State policy that; "waters of the State
shall be regulated to attain the highest water quality which is
reasonable". The original discharge of wastes to the groundwater at
this site was in violation of this policy, therefore, the groundwater
needs to be restored to its original high quality to the extent
reasonable. -Based on available information, as found in the
discharger's technical reports "Draft Comprehensive Plan" dated June
1987 and revised October 1987 and "Draft Comprehensive Plan
Supplement" dated April 1988 and revised July 1988, the change in
water quality does not unreasonably affect beneficial uses and is
consistent with the maximum public benefit as defined in State Board
Resolution No. 68-16. This limited degradation would not exceed any
established water quality policies; the remediation water quality
levels proposed are well below current applicable health criteria; and
the levels, do restore the quality of the groundwater to the extent
reasonable given technical and economic constraints. These
constraints include the high additional incremental costs for removal
of small amounts of additional pollutants and the need to minimize the
removal of groundwater to achieve acceptable cleanup levels.
22. The remediation level for the B and deeper aquifers is 0.25 NCHI and
1.0 CHI as well as one fourth the noncarcinogen drinking water action
=. level or health criteria for each non-carcinogen and the^ne in one
IBMSCR10/21/88 -7-
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ORDER No. 88-157
million risk concentration for each carcinogen. The level for the
transmissive areas of the A aquifer is the drinking water action level
or health criteria for each chemical. These remediation levels are at
or be-low drinking water health criteria, action levels, and standards
and will assure preservation of beneficial uses by maximizing the
quality of groundwater to the maximum extent feasible. The soil
remediation goal is 1 ppm for each pollutant; a goal is set due to the
technical uncertainties associated with remediation of soil by means
other than excavation which is no longer feasible due to prohibitive
cost. These remediation levels may be attained witiii.n t-en uo twenty
years. This goal vill be re-evaluated based on chemical leachability
test results for the so.il and evaluation of pilot and full scale
remediation efforts.
23. Based on historic water quality data for monitoring wells upgradient
of and near Edenvale Gap, chemical concentrations are not expected to
significantly increase in water supply wells in the undefined area.
Remediation levels would be similar to concentrations (approximately
'30 ppb each TCA. and Freon), which flowed through Edenvale Gap and into
the undefined area prior to plume interception during interim
remediation. Concentrations in the Edenvale Gap wells will not'be
allowed to increase above 30 ppb each for TCA and Freon or 0.6 ppb
1,1-DCE.
In order to assure effective verification monitoring of groundwater
leaving the defined area through the Edenvale Gap, a continuously
pumping well needs to be monitored. This well must be screened in at
.least the B and C aquifers. The well must be located, and pumped at
sufficient volume, to. assure a capture zone representative of the
groundwater passing through the Edenvale Gap.
24. If new information indicates remediation levels cannot be reasonably
attained or can be reasonably surpassed, the Regional Board will
decide if further final remediation actions beyond those completed
shall be implemented at this site, based to a significant degree on
the information developed pursuant to this Order. In accordance with
the State Board Order No. 86-90 requirements, the Regional Board will
base its decision on an evaluation of .monitoring data obtained after
temporary shutdown of extraction wells prior to permanent abandonment
of extraction wells. If changes in health criteria, administrative
requirements, site conditions, or remediation efficiency occur, the
discharger will submit an evaluation of the effects of these changes
on remediation levels specified in Specification B.3, 4 and 6 and on
Table 1 and 2 of this Order.
IBMSCR10/21/88 -8-
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ORDER No. 88-157
The Regional Board recognizes chat the discharger has already
performed extensive investigative and remedial work onsite and
offsite; and that the discharger is being ordered hereby to perform
substantial additional remedial tasks. It is in the public interest
to have the discharger undertake such remedial actions promptly and
without prolonged litigation or the expenditure of public funds. The
Board recognizes that an important element in encouraging the
discharger to invest substantial resources in undertaking such
remedial actions is to provide the discharger with reasonable
assurances that the rtcedirl ^ctic^.s cillad for in this Order will be
the final remedial actions required to be undertaken by the
discharger. On the other hand, the Board also recognizes -its
responsibility to protect water quality, public health, and the
environment and that future developments could indicate that some
additional remedial actions may be necessary. The Board has
considered and balanced these important considerations, and has
determined that the remedial actions ordered herein represent the
Board's best, current judgment of the remedial actions to be required
of the discharger. The Board will not require the discharger to
undertake additional remedial actions with respect to the matters
previously described herein unless: (1) conditions on the site,
previously unknown to the Board, are discovered after the adoption of
this Order, or (2) new information is received by the Board, in whole
or in part after the date of this Order, and these previously unknown
conditions or this new information indicates that the remedial actions
required in this Order may not be protective of public health and the
environment. The Board will also consider technical practicality,
cost effectiveness, State Board Resolution No. 68-16 and the other
factors .evaluated by the. Board in issuing this Order in determining
whether such additional remedial actions are appropriate and
necessary.
25. In accordance with the Health and Safety Code Section 25356.1, Section
121 of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) this final remedial action plan is
equivalent to a feasibility study, satisfies the requirements of the
California Water Code Section 13304 and is protective of human health
and the environment, attains Applicable or Relevant and Appropriate
Requirements (ARARs), utilizes permanent solutions and alternative
treatment technologies and resource recovery technologies to the
maximum extent possible for short term effectiveness, is
implementable, is cost effective, is acceptable based on State
regulations, policies, and guidance, and reduces toxicity, mobility,
and volume of pollutants, and addresses public concerns.
IBMSCR10/21/88 -9-
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ORDER No. 88-157
26. The Board adopted a revised Water Quality Control Plan for the San
Francisco Bay Basin (Basin Plan) on December 16, 1986. The Basin Plan
contains water quality objectives and beneficial uses for South San
Francisco Bay and contiguous surface and groundwaters.
27. Development of this final remediation action plan was based on the
Regional Board's evaluation of seven years of water and soil quality
data. Random samples have been collected and analyzed by the Regional
Board to confirm the validity of data generated by the discharger.
However, the data has not yet been validated using EPA validation
guidance. The quality of this data has been taken into consideration
and has been used in a manner consistent with the data's quality.
. »*"
28. The existing and potential beneficial uses of the groundwater underlying
and adjacent to the facility include:
a. Industrial process water supply
b. Industrial service water supply
c. Municipal and domestic water supply
d. Agricultural water supply
29. The discharger has caused or permitted, and threatens to cause, or
permit, waste to be discharged or deposited where it is or probably
will be discharged-to waters of the State and creates or threatens to
create a condition of pollution or nuisance. Onsite and offsite final
containment and remediation measures need to be implemented to
alleviate the threat to the environment posed by the plume of
pollutants. . .
30. This action is an order to enforce the laws and regulations
administered by the Board. This action is categorically exempt from
the provisions of the CEQA pursuant to Section 15321 of the Resources
Agency Guidelines.
31. The Board has notified the discharger and interested agencies and
persons of its intent under California Water Code Section 13304 to
prescribe Site Cleanup Requirements for the discharge and has provided
them with the opportunity for a public hearing and an opportunity to
submit their written views and recommendations.
32. The Board, in a public meeting, heard and considered all comments
pertaining to the discharge.
IBMSCR10/21/88 -10-
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ORDER No. 88-157
IT IS HEREBY ORDERED, pursuant to Section 13304 of the California Water
Code, chat the discharger shall cleanup and abate Che effects described in
the above findings as follows:
A PROHIBITIONS . •
1. The discharge of wastes or hazardous materials in a manner which
will degrade water quality or adversely affect the beneficial
uses of the waters of the State is prohibited.
2. Further significant migration of chemicals above remediation
levels, as described in Findings 22 and 23, through subsurface
transport to waters of the State is prohibited.
3. Activities associated with the subsurface investigation and
cleanup which will cause significant adverse migration of
chemicals are prohibited.
B. SPECIFICATIONS .
1. The storage, handling, treatment or disposal of soil or
groundwater containing chemicals shall not create a nuisance as
defined in Section 13050(m) of the California Water Code.
2. The discharger shall conduct monitoring activities as needed to
define the current local hydrogeologic conditions, and the
lateral and vertical extent of soil and groundwaier containing
chemicals. Should monitoring results show evidence of plume
migration above remediation levels as described in Findings 22
and 23, additional plume characterization may be required.
3. Final remediation levels for chemical concentrations in any B or
deeper aquifer well containing chemicals from the discharger's
facility, shall be- equal to or less than its Table 1
concentration and equal to or less than a NCHI of 0.25 and a CHI
of 1.0.
The NCHI is calculated as shown using denominator values as
listed in Table 3.
n
(actual concentration of each chemical in ppb)
(each chemical's Table 3 concentration in ppb)
IBMSCR10/21/88 -11-
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ORDER No. 88-157
The CHI is calculated as shown using denominator values as listed
in Table 4.
n
(actual concentration of each chemical in ppb)
(each chemical's Table 4 concentration in ppb)
Chemica1 concentrations shall no*" *° ^oun'1 *"> equal or exceed
Table 1 concentrations based on the moving annual average .of
analytical results as determined at the end of each quarter.
If the moving annual average in any quarter increases by 50%
relative percent difference (RPD) from the previous quarter,
which will be considered a baseline quarter, then the discharger
shall inform the Regional Board of such an increase. After the
first quarter following the baseline quarter, the second
quarterly average is still 50% RPD above the baseline quarter and
the concentrations are above final remediation levels, then a
threatened violation is present and the discharger shall inform
the Board of the. causes of this threatened violation. If. the
third quarterly average is an increase of 50% RPD from the
baseline quartet and concentrations are above final remediation
levels then the discharger shall be considered to be in violation
of this order and shall inform the Board of how and when the
discharger will regain compliance.
If quarterly average concentrations increase above 30 ppb each of
Freon-113 and TCA or 0.6 ppb 1,1-DCE, in wells ORBC^2, ORBC-3,
35-BC, 36-BCD, 37-BC, 40-BC, 38-BC, 39-BC, and 44-BC, the
discharger shall inform the Regional Board of how and when the
discharger will regain compliance.
4. Final remediation levels for each chemical concentration in the
transmissive areas of the A aquifer shall be equal to or less
than each chemical concentration as listed in Table 2.
5. The discharger shall-optimize, with a goal of 100%, its use of
the groundwater extracted from its groundwater cleanup activities
to aid the cleanup and reduce the effect of water level declines.
6. The discharger shall remediate soil to a goal of 1 ppm for each
chemical. This goal, may be modified by the Regional Board if the
discharger demonstrates with site specific data that higher
levels of chemicals in the soil will not threaten the quality of
vaters of the State. ~*"~
IBMSCR10/21/88 -12-
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ORDER No. 88-157
7. .Compliance poincs shall be established at all monitoring wells
which at any given time are outside the 0.25 NCHI and 1.0 CHI
plume boundary.
. 8. The discharger shall maintain extraction wells ORBC-2 and ORBC-3
in operable condition until the remediation levels are attained
throughout the entire plume area.
y. Ine discharger shall implement the final Remedial Action Plan
described in Finding 17, as modified by this Order.
10. Interpretation of all the above specifications shall recognize
the inherent constraints placed on the discharger's ability to
control groundwater levels, and potential migration of chemicals
of concern due to pumping by other groundwater users and the
apparent hydrologic imbalance in the Santa Teresa Groundwater
Basin. However, the discharger shall c'omply with this Order to
maximum extent feasible.
C., PROVISIONS
1. The discharger shall submit to the Board acceptable monitoring
program reports containing results of work performed according to
a program prescribed by the Board's Executive Officer.
2. The discharger shall comply with this Order immediately upon
adoption with the exception that the discharger shall comply with
Prohibitions A.I., A.2., and A.3. and Specifications B.I., B.2..
B.3., B.A, B.5., B.6., B.7., B.8. and B.9. above, in accordance
with the following tasks and compliance time schedules:
a. COMPLETION DATE: December 15. 1988
TASK 1 - EDENVALE GAP WELL MONITORING
Submit a technical report acceptable Co the Executive
Officer demonstrating effective monitoring of groundwater
passing through the Edenvale Gap. This report shall at a
minimum specify for an existing or proposed well, the well's
location, screened interval, pumping rate, anticipated
capture zone and proposed monitoring schedule. If a new
well(s) is proposed, an installation and monitoring time
schedule shall be included. The Executive Officer shall
amend the Self-Monitoring Program attached to this Order to
indicate when monitoring shall- begin and its frequency.
IBMSCR10/21/88 -13-
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ORDER No. 88-157
b. COMPLETION DATE: December 15, -1988
TASK 2 - GROUNDtfATER USE PLANS
Submit a technical report acceptable to the Executive
Officer which contains a description of the groundwater use
plans associated with the final remediation plan. The
report shall include documentation of efforts to secure
users for the water, reasons why potential users would not
accept the water, and justification for why the pumped water
cannot be used for beneficial uses or returned to the Basin.
The technical report shall demonstrate how groundwater
extracted from the Edenvale Gap will be reused, including
specific uses and time schedules for implementation.
c. COMPLETION DATE: July 17, 1989
TASK 3 - IN SITU VAPOR EXTRACTION PILOT STUDY EFFECTIVENESS
AND FULL SCALE PROPOSAL
Submit a technical report acceptable to the Executive
Officer which contains an evaluation of the effectiveness of
in situ.vapor extraction pilot studies conducted in source
areas on site. This evaluation shall address the
feasibility of achieving the soil remediation goals as set
forth in Specification 6 of this Order.
d. COMPLETION DATE: -July 17. 1989
TASK 4 - "A" AQUIFER EXTRACTION WELL PILOT STUDY RESULTS AND
PROPOSED BOUNDARY AND OFFSITE LOCATIONS
Submit a technical report acceptable to the Executive
Officer which contains a description and results of the A
aquifer extraction well pilot study and a remedial design
proposal for full scale A aquifer extraction well locations.
The report shall contain an evaluation of capture zone
confirmation for each extraction veil and a proposal for
installation of extraction, piezometric, and monitoring
wells. This report shall also include a Sample Plan which
proposes well location, construction, development and
monitoring schedule.
e. COMPLETION DATE: August 21, 1989
TASK 5 - ON SITE GROUNDWATER UTILIZATION
Submi, a technical report acceptable to the Executive
Officer which contains an evaluation of the irrigation,
IBMSCR10/21/88 -14-
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ORDER No. 88-157
b. COMPLETION DATE: December 15. 1988
TASK 2 - GROUNDtfATER USE PLANS
Submit a technical report acceptable to the Executive
Officer which contains a description of the groundwater use
plans associated with the final remediation plan. The
report shall include documentation of efforts to secure
users- for the water, reasons why potential users would not
accept the water, and justification for why the pumped water
cannot be used for beneficial uses or returned to the Basin.
The technical report shall demonstrate how groundwater
extracted from the Edenvale Gap will be reused, including
specific uses and time schedules for implementation.
c. COMPLETION DATE: July 17, 1989
TASK 3 - IN SITU VAPOR EXTRACTION PILOT STUDY EFFECTIVENESS
AND FULL SCALE PROPOSAL
Submit a technical report acceptable to the Executive
Officer which contains an evaluation of the effectiveness of
. in situ vapor extraction pilot studies conducted in source
areas on site. This evaluation shall address the
feasibility of achieving the soil remediation goals as se.t
forth in Specification 6 of this Order.
d. COMPLETION DATE: July 17, 1989
TASK 4 • "A" AQUIFER EXTRACTION WELL PILOT STUDY RESULTS AND
PROPOSED BOUNDARY AND OFFSITE LOCATIONS
Submit a technical report acceptable to the Executive
Officer which contains a description and results of the A
aquifer extraction well pilot study and a remedial design
proposal for full scale A aquifer extraction well locations.
The report shall contain an evaluation of capture zone
confirmation for each extraction veil and a proposal for
installation of extraction, piezometric, and monitoring
wells. This report shall also include a Sample Plan which
proposes well location, construction, development and
monitoring schedule.
e. COMPLETION DATE: August 21, 1989
TASK 5 - ON SITE GROUNDWATER UTILIZATION
Submi. a technical report acceptable to the Executive
Officer which contains an evaluation of the irrigation,
IBMSCR10/21/88 -14-
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ORDER No. 88-157
cooling cower, and lake water use paccerns and proposed use
of extracted groundvater, including a projected range of
volume, location, application, and seasonal rate of
groundwater usage. . •
f. COMPLETION DATE:' August 21. 1989 .
TASK 6 - CRITERIA ^OR DECISION ANALYSIS OF FINAL PLAN
IMPLEMENTATION AND CONTINGENCY PROPOSAL
Submit a technical report, acceptable to Che executive
Officer which contains criteria used to determine which
plan, either the Remedial Action Plan (RAP), Contingency 2,
or Contingency 1, shall be initially implemented as
described in' the discharger's "Draft Supplement
Comprehensive Plan". .These criteria shall be based on
saturated thickness, rate of decline or rate of recovery of
groundwater levels basin hydrologic balance within a range
of storage or overdraft values, and the trend in stability
of water levels at or near the site.
;. COMPLETION DATE: April 20, 1990
TASK 7 - "A" AQUIFER BOUNDARY'AND OFF SITE EXTRACTION WELL
INSTALLATION ,
Submit a technical report acceptable to the Executive
Officer which contains a description of construction and
implementation of the A aquifer boundary and off site wells.
h. COMPLETION DATE: February 19, 1992
TASK 8 - FINAL PLAN CONSTRUCTION COMPLETION
Submit a technical report acceptable to the Executive
Officer which describes the construction and implementation
of the final remedial action plan.
i. COMPLETION DATE: October 19, 1993
TASK 9 - FIVE YEAR STATUS REPORT AND EFFECTIVENESS
EVALUATION
Submit a technical report acceptable to the Executive
Officer contair '.ng the results of any additional
investigation; an evaluation of the effectiveness of
installed final •remedial measures and remediation costs;
additional recommended measures necessary to achieve final
cleanup objectives; a compf'ison of previous expgr^ed costs
IBMSCR10/21/88 -15-
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ORDER No. 88-157
with Che costs incurred and projected costs necessary to
achieve remediation levels and goals; and the tasks and time
schedule necessary to implement any additional final
remedial measures. The evaluation shall include, but need
not be limited to, an estimation of the flow capture zone of
the extraction, wells, establishment of the cones of
depression by field measurements, and presentation of
chemical monitoring data. This report shall also describe
the use of extracted groumJwater and evaluate and document
Cut- rt.uuvix cu.d/ui cleanup of polluted soils, if such
removal and/or cleanup is an element of the remedial
measures. In addition to regular groundwater monitoring
data, on site soil samples shall also be collected,
analyzed, and--leachability tests performed to determine the
effectiveness of groundwater and soil air extraction on
saturated and unsaturated soil located on the site.
j. COMPLETION DATE: Two months after request by Executive
Officer
TASK 10- "8" AND DEEPER AQUIFER EXTRACTION WELL INSTALLATION
PROPOSAL
Submit a technical report acceptable to the Executive
Officer which contains proposed extraction well locations in
order to comply with Prohibition A.I., A.2., and A.3. and
Specifications B.3.
k. COMPLETION DATE: one month after the end of each study
TASK 11 - ADDITIONAL PILOT STUDIES
Submit a technical report acceptable to the Executive
Officer which contains a description of pilot study results,
an effectiveness evaluation of the pilot study, a
description of the methodology and basis of the pilot study
approach and all other supporting information, in addition
to field notes and laboratory originated data summary
.sheets.
1. COMPLETION DATE: two months after request made by the
Executive Officer
TASK 12 - EVALUATION OF NEV HEALTH CRITERIA
Submit a technical report acceptable to the Executive
Officer which contains an evaluation of how the final plan
and cleanup levels would be affected, if the concentrations,
as listed in Specification B.3., Tables 3 and fc^^pd used to
IBMSCR10/21/88 -16-
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ORDER No. 88-157
calculate Hazard Index numbers, change as a result of
changes in source document conclusions or promulgation of
drinking water standards or action levels.
m. COMPLETION DATE: four months prior to proposed
" implementation of extraction curtailment
TASK 13 - WELL ABANDONMENT CRITERIA AND PROPOSAL
Submit a technical report acceptable to the Executive
crriv-ei which contains a proposal for abandoning groundwater
extraction wells and the criteria used to justify well
abandonment. The proposal shall include temporary
curtailment of extraction well operation for an extended
period of time co study the effects on pollutant migration
prior to well abandonment. This report should identify the
method, specific monitoring wells, and the basis for the
time frame to be used to determine that final cleanup levels
have been reached and that the potenti?! for increases above
remediation- levels in concentrations is minimal. This
report shall include supporting data for and an evaluation
of water quality in areas believed to be remediated.
n. COMPLETION DATE: 30 days after Regional Board approves
curtailment.
TASK 14 - CURTAILMENT IMPLEMENTATION
Submit a technical report acceptable to the Executive
Officer documenting completion of the necessary tasks
identified in the technical report submitted for Task 13.
o. COMPLETION DATE: 60 days after concentration increase is
confirmed as provided in Specification 3.
TASK 15 - CONCENTRATION INCREASE EVALUATION AND RESPONSE
PROPOSAL
Submit a technical report acceptable to the Executive
Officer which contains an evaluation of the occurrence of
concentration increases in extraction and monitoring wells
as described in Specification B.3. In the event of
noncompliance based on Specification" B.3., the technical
report shall contain an evaluation of the costs, benefits,
and drawbacks of modifying active hydraulic cleanup and
containment measures in comparison with a continued
monitoring alternative. This technical report shall also
include a proposal for a response tr meet this Order's
requirements.
IBMSCR10/21/88 -17-
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ORDER No. 88-157
p. COMPLETION DATE: 30 days after the Board determines whether
additional active measures are appropriate.
TASK 16 - RESPONSE IMPLEMENTATION
Suboit a technical report acceptable to the Executive
Officer which documents the implementation of the proposal
in Task 15 which will be implemented should pollutant
concentrations increase in extraction and monitoring wells
as provided in Specifications B."J -r>d B.7.
q. COMPLETION DATE: one month after release confirmation
notification.
TASK 17 - PROPOSAL FOR REMEDIATION OF NEW RELEASES
Submit a technical report acceptable to the- Executive
Officer which contains a proposal for remediation of new
releases ohsite, and an implementation time schedule. This
report shall evaluate the removal and/or cleanup of soil
containing chemicals; evaluate alternative hydraulic control
systems to contain and to remediate groundwater containing
chemicals; shall be consistent with the final remediation
plan and with the National Contingency Plan.
r. COMPLETION DATE: two months after request by Executive
Officer.
TASK 18 - EVALUATION OF NEW TECHNICAL INFORMATION
Submit a technical report acceptable to the Executive
Officer which contains an evaluation of new technical and
economic information which indicate that remediation levels
in some plume areas may be considered for revision. Such
technical reports shall not be required unless the Executive
Officer or Board determines that such new information
indicates a reasonable possibility that the Order nay need
to be changed under the criteria described in Finding 24.
The submittal of technical reports evaluating additional final
remedial measures will include a projection of the cost,
effectiveness, benefits, and impact on public health, welfare,
and environment of each alternative measure. If any additional
remedial investigations or feasibility studies are found to be
necessary, they shall be consistent with the guidance provided by
Subpart F of the National Oil and Hazardous Substances Pollution
Contingency Plan (40 CFR Part 300), Section 25356.1 vc) of the
California Health and Safety Code, CERCLA guidance docunents, the
State Board's Resolution No. 68-16, and this Order. "*"•""
IBMSCR10/21/88 -18-
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ORDER No. 88-157
A. If^_the__dis.charger is delay_ed:,__ interrupted or prevented from
complying with this Order or meeting one or more of the time
schedules in this Order, the discharger shall promptly notify the
Executive Officer. In. the event of such delays or noncompliance,
the Regional Board will consider modification of the time
schedules established in this Order.
5. Monthly technical status letter reports on compliance with the
Prohibitions, Specifications, and Provisions of tnis Order shall
be submitted by the fifteenth of each month to the Regioaal Board
commencing December 15, 1988 and covering the previous month.
On a monthly basis thereafter, or as required by the Executive
Officer, these reports shall consist of a report that, (1)
summarizes work completed since submittal of the previous report,
and work projected to be completed by the time of the next
report, (2) identifies any obstacles of which the discharger is
aware that may threaten compliance with the schedule of thi"
Order and what actions "are being taken' to overcome these
obstacles, and (3) includes, in the event of non-compliance with
any Specification or Provision of this Order, written
notification which clarifies the reasons for non-compliance and
which proposes specific measures and a schedule to achieve
compliance. This written notification shall identify work not
completed that was projected for completion, and shall identify
the impact of non-compliance on achieving compliance with' the
remaining requirements of this Order.
6. On a quarterly basis, or as required by the Executive Officer,
monitoring reports shall include, but need not be Halted to,
updated water table and piezometric surface maps for all affected
water bearing zones, and appropriately scaled and detailed base
maps showing the location of all monitoring wells and extraction
wells, and identifying"adjacent facilities and structures. The
self-monitoring plan for this Order may be changed, as needed, by
the Executive Officer. Cross-sectional geological maps
describing the hydrogeological setting of the site shall be
provided in the first'quarterly status report for each calendar
year that this Order is in effect. If five or more new soil
borings or wells are completed during any quarter, updated cross-
sectional geological maps shall be provided in the quarterly
report for that quarter.
7. All hydrogeological plans, specifications, reports, and documents
shall be signed by or stamped with the seal of a registered
geologist, engineering geologist or professional engine**?
IBMSCR10/21/88 -19-
-------
TABLE 3
CONCENTRATIONS USED AS DENOMINATORS TO CALCULATE HAZARD INDICES
NONCARCINOGENIC EFFECTS
Chemical
Chloroform
r'.ithyl ;r.; :,w.:3P'.i2 (MC)
l,l-D1chioroethane (1.1-DCA)
1,1,1-TM chl oroe thane
(1,1,1-TCA)
l.l-D1chloroethylene (1.1-DCE)
1,2-01chloroethylene (1,2-DCE)
Trlchloroethylene (TCE)
Perchloroethylene (PCS)
Freon 11 »
Freon 12
Freon 113
Toluene
Xylene
N-Kethyl-2-P^rroHdone
Isopropanol
Acetone
Ethyl An\yl Ketone
Shell Sol 140
Concentration
fpobl
90
420
20
200
6
16
52
136
3,400
750
18,000
100
440
700
450
700
123
1,000
Source of Estimate
201 Of EPA RfD*
20% Of EPA RfD „
OHS Action Level2
DHS Action Level
DHS Action Level
DHS Action Level
20% Of EPA DWEL*
20% Of EPA DWEL
DHS Action Level
20% of EPA RfD
DHS Action Level
OHS Action Level
EPA Lifetime Health
Advisory4
DHS Site Criteria5
DHS Site Criteria
20% of EPA RfD
DHS Site Criteria
DHS Site Criteria
^Environmental Protect loo Agencjr. J987&. SfD denotes reference
dose. •>, •
'Department of .Health Services. 1987a.
^Environmental Protection Agency. 1985c.
^Environmental Protection Agency. 19855.
Department of Health Services. 1987b.
-------
TABLE 2 '
TARGET REMEDIATION GOALS FOR THE A-AQUIFER ZONE
Chemical
Methylene Chloride
Chloroform
1,1-Dlchloroethane
1,1,1-Trlchloroethane
1,1-01chloroethylene
l,2-D1ch1oroethylene
Trlchloroethylene
Perchloroethylene
Freon 11
Freon 12
Freon 113
N-Methyl-2-PyrrolIdone
Isopropanol
Acetone
Ethyl Anyl Ketone
Shell Sol 140
Xylene
Toluene
Benzene
Concentration
feob)
40
6.0
20
200
6
16
5
4
3,400
750
18,000
700
450
700
123
1.000
440
100
0.7
Source of Goal
OHS Action Level1
OHS Applied Action Level
DHS Action Level
DHS Action Level
OHS Action Level
OHS Action Level
OHS Action Level
OHS Action Level
DHS Action Level
2W of EPA RfO3
OHS Action Level
DHS Site Criteria4
OHS Site Criteria
20% of EPA RfO
DHS Site Criteria
DHS Site Criteria
EPA Lifetime Health
Advisory5
DHS Action Level
OHS Action Level .
•[California Department of Health Services 1987a.
JCallfornla Department of Health Services 1986c.
'Environmental Protection Agency 19B7&. RfD denotes Reference Oose.
^California Department of Health Services lS87b.
^Environmental Protection Agency 1985b.
-------
TABLE J_.
TARGET REMEDIATION GOALS FOR THE B- AND DEEPER AQUIFER ZONES
Chemical
Freon 113
1,1,1-Trlchloroethane
1,1-Dlchloroethylene
I,l-D1ch1oroethane
Freon 11
Trlchloroethylene
Chloroform
Methylene Chloride
Concentration
fpptO
4500
50
1.5
5
850
3.1
6.0
4.8
Source of Goal
0.25 x OKS Action Level
0.25 » IN* Action level
0.25 x OHS Action Level
0.25 x DHS Action Level
0.25 x DHS Action Level
10-6 Rifk Level2
10-6 R1sk Levei
10-* Risk Level
^Department of Health Services 1987a.
^Environmental Protection Agency 1987a,
-------
ORDER No. 88-157
8. All samples shall be analyzed by laboratories certified to
perfore analysis on Hazardous Materials or laboratories using
approved EPA methods or an equivalent method acceptable to the
Executive Officer. The discharger shall request laboratories to
follow EPA guidance "Documentation Requirements for Data
Validation of Non-CLP Laboratory Data for Organic and Inorganic
Analyses' dated May 1988 for preparation of data validation
packages when required by the Executive Officer. All
laboratories shall maintain quality assurance/quality control
records for Board review.
9. The discharger shall maintain in good working order, and operate,
as efficiently as possible, any facility or control system
installed to achieve compliance with the requirements of this
Order.
10. Copies of all correspondence, reports, and documents pertaining
to compliance with the Prohibitions, Specifications, and
Provisions of this Order, shall be provided to the following
agencies:
a. Santa Clara Valley Vater District
b. Santa Clara County Health Department
c. City of San Jose
„. r. d. State Department of Health Services/TSCD
e. State Vater Resources Control Board
f. U. S. Environmental Protection Agency, Region IX
Additional copies of correspondence, reports and documents
pertaining to annual reporting of compliance with the
Prohibitions, Specifications, and Provisions of this Order shall
be provided for public use when requested by the Executive
Officer.
i
11. The discharger shall permit the Board or its authorized
- representative, in accordance with Section 13267(c) of the
California Vater Code:
a. Entry upon premises in which any pollution sources exist, or
•ay potentially exist, or in which any required records are
kept, which are relevant to this Order.
b. Access to copy any records required to be kept under the
terms and conditions of this Order.
- -. c. Inspection of any monitoring, equipment or wchodology
IBMSCR10/21/88 -20-
-------
ORDER No. 88-157
implemented in response to this Order.
d. Sampling of any groundwater or soil which is accessible, or
may become accessible, as part of any investigation or
remedial action program undertaken by the discharger.
12. The discharger shall file a report on any changes in site
occupancy and ownership associated with the facility described in
this Order.
13. If any hazardous substance is discharged in or on any waters of
the state, or discharged and deposited where it is, or probably
will be discharged in or on any waters of the state, the
discharger shall .Lwne'diately report such discharge to this
Regional Board, at (415) 464-1255 on weekdays during office hours
from 8 a.m. to 5 p.m., and to the Office of Emergency Services at
(800) 852-7550 during non-office hours. A written report shall
be be filed with the Regional within five* (5) working days and
shall contain information relative to: the nature of waste or
pollutant, quantity involved, duration of incident, cause of
spill, Spill Prevention and Containment Plan (SPCC) in effect, if
any, estimated size of affected area, nature of effects,
corrective measures that have been taken or planned, and a
schedule of these activities, and persons notified.
14. The Board will review this Order periodically and may revise the
requirements when necessary under the criteria in Finding 24.
15. Regional Board Order Nos. 84-90 and 88-45 are hereby rescinded.
. ' i
I, Steven R. Ritchie, Executive Officer, do hereby certify that the
foregoing is a full, true and correct copy of an Order adopted by the
California Regional Water Quality Control Board, Sar^Francisco Bay Region,
on October 19, 1988.
Attachments:
Steven R. Ritchie
Executive Officer
TABLE 1 • Target Remediation Goals for the B- and Deeper Aquifer Zones
TABLE 2 - Target Remediation Goals for the A-Aquifer Zone
TABLE 3 • Concentrations Used as Denominators to Calculate
Hazard Indices Noncarcinogenic Effects
TABLE 4 - Concentrations Used as Denominators to Calculate
Hazard Indices Possible Carcinogenic Effects
SITE MAP .—-
IBMSCR10/21/88
-21-
-------
TABLE **
CONCENTRATIONS USED AS DENOMINATORS TO CALCULATE HAZARD INDICES
POSSIBLE CARCINOGENIC EFFECTS
Chemical •
Methylene
chloride
Chloroform
Trlchloroethylene
..«»•
Perchloroethylene2
OR1
(DDbl
.4.6
6.0
3.1
0.67
I
•'• '/•••
1 -V '
h
' vv*DR /Is the concentration of a chemical 1n drinking water that 1s
ipjredlcted to Increase cancer risk by one,case out of. one million,
1'-'•"••' Dnsum1ngr2 liters of water per^day for 70-years, U.S.
Risk Information System, April,'»1987. These numbers
oh unit risk factors calculated by the^EPA Carcinogen •.
,'yy; Assessment Group. They are theoretical upper bound r1fk»*ji , \
included
*l/^ !
»<*•- •» J
u.....
-------
ytn t«40i
to™ 4«F-fcy ion
SITE M«VP
-------
PART 4
RESPONSIVENESS SUMMARY
8
-------
APPENDIX C
RESPONSIVENESS SUMMARY
-------
.11 Of
AMD
AGCNCV
Gto*Gt
EPARTMENT OF HEALTH SERVICES
3X1' 'BSTANCES CONTROL DIVISION
S1 L -LEY WAY. ANNEX 7
RKE..../.CA 94704
August 17, 1988
Steve Richie
Regional Hater Quality Control Board
1111 Jackson Street, Rm 6040
Oakland, CA 94607
Dear Mr. Richie:
Tentative Orders for site clean-tip and BTDES Permit for
Tpf-oi-ryi t j on* 1 Business Macnines (IBM) • San Jose, Santa Clara
County. File Mo.£ 2189.8031 (BAA). MPDES Permit Mo.: CA OO27961.
On reviev of the above referenced tentative Orders, NPDES permit,
and documentation received in support thereof, the California
Department of Health Services, Toxic Substances Control Division
finds the Orders and NPDES permit, substantially meets the
applicable requirements of the California Health and Safety Code.
Therefore, the Department hereby supports the tentative Orders
and NPDES permit becoming final.
Sincerely,
Bovard K. Batayama
Chief, Site Mitigation Unit
Region II
Toxic Substances Control Division
HH:DLC:sj
-------
8/15/88
HAZARD IIDKI
Why is the Hazard Index used as a measure in determining
fundamental water quality? The answer is because it glTes
os an immediate view as to how safe the water is to drink.
Since it is defined as the ratio of concentration of
chemicals existing in the water to the concentration which
has been determined to be safe, it becomes a. very useful
tool in setting state policy.
It is useful to divide health effects of the chemicals which
are found in water into at least two categories:
noncarcinogenic effects and possible carcinogenic effects.
The corresponding hazard indices may be referred to as the
hazard index for noncarcinogenic effects (MCHI) and the
index for possible carcinogenic effects (CHI).
The NCR! la calculated as the sum of ratios of measured
water quality to relevant.drinking water criteria:
HCHI - C^/SL, + Cj/8^ *-"+cn/SL^
where C is the concentration of chemical actually found in
the water, and SL is the safe level' of that chemical based
on DBS action levels or other appropriate health based
criteria for noncarcinogenic effects. Thus, if an MCHI is
leas than 1, the individual chemical concentrations are
lower (better) than their respective drinking water
criteria.
is CHI is calculated as the mom of the ratioa of concen-
trations which exist in the water to the concentration which
theoretically could cause-a one-in-a-million incremental
cancer risk if two liters of the water were (for e.g.)
consumed every day for 70 years:
CHI - C //SL, * C/SL +...+C /SV,
I f «k «t *V •»
where C is as defined above but SL has the meaning in this
equation of being the level which would create the one in a
million incremental lifetime risk. For many riak
calculations this is considered a deminimnm risk and is
therefore appropriate to be considered as the safe level.
-------
'.ioral Bus>n«ss Machines Corporation
<<»OB>-256-4467
September 9, 1988
5600 Con leRoad
San JOM. California 95193
HAND
I V E R" E D
Steven Ritchie, Executive Officer
Regional Water Quality Control Board,
San Francisco Bay Region
1111 Jackson Street, Room 6000
Oakland, CA 94607
5EP 10
QUALITY COKmOL BOARD
Subject: IBM Comments on RWQCB Tentative Orders
Dear fir. Ritchie!
Attached please find IBM's comments to your tentative orders
for both the Site Cleanup Requirements and NPDES Waste
Discharge Requirements for your review and consideration.
Many of these have already been discussed with you or your
staff. - .
I look forward to working with you and your staff to
incorporate these comments into your orders.
Very truly yours,
H. Ray Kerby
Director, Environmental Programs
270-122
Attachment
cc: w/attachment
Belinda Allen - RWQCB (3 copies)
-------
9 September 1988
CONNECTS ON RWQCB TENTATIVE ORDERS
I. SITE CLEANUP REQUIREMENTS TENTATIVE ORDER
REOPENER PROVISIONS
The proposed Order contains several provisions that relate to the
possibility of future changes 1n the remedial action plan which IBM
would be ordered to carry out. A ninter of these provisions refer to
possible changes In the basic remedial goals established In the Order
(Findings 18 and 21); several relate to possible »od1f1cations of the
groundwater extraction tnd reuse program (Findings 17 and 21); others
refer to additional site investigations, changes 1n the monitoring
program, or reports to be submitted by IBM on possible changed remedial
plans (Findings 9, Specification 2, and Provisions 2.r, 2.v and 6); and
one relates to a five-year status report tnd effectiveness evaluation
(Provision 2.q). In addition to these specific Items, Provision 14 1s
a general section, saying that *tht Board will nvicw this order
• • _
periodically tnd ny rtvlse the requirements when necessary."
IBM recognizes that the Board has responsibilities to protect
beneficial uses of water and the public health and that a cleanup order
should Include reasonable reopener provisions so that the BoanT, and
IBM, can respond appropriately to new developments. However, IBM
ISG148B 1 880015
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9 September 1968
believes 1t 1s also Important for the Board to recognize that IBM, and
other companies which will be presented with proposed final cleanup and
abatement orders, need reasonable certainty regarding Order
requirements as they commit to the substantial efforts and expenditures
that will be Involved 1n large remedial programs.
IBM has already performed extensive Investigative and remedial work
onslte and offslte. The proposed Order would direct IBM to perform
•any additional remedial tasks. It Is 1n the public Interest to have
private parties, such as IBM, undertake these actions promptly tnd
without prolonged litigation or the expenditures of public funds.
Therefore, 1n situations such as this, where the site has been
extensively studied tnd we are dealing with t final cleanup Order
rather than an Interim step, we believe tn Important element in
encouraging companies to undertake the remedial actions 1s to provide
them with reasonable assurances that the actions called for 1n the
Order will be the final remedial actions required of the company.
Admittedly. It Is difficult to balance this need for. certainty with the
need for some "reopeners" to permit adjustments reflecting future
developments. In the federal Superfund process, this balance Is
usually achieved through a 'Consent Decree,* a contractual document
that 1s approved by the Court and which contains a ^precise definition
of the remedial actions and a specific rtopener clause. IBM has
submitted to the Staff a proposed form of Consent Order that could be
ISG14BB 2 B80015
-------
9 Sept enter 1988
used in lieu of the unilateral. Section 13304 Order format. We believe
that the Consent Order approach 1s the best way to address the reopener
Issue and several other Issues which are presented by the proposed
unilateral SCR Order. We urge the Board to consider using a Consent
Order format; however, we understand that the Staff's present Intent 1s
to utilize a unilateral Order.
In this light, we suggest that the Order should contain a specific
Finding that discusses the policy Issues Addressed 1n this cotiment and
establishes the context 1n which future changes to the Order will be
evaluated.
We suggest the following new Finding:
•The Board recognizes that IBM has already performed extensive
Investigative and remedial work ensUe and off site; and that IBM Is
being ordered hereby to perform substantial additional remedial
tasks. It 1s in the public Interest to have private parties
undertake such remedial actions promptly and without prolonged
litigation or the expenditure of public funds. The Board
recognizes that an Important element In encouraging private
parties, such as IBM, to Invest substantial resources In
undertaking such remedial actions 1s to provide them with
reasonable assurances that the remedial actions called for"Tn
orders such as this will be the final remedial actions required to
880015
-------
9 September 1988
*
•
be undertaken by the Company. On the other hand, the Board also
recognizes Us responsibility to. protect water quality, public
health, and the environment and that future developments could
Indicate that some additional remedial actions may be advisable.
The Board HAS considered and balanced these Important
considerations, and has determined that the remedial actions
ordered herein represent the Board's best, current judgment of the
final remedial action to be required of IBM and that the Board will
not require IBM to undertake tny additional remedial actions 1n
respect to the natters described herein unless conditions on the
site, previously unknown to the Board, are discovered after the
date of this Order or Information Is received by the Board, 1n •
whole or in part after the date of this Order, and these previously
unknown conditions or this Information Indicates that the remedial
actions required 1n this Order are not protective of public health
and the environment, and unless, after considering technical
practicality, cost effectiveness, State Board Resolution 68-16 and
the other factors evaluated by the Board 1n Issuing this Order, the
Board detemints that such additional medial actions art
appropriate and necessary. The advisability of any other change to
this Order, whether requested by IBM or the Board Staff or whether
they arise from the five-year review described In Provision 2.q or
otherwise, shall also be evaluated on the basis of these factors.*
I5R148B 4 WOOLS
-------
9 September 1988
This language reflects the basic policy Issues Involved In developing
an approach to "reopeners" and generally tracks the type of rtopener
language now recomnended by EPA under CERCIA. Additionally, the
language Includes references to several specific factors because they
are not expressly included 1n Section 13304, although we believe they
are Implicit 1n the overall structure and Intent of the Water Code and
the Board's role as lead agency for the IBM project.
Because the re opener issue would be dealt with 1n the recomnended
Finding, we suggest the following additional related changes to the
Proposed Order:
1. Revise the first sentence of the second paragraph 1n Finding 9 to
read as follows:
•The discharger trny be required to perform additional plume
characterization 1f «on1tor1ng results Indicate that potential
conduits aay have transmuted chemicals to deeper aquifers and If
the Executive Officer or the Board determines that such results
Indicate • reasonable possibility that the Order nay need to be
changed under the criteria described In Finding - (the
•Reopener" Finding).*
*2. Delete the last sentence of Finding 17. -*•":
IS614BP, 5 880015
-------
9 September 1988
3. Delete the last sentence of Finding 18.
4. Delete Finding 21. (Note that the report requirements described
1n the last sentence of this Finding are dealt with in
Provisions 2«r and 2.v below.)
5. Add the following sentence to the end of Provisions 2.r and 2.v:
•Such technical reports shall not be required unless the Executive
Officer or the Board determine* that such new Information indicates
a reasonable possibility that the Order ny need to be changed
under the criteria described In Finding _ (the "Reopener1
Finding).-
6. Delete Provision 6.
7. Revise Provision 14 to read as follows:
• • •
•The Board will rtvlev this Order periodically and «ay revise the
requirements when and If necessary under the criteria described 1n
Finding • (the -Reopener" Finding).*
• • .
The Staff Report also contains several statements regarding possible
changes in the Order. See pages 8, 9, 10, and 12. If our suggested
changes 1n the Order are made, the record should reflect that these
XSG148B
-------
9 September 1988
*
•
Garments 1n the Staff Report are superseded by the text of the Order
Itself.
JURISDICTIONS. MATTERS
to be conn It ted to cooperation with the Regional Board.
These comments are being submitted 1n the same spirit. However, and
^:- - fflt»^ee recort^-lBMtnotes that 1t has not conceded that the Board has
iucn lie* tntf&nfccgurtadtcttonal power to Issue the proposed Order under Water
.:- -, £ede, Sect ton 13304. IBM believes that Section 13304 (f) provides a
i _;. traslv *cr -challenging the proposed Order. Additionally,
Section 13304 (a) authorizes in Order 1f the waste discharge 'creates,
or threatens to create, a condition of pollution or nuisance." IBM
does not concede that 1U activities have created a present condition
or threat of pollution or nuisance, as those terms art defined In the
Water Code. Nonetheless, IBM 1s hopeful that 1t can continue to work
with the Board 1i a cooperative, aonadversarlal Banner to address
;:: < ca M -gpoand*ater copdltlOTS 1n the Yldalty of tl* IBM plant.
IS614BB ^001S 7 B80015
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9 September 1988
OTHER ITEMS
Finding 3; Onslte Chemical Usage
Freon 11 arid 12 are not solvents. The tern "organic solvents" 1n the
second sentence should be replaced with "organic chemicals."
Finding 4
The second, third, and fourth sentences 1n Finding 4 contain
conclusory language with which IBM cannot agree. IBM suggests that
these sentences be revised to read as follows:
•In November 1981, additional Investigation revealed that these
chemicals were found In nearby groundwater and a comprehensive,
site-wide Investigation program was Initiated as requested by the
Regional Board Staff. Other sources of potential releases of
chemicals were found at tht IBM site, Including a possible source
of Free/) 113. Aeon* tfce possible sources of releases, the
discharger Identified certain tank and pipeline failures and tank
and sump overflows."
*
Additionally, and as a general comment, IBM objects to the use of terms
such as "pollution- and "pollutant" In the proposed Order tndfKe Staff
Report to the extent that these phrases carry my Implication that
IS6148B 8 880015
-------
9 September 1988
there 1s, or has been, any significant risk to public health or the
environment.
Finding 6
The third sentence ef Finding 6 suggests that the chemicals which may
have been released from the IBM site are present 1n the area beyond
Eden vale Gap. This 1s the so-called "Undefined Area1. As IBM has .:
previously stated. It does not believe such t conclusion 1s warranted.
Although concentrations §f certain of the chemicals nay be found In the
Undefined Area, It has not been established that these ire from
releases at the IBM site. Numerous other potential sources exist.
Accordingly, IBM requests the deletion of this sentence.
In respect to the last sentence of Finding 6, IBM acknowledges that no
other responsible party has yet been associated with the ehenlc&ls
found 1n the area extending to the Edenvale Gap; but the Company
reserves Its right to Identify and take appropriate action In respect
to any party that tecoaes Identified is • source of nch chalctls.
Finding 8: Effects on water Supply Wells
. <*
The second sentence should be revUed as follows:
•Some public and private drinking water supply wells have been
affected
ISG148B 9 160015
-------
9 Septenfcer 1988
•
*
The third sentence should be revised to read:
"...regular service from its water supply wells and drinking water
supply from some private wells was discontinued, even though..."
The last sentence should be replaced by the following sentence:
•One public drinking water supply well has been token out of jf
service and one has been destroyed since the Investigation began."
Finding lit Effects of Declining firoundwater Levels
The following paragraph should be added to Finding 11 to clarify the
fact that IBM 1s not solely responsible for groundwater changes In the
Santa Teresa basin:
•Notwithstanding these reductions In the discharger's extraction
rates, groundwater levels have continued to decline. Pimping and ' "
recharge activities wltMn the Santa Teresa firoundwater tasln by
others affects vertical and lateral hydraulic gradients and nay
Impact plume «1g ration control at the IBM site and off site.
Furthermore, the overall Imbalance In the hydrologic budget for the
Santa Teresa Groundwater Basin 1s beyond the sole control of IBM."
ISG148B 10 680015
-------
9 September 1988
Find*re 14; Lead Regulatory Agency and Applicable Laws
The last sentence should be replaced with the following wording:
•Even though, since 21 June 1988, the IBM site has been proposed to
be dropped from consideration ts a CERCLA site, the Regional Board
will continue to regulate the remediation under CERCLA as amended
by SARA."
IBM continues to believe that a clear confirmation of DHS and EPA
concurrence with this Order and remediation plan ts necessary. This
needs to be the subject of further discussions between IBM and the
Involved agencies.
•• . ' . '• •
Finding 15; Alternative Plans Evaluated
We note that six alternative plans were evaluated, not five, and that
Alternative € was rtconmendedr not Alternative 5.
Finding 16; Croundwater Extraction and Reuse
The second sentence should be revised ts follows to wore accurately
reflect State Water Resources Control Board Resolution No. 88-88:
ISG148B 11 88001S
-------
9 September 1988
•If use or recharge of significant amounts 1s not proposed for the
period after January 31. 1989. the discharger shall fully Justify
j»i;\*t
reasons for not using or recharging the groundvater.*
Finding 18; Hazard Indices
The statement 'A NCHI value greater than 1.0 Indicates that health
tffects may occur due to long tern exposure" 1s.Inaccurate. In fact,
no human health tffects would b« expected at concentrations hundreds of
times higher than those resulting In a NCHI of 1.0. A more accurate
statement should read that an NCHI of 1.0 Indicates that t,i of the
chemicals of Interest found 1n the drinking water aquifers offslte are
present at concentrations equal to or below (better than) their
relevant drinking water criteria.
Finding 19 -
To clarify and complete the findings regarding State Board
-Resolution €8-16. wt suggest that the last sentence of Finding 19 read
as follows: -
•The proposed remediation levels, based on currently available
Information, are acceptable at this site given that the United
degradation which would be present at these proposed remediation
levels would not exceed any established water quality policies;
ISG148B 1?
-------
9 September 1988
that the resultant water quality would be well below (I.e., better
than) applicable health criteria; that some limited degradation has
alread^ occurred and cannot practicably be totally reversed; and
that the proposed remedial levels would not unreasonably affect
beneficial uses and are consistent with naxlmum public benefit.
The proposed remediation levels are also consistent with the policy
guidelines 1n Water Code Sections 13241 tnd 13000."
Finding 20; Remediation Coals for the A-Aoulfer Zone
This finding should Indicate that the remediation goals In Table 2
apply only to the transmlsstve areas of the A-aqu1fer zone. This 1s
consistent with the goals proposed In the draft Comprehensive Plan and
the draft Comprehensive Plan Supplement tnd recognizes the practical
limitations of extraction from Iow-transm1ss1ve areas. Specific
criteria for defining these areas will be Included In relevant
technical reports.
The second sentence «f Finding 20 should be svdlfitd to read as
follows: ••• •
•The lever for the transmlsslve areas of the A-aqulfer ....•
1*61488 13 880015
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9 September 1988
Finding 20; Remediation Goals for Son (Also see Corrment on
Provision 2. Task 7)
The soil remediation goal should be 100 times the applicable DHS
drinking water action level (DUAL) or equivalent (see Table 2 of
tentative order) rather than 1 ppm for tach chemical of concern. The
1 ppm (1 ing/Kg) goal appears arbitrary and not scientifically based on
risk assessment and chemical-specific fate tnd nobility character-
1st1cs. For example, the 1 ppm goal appears to be Inconsistent with
other State and RWQCB guidelines for fuel leak cleanups. Furthermore,
the soil remediation goal should be applied only 1n areas where there
1s a reasonable potential for exposure that nay afftct public health or
the environment.
The risk assessment-based approach Is discussed In Appendix 6 of the
draft Comprehensive Plan, which has been favorably reviewed by the
agencies. That discussion demonstrated that, at a level of 100 tines
the DUAL, axposura through Inhalation of wapors from subsurface
chemical concentrations and potential Migration to groundwater vert not
expected to be significant; I.e., the soil remediation goal as proposed
by IBM Is consistent with other remediation goals for the site. This
approach was previously reconnended to the RWQCB (Kennedy/Jenks/Ch 11 ton
letter of 22 July 1988 forwarded to RWQCB by IBM letter dated 25 July
1988). . ~~~
ISG148B 14 880015
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9 September 1988
The third sentence of Finding 20 should be revised to read as follows:
•These remediation levels are at or below drinking water health
criteria,....•
The fourth sentence of Finding 20 should be codified to read as
follows:
•The toll remediation goal 1$ *~pt<* 100 times the DHS drinking
water action level (DWAL1 or equivalent (see Table 21 for tach
pollutant 1n areas where there 1s reasonable potential for exposure
that may affect public health or the environment; a goal 1s set..."
Flndino 22 . .
This Finding Is Intended to state that the Board has Bade the findings
necessary to confine that the renewal action plan Is consistent not
only with the provisions of the Water Code but alto with applicable
provisions of the Health and Safety Code (relating to remedial action
plans) and with CERCLA's cleanup standards. Me suggest these
clarifications to the Finding:
•
•In considering the final remedial action plan, the Board has
considered not only the requirements of the California Utter Code
(Including Section 13304) but also the requirements under the
ISG148B 15 880015
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9 September 1988
California Health and Safety Code relating to remedial action plans
and the provisions of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) relating to cleanup
standards and compliance with the National Contingency Plan (NCP).
The reports that have been submitted by IBM and reviewed by Staff
and the Board are equivalent to the type of feasibility studies
which are called for by Health and Safety Code Section 25356.1 and
the NCP. After consideration of the factors and criteria that are
relevant to actions under Water Code Section 13304, Health and
Safety Code Section 25356.1 and Section 121 of CERCLA. the Board
has determined that this final remedial action plan Is protective
of human health and the environment, attains applicable, relevant
and appropriate requirements (ARARs), utilizes permanent solutions
and alternative treatment technologies and resource recovery
technologies to the maximum extent possible for short-term and
long-term effectiveness, reduces toxlclty, mobility and volume of
pollutants. Is Implementable. 1s cost effective, and 1s acceptable
based on the applicable state and federal regulations, policies and • •
9u1danet.B
Finding 25
IBM does not agree with the Implication that a condition of "pollution1
or "nuisance1 has been created or threatened. Likewise, IBM does not
concede that there 1s any significant threat to the environment posed
IS6148B 16 680015
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9 September 1988
by current conditions or that any further containment or remediation
measures are necessary to alleviate any threat to public health or the
environment.
Finding 26
In respect to compliance with CEQA or any other federal, state or local
permitting rules which night otherwise be considered applicable to
actions under the Order. IBM notes that Section 121(e) of CERCLA
appears to provide a specific exemption from such requirements.
Prohibitions
All three of the proposed Prohibitions contain terns such as "degrade,"
•adversely affect* and 'significant nlgratlon of pollutants above
remediation levels.* Standing alone, these phrases art too ambiguous
and vague to be Included In an enforceable Order, the violation of
which could expose IBM to substantial penalties. In light of the wany
specific provisions and tendItlens 1* ttot Order, «e suggest taat the
three Prohibitions are unnecessary and should be deleted. As a
minimum, the Prohibitions should be clarified to Indicate that the
actions which would be taken by IBM under the Order and the achievement
of the objectives of the Order would not constitute a violation of
Prohibition I. Also, the Order should be clarified to confto-that a
•migration of pollutants* which does not constitute a 'violation* under
IS6148B 17 880015
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9 September 1988
Specification 3 would not be considered a "significant migration of
pollutants above remediation levels" as defined 1n Prohibitions 2
and 3.
Specification 3: Remediation Goals for B- and Deeper Aoulfer lones
fsee also comment on Section C.I of Groundvater Self-Monitoring
Program)
The last sentence on page 7 In Specification 3 1s not a complete
sentence and should be clarified. Furthermore, calculating hazard
Indices for • calendar quarter Is Inconsistent with the health-based
« •
hazard Index approach. All hazard Indices calculated for th* drift
Comprehensive Plan nave been based on annual avenges and a minimum of
4 samples. This Is consistent with the health-based objectives
expressed 1n the draft Comprehensive Plan that evaluated potential
chronic health effects assuming long-term (I.e., lifetime) exposure to
low levels of chemicals In drinking water. This approach 1s consistent
with EPA's requirements for Monitoring VOCs 1n drinking water supplies *
on the basis of a running annual average of quarterly samples.
Therefore, chemical concentrations to be used In hazard Index
calculations or with respect to Table 1 should be running annual
averages calculated quarterly.
Incorrect table references are shown in the denominators 1n the —
equations for computing the Hazard Indices. For the NCHI calculation.
XSG148B 18 680015
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9 September 1988
the reference 1n the denominator should be to Table 3 and not Table 2.
For the equation computing CHI, the reference should be to Table 4
Instead of Table 3.
Specification 4; Remediation Goals for A-aou1fer lone
Specification 4 should be modified, as discussed above for Finding 20,
to read as follows:
•4. Final remediation levels for each chemical concentration 1n
any well 1n the transmlsslve areas of the A-tqu1fer zone tffected
•
by pollutants from the discharger shall be equal to or less than
the corresponding chemical concentration is listed In Table I £.'
Specification 5; Reuse Coal
IBM's goal of conserving water resources, ts feasible and practical,
will help reduce groundwater level declines. However, IBM's reuse
(even 1f 1t were 1001 of *tts froundwater «xtnct1on for remediation)
will not offset the current basin overdraft such that groundwater
levels will stop declining.
As discussed 1n our 25 July 1988 response to RWQCB's 8 July 1988
foment (No. 5) on Section 4, IBM's historical groundwater txtftctlon
and water level data provide Insight Into the significance of the
19 880015
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9 September 1988
volume of IBM's extraction relative to the overall basin balance.
IBM's 1,900 AFY reduction 1n extraction from 3,100 AFY (1983-1988) to
1,200 AFY (current) did not result 1n a significant recovery of water
levels. This lack of response Indicates that a similar contribution to
the basin (I.e., IBM's reuse of up to an additional 1,200 AFY compared
with the estimated total current pumping of about 20,000 AFY) would not
have a significant effect on the basin water levels.
n
Specification 5 should be revised to read:
•The discharger shall optimize, as feasible and practical, with
a-feal-tf-SCVr Us use of the groundwater extracted from Its
t
cleanup activities. 4ft-«re'SF-t»-pfeveH*-tfe}ayc-4ft-eleaiiup-«'ue-te
Specification 6t Remediation Coal for Sen
As discussed above for Finding 20, Specification 8 should b* Modified
to read u follows: •
•6. The discharger shall remediate soil to • goal of 1 ppm
100 times the DHS drinking water action level fDWALl or equivalent
(see Table 2^ for each chemical In areas where there 1s a
reasonable potential for exposure that may affect public health o"r
the environment."
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9 September 1988
Specification 7; Compliance Points -
Specification 7 should be replaced with the following, which Includes a
11st of Initial compliance wells:
•7. Compliance points shall be it offslte monitoring wells within
the B- tnd deeper aquifer zones, outside the 0.25 NCHI plume
boundary. Initially (on the basis of the current plume
configuration), the compliance wells will be:
Edenvale Gap: 35-BC. 36-BCO, 37-BC, 38-BC. 39-BC. 40-BC. and 44-BC
Laterals 16-B, 15-B, 10-B, 1S-B, 1-B, 7-BU, 7-BL.ind.23-B
Vertical: 29-6. 24-C, 20-C. 9-C. 5-C, 13-C. 4-C, 6-CU. 8-CL, 1B-C,
7-C. 1-C, 2-C. 47-0, 9-0, 13-0, 2-D, 9-ND-186, 1-DU. 1-DL, and 11-C
As the 0.25 MCHI plane ctanoes size, the Utenl and vertical
compliance points will be ewved, after RWQCB approval, to those
existing wells Immediately outside the 0.25 NCHI plume boundary and
beneath the plume.*
21 680015
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9 September 1988
Table 4 of the Groundwater Self-Monitoring Program for the Tentative
Order should be revised to reflect these changes 1n the compliance
point wells.
Add New Specification 8
A new specification 8 should be Included that reads:
•8. Interpretation of til the above specifications shall recognize
the Inherent constraints placed on the discharger's ability to
control groundwater levels, and potential Migration of chemicals of
concern due to pimping by other groundvater users and the apparent
hydrologlc Imbalance In the Santa Teresa Groundwater Basin.*
Provision C.2: Tasks
IBM submitted a proposed Implementation schedule for the RAP or
Contingency 2 remediation activities on Figure $-7 of the draft
Supplement dated April 1988. Tills figure presented IBM's projection of
the timetable required for project Implementation. However, the draft
Tentative Order and draft NPDES permit contain task submlttal dates
that represent significant reductions In the tine available for
Implementation. IBM has concluded that the task schedule Included 1n
the draft Regional Board documents cannot reasonably be net given the
ISGU8B
-------
9 September 1988
typical needs of projects having similar complexity and permitting
requirements.
Attached 1s a figure summarizing the time required for major project
elements. Time 1s shown to cover necessary Investigations, preliminary
and final design, tgency reviews and approvals, permitting,
construction, tnd startup.
Interrelationships among major project tasks art also Indicated. For
example, it Is prudent to complete final treatment facility design
4
drawings after completion and review of the mid-1989 groundwater
conditions evaluation to be submitted 1n a report due. 21 August 1989.
On the basis of these considerations, the Implementation schedule
attached represents reasonable time frames for Implementation of the
necessary project facilities.
In addition, the RUQCB proposed completion dates for Task i (BAAQMD
Application filed) and Task 7 (8- and Deeper Aquifer Extraction Well
Installation Proposal) that place each task out of sequence. Each task
1s discussed separately below.
* ' . .: «
IBM believes that, under CERCLA Section 121(e), IBM way not be required
"to obtain a permit from the Bay Area Air Quality Management M*trlct
for operation of the air stripping towers. However, IBM plans to work
1S6148E. 23 880015
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9 September 1988
with this Board and the BAAQMD to ensure that the operation of these
towers does not present any significant risks to health or the
environment.
In the event a permit is necessary, the 21 November 1988 due date for
Task 1 appears to be premature for filing a complete Bay Area A1r
Quality Management District (BAAQMD) application. Relatively detailed
plans and equipment specifications typically Bust accompany such an
application. These Items will not be completed by November 1988. IBM
will initiate liaison with the BAAQMD by 21 November 1988 and will
submit the required applications, ts necessary. 1n • timely Banner
consistent with the attached project schedule.
The proposed completion date (20 February 1989) for Task 7 Is also
premature. By this date, there will not be sufficient additional
Information on which to base further definition of extraction well
locations and parameter*. The ntractloe well Installation proposal
should follow the groundwater condition decision analysis scheduled for
completion 21 August 1989 (Task 12), after the plan to toe Implemented
Initially has been determined.
Provision 2.1 •
As discussed above. CERCLA Section 121 (e) appears to provide that a
permit for Irrigation use (or other reuse or recharge) of the extracted
water 1s not required. Nevertheless, IBM Intends to work with the
9A _«aoftU
-------
9 Sept enter 1988
Board to review the substantive aspects of this matter to ensure that
Irrigation reuse (or other reuse or recharge) does not present any
significant risks to health or the environment.
Provision 4; Completion Delays
Provision 4 should be replaced with the following:
•4. If the discharger Is delayed. Interrupted or prevented from
meeting one or wore of the completion dates specified 1n this
Order, the discharger shall promptly notify the Executive Officer;
and 1f such delay. Interruption or prevention results from a cause
or causes beyond the reasonable control of discharger (Including.
' with limitation, delays resulting from the time required for action
by any governmental agency, equipment or delivery delays by third
parties, strikes, or acts of God) the scheduled completion dates
shall be extended to the extent made necessary by such cause or
causes%*
Provision 6; Quarterly Monitoring Reports "-
The last sentence should be revised to read as follows:
25 880015
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9 September 1988
•Appropriate logs and cross-sections shall be presented In the
relevant technical reports required by this Order.*
Provision 11
This Specification purports to permit the Board, or Us authorized
representative, to obtain entry, access to documents, ttc. IBM Intends
to continue cooperating with the Board and Us Staff and to provide
relevant data and records. However, this proposed Specification could,
1n some situations, exceed the power of the Board under Section 13267.
, «*
IBM reserves Us rights to challenge any requests by the Board or Us
authorized representative, to the extent they are not consistent with
Section 13267, In any event, we suggest that subparagraph (d) of
Specification 11 should be revised to add "In response to this Order"
to the end of the paragraph.
Provision 13 i
In light of the provisions of Water Code Section 13271 (relating to
notifications of hazardous substance discharges), IBM does not believe
that there 1s any need for Specification 13. The Specification should
be deleted. If the Specification Is Intended to Impose any duties
beyond those already required under Section 13271, we would aWrtelate
knowing the rationale and statutory basis for this.
ISG148B 26 680015
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9 September 1983
II. NPDES PERMIT TEKTATIYE ORDER
Finding 6.B and Effluent Limitation A.3; Waste 003 Flow Rate
The flow rate for «aste 003 nay be as high a» 2.5 «&l/ under
conditions (I.e., after the treatment systems become operational). For
example, under recovering groundwater level (Contingency 1) conditions,
Waste 003 flews of this Magnitude could result If recharge 1s not
feasible and other reuse options ire not Identified or If recharge
wells are temporarily shut down. Thus, the 1.0 NGD flow limitation
shown Is Inappropriate, especially as a dally euxlnum or Instantaneous
maximum. The flow rate limitation for Waste 003 should'be revised from
1.0 MGD to 2.5 NGD for the final conditions.
Finding 6; Description of Waste 005
The penultimate paragraph (first paragraph on page 3) should be revised
«s follows:
•Due to the high yield of groundwater from monitoring wells, low
pollutant concentrations, scattered monitoring well locations, .nd
the Intermittent nature of the discharge, polluted groundwater, as
- described In Waste 005, produced from Intermittent groundwrter
ISG148B 27 880015
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9 September 1988
sample collection from all aouUer zones, and aquifer testing of
the B- and deeper aquifers will be untreated prior to discharge."
Replace the sentence 1n the original text that follows the above
sentence with:
•Because of the variability 1n aqulfler test conditions (e.g.,
water quality and flow rate), treatment and disposal of groundvater
produced from aquifer testing of A-aqu1fer zone wells will be
considered en t case-by-case basis."
The maximum dally volume of groundwater produced from sampling the
source- and plume-ana A-aqu1fer zone monitoring wells that have
concentrations exceeding the A-aqu1fer zone target remediation goals
(which are generally Much more stringent than the Waste 003 tnd 004
Interim limits) 1s small compared with the total storm sewer discharge
from the IBM site. Of the 21 A-*4vlfer zone von1 toring wells sampled
that currently have concentrations exceeding the target goals, 8 are
wpled tlnonthljT
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9 September 1983
*
RA-2. R3-2, and RB-3 (about 600 gallons per minute, or 360,000 gallons
over 10 hours).
Finding 12; Effluent Limits
The sixth sentence should be modified as follows:
•Limits ire subject to reconsideration when additional
4«fiflM%4t«-e?-f**a*-fMtt'eURes or revised regulations are
ava4*a»4a adopted."
The last sentence should be modified to read as follows?
•However, BAT In this case differs from other eases due to the
higher flow rates am , low Influent chemical concentrations, and
treatment siting constraints.*
Effluent Limitations A.2. A.3. and A-4; Oil and Crease Analysis
The oil and grease limitations should be revised to allow IBM, at Us
option, to monitor this parameter as oil and grease or a total organic
carbon (TOC), rather than specifying oil. and grease is "PC.
rrnnn w BSOOIS
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9 September 1988
Effluent Limitations A.3 and A.4: Waste 003 and Waste 004
Instantaneous Maximum Limits for Inorganic Chemicals
The effluent limitations for some Inorganic chemicals appear to be 1n
the range of background levels for groundwaters In the Santa Teresa
Groundvater Basin. IBM believes that It should not be responsible for
effluent limitations that ire beyond Its control due to the natural
environment.
•
Effluent Limitations A.4; Waste 004 Instantaneous Maximum Limits for
1.1.1-tMchloroethane and Freon 113
The 40 ug/1 effluent limitation for I,l.l-tr1chloroethane (TCA) and for
Freon 113 would be too low for an Instantaneous maximum limit. The
• '. ' •
projected water quality for offsite wells presented 1n IBM's NPOES
permit application and In the draft Comprehensive Plan Supplement Is
based on long-term average values. To account for the observed
significant fluctuations from average concentrations, unknown
concentrations 1a Tuturt offslU extraction wells. «ad aasslblt
fluctuations In spray nozzle treatment performance, the limits for TCA
and Freon 113 should be set at or above 60 ug/1 for each chemical.
1S6148B 30 880015
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9 September 1988
E'^'.-e-t Limitation A.7: Bloassav Testing
IBM requests clarification of the Intent, design and protocols of Lrlow
through 96-hour bloassays" for groundwater discharges, particularly at
offslte locations. In addition, IBM requests that the relationship
between these t>1 MS says and the bloassay test program requested by
RWQCB 1n Us letter dated 12 August 1988 be clarified.
Receiving Water Limitations B.I and 6.2
It 1s unclear how receiving water limitation: (e.g., dissolved oxygen,
pH, temperature, ttc.) tpply to groundwater discharges routed through
storm sewers. However, assuming that they do apply, receiving water
quality should be Judged on the basis of the cvncept of no net adverse
Impact, taking Into account upstream water quality when appropriate.
Provision 6: Re-evaluation of Permit
The first ttnttAC* should bttodlfltd to rtad as follows:
•This permit may be rt-tvaiuated by the Regional Board prior to the
expiration date after the tine new regulations regarding non-point
source discharges are adopted and Imp 1 emerged.•
ISG1488 31 880015
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9 September 1983
III. GROUNDWATER SELF-MONITORING PROGRAM
'' • **
Section C.I; Violations of Requirements
The first paragraph provides for Increasing the frequency of sample
collection and analysis. However, the provision for subsequent
decrease 1n sampling frequency 1s not addressed (see following comment
regarding C. 3. d).
Consistent with mediation goals, the second paragraph should be
•odlfled as follows:
•If 4Mftitet-efHMFe-tKaR-IO-Mt-ef-e4thef
a running annual average
concentration exceeds a target remediation goal for the B- and
deeper aoulfer tones, or 1f i running annual averaoe hazard
Index exceeds 0.25 NCHI or 1.0 CHI 1n £ compliance point well,
the 41*ehArger stall 4ocrttst sample collection «nd analysis as
follows."
The third paragraph (and Site Cltanup Requirement Specification Task 3)
Indicates that hazard Indices will be based en calendar quarterly
averages. Calculating hazard Indices for a calendar quarter TT
Inconsistent with the health-based hazard Index approach. All hazard
XSG148B 32 680015
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9 Sep ar 1988
Indices calculated for the draft Comprehensive Plan have been based on
annual averages and a minimum of 4 samples. This 1s consistent with
health-based objectives and the EPA's compliance monitoring
requirements (running annual average of quarterly samples) for VOCs 1n
drinking water. To provide meaningful quarterly Information, running
annual averages c&luUled quifUrly she-.Id t: rysclflsd-
C.3.d; Self-Monitoring Plan Revisions
Consistent with the 14 July 1988 Proposed Revisions, Phase II. IBM
Self-Monitoring Plan, the following criterion should be added:
•(5) Altar wrap!Ing frequency basad on tvaluation of collactive
database."
To cover those cases of Increase in sampling frequency ts described 1n
C.I, an additional criterion for SMP revision should be added:
•(7) Following a temporary Iftcraase Ut sanpHig frequency, as
described In C.I,,the regular sampling frequency will
rusume after 4 samples show stable or decreasing
concentrations (I.e., iot Increasing ewre than 50 percent
RPO between samples).*
680015
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9 September 1583
IV. RWQC3 STAFF REPORT
Page 6: NCHI Calculation
The denominator of the equation calculating the NCHI should refer to
TaLie 3 uui.cau «T Taule 2. In the expanded equation shown at the
bottom of Page 6, the denominator for TCE Is 52 (rather than 5 as
shown), which is the relevant criterion for noncarclnogenlc health
effects for TCE.
Page 7; CHI Calculation
The denominator shown In the equation at the top of Page 7 should refer
to Table 4. not Trblt 3.
Page 9: Third Item Under •Implementation of the Draft Remedial Action
Plan...* B- and C-aoulfer lone Extraction wen Clusters
As Addressed in IBM'* 22 July 0988 response to Itm 6 of the RWQCB
staff's letter of 6 July 1988 concerning the Proposed Remedial Action
Plan, extraction fron the C-aqu1fer zone will not prevent downward
vertical chemical algratlon. It would, in fact. Increase the leakage
from the B-aquiff zone thereby spreading pollutants vertically
downward, and would Increa-vthe hydrologlc lefcalance of the_Smta
Teresa Basin.
IS6148B 94 880015
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9 September 1S8S
In the Santa Teresa Basin, water levels are higher 1n upper aquifer
zones than 1n lower zones. The downward vertical hydraulic gradient 1s
caused by large-scale groundwater extraction from the C- and deeper
aquifer zones. Because this downward vertical hydraulic gradient
exists between aquifer zones, rroundwater 1n the upper zones has
migrated and will continue to nigrate to lower aquifer zones.
IBM alone cannot prtvent downward vertical migration of groundwater.
To reduce further vertical chemical Migration, IBM has proposed to
aggressively remediate the A- and B-aqu1fer zones both at the plant
site boundary, at enslte areas, and offslte. By Initiating additional
remediation of groundwater In the A-aqu1fer zone, the source §f
chemicals to the B- and deeper aquifer zones will be controlled further
by reducing vertical migration to the B- and deeper aquifer zones.
Similarly, by remediating the 0.25 NCHI plume 1n the B-aqu1fer zone,
continued vertical migration to the C- and deeper aquifer zones will be
further reduced.
IBM would.consider a slight revision of the RAP saturated thickness
criterion to accommodate additional groundwater extraction In the
B-aqu1fer zone 1fs (1) th. Hazard Indices Increase and clearly threaten
to exceed the cleanup goa's 1n the C- and deeper aquifer zones, and
=<2) additional Information collect*"* by the Santa Teresa Baslo*~
Groundwater Management Task Force on groundwater level and groundwater
880015
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9 September 1988
basin conditions Indicates that groundwater level conditions have
stabilized at slightly less than RAP conditions. Groundvater
extraction from the C- tnd deeper aquifer zones Is not I recommended
remedial action to prevent additional downward vertical chemical
Bigration.
We note that the target remediation goals 1n the B- and deeper aquifer
zones are shown in Table 1. not Table 2.
ISG148B
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BUtT^ABEA
////////
-------
SocieiY DOC.
August 11, 1988
Regional Water Quality Control Board GUALHY COMT?.OL 20£;D
IBM - COMMUNITY RESPONSE
Attention: Community Relations Officer
1111 Jackson Street, Room 8
Oakland, CA 94607
Dear Community Relations Officer:
The Sequoia Audubon Society's Conservation Committee has reviewed the "IBM
San Jose Superfund Site, Fact Sheet 13.* This 1s In relation to the Proposed
?1nal Cleanup Plan for IBM San Jose Site. The proposed plan lists six cleanup
Iternatlves. We favor f6: Achieve better than safe drinking water levels
lAqulfer Protection with Safety Factor assuming varying levels of groundwater
1n the aquifer). Alternative 16 1s the best plan to ensure complete cleanup
of toxins and to prevent them from entering drinking water.
Sincerely.
Vice President
-------
SA.S7X CLA*A COUtfTY
WUFACTUJUNG CROUP
C-wwvwC£0
I. MAM
OLl
•J.I
OAVB
August 17, 1988
Peter Snyder, Chairman
Regional Vater Quality Control Board
1111 Jackson Street
Oakland, CA 94607
Dear Chairman Snyder:
The Santa Clara County Manufacturing Group
consists of 90 coapanies located in Santa Clara
County employing ever 200,000 people. Employees
•nd families of member companies number veil over
half a million people who lira and work in this
Yelley. Ve are Titally concerned with the health
of oar employees and all citizens as well as with
the continued economic health of tha community.
Ve support, with some reservation, the IBM plan.
la developing their cleanup plans our member
companies have acknowledged thair responsibilities
by spending vail over $200M to data, just in Santa
Clara County, monies that would normally go to
atockholders, employees and future investments.
Ve have aot asked for mad do mot vast public funds
for this purposa.
For aeveral years the Clean Vatar Task Force,
a sored by the Manufacturing Greap, has been
1 red in public apeak!
pc -making groups, an
•c -.on materials oa c
COG /. Va have baea co
that industry rill do wb.
testifying before key
*bliahiag public
:>ap iaaues ia this
tent in damonatratiag
ia necessary to pursue
rational cleanup piana (aaa attached principles).
Our afforts and prograaa are being haapered by the
lack of *p«cific foala, »aaad oa the aest
•cisjntific mad technical data, to guide our
afforts. Va are vary concerned that in this plan
these objective goals are still not apparent.
Vhat we see reflected in this plan ia a aubjeetive
compromise rather than a mat of goala baaed oa
good aciaaca. Tha presentation to tha community
oa August 11 was filled with tha tona that, while
a Hazard Index (B.I.)«1 would protect the safety
of tha aquifer and tha public, going to four times
battar was a good thing to do. The^froposed order
seems to fall short of providing IBM vith clear
attainment goala even baaed oa tha four times
aafer than necessary rules. This ia
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Page 2
August 17, 1988
erident in the paragraph vhich specifies that when
that goal is reached at any point of tine, the
board will then decide if the goal should be
changed. It is just not possible to build optimal
plants to do the cleanup vith this type of Boring
target. Our indistries recognise and agree with
the need to siodify goals when new information
concerning bealtu n**ndards arise, but goals
should not be changed arbitrarily.
Ve believe this plan has within it the ingredients
for a policy solution to the unknown goals
problem. Since the H.I. is defined to be the
xatio of the concentration of the chemical vhich
ia present to the amount vhich ia aafa (aee
attachment oa E.I.) it ia the ideal route for the
atate and regional board to communicate uniform
cleanup goala baaed on good acienea. Thua the
state might choose a H.I. of unity ma the
appropriate guideline mince thia apecifiaa that
all sites will be cleaned «p to the point of
adquately protecting the environment. Thia allows
flexibility for each mite to modify its specific
H.I. ma m fraction of the specific geology,
probability of contamination of drinking water
supplies, etc. Thia local option might result in
an E.I. greater than one or leas than one,
Uae of the B.I.»1 mm m general guideline provides
m vay to balance th» issue of vater conservation
vith clemaap. If adopted there vomld mo longer be
a Question mt the state Icrel that cleannp to m
level of B.I.-l is mot m vmste of the etate'a
vater resource. Setting much m foml vbald help to
reduce *he public's confuaioa about the
appropriate balance betveea protection of the
environment, health concerns, vater. co'naervation
mad cost, a B.I. of one is mot in may sense a
permiaaion to pollute op to that level. Ve
support tough standards to mvoi ' may future
contamination of the aquifer. At the same time ve
meed to mdopt rational policier for cleaning up
contaminmtioa from past events vhich is already
there from m vide variety of practices *»hieh ve
all thought vere mcceptsble mt the time. The lack
of much m guideline leads mm to msk the regional
board "vhy is may vater beiag pumped to achieve
cleanup goals vhich sre acknowledged to be four
times safer than are mecessary to protect health
mad the environment?"
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Page 3
August 17. 1988
Ve request that the board publish the aaount of
money that IBM will have to spend to achieve an
H. I.*.25 versus a H.I.-1. Ve also request the
Board publish the amount of vater that will be
puaped and dumped to achieve an H.I.».25 versus an
H.I.-l. Ve feel this vill assist the public in
understanding the board** priorities and
trade-offs.
The second concern that ve have with this plan is
that there has been unreasonable ti»e and cost to
get to where ve are. Part of the reason has been
the lack of goals, part has been the overlapping
multiple bureaucracy which la so complex that it
costs over $2M to generate the necessary paper
work to define a cleanup plan, and part la because
we have decided the only appropriate decision
proceaa is that of coasensua. Vhile we accept the
advantages of having a consensus, we ace eoae real
dangers with the consensus process aa ve have
watched it work in developing this plan. It takes
yeara to define all the engineering and technical
parameters associated with a plan aueh aa this and
during this time the consensus aa to what is .best
for the community ia most likely to change as it
has in the IBM plan. Our concern ia that before
the requisite plants and facilitiea for this plan
can be built, the consensus ia likely to change
again. Ve need more leadership and laaa
averaging of opinion ia deciding theae critical
iaauea. Tbia leadership aeeda to extend to
informing the pntlic that their intereata are
being protected.
Finally ve «oat Bake a coaaent on the overall coat
of thia plan aa it relates to the future of our
other cleanup plans ia the county. Vhile thia
plan develops a rationale for chooaiag a I.I. of
.25, the preaentation on August 11 allowed the
iaterpretatioa that the coat of H.I. of .25 ia *
Justified on the basis that IBM can afford it. Ve
•eke a atrong request that aa ve move into other
final cleanup plane, the board focaa on vhat ia
beat for the health of the people and the—^
protection of the environment rather than their
Judgment aa to vhat a given coapany can afford.
Ve vould expect any gnideliaea vhich are developed
vonld be applied evenhandedly to all of our
contaainatioa problema including gaaoline tank
leaka and hone coataaiaatioa aoarcea.
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Page 4
August 17, 1988
Ve support the specific plan as presented.
However, we hope our concerns will be taken into
account as other plans are developed. Ve would be
happy to work in cooperation with the board in
further development of these ideas.
Ve have and continue to be a strong advocate for
the leadership role of the XWQCB is Santa Clara
County cleanup plans. Oar comments are intended
to be constructive and to contribute to an
improved cleanup proceas.
Sincerely
Gary Bu
Presid
GB:lk
Attachments
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pro coorowiTza QJATOP
1) Cocparu.es accept their responsibility to protect public health
and the environment.
2) Companies will complete a thorough investigation of contaminated
areas.
3) Companies will comply with all applicable environmental statutes
and regulations.
4) Cleanup programs will proceed with all practical speed consistent
with timely decisions by the regulatory agencies.
5) Cleanup plans will be based on scientific information and cleanup
techniques which balance risks, costs, and benefits.
6) Cleanup plans BUSt contain measurable goals that state the require-
ments for the completion of cleanup activity in a planned, consistent
manner. •
7) Companies will inform and help educate employees and the community
of cleanup plans, relative risks, and other related measures.
8) The best interests of the community are served by expending valuable
resources on cleanup activity up to, but not beyond, what is accessary
to protect puhlic health and the environment.
9) Companies expect public officials to support, cleanup plaas based
on good acienca that rmfLecta the risks, casts aad benefits to
society.
10) Public agencies and officials must be proactive in public education
on toxics. When cleanup plans have been defined which protect public
health and the environment, the appropriate agencies aust actively
support and communicate this to the public.
lev. 6/2/87
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Comments on Proposed Final Cleanup Plan for IBM, San Jose Site
S nbmcig£ ty (FID in Mag «nd »ddrm tf joo with to receive a written response)
Street Address:
City: ,_fl»x,
1/7^ /> "
State: C^ Zip:
WntteB ******•***•• mxj bt- BiHp*nft4 tt the Fnb&c
Regional Water Quality Control Board
IBM- CX)MKrUNTTY RESPONSE
Att* CoouDuoity RelAtioos Officer
1111 Jackson Street, Room 6000
Omkland,Ca 94607
/
A / *s
OIIC* t
/ .^^^
V
-------
/«-
Comments on Proposed Final Cleanup Plan for IBM, San Jose Site
Submitted by-^(F3I a name tad tddrtu if you wub to receive a written recpoote)
Name: JT^V^ Ut*,& tf-i r.
Street Address: /V^r Is// ^"/^d ^ ,
City: VC^ ."I^Sr" Sute: Z>T Zip: ? *T//
//*)> feH
Regiooil Water Quality Coetrol Bo«4
IBM • COMMUNITY RESPONSE
Attl Q*»*" •""*"*> RdfttlOBS OffiOBT
UUJtckion Street, Roan 6000
O*kknd,C» 94607
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/"
,r>a
or c/*s)c
JL C 3 ^c^-- Os*
&• Jp
CALIFORNIA RWin
flUG 101988
o/x £*— fy^^7 QUALITY nONTR0l
-------
n Proposed Final Cleanup Plan for IBM, San Jose Site
Snbmincdby.
Street Address: 35V O/9e $^. . ~ ~ £>
City, So^J-nts^ State:
? ^ *--'
ter Qufity Cootrol Bovd
IBM - COMMUNITY RESPONSE
Art: Community Rektiou Officer
Ull Jackson Street, Room 6000
Oakland, Ct 94607
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E AGUES OF WOMEN VOTERS OF SANTA CLARA COUNTY
LOS AtTOS-MTs VIEW AREA
SAN IQSE-SASTACLARA
CUPERTINO SUNNYVALE
LOSGATOS SARATOGA
August 9, 1988 AUGH1988
QUALITY CONTROL BOARD
Regional Water Quality Control Board
IBM -COttlUNITY RESPONSE
Attention: Community Relations Officer
1111 Jackson Street, Room B
Oakland, California 94607
Gentlemen:
The League of Women Voters supports comprehensive measures to provide
maximum protection to human health and the environment from the
adverse effects of hazardous materials. We believe an integrated approach
should be taken to prevent harmful exposures through soil, surface, and
groundwater contamination; bloaccumulatton, air pollution, and direct
contact. Cleanup of hazardous wastes should meet health based standards
that include a margin of safety above the assessed risk. Maximum
cons ideraticm should be given to the effects on the economy and
employment. Minimal consideration should be given to costs or effects on
the price of the product .
We have reviewed the Proposed final Cleanup Plan for the IBM San Jose
Site. Alternative No. 6, designed to clean up groundwater four times
better than safe drinking water levels with provision for onsite reuse of
cleaned up water has merit The Hazard Index is a good approach for taking
into consideration potential cumulative or combined effects of mixtures
of pollutants, since it effectively lowers the permissible amount of each
component as the number of pollutants increases. ^
The proposal also appears to be a workable solution to the problem of
varying groundwater levels caused by drought or excessive rain over the
twenty year period.
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LEAGUES OF WOMEN VOTERS OF SANTA CLARA COUNTY
LOS ALTOS-VTS V!£* AREA
SAN IOSE-SASTACLARA
CUPERTINO SUNNYVALE
L05 C.VTOS-SARATOGA
PALO ALTO
Regional Water Quality Control Board—2 (8/9/88)
IBM should continue to look for ways to use the treated water both on and
offslte, since the volume will undoubtedly exceed IBM's present water
needs onsite. Relnjectlon onslte needs careful monitoring to make certain
that it does not move the plume in ways to allow it to go.off site again. We
assume that the monitoring wells are 1n place to assure that relnjectton
works as planned. If drought continues and water levels go even lower, It
may be necessary to reconsider recharging the treated water Into the
percolation ponds, but unless conditions become really severe it Is best to
avoid doing that.
We are very concerned about the potential for Freon getting into the air
during the aeration treatment of the water. Since Freon has become a
worldwide upper atmosphere problem, every opportunity should be taken to
prevent escape of any amount into the atmosphere. IBM should be required
to carbon treat the air from alrstripplng operations to remove possible air
pollutants even though the amounts are so small that with dilution they
would not affect human health through breathing.
With proper monitoring and tne addition of carton treatment of stripped
air, Alternative No. 6 appears to be a careful and appropriate cleanup
proposal.
Sincerely, ~ ;
Ann Clifton, Chair
County Council of the
Leagues of Women Voters
of Santa Clara County
Cupertino-Sunnyvale
Los Altos/Mountain view Area
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APPENDIX D
CORRESPONDENCE
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IBM HAILING LIST
(1) State Water Resources Control Board
P.O. Box 100
6acraa«nto, CA 95814
Attn:. Gil Torres
Harding Lavson A*soc.
P.O. Box 578
Novato, CA 94948
Attn: Randy Stone
(2) USEPA r*
215 Fremont St.
San Francisco, CA 94105
Attn: Mary Masters
(3) Department of Health Services
Toxics Substance Control Division
2151 Berkeley Way, Annex 7
Berkeley, CA 94704 .
Attn: Bovard Batayama
(4) Santa Clara County Health Department
2220 Moorpark Avenue
San Jose, CA 95128
Attn: Lee Esquibel -
(5) Santa Clara Valley Water District .
5750 Almadeo expressway T
San Jose, CA 95138
Atta: John T. O'Hallorma.
Tea Iwmnura - % ^
Walt Wadlow
(6) IBM
5600 Cottle Road
San Jose, CA 95193 -
Attn: Hay Xerby
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CALIFORNIA REGIONAL WATB?
5to»« »f Colrfornio
LA j • SEP 07 1933
Memorandum
QUALITY CONTROL BOARD
To ! Steven Ritchie °°" ' September 6, 1988
Executive Officer
^4
California Regional Water Quality sublet: Additional Comments
Cr«r,trol Board . Tentative Order for Site
San Francisco Bay Region Cleanup and NPDES Permit
1111 Jackson Street, Room 6040 for IBM, San Jose, Santa
Oakland, CA 94607 Clara County W43-000
CWC-IBM
Clifford L. Bowen,
District Engineer
Monterey District
Public Water Supply Branch
.This is an additional comment to our August 29, 1988, memo
regarding the Tentative Order for Site Cleanup and NPDES
Permit for IBM, Sit* Cleanup Levels. . . .-
Our recommendation of applying the Bane level of Hazard Index
at 0.25 for carcinogens has generated much discussion to where
additional clarification is warranted. The Department concur*
with the IBM proposed cleanup plan as vail as the Regional
Board Tentative Order that the proposed sit* cleanup levels of
0.25 KCHI and 1.0 CHI will not unreasonably affeet the
beneficial uses of the groundwater in the B and deeper
aquifers. However, for the purpose of »axiaum public health
protection, we would prefer that the sane factor of eafaty,
0.25 HI, for non°earcinogenc be applied for carcinogens
present in the affected aquifer*. We would like to point out
two areas of concern in a&king the suggestion of using the
0.25 CKZ. Our intent is to further assure that groundwater
left in the affected aquifers be significantly less than the
drinking water standards and action l«val«3
1. The HCHI and CHI only address the toxic «ffect,s of
contaminants within their specific non-carcinogenic and
carcinogenic groups and do not address the hazards when
chemicals froa each group are stixed together. There »re
unknown syr»*Tqi»xic effects relating to mixtures of
contaminants in drinking water. We believe that in the
absence of concrete health effects data, a reasonable
aargin of safety should be used for both groups of
contaminants in prescribing the Hazard Index.
2. The Hazard Indices used in the GHZ may increase or
decrease based on the future setting of drinking vater
standards and action levels (Reference source: Site
Cleanup Requirements, page L, Item 118). A 1*^ CHI
could mean cleanup would be only to the drinking vater
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IBM MAILING LIST
(1) State Water Resources Control Board
P.O. Box 100
Sacramento, CA 95814
Attn: Gil Torres
(2) USEPA
215 Fremont St.
San Francisco, CA 94105
Attn: Mary Masters
(3) Department of Health Services
Toxics Substance Control Division
2151 Berkeley Way, Annex 7
Berkeley, CA 94704
Attn: Howard Hatayama
(4) Santa Clara County Health Department
2220 Moorpark Avenue
San Jose, CA 95128
Attn: Lee Esguibel
(5) Santa Clara Valley Water District
5750 Alnaden Expressway
San Jose, CA 95118
Attn: John T. O'Halloran
Ton Iwamura
Walt Wadlow
(6) IBM
5600 Cottle Road
San Jo»e, CA 95193
Attn: Hay Kerby
(7) Kennedy/Jenks/Cbilton Consulting Engineers
657 Howard Street
San Francisco, CA 94105
Attn: Thomas Kalinovski
(p) Harding Lawson Assoc.
P.O. Box 578 ,
Novato, CA 94948
Attn: Randy Stone
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Kr. Steven Ritchie
Page 2
September 6, 1988
standard for one specific chemical, if that vac the only
chemical detected. The Department feels that cleanup
should be to levels veil below the drinking water
standards and, to the maximum extent possible, within
reasonably technical and economical limits. This is
consistent vith ?"*••.t* ««•»••••* »*rmt-.ed Resolution 68-16
"Statement of Policy with Respect to Maintaining High
Quality of Waters in California * as well as our Drinking
Water Program's goal to assure that the water users are
provided with the best quality of water supply available
at all times. The drinking water standards and action
levels should not be used to condone contamination up to ff
those levels.
The Department's recommended 0.25 CHI is a goal to provide for
the margin of safety in assuring that downstream water users
are, to the extent possible, provided with the bast quality of
water available at all times,
ee: IBK Mailing List
Retail Hater Agendas
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Santa Qoro Volley Water District
DISTRICT BOARD Of DIRECTORS
JOE PANDrr. CHAIRMAN • DISTRICT 1
PATRICK T. FERRRO- DISTRICT 2
RO8£P^ W GODSS • DISTRICT 3
JOE DONOM UE • DISTRICT 4
JAMES .' LfM'MAN-DISTRICT 5
JOE JUDGE, VICE CHAIRMAN-AT tAftGE 57SO AIMADEK EXPRESSWAY
SJG SANCHEZ • AT 1>RGE UN JOSE. CALIFOHNIA Kill
TELEPHONE (401) 2C5-2COO
SUSAN A. VINO
CLf RK Of THE BOARD
August 30. 1988
CALIFORNIA REGIONAL WATER
SEP o 9 1988
QUALITY CONTROL BOARD
Mr. Peter V. Snyder, Chairman
Kegional Water Quality Control Board
San Francisco Bay legion
1111 Jackson Street, loom 6000
Oakland, California 9460?
Dear Kr. Snyder:
The Santa Clara Valley Vater District Board expresses appreciation for the
legional Board's lead rol« IB over sight of the IBM and other groundvater
pollution cases la our arts. Ve also want to thatLt the legional Board for
coordinating the special workshop and hearing in Santa Clara County on IBM's
proposed final cleanup plan.
Upon careful reviev, the District Board has adoptad a lesolution which outlines
the District's consents and recommendations OB tht proposed Tentative Orders
to IBM for site cleanup and KFDZS permit. V* transmit a copy herewith.
The District is deeply concerned "with and actively involved ift vrotecting the'
integrity of the groundwater in Santa Clara County. The froundviter basins
represent aa la^ortaat watar resource which anst be preserved. While complete
cleanup of the, existiag IBM eontssdnatioa to- Boa-detectable levels is a
desirable goal, the District recognizes that this is technically infeasible.
The District also recognises the need to strike a balance between pumping for
groundwatcr cleanup to protect public health and the need to conserve the
extracted water as a valuable resource.
With this balance in mind, the District supports the proposed cleanup plsn
(Alternative 6) with the amendments suggested by the Regional Board staff and
by our District Besolution.
Two of the most critical iaaues to the District are the level of protection
from further degradation afforded legion IX (the undefined region) north of
Idenvale Gap and the and use of the extracted waters. It is the District's
-------
Mr. Peter V. Sny :hairman -2- August 30, 1988
understanding that last contaminant levels similar to those that would be
expected to occur under the proposed plan moved through the Edenvale Gap without
producing elevated contamination levels In wells located in Region 11.
Our suggestion that the Regional Board strengthen the proposed plan as stated
in the Resolution includes • request that IBM be required to increase the water
reuse goal to 100X. The District will assist IBM in developing reuse markets
with an option for District credit or refund for vater that the District can
accept and use vithin system operational constraints. Additionally, the
District will develop a marketing strategy which prioritites nonpotable reuse
of the water followed by direct reuse or recharge into District facilities.
The District vlll also seek (rant monies that could be used to enhance the
quantity of vater that could be reused and requests your aupport in encouraging
the State Vater Resources Control Board to broadly define any auch monies that
could be made available-
The District looks forward to continued cooperation with the Regional Board
in resolving the difficult issues associated with implementing an appropriate
cleanup plan for IBM. to further this and. tee District will continue to
coordinate the Santa Taraaa Subbasin Management Committee to provide input to
IBM and the Regional Board on issues associated with cleanups in the aabbasln.
Ve suggest that IBM'a proposed remedial -action plan, modified toy the Regional
Board staff* aaendmeata la the draft order aad incorporating our
recommendations, vlll represent ao appropriate application of the State's policy
oa Maintaining High Quality of Maters IB California (SVRCB '. Resolution
So. 6B-16)o
Joe Tandit. Chairman
Board of Directors
Attachment
be: SCWD - Board of Directors (8/30/88 S4«n
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San Jo»»
37< WBS: Sanu CJtn St SfP n ft
P.OBo«229 Wtr09
San Jose CA 85196
4O6 279-7606
September 9, 1988
Mr. Peter W. Snyder, Chairman
Regional Water Quality Control Board
San Francisco Bay Region
1111 Jackson Street, Room 6000
Oakland, CA 94607
RE: IBM Remedial Action Plan and Tentative Order for Site *?
Cleanup.
Dear Mr. Snyder:
The San Jose Water Company appreciates the continuing
efforts of your board and staff to oversee the final remedial
action plan for the IBM groundwater contamination case. We also
appreciate the public hearing and workshop held in San Jose for
the purpose of informing and soliciting conments from the South
Bay Community. This letter summarizes San Jose water Company's
comments on the proposed order for site cleanup.
Although there are many complex issues to be considered in
the final remedial action plan, the overriding concerns of the
water company are to 1) protect the Santa Clara and Santa Teresa
Groundwater Basins as high quality sources of domestic water
supply and 2) conserve the area's available water resources. The
key issues to be considered are thus the groundwatex cleanup
goals and the conservation of pumped water used to acMeve those * •
goals.
Groundwater Cleanup Goals -
We are generally in agreement with your staff's
recommendation to pursue cleanup in accordance with alternative €
(aquifer restoration to specific cleanup goals with pumping
contingencies for responding to changing groundwater levels). *t
is our understanding that varying levels of groundwater in the
Santa Teresa Basin will affect cleanup operations and that the
most efficient and timely cleanup can be achieved by the careful
management of pumping activities in response to available
groundwater supplies.
Regarding the specific cleanup goals, we agree that cleanup
in the B and deeper aquifers should proceed to the recommended
0.25 hazard index for non-carcinogens (NCHI). However, we concur
-------
with the Department of Health Services, Public Water Supply
Branch that the same level of hazard index should be applied to
carcinogens. Therefore, we recommend that the cleanup goal for
carcinogens be a hazard index of 0.25 rather than 1.0 as proposed
by your staff. This would assure that drinking water standards
can be achieved in the Sa*.wa Teresa Basin with some margin for
error. Recognizing that "rero level" cleanup goals are
impossible to attain, this approach is both reasonable and
protective of the beneficial uses of these aquifers.
Although we agree with the general approach to cleanup in
the Santa Teresa Basin, we strongly auppuit further requirements
for extraction, monitoring and water quality goals at the
Edenvale Gap. Such requirements would provide a mechanism to
better evaluate cleanup performance in terms of containment
within the Santa Teresa Basin and protection of the Santa Clara
Basin.
As you know, the existing cleanup order limits to 10 parts
per billion (ppb) the concentrations of the principal
contaminants, TCA and Freon 113, that may be present in
groundwater at the Edenvale Gap. The proposed order abolishes
these limits in favor of the 0.25 NCHZ in B and deeper aquifers.
Since TCA is the primary component of the 0.25 NCBX calculation,
it is reasonable to conclude that as a result of the new order up
to 50 parts per billion TCA would be allowed to persist in the
deeper aquifers of the Santa Teresa Bacia.
In proposing the order, the Regional Board Staff concluded
that the 0,25 KCHI cleanup goal weu'IS not result in degradation
of groundwater in the Santa Clara Basin. This is based on .the
assumption that as groundwater flows toward the Edenvale Gap,
there will be sufficient dilution to reduce levels of TCA from
the maximum 50 ppb to 30 ppb or less. IBM has estimated that 30
ppb is the highest concentration of TCA ever passing through the
gap, and that the 1 to 3 ppb TCA and Freon 213 observed in the
affected Santa Clara Basin veils (five owned by tbe San Jose
Water Company) axe a result of this occurrence. They therefore
-conclude that levels of contamination will not Increase in San
Jose Water Company wells. While this logic is reasonable, it is
•our position that there must be adequate groundwater monitoring
and specific water quality goals at the gap to demonstrate this
level of containment. An appropriate goal would be something
less than 30 ppb TCA, which if exceeded would trigger additional
extraction of groundwater at the gap or other appropriate
remedial action.
Monitoring at the gap should include samples frogat least
one continuously operated extraction well (such am ORBC3) in
addition to the proposed aquifer-specific monitoring wells. The
extraction well is capable of campling a greater area within the
gap and could be used to demonstrate ongoing compliance with "at-
the-gap" water quality goals. Pumping rates in the range of 350
gpm (0.5 MOD) would probably be sufficient to achieve the desired
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Stct* V Caltfwnic TK« lM«wrtM Agency
Amorandum
T<> • Mr. Steven Ritchie Do*: September 7, 1988
s . Executive Officer
Regional Water Quality
Control Board, Region II
1111 Jackson Street, Room 6000 CALIFORNIA ReA'CttAI
Oakland, CA 94607
SEP os 1988
From i Department *f F»h «nd Oonw
QUALITY CONTROL BOARD
&/t>tect: Santa Teresa Groundwater Basin Cleanup Program
Pairchild Seai Conductor Corporation (Pairehild) and
International Business Machines (IBM) have been engaged in a
remedial cleanup program for the Santa Teresa Ground water Basin.
As part of this cleanup program, both Pairchild and IBM have
pumped large quantities of groundwater with discharge to Canoas
Creek, tributary to Guadalupe River. Due to increased flows to
the Guadalupe River resulting from this discharge, instream
habitat conditions have significantly improved and approximate
historic levels. .
ft*ch year since 1986, Chinook salmon and steelhead trout spawning
has been documented in the Guadalupe River. In 1987, 247
spawning redds were observed. All but three of these were found
below the Canoas Creek confluence.
It is the position of our department that the discharge of
treated groundwater. results in a beneficial use by supporting an
anadromous fishery in the Cuadalupe River. In addition, this
discharge provides freshwater inflows to Guadalupe Slough which
are essential to maintenance of rearing habitat for aany
estuarine fish species.
Upon request, further documentation can be provided which
demonstrates the beneficial use of this treated ground water
discharge for fish end wildlife resources. .
Please contact Michael Rugg, Associate Water Quality Biologist,
at (707) 944-5521? or Linda Olmer, Fishery Biologist* at (408)
458-0904.
Brian Hunter
Regional Manager
Region 3
ccs Belinda Allen
RWQCB - Oakland
Ray Kerby
International Business Machines
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RESOLUTION NO. 68- 69
ADOPTING P :ON REGARDING PROPOSED REMEDIAL ACTION PLAN
RESOLVED by th ioard of Directors of Santa Clara Valley Water District
that the position of this Board regarding the Renedial Action Plan Proposed by
International Business Mach_..es is, and shall be reported to the San Prancisco
Bay Regional Vater Quality Control Board, as follows:
Proposed Plan
Support Alternative 6 as amended by Regional Board .staff.
Support 0.25 RCHI and 1.0 CHI in Region 1. unless health authorities
determine that more stringent levels are necessary.
Additions to Proposed Plan
Request that Regional Board:
- Require adequate monitoring at Cdenvale Gap and continued extraction
of groundvster at or in the vicinity of ORBC-3 as necessary to prevent
further degradation of water quality ia the regioa downgradient from j
the Sap.
• Increase reuse goal to iDOX.
Position on Reuse Alternatives
District wills
- Encourage maximum reuse of extracted watera by assisting in development
of reuse markets with the option for District credit or refund for
that water the District can accept and mse within system operational
.constraints.
- Adopt a marketing strategy emphasising a priority efs
1. landscaping, construction water and other nonnotable uses.
2. Direct reuse or recharge into District facilities of
adequately monitored water meeting treatment goals as defined
ia Regional Board draft cleanup order. .'
• Continue coordination of Santa Teress Subbasin management committee»
- Seek grants to enhance reuse.
PASSED AND ADOPTED by the Board of Directors of Santa Clara Valley Vater
District this 30th day of August. IWft, by xae following votes
AYES: Directors i.iunmL ». 1.fguao i. m umn LM&
WOES: Directors *.*.Cress, J.Pandit
ABSENT: Directors Bone
SANTA CLARA VALLEY-HATE* DISTRICT
Chairmatr oi the ftoaro^ot Directors
ATTEST: OT&AH A. PIN6
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monitoring. It is our understanding that this water could be
conserved by providing sufficient treatment to make it suitable
for recharge or direct use as domestic water supply. The San
Jose Water Company would cooperate with the Regional Board and
Department of Health Services to assure that water meeting all
applicable health standards is put to additional beneficial use.
Conservation of Extracted Groundwater
As stated in our letter to Mr. Ritchie, dated July 13, 1988,
it is the position of the San Jose Water Company that pumped
grocu.dwater from tl.a I3M cl^^up should be treated as necessary
and put to additional beneficial use. This should be •
accomplished to the maximum extent feasible consistent with the
appropriate public health standards and water quality criteria
for the intended use. With this in mind, we recommend that the
Board reo^iire IBM to increase the re -use goal from 50 percent to
100 percent of the extracted groundwater.
extracted water is potentially useable for either
recycling (reinjection into the aquifer), groundwater recharge,
direct use or non-potable uses. To minimize the costs associated
with treating and transporting this water, IBM should maximize
non-potable use at it's own site. Additionally, we support the
proposed order to require IBM to conduct a pilot study and
prepare a proposal for full-scale reinjection of treated
groundwater. It is our understanding that such recycling of
extraction water may result in more efficient and timely cleanup
and would lessen the impact of IBM's pumping on groundwater
levels in, the Santa Teresa Basin.
Treated water of a very high quality (less than 1 ppb total
VOCs) can be obtained by air-stripping or granular activated
carbon (GAC) treatment. Such water will surpass drinking water
standards by a vide margin and could be made available for
recycling, recharge or direct use for domestic supply. Although
the treatment and conveyance of oil-site extraction water may be
subject to siting constraints, IBM should be required to provide
'the appropriate facilities vhererer recharge or direct use is
feasible. This includes construction of treatment facilities to
be turned over to and operated by water purveyors or the Santa
Clara Valley Water District.
A final consnent on the issue of re-use is that adequate
monitoring and quality assurance must be provided to demonstrate
the performance of water treatment for the various re-use
options. San Jose Water Company's position on re-use is based on
the quality of water achievable as reported by IBM. Although
treatment facilities may be turned over to the Water XftStriot or
a water purveyor for operation and maintenance, construction and
testing of facilities should be performed by IBM under the
supervision of the Regional Board and Department of Health
Services.
-------
In concluding, it cannot be overemphasized that the Santa
Clara Groundwater Basin is a vital source of supply for the San
Joso water Company and the 740,000 people we serve. This
resource should be protected against contamination to the maximum
extent possible within reasonably technical and economic limits.
We therefore request that you strengthen the proposed order for
site cleanup by adopting specific cleanup goals and requiring
additional extraction and monitoring at the Edenvale Gap. We are
prepared to work with your staff and the Santa Clara Valley Water
District to assure that this and other extraction water is put to
additional beneficial use, including recharge or direct use where
it is feasible and appropriate.
The San Jose Water Company would be pleased to meet with you
or your staff to discuss these recommendations. Thank you for
the opportunity to comment on this important proceeding.
Very truly yours.
R. Scot* Yoo
Water Quality Manager
RSY:mh
co: State Dept. of Health Services
Santa Clara Valley Water District
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Responsi ness Summary
SUMMA f OF COMMZNTTS AND STAFF RESPONSES
q. IBM i .uld have the option of •oaltoriBg oil a*d grc*M Umlutioai as cither oil aad greue
or tout i ;anic car boo.
Response Staff concur* and has modified the orders.
r. IBM t uld act be held accountable for effluent limitations that are beyond Its control due
to the ai ral environment.
Responsi Staff concurs and routinely takes these kinds of factors into consideration when
evaluating monitoring data, provided it can be positively shown what the natural
conditions are. If IBM and staff differ in interpreting this, it can be decided in a
public hearing before the Board. No change is therefore necessary in this order.
i. The 4 ig/1 effluent limits for TCA aid Freoa are too low for aa lasUntaaeoas maximum.
Retpont< After further review of the technical data submitted, staff concurs and has raised
the instantaneous maximum to 60 ug/1 and added a quarterly average limit of 40
ug/1 in the Tentative NPDES Order.
t. IBM r uests clarification of the flow through 96 hour bloassay.
Responu • Staff will gladly work with IBM when it becomes necessary to install the bioassay
monitoring equipment. The self monitoring program has been modified to require
this test only at the on-site discharge point
•. Recel ig water limitations should tale Into account •pitreana water quality.
Responsi - See Response 9j. .
v. Chan i criteria OB which aa Increase In umple collectloa and analysis is based,
Respons - Staff concurs with using a running annual average for hazard indices but also
believes specific concentration limits for certain chemicals should be retained.
w. Rerii language regarding monitoring plan rcrtsloat and recamptioa of regular monitoring.
Respoai - Staff con cars with these suggestions and has incorporated them into the
monitoring program, with one additional modification to limit resumption of
regular monitoring only if the ground water is in compliance with the SCR.
KEY Cl VNGES TN THE CLEANUP PLAN AS A RESULT OF COMMENTS
1. Jditional limits for the chemicals of concern, i.e. TCA. Freon and DCE, have been
ded i or ground water passing through the Edenvale Gap.
2. ae re-se goal has been raised from 50 to 100%.
3. ~'" requirement foi . continuously pumping monitoring well at the Edetxwfe gap has been
Ided. Reuse of groundwater from this well has been given the highest priority.
9/30/81 -13-
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SUMMARY OF COMMENTS AND STAFF RESPONSES
obtain the permit. Should administrative matter* delay the cleanup we will take
appropriate actions to assure timely compliance.
I. Suggest removal of the proposed prohibition la the SCR.
Response - These prohibitions are standard wording and are applicable to this cleanup. With
regard to the claim that these prohibitions contain vague phrases, if in the future
staff should determine that a violation has occurred and recommends
enforcement to the Board, the Board in a public hearing would consider all
relevant facts from the staff, public and IBM to decide whether a violation had
occurred and the consequences as they apply to the particular ease before it In
addition, day-to-day guidance from staff ha* been and remains available.
j. Chemical concentrations ased la the Hazard ladex calcalatloa shoald be nnnlng aaaaal
arerages calculated quarterly.
Response - Staff concurs that this is an appropriate means to determine compliance with the
cleanup plan.
k. Remove goal of SOS nose of gronadwater.
Response - See Response 3jL
1. Add specification that acknowledges the possible Impact oa grouadwater levels of asers other
than IBM. •
Response - This appears to be a reasonable request and it has been added.
so. Change task submlftal dates.
Response - The task compliance submittal dates have been modified pursuant to this request
a. Delete Provision 13, It Is covered by Water Code Section 13271.
Response - This provision is standard language contained in all cleanup orders and is
intended to implement Section 13271 on a site specific basis.
o. The flow rate llnltatloa for Waste 003 shonld be revfstd frosa 1.9 to 2.5 MGD. i
to be reused. Therefore reducing the allowable discharge after treatment works
are. in place is consistent with the overall goaJ of both the Regional and State
Boards. Therefore, staff does not believe this request is appropriate.
p. Revise Finding 6 regarding Waste 005 to remove restrictions oa disposal of frondwater from
A aquifer on case by case basis. .
Response • Since the A aquifer has the highest concei "rations of chemicals, ttaff believes the
restrictions contained in the SCR should remain.
9/30/88 . -12-
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SUMMARY OF COMMENTS AND STAFF RESPONSES
provision for quarterly monitoring reports appears to be out of place in this
section of the comments. Since this is standard language for cleanup orders surf
does not believe it should be deleted in this case.
b. Urge Board to «se Content (rather than ••(lateral) Order format to address Issues which
may need to be reopened.
Response - Board orders are adopted, and modified, in public hearings where the discharger,
Board members and staff, and other interested parties all have the opportunity to
have input into the process. Therefore, we do not view Board orders as being
unilateral. Additionally, ta appeal process is available under State law.
c. IBM does not concede that the Regional Board has JBrisdlctioaal power to Issue the proposed
order.
Response • The staff position, which the Board has supported on numerous occasions, is that
the issuance of Site Cleanup Requirements is the appropriate means of dealing
with cleanups under the Water Code.
4. IBM does »ot concede that Its activities have created a condition or threat of pollution, or a
ilgnlficant threat to the environment.
Respoose - The Board in prior orders has previously found that there is ample evidence that
the discharge of chemicals at and from the IBM site has, and threatens to,
adversely impact the real and potential beneficial uses of f roundwater. Therefore,
pollution and a threat to pollute do exist
e. Indicate that there are other possible soarces for chemicals la the area beyond Edeavale
Gap.
Response - Staff agrees that there may be other, as yet un^entified sources beyond the Gap.
However, we also believe that there is sufficient evidence that IBM has
contributed to the chemicals found in this area.
f. Clarification that the Regional Board will matinee to r*fulat* the IBM cleanup, whether or
•ot it Is a CERCLA site.
Response - It is the Board's intent, as stated in the SCR, to do just that
I. Soil rcmedlatfM joab abe«U he 1M times the •pfBcabfe DBS tMaJJa* water standard.
Response • see Response 6jt. _
h. IBM aotes that CERCLA Sectioa 121(e) appears to provide an exemption from compliance
with CEQA aad other permitting rales.
Response - Staff concurs that CERCLA does allow for exemption from the administrative
aspects, but sot the substantive aspects, of obtaining permits for on-site
activities. We have chosen not to use this section of CERCLA for CEQA, and
instead we are using an exemption that already exists under stsje. law. In other
cases, such as a permit from ths BAAQMD, we believe the best way to assure
compliance with the substantive portions of the permit requirements is to actually
9/30/88 -II-
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SUMMARY OF COMMENTS AND STAFF RESPONSES
j. Was land subsidence addressed IB the plan?
Response - It was addressed in the remediation plan and found not to be expected.
k. Who U responsible if subsidence does occur?
Response - Subsidence is not expected. However, if it should occur, we believe the matter
may have to be decided by the courts after determining who caused it and what
damages occurred because of it
1. Strike the enforcement paragraph la (be Flaa, It has IBM policing lt*lf.
Response - Self monitoring has been, and is, the standard practice for inuring compliance
with all Regional Board orders. With routine and spot checking by Board staff,
we have found this to be a satisfactory, useful, and efficient method of
determining compliance with all the orders issued by the Board.
I. Board should require IBM to brlag IB urface water to Inject at the property Uae la order to
contain the pollutants on their property.
Response - Staff believes that in the long run it b better to remote the pollutants from the
groundwater rather than attempt to contain them. Also, pollutants have already
migrated beyond the properly boundary.
IBM COMMENTS
8. EDITORIAL COMMEJfTS : •
Editorial comments (ej. typographical errors, clarifications, tic.) have been incorporated into the
cleanup plan and orders in those eases where the intent of the cleanup plan has not been changed.
Any changes that impact the actual cleanup program are described below. ... • •
9. NON-EDTTORIAL COMMENTS
a. Grounds for reoptnlag the rcsnedlatioa flu for hither Board rtrlew or actba teed better
definition.
Response - Staff accepts, with modification, IBM's proposal for a general policy statement
retarding fvtwre changes to the cJetvop plan. This will be iacfoded IB the SCR ts
• finding. The staff jnodificatkm to tht proposed language is to clarify that any
changes would be based cm either newly discovered site conditions or other
information not available to the Board at the time of adoption of the remediation
plan. :
Staff does not believe that the other changes proposed by DM to go along with
the above policy statement are appropriate. Some suggested specific deletions of
grounds for modifying the remediation plan in contrary to the 'other
information* portion of the policy statement. Also, requiring that changes in the
monitoring program, technical evaluations, or periodic Board r*nir • be limited to
conditions listed in the policy statement is too restrictive of the Board's
responsibility to protect water quality. Finally, the request for deletion of the
9/30/88 -10-
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SUMMARY OF COMMENTS AND STAFF RESPONSES
c. If Technical Assistance Grants are lot available, IBM tbould be encouraged to put np an
equivalent amount of aaoney.
Response - This would have to be negotiated between IBM and community groups. The
Board has no authority to require this.
d. There are BO precis* recharge capacity estimates.
Response - The remediation plan calls for submitting detailed groundwater reinjection plans
by January 1990. These plans should include these estimates.
e. The Board should lirestigate ways to limit paperwork associated with developing cleanup
plans.
Response - The Board staff attempts to limit the paperwork as much as is allowed under the
various state and federal laws «•; -a it is required to enforce. Utilizing one
report to satisfy the three regulatory agencies is one method the Board has chosen
to reduce paperwork. Submittal of complete reports by dischargers would help
eliminate much of the correspondence involved in developing Acceptable cleanup
plans.
f o There should be snore leadership aid less averaging of •pinions In deciding critical Issues.
Response - When deciding critical issues it is important that all opinions be heard tnd
considered. We believe the Board is taking an active leadership role in this issue
given the legal constraints imposed upon it
g. Board sho«U develop more and better public education Baterialf, particularly with regard to
public safety and risk.
Response • The Board is doing what it can given the limited resources la this area. We nave
issued, and plan to continue doing so. public fact sheets on Regional Board lead
CERCLA sites as final cleanup plans are developed and considered for adoption.
h. How long »til treatment systtau are b«llt and In •pcrmttm?
lespoase • The schedule contained in the remediation plan and SCR ic . -
Of/silt:
treatment design - January 1989
treatment operational - August 1989
Onsite:
treatment preliminary design -March 1989
treatment final design - October 1989
treatment operational - June 1991
I. To what degree was Plan f Mthored by DM?
Response • Plan 6. "the remediation plan', was originally drafted by DM. However, the final
plan has been modified by Board staff.
9/30/88 .9.
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SUMMARY OF COMMENTS AND STAFF RESPONSES
6. SOIL CLEANUP
a. Steam Injection will work with vapor recovery.
Response - The remediation plan did evaluate several methods of soil remediation, including
steam injection and bioremediation. The plan concluded they were technically not
applicable to this site (e.g. heat treatment with steam injection, since it is an
unproven technology) or that they were of limited applicability (e.g.
bioremediation). Soil remediation techniques which were chosen include soil
removal, which has already been accomplished, and vapor extraction.
Detailed plans, btsed on current pilot studir*. for toil cleanup by vapor
extraction are due under this n mediation plan by January, 1989. If tne current
proposal proves unable to reach soil cleanup goals, then additional technologies
will have to be investigated.
b. How Is the toll going to be cleaned sip?
Response - 23,000 cubic yards of contaminated toil have already been removed from the
areas with the highest concentrations of chemicals. For the remaining soils which
contain chemicals above the cleanup goals, the remediation plan calls for toil
vapor extraction wells to be installed.
c. Have alternative toll cleanup methods, neb as tteaai injection, keen eralnated?
Response - See Response 6a.
d. Can bio-remediation be used to enhance toll cleanip?
Response - See Response 6.a.
e. The toll cleanup goals should be 100 tiaies the applicable drinking water itaadard.
Response - The proposed goal may not be adequate to protect drinking water resources,
depending on the nature of the interactions between the chemicals and the toil.
Therefore the SCR contain a more conservative limit of 1 ppm. but allows IBM
to request a higher number if it can prove ao adverse impacts on the
troundwaier (e.g. lack of mobility of the chemicals in the soil).
7. MISCELLANEOUS
a. Proper monitoring should be perforated.
Response • Both the SCR and the NPDES Permit (for surface water discharge) contain
extensive monitoring programs, in addition, Board staff will be d' 'ng periodic
compliance inspections throughout the cleanup process. Aho see l.b.
b. IBM should renaia a proposed CERCLA site.
m, •
Response - Board staff agrees with this position and has ao informed the EPA. However, the
final decision rests with EPA.
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c. How soon will you evaluate the effectiveaeu of the scrubbers?
Response - The BAAQMD requires that any air pollution control equipment go through their
permitting process prior to being built. Therefore the scrubbers will be evaluated
prior to being installed or operated.
f. What problem would there be !• putting the scrubbers en the air striken before the air
strippers are up?
Response - Technically this would not be a problem. However, see Response 4.a. regarding
whether it is necessary.
g. Will T*p— r»??T»ry go OB 20 yean or beyond If 1 ppm If not Met, or will It continue only
•Dtll recovery levels off?
Response • Vapor recovery will continue as long AS it is effective in r-moving chemicals
from the soil and until either the cleanup goals are met or :.. .creative goals are
set by the Board based on threat to water quality (see Response 6.e.).
S. COST
«. Cost relative to hazard Index aad aaouat of water should be published.
Response - This information is in the administrative record which is available for public
review.
b. Multiple bureaucracies cause delay aa>d Increase costs.
Response - Regional Board staff, acting as the lead agency in this ease, has attempted-to do
what it couJd to expedite this cleanup process. However, other agencies, local,
state, and federal, all must make sure that their own laws, regulations, and
requirements are complied with, and this does sometimes cause delays.
c. IBM should spend whatever It takes to restore the froundwater.
Response - Stare law and policy requires cleanup actions to be reasonable, and one aspect of
reasonableness is cost. Abo, one of the criteria under CERCLA for choosing a
final cleanup plan is cost. Based on these state and federal requirements, costs are
considered when choosing a final plan.
d. Board should focus on what It besl for pcblic health and the environment, lot on what a
company'can afford.
Response - The remediation plan will protect public health, based on known standards, and
can be changed if the health standards change. The cleanup goals include a
significant safety factor. Costs were considered when deciding cleanup goals
beyond those needed to protect human health. Also, aee Response 3x.
e. Is IBM paying for all the water they are pumping out of the ground?
Response - IBM is paying the Santa Clara Valley Water District for all extracted
froundwater.
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SUMMARY OF COMMENTS AND STAFF RESPONSES
measures when groundwater levels are falling, which is what happens during
drought conditions.
q. It there »ny intent to force the SCVWD to blend reused water Into existing water systems?
Response - See Response 3J.
•-?;•.
r. What objection does the SCVWD have to discharging treated gronadwater into their
percolation ponds?
Response - District staff did note certain management and technical difficulties with the
proposal to discharge to the percolation ponds, however there is no formal
objection from the District at »»•« time if the ground^-ater b sufficiently treated.
The primary obstacle to this proposal are the costs of treating and transporting
the groundwater.
a. How Bach of the system for piping treated grouadwater to Markets la IBM going to pay?
Response • See Response 3.c. Also, these matters would have to agreed to between IBM and f,
the user of the water.
4. AIR EMISSIONS
a. Should require air scrubbers.
Response - For questions on whether air acnibben, or any other method of air pollution
control equipment, will be needed, Regional Board staff will be relying on the
Bay Area Air Quality Management District's (BAAQMD) permit program to
assure protection of public health and the environment. This cleanup plan
requires IBM to obtain the proper permits from the BAAQMD. In addition, the
cleanup proposal did address the potential *:alth impacts of air emissions from
groundwater treatment units and found them to be insignificant. Also see
Response 2.b.
b. Don't allow Freoa tmluloas lato the air (to protect ezoae layer)
Response - Set Response 4.a, .
»
e. What happens to Material that is volatlltee* when tttatiaf water? b It relea*«d to the
atmosphere?
Response -. Any treatment using air stripping, a* b proposed in this case, will release
chemicals to the air unless further treatment is required. As noted in 4.a. above
we are relying on the BAAQMD to decide whether further treatment is needed.
d. Do you add together all nearby sources of air foliation whea determining what standards an
appropriate to meet?
Response - BAAQMD procedures do take this into consideration.
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Responsiveness Summary
SUMMARY OF COMMENTS AND STAFF RESPONSES
i. Treated groundwater should »ot be bleadtd la to existing water supplies.
Response - As long is the water is sufficiently treated to meet the concerns of the
Department of Health Services, which regulates water supply systems, and the
water purveyors, the Regional Board has no objections to blending treated
groundwater into water supplies. Also see Response 3 v
J. Don't put any inclean water Into the ••dergrooad basin.
Response - The remediation plan calls for treating any recharged groundwater to an average
of less than 1 ppb. Current technology does not allow for any stricter
. requirements.
k. Stop discharging water to Caaoas Creek.
Response - Prior to complete reuse of extracted groundwater. discharge to surface water is
the most reasonable option available. The NPDES permit to be adopted as part of
this remediation plan is designed to assure protection of the beneficial uses of
Caapas Creek. At this time, based on several yean of existing data, there is no
indication that there would be any adverse impacts if this portion of the cleanup
plan is complied with. Also, note comment 3J. below.
1. Discharge of treated ground water to Caaoas Creek Is beneficial because It supports fish la
the Guadalupe River.
Response • This comment is from the Department of Fish and Game. We concur with it,
however, any final decisions-will have to consider a balance between maintaining
fish habitat created: by .the discharge of extracted'.groundwater cleanup, reuse,
and conservation.
•a. Does the plaa aay that untreated grouadwater will be pumped late Caaoas Creek?
Response • In order to continue the gronndwater cleanup, the current practice of discharging
untreated groundwater to Canoas Creek will continue until treatment units are
built and operated pursuant to the cleanup plan. This current and past discharge
appears not to have created problems, sec comment 3J.
•. Look lato a more structured relajectioa program. :
Rfspoai* - The remediation plan currently calls for a reinjection program on-site. Details of
this program are due to be submitted in January 1990. When reviewing the
detailed program this comment will be considered.
o. Is IBM going to continue to reuse water to Irrigate trees that bear crops which are sold?
Response - The remediation plan does call for continued irrigation of fruit trees on IBM's
property.
a. Have drought conditions beea takea lato account? ~™"~
-Response • Contingency 2 of the Remedial Action Plan specifically addresses cleanup
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Responsiveness Summary
SUMMARY OF COMMENTS AND STAFF R£SPONSES
3. CROUNDU'ATTR
a. Increase reuse to IOCS.
Response - The SCR have been amended to increase the reuse goal from 50 to 100%.
b. Reuse should b« naximlted oa aad off site.
Response - see Response 3 .a.
c. Consider growing hay oa aearby Uad aad irrigatiag with rcclalaied extracted groaadwater.
Respoose - The Regional Board does not have the authority to specify how groundwater is to
be reused. A specific proposal from IBM regarding reuse is required oy
December IS. 1988 as a SCR task. The Regional Board staff will review and
approve this proposal and then forward it to the State Board for their review, as
required by State Board Resolution 88-88. This proposal will also be available for
public review at the Regional Board office and at the Santa Teresa Library.
Implementation of the plan most likely will require further Board action to adopt
reclamation requirements.
d. IBM should be required to coat tract aad test appropriate facilities wberercr recharge or
direct reuse Is feasible.
Response - Specific proposals for ground water treatment and reuse must be submitted to the
staff and Board for approval prior to implementation. Also, aee Response 3.c.
e. Market treated groaadwater.
Response - See Response 3x.
f.. Chemicals should Bot be allowed to eater Great Oaks Water Company (COWC) aapply wells
doe to recharge.
Response - Staff will review any proposals for recharge to reasonably assure that water
supply wells and beneficial uses will aot be adversely impacted. A significant
factor in this concern which is beyond the control of IBM and the Regional
Board is the rate aad duration of pumping by the local water wen, including
COWC, which potentially could draw pollutants from the IBM site to their wells
•wgardka «f what is doae at the aite.
g. Plume movement should not be allowed taring recharge.
, Response • The cleanup plan requires that during remediation the plume of chemicals, as
defined by the 0.25 HI, not expand.
h. Avoid BSC of recharge ponds Bales* a severe drought exists.
Response - See Response 3.C. — •-
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SUMMARY OF COMMENTS AND STAFF RESPONSES
h. Cleanup should be to ion-detectable levels !• order to comply with the Noi-degradatlon
Policy.
Response - The Non-degradation Policy requires reasonable cleanup. Staff does not believe
that cleanup to non-detectable levels can be justified as reasonab^ given
technical and economic constraints and the need to conserve groundwater.
I. Cost should tot b« considered when establishing cleanup levels.
Response - Cost is only one consideration, others include beneficial uses, technical
feasibility, drinking water standards, and the need to conserve groundwater. In
addition, under CERCLA costs mu*t be Cvnside.eu wLwu «>»1»«UU» twinedial
action plans.
J. Support the Hazard ladex approach to aettiag cleaanp levels.
Response - aoae
k. Recommead establishiag a carcinogenic Hazard ladex goal of 0.25.
Response - The Remedial Action Plan's Hazard Index (HI) goals are DOW 0.25 for non-
carcinogens and 1.0 for carcinogens. The reasons for the different indices
include: 1. The chemicals of primary concern, the ones which have migrated off-
site, are in aon-carcinogens; 2. The carcinogens are essentially confined to on-
site in the shallow A aquifer, which, while it is a potential drinking water
source, is not now used for drinking water, .and 3. The method of calculating the
two indices are not the same, with the non-carcinogen index based on laboratory
data and the carcinogen index based on statistical,analysis, therefore setting the
° same value does not have a basis. Objectives of the investigations and studies to
date are not detailed enough to define the extent and aature of cleanup that
• would be needed to reach a CHI of 0.25. For the above reasons, at this time staff
does not recommend modifying the CHI or delaying a final decision. However,
staff believes this is a valid concern and has therefore added a requirement that
such a modification be evaluated when doing the five year evaluation of the
Remedial Action Man.
1. Pumping should not continue since the froaadvater Is Already safe to Iriak.
Response - The protection of beneficial uses, ia tikis case driakag water supply, is just one
of the goals of this cleanup plan. The other major goal m to implement the State's
non-degradation policy by cleaaiag op the water to the extent reasonable*. la
addition, cleaning up to below drinking water standards adds aa extra level of
*" . protection should those standards change ia the future or if future spills or leaks
occur.
SB. Require each separate operation to meet the «ae la a million caacer risk reqairemeat.
Response - The remediation plan requires all groundwater to be cleaned apjo the 1.0 CHI,
or one in million additional cancer risk. Putting separate requirements on each
operational unit would not increase the cleanup of the groundwater.
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b. Cleanup should b« permanent.
Response - The remedittioD plan will implement a permanent cleanup of pollutants in
groundwater and soil along with continued monitoring to assure the effectiveness
of the cleanup. Permanent destruction of the pollutants is possible under the plan
. using air pollution control equipment. The Plan relies on the permitting process
' of the Bay Area Air Quality Management District to protect public health and
the environment from exposure to airborne pollutants. A decision on whether
permanent destruction of the pollutants is necessary will be made by the
BAAQMD based on their permitting process. An analysis of the impact of air
pollutants in the plan shows insignificant impact, i.e. i maximum of less than a
one in ten million increased risk of cancer due to exposure to untreated air
emissions.
c. The final cleanup should mot rely OB dilation.
Response > The remediation plan relies primarily on the extraction and treatment of
Irouhdwater to meet cleanup goals. The need to conserve groundwater does limit .f
the amount of extraction feasible. Also, there will be aome dilution through ,
natural processes. However, dilution is not t major method of meeting the
cleanup goals.
d. Permanent destruction of pollutants nslag Innovative technology Is seeded.
Response - Innovative technology was addressed in the draft remediation plan. See Response
2.b.
e. Final cleanup levels should not be based on drinking .water action levels.
Response - Cleanup levels are based on two major bases contained in Federal and State law,
regulation, and policy. Pint is a legal requirement for the protection of the
beneficial uses of the grouadwater. This requires that the groundwater be cleaned
up to at least potable drinking water levels. The second basis is the State's policy
to maintain the existing high quality of the waters of the state (non-degradation
policy), which requires cleanup to the extent reasonable. Available information
indicates that cleanup to • hazard index (HI) of 0.25 for non-carcinogens and a
1.0 HI for carcinogens, which is much more stringent than most drinking water
standards, meets the nondegradation goal. The remediation plaa does allow for »
even stricter kveb if information gathered during the cleanup shows that further
removal of chemicals ii reasonable or *
f. Cleanup levels abovld not be arbitrarily set
Response - Cleanup levels are based on drinkiag water requirements tad the extent of
chemical removal that is technically and economically reasonable. Also, see
Response 2.e. above. ' .
g. Concern abbot fnture changes la acceptable levels «f chemicals la drinking water.
Response - The remediation plan allows the Regional Board to modify'Cleanup goals if
drinking water standards are modified in the future. Abo, the cleanup goals in
the plan are below the current standards, which allows an extra margin of safety.
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SUMMARY OF COMMENTS AND STAFF RESPONSES
The following comments ore summarized from the submitted written comments and oral com-
ments and testimony made during the evening staff workshop of August II and the Board Public
Hearing of August 17. The key to the person or agency responsible for the comment is shown
previously; correspondence is at Appendix D and verbal comments are from transcripts or the
staff meeting summary.
l.EDENVALE CAP
•.There should be additional coatrol of froandwater passing through the EHcarale Gap.
Response - The remediation plan, established cleanup goals throughout the plume area.
including the Edenvale Gap. The groundwater at the Gap will need to be
controlled by IBM to meet those goals. Staff has amended the Site Cleanup
Requirements (SCR) to include additional limits at the Gap of 30 ppb for Freon
and TCA and 0.6 ppb for DCE. These additional limits further define the
distribution of chemical concentrations within the cleanup goals and should
assure no additional degradation of groundwater beyond the Gap.
b. Continuous »oa1toriag shoald be required at the Gap walls.
Response - The remediation plan includes a self monitoring plan which requires frequent
monitoring of all monitoring and extraction wells in and near the Edenvale Gap
area. This monitoring plan Is based upon extensive past data.
e. Current restrictions oa movement .of chemicals should reaaln IB the remedlatioa plan.
Response • The current limits oa chemicals passing through the Gap are 10 ppb for TCA
and Freon and 0.5 ppb DCE. These limits were viewed as interim when they
were adopted by the Regioaa] Board with the understanding that they would
most likely not apply whea the Board established the (then tentative) final
cleanup foals of 0.25 NCHJ. These limits have been revised as described in
Response la. to be consifteaf with the overall remediation plan.
d. Add concentration limits for TCA a»d Freon at the Gap.
Response- See Response la. above.
«. Add pumping monitoring wall at the Gap. _
Response - Staff concurs that this would help assure better monitoring of groundwater
passing through the Gap and has added this requirement to the SCR.
2. CLEANUP LEVELS •
a. Support prop i cleanup goals.
Response -
10/5/88 -1-
-------
10
s. The 40 ug/1 effluent limitations for TCA and Freon 113 are too low for an in-
stanteous maximum limit. The limits should be 60 ug/1 or higher for each
chemical.
t. IBM requests clarification of the "flow through 96-hour bloassays', and of
the relationship between these bloassays and the bioassay test program
requested by the Regional Board In Its 12 August 1988 letter.
u. If receiving water limitations apply to groundwater discharges routed through
storm sewers, the quality of the receiving water should be judged based on the
concept of no net adverse Impact, taking Into account upstream water quality
when appropriate.
Non-Editorial Comments - Groundwater Self "Monitoring Program
v. Revision to Section C. 1 - Violation of Requirements to change criteria on which
an increase in sample collection and analysts Is based
w. Revise language in Section C.3.d regarding Self-Monitoring Plan Revisions. Add
language that specif les when regular sampling frequency will resume.
-------
t> Board should use Consent (rather than unilateral) format to address issues
which may need to be reopened.
c. IBM does not concede that the RWQCB has the Juhsdictional power to Issue the
proposed Order.
d IBM does not concede that Its activities have created a condition or threat of
pollution or nuisance, or a significant threat to the environment.
e. Revision to indicate that other possible sources exist for chemicals found in
the area beyond Edenvale Gap.
f. Clarification that the RWOCB will continue to regulate the IBM cleanup,
whether or not IBM continues to be considered as a CERCLA site.
g. Soil remediation goals should be 100 times the applicable DHS drinking water
action level or equivalent rather than Ippm for each chemical of concern. Also,
soil remediation goal should only be applied in areas where there's a reason-
able potential for exposure.
h. IBM notes that CERCLA Section 121(e) appears to provide an exemption from
compliance with CEO A or other permitting rules.
1. IBM suggest deletion of the proposed Prohibitions, or at a minimum, editorial
changes as mentioned in * 13 above.
j. Chemical concentrations to be used in Hazard Index calculations should be
running annual averages calculated quarterly.
k. Revision to remove goal of 50% reuse of extracted groundwater.
1. Add Specification 6 which acknowledges the possible impacts on the
groundwater levels of users other than IBM
m. Various changes to task submlttal dates.
n. Delete Provision 13. It is covered by the provisions of Water Code Section
13271.
Non-Editorial Comments - NPDES Permit Tentative Order
o. The flow rate limitation for Waste 003 should be revised from 1.0 MGD
to2.5MGD.
p. Revise paragraph tn Finding 6 on 'Description of Waste 005' to state that the
polluted groundwater produced from intermittent sample collection Ham-all
aquifer zones will be considered on a case by case basis. Further revise that
same paragraph to state that treatment and disposal of groundwater produced
from aquifer testing of the A-aquifer zone wells will be on a case by case
basis.
a IBM should have the option of monitoring the oil and grease limitations as
- either oil and grease or as total organic carbon. ^^
r. IBM should not be held accountable for effluent limitations that are beyond its
control due to the natural environment
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... .8
IBM's Comments on Tentative Orders for 5CRs and NPDE5 Permit
6. Editorial Comments - SCRs Tentative Order
a. The phrase "organic chemicals' should be used 1n place of "organic solvents'
b. IBM objects to the use of the terms "pollution' and 'pollutants'.
c. Minor language changes In Finding 8 - Effects on Water Supply Wells.
d. Revision to clarify that IBM is not solely responsible for groundwater changes
in the Santa Teresa Basta
e. Incorrect number of alternative plans evaluated.
f. Clarify that recharge of significant amounts of groundwater is expected after
January31. 1989.
g. Correction to make a more accurate statement about the meaning of an NCHI of
1.0.
h. Clarification of language In Finding 19 regarding remediation levels.
i. The remediation goals in Table 2 and Specification 4 apply only to the
transm fsslve areas of the A-aqulfer zone.
j. Clarification to confirm that the cleanup plan is consistent with the
provisions of the Water Code and the Health and Safety Code.
((.Clarification of language In Prohibitions to specify what actions do or do not
constitute violations, and confirmation that pollutant migration which is not
considered a violation under Specification 3 would not be considered "signi-
ficant migration" under Prohibitions 2 and 3.
1. Incorrect table references shown In denominators in the equations for
computing the Hazard Indices.
m. Specification 7 to include a list of Initial compliance wells.
n Change of language In Provision A on completion delays.
o Language change In Provision 6 on Quarterly Monitoring Reports.
p. Minor language change In Provision 1 \ regarding Board access to IBM
documents.
Editorial Comments - frfflPES Permit Tentative Order
q. Modify language In Finding 12 regarding effluent limits.
r Language change regarding re-evaluation of the permit
• s Incorrect table references shown In denominators In the equations for
computing Hazard Indices.
4> Non-Editorial Changes - SCRs tentative Order _^_
a. Better definition needed regarding grounds for reopening the remediation plan
for further Board review or action,
-------
•
. The soil cleanuo qoal should be 100 times the annuals
DHS drlnklna water action level or eoutvalent
j
Miscellaneous - Total Number of Comments • H
Prooer monltorlna should he onrformprl
;. IBM should remain a orooosed CERCLA «;iti»
. If Technical Assistance Grants are not available., |RM
should be encouraged tq out uo an eoulvalent amount Qf
money to substitute for the Federal oroorarp
. There are no oreclse recharge caoacl ty estimates,, y*fr
. Board should Investigate ways to limit oaoerwork
associated with develoolng cleanuo olan«
. Need more leadershlo and less averaging of oolnlon Ip
deciding critical Issue^
. Board should develoo more and better nubile education mat-
erials oartlcularlv with reoard to nubile safety and rlsjf
How long until the treatment svstems are built and ooerattn
••^^
fl?
Strike the enf&rcement paragrabh CD") In the Plan, it
ha*? IRM hnllrlnn Itself
Board should write a new order reoulrlng that IBri brino
In surface water and Infect It at their nronerty line to keeo
CTY
iBMHM
DHS
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i
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-------
i. Air Emissions icontlnuem
f. How soon will you evaluate foe effectiveness of the
scrubbers? '. _•
£11
£11
seme.
g. What problem would there be In putting the scrubbers on
the air strtoners before the strlooers are un? _
h Will vaoor recovery go on ?Q year9 or beyond If 1 pom
Is not met. or will It continue only until recovery levels
oftj?
15.Cost -Total Numbernf Comments - S
a. Cost relative to Hazard Index and amount of water should be
nnhll chert
b. Multiple bureaucracies cause delayjnd Increase costs.
c. IBM should spend whatever It takes to restore the water.
d. Board should focus on what Is beat for public health and the
Ironment
is IBM paying far all of the water they're Dumping out of the
Soli Cleanup - Total Number of Comments - 5
steam infection win work with vaoor recovery, the otl
-------
roundwater Reuse (continue)
Does the olan say we're going to oumo untreatable water
Into Canoas Creek?
Look Into more structured reinjectlon: Dump v< jter back
to Just south of the IBM site, rein ject into aauifer then
recycle by oumolng out again
Is IBM going to continue to reuse water to Irrigate trees
that bear croos that are going to bg gp|07
Have you taken Into account the oosBtblllty of drought
conditions contlnulno?
10 you have any Intent of forcing the SCVWD to blend the
peused water Into our existing water sy^terp^
rfhat objection does the SCVWD have to discharging the
treated water Into their oercolatlon nonds?
How much of the system to of oe the reused water to
market ta IBM oolnn to oav?
Ir Emissions - Total Number of jpommants - 8
ipn't allow Freftn emission into air (to protect ozone lay
tfha* haonpns to the material that's volatilized when
vmi mirtfv the water? i« it released to the atmosohcre?-
Do you add together all Jie nearby sources of air oolliitio
"hpn rtpfprfnlnlnd what standards are aooroorlate to mee
blTY
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•
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RETAILFRS
.
— — ••—
-------
. Cleanuo Levels (continued)
.). Suooort Hazard Index aonroach to setting cleanuo levels
Ic Carclnoaenlc hazard Index of 0.25 recommpndPrt
K Pumolno should not continue since water Is already safe
nr Reoulre each seoarate IBM ooerailon (the electronics
shoo machine shoo, etc.) to meet the one cancer death,
oer million reoulrement .__
13. Groundwater Reuse - Total Number of Comments - 27
a. Increase reuse to lOQ^V
b Reuse should be maximized pn and off ^|fp
c. Consider growing hay on the unused land nearby. Irrigate
It with reclaimed wntejr
d IBM should be reoutred to construct and test aooroorlate
1 facilities wherever recharge or direct use Is, feasible
e Market treated oroundwatpr
f Chemicals should not be allowed to enter Great Oaks
o. Plume movement should not be allowed during recharge —
h Avoid use of recharge ponds unleaa a severe drought exist
1. Treated groundwater should not be hlPnrtPfl into existing
1 Don't nut anv unclean water Into the underornund basin — _
1. Discharge of treated groundwater to Canoas Creek Is
beneficial because It suDDorts Guadaluoe River fishery
QITY
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-------
p • "»• ••»•" VF» \~\* m 11.111 «j in ntJrVJJi
7*1ttfrS
Edenvale Can - Total Number of fpmjnents - 9
. rfccO COnLIUIS at tuGnVdlc G2P ^ .-
Want continuous monitoring at Gan
. Current restrictions on movement of contaminant
should remain In cleanuo oermlL
. Add numerical concentration levels for TCA and Frebri
at the Gao. consistent with the overall 0 25 I^UPI
. Add DumDlng: monitoring well at the Rai)
Cleanuo Levels - Total Number of Comments - 22
^SuDDprt oroDosed cleanuo goals -
, Need oermanent ct?3nuo*
Cleanup should not be by dHutfon
Need oermanent destruction of oollutants using
Innovative technoloot***
Should not use drinking water action k ts for
cleanun leveta
Cleanuo levels siiOulL not be arbitrarv • > ] '
Concerned amut future changes In what are now consider
£|eanun should be to non-detectable based on the
Cost should not be considered In determining cleanup level
Jt M
CITY
5d
Is
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it ion Btr^BAHVLO
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-------
3 Gro'jndwater Reuse - The primary concerns were for the maximization of reuse
and for what the treated water should or should not be used, with 27 comments
made by 6 groups, this issue ranked first in significance to the commentors.
CBE/ WATER
CITY CTY DHS EPA F&6 PUBLIC SVTC SCVWD RETAILERS TOTAL
1 1 14 2 4 5 22
4 Air Emissions - The major area of Interest was in assuring that atr scrubbers
would be part of the air treatment system. Eight comments were received on this
general topic, from 3 different groups, making the issue rank fourth in local
interest
CBE/ WATER
CITY CTY DHS EPA F&G PUBLIC SVTC SCVWD RETAILERS TOTAL
6 1 1 B
5. Cost - Interest was expressed in focusing less on the cost of cleanup and more
on the 'quality' of the cleanup. Five comments came in from the public on this
issue, ranking It fifth along with Soil Cleanup.
CBE/ WATER
CITY CTY DHS EPA F&6 PUBLIC SVTC SCVWD RETAILERS TOTAL
5 _ &
6. Soil Cleanup - The exploration of steam Injection as a soil cleanup method was
the issue most frequently raised. Three different groups made a total of 5
comments on this general topic, causing It to-rank fifth along with Cost
CBE/ WATER
CITY CTY DHS EPA F&G PUBLIC SVTC SCVWD RETAILERS TOTAL
' 3 f ' • 1 5
7. Miscellaneous • Fourteen comments on other diverse topics were made by two
groups. This category seemed appropriate (or those comments.
CBE/ WATER
CITY CTY DHS EPA F&G PUBLIC SVTC SCVWD PETAILEPS TOTAL
Q S 14
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IBM RESPONSIVENESS SUMMARY
The purpose of this Responsiveness Summary Is two-fold: first, It provides the
Regional Water Quality Control Board with Information about the community's
general concerns about the site and their preference regarding the proposed
cleanup plan, and second, 1t demonstrates to members of the public how their
concerns were taken into account as part of the decision making process.
Six major issues were raised regarding the IBM Tentative Orders and Proposed
Final Cleanup Plan. These were: the need for additional controls or monitoring at
Edenvaie Gap concerns about the adequacy and appropriateness of the cleanup
Levels, how much Groundwater Reuse ,s enough, Air Emissions, the Cost of
Cleanup, and Soil Cleanup. Concerns which did not fall into these categories art
addressed in the section titled Miscellaneous. A separate section addresses IBM's
comments.
A description of each issue and general information about who raised that
Issue follows. A table which summarizes the general comments begins on page 3.
IBM's comments can be found on page 8. Staff's response to all comments follows
that. .
DESCRIPTION OF MAJOR ISSUES
1. Edenvaie Gap - The primary concerns were for continued monitoring and/or
controls at the Gap. This issue ranked third in terms of number of comments,
with a total of 9 comments being made by 5 different groups.
CBE/ WATER
« CITY CTY DHS EPA T&6 PUBLIC SVTC SCVWD RETAILERS TOTAL
1 11 3 3 i
2 Cleanup Levels - General Interest was expressed in what the actual cleanup
levels are, and in how they were established Beyond this, concerns varied widely.
Some felt that pumping should cease since the water was already safe, others felt
cleanup should continue until chemicals were non-detectable. This issue ranked
second m terms or number or comments made, with 22 comments coming m from 5
groups. -
CBE/ WATER
CITY CTY DHS EPA F&6 PUBLIC SVTC SCVWD RETAILERS TOTAL
2 12 33 2 22
«• City -City of San Jose, Cty- Santa Clara County, DHS-Department of HeelthServtees. EPA-
Environmental Protect ion Agency, F&O-Fiah&tene, Public -People uneffilteted with any of the other
groups, or members of public Interest groups such as the League of Women Voter? C&&/SVTC • Citizens
for e Better Environment/Silicon Valley Toxics Cool I lion, SCVWD - Santa Clare Valley Water District
-------
at* •» CoWomia f Ck ; of He: - Wvkts
AUG301988
-j • .
\4iorandum
QUALITY CONTROL BOARD
Steve Ritchie ' Augu , l9E
Executive Officer ...
California Regional Water Quality *»i»e" Tenti Order for
Control Board Bite Clet nd K?:zs
San Francisco Bay Region Permit f c . , EE: Jose
1111 Jackson Street, Room €040 Santa Cli -unty
Oakland, CA 94607 W43-000 c M
Clifford L. Bowen, P.E.
District Engineer
Monterey District
Public Water Supply Branch
The subject document has been reviewed as requested have
the following recommendations;
1. SITE CLEANUP LEVELS
The proposed remediation lavala for tha B- and ^er
aquifers are 0.25 NCHX for noncarcinogens and 3JI fcr
carcinogens (Reference aourca: Sita Cleanup I re*
ments, paga 5, Item 120). Tha Department of I i
Services, Public Water Supply Branch, concur! tha
prescribed .25 VCHZ levels for noncareinogenc, .:ver,
va racomnend applying tha sane level of ha z arc ax at
0.25 for tha carcinogens found in the IBM cent ation
aita as final cleanup lavala for that groundwtv
2. PLUME CONTROL XT AND BEYOND EDENVALE GAP
We concur with tha objactivea of Regional BOL: IBM
Cleanup plan to (1) protect public health ELTK
environment, (2) be tachnically feasible, tnc
cost-effective (Reference aourca: Sita Cletr.
Requiraaanta, paga 4, Xtaa IIS). Tba goal oi
Drinking Water Program is to assura that vatc rs t: f
to tha axtant poaBible, provided a raliable r of
aafa drinking vatar at all times. We, there: ctrc: :.y
recoamend that tha aquifers used for doneetir iy
purposes ba protected against contamination
maximum extent poaaibla within reasonably '
aconomical limits. Consequently, we atr
maintain optimal plume control at tha F
critical sona of chemical capture of t'
Program in order to minimize tha relr ^i.
- beyond tha Gap and into tha undefir Ic ; .
Since Region II aquifers ara extent. ' ^v.
, stream municipal and private communit. tic
supply, tha ralaasa of chemicals beyon, -ulc
directly impact tha watar quality of the vat
sources of these downstream uaara. Tho&c L
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Hazardous
Informc
US
Phi]
Kr. sr -e Ritchie
Page 2
August 29, 1988
levels permitted under the subject order should not be
used to condone contamination up to those levels where
the release of those contaminants can be minimized by
available technology and economically feasible measures.
3. EXTRACTED GROUNDWATER REUSE „ ' '
The Department of Health Services recognizes that the
extracted groundvater generated in the IBM Cleanup
Program is a significant resource which should not be
wasted. We support the State Water Resources Control
Board's Resolution No. 88-88 to maximize beneficial reuse
of the extracted groundvater. We further concur with the
Regional Board's proposed treatment levels at 1 ppb or
less of total volatile organic chemicals for extracted
water to be recharged into the groundwater rquifers
(Reference source: IBM Superfund Sits Fact Sheet f3,
July 1988, pags 6). These proposed level* for the
extracted vatsr would be adequate from a public health
standpoint to not compromise the beneficial use of the
recharged groundwater aquifers for subsequent domestic/
drinking purposes*
•4o Please forward copies of all correspondence, report*
and documents pertaining to compliance vith the Site
Cleanup,Requirement* to the Department of Health Services
- Public Water Supply Branch (Reference source: Site
Cleanup Requirements, C. Provisions, Item- fio, pages
14-15).
We appreciate the opportunity to provide technical review and
evaluation relating to rater supply issues of the IBM Cleanup
Program. For further questions on this matter* please contact
Catherine 6. Ling at (415) 540-2160.
cc: IBM Mailing List«
Retail Water Agencies
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