United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-91/060
June 1991
&EPA Superfund
Record of Decision:
FMC (Fresno Plant), CA
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50272-101
REPORT DOCUMENTATION 1" REPORT NO. I ~ 3. Reciplent'8 Acc:eulon No.
PAGE EPA/ROD/R09-91/060
4. TIle IIId SUb1I1Ie 5. Report Dete
SUPERFUND RECORD OF DECISION 06/24/91
FMC (Fresno Plant), CA
6.
First Remedial Action - Final
7. Author(8) 8. Perfonnlng Organization RepI. No.
.. I'erfonnlng Orgalnlzatlon Name IIId Add- 10. Pl'ojectlTuklWOI'k Unit No.
11. Contnct(C) or Gr.nt(G) No.
(C)
(G)
1~ SponaorIng Org8lU8tlon Name IIId Addre88 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Noles
16. Abell'8ct (UmI1: 200 worda)
The 17-acre FMC (Fresno Plant) site is an active pesticide manufacturing facility in
Fresno, California. Surrounding land use is primarily industrial, but several
residential areas are within 1 kilometer of the site. The site overlies two
unconsolidated sand zones that are a potential source of ground water, and have been
contaminated by site operations. Since 1931, various agricultural product operations
have been conducted onsite including sulfur processing, and fertilizer and pesticide
manufacturing. Wastewater from liquid pesticide formulation was discharged to a
4.92-acre area of the site via a trench during the 1960's and 1970's. From 1963
until 1974, wastewater from oil drum cleaning operations was stored in an
above-ground tank and was sprayed on a concrete evaporation slab in an oil drum yard.
A former disposal pond area was used for the disposal of fertilizer process wastes
from 1967 to 1972. From 1972 until 1983, a wastewater evaporation pond was used for
the discharge of wastewater, including oil drum washing rinsate. From 1976 until
1988, a rainwater percolation pond was used to collect surface runoff from
non-production areas of the site. These waste disposal practices have led to
contamination of onsite soil and ground water. In 1980, FMC excavated a portion of
the contaminated
(See Attached Page)
17. Doament An8IyaIa L De8crlpto18
Record of Decision - FMC (Fresno Plant), CA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE, toluene, xylenes), other organics (dioxin, PAHs,'
organochlorine and organophosphorus pesticides, phenols), metals
II. Identilier8/Open-Ended T...... (arsenic, chromium, lead)
c. COSA TI FIeIdIGroup
18. Avlilabllty SI8temant 1.. Security CI... (Thia Report) 21. No. 01 Pagea
None 120
20. Security CI... (Thl. Page) 22. PrIes
Nnnp
See ANSl-Z3I.18 See '""rrucli~ on Rewrae
(Formerly NTlS-35)
DepartmentOICOmnMWes
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EPA/ROD/R09-91/060
FMC (Fresno Plant), CA
First Remedial Action - Final
Abstract (Continued)
soil in the oil drum yard. In 1983, discharge to the wastewater evaporation pond was
discontinued. In 1985, 1,500 cubic yards of contaminated soil were excavated from the
waste pond. In 1989, this pond was lined with a synthetic liner. Investigations by
FMC under EPA oversight from 1989 to 1991 characterized and quantified site.
contamination, affected media, and probable source areas. This Record of Decision
(ROD) provides for remediation of onsite source areas and restoration of ground water
as a final remedy. The primary contaminants of concern affecting the soil and ground
water are organochlorine and organophosphorous pesticides; although VOCs including PCE,
TCE, toluene, and xylenes; other organics including dioxin, PAHs, and phenols; and
metals including arsenic, chromium, and lead also are present.
The selected remedial action for this site includes excavating approximately
25,000 cubic yards of contaminated soil from onsite source areas, and treating the soil
using soil washing and stabilization technologies; backfilling the excavated areas with
treated soil; treating soil wash water using carbon adsorption; capping unpaved and
excavated areas including the 4.92-acre wastewater evaporation pond, oil drum yard, and
percolation pond; onsite pumping and treatment of ground water using filtration, air
stripping, and carbon adsorption; reinjecting or reusing the treated ground water
onsite; providing an alternate water supply to onsite or offsite well users, if
necessary, to eliminate adverse affects to ground water treatment; monitoring ground
water; and implementing institutional controls including deed, land, and ground water
use restrictions. The estimated present worth cost for this remedial action is
$17,310,681, which includes an annual O&M cost of $445,163 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Clean-up standards for soil are based on a
carcinogenic risk level of 10-4 and an HI=l. However, when combined with capping and
institutional controls, the selected soil remedy attains a 10-6 carcinogenic risk
level. Ground water cleanup standards are based on the more stringent of Federal or
State MCLs or non-zero MCLGs. If these standards do not exist, State Action Levels,
site-specific Health-Based Levels, or Quantification Limits will be used.
~
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RECORD OF DECISION
FMC-FRESNO SITE
FRESNO CALIFORNIA
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DECLARATION
for the FMC-Fresno
Superfund Site
SITE NAME AND LOCATION
FMC Pesticide Formulation Facility
Fresno, California
STATEMENT OP BASIS AND PURPOSE
This decision document presents the selected remedial action
for the FMC-Fresno site in Fresno, California chosen in accor-
dance with the Comprehensive Environmental Response, Compensa-
tion, and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA), and, to the extent
practicable, the National Oil and Hazardous Substances Contin-
gency Plan (NCP). This decision is based on the administrative
record for the site.
The State of California concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an im-
minent and substantial endangerment to public health, welfare, or
the environment.
DESCRIPTION OF THE SELECTED REMEDY
Final groundwater and soil remedies have been selected for
the FMC-Fresno site. The selected groundwater remedy is as fol-
lows:
institutional controls restricting installation of on-
site water wells;
extraction of contaminated groundwater;
treatment of contaminated groundwater using air strip-
ping and carbon adsorption technologies; and
reinjection or re-use of treated groundwater.
continued groundwater monitoring to ensure the effec-
tiveness of the remedy.
The selected soil remedy is as follows:
institutional controls restricting future residential
use of the site;
excavation of contaminated soils which exceed selected
cleanup standards (these soils constitute the principal
threat at the site);
treatment of contaminated soils using soil washing and
stabilization technologies; and
capping of excavated and unpaved portions of the site.
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The cost of the groundwater remedy is estimated to be
$7,207,027 and the cost of the soil remedy is estimated to be
$10,103,654, resulting in a total project cost of $17,310,681.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy uses per-
manent solutions and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element. Due to thesig-
nificant depth of soil contamination, this remedy will result in
hazardous substances remaining on site above health-based levels.
A review will be conducted within five years after commencement
of remedial actions to ensure that the remedy continues to
provide adequate protection of human hea~th and the environment.
".2~
Date
Dan~el W. McGovern
Regional Administrator
U.s. EPA Region 9
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Record of DecisioD
DC-PreSDO Site
Concurrence -- Hazardous Waste Management Division
11 on, D1rector
ous Waste Management Division
"-24 -4/
Date
-------
aecord of DecisioD
ftC-PresDO sit.
Concurrence -- Water Management Division
--112i.J1L Ja 0~
~Darry Seraydar~an, D~rector
I~ater Management Division
Co-~~ L
Date
-------
Record of Decision
DC-Fresno Site
Concurrence -- Air and Toxics Division
6' J). ,I
Date
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In
aecord ofD8cisioD
PKC-PresDO site
Concurrence -- Assistant Regional Administrator
tftt.;.u .~
Nora cGeee
Assistant Regional Administrator
~/~
Date
-------
Record of Decision
DC-FreSDO site
Concurrence -- Office of Regional Counsel
-.:1>...1-"''-1. ';1,' .1. ~hlJ.."'v-{_.L
Nancy Ma el
Office of Regional Counsel
~ /;21 /9/
I I
Date
-------
~
Laura Yos 1., Deputy
Waste Programs
Record of DecisioD
FKC-PreSDO Site
Concurrence -- RCRA Program
6/ur /'1/
. . Date
Director
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Table of Contents
~
Declaration
I.
site
Deser iption. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1 .
II.
site History and Enforcement Activities.............
History of Site Activities.....................
History of Enforcement Activities..............
Highlights of Community Participation...............
2
2
3
III.
4
IV.
Scope and Role of Response Action...................
5
V.
Summary of Site Characteristics.....................
Groundwater Contamination......................
Soil Contamination............... ..............
6
7
8
VI.
Summary of Site Risks............................... 11
Human Health Risks............................. 11
Environmental Risks............................ 14
Health-Based Cleanup Levels.................... 14
VII.
Description of Alternatives......................... 15
A.RA.Rs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 15
Cleanup Standards.............................. 18
Groundwater Alternatives....................... 21
Soil Alternatives.............................. 24
VIII~
Comparison of Alternatives.......................... 30
Groundwater Comparative Analysis............... 31
Soil Comparative Analysis...................... 33
IX.
The Selected Remedy................................. 36
Selected Groundwater Remedy.................... 37
Selected Soil Remedy........................... 38
X.
Statutory Determinations............................ 41
XI.
Documentation of Significant Differences............ 44
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1.
2.
3.
4.
Location
Facility
Geologic
Selected
List of Fiaures
Map
Map
Cross-Section
Groundwater Contaminant
Plumes (Second Sand Zone)
List of Tables
Groundwater Contaminants and Cleanup Standards
Soil contaminant Summary
Soil Cleanup Standards for Indicator Chemicals and Summary
of Soil Contamination by site Area
Summary of Carcinogenic Risk and Non-Carcinogenic Risk
Cost of Selected Remedy for Groundwater
Cost of Selected Remedy for Soil
1.
2.
3.
4.
s.
6.
Appendix A
A-l.
.A-2.
A-3.
A-4.
A-s.
Appendix B
ADDend ices
Description of Federal ARARs
Description of State ARARs
Description of TBCs
Identification of Federal ARARs for Groundwater and
Soil Alternatives
Identification of State ARARs for Groundwater and Soil
Alternatives
Response Summary
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DECISION SUMMARY
I.
SITE DESCRIPTION
Name and Location
The FMC-Fresno site is located in the south end of the city
of Fresno, California, as shown in Fiqure 1. The facility oc-
cupies approximately 17 acres of land, bordered on the north by
Church Ave., to the east by a spur of Atchison, Topeka and Santa
Fe Railroad, and to the south and west by South Sunland Ave. The
current physical layout of the FMC facility is shown in Fiqure 2.
Much of the site is now occupied by pesticide formulation build-
ings, warehouses, and offices. A 4.92-acre area of land at the
north end of FMC's property is vacant and unused. A waste pond
and rainwater percolation pond that are no longer in use are lo-
cated on the property immediately south of the 4.92-acre area.
The majority of the remainder of the property is paved and con-
stitutes the active plant. The entire FMC property is fenced.
TODOqraDhv and Ecoloqv
The FMC-Fresno site is on the east side of the San Joaquin
Valley, the southern section of the Great Valley Geomorphic
province of California. The ground surface at the site is flat,
at an elevation of about 284 feet above sea level. There is a
maximum relief of about 2 feet except where ponds have been ex-
cavated for the collection of surface drainage or waste disposal.
The majority of the site is paved with the exception of the 4.92
acre-area which is sparsely vegetated by weedy grasses.
Adiacent Land Uses
The area within 0.5 km of the site is primarily industrial;
however, within 0.5 to 1 km of the site there is a playground and
several residential areas, including the outskirts of the town of
Calwa. Additional residential areas and several schools are lo-
cated within 1 to 2 km of the site.
Surface Water and Groundwater Resources
There are no naturally occurring surface water bodies or
wetlands on the site nor within a one mile radius of the site.
The nearest surface water body is the San Joaquin River, which is
located app~oximately 4.5 miles to the northeast of the site.
Rainfall at the site averages 9.8 inches per year. The FMC-
Fresno facility is equipped with sumps, drains, and berms which
are designed to capture surface water runoff; however, surface
runoff has been observed to flow off the site and collect on Sun-
land Ave. .
1
.;:. J . ~,
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FIGURE 1
0 Wmchell
School
P Shopping
Center
Sequoia Jr.
High School
CHURCH AVE
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SCAI.( aN II t,
8ECHTEl ENVIRONMENTAL. INC.
,... '...C"(e
II
Q
DRY WEll, 4 FEET IN DIAMETER
INACTIVE DRY WELl! AS OF 1117111
o
SfPTIC TANK
FMC FRESNQ
OTHER POTENTIAL SOURCES
II!! STAINED ARfAS IDENTIFIED ON AERIAL PHOTOGRAPHS,
POTENTIAL CONTAMINANT
SOURCE AREAS
-------
The San Joaquin Valley is a large structural trough which
has been filled by sediments eroded from mountain ranges to the
east and west. These sediments are more than three thousand feet
thick beneath the FMC-Fresno site. Unconsolidated sediments un-
derlying the Fresno area contain the majority of groundwater.
These sediments have been divided into six major units, only two
of which, the older alluvium and continental deposits, are
present beneath the site. Groundwater in the area is extracted
primarily from the older alluvium, which is generally unconfined,
although semi-confined conditions occur locally.
Beneath the site, several lithologic units have been
delineated to a depth of 100 feet, and in particular two water
bearing sand. zones have been characterized. These are il-
lustrated in the geologic cross section shown in Figure 3.
During the period 1983-1989, the water table beneath the site
declined more than 17 feet. CUrrently, the water table is ap-
proximately 72 feet below land surface and the direction of
groundwater flow is to the north-northwest. Several municipal,
industrial and private supply wells exist within the vicinity of
the site. These wells are typically screened beneath the first
and second sand zones mentioned above. Groundwater quality in
the area is generally good, with the exception of elevated
nitrate levels. Pesticides and volatile organics have been also
been detected in municipal supply wells upgradient and
downgradient of the site; although FMC-Fresno site does not ap-
pear to be the source of this contamination.
II.
SITB HISTORY AND ENFORCEMENT ACTIVITIBS
Historv of Site Activities
Industrial operations at the FMC-Fresno site began in 1931,
when Sun land Sulfur Company began processing sulfur for agricul-
tural uses. In 1946, Sunland started formulating fertilizers and
dry pesticides in addition to sulfur products. FMC bought the
facility in 1959, and added the formulation of liquid pesticides
to plant activities.
Several waste handling operations have been conducted at the
facility. Wastewater from the liquid formulations was discharged
to the 4.92 acre-area via a trench during the 1960's and 1970's
(Figure 2). From 1963 to 1974, FMC collected wastewater from oil
drum cleaning operations in a 600,000 gallon above-ground tank
and sprayed the collected wastewater onto a concrete evaporation
pad which was located within the current oil drum yard. Fer-
tilizer process wastes are believed to have been disposed in the
former disposal pond area from 1967 to 1972. In 1972, FMC con~
structed a wastewater evaporation pond (waste pond) into which
wastewater was discharged. Rinsate from the oil drum washing
operation was also discharged to the waste pond. In 1976, a per-
colation pond was constructed and began receiving runoff from
non-formulation areas of the site.
2
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FIGURE 3
B
B'
300 _
RAILROAD SPUR
W-9 W-8
RAILROAD
S. SUNLAND
> '.I.STSANQZO'NE . .•
:'-" 2ND SAND 20NE ;••
T.D. 118.5 FT.
T.D. 120.4 FT.
T.D. 151 .OFT
100 200 300 feet
I I I
I— 300
~- 250
LU
LU
LL
- 200 §
LU
- 150
100
100
HORIZONTAL SCALE
(VERTICAL EXAGGERATION: 4 TIMES)
EXPLANATION:
Clavev Sift S». Clay Typically brown, dry to slightly damp. Stiff,
Trace of fine -grained sand seams.
Sandy Sift: Typically brown, damp to wet, dense, slightly
cemented.
Sand. Sihv Sand: Typically brown, fine to coarse grained,
medium dense.
Screened interval
Total depth of test hole from ground surface.
BECHTEL
SAN FRANCISCO
FMC FRESNO
GEOLOGIC SECTION B • B'
1801?
FIGURE 1.2.7
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In 1980, FMC excavated an unknown volume of contaminated
soils from the north side of the oil drum yard, which is now
paved. In 1983, FMC discontinued wastewater discharge to the
waste pond. Approximately 1500 cubic yards of visibly con-
taminated soils were excavated from the waste pond in 1985. In
1988, FMC discontinued use of the percolation pond. In 1989, the
waste pond was lined with a synthetic liner in order to comply
with the California Toxic Pits Cleanup Act (TPCA).
Historv of Federal and state Enforcement Activities
The FMC-Fresno site is currently regulated under both the
Comprehensive Environmental Response, compensation, and Liability
Act (CERCLA) and the Resource Conservation and Recovery Act
(RCRA). A description of regulatory activities which have oc-
curred under both federal and state programs, is provided below.
In 1979 the California Regional Water Quality Control Board
(Regional Board) requested that FMC initiate a groundwater
monitoring program after the Regional Board conducted an inspec-
tion that revealed the potential for groundwater contamination
from the site. FMC subsequently conducted groundwater and soil
sampling in conjunction with the Regional Board and the Califor-
nia Department of Health Services (DHS).
. In August, 1980, FMC submitted a Notification of Hazardous
Waste Activity to EPA under Section 3010 of RCRA, identifying the
FMC-Fresno plant as a generator and a treater/storer/disposer of
hazardous waste. On November 18, 1980, FMC submitted a RCRA Part
A permit application to EPA, as a treater and storer of hazardous
waste. On March 30, 1981, DHS issued an Interim Status Document
for the FMC-Fresno plant. On November 22, 1982, DHS requested
that FMC submit a permit application for hazardous waste opera-
tions and an Operating Plan (the State equivalent of a RCRA Part
A permit application). FMC submitted the application and plan on
March 18, 1983.
In January 1983, FMC ceased discharge to the waste pond.
The waste pond was subsequently drained later in 1983 as FMC
began to meet regulatory requirements for closure of the pond.
In 1985, approximately 1,500 cubic yards of contaminated soil
were excavated from the waste pond and disposed at an offsite
facility.
On October 15, 1984, the FMC-Fresno site was proposed for
inclusion on the National Priorities List (NPL), EPA's list of
the nation's most urgent hazardous waste sites. In 1985, DHS
turned over the regulatory lead for the site to EPA. In Decem-
ber, 1986, EPA and FMC signed a Consent Order, a legally binding
agreement, requiring FMC to perform a Remedial Investigation/
Feasibility study (RI/FS) for the site. The site was removed
from the NPL by an October 4, 1989 rulemaking which determined
that RCRA facilities subject to the Hazardous and Solid Waste
3
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Amendments (HSWA), with a non-recalcitrant and non-bankrupt
potentially responsible party (PRP), should be cleaned up under
RCRA authorities where possible (RCRA deferral policy). However,
qiven that an existinq Consent Order was in place and an RIIFS
was underway, EPA decided to complete the RIIFS process. The
Remedial Investiqation was conducted in two phases. EPA approved
the Remedial Investiqation report on Auqust 24, 1990, and the
Feasibility Study report was approved on May 21, 1991. EPA com-
pleted the Risk Assessment Report for the site on September 21,
1990.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The CERCLA requirements for public participation include
releasinq the RI and FS reports and the proposed plan to the
public and providinq a public comment period on the RIIFS and
proposed plan. EPA met these requirements by placinq these docu-
ments in the public information repositories established for the
site and mailing copies of the proposed plan to individuals on
the mailinq list. Furthermore, EPA conducted a public meetinq on
May 28, 1991 durinq which the proposed plan was presented and
comments were accepted.
To date, the followinq community relations activities have
been conducted by EPA at the FMC-Fresno site:
December 1987
Community relations plan for the site was
completed.
March 1987
EPA distributed a Fact Sheet announcinq the
siqninq of an Administrative Order on Consent
for the RIIFS and the completion of the work
plan, samplinq plan, and quality assurance
plan for the RI.
EPA distributed a Fact Sheet announcinq the
completion of the first phase of the RI,the
beqinninq of the second phase of the RI, and
the deletion of the site from the NPL.
October 1988
April 6, 1989
July 27, 1989
Administrative Record sent to the Fresno
County Central Library.
, First Supplement to the Administrative Record
sent to the Fresno County Central Library.
November 1990
EPA distributed a Fact Sheet announcinq the
availability and results of the RI and Risk
Assessment reports.
April 10, 1991
Second Supplement to Administrative Record
sent to the Fresno County Central Library.
4
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May 2, 1991
EPA sent an advance copy of the Proposed Plan
to the Fresno City Council.
A public notice was published in the Fresno
Bee announcing the availability of the
proposed plan and Administrative Record and
announcing the dates of the public meeting
and public comment period.
May 3, 1991
May 6, 1991
EPA distributed the proposed plan fact sheet
via a mailing list. The fact sheet explained
the results of the RIfFS and EPA's preferred
plan for cleaning up the site. The Fact
Sheet also announced the date of the public
meeting and the public comment period. A
Spanish version of the fact sheet was also
distributed via a mailing list and bilingual
media sources.
May 8, 1991 -
June 7, 1991
Public Comment period for the proposed plan
and RIfFS.
May 24, 1991
Third Supplement to Administrative Record
sent to the Fresno County Central Library.
EPA briefed representatives of the City of
Fresno on the proposed plan.
May 28, 1991
EPA conducted a public meeting during which
the proposed plan was presented and comments
were accepted. The meeting was simul-
taneously translated into Spanish.
EPA has prepared the attached response summary which
provides EPA's responses to comments submitted in writing during
the public comment period, and to comments that were presented
during the May 28, 1991 public meeting (see Appendix B).
May 28, 1991
IV.
SCOPB AND ROLB OF THB RBSPONSB ACTION
The response actions selected in this ROD address the
groundwater and soil contamination caused by operations at the
FMC-Fresno site. Cleanup of contaminated groundwater and soil
as described by this ROD, constitutes a final remedy for the
site. Within the FS and ROD, separate groundwater and soil al-
ternatives have been presented. Protective groundwater and soil
remedies are both required in order to reduce the cumulative risk
from all contaminants at the site to acceptable levels.
The primary objective of the response action for groundwater
is to restore contaminated. groundwater to its beneficial use as
drinking water. Furthermore, the groundwater response action ob-
5
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jectives are to prevent ingestion and contact with contaminated
groundwater, prevent inhalation of volatile organic compounds
(VOC)s in groundwater, and prevent continued migration of
groundwater contamination offsite. In addition to meeting risk-
based objectives, the groundwater response action is required to
meet all Applicable or Relevant and Appropriate Requirements
(ARARs). The response action addresses contaminated groundwater
through the use of institutional controls, groundwater extraction'
and treatment, and continued monitoring.
Surface and near-surface contaminated soils contaminated by
pesticides, herbicides and other contaminants constitute the
principal threat at the site through exposure via direct contact
and ingestion. The response action addresses this principal
threat through a combination of excavation, treatment,. contain-
ment, and institutional controls. Deep subsurface contaminated
soil at the site constitutes a low-level threat through continued
migration to groundwater. The response action addresses deep
soil contamination through containment (capping), institutional
controls, groundwater extraction and treatment, and continued
monitoring.
The combination of groundwater and soil response actions
will ~esult in an lifetime carcinogenic risk level less than
1X10- and a non-carcinogenic Hazard Index of less than 1, and as
a result will be within EPA's acceptable risk range. Specific
cleanup standards for groundwater and soil have been established
for the site and are discussed in subsequent sections of this
ROD.
The response actions described by this ROD, address
groundwater and soil contamination currently existing at and
emanating from the site. The response actions address soil and
groundwater contamination beneath and emanating from physical
structures at the site; however, the response actions do not ad-
dress the physical structures themselves (e.g. buildings, 600,000
gallon tank, smaller waste tanks, solid waste storage areas, pes-
ticide drum storage area, hazardous waste compactor, dry wells,
and hazardous waste and rainwater sumps). These structures, and
the facility as a whole, shall continue to be regulated under
RCRA and 40 CFR P~rts 264 and 265, as appropriate.
V.
SUMMARY OP SITE CHARACTERISTICS
The Remedial Investigation for the site was conducted in two
phases during which samples of surface soils, subsurface soils,
and groundwater were collected throughout the site, from nearby
offsite locations, and from potential background areas.' The sam-
pling effort was followed by chemical analyses of over 100 com-
pounds, many which were present above detection levels in the
various media.
6
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Groundwater Contamination
. The groundwater monitoring network at the FMC-Fresno
facility consists of 29 wells. Water quality data from addi-
tional offsite municipal and industrial supply wells was also ob-
tained. The location of these wells is shown in Figure 4.
Groundwater in both the first and second sand zones is con-
taminated. Groundwater contamination beneath and downgradient
from the site is believed to have originated from past wastewater
discharges to the oil drum yard area, the south central portion.
of the 4.92 acre-area, the waste pond, and the site sumps and/or
dry wells. Pesticide contamination in groundwater appears to be
limited to the vicinity of the site; however several site-related
contaminants have been detected in downgradient wells. The
downgradient extent of groundwater contamination emanating from
the site has not been completely defined, and will require fur-
ther investigation during the remedial design phase. A complete
list of those chemicals detected in groundwater and their maximum
concentrations is presented in Table 1. .
Numerous contaminants have been consistently detected in
groundwater from the first sand zone. These include endosulfans,
dieldrin, casoron, monuron, dimethoate, DNBP (dinoseb), 4,6-
dinitro-o-cresol (DNOC), pentachlorophenol (PCP), toluene, ,
chloroform, 1,2-dichloropropane (DCP), and trichlorethylene
(TCE). Many of these groundwater contaminants are also present
in the second saturated sand zone; although concentrations
detected in the second sand zone are typically lower than those
detected in the first.
The relationship between the second sand zone and underlying
aquifers in the vicinity of the site is not well-documented.
However, the onsiteFMC Supply Well which is reportedly screened
at a depth of 200 - 300 feet has not shown measurable levels of
contamination to date. This well is used to provide water for
onsite drinking and industrial uses, and is tested regularly.
This suggests that aquifers underlying the first and second sand
zones have not been contaminated by chemicals from the site.
Pesticide concentrations in groundwater in the vicinity of
the site range from less than one part per billion (ppb) to 1,100
ppb (dimethoate), but are generally on the order of tens of ppb
(see Table 1). Pesticide groundwater plumes appear to be fairly
restricted in horizontal extent. To illustrate this, Figure 4
shows the areal extent of toxaphene contamination within'the
second sand zone.
Volatile compounds frequently detected in onsite and
downgradient samples include chloroform, DCP, and TCE. 'DCP has
been detected onsite at a maximum concentration of 5,200 ppb, and
has been detected downgradient from the site at 10 ppb, which
exceed the maximum contaminant level (MCL) of 5 ppb (see Table
1). As indicated in Figure 4, the DCP groundwater contaminant
plume extends at least a thousand feet downgradient from the
7
-------
TARI.E I
CHEMICAI...SPECIFIC ARARs AND QUANTITATION LIMITS
FOR GROUNDWATER CONTAMINANTS (ppb)
(
Maximum EPA EPA California California Quantitatlon PRC Selected
Chemkal Conftn. MCL MCLG MCI.. Action Umlt Health-Rased Clean-Up
tratlon (I) (I) (2) l..ev~I(2) (3) Goal I..nel
Acelone 5,100 10 431 431
Aldrin 3.4 0.05 0.05 0.0009 0.05
Aluminum 72,000 1,000 200 --- 1,000
Ar5enic 17 50 50 5 0.44 50
Dendin (Bennuralin) 96 10 2,590 2,590
BHC-bela 0.52 0.3 0.05 0.()086 0.3
BHC-gamma (Undane) 3.3 0.2 0.2 4 0.05 0.0119 0.2
Bis(2-elhylheK)'l) phlhalale 39 4 10 1.11 4
Bolero (Thiobencarb) 6.1 70 25 86.2 70
Bromodichloromelhane 40 100. 5 0.0595 100
Carbon lelrachloride 13 5 0 0.5 5 0.0595 0.5
Ca!iOron (Dichlobenil) 29 0.25 4.3 4.3
Chlordane 4.7 2 0.1 0.5 0.0119 0.1
Chloroaniline (4-) 13 10 0.442 0.442
Chlorobenzene 140 100 100 30 5 86.2 30
Chloroform 126 100. 5 1.27 100
Chloronitropropane 0.34 0.05 --- 0.05
Chromium (Iolal) 1,500 100 100 50 10 43.1 50
Cyclohexanone 420 50 21,600 21,600
DCPA (Daclhal) 2.3 0.25 4,310 4,310
DDD 2.5 0.1 0.0645 0.0645
DDE 0.83 0.1 0.0455 0.0455
DDT 3 0.1 0.0455 0.0455
Diazinon 1.4 14 I 17.24 . 14
Dibromochloromelhane 7.9 100. 5 0.0921 100
Dibromochloropropane (DBCP) 110 0.2 0 0.2 0.25 0.0055 0.2
Dichloroelhane (1,1-) 6.5 5 5 431 5
Dichloroethene (1,1-) 4.9 7 7 6 5 0.0129 6
Dichloroelhane (1,2-) 12 5 0 0.5 5 0.0851 0.5
Dichloropropane (1,2-) 5,200 5 0 5 5 0.114 5
Dieldrin 4.5 0.05 0.1 0.001 0.05
Dimelhoale 1,100 140 1.3 1.72 140
DisYSlon 9 0.35 0.345 0.345
. "
Page lof2
-------
TABLE I
aiEMICAL4»iJKCIFIC ARAfts AND QUANTITATION LIMITS
FOR CROUNDWATER CONTAMINANTS (ppb)
Chemical
DNBP (Dinoseb)
DNOC
Endosulfan 1
Endosulfan II
Endrin
Elhion
Elhyl Paralhion
Elhylene dibromide (EDO)
Hcplachlor
Methyl ethyl kelone
Methyl paralhion
Monuron
Nitrate
Oxadiazon (Ronstar)
Oxyfluorfen (Goal)
Penlachlorophenol
Tedion (Telradifon)
TEPP
Tetrachloroelhane (1,1,2,2-)
Telrachloroelhene
Toluene
Toxaphene
Trichloroethane (1,1,1-)
Trichloroelhane (1,1,2-)
Trichloroelhene
Xylene
Zinc
Maximum
Concen-
Iration
31
1.3
2.5
2.1
1.8
8.5
6.7
6.5
0.79
1.200
2
22
140,000
4.1
0.14
1,200
5.4
3
20
3.8
29
86
. 3.7
5.5
207
.7
11,000
EPA
MCL
(1)
7
0.2
0.05
0.4
10,000 (N)
5
1,000
3
200
5
10,000
5,000(SMCL)
KPA
MCLC
(1)
7
2
0
0
0
0
1,000
200
0
10,000
California
MCL
(2)
0.2
0.02
0.01
45,000 (NO3)
1
5
5
200
32
5
1,750
California
Action
l*vel (2)
35
30
30
30
100
QnanUtattoa
Limit
(3)
0.35
1.25
0.05
0.1
0.1
10
0.3
0.25
0.05
10
0.6
5
10
0.5
0.5
50
1
40
5
5
5
1
5
5
5
5
20
PRC
Health-Based
Goal
8.62
—
0.431
0.431
2.59
4.31
1.12
0.0001
0.0034
216
2.16
—
—
43.1
25.9
0.967
—
—
0.0387
0.152
1,290
0.0141
388
0.136
0.704
8,620
1,720
Selected
Clean-Up
Level
7
1.25
0.431
0.431
0.2
35
30
0.0001
0.01
216
30
5
10.000
43.1
25.9
30
1
40
1
5
1,000
0.0141
200
32
5
1,750
5,000
MC1.G- MCL Goal
FOOTNOTE:
MCL- Maximum ConUminMt Level SMCL - Secondary MCI.
(I) Reference: Region IX EPA Drinking W.ler Standards A Health Advisory Table. January 1991.
(2) Reference: Summary of California Drinking Water Standard*. California Department of I leallh Services. October 1990.
(3) Quanlilatkm limit b the CLP Contract Required Quanlilalion/Detenion I Jmil (CRQL/CRDL) or 5 times the Method Detection Limit (MDL).
• Total trihatomethana
Page 2 of 2
-------
"
,
,
,
,
,
"
,
.
,10' "
I "
\ . \
, \
" ,
"'_1
1
~
<
....,
e,:,
~
a::
.0
~
<
l-
V)
<
L..:
FIGURE 4
+
.N
.
CITY OF FReSNO
WfLL NO.;6
4.92 ACRe AReA
(UNPA VED) .
OIL DRIJM YARD
~
-DCP
....... TOXAPk£N£
~ 1.t SAND ZONE WONITORINCi WELL
. 2nd SAND ZONE wONITOI!ING WUL
. 1.t AND "rid ZONE ClUS'TtR Of' WONITORING WE!.l..S
. HAZARDOUS WASTE SUMPS
I ~ TANK PADS
~ 150' 300' 450'
~ I I
APFROXI\oIA it: s:,,~
.
TOXAPHENE & 1.2-
DICHLOROPROPANE (DCP)
GROUNDWATER CONTAMINANT
PLUMES. 2nd SAND ZONE
rMC - FRESNO SITE
&qo'
ft
m
-------
site. At least five. contaminants have been detected in
groundwater downgradient from the site in excess of the selected
cleanup standards. These include DCP, DBCP, ethylene dibromide,
BHC-gamma (lindane), and nitrate. Additional groundwater inves-
tigation will be required to determine the downgradient extent of
contamination. Furthermore, it is possible that several of the
contaminants detected onsite and downgradient of the site
(including TCE and chloroform) may have originated, at least in
part, from upgradient sources. However, upgradient contaminant
concentrations and background levels at the site have not been
thoroughly characterized.
Levels of total dissolved solids (TDS) beneath the middle of
the FMC-Fresno site are higher than levels upgradient and
downgradient, suggesting that the facility has contributed to in-
creased levels of TDS in shallow groundwater. Similarly, nitrate
levels beneath the middle of the FMC-Fresno site are higher than
upgradient and downgradient levels, suggesting that facility has
also contributed to elevated levels of nitrate. Nitrate levels
onsite and downgradient from the site exceed MCLs.
Heavy metal concentrations in samples from wells beneath the
FMC facility exceed MCLs for several contaminants. The maximum
concentrations of aluminum, and chromium exceed MCLs, while man-
ganese, and zinc exceed secondary MCLs. Furthermore, the onsite
concentrations of these chemicals exceed the concentration ranges
detected in upgradient wells.
Soil Contamination
Although soil contamination is present throughout much of
the site, the majority of contaminants and highest concentrations
are found within several specific site areas. Table 2 presents a
complete list of contaminants detected in soil, frequency of
detection, and maximum concentration. Table 3 summarizes the
concentration of indicator chemicals in surface and near surface
soils within each of the site areas containing significant soil
contamination. The selection and use of indicator chemicals and
their respective cleanup standards is discussed in the "Soil
Cleanup Standards" section of this ROD. As can be. seen from
Table 3, contaminonts are present beneath the following site
areas in excess of the selected cleanup standards: the 4.92
acre-area, the waste pond, the oil drum yard, tank pads, stained
soil areas, and in the vicinity of several hazardous waste sumps
(see Figures 2 and 4 for the location of these site areas)
A discussion of soil contamination within each of these site
areas is provided below. .
4.92 Acre-Area: Contaminants detected in the 4.92 acre-area are
believed to have originated from wastewater discharged to the
area in the 1960's and 1970's. Contaminants detected in the
highest concentrations and greatest depths are found in portions
of the area where ponding of wastewater occurred (e.g. the south
8
-------
. ..-:- -- _.~-;---:-. :'" /.,. .
TABLE 2
SOIL CONTAMINANT SUMMARY (ppm)
DETECTION MAXIMUM
FREQUENCY % CON CENTRA nON
CHEMICAL
Acetone
AJdrin
Aluminum
Arsenic
Azinphos-methyl
BHC-alpha
BHC-beta
BHC-gamma
Baytex
BeneCin
Benefin/trifluralin
Benzo( a )anthracene
Benzo(a)pyrene
Benzo(b,k)f1 uoranthene
Bis(2-ethylhexyl) phthalate
Botran
Bromodichloromethane
Bromoform
CIPC
Carbaryl
Carbofuran
Carbon disulfide
Carbophenothion
Casoron
Chlordane
Chlormephos
Chloro.2,2,I-f1uoroethane (1,1,2-)
Chlorobenzene
Chloroform
Ch lorothalonil
Chromium (total)
Chrysene
Copper
Coumaphos
Cyclohexanone
Cythion/ethyl parathion
DCPA
DDD
DDD/Endosulfan IJII
DDE
Page 1 of 3
1.6
10.9
100.0
59.8
0.5
2.5
28
9.2
2.7
0.9
100.0
1.8
1.8
100.0
1.8
1.3
2.9
0.6
42.9
3.0
1.4
100.0
10.1
4.4
3.2
13.6
3.5
1.7
5.5
0.8
100.0
1.8
100.0
0.5
10.5
66.7
0.8
17.0
100.0
31.1
37
170
15,000
13
1
1.6
7.4
24
140
0.032
7.9
0.22
0.14
0.28
0.97
0.24
0.3
0.59
100
19
'0.28
11
480
3.3
35
6.1
0.68
73
21
0.0076
92
0.17
82
1
630,000
600
0.0095
480
5
310
-------
,
TABLE 2
SOIL CONTAMINANT SUMMARY (ppm)
CHEMICAL
DETECTION MAXIMUM
FREQUENCY % CON CENTRA nON
DDT
DEF
DHBP
Di-~-butyl phthalate
Diazinon
Dibrom/phorate
Dibromochloromethane
Dibromochloropropane
Dibromoethane (1,2-)
Dichloroethane (1.2-)
Dichloropropane (1,2-)
Dichloropropene (trans-l,3-)
Dic10ne
Dieldrin
Dimethoate
Dimethylphenol (2,4-)
Dinitro-o-cresol (4,6-)
Diphenamid
Disyston
Endosulfan I
Endosulfan 1/lI
Endosulfan II
Endosulfan sulfate
Endrin
Ethion
Ethyl benzene
Ethyl parathion
Ethylene dibromide
F1uoranthene
Heptachlor
HpCDDs (total)
HpCDFs (total)
HxCDFs (total)
IPC
Iron
Isophrone
Kelthane
Lead
Malathion
Manganese
40.9
9.7
13.0
3.4
3.5
100.0
2.3
23.7
2.9
1.2
15.5
0.6
0.3
32.6
1.7
1.8
3.0
0.9
7.8
40.7
42.9
33.9
9.6
11.5
26.9
14.3
6.8
5.0
1.8
3.8
.66.7
66.7
77.8
14.3
100.0
24.6
0.9
39.5
14.7
100.0
1,300
1,100
250
4
120
230
2.7
89
11
1.5
38
0.14
0.02
100
24
1
0.074
0.37
280
360
3,000
190
19
98
3,000
160
S40
6.7
0.13
2.5
0.0051
0.0038
0.0018
63
23,000
59
0.22
27
4,600
6,500
Page 2 of 3
-------
TABLE2
SOIL CONTAMINANT SUMMARY (ppm)
CHEMICAL
Methiocarb
Methoxychlor
Methyl parathion
Methylene chloride
Methylnaphthaleae (2-)
Naled
Naphthalene
Nitrophenol (4-)
Nitrosodiphenylamine (n-)
OCDD
OCDF
Oxadiazon
PCNB
Pentachlorophenol
Phoratc
Pyrene
TCDDs (total)
TEH (as diesel fuel)
TEH (as gasoline)
TEPP
Tedion
Temephos
Tetrachloroethane (1,1^2-)
Tetrachloroetbene
Toluene
Toxaphene
Trichloroethane (1,1,1-)
Trichloroethane (1,1,2-)
Xylenes (total)
Zinc
DETECTION
FREQUENCY %
1.9
13
0.9
3.5
153
6.8
5.1
8.5
1.8
88.9
66.7
0.8
6.9
36.2
10.7
1.8
11.1
100.0
100.0
5.1
18.5
0.5
19
2.9
9.1
11.1
12
23
215
100.0
MAXIMUM
CONCENTRATION
52
17
12
3.4
300
6,100
140
8.8
6.1
0.027
0.0033
0.026
13
65
2,000
0.17
0.00022
220
4,200
15
59
10
5.3
0.75
14
15,000
0.24
1.9
6,200
456
Page 3 of 3
-------
HBU
Area
Cardnogenlc DBL (3)
Noncarcinogenic DBL
4.92-Acre.. ..... ......:.
Background
Off-site
Dry Formulation
Dry Well
Fonner Disposal Pond
Truck Unloading
HWS ..:. .:....: :. ::.':\:):;':){'. .
Oil Drurn Yattt
Old Lab Waste
Percolation Pond
Raitt_tet Sump:::?
Runoff Pond
... on .... .n" .
StaineaSO~.I:::::':
Tank Pad ~
wasfePond'
TABLE 3
SURFACE AND NEAR SURFACE son~ CONTAMINATION BY AREA
MAXIMUM CONCENTRATION (ppm)
Aldrin
21.8
2.4
}:.100....:..
0.002
/8.1
\5,6\>
0.018
0.084
..... .. '. .
.::::170.::.::.
> ..\:).9>
.:::.?37:i
Dieldrin
23.2
4.0
..::::.:...::..52':::..
0.008
0.28
0.008
0.095
0.25
c..:
.."~
1.2
.':.{5O,
0.84
'100
Tom-
phene
337
DDT (1)
1,092
-- 43.2
: IS,(XK) :..':'.:': 750.
0.41
0.83
0.87
11
0.74
'...~:'..
230
22
:. t~400d
55
0.43
2.69
:: 1,510.
dlS3 .....
0.397
2.4
9.2
:1~700.:....
\206:.:..:..
\670'"
Endo- lIepta- Dime-
Chlordane lIulfan8 (2) EBB chlor DlllJlton PIaonte thoate
285 --- 2.2 82.6 - - -
4.8 4.0 -- 40 3.2 8.0 1'.0
:....".. 8.7 1,100 0.27 1.3 i:.64di '47 t 0.7
0.12
4.6
0.12
0.08
2.75
Id{ 550 d.:. c 6.7
1/ .. ~;. OJ)68
0.004
FOOTNOTE:
(1) IlICIudinl ODD, DOH.
(2) IlICIudinl encbulfu I and encIo8ulfu IL
(3) Cardnocenlc r-lth-l8ed dean-up IeYeIs (HOL) - derived baed on an acas carcinogenic risk of Iln 10,000 (IB.04); noncardJlO&ellIc HUlA - baed on a hazard Inda or 1.
The 8elected HUL for a contaminant, beiq hllhlllhted, II the most ~tl1/e HOL value.
0.78
..
..:..:280...:.: ..:.:'..2,000..
47/: 1.1
0.08
4
0.16
::...14.8,
1.49
>.93/
1.63
0.39
2.6
0.01 ~..::;.
0.002 0.23
:UO
. P. . ....
:'.:'3,000.:
2.S
2.4
>61Q
..6.2)
1.8
1.1
I
.:. .1 Concentration --r. the eelec:ted H81..
-------
central portion of the area and in the vicinity of the former
disposal pond). In ,these portions of the 4.92 acre-area, con-
taminants have been detected at depths in excess of 50 feet.
50il contamination in the remainder of the 4.92 acre-area is
primarily restricted to the top 10 to 20 feet below the surface.
50il contamination beneath the 4.92 acre-area tends to decrease
with depth.
contaminants detected in the hiqhest concentrations in sur-
face and near-surface soils (ie. less than 15 feet below the land
surface) include the endosulfans (I and II), DDT series (DDT,
DDE, DDD), toxaphene, malathion, ethion, xylenes, and ethyl ben-
zene. The contaminants detected in the highest concentrations at
depths in excess of 50 feet include DHBP, PCP, and
dibromochloropropane (DBCP). Dioxins and furans were also
detected in samples from the 4.92 Acre-Area and Oil Drum Yard;
althouqh dioxin/furan analyses was limited to only eiqht samples.
wast. Pond: The contaminants detected in the hiqhest concentra-
tions in soils beneath the waste pond include endosulfans,
malathion, ethion, and xylenes. These chemicals, alonq with
others includinq PCP, DBCP, cyclohexanone, isophorone, and
4-nitrophenol were detected at depths as qreat as 50 to 55 feet
below the qround surface. The constant head of wastewater in the
pond while in use was likely responsible for migration of con-
taminants to depths in excess of 50 feet. A qradual decline in
the levels of contamination in soils is observed beneath the
waste pond.
oil Drum Yard: Contamination in the oil drum yard is present in
the hiqhest concentrations and the qreatest depths in the north-
east corner of this area. The contaminants detected in the
hiqhest concentrations include endosulfans, DDT series,
toxaphene, total extractable hydrocarbons (TEH), cyclohexanone,
and xylene. Twenty-one organic contaminants have been detected
beneath the oil drum yard at depths in excess of 50 feet includ-
inq the following: endosulfan I and II (93 ppm), DDT (84 ppm),
aldrin (34 ppm), and dieldrin (11 ppm). The concentration of
contaminants at depths of 50 feet or qreater beneath the oil drum
yard are siqnificantly hiqher than contaminant concentrations at
comparable depths beneath the 4.92 acre-area and waste pond.
Furthermore, the concentrations of these contaminants do not con-
sistently decrease with depth, as they do in the 4.92 acre-area
and the waste pond. It is likely that enhanced miqration of pes-
ticides has occurred beneath the oil drum yard as a result of
their dissolution in solvent (cosolvation). The solvents
cyclohexanone and xylene are present on oil drum yard soils at
concentrations on the order of thousands of parts per million
(ppm).
Hazardous wast. and Rainwater Sumps: Effluent from wastewater
discharqes and rainfall onto the paved portion of the site are
collected by two separate systems of sumps. Twelve hazardous
waste and 20 rainwater sumps are present at the site. Or-
9
-------
ganochlorine and organophosphorous pesticides, chlorinated her-
bicides, volatile aromatics, and halogentated organics were
detected beneath several of these sumps. In particular, con-
taminants were detected below Hazardous Waste Sumps 2, 7, 9, and
12 and Rainwater Sump 14 at levels in excess of the selected
cleanup standards. Cyclohexanone is present beneath several of
the sumps at high concentrations (up to 630,000 ppm) and may have.
contributed to contaminant migration to depths in excess of 30
feet below some of the sump locations.
Tank Pads: Several tank pads are present onsite. Some of these
pads hold up to ten above-ground storage tanks. The contents of
these tanks have varied over time and it is likely that spills or
leaks from the tanks have occurred. Organochlorine and organ-
phosphorous pesticides, chlorinated herbicides, volatile
aromatic, and chlorinated organics have been detected in soil
beneath several of these tank pads. Soil contaminants are
-present beneath several of these tank pads at levels in excess of
the selected cleanup standards.
stained Soil Areas: Several areas of stained soils have been
identified from aerial photographs and may have been locations of
surface spills. Organochlorine pesticides are the predominant
contaminants detected in these areas. Soil contaminants have
been detected in these stained areas in excess of the selected
cleanup standards.
Other Areas: Soil contaminants have also been identified beneath
other areas of the site including the dry formulation area, dry
wells, former disposal pond, former truck unloading and washing
area, former laboratory waste area, percolation pond, runoff col-
lection ponds, and several offsite areas. soil contaminants
detected in these areas were not present in excess of the
selected cleanup standards.
VI.
SUMMARY OP SITB RISKS
The risks to human health and the environment at the FMC-
Fresno site are described in the site-specific risk assessment
report that was prepared by EPA. In this risk assessment, the
No-Action scenario was evaluated, assuming unrestricted access to
site contaminants (including soil and groundwater) and that all
ongoing treatment or mitigation measures (if any) are terminated
immediately. Evaluation of the No-Action scenario is a require-
ment of the NCP, and is taken to represent a baseline condition.
The information provided by the baseline risk assessment is then
used to characterize the current and potential threats posed by
the site to human health and the environment.
10
-------
-. -- . - --- .- --~ ~~--
---. ,..-
Human Health Risks
The risk assessment process consists of several major steps
including contaminant identification, exposure assessment,
toxicity evaluation, 'and risk characterization.
contaminant'Identification: As part of the contaminant iden-
tification process, the media of concern, soil and groundwater,
were first identified. For soil, specific depth ranges of con-
cern were identified. The surface soil zone selected under,
present site, conditions extends from the surface to a depth of
two feet. Soil conditions at depths greater than two feet were
not considered under present site conditions, becaus~ it was con-
sidered unrealistic to assume any direct contact or atmospheric
transport of the subsurface soils. The subsurface soi.1 zone
selected under future land use conditions extends vertically from
the surface to a depth of fifteen feet. The selection of this
depth interval assumes that if the site were developed, excava-
tion could bring subsurface soil to the surface, resulting in
potential human exposure.
soil contamination near the water table was also considered
in the risk assessment, in order to evaluate the effects of a
rise in the water table. As a result, soil contamination between
50 and 70 feet below land surface was evaluated for potential
health effects through exposure to groundwater. Soil contamina-
tion existing at depths between 15 and 50 feet below land surface
did not affect the risk assessment, due to th~ lack of an ex-
posure pathway.
Numerous contaminants have been detected in groundwater and
soil at the FMC-Fresno site. Several screening steps were per-
formed to identify contaminants to be used in the risk assess-
ment. These screening steps included elimination due to data
quality constraints, elimination due to unavailability of
toxicity data, and elimination due to comparison of contaminant
concentrations to background levels. As a result, 55 groundwater
contaminants and 59 soil contaminants were selected as chemicals
of concern to be used in the risk assessment. The manner in
which these chemicals are addressed by the selected remedies for
the site is discussed further in the "Groundwater Cleanup stan-
dards" and "Soil 'Cleanup Standards" sections of this ROD.
Exposure Assessment: The exposure assessment step of the risk
aS,sessment involves identification of current and future pathways
of exposure. The site is located within a primarily industrial
area, and is currently zoned for heavy industrial use. However,
residential areas are located within 0.5 - 1 km of the site, and
it is conceivable that residential use of the site could occur in
the future. Standard assumptions were used to estimate chemical
intakes for each route of exposure. Exposure scenarios as-
sociated with the site include both restricted and unrestricted
access conditions. The restricted access condition assumes cur-
rent use conditions with no development or new well construction.
11
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The unrestricted access condition assumes there is free access to
the site and the potential for new development, including con-
struction of new drinking water wells and family residences.
The following exposure routes were evaluated under restricted ac-
cess conditions: ingestion of groundwater, inhalation of soil as
dust, direct contact with groundwater, and inhalation of VOCs
from groundwater~ The following exposure routes were evaluated
under unrestricted access conditions: ingestion of groundwater,
ingestion of soil by children, direct contact with groundwater,
direct contact with soil by children, inhalation of soil as dust,
and inhalation of VOCs from groundwater.
Toxicity Assessment: Both carcinogenic and non-carcinogenic
chemicals have been identified in soil and groundwater at the
FMC-Fresno site~ Cancer potency factor (CPFs) have been
developed by EPA's Carcinogenic Assessment Group (CAG) for es-
timating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. CPFs, which are expressed in
units of mg/kg-day, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg/day, to provide an upper-bound es-
timate of the excess lifetime cancer risk associated with ex-
posure at that intake level. The term "upper-bound" reflects the
conservative estimate of the risks calculated from the CPF. Use
of this approach makes underestimation of the actual cancer risks
highly unlikely. CPFs are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for in-
dicating the potential for adverse health effects from exposure
to chemicals exhibiting non-carcinogenic effects. The RfD is an
estimate, with an uncertainty of perhaps an order of magnitude,
of a lifetime daily exposure for the entire population (including
sensitive individuals) that is expected to be without appreciable
risk of deleterious effects. Estimated intake of chemicals from
environmental media (e.g. the amount of a chemical ingested from
contaminated drinking water) can be compared to RfDs. RfDs are
derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied (e.g. to account for
the use of animal data to predict effects on humans). These un-
certainty factors help ensure that the RfDs will not underes-
timate the potential for adverse non-carcinogenic effects to oc-
'Cur .
Risk Characterization: Risk characterization is the last step in
the risk assessment process. At this point, the information from
the previous steps is combined to determine if an excess health
risk is present at the site. Excess lifetime cancer risks are
determined by mUltiplying the intake level by the cancer potency
factors. These risks are probabilities that 2re generally ex-
pressed in scientific notation ~e.g., 1 X 10-). An excess
lifetime cancer risk of 1 X 10- indicates that, as a plausible
upper-bound, an individual has a one in one million chance of
12
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,'<."j. '
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. \
developing cancer as a result of site exposure to a carcinogen
over a seventy year lifetime under. the specific exposure condi-
tions at a site. As is stated in the NCP (40 CFR Section
300.430(e», "For known or suspected carcinogens, acceptable ex-
posure levels are generally concentration levels that represent
an excess ~iper-bou~g lifetime cancer risk to an individual of
between 10 and 10 ".
Table 4 summarizes the estimated carcinogenic risk at the
site, based on a No-Action scenario. Carcinogenic risk is .
presented fc~ both mean and reasonable maximum exposure (RME)
conditions. Under restricted access conditions, unacceptable to-
tal carcinoaenic risk results under RME conditions at the FMC-
Fresno site; but the total carcinogenic risk is within the ac-
ceptable range. under mean exposure conditions. Exposure to con-
taminated groundwater, via ingestion and inhalation of VOCs,
which is expected to migrate offsite in the future contributes
most to the excess cancer risk. Dibromochloropropane, 1,2-
dichloropropane, ethylene dibromide, 1,1-dichloroethene, and ar-
senic contribute the majority of risk associated with the
groundwater pathway. For the offsite public, the only currently
complete exposure pathway is exposure to contaminated surface
soi~ through inhalation of dust; however the associated risk (8 X
10- )is negligible in comparison to that posed by exposure to
groundwater.
Under unrestricted access conditions at the FMC-Fresno site,
unacceptable carcinogenic risk results under both mean and
reasonable maximum exposure (RME) conditions. The routes of ex-
posure that contribute most to this risk are ingestion of
groundwater, ingestion of soil by children, direct contact with
soil by children, and inhalation of VOCs from groundwater. The
contaminants that contribute the majority of risk associated with
the groundwater exposure pathways are similar to those for
restricted access conditions. The contaminants that contribute
the majority of risk associated with the contact and ingestion of
soil are ethylene dibromide and toxaphene.
Potential concern for non-carcinogenic effect of a single
contaminant in a single medium is expressed as a hazard quotient
(HQ) (or the ratio of the estimated intake derived from the con-
taminant concentrations in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population is ex-
posed, the hazard index (HI) can be generated. The HI provides a
useful reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across
media. An HI in excess of 1 is generally regarded by EPA as rep-
resenting an unacceptable life-time, non-carcinogenic human
health risk.
Table 4 summarizes the estimated non-carcinogenic risk at
the site, based on a No-Action scenario. Non-carcinogenic risk
is also presented for both mean and RME conditions. Under
13
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TABLE 4
SUMMARY OF EXCESS CANCER RISK
RESTRICTED AND UNRESTRIcrED ACCESS
EXCESS CANCER RISK
0.1
I.000E-03
O.oI
IlESTlUcnD sm ACCESS
UNRE.Sn1cnD sm ACCESS
1.000E-05
1.000E-06
I.000E-07
1.000E-08
la/b
2aIb
3a1b 4a1b 5a1b 6aIb 7a1b 8a1b
EXPOSURE ROUTE SCENARIO
9a1b
lOaIb
SUMMARY OF HAZARD INDICES
RESTRICTED AND UNRESTRICTED ACCESS
IlESTIUCTED SITE ACCESS
UNIlESTIUCTED sm ACCESS
0.1
O.oI
1.000E-05
1a1b
2aIb
3a1b 4a1b Salb 6aIb 7a/b 8a1b
.EXPOSURE ROUTE SCENARIO
9a1b lOa1b
- MEAN
!Z21 RME
bIb:
2./b:
a./b:
bIb:
INGESTION OF GROUND WATER
INHALATION OF SOIL AS DUST
DIRECT CONTACT WITH C.W.
INHALATION OF vOCe rROM G.W.
bIb: INGESTION OF CROUND WATER
'./b: INGESTION OF SOIL BY CHILDREN
'../b: DIRECT CONTACT WITH CROUND WATER
la/b: DIRECT CONTACT WITH SOIL BY CHILDREN
h/b: INRA.LA.TION OF SOIL AS DUST
10./b: INHALATION or VOCI rROM C.W.
-------
restricted access conditions, unacceptable non-carcinogenic risk
(HI greater than one) exists under mean and RME conditions. Ex-
posure to contaminated groundwater, via ingestion and inhalation
of VOCs, which is expected to continue to migrate offsite in the
future, again contributes the majority of the risk. Dimethoate
contributes the majority of the risk associated with the
groundwater exposure pathway. .
Under unrestricted access conditions, unacceptable non-
carcinogenic risk also exists under mean and RME conditions. The
pathways and chemicals that contribute the majority of this risk
include ingestion of groundwater, ingestion of soil by children,
direct contact with soil by children, and inhalation of VOCs from
groundwater. Dimethoate, chlordane and disyston contribute sig-
nificantly to the risk associated with these exposure pathways.
Finally, a separate quantitative risk assessment for in-
direct exposure to contaminants found in deep subsurface soils at
the FMC-Fresno site was performed. The results of this quantita-
tive risk assessment for onsite exposure indicaied human health
risks in excess of a carcinogenic risk of 1X10- and in excess. of
a Hazard Index value of 1. The risk estimate for onsite exposure
to contaminants from deep subsurface soils that have migrated to
groundwater is comparable to the estimated risk from onsite ex-
posure to existing groundwater contaminants. Although the two
risk estimates are not additive, if the water table did rise sig-
nificantly and the existing groundwater contaminants now found
onsite were present, the resulting risk could be greater than
each individual risk estimate.
The estimated risk from offsite exposure to contaminated
groundwater resulting from contaminant migration from the deep
soils into groundwater is within the acceptable carcinogenic risk
range for the contaminants evaluated. No hazard quotients could
be calculated for these contaminants.
Environmental Risks
The FMC-Fresno site is located in a highly developed in-
dustrial area surrounded by agricultural and residential areas,
and no substantial populations of fish, wildlife, or game species
occur onsite or in the vicinity of the site. As a result, the
risk assessment did not evaluate environmental risks.
Health-Based CleanuD Levels:
Based on the results of the risk assessment, EPA has calcu-
lated health-based cleanup levels specifically for this' site.
The report entitled "Health-Based Goals for Remediation of the
FMC Pesticide Formulation Facility," calculates health-based ~oil
and groundwater concentrations that would result in a 1 X 10-
levels of carcinogenic risk and non-carcinogenic Hazard Index of
1. This study was based on results of the Remedial Investigation
14
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and Risk Assessment reports. Due to conservative assumptions in-
corporated into the Risk Assessment pertaining to future onsite
exposure pathways and the number of contaminants present, these
calculations were based on ingestion of contaminated soil and
groundwater under mean rather than RME exposure conditions. The
resulting carcinogenic and non-carcinogenic health-b~sed cleanup
levels were calculated for, each groundwater contaminant. For
surface and near-surface soil (0 - 15 feet), these calculations
were based on the ingestion of contaminated soil by children un-
der mean exposure conditions. The resulting carcinogenic and
non-carcinogenic health-based cleanup levels were calculated for
each soil contaminant. Health-based goals for exposure to deep
soils (50-70 feet) through ingestion of contaminated groundwater
were also calculated. A more complete discussion of the health-
based levels and their use at the site is presented in subsequent
sections of this ROD.
VII.
DESCRIPTION OP ALTERNATIVES
To facilitate the detailed analysis of alternatives with
respect to the nine evaluation criteria specified in the NCP, 40
C.F.R. Part 300.430, proposed site remedial alternatives were
separated into two components: groundwater cleanup alternatives
and soil cleanup alternatives. However, before beginning an in-
depth discussion of these alternatives, Applicable or Relevant
and Appropriate Requirements (ARARs) and selected cleanup stan-
dards are presented below. .
ARARs
Chemical-specific, action-specific, and location-specific
ARARs have been developed for the FMC-Fresno site. Appendices
A-1, A-2, and A-3 describe all federal ARARs, state ARARs, and
requirements to be considered (TBCs) for the site. Furthermore,
Appendices A-4 and A-5 identify the alternatives to which
specific federal and state ARARs apply. A general summary of
ARARs is provided below.
Chemical-Specific ARARs
Chemical-specific ARARs are health- or risk-based numerical
values or methodologies that establish concentration or discharge
limits for particular chemicals. Presently, there are a limited
number of chemical-specific ARARs which have been promulgated.
Groundwater in the first sand zone beneath the site is con-
sidered to be a potential source of drinking water, while
groundwater in the second sand zone is considered to be a current
source of drinking water. Several requirements are considered
chemical-specific ARARs or other requirements to be considered
(TBCs) for groundwater and are pertinent to all the groundwater
alternatives (Alternatives GW1-GW5). The chemical specific ARARs
for the groundwater alternatives are:
15
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Maximum contaminant LevelS (MCLs) as established under
the Safe Drinking Water Act (SDWA);
Non-zero Maximum Contaminant Level Goals (HCLGs) as es-
tablished under the SDWA; and
State MCLs as established under the California Safe
Drinking Water Act.
The TBCs for the groundwater alternatives are:
Action Levels developed by DHS;
Applied Action Levels developed by DHS;
Water Quali~y Standards;
Health Advisories developed by EPA and the National
Academy of Sciences; and
Cancer potency factors for carcinogenic chemicals and
reference doses for non-carcinogenic chemicals, as
presented in EPAs Integrated Risk Information System
(IRIS). The information in IRIS has been used to cal-
culate health-based cleanup levels for contaminated
groundwater (see "Cleanup Standards for Contaminated
Groundwater).
A more detailed description of the above ARARs and TBCs is
presented in Appendix A, and chemical-specific federal and state
MCLS, MCLGs, and state Action Levels are presented in Table 1.
No chemical specific ARARs have been identified for soil
contaminants. Cancer potency factors for carcinogenic chemicals
and reference doses for non-carcinogenic chemicals, as presented
in IRIS, have been identified as TBCs for contaminated soil. The
information in IRIS has been used to calculate health-based
cleanup levels for contaminated soil (see "Cleanup Standards for
Contaminated Soil"). Furthermore, a dioxin cleanup standards of
1 ppb in soil, as recommended by the Center for Disease Control,
has been identified as a TBC for contaminated soil (see
Kimbrough, R.D., Falk, H., Stehr, P., et ale Health implications
of 2,3,7,8-tetrachlorodibenzodioxin (TCDD) .contamination of
residential soil. J. Toxicol Environ Health. 1984, v. 14, pp.
47-93.).
Action-Specific ARARs
Action-specific ARARs are requirements associated with a
particular .technoloqy or activity. The Air Pollution Control
District (APCD) of Fresno County has adopted the federal and
state ambient air quality standards. Potential air emission
sources under APDC jurisdiction must demonstrate that emissions
from the facility or equipment will not prevent or interfere with
the attainment or maintenance of the ambient air quality stan-
dards. In addition, federal requirements have been identified
which restrict the emissions of volatile organic compounds
(VOCs). These requirements, as summarized in a Hay 1988 document
issued by the Office of Air Quality Planning and Standards en-
titled "Issues Relating to VOC Regulation Cutpoints,
16
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Deficiencies, and Deviations," state that sources in need of con-
trols are those.with an actual emission rate in excess of three
pounds per hour or fifteen pounds per day. Groundwater alterna-
tives using an air stripper (Alternatives GW3-5) will have to
meet the above-mentioned county and federal air quality require-
ments. The groundwater alternatives using an air stripper will
also have to meet RCRA requirements for air emissions from
process vents, as described in 40 CFR Section 264.1032. Soil al-
ternatives will also have to comply with federal, state, and
county ambient air quality standards.
Releases of contaminants into surface water and groundwater
in Fresno are regulated by the Central Valley Regional Water
Quality Control Board (the Regional Board) under the authority
provided by the Porter-Cologne Water Quality Control Act and the
California Water Code. Reinjection of treated groundwater
(Alternatives GW4 and GW5) must comply with the substantive re-
quirements of the above codes concerning waste discharge require-
ments. The treated groundwater must also meet chemical-specific
cleanup standards prior to reinjection. For discharge to a
Publicly Owned Treatment Works (POTW) (Alternative GW-3),
pretreatment requirements are ARARs.
The Resource Conservation and Recovery Act (RCRA), as
amended, provides the general framework for regulations concern-
ing the generation, transport, treatment, and disposal of hazard-
ous wastes. The federal regulations potentially pertinent to the
FMC-Fresno site are found in Title 40 of the Code of Federal
Regulations (CFR) in Parts 260 through 265, 268, and 270.
EPA has determined that RCRA requirements are applicable to
a CERCLA site if the site contains listed or characteristic haz-
ardous waste that was treated or disposed after the effective
date of the RCRA regulations. RCRA requirements are also
relevant and appropriate for activities involving wastes sig-
nificantly similar to RCRA hazardous wastes or to wastes disposed
prior to the effective date of the RCRA regulations. For CERCLA
activities, reasonable efforts must be made to determine if a
substance is a RCRA listed hazardous waste. The determination of
a listed waste relies on specific information about the waste
(e.g. source, prior use, process type, etc.). Due to a lack of
affirmative information about the waste at the FMC-Fresno site,
contamination currently existing at the site is not presumed to
have originated from RCRA listed waste. However, if contamina-
tion at the site exceeds RCRA characteristic levels, RCRA regula-
tions pertaining to characteristic waste will apply. State
criteria for identification of hazardous waste and extremely haz-
ardous waste are based on Soluble Threshold Limit Concentrations
(STLC) and Total Threshold Limit Concentrations (TTLC),"as
described in 22 CCR, Div. 4, Chapter 30, Art. 11.
Any remedial alternative involving placement of restricted
RCRA hazardous wastes during the course of the remedial action is
subject to EPA's Land Disposal Restrictions (LDRs) (40 CFR Part
17
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. ~: ~...;' -','
. ."
268). EPA has determined that the soil and groundwater alterna-
tives evaluated for this site do not involve placement of a RCRA
restricted waste, and as a resultLDRs are not applicable.
Several of the soil alternative would involve excavation of a
characteristic waste. However, prior to placement, this waste
would be treated to levels that do not constitute a characteris-
tic waste, and as a result LDRs would not apply.
40 CFR Part 264 - Standards for Owners and Operators of Haz-
ardous Waste Treatment, Storage, and Disposal Facilities and 40
CFR Part 265 - Interim Status Standards for Owners and Operators
of Hazardous Waste Treatment, Storage, and Disposal Facilities
have both been identified as ARARs for the site and are pertinent
to the soil and groundwater alternatives. For example,
groundwater monitoring requirements of Parts 264 and 265 (subpart
F) are pertinent to all the groundwater alternatives. Additional
sections of Parts 264 and 265 are also pertinent to the
groundwater alternatives. As another example, Subpart F of Parts
264 and 265 - Closure and Post Closure would apply to the waste
pond and as a result is pertinent to all the soil alternatives.
Location Specific ARARs
Location-specific ARARs are restrictions placed on the con-
centration of hazardous substances or on the conduct of ac-
tivities at a site because of its location. For soil alterna-
tives that involve the construction of a new landfill
(Alternative S4), standards set forth in 40 CFR Part 264.18 and
Chapter 15 of the California Code may be applicable. These stan-
dards address setback from Holocene faults, and design, construc-
tion and maintenance standards relative to the 100-year flood
plain.
Groundwater CleanuD Standards
Groundwater cleanup standards selected for the FMC-Fresno
site are presented in Table 1. Groundwater cleanup standards
were established for all non-naturally occurring contaminants
detected in the groundwater. Where they exist, federal Maximum
Contaminant Levels (MCLs) and non-zero Maximum Contaminant Level
Goals (MCLGs) were selected as the cleanup goals for contaminated
groundwater below and emanating from the FMC-Fresno site. State
MCLs were selected as the groundwater cleanup goal when federal
MCLs or MCLGs did not exist, or the state MCL was more stringent.
California Action Levels have been selected as cleanup standards
when no federal or state MCLs exist.
For many of the groundwater contaminants present at the
site, requlatory tolerances (ie. federal or state MCLs or state
Action Levels) have not been established. In these instances,
EPA selected the health-based cleanup levels calculated for the
site. Pursuant to the NCP (404CFR 300~430(e) (2», an acceptable
carcinogenic risk ragge of 10- to 10- has been established.
EPA has selected 10- (or a hazard index of one - whichever is
18
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stricter) as the cleanup objective for contaminated groundwater.
This decision was based on the fact that water from the first
sand zone is considered to be a potential source of drinking
'water and water from the second sand zone is considered a current
source of drinking water. Additionally, EPA has selected
health-based cleanup levels rather tha2 MCLs for two chemicals
for which the MCLs only achieved a 10- level of protection.
These two chemicals are ethylene dibromide and toxaphene. As
discussed in the NCP, 40 CFR 300.430(e) (2) (i) (D), selection of
cleanup standards which are stricter than MCLs may be considered,
"in cases involving multiple contaminants or pathways where at-
tainment of chemical-fpecific ARARs will result in cumulative
risk in excess of 10-." Finally, for those chemicals for which
no health-based or regulatory levels exist, practical quantifica-
tion limits (the lowest level at which a chemical can be ac-
curately measured with currently available technology) have been
selected as cleanup standards. The quantification limits
selected were based either on EPA's Contract Required Quantita-
tion Limits or on five times the currently accepted detection
limit. Quantification limits were selected as cleanup standards
for five chemicals - chloronitro-propane, DNOC, monuron, tedion,
and TEPP.
In several instances, the selected cleanup standards are
below the quantification limits. In these cases, the quantifica-
tion limits will be used as interim cleanup standards. The
quantification limits will be reviewed by the lead agency on a
biannual basis, so that in the future it may be possible to meet
the health-based and regulatory cleanup standards.
Background groundwater contaminant levels have not been es-
tablished in the vicinity of the site. If in the future, back-
ground contaminant levels are established to the satisfaction of
the regulatory agencies, groundwater cleanup standards will be
modified to ensure that the standards are not more stringent than
the background levels.
EPA believes that cleanup levels should generally be at-
tained throughout the contaminated plume, or at and beyond the
edge of the waste management area, when waste is left in place.
Since waste is being left in place in the south-central 4.92
acre-area, the waste pond, the oil drum yard, and certain sumps
(ie. hazardous waste sumps 2, 7, 9, and 12 and rainwater sump
14), the area of attainment for groundwater cleanup standards
shall be defined as all areas within the contaminated plume at
arid beyond the edge of those areas where soil contamination is
left in place in excess of the selected cleanup standards. The
downgradient plume shall be considered the point at which site-
related contaminants no longer exceed cleanup standards (see
Table 1). The downgradient extent of the contaminant plume has
not been identified, and additional groundwater investigation
will be required during the RD phase to determine the down-
gradient extent of contamination.
19
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r',- 'I"'
::; .':",.. -rr.;,; ) fr;t~ '
. .
I, ".'.}. .
Soil CleanUD Standards
Surface and near-surface soil cleanup standards for the
FMC-Fresno site are based on a carcinogenic risk level of 1X10-4
(one in ten thousand excess cancer cases) and a non-carcinogenic
Hazard Index of one, as calculated in the document entitled
"Health-Based Goals for Remediation of the FMC Pesticide Formula- .
tion Facility Fresno, California," in accordance with the NCP, 40
CFR 300.430 (e) (2) (D). Health-based cleanup standards were.
originally calculated for all soil contaminants detected at the
site. However, due to the large number of chemicals detected in
soils at the site, EPA determined that it would be difficult to
implement a ~emedy based on the presence of this large number of
contaminants. Consequently, a smaller group of indicator chemi-
cals for soil were selected based on their maximum concentration,
frequency of detection, and contribution to risk. As a result,
twelve indicator chemicals were selected for the soil contamina-
tion at the site. By focusing on the cleanup of indicator chemi-
cals, the selected remedy for soil is protective of human health
and the environment. The soil indicator chemicals and their
cleanup standards are presented in Table 3. The selected remedy
for groundwater addresses all chemicals detected in groundwater,
not just the twelve indicator chemicals. Furthermore, the risk
assessment for the site, considers all chemicals of concern
detected in groundwater and soil, not make just the twelve in-
dicator chemicals.
These cleanup standards for soil are based on the presence
of a single indicator chemical. If it is determined that mul-
tiple indicator chemicals are present, the cleanup standard will
be adjusted downward to account for multiple contaminant risks.
This determination will be made in the field during the remedial
action phase. For example, if three carcinogenic and two non-
carcinogenic indicator chemicals are found in confirmation
samples taken during excavation, the carcinogenic and non-
carcinogenic cleanup standards will be divided by factors of
three and two, respectively, and the extent of excavation will be
adjusted appropriately.
A cleanup standard of 1 part per billion dioxin in soil has
been selected. This is based on a recommendation by the Center
for Disease Control (CDC) regarding acceptable levels of dioxin
in residential soil (see Kimbrough, R.D., Falk, H., Stehr, P., et
ale Health implications of 2,3,7,8-tetrachlorodibenzodioxin
(TCDD) contamination of residential soil. J. Toxicol Environ
Health. 1984, v. 14, pp. 47-93.).
Since the threat of exposure to deep subsurface soil con-
taminants is considered to be a low level threat that can be ad-
dressed by implementing institutional controls, installing a cap,
and performing groundwater extraction, treatment, and monitoring;
20
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the health-based levels for deep soils have not been selected as
cleanup standards. As is explained in the "Selected Remedy" sec-
tion, a maximum excavation depth of 15 feet has been selected.
Groundwater Cl.an~p Alternatives
Alternative GW1:
No Action (Monitorina).
Evaluation of the no-action alternative is necessary to
evaluate site conditions with limited remedial measures, and to
compare the benefits of other alternatives. Under the no action
alternative for groundwater, a groundwater monitoring program
would be conducted at the site for a minimum of thirty years, as
required by 40 CFR Parts 264 and 265.' This program would use the
existing groundwater monitoring network and additional wells as
necessary.
The costs associated with this alternative are as follows:
capital Costs $0
o , M Costs $4,606,389
Total Project Costs $4,606,389
Alternative GW2:
Institutional Controls.
Under this alternative, a groundwater monitoring program as
described in Alternative GW1 would be conducted, and institu-
'tional controls would be implemented. These institutional con-
trols would consist of deed restrictions restricting the instal-
lation of onsite water wells, except those used for monitoring
and extraction of groundwater contamination. Furthermore, peri-
odic monitoring of all wells within the area of the contaminated
plume would be conducted. If any of these wells contain con-
taminants in excess of the selected cleanup standards, then the
wells would either be replaced, fitted with well-head treatment
systems, or an alternative water supply will be provided.
The time required to implement this alternative would be
minor. The costs for this alternative are the same as for Alter-
native GW1 (Total Project Costs - $4,606,389). There would be
some additional cost associated with implementing the institu-
tional controls; however, these costs would be relatively minor.
Alternative GW3: Institutional Controls. Extraction. Carbon
AdsorDtion/Air StriDDina. Discharae to Publiclv OWned Treatment
Works (POTW).
Under this alternative, a groundwater monitoring program and
institutional controls as described in Alternatives GW1 and GW2
respectively, would be implemented. Furthermore, if it is deter-
mined that the use of any onsite or offsite well would adversely
affect the groundwater cleanup plan, then an alternative water
supply would be provided to the user of this well. Groundwater
21
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would be extracted, via extraction wells, from the first two
saturated sand zones. The exact number of extraction wells, well
locations, and extraction rates would be determined during the
remedial design (RD) phase. However, the design of the
groundwater extraction system must be sufficient to capture all
contamination beneath and emanating from the FMC-Fresno facility
exceeding the selected cleanup standards. Groundwater extraction
and treatment would be conducted until the selected cleanup stan- .
dards have been met at all points within the area of attainment.
Groundwater monitoring would be conducted for at least five .years
after the selected cleanup standards have been met. Furthermore,
as required by 40 CFR Parts 264 and 265, groundwater monitoring
would be conducted for a minimum of thirty years. Additional
groundwater investigations would be performed as necessary to
define the downgradient extent of the contaminant plumes.
The extracted water would be treated using air stripping and
activated carbon adsorption technologies. Contaminated water
would be pumped from the extraction wells into an equalization
tank. A continuous stream of water would then be pumped through
a prefilter to an air stripper for the removal of volatile or-
ganics. The liquid effluent from the air stripper would be
pumped through liquid phase activated carbon adsorption units.
The treated water would then be piped to a sewer line connection
for discharge to a POTW. Treated water could also be re-used on-
site. Final design of the air stripping and carbon adsorption
units would be performed during the RD phase.
To comply with Fresno Air Pollution Control District Rules
and Regulations as well as federal requirements (which state that
sources with an actual emission rate of in excess of three pounds
per hour or fifteen pounds per day need emission controls), con-
trol of atmospheric volatile organic compound (VOC) emissions
from the air stripper may be necessary. This would be ac-
complished using a vapor phase carbon adsorption unit. The deci-
sion to treat air emissions from the air stripper will be made.
during the RD phase if it is determined that emissions will
exceed allowable levels.
Surface soils would be capped to prevent infiltration of
water and continued migration of soil contaminants to
groundwater. The design and cost of this cap is presented along
with the soil cleanup alternatives.
. The time required to reach ARARs under this alternative is
difficult to estimate. However, modeling predictions indicate
that once groundwater extraction began it would take a minimum of
10 to 20 years to reach ARARs in the first sand zone and a mini-
mum of 5 years to reach ARARs in the second sand zone. The costs
associated with this alternative are as follows:
Capital Costs $452,563
o & M Costs $6,629,465
Total Project Costs $7,082,028
22
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Alternative GW4: Institutional Controls. Extraction. Carbon
AdsorDtion/Air StriDDina. Reiniect to Second Sand Zone
Under this alternative, a groundwater monitoring program and
institutional controls as described in Alternatives GW1 and GW2
respectively, would be implemented. If it is determined that the
use of any onsite or offsite well would adversely affect the
groundwater cleanup plan, then an alternative water supply would
be provided to the user of this well. Furthermore, groundwater.
extraction and treatment as described in Alternative GW3 would
also be conducted. However, treated groundwater would be rein-
jected onsite to the second sand zone, rather than being disposed
of at .a POTW. Treated water could also be re-used onsite. Rein-
jection of water to.the. second sand zone would conserve local
water resources and could flush the aquifer and accelerate its
restotion.The number and location of reinjection wells would be
determined by groundwater modeling conducted during the RD phase.
Surface soils would be capped to prevent infiltration of
water and continued migration of soil contaminants to
groundwater. The design and cost of this cap is presented along
with the soil cleanup alternatives.
The time required to reach ARARs under this alternative is
difficult to estimate. However, modeling predictions indicate
that once groundwater extraction began it would take a minimum of
10 to 20 years to reach ARARs in the first sand zone and a mini-
mum of 5 years to reach ARARs in the second sand zone. The costs
associated with this alternative are as follows:
capital Costs $525,688
o & M Costs $6,681,339
Total Project Costs $7,207,027
Alternative GW5: Institutional Controls. Extraction. Carbon
AdsorDtion/Air StriDDina. Reiniect to First and Second Sand Zone
Under this alternative, a groundwater monitoring program and
institutional controls as described in Alternatives GW1 and GW2
respectively, would be implemented. If it is determined that the
use of any onsite or offsite well would adversely affect the
groundwater cleanup plan, then an alternative water supply would
be provided to the user of this well. Furthermore, groundwater
extraction and treatment as described in Alternative GW3'would
also be conducted. Treated groundwater would be reinjected on-
site to the first and second sand zones, rather than being dis-
posed of at a POTW or being reinjected to only the second sand.
Treated water could also be re-used onsite. Reinjection of water
to the first and second sand zone would conserve local water
resources and could flush both sand zones of the aquifer and ac-
celerate their restoration. The number and location of reinjec-
tion wells would be determined by groundwater modeling conducted
during the RD phase.
23
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Surface soils would be capped to prevent infiltration of
water and continued migration of soil contaminants to
groundwater. The design and cost of this cap is presented along
with the soil cleanup alternati~es.
The time required to reach ARARs under this alternative is
difficult to estimate. However, modeling predictions indicate
that once gr.oundwater extraction began it would take a minimum of
10 to 20 years to reach ARARs in the first sand zone and a mini-
mum of 5 years to reach ARARs in the second sand zone. The costs
associated with this alternative are as follows:
capital Costs $525,688
o & M Costs $6,681,339
Total Project Costs $7,207,027
soil C1eanuo Alternatives
Based on the selected soil cleanup standards it is estimated
that approximately 25,000 cubic yards of soil will require treat-
ment. The costs and volume calculations associated with these
cleanup levels were presented in Appendix D of the FS report.
Alternative Sl:
No-Action.
Evaluation of the no-action alternative is necessary to
evaluate site conditions with limited remedial measures, and to
compare the benefits of other alternatives. Under the no-action
alternative for soil, conditions at the site would remain as they
are now. The existing fence would be maintained to prevent ac-
cess by unauthorized personnel.
There would be no costs associated with this alternative.
Alternative S2:
Institutional Controls.
Under this alternative, conditions at the site would remain
as they are, and ~nstitutiona1 controls restricting future use of
the site would be implemented. These institutional controls
would consist of deed restrictions precluding the construction of
residential buildings onsite, and would require compliance with
California Health and Safety Code Section 25232. This section of
the code requires a written variance from the California Depart-
ment of Health Services (DHS), or its successor agency for any
new use of the land, other than the use, modification, or expan-
sion of the existing facility or for subdivision of the land,
other than division of the portion of land designated as a haz-
ardous waste property from portions not so designated. A RCRA
cap would be placed over the waste pond in accordance with RCRA
closure of the unit under 40 CFR Parts 264 and 265.
24
I '
I
I
I
I
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.
t
The time required to implement this alternative would be
minor. The costs associated with this alternative are as fol-
lows:
capital Costs
o & M Costs
Total Project Costs
$56,875
$36,317
$93,192
Alternative S3:
Institutional Controls. CaDDina.
Under this alternative, institutional controls would be
implemented as described in Alternative S2. Additionally, a cap
would be installed to prevent contact with contaminated soils and
migration of soil contaminants to groundwater. This cap would
cover unpaved and excavated areas of the site in the vicinity of
the 4.92 Acre-Area, Waste Pond, Oil Drum Yard, Percolation Pond,
and other areas as appropriate. Additionally, the cap in the ac-
tive formulation area of the site would be maintained. The cap
would be constructed of soil cement and asphalt. The asphalt
layer would prevent infiltration of precipitation; while the soil
cement layer would provide a physical barrier between potential
users of the site and would also augment the effectiveness of the
asphalt in preventing infiltration. Long-term monitoring and
maintenance of this cap would be performed, as appropriate.
Where necessary (ie. the waste pond) the cap design will meet
RCRA capping and monitoring requirements.
Implementation of this alternative would take approximately
12 months from the time of remedial design approval. The costs
associated with this alternative are as follows:
Capital Costs
o & M Costs
Total Project Costs
$1,337,375
$160,832 .
$1,498,027
Alternative S4:
CaDDina.
On-Site RCRA Landfill. Institutional Controls.
Under this alternative, institutional controls would be
implemented and a cap would be installed, as described in Alter-
natives S2 and S3 respectively. Additionally, contaminated soils
present in excess of the selected cleanup standards would be ex-
cavated to a maximum depth of 15 feet, and placed in an onsite
landfill constructed in accordance with specifications contained
in 40 CFR Part 264 and in California Administrative Code Title
23. The proposed RCRA landfill would be located within or near
the the existing waste pond or percolation pond or another
suitable area within the 4.92 acre-area, and would have to be
large enough to accommodate the volume of soil requiring cleanup.
Initial activities would involve removing enough soil to provide
25
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a sufficient volume for the landfill. The surface of the
landfill would be contoured to match grades of adjacent areas. A
RCRA-approved double liner consisting of impermeable clay and
synthetic materials would be installed, together with a dual
leachate collection system. After the excavated material was
placed in the landfill, it would be covered by a RCRA-approved
cap consisting of a low permeability clay layer, synthetic liner,
sand drainage layer, and a topsoil cover. A suitable monitoring
and maintenance plan would be instituted to ensure the long-term
integrity of the RCRA cap.
Implementation of this alternative would take approximately
7 months from the time of remedial design approval. The costs
associated with this alternative are as follows:
Capital Costs
o & M Costs
Total Project Costs
$9,586,366
$160,832
$9,747,198
Alternative S5:
stabilization. Institutional Controls. CaDDinq.
Under this alternative, institutional controls would also be
implemented and a cap would be installed, as described in Alter-
natives S2 and S3 respectively. Additionally, contaminated soils
present in excess of the selected levels would be excavated to a
maximum depth of 15 feet, screened and stockpiled in a lined and
bermed area prior to treatment. stockpiled soils would be stabi-
lized using an appropriate stabilization treatment process as
selected from the bench-scale treatability studies performed
during the Feasibility Study and additional field-scale
treatability studies performed during Remedial Design. A portion
of the stabilized material would be used in construction of the
soil cement layer of the cap. The remaining stabilized materials
would then be returned to the excavated areas.
stabilization/fixation is a process that combines organic
and/or metal contaminants with various fixing agents. The resul-
tant compound binds soil constituents with additives such as
silicates, reducing the mobility of the contaminants. Prior to
performing the actual excavation and treatment of contaminated
soils, field-scale treatability studies would be performed to en-
sure that stabilization is capable of effectively treating the
contaminated soils. Bench-scale treatability studies for stabi-
lization were conducted during the Feasibility Study.
Implementation of this alternative would take approximately
15 to 31 months from the time of remedial design approval. The
costs associated with this alternative are as follows:
capital Costs
o & M Costs
Total Project Costs
$5,583,050
$223,089
$5,806,139
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Alternative S6:
. troIs. CaDDina.
soil Washina. Stabilization. Institutional Con-
Under this alternative, institutional controls would also be
implemented and a cap would be installed, as described in Alter-
natives S2 and S3 respectively. Additionally, contaminated soils.
present in excess of selected cleanup levels would be excavated
to a maximum depth of 15 feet, and processed with commercially
available size reduction and separation equipment including
screening, crushing, and size separation devices. An appropriate
soil washing technology would be selected from the bench-scale
treatability studies performed during the Feasibility Study and
additional field-scale treatability studies performed during
Remedial Design. Coarse grained soils separated during the soil
washing process would be used as onsite fill if it was determined
that the levels of contamiriants in these soils are below the
selected cleanup standards. Fine grained soils separated during
the soil washing process would be stabilized. Coarse grained
soils th~t contain contaminants in excess of the selected cleanup
standards would also be stabilized. The stabilization process
would occur as described in Alternative S5, and the stabilized
material would be returned to the excavated areas. The con-
taminated rinse waster generated during the soil washing process
would be treated using carbon adsorption.
Soil washing is a volume-reducing technology that qenerally
applies to the treatment of soils having a larqer fraction made
up of sands, gravels, or larqer sized particles. The technoloqy
is based on the principle that contaminants adhere preferentially
to the finer particles consisting of silts, clays, and humic
materials, and that the extent of contamination of the larger
fraction materials is related to adhesion of the finer materials
to the exterior surfaces of the larger grains. Soil washing
mechanically separates the more highly contaminated fine soil
fraction from the lesser contaminated coarse soil fraction. Ad-
ditives may be used in conjunction with the water wash to improve
the effectiveness of the process. Prior to performing the actual
excavation and tre~tment of contaminated soils, field-scale
treatability studies would be performed to ensure that stabi-
lization and soil. washing are capable of effectively treating the
contaminated soils. Bench-scale treatability studies for stabi-
lization and soil washing were conducted during the Feasibility
study.
Implementation of this alternative would take approximately
15 to 31 months from the time of remedial desiqn approval. The
costs associated with this alternative are as follows:
Capital Costs
o & M Costs
Total Project Costs
$9,900,069
$160,835
$10,103,654
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Alternative S7:
Dina.
Solvent Extraction. Institutional Controls. CaD-
Under this alternative, institutional controls would also be
implemented and a cap would be installed, as described in Alter-
natives S2 and S3 respectively. Additionally, contaminated soils
present in excess of selected cleanup levels would be excavated
to a maximum depth of 15 feet, screened, and stockpiled in a
bermed and lined storage area. The stockpiled soils would be
treated using an appropriate solvent extraction process as
selected from the bench-scale treatability studies performed
during the Feasibility Study and additional field-scale
treatability studies performed during Remedial Design. This
process involves bringing contaminated soil in contact with sol-
vent (triethylamine) in a blade-stirred vessel. The solvent is
recovered by distillation, and the contaminants are discharged as
oily residue. The extracted contaminants would be sent to an
off-site incinerator for destruction, while the extracted solvent
is recylced. The treated soil would be used as onsite fill. Ac-
cording to the vendor, the residual solvent remaining in the soil
is biodegradable and does not constitute a regulated waste.
The Basic Extraction Sludge Technology (B.E.S.T.) as offered
by the Resources Conservation Company was the solvent extraction
process evaluated during the Feasibility Study. This process
employs triethylamine as a solvent for hydrocarbon or chlorinated
organic compounds. Prior to performing the actual excavation and
treatment of contaminated soils, field-scale treatability studies
would be performed to ensure that solvent extraction is capable
of effectively treating the contaminated soils. Bench-scale
treatability studies for solvent extraction were conducted during
the Feasibility Study.
Implementation of this alternative would take approximately
15 to 32 months from the time of remedial design approval. The-
costs associated with this alternative are as follows:
Capital Costs
o & M Costs
Total Project Costs
$15,499,466
$160,832
$15,660,298
Alternative S8:
CaDDina.
Under this alternative, institutional controls would also be
implemented and a cap would be installed, as described in Alter-
natives S2 and S3 respectively. Additionally, contaminated soils
present in excess of selected cleanup levels would be treated via
vitrification. Vitrification at the FMC-Fresno site would be
performed in both in-situ (in place) and trench settings. To
maximize the efficiency of the process, some soils would be ex-
cavated and placed in the waste and percolation ponds prior to
vitrification. These soils would then be treated using several
In-Situ Vitrification. Institutional Controls.
28
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vitrification settings. Following vitrification, the pond areas
would be backfilled, as the vitrified area would be expected to
subside 20 to 35 percent. FOllowing confirmation testing, the
excavated areas would also be backfilled.
The vitrification process is a thermal treatment process
that converts contaminated soil into a chemically inert, stable,
glass-like and crystalline product. This is accomplished by
placing electrodes in the contaminated soil and applying an
electric potential. The surrounding soil is heated to a tempera~
ture above the normal fusing temperature of the soil. As the
vitrified mass grows, it incorporates inorganic elements and
pyrolyzes organic components. The pyrolized by-products migrate
to the surface of the vitrified zone where they combust in the
presence of oxygen. The combustion gases are drawn into an off-
gas treatment system.
Implementation of this alternative would take approximately
15 months from the time of remedial design approval. The costs
associated with this alternative are as follows:
Capital Costs
o & M'Costs
Total Project Costs
$25,489,313
$160,832
$25,649,695
Alternative S9:
caDcina.
Onsite Incineration. Institutional Controls. .
Under this alternative, institutional controls would also be
implemented and a cap would be installed, as described in Alter-
natives S2 and S3 respectively. Additionally, contaminated soils
present in excess of selected cleanup levels would be excavated
to a maximum depth of 15 feet and incinerated onsite. Prior to
thermal processing, contaminated s~ils would be passed through a
grizzly screen to reduce particle size and to remove oversized
materials. other process options such as crushing, blending,
drying, and chemical characterization may be required. Con-
taminated soil would then be fed into the combustion chamber.
The treated soil would be stockpiled for characterization to con-
firm destruction and leachability. The. decontaminated soil would
be used as backfill onsite.
Various incineration systems were evaluated during the
Feasibility study and the Circular Bed Combuster (CBC) was
selected for the development of this alternative. The CBC system
is a modification of fluidized bed technology.. A standard.
fluidized bed combuster has a fixed depth; however, in a CBC sys-
tem high velocity air is introduced at the bottom of the
refractory-lined combustion chamber carrying the bed out of the
fluidization zone. This results in entrapment of the wastes and
combustion along the entire height of the combustion section.
The vendor has indicated that the CBC technology meets all
29
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. ' '..
-'" ~.' "i:t"1",-~1-. "f-'
" I, ,-,'
I' '.[' ,
',I'
'.,' '.
,. 'j
California pollution control regulations. The destruction ef-
ficiency of the CBC process would be expected to meet the RCRA
requirement of 99.9999 percent for the site contaminants.
Implementation of this alternative would take approximately
11 months from the time of remedial design approval. The costs
associated with this alternative are as follows:
Capital Costs
o & M Costs
Total Project Costs
$27,560,384
$160,832
$27,721,216
VIII.
StJJDIARy OP COMPARATIVB ANALYSIS OP ALTERNATIVES
Each of the alternatives described in the preceding section
was evaluated according to the nine criteria defined below. Each
criterion is discussed in detail on the pages that follow this
list.
Threshold criteria
1. OVerall pro~ec~ion of human heal~h and ~he environmen~.
dresses whether the alternative can adequately protect human
health and the environment, in both the short and long-term,
contaminants present at the site.
Ad-
from
2. Compliance wi~h Ped.ral and S~ate environmen~al 8tandards.
Addresses whether the alternative will meet all of the applicable
or relevant and appropriate requirements (ARARs) of Federal and
State environmental statutes or provide grounds for invoking one
of the waivers.
primarv Balancina Criteria
3. Lonq-~erm effectiveness and permanence. Refers to the long-
term effectiveness and permanence afforded by the alternative
along with the degree of certainty that the alternative will
prove successful.
4. Reduction of tOKici~y, .obili~y, or volume. Refers to the
degree to which the alternative reduces toxicity, mobility, or
volume of the contaminants and reduces the inherent hazards posed
by the site. '
5. Shor~-term effectiveness. Refers
posed to the community, the potential
potential environmental impact during
ternative. .
to the short-terms risks
impact on workers, and the
implementation of the al-
I. Implementability. Refers to the ease or difficulty of im-
plementing the alternative by considering technical feasibility,
administrative feasibility, and availability of materials and
services.
30
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7. co.~. Includes capital costs, annual operation and main-
tenance (0 & M) costs, and net present value of 0 & M costs.
Balancing criteria 3 and 4 receive added emphasis in evaluating
alternatives.
Modifvina criteria
8. state acceptance. Indicates whether the state concurs with,
opposes, or has no comment on the preferred alternative.
I. CommUDi~y acceptance. Indicates whether the community agrees
with, opposes, or has no comment on the preferred alternative.
Groundwater Com~arative Analvsis
OVerall Protection of Human Health and the Environment
When coupled with a protective soil remedy (ie. Alternatives
S3-S9), Alternatives GW3, GW4, and GW5 are protective of human
health and the environment. Alternatives GW1 and GW2 would not
eliminate potential exposure to contaminated groundwater, and as
a result are not protective of human health and the environment.
Groundwater extraction and treatment systems of Alternatives
GW3, GW4, and GW5 would eliminate the potential for contamination
of offsite drinking water supplies. These three alternatives
would gradually remove contaminants from the environment. Alter-
native GWS, which involves reinjection of treated water to the
first sand zone, could increase migration of deep soil con-
taminants to groundwater. It is possible that these some of these
contaminants would not be captured by the groundwater extraction
system, and as a result Alternative GW5 may not be as protective
as Alternatives GW3 and GW4.
compliance with ARARS
Appendices A-4 and A-5 indicate the alternatives to which
specific federal and state ARARs apply. Alternatives GW3, GW4,
and GWS would meet all existing chemical-specific, action-
specific, and location-specific ARARs.
Alternatives GW1 and GW2 would not meet chemical-specific
ARARS for groundwater contaminants.
Long-Term Effectiveness and Permanence
Alternatives GW3, GW4, and GWS are capable of permanently
removing a large portion of the groundwater contamination, and
thereby are capable of providing long-term effectiveness.
Groundwater modeling results suggest it may take at least 10 to
20 years to attain ARARS onsite and offsite.
31
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-_......iL_~
, -
Alternative GW2 would minimize the potential for onsite ex-
posure to contaminated groundwater. However, contaminated
groundwater would continue to migrate, and offsite receptors
could be exposed. As a result, this alternative would not
provide long-term effectiveness and permanence. Alternative GWl
does not reduce the threat of exposure to groundwater con-
taminants and does not provide long-term effectiveness.
Reduction of Toxicity, Nobility, and Volume
Through the combined effects of extraction, treatment and
reinjection, Alternatives GW3 and GW4 would provide the greatest
reduction in volume and mobility of contaminated groundwater. By
extracting and treating groundwater, contaminants present in the
two water bearing sand zones will be removed. The effects of ex-
traction and reinjection will also result in a reduction in
mobility of contaminated groundwater by providing hydraulic con-
trols. Alternative GW5 would also provide a significant reduc-
tion in the volume of contaminated groundwater, but it is pos-
sible that reinjection to the first sand zone could result in in-
creased migration of deep soil contaminants to groundwater.
Alternatives GWl and GW2 do not provide a reduction in
toxicity, mobility, or volume of groundwater contaminants.
Short-Term Effectiveness
As water supply wells in the vicinity of the site have not
yet been affected by site-related chemicals, there are no short-
term risks associated with the groundwater alternatives. Fur-
thermore, since the site is fenced and access restrictions are
enforced, and it is expected that standard health and safety pro-
cedures would be followed, there would be no adverse short-term
effects to workers or nearby residents associated with construc-
tion activities relating to Alternatives GW3, GW4, and GW5. No
additional construction or onsiteactivities occur under Alterna-
tives GWl and GW2.
Implementability
All the groundwater alternatives evaluated are implement-
able. Alternative GWl is readily implementable since no action
would occur. Alternative GW2 is also readily implementable since
only administrative requirements are required. Alternatives GW3,
GW4, and GW5 all appear to be equally implementable. Discharge
to the POTW (GW3) is feasible, contingent upon acceptance of the
water by the POTW. Reinjection of the treated water (GW4 and
GW5) will require additional groundwater modeling in order to
determine the optimum design of the reinjection system. Treated
water could 81so be readily re-used onsite. Groundwater extrac-
tion, air stripping, and carbon adsorption are well-established
technologies that could be implemented at the site.
32
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Cost
, The costs for Alternatives GWl and GW2 are both ap-
proximately $4,606,389. In both cases the majority of the cost
is for continued monitoring over a thirty year period. It is
likely that there would be some minor additional costs associated
with Alternative GW2 for administrative requirements. The costs
for Alternatives GW3, GW4, and GW5 are roughly similar, ranging
from approximately $7,082,028 to $7,207,027.
state Acceptance
The state of California, through both DHS and the Regional
Board, have participated in the RIfFS activities. Both state
agencies assisted in the development of ARARs, and DHS,has been
active in the remedy selection process. Since Alternatives GWl
and GW2 are not protective and would not restore the contaminated
aquifers, these alternatives would not be acceptable to the
State. Since Alternative GW5 could result in increased levels of
groundwater contamination, this alternative would not be accept-
able to the State. Alternatives GW3 and GW4 would both be ac-
ceptable to the State; although it is likely that Alternative GW4
would be preferable since groundwater resources would be con-
served.
community Acceptance
Public comments on the proposed plan are presented in the
"Response Summary" (Appendix B) of this ROD. Alternatives that
are not protective of human health and the environment (GWl and
GW2) would not be acceptable to the community. Since Alternative
GW5 could result in increased migration of groundwater contamina-
tion, this alternative would not be acceptable to the community.
Alternative GW3 would be acceptable to the community, although
several individuals have expressed concerns over conservation of
groundwater resources. Alternative GW4 would be acceptable to
the community, although several individuals have expressed con-
cern that reinjection to the second sand zone could cause enhance
migration of groundwater contamination.
80il Com~arative ADalvsis
OVerall Protection of Human Health and the Environment
When combined with a protective groundwater alternative (ie.
Alternatives GW3, GW4, or GW5), Alternatives S3 through S9 would
all offer a similar, high level of protection against exposure to
contaminated soils through institutional controls and capping.
Alternatives S5 through S9 offer greater long-term protection
since they incorporate treatment. Alternatives S7, S8, and S9
offer the highest level of protection since they use a greater
degree of treatment as compared to Alternatives S5 and S6. Al-
ternative S2 offers a low level of protection, since there is no
33
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guarantee that institutional controls will be maintained over
time. Alternative Sl offers little protection against exposure
to contaminated soil.
complianoe with &RARs
Appendices A-4 and A-5 indicate the alternatives to which
specific federal and ~~ate ARARs apply. With the exception of
Alternatives Sl and 5~. all of the soil alternatives meet ARARs.
Alternatives 51 and S~ would not meet 40 CFR Parts 264 and 265.
For those alternative that involve excavation and/or treatment.
(Alternatives S4-59), health-based cleanup levels for surface and
near-surface soil were calculated based on TBCs identified for
the site (CPF.s and RfDs contained in IRIS), and have been
selected as soil cleanup standards. Alternatives S7-59 are
capable of directly meeting these standards through treatment.
Alternative S6 meets these standards through treatment and immo-
bilization, while Alternative S5 meets these standards through
immobilization. Alternative S4 meets these standards through
containment of the waste.
Long-Tera Effectiveness and Permanence
Alternatives S5 through S9 offer a high level of long-term
effectiveness since they all utilize treatment. Alternatives 58
and S9 offer the greatest level of long-term effectiveness, since
they achieve high levels of contaminant destruction or removal.
Alternative S7 offers a slightly lower, but still very high,
level of long-term effectiveness. The long-term effectiveness of
ALternatives S5 and S6 is lower than that of Alternatives S7, S8,
and S9 since the bulk of contaminants would remain onsite under
these two alternatives. The long-term effectiveness of Alterna-
tive S6 is better than that of Alternative S5, since the more
mobile compounds would be removed by soil washing prior to stabi-
lization. Alternatives S3 and S4 offer a moderate level of
long-term effectiveness since they rely on proper maintenance of
the cap and institutional controls. Alternatives Sl and S2
provide little long-term protection against exposure to con-
taminated soils.
Reduction of Toxicity, Mobility, or Volume
AlternativesS7, S8, and S9 would all result in significant
and permanent reductions in the toxicity and volume of soil con-
taminants. Results of treatability studies and literature
reviews indicate these alternatives are capable of attaining
higher cleanup standards than Alternative S6. There is some con-
cern that residual solvents left by Alternative S7 could result
in increased mobility of soil contaminants. Alternative S6 would
result in a reduction in the volume of contaminated soil, and
would reduce the mobility of soil contaminants. Alternative S6
would provide for a greater reduction in contaminant mobility
than Alternative S5, since the more mobile contaminants would be
removed by soil washing prior to stabilization. Alternatives S3
34
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and 85 would reduce the mObility of soil contaminants, but would
result in a slight increase in volume of contaminated material.
Alternative 54 would reduce the mobility of soil contaminants
without affecting the volume of material. Alternatives 51 and 82
would not provide any reduction in contaminant toxicity,
mobility, or volume.
Short-Term Bffectiveneaa
Alternatives 51 and 52 do not pose any short-term risks,
since access to the site is already restricted and these alterna-
tives would not disturb contaminated soil. Alternatives 53
through 59 pose some short-term risks to community and worker
health during implementation; however, these risks could be
eliminated through proper engineering, safety and management
practices. Alternatives 83 through 59 involve construction or
earthmoving activities that would generate fugitive dust. Alter-
natives 88 and 89, which use thermal treatment technologies, pose
the additional risk that may be associated with off-gas emis-
sions. Alternative 87 involves offsite transport of contaminated
material which could cause a threat in the event of an accident
during transport.
Implementability
All of the alternatives are implementable. Alternatives 81
and 82 would be easy to implement since no additional materials
or equipment would be required. Alternatives 53 and 54 would
also be easy to implement since they require conventional equip-
ment and standard construction methods. Alternative 55 is a fre-
quently applied treatment technology, and the required materials
and equipment are readily available. Alternatives 56, 57, and 58
rely on technologies that are not fully demonstrated, and there
is some uncertainty regarding their ease of implementation. The
required equipment for Alternative 57 is not currently available,
but it is expected by some time in 1992. Adequate offsite in-
cineration capacity, as required for Alternative 57 is available.
Alternative 58 is only available through one vendor, and the
technology has not been commercially demonstrated. Field-scale
treatability studies would be required for Alternatives 55, 56,
57, and 58 to establish firm cost estimates and provide engineer-
ing design data. Alternative 59 would require an onsite test
burn prior to full-scale operation.
Coat
Alternative 51 would involve no additional costs. Alterna-
tive 52 would require relatively minimal costs to implement
($93,192). The cost of Alternative 53 is considered fairly low
($1,498,027), while the cost of Alternative 55- is considered low
to moderate ($5,806,139). The costs of Alternatives 54 and 56
are considered moderate ($9,747,198 and $10,103,654
respectively), while the cost of Alternative 57 is considered
35
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moderate to high ($15,660,298). The costs of Alternatives S8 and
S9 are considered high ($25,649,695 and $27,721,216
respectively).
The actual volume of soil that will be treated may change
once field operations begin. Of the alternatives that involve
treatment of soil, the costs of Alternatives S4 and S5 are the
least sensitive to changes in volume, while the costs of Alterna- .
tives S6, 87, S8, and S9 are the most sensitive to volume
changes.
state Acceptance
The State of California, through both DHS and the Regional
Board, has participated in the RIfFS activities. Both state
agencies assisted in the development of ARARs, and DHS has been
active in the remedy selection process. Since Alternatives Sl
and S2 are not protective of human health, these alternatives
would not be acceptable to the State. Since Alternatives S3 and
S4 do not use treatment or provide long-term protection, it is
unlikely that these alternatives would be acceptable to the
State. Alternatives S5 through S9 may be acceptable to the
State; although the State has expressed concerns over residual
solvent associated with Alternative S7. The State has also ex-
pressed a desire for some form of pretreatment with respect to
Alternative S5. -
Community Acceptance
Public comments on the proposed plan are presented in the
"Response Summary" (Appendix B) of this ROD. Alternatives that
are not protective of human health and the environment (Sl and
S2) and do not provide long term protection (S3 and S4) would not
be acceptable to the community. It is anticipated that onsite
incineration would not be acceptable to the community. Further-
more, it is anticipated that Alternatives S5 through S9 would be
acceptable to the community, although several individuals have
expressed concern about contaminated soils at depth that are
being left in place.
IX.
THB SELECTBD REMEDY
This section presents the selected remedies for groundwater
and soil contamination. Alternative GW4 is the selected remedy
for groundwater, and Alternative S6 is the selected remedy for
soil. The cost of the groundwater remedy is estimated to be
$7,207,027 and the cost of the soil remedy is estimated to be
$10,103,654, resulting in a total project cost of $17,310,681.
Tables 5 and 6 provide a cost breakdown for the groundwater and
-soil remedies.
36
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I__~_~.
TABLE 5
COST OF SELECTED REMEDIES FOR GROUND WATER
COST ITEM TOTAL UNIT COST TOTAL
QUANTI'IY ($/UNIT) COST ($)
. CAPITAL COSTS
GW Collection
ExtraCtion Wells 17 5,000 85,000
ExtraCtion System (17 pumps, 5 panels) 1 85,000 85,000
Compressor 1 3,500 3,500
Collection System (allowance for pump, piping, tank) 1 20,000 20,000
Treatment System
Air Stripper 1 15,000 15,000
CarbOn Unit (2-2000 Ib units) 1 60,000 60,000
Transfer System (pump filter) 1 5,000 5,000
InjeCtion System (pump, piping, tank) 1 30,000 30,000
InjeCtion Wells 2 10,000 20,000
TOTAL DIRECT CAPITAL COSTS 323,500
25% EPCM (a) 80,875
30% CONTINGENCY (b) 121,313
TOTAL CAPITAL COSTS 525,688
OPERATION & MAINTENANCE COSTS
Access Restrictions
Maintain Fence & Gate yearly 1,000 1,000
Patrol Site (by client personnel) daily 27 10,000
GW Extraction!freatment
ExtraCtion System Compressor yearly 2,000 2,000
Pump Ejector Replacement (20% of Equip. Cost) yearly 17,000 17,000
Operator daily 35 13,000
Maintenance Crew (2 engineers, 2 days/month) 400hrs1yr 3S 14,000
CarbOn Replacement & Disposal yearly 6,500 6,500
Packing Replacement or aeaning yearly 1,000 1,000
Transfer Pumps yearly 3,000 3,000
Filter Replacement yearly 500 500
GW InjeCtion
InjeCtion Pumps yearly 3,000 3,000
Treatment Monitoring (Influent & Effluent) monthly 3,200 40,000
Groundwater Monitoring
Two Field Engineers 160 brs/yr 50 8,000
Pump Trucks 4 timeslyr 2,000 8,000
LabOratory Analysis 4 timeslyr 45,000 180,000
Annual Planning & Reponing 300 brs/yr 50 15,000
SUBTOTAL ANNUAL O&M COSTS 322,000
35% MANAGEMENT & CONTINGENCY (c) 112,700
TOTAL ANNUAL O&M COSTS 434,700
O&M PRESENTWORTII (30-1' @ 5%) (d) 6,681,339
TOTAL PROJECT CAPITAL AND O&M COST 7,207,027
l'OO'TNarrs:
(a) 25% EPCM is 25'11> o( t01a1 direct capilal COlt!.
(11) 30'!1> coaliaceacy is 30'!1> o( tile lum o( tolal direct c:apilal c:ostIaad 25'11> EPCM.
(c) 3S% maaacemeDt & coaliaceacy is 3S'II> o( lubtotal aaaul O&M COItI.
(d) O&M preseat wonll owr 30 yean (a -30) at a discouat nte o( S'II> (i -O.OS) is tile product o( tile auual O&M COSII aad a
(actor F o( tS.372S. c:alc:ulated (rom tbuqulioa F - ((1+ i) ~ a).I) I(i:ll (I+i) ~ a~ wbere OM me8aa"to tile power 0(".
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TABLE 6
COST OF SELECTED REMEDIES FOR SOIL
COST ITEM UNIT TOTAL UNIT COST TOTAL
QUAN1TIY ($/UNIT) COST ($)
CAPITAL COSTS
Exc::avationlBackfilllCompaction cy 25,000 8 200,000
Shoring of Waste Pond (Sheet Pile) sf 6,400 9 57,600
RCRA Cap for Waste Pond sf 7,000 5 35,000
Asphalt Capping lot 1 524,000 524,000
Soil Washing:
Mobilization/Demobilization lot 1 200,000 200,000
Soil Washing (Volume Reduction) tons (a) 37,500 75 2,812,500
Stabilization of Fines tons 11,250 125 1,406,250
Wash Water Treatment (Allow) 1,000 gal 2,500 100 250,000
Mobile Confirmation Sampling day 188 1,500 282,000
Laboratory Confirmation sample 500 500 250,000
QA/QC Lab Testing ton 37,500 2 75,000
Soil Washing Total 5,275,750
TOTAL DIREcr CAPITAL COSTS 6,092,350
25% EPCM (b) 1,523,088
30% CONTINGENCY (c) 2,284,631
TOTAL CAPITAL COSTS 9,900,069
OPERATION & MAINTENANCE COSTS
RCRA cap maintenance @ 5% 1 1,750 1,750
Asphalt Cap Maintenance per yr 1 6,000 6,000
SUBTOTAL ANNUAL O&M COSTS 7,750
35% MANAGEMENT & CONTINGENCY (d) .2,713
TOTAL ANNUAL O&M COSTS 10,463
O&M PRESENT WORm (30-yr @ S,*,) (e) 160,835.
ADJUST 42,750
TOTAL PROJECf CAPITAL AND ()&MCOsT ," . 10,103,654
FOOnJOTES:
(a) Assuming 1.0 cubic yard equsls 1.5 tons.
(b) 25% EPCM is 25% of lotal direc:t capital costs.
(c:) 30% conlingency is 30% of Ihe sum of lotal direcl capital costs and 25% EPCM.
(d) 35% management & conlingency is 35% of sublotalannusl O&M costs.
(e) O&M presenl wonh over 30 yean (n"30) ala discounl nte of 5% (i..O.05) is Ihe product of Ihe annual O&M costs and a
rac:l.orF of 15.3725. calculaled from Ihe equalion F '" [«1 +i)"n)-lJ I [i x (1 +i)'" nJ, where.""" means .10 Ihe power of".
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Selected Groundwater Remedy
Groundwater Remedy Description
Alternative GW4 is the selected remedy for cleanup of
groundwater contamination at the FMC-Fresno site. The cost of
the selected groundwater remedy is shown in Table 5. The
selected remedy will result in a residutl carcigogenic risk
within the protective risk range of 10- to 10-. The goal of
the remedial action is to restore the groundwater to its benefi-
cial use, which at this site includes use as drinking water.
Based on information obtained during the remedial investigation
and the analysis of all remedial alternatives, EPA believes the
selected remedy will be able to achieve this goal, at least
within the area of attainment. The area of attainment. has been
defined as all areas within the contaminated plume except im-
mediately below those areas where soil contamination, in excess
of the.selected cleanup standards, has been left in place (ie.
portions of the south central 4.92 acre-area, waste pond, oil
drum yard, and certain hazardous waste sumps. Specifically the
selected remedy for groundwater cleanup is as follows.
Implementation of institutional controls restricting
the installation of onsite water wells, except those
used for monitoring and extraction of contaminated
groundwater. Furthermore, periodic monitoring of all
wells within the area of the contaminated plume will be
conducted. If any of these wells contain contaminants
in excess of the selected cleanup standards, then the
wells will either be replaced, fitted with well-head
treatment systems, or an alternative water supply will
be provided. Furthermore, if it is determined that the
use of any onsite or offsite well will adversely affect
the groundwater cleanup plari, then an alternative water
supply will be provided to the user of this well.
Groundwater extraction from both the first and second
saturated sand zones. The number of extraction wells,
location of these wells, and pumping rates shall be es-
tablished during the RD phase. However, the design of
the groundwater extraction system should be sufficient
to capture all contamination beneath and emanating from
the FMC-Fresno facility, that is in excess of the
selected cleanup standards (see Table 1). Groundwater
extraction 'and treatment will be conducted until the
selected cleanup standards have been met at all points
within the area of' attainment. Additional groundwater
investigations will be performed in order to define the
downgradient extent of the contaminant plumes and to
develop hydrogeologic models for design of the extrac-
tion system.
37
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1 ~ '.. ~ {~
The extracted groundwater will be treated using air
stripping and carbon adsorption technologies. A vapor
phase carbon adsorption unit will be added if emission
of VOCs from the air stripper exceed requirements of
the Air Pollution Control District of Fresno County or
if emissions exceed the federal limit of 15 lb./day.
Groundwater that has been treated to the selected
groundwater cleanup standards will be reinjected to the
second sand zone or deeper, depending on the location
of the reinjection well and the volume of water being
reinjected. The number of extraction wells, location
of these wells, and reinjection rates will be deter-
mined during the RD phase. A portion of the
treated groundwater may also be re-used onsite.
continued groundwater monitoring will be conducted at
and downgradient from the site for a period lasting un-
til at least five years after the selected cleanup
standards have been met. Furthermore, as required by
40 CFR Parts 264 and 265, the period of groundwater
monitoring will not be less than thirty years. Addi-
tionally, all residential, municipal, agricultural, and
industrial wells located within the area of the con-
taminated plume will be monitored periodically.
Groundwater Remedy Selection Rationale
Alternative GW4 provides the best balance of tradeoffs with
respect to the nine criteria. Alternatives GWl and GW2 were not
protective of human health and the environment and did not meet
ARARs. Alternative GWS could result in increased migration of
deep soil contaminants to groundwater, which in turn could cause
increased risk associated with exposure to groundwater. Alterna-
tive GW4 was preferred over Alternative GW3 since groundwater
resources are conserved under Alternative GW4.
Selected Soil Remedv
Soil Remedy Description
. Alternative S6 is the selected remedy for cleanup of soil
contamination at the FMC-Fresno site. The cost of the selected
soil remedy is shown in Table 6. Surface and near surface con-
taminated soils contaminated by pesticides, herbicides and other
contaminants constitute the principal threat at the site through
exposure via direct contact and ingestion. The selected remedy
addresses this principal threat through a combination of excava-
tion, treatment, capping, and institutional controls. Deep sub-
surface contaminated soil at the site constitutes a low level
threat through migration to groundwater. The selected remedy for
soil addresses deep soil contamination through containment
(capping) and institutional controls. In addition, the selected
remedy for groundwater addresses deep soil contamination by ex-
38
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tracting and treating any contamination that migrates from the
deep soil to groundwater. Through the use of capping and in-
stitutional controls, the selected remedy for soil attains a 10-6
level of protection by preventing exposure to contaminated soil.
Through excavation a~d treatm!it of, contaminated soil, the,
selected remedy prov~des a 10 level of long-term protect~on
should the cap or institutional controls become ineffective in
the future. Specifically the selected remedy for soil cleanup is
as follows.
Implementation of institutional controls which would
consist of deed restrictions precluding the construc-
tion of residential buildings onsite, and would require
compliance with. California Health and Safety Code Sec-
tion 25232. .
Excavation of contaminated soils to selected cleanup
standards. At a minimum, this would require excavation
within the following site areas: 4.92 acre-area, waste
pond, oil drum yard, tank pads, hazardous waste sumps
(HW2, HW7, HW9, HW12), rainwater sumps (RW14), and
stained soil areas. A maximum excavation depth of 15
feet below the present land surface has been selected
for the following reasons: .
it is unlikely that future receptors could
come in direct physical contact with soil
contaminants present at depths in excess of
15 feet;
a cap will be installed to prevent contact
with contaminated soils left in place and to
prevent infiltration of rain water;
results of the RIfFS indicate that in several
areas of the site, there is a significant
decrease in soil contaminant levels between
10 and 15 feet below the land surface;
results of the RIfFS indicate there are only
a few areas where contamination is present in
excess of the selected cleanup standards
below 15 feet; and
cost and technical considerations make it im-
practical to excavate further than 15 feet.
As the FMC-Fresno plant is an active facility, excava-
tion. and treatment of contaminated soils in excess of
the cleanup standards, beneath areas within the active
portion of the facility, will occur in a phased manner
to allow continued operation of the facility. The
scheduling of this phased approach will be determined
during the RD phase.
Excavated soils will be treated using soil washing and
stabilization technologies. The purpose of the soil
washing process is reduce the volume of contaminants
39
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. . ;~~. tS"
i , . ~ . .. t i
"'j ";..,;.. r'. ,:',:'...
and soil requiring stabilization. The soil washing
process will also remove the more soluble and mobile
contaminants so that the stabilization process will be
more effective. Coarse grain soils separated during
the soil washing process will be used as onsite fill if
it is determined that the levels of contaminants in
these soils are below the selected cleanup standards.
Fine grained soils separated during the soil washing
process will be stabilized. Coarse grained soils that
contain contaminants in excess of the selected cleanup
standards will also be stabilized. The contaminated
rinse waster will be treated using carbon adsorption.
The stabilized material will be tested using the
Toxicity Characteristic Leach Procedure (TCLP) test to
ensure that the material is no longer a hazardous
waste. The stabilized material will also be tested for
compliance with state Soluble Threshold Limit Con-
centrations (STLC) and Total Threshold Limit Concentra-
tions (TTLC) as described in 22 CCR, Div. 4, Chapter
30, Art. 11, to ensure that the material is no longer a
hazardous waste. Finally, the stabilized material will
be tested to ensure there is at least a 90 percent'
reduction in contaminant mobility as measured by com-
paring total waste analysis before and after stabi-
lization. Once these requirements have been met, the
stabilized material will be returned to the excavated
areas. A portion of the stabilized material will be
also used in construction of the soil cement layer of
the cap.
Prior to performing the actual excavation and treatment
of contaminated soil, field-scale treatability studies
will be conducted in order to select the most effective
soil washing and stabilization technologies and to en-
sure that these technologies will meet the above men-
tioned performance standards. Bench-scale treatability
studies conducted during the FS indicate that stabi-
lization is capable of attaining at least a 90 percent
reduction in contaminant mobility.
After excavation, confirmation samples will be taken to
ensure that the selected cleanup standards have been
met.
All excavated or unpaved areas of .the'site will be
capped. Th~s combination cap will be constructed of
soil cement and asphalt. Since the waste pond is a
RCRA unit, the cap over this area of the site will need
to meet the RCRA requirements for capping and monitor-
ing. All capped areas of the site will be maintained
as appropriate.
40
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soil ....47 S.l.c~ioD "~ioDa1.
. Alternative S6 provides the best balance of tradeoffs with
respect to the nine criteria. Alternatives Sl and S2 are not
protective of human health and the environment and do not meet
ARARs. Alternatives S3 and S4 do not provide long-term effec-
tiveness and permanence and do not use treatment as a principal
element of the remedy. Although Alternative S5 is protective of
human health and the environment, meets ARARs, and uses treatment
as a principal element of the remedy; this alternative provides.
a lesser reduction in contaminant toxicity, mobility, or volume
as compared to Alternative S6. Alternative S6 provides a greater
reduction in contaminant mobility than Alternative S5. Further-
more, Alternative S6 provides a reduction in contaminant volume,
while Alternative S5 results in an increase in contaminant
volume. Alternatives S7, S8, and S9 were not selected primarily
due to their high cost. EPA felt it could not justify the high
cost of these alternatives given that some soil contamination
would still be left in place. Furthermore, there were some con-
cerns over the implementability of Alternatives S7 and 58.
Finally, it was anticipated that the community would have ob-
jected to Alternative S9.
x.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In ad-
dition, Section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for this site must comply with ARARs
established under federal and state environmental laws unless a"
statutory waiver is justified. The selected remedy also must be
cost-effective and utilize permanent ~olutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently
and significantly reduces the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following sec-
tions discuss how the selected remedy meets these statutory re-
quirements.
Protection of Human Health and the Environment
Threats to human health and the environment posed by the
site, include ingestion of contaminated groundwater, contact with
contaminated groundwater, inhalation of volatile organic com-
pounds (VOCs) in groundwater, and ingestion and contact with con-
taminated soils. The selected remedy for groundwater addresses
the threat of exposure by requiring extraction and treatment of
contaminated groundwater to regulatory and risk-based levels.
The implementation of institutional controls will provide further
protection by ensuring that water wells are not installed onsite.
41
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;. ::-1~7:~:';:'\'~~ln7' .;-~._--_. ~'~' :':, -I~'~'!i ,;.v':'.;J-'~:
", .
" ,> .--- . ~ , "
The selected remedy for groundwater will resuli in a ca~~inogenic
risk within the protective risk range of 1X10- to 1X10 and a
non-carcinogenic Hazard Index less than one.
The selected remedy addresses the. threat of exposure to con-
. taminated soil in several ways. First of all, by capping the
site and implementing institutional controls, the threat caused
by ingestion and contact with contaminated soils is removed. By
eliminating the soil exposure pathway, the selected remedy for
soil will attain a carcinogenic risk of 1X10- and a non- .
carcinogenic Hazard Index less than one. By excavating and
treating surface and near-surface soils to risk-based levels, the
remedy also provides long-term protection from ingestion and con-
tact with soils, should capping and institutional controls become
ineffective at some point in the future. . Since the4soil cleanup
standards are based on a carcinogenic risk of 1X10- and a non-
carcinogenic Hazard Index less than one, the selected remedy will
provide long-term protection within the acceptable risk range.
By implementing institutional controls, installing a cap, and
performing groundwater extraction, treatment, and monitoring, the
threat of exposure to deep subsurface soils, which could poten-
tially migrate to groundwater, is also addressed.
ComDliance with ADDlicable or Relevant and ADDropriate Reauire-
ments lARARs) .
The selected remedy complies with all federal and state
ARARs identified for the site. ARARs and TBCs identified for the
site are presented in Appendices A-1, A-2, and A-3, and are dis-
cussed generally below.
Chemical specific ARARs
Federal and State MCLs and non-zero MCLGs are relevant and
appropriate to the cleanup of groundwater at the FMC-Fresno site,
and have been selected as cleanup standards for the chemicals for
which they exist. Health-based cleanup levels for groundwater
were calculated based on TBCs for the site, and have been
selected as cleanup standards for those chemicals for which no
MCLs exist. Groundwater will be treated to the selected cleanup
standards prior to being reinjected onsite.
Health-based cleanup levels for surface and near-surface
soil were calculated based on TBCs for the site, and have been
selected as soil cleanup standards (to a maximum depth of 15
feet). Under the selected remedy for soil, treated soils will
not be returned to the ground unless they meet the cleanup stan-
dards or are unless they have been stabilized and meet the per-
formance criteria (ie. are no longer considered hazardous waste
under TCLP testing and have a 90 percent reduction in contaminant
mobility) .
42
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Aotion-specifio &BARs
40 CFR Parts 264 and 265 are ARARs.for the site. The
selected remedy for groundwater will meet groundwater monitoring
requirements described in these regulations. The soil remedy
will also meet pertinent sections of Parts 264 and 265. Since
the selected remedy does not involve placement of a restricted
waste, EPA has determined that Land Disposal Restrictions do not
apply. The selected remedy for soil will involve excavation of a
characteristic waste. However, prior to placement, this waste.
will be treated to levels that do not constitute a characteristic
waste, and as a result LDRs will not apply.
Air emissions from the air stripper will have to meet
federal and state requirements for discharge of VOCs. .The
selected remedy for soil will meet federal and state ambient air
quality standards during excavation. Reinjection of treated
groundwater will meet the substantive requirements for reinjec-
tion under federal and state statutes.
Location specific ARARs
No location-specific ARARs have been identified as pertain-
ing to the selected remedy.
Cost-Effectiveness
The selected remedy is cost-effective in addressing the
risks posed by the site. Section 300.430(f) (ii)(D) of the NCP
states that once a remedial action satisfies the threshold
criteria (ie. overall protection of human health and the environ-
ment and compliance with ARARs), cost-effectiveness is determined
by evaluating three of the five balancing criteria (long-term ef-
fectiveness and permanence, reduction of toxicity, mobility, or
volume through treatment, and short-term effectiveness. The
three groundwater alternatives that are protective of human
health and the environment, are all very similar in cost. The
selected remedy is the most health protective, provides the
greatest level of reduction of toxicity, mobility, or volume, and
returns treated groundwater to its beneficial use.
. .
The selected remedy for soil provides the best overall ef-
fectiveness at the lowest cost. Alternatives Sl and S2 are not
health protective. Alternatives S3 and S4 do not provide ade-
quate long-term effectiveness. The selected remedy provides a
greater level of reduction in toxicity, mobility, or volume than
Alternative S5. Furthermore, the Selected Remedy is sig-
nificantly less expensive than Alternatives S7, S8, and S9; yet'
still provides an acceptable level of long and short-term effec-
tiveness and reduction in toxicity, mobility, or volume.
43
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Use of Permanent Solutions and Alternative Treatment Technoloaies
to the Maximum Extent Practicable
. .
EPA has determined that the selected remedies for
groundwater and soil represent the maximum extent to which per-
manent solutions and treatment technologies can be used in a cost
effective manner. The selected groundwater remedy will result in
a reduction in the volume and mobility of groundwater con-
taminants through groundwater extraction, treatment, and relnjec-
tion. Continued groundwater monitoring will be conducted for a
minimum of thirty years to ensure th~t the groundwater remedy is
protective of human health and the environment.
The selected remedy for soil uses soil washing and stabi-
lization treatment technologies the reduce the volume pf con-
taminated soil and to permanently immobilize the soil con-
taminants. Additionally, a cap will be placed over the site to
reduce the mobility of soil contaminants left in place at depth.
When compared to the other soil alternatives that were protective
of human health and the environment and met ARARs, EPA feels that
the selected remedy provides the best balance of tradeoffs in
terms of long-term effectiveness and permanence, the statutory
preference for treatment as a principal element, reduction of
toxicity, mobility, or volume through treatment, short-term ef-
fectiveness, implementability, cost, and state and community ac-
ceptance.
Preference for Treatment as a PrinciDal Element
The selected remedies for contaminated groundwater and soil
satisfy the statutory preference for remedies that employ treat-
ment as a principal element. By treating the contaminated
groundwater to the selected cleanup standards using air stripping
and carbon adsorption treatment technologies, the treated water
can be returned to its beneficial use, either through onsite
reinjection or onsite use at the facility. By treating soils
contaminated in excess of the selected cleanup standards using
soil washing and stabilization treatment technologies, the remedy
addresses the principal threat at the site.
XI.
DOCUMENTATION OP SIGNIPICANT CHANGES
Cleanup standards for dioxins and furans in soil have been
included in the ROD. These standards were not previously iden-
tified in the proposed plan.
The proposed plan indicated the decision process for select-
ing groundwater cleanup standards would be based on the following
hierarchy:
federal and state MCLs (whichever is stricter),
health-based levels (when federal and state MCLs do not
exist) ,
44
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state Action Levels (when federal and state MCLs and
health-based levels do not exist),
quantification limits (when regulatory and health-based
levels do not exist).
The process for selecting groundwater cleanup standards has
been revised as follows:
federal and state MCLs (whichever is stricter),
state Action Levels (when federal and state MCLs do not
exist),
health-based levels (when federal and state MCLs and
state Action Levels do not exist),
quantification limits (when regulatory and health-based
levels do not exist).
The proposed plan indicated that health-based levels rather
than MCLs were selected as groundwater cleanup standards for four
chemicals whose MCLs only achieved a 10- level of protection.
These four chemicals were BHC-gamma (lindane), toxaphene, hep-
tachlor, and ethylene dibromide. Upon further review of the risk
data, this list of chemicals for which health-based levels rather
than MCLs were selected as groundwater cleanup standards has been
revised to include only toxaphene and ethylene dibromide.
Finally in response to public comments received, a require-
ment for periodic monitoring of all residential, municipal,
agricultural, and industrial wells located within the area of the
contaminated plume has been added to the selected remedy for
groundwater. If any of these wells contain contaminants in ex-
cess of the selected cleanup standards, then the wells will
either be replaced, fitted with well-head treatment systems, or
an alternative water supply will be provided. Furthermore, if it
is determined that the use of any onsite or offsite well will ad-
versely affect the groundwater cleanup plan, then use of this
well will be discontinued and an alternative water supply will be
provided to the user of this well.
45
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APPBNDIZ A
."
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TABLE A-I(I)
fEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE
Sta.u.. .r Repl.'''.
CII.II..
YesINo
Applia ID CERCL\ lile ctiJc:h8.. to public
drinkin. Wilier IOIIIa8, incladin. wldtol'uund
drinldn. wilier 1IOIIn:eI.
SlI'e Drintina Wiler Ad
42 U.S.C. I 300f .
WIllI.
Pub. L 93-5ZJ
Nllion8I Prinury
Drintin. W"""
SI8nIIInII
40 CFR Part 141
Muimam ConI8millllll
Lewd GoaI8 (MQ.Gs)
40 CRt 141,
Sabp.. F
Ut.dt.puomd Injecdon
Control Rqal8lion8
40CFR
PIiiU 144-141
Duerlpllo.
0081 01 the Ad 810 P"*d INm..
heallII bJ proIIICtin. the qu8lily or
drinkin. wiler. The Act..1horiua
the esl8b1islunal1 of cn.tin. Wilier
8IIIIdIIdL
Eatablisha primary muim8m con!8-
mill8llllewe" (MCU) IIIIt .e heallII-
b8scId ...... r... public wll«
'JIIeIIII
Eltablilha drinlinl wiler .8II1J
1081. HI ..leYe" or no known ...
IIIIicipI8ed "'me health effects.
willi IIIIdeqaIle m8p ollll'eIy.
PIurideI f... potecdon or ....
poand COUrta or mntin; w8Ia.
(I) The AltAR. icIenIificIIion Ind ddmntnlllon pIuce8I 8 cllalAed in Section 13 of the leal
,
FMC-Fresno
A-l
Appllublel
Relnan' and
Approprla'e
Co....,
YesINo
~ - AltAR. for IIIJ water dill 8
considered ID be . IOIIIt:e ... potenti81
IOUn:e or ch1kin8 Wiler. Me'" - .."Hc:eble
lithe lip when the -ta is directly pnwided to
25 or more people or 15 ... more ""ice
connecbonl. 0IherwiIe. Me'" .e relnllll
end IppIUIIriIIe.
NoIYa
MCLGIII'e not fedenIIJ enfon:able *Wdna
wiler""'" INI CERaA ,121(d) ....
raised MCLGIInd WIler qa8li1y criteri. (-
below) 10 the IeYd 01 poIaIli8lly rele.... end
eppropriIIe. MCLGI m.y be conIidmd when .
CERaA cle_p mey reqaile more mnln
......... then the MCLI. EPA"" determined
11111 the 11M or MClDI wiD be decided on .
cue by C8Ie b8li.. MCLOI- reln"llnd
IppI'OpI'iIie where the chemic8l-.pa:ific 1081 is not
laO.
YesINo
SabltlllliYe reqaIremenIa meJ Ipply if 8re8Ied
pound W8Ia is reinjecled.
-------
T AILE A-I
FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS. CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE
Statut. or Replallo.
cllan..
DuulpUo.
A ppUnblrl
Rrlnanl and
Appropriate
Com.e.'
CIe8n Wr18 Ad
W... QuliIJ
Critaia
TOle Pollaunl
fJII8aII SIIndInII
N8dan8I PoIlu...
DiIch8rp Elimination
S,IIan
FMC-F"--"o
33 U.s.C.
, 1151-1376
40 CFR P8rt 131
Qa8Ii1J Crileria
for Wiler, 1976.
1980,1986
40 CFR PIlI 129
40 CFR
Plit 122. 115
PIoridr.s for the raIOntion UIII
munteftlJlCe or the chemicll, physicll,
UIII biolOlicll illlepily of the nation's
waten. Enlblina ltatu~ for a Iys~m
of minimum n8lional dllamt disch_If:
ItIndards; a c:onstruction Ifllll program ror
I'01Ws; oce8P discharlf: laIuirements; IIId
wr18 quality criteria.
FedtnI .... qaaIiIJ aikria In:
..iddina &om which S"'detamine
their -Ia quality ........ Criteria ue
"doped for die proIeCtion of humlll
health and aquIdc lifc.
Establishes eflluenllIandanI8 01
prohibilions for u:rt8in toaic:
poilu.....: IIdri~ielcna. oor,
endrin. 1Ouphene. benzidine. PCB..
Requires permits for die dilcharJc
of pollutants &om any poinlSOUn:e
i.-o wllas of the Unik'Jd SI.es.
The Actdelinea a poinlsoarce u
any diJamable. confined or
discme comeylllCC from which
poIlullllllln: or may be discharpd.
Ernuenllimilltion. mUll protect
bmeflCiai uses of _la.
M
YarlNo
NoIYea
NclNo
NcINo
Applicable 10 direct dilcharpllO nrfaoe w....
An indinx:t dischar.e 10 a PUI'W may be conai-
dl:red.. off-aile 8ctiYity even thou.h die con.
ycyance Iyllem it 10C8Ied on-lile. A PUI'W
may require a CERCLA WUlewllla 10 nM!Ct
"prdJe8IIPa1t" atandards prior 10 accepunca.
If a waea qulltty standard is anilable ror a
con&amin-. that IUddIl'd should be used nths
th.. the c:ri1eria. Buin PI... established Wala
qulltt,....... in the State. Wiler qulltty criteria
lie reieY... and appropriIIe in c:aa where a standard
doea POI Cllist.
Appliea 10 apedfied f8cilidea diac:h.,inl mlO
payilable walal.
NPOES iI POlin AKAR for reinjection or
disch_ac 10 the PUI'W. HoWCYCJ,Iubltan-
bye and administrlliyc requirements and
pretreatment Sl8ndards may haYe 10 be met fOl
disch_Ie 10 the PUI'W. .
-------
'TABLE A-I
FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS. CRITERIA, OR LlMlTAnONS
FMC FRESNO PLANT SITE
S.8.D.e or -...-18.".
EIIIaenI Gtlidelba ...
SI8Mbrdl for PaIicide
ChemkaI Manaf8Clllrina
NIIionII Pr~....nent
SIInd8d8
Clean Air Ad
NIIionII Prim8y ...
SecondIry Ambienl Air
QuIiIy SIInIIInI8
NIIion8I EmI..1on
SI8IdInI8 for IIaz8do8
Air PolI.""1I (NESHAPS)
FMC-Freno
CII.II..
Delcrlpll..
Appllnblr'
Rrlnan. and
Appropr.a..
Co..e..
40 CAt P8rt 4SS
40CFR
P8t 40)
42 U.S.C.
II 14011iLB1L
40 CFR
P8t SO
40 CFR
Pm 61
ReqainllpeCific efllaenl c:h8ncteriJ-
Iia for poinl108rc:a of disch8rae
10 ....illble w8lal.
Sell II8IIIIIrda ID aJl'lbol poilu.....
which P" Ihmulh or intcdae wilb
IIaImaII proceua in pabliclY-Gwned
IraImaIt WOIb (POTW) or which may
ClllUminale leWllae .Iad..
Re..... emiaiuna ID protect a.m..
huhh ... !he tIIYimnmenI.. En_linl
.latule ror mljor proYilion8 I8dI u
Na~Am--Air~~SIand~
NESHAPS. ... NSPS.
Emblilha NIIionaI Ambient Air
QuIi~ SI8MbrdI (NAAQS)
for !he proIecIion of public
he8hh ... wdflR.
Seta emI..1on IIInIbrd8. monllorinl.
"'Iatina reqairanau for
de8iJRl!led.lwerdoas pollublnlllUda.
mercury. beryllium, ubalOl.
inorl- enenic. ... benzene.
SIIndanII onI, lippi, ID apecilically
named 1OIIrc:a in !he rqul81ion8.
A3
NcJ(Ya
YalNo
Ya,INo
Ya,INo
NoINo
Applia to di8ch... raahina from Ihe IIIIIIII-
flCCUrinl of patitidt:.. PraraImmIIl8nd8nl8
for new IOUIa8 are aamnd, ~1ROYed. If.udI
reqainlmenll are n:in818t1Jd, Ihey 1ft poIenli8ll,
rdeY......1ppIOpIiaIe.
The all8ft... e.8Ia8I8d m8J Include
di8c:huae ID 81U1W.
Sut....dYe reqailanenb 01 Ihe Y8iou
pI'OJrImI (e.l.. NESHAPI. NSPS)
promed by !he Clean Air Ac:l1ft prima;1y
implanenled Ihmup !he reaionll Air
Pollulion Conbol DilIric:u for '''1ion8ry
-rea. Applicable for nmedial lllem8dye
ifill may ~h in air emil.iORl.
PrImary 8IInd8nI8 8pptic8IJIe to .,
11l8ft8dYe emiaina reluilled poilu"'''.
Chemical, repilled by NESHAPS
hne IlOl been iclenlified llihe lile
IndIor emillion IOUR:eI nlllled in !he
~auillion are IlOl8 CIOIlljM1ent of
!he remedial 8hrmlliYa under nllulion.
-------
T AILE A-I
RDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS. CRITERIA. OR LIMITATIONS
FMC FRESNO PLANT SITE
S'.'a.. .r R.pl.'''.
cu.u..
De.erl,Uo.
Appllc:ablel
Relnan' and
Approprl.'.
Co.....
New So8n:e Pafonn...
S1and8dI (NSPS)
Solid W.1e DiIpo8aI Ad
HIZII'doa8 Wille MIIIIp-
menI SJIIaIII General
5...... Apptic:abIe tit
GenaIlOn of H8l.IIdoa
Walle
S""" AppIicIbIe tit
Tr_..-Ibo. of IIuInIo8
Walle
SIIndInII fur 0Mwn II1II
OpInIon of IIaunIoaI
Wille TruImenL S8on8e.
end DiIpouI FacitiUel
FMC-F- .,0
40CFR
Plit 60
42 U.s.C.
It 6901-6981
40 CFR PIlI 260
40 CFR PIlI 262
40 CFR 'III 263
40CFR
P1lt264
SdI emission .18ndInI8 for new
II1II modified 1OIIIaII. The ItnIIrdI
RI1ecIIhe depee of emission reduction
. ldIinlible dwouah danonstnled
tJa. lel:hnolou. COIIIiderinl COllI
end a ..mba of ochet flClOR.
11IiI1Iw - been .........
bJ RCRA end HSWA.
Pnrride8 definidonl of h8z8doa
Wille lamS, procedufts for rule-
mlkina pditionl, end pmc:edurea
for delislinl a W8IIe.
I!II8IIIisheI ....... for
amenron of haz8doua WI8te.
ElubIishelIt8nd8dl which IppIJ
to pmonIlrll1lpOltinl haz8douI
.ute wilhin &he U.S. or if &he Iranl-
portIIion reqaira a mlllife81 under
40 CFR 'lit 262.
Ealablishea minimam lIIIionai
...... wtUch define !he 8ta:fII-
able lIIIII8Iement of hazlldous .-
for ownas 8nd opaaton of flCilibes
which Ire'" .Iore., or diIpoIe of
hazIIdous w8lle.
M
NoINo
YalNo
YalNo
YalNo
Y IJI/Yea
Subpllt E pnwidea"'" of pafonnmce for
incinerlIOrIlh. bum IOlid wale. .Solid
Wale. in !hiIlUbpIII is defllled . Rruse
containinl more dI.. 50'11. municipal type
W.Ie. Other IUbpllll of !he NSPS also do
not applJ.
May be lppIicabIe If.ari8nceI or delisdna II
nquind.
Appliable if !he leleded altemaliYe imolYea
I-alion IIId oII-si1e IrInlpOlt of haz8nIous
W.IeI.
Appticable If die teIeded remedy lmolYea
oII-1i1e 1r8lllpOlt8lion of haz8nIoa. wille.
Aff'/ mnedy .... lmolYea C8mId IreIImenI.
.toraae or disposal will aenerllly be Ipplicllble.
U !he action doeI not imolYe camnllrellmenl.
ltOJaae or disposal, it may be mennt IIId
1ppI'Opri1le.
-------
T AILE A.I
FEDERAL APPLICABLE OR R[LEVANT AND APPROPRIATE REQUIREMENTS, CRnERIA, OR LlMnATIONS
IiMC FRESNO PLANT sin: .
S.....e er R....I..Io.
CI..U..
Appllnblel
Relennl and
Approprlale
Co..e..
. 0enrnI FadJit'/
St8ndIrdI
.~.....
~ftIItion
. ~ Plan""
1!maJaK;,/ "'...........
. Mlllifaa S'JIImI. Record-
bepin.. ... ReportUt,
. Rcae- fnJm Solid
Wille M8II8pIIIC"
Unill
. CIonre... JIOII-
CIoIIIIe
o FiaInd8I Req;oLenlleftllS
. u.e... Manaaanmt of
Cont8inen
. Tank S'JI1e1M
FMC-Freno
DeurlpUo.
40 en 26UG.1UrA.
S.IJpIrtB
YesJNo
40 en 264.30, IUrA.
Subpll1 C
YesJNo
40 CFR 264~ IUrA.
Sa"" D
YesJNo
40 en 264.10. IUrA.
Sa"'" B
40 en 264.90. IUrA.
Sabpll1 P
YesJNo
YesJNo
40 CFR 264.1 to. ......
58"" 0
YesJNo
40 en 264.140. 4I!IS..
5."'" H
YesJNo
40 en 264.170. ......
Subpart I
YesJNo
40 en 264.190.......
Subpll1 J
Yes/No
AS
Applicable for on-Iite balmenl. l8Dnae or
dispouI of hu.8nIoaI w... Location II8nd8nII
(i.e. 1etb8ct from hoIooene f.ll and deai....
COIIItnK:tion. opalllion ... maintm8nce .18nd8nII
mlliyc 80 the 100- 'JC8I' IIood) 1118,/ be Ipplic8b1e
for . new 1IndfiD.
Applicable for on-lite 1re8tmeI.. ...... or
dispouI of hu.8nIoaIw...
Applic:8ble for on-Iite ......... 18ar. or
diIpoI8I of hu.8nIoaIw...
Applicable onI'J if W8I8e IIIrInIported for
off..ite baIment. 18ar8ae. or cIispouI.
Applicable if h8Z8ldoa1 w- nmaInI on-lite.
The muimum conl8minana concenlnliOlll
IhII can be rde8Ied from haurdou ..te
aniu ale 1dentic:81 80 the MCLL
AppIic:8bIe if....... -- "baled, I8DIed
or disposed of in . new on-lite ...11.
NoIlJIPlic8bIe for 00III01idaIion within 8R8
of conl8milllbon or in-lita lralmenl.
Applicable for clonRJpost-clolure of 811,/
1re8lmmlor dillpOlll uniL
AppHc:8b1e if nmedy imoIY.ltonIc of
haurdoul w.te in c:onI8inrn.
Applicable if remedy lnvolY.1re8IJnenI or
siorage of hu8dous ....Ie in lAnk sysl£m..
-------
.TABLE A-I
FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRnERIA, OR LlMnAnON!
FMC FRF..sNO PLANT SITE .
SlIItute or Replatlo. Cltatlo. Delcrlptlo.
. Sarface ~.8e8111 40 CFR 264.220, a.aa..
Subp8rt K
. W.te Pilea 40 CFR 264.250, d..BII,;
Sabp8rt L
. 1..8n11'caInw:nI 40 CFR 264.:no, ....
Sabp8t M
. L8nIIIiIII 40 CFR 264.300, d.BIL.
Sabpart N
. Ir..h......... 40 CFR 264.340, ....
Sa"'" 0
Appllubl~1
R~kY8D' and
Approprlal~
Co...e.t
NoINo
No remedy is beina COIIIidenId IhII would !lie a
new surface impoundment.
Yei/No
AppliCllble If ranedy imolYea l80nIe of
huInIoul walle in W8IIe pilei for . period
pula Ib.. 90 days.
NoINo
No ranedy is beina eu..icIa..cl1hll would
atilize Iud bUlmelL
Yei/No
Applicable If ranedy lmolYm pla:8nenl of
huInIoul wllte in . new on-lite IandfiU.
YesINo
Applic:able if ranedy imooIYm IIe8ImenI
of hazanIoaa W8IIe in .. on-li1e intinrnllor.
. MiaceU-
Una
40 CFR 264.600, ....
Sabp8rt x
Yei/No
Eaisdna emi.ioa limitadona in Sabpm 0
.e euendaJlylechnoloty-bued.. As 0' Ibis
date, additXmal emission timi.. !hat - health-
bued have Ileal rmalized bul not Jd promul-
I""" (FR. VoL ~~. No. 82, April 21. 1990).
Applicable If remedy imam8 on-lite
Ireatmenl in a milceUIMOUJ aniL
l...un Statal 1'5D
Facility S"" -
Closure II1II "'I-CIoI8re
40 CFR Pat 26~.
Subpart 0
EsIabIishr.l enure performance
I88ndIadIIIId poII<1oIun:
CIR requ8anentl.
Ya/No .
Applicable eo claaure of the W.te Pond.
FMC-P"--"'Io
M
-------
TABLE A-l
FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE
SUIuU
•r Regulation Cltatlos)
Description
Applicable/
Relevant and •
Appropriate
COIMMCBI
Ah* Emission Standards
forProccM Venu
SubpartAA
Ak Emission Standards
for Equipment Leak*
SubpartBB
EsuMishts standard limiting organic No/No
emissions at TSDFs requiring • RCRA
permit. Standard* apply to process venls
associated with foorce* such at solvent
extraction and air or Meant (tripping
operations that manage hazardous waste
containing at least 10 ppmw total organic
conccntrabon.
EstsDrishts requncuieiRM for equipment No/No
that contains or contacts hazardous
wastes with organic concentrations of
at feast 10 percent by weight.
Project watte contains substantially less
less than 10 ppmw organic
concentration.
Requtr
iaWily pcvtnn kv uvpcction
*dkeeping. Wane is not sufficiently
similar for requirement to the relevant and
appropriate.
Standards for the
Management of Specific
Hazardous Waste and
Specific Types of
Hazardous Waste
Management Facilities
40 CFR Part 266
EsuMishi
i which apply
to recyclable materials that are
reclaimed to recover economically
significant amount of precious
metals, including gold and silver.
No/No
No remedy is being considered that would
involve recycle or reuse of hazardous waste.
Interim Standards for
Owners and Operators of
New Hazardous Waste
Land Disposal Facilities
Land Disposal
Restrictions
Hazardous Wraste fnHiitu
Program
40 CFR Part 267
40 CFR Part 268
40 CFR Part 270
Underground Storage Tanks 40 CFR Part 280
Establishes minimum national stand- No/No
anta that define acceptable
management of hazardous waste for
new land disposal facilities.
Restricts the land disposal Yes/No
of hazardous waste and specifies
treatment standards that must be
met before these wastes can
be land disposed.
Establishes provisions covering • No/No
basic EPA permitting requirements.
Establishes regulations related No/No
to underground storage tanks.
If the selected remedy involves use of a new land
disposal facility. 40 CFR Part 264 standards
would be applicable.
Applicable If the selected remedy involves place-
ment of waste from outside the area of conta-
mination; if waste is removed, treated and
redepositod into the same or another unit A
treaUbility variance may also be applicable.
fVrmits are not required for on-site CERCLA
response actions. Substantive requirements of
40 CFR 264 may be applicable.
No underground tanks to be remediated.
FMC-Fresno
-------
TAILE A.I
FEDERAL APPLICAILE OR RELEVAr~!. ;~"J.t APPROPRIATE REQUIREMENTS. CRITERIA. OR LIMITATIONS
FMC FRESNO PLANT SITE
St.tut. .r Rqul.n..
Cltall..
Denrl,lIoa
Appllcablel
Relnant and
Appropriate
Co....t
~.....18I SafdJ ...
Haith Ad
....... MIIaiII
TnntIpOI18Iion Ad
....... MIIIIiIII
TI8IIIpOIUIioft
Replalionl
NIIIonII Hiltaric
Praenllion Ad
A~'"
Hilloric Praen8lion
Ad
Hi8lGric Sits. BaUdin...
Objectl'" Anliqaitiea
FMC.F '0
29 U.S.C.
It 6.51-671
49 U.S.C.
It 1101-1113
49 CFR P-
107. 171-171
16 U.S.C. t 470
40CFR 6.301(b)
36 CFR P8It 100
16 U.S.C. t 469
40CFR
6.30I(c)
16 U.S.C.
11461--467
40CFR
6.301(8)
Rq"" worbr health ... safely.
ReplllellnnlpOr1llian of
hu.8nIoas tn*riaIa.
Requila feclmllllf8dellO ..
inlO 8CCIOUnt the dfcct or any
Feden1Iy-8IIiIIed undM8tina or
licaaain. OIl UIJ dislrict, lite.
buildin.. IIInICIaJe, or object that
is included in or dipble for .
Inc:lalion In the Nadon" ReaiJter
of HiJlDriI: l'l1I:e8.
Es8IbIisha pruc:edura 10 prowide
felf plUGYlIion 01 hil8orica1...
arch8eoIosical daI8 which mi,.. be
deI8roJed d8'0Dlh alla'IIIIion of
Ianin . a raah of a federal
c:onsInIdion projeclor I fedr.nlly
licalled lICIiYiIy or propam.
Requ8a IedInIIllf8delIO
considerlhe uistence ...1oc:aIion
of landmarb 0II1he Naliona1 Rc,illIy
of NalUnl Landm8b 10 IVoid un-
clairable irnpactI on IUCh landmarb.
M
Yes/No
YesINo
N~
~o
NeINo
Applies 10 aU raponae acliYi1ea under Ihe
NCP.
Applicable If ..Ie .lhipped off..ite.
No dislricl. lite. baiJdina. IInIcIaJe. or objecI
.ill be 8fJccted th. iI included in or eli,ible for
incluaion in Ihe Nalion" Rc,iaIcr 01 Hilloric
PlII:e8.
The mnedJ' doea nul affect hiIIDrk:aI or an:haeo-
Iopcll data.
No nablnllan&nllb wiD be affeded.
-------
TABLE A-I
FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE
SUtutt or Regulatlo.1
Protccdofi aVn Conwrv ition
of WildUfe-Game. Fur-
Bearing Animals and Fish
Citation
16 U.S.C.
|| 661-667
Description
Requires consultation when Federal
department ot agency proposes 01
authorizes any modification of any
Applicable/
Relevant and
Appropriate
No/No
Comncal
No streams or other water bodies will be
affected.
Endangefed Species Act
16 U.S.C. 1531-1536
50CFRPut402
stream or other water body and
adequate provision for protection
of fish and wildlife resources.
Requires ictkut to conserve
endaiigetou species within cnocsl
habitats upon which endangered
species depend, includes con-
sultation with Department of
Interior.
No/No
No endangered species found on-site.
Clean Water Act
Dredge, or Pill Require*
mcnU(S«ctk)o404)
BOO off tuiuuff md
KIVOT iinpiwojiMfitv
Generally
General Regalatory
Policies • Department of
iheAimyCotpeof
Engineers
Excessive Order.
Protection of Wetlands
33 U.S.C.
|| 1251-1316
40 C« Parts
230.231
33 U.S.C. | 403
33 CHt Parts
320-330
•Exec, Order 11990
40CFR
|6.302(a)
and Appendix A
Requires peiiiiils for discharge of
dredged or fill material into
navigable waters.
Requires peiiirit for stntctores or
work in or affecting navigable
waten.
Requires Federal agencies to
avoid to the extent possible,
the advene impacts associated
with the destruction or loss of
wetlands and to avoid support of
new construction in wetlands if a
practical alternative exists.
No/No
There win be no discharge of dredged or fill
materials into navigable waters as part of the
remediation.
No/No
No/No
No activities wiD affect navigable waters of the
U.S.
There are no wetlands in the vicinity of the site.
FMC-Fresno
-------
TAILE A.I
RDERAL APPLICAILE OR REUVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE
S..tat. .r RIp18"o.
CII.....
Deurl,Uo.
Applluble'
R~lnan' and
Approprlal~
Co....t
f.IeaIIhe OrtIs.
F10cqMin MII'I...-m
NIIionII \ViIIImMa
~1Iion Syatem
N8don8I Wildlife
Refuae 5J1tem
Administrllion Ad
Wild .... Scenic RiYen
Ad
C..uI Zone M8I8aemen1
Ad
fMC-F- "0
Eaec. OrtIs 11988
16 U.s.C. 1 1131
50 CfR 1 35.1
16 U.s.C. 1 668dd
5OCfRI21
16 U.S.C. 1 1211
40CfR
1 6.302(e)
16 U.s.C. 114"
Requins FedenllsenciellD
enlalle &he P*ftbal dfecu 01
actions &hey may like in I
ltoodpIain 10 noid die IdYcne
imp8dl assoc:illed willi direct 8nd
indim:1 deYelopmenl of I ~ain.
Establlshe8 &he nadonal IJlIeIII of
wiIdr:meu .88 includina a policy .
for proIIIClina and mlRllina Ihe8e
II'UI. It prohibill ~ ldiYilim
wilhin wiIdrmeu 1IeII.
R8IIricIa ldiYities wililin I
NIIionaI Wildlife Refuae.
Pnlhibill adYaIe dfecu an
Ia:IIic riYa.
00ftrnI KliYiIielIn die
COlI'" mne.
A-I"
Ya/No
NetlNo
NetlNo
~o
NvlNo
Zone.. defined. 100.,.. ,hallow fIoodina
area. Howner. Oood pnJIIJC:tion project ...
authorized 8nd under COIIItI'Uc:tion. The 100.,..
Rood e"ft'lt il not e1lpec:ted 10 affect &he FMC
lite under poIt-projecl aHIIIiliona.
1bere _no wiIdcniea -- on-aite 01
adjacalllD lite.
1bere _no wildlife rd'aae - OIHite or
adjacalllD lite.
1bere - no deli""'" wild 01 acenic
riverl on-litc or adj8CeM 10 lile.
Site II not Ioc:tIed In I CI08I'" lJDIIe.
-------
TABLE A.~I)
STATE APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE .
SI.lute .r Rel'll.tloll
cu.tI..
Delerlptl..
Applicable!
Rele..nl and
Approprlale
Air RaolllU8 Act
Co..e.t
PIano CoanlJ Air
PoI181ion Control
Dialric:l Run 8nd
Repl8lion8
Air TOllel -Hot SpotI-
Infurmllion ...
AIUIIInaII Ad
C8lif0mi8 We
Drinkina Wlia Ad
JIaJIh a SaldJ
Code. Div. 26
Sec. )9000 ~
11 CCR. Pwt m,
Chapta I, Sec.
60000 ....
fIano ea...., Air
PoUalioe ConIroI
DiaIrid Ru. ...
Rqalldonl
tIeaIIh a SlldJ
Code. ChIIJ'G 1151
S.... 1981
Sec. 400 J&..BII.
JIaJIh a SrldJ
Code, Div.~,
P.. I, Chapter 1,
Sec. 4010 J&..BII.
Rqublea both ......vehic:a" II1II
vehic:ulu IDUna 01 air conI8ni.
nanII in California. Define8
reillionship of the California
'. Aw R-.:a B08d (ARB)'"
local or reaional air pollution
c::oncrol districts (APeD).
Eatablishel Ambient Air QualiIJ
Stmd8dI.
. Run'" rquilliona pertain 10
.talion., IOUIU8 of Iir anislionl.
Rulel ad&eu visible aniuionl
prohibition, incinr:rIW lllandlrdl,
nais8nce, 8nd complilllCe wi... PSI>;
NESHAPS; NSPS; 8nd ambient
air anislion 1I8nCI8dI.
Requira openk1n of (adlida
emittina 100ft IhaS'I I tpeCified
!eYei 0' pollalll\l8 10 pafonn
1ft ISIeIIIIICD 01 "-
emil.ionI. Cer18in (KiUda.
upriori1izedbJlhelir
dillrict will need 10 perform a
rist IllalmenL
ReJUlllkIIII pam. public
wiler Iync"" proYides for
driMina wiler quality
II8ndInII . Muimam
ConIIminanl Levell (MCLI),
Secondary Muimum ConIaminllll
Leyell (SMCu).
(I) The ARAKI ideNificllion and ddaminllion pmceII it discuaedln Section 1.3 o( the leU.
FMC-Frnno
A-II
YesJNo
YesJNo
YetlNo
N~a
The Ad II primarily Implemented dao8.h the
APeDa (or llllion., lOurc:a.
Sablllnlift nqairemIeNIlpplicable 10 allemadYa
III.. hive the polenlial 10 emit air poIlulanta.
Sa"l8IdYe requiraMIllllllppticable 10
10 aluml,"a thII anit lubstanca
reaul8led under Ihe -Hot Spots- proanm
Muimum ConIami....1 Levell are IICCepIIbIe
COttLOlblllion limill from I -free f1owin. cold
willer outlet of the allimJlle user. - To apply
thilltandIrd . I cleanup level (or pound
Wiler me...1h81he law, II1II the II8nCIard, II
-rilevllll 1IIII1IppIOIIriIIe-.
-------
TABLE A.2
STATE APPLICABLE OR RF-LEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE
S....te or R~ul.llo.
CIt.....
Deur'pll..
Appllcabltl
Rtlnanl and
Approprla't
COIDllle.'
Califomi. Slfc
Drintinl Watt:r Act (aIIII'd)
...... CoIope W8Ier
Q8a1iIJ Conlrul Ad
FMC-J'
'0
22 CCR. DiY. 4,
ChapIer IJ,
Sec.6440I",.
W- Code. DiY. 7,
Sec. 13000",
23 CCR. Dn. 3:
- ChIp8er 9,
Sec. 22100 IU&
- ChapIer 9.1,
Sec. 22AO .....
-Chlp8erlo.
Sec. 2JOO .....
. - Ch8p8er IJ,
Sec.1JIOIU&
- ChIp8er 16,
Sec:. 2610"",
E8c8bIishr:I prina8J and Iea1IIdIry
..... W81a""'" for public
. Wala IJlIe1n8.
JcIendIicaIion or ..... dada and
authorities of State and Rcpooal
Wltallo8rdL
W.. Disch8ae Rcportalllll
Requirements.
1!nfoR,a'1iI:III """"""e. ..
Calc and DeaiIa Ontrn.
I..Icen8Ina and Rcplalion or
Use of Oil Spill Cleanup Alenta
DiIdI.. or W.. eo lAnd.
Replations atabtishinl ...te
and lite cl_ificationl and
WIIte manqementnqairanaltl
. wute 1reatmeN,. IlOrqe. or
diIpoIaI in landfiUl. IUrface
impourdnentl. wute pilei, II1II
land Ire8lment facilities.
Underpoand Tank Rqalationl.
New and eaistinl UST oonstruc:tion.
monitorina. repairs. releases of
IUbstances and closure.
A-'"
Y eaJNo
N~es
NQlNo
N~
Yfll/Yea
NQlNo
The Cenlral VIlleJ RqionaI W8lerQalllty
Conlml Board will be in.utYed in aettina
cleanup pia for anJmina&ecl aoil and around
wlta and for detaminina ~Ie conditions
for reinjection.
SubItandYe reqairantftll may IppIJ If the
remedy ImotYea a new wute m_aanena
aniL
Adminillr"ft nquiremenll not ARARL
Oil spill cleanup qen18 not pat or potential
remedies.
Applic:lble eo cloaare or Wille pond. May be
lppIicable or ,*,,11\& and 1ppI'Opi* If remedy
in.ulYes use of new ReRA 1....60 or
enp.aed odJ.
. No underground tanb 10 be remedilfed.
-------
T AILI A-J
STATK APPLICAILE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LlMlTAnONS
FMC fRESNO PLANT SITE
51.11111 .r RIpI.IIo.
CU.II..
DllerlplloD
Appllnble'
Reln.nl 8nd
Approprl811
Co..eal
W.. Well SUnd8dI:
Stale ofr.liforni.
CItifomio H8Z8Idoua
Wille ConllOllAwI
Site DriItina
W8Ief A TolLia
EnfOlClelllall Act
of 1916
rPmposidon IS'
C8Iifuraia H8Z8doaI
Subsl8lte ACCI08n&
~
Sab8aInca C1an8p
Bond Ad
FMC-Frallo
BIllIdin 74-11
Ite8Idt a Slfdy
Code. DiY. 20.
a..- 6.5,
Sec. ~Ioo.....
22 CCR, DiY. 4
ChIpta 30,
Sec. 66001 a.JIII,
HeoIIh a Slfdy
Code. Diy. 10,
CIup8a 6.6,
Sec. 2624905
....
Hahh a Slfdy
Code, Diy. 10,
Ch8pta 6.8, See.
~JOO fiI.BII,
The IIIndInIIIft inIend8d ID ""'.,
to the conslnlc:tion, Iftd I118jor
,,,,",,,Dt......uon. or clabutlion of
Wilier weill.
Rqalllions .~"" h8z8rd0u1
W8I&e COIIIrOI; mlll8lanena Iftd
CIOIIIrOI of huonIoua wale flcililim;
tnnsponation; labonIories;
cl8Uific8lion of exRmely hounIoal,
hourdouI, Iftd nonhaz8doua wlSle.
Minlmam .......... for man..,.,..
of hu8rdoua ... eJlllandy
hu8doaa Wille.
Protection of clrintina wsta by
prohibilinl any delel:l8b1e disc:h8le
of cat8in listed an:in0p8 ...
reprodlldive IDUc:8ntI. Reqaira
wom. ID be aiYeII wha8 any
eXpoIIIre ID the chemic811
(repllled .... die Ad) 1ft
8I1icip8ted.
EIubIisha . propun to pmYide
for n:sponse ..Ihority for relusa
of huIrdoul IUbII8nca; axnpenI8Iion
for Injuria rmahinl from exposure to
to reIe8Ia of h8Z.udoaa nbaI8nca;
pIOYision of 8dequ1l.e rnaIthina fundi
for CERCLA IClionl.
A-I]
YaINo
Yfll/Yes
Yfll/Yes
MaINo
Ya/No
Freano Coanty"" 8IIopIed Ralldin 74-11
. ill ordinlllCe. 1baefore. well
c:onstrucIion. 8II8ncIo818M111 and destruction
must comply wi'" IheIe It.IIIIbntI.
May be IppIk:lble to dome of wute pond
... "",licable or releY811 "'1IfJPIOPri1le for
mncdillion of other aite 1R8I.
May be IIppIic8bIe 10 cIoI8re of WUIe pond
"'1IppIic8bIe or releY811 "'1IIppIUIIri1le
for remcdillion of other aile 1ft..
ProYiaionl Ipply only to ca18in Hated
chanic811 8nd to peI'A)III in Ihe cuane
of duinl buslneu. Additionally, the treItIJcI
Wlter . returned to the IUI'Ie IIJIIroe or
WIII:r lapply.
SullltantiYe ftNIllbemmll 0' 8 Remedial
Action PI.. (RAP) mull be met.
-------
TAILE A.2
STATE APPLICAILE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITADONS
FMC FRESNO PLANT SITE
Sta.u.e .r -.18.10.
Clta.I..
Delerl,Uo.
Appllublel
Reltvant and
Appropriate
C...e..
NoIlII AltAR for ~CLA dvids.
Jfa8doaI M8ImaI8
Rdale PI8ns IIId
Ln_*'7 Requiranenla
EAt ilClftllleftIai Q8I1iIJ
AaeamenI Requiranalll
H-.doaI Su"""
Ad
SI8nd8IdI far Solid
W--1tIndma 8nd
DispouJ
CllibnIa To.
Pi.. ae-p Ad
(I'PCA)
FMC-F' "0
HeaIdI a Safely
Code. Diy. ».
ChIpta 6.".
Sec. 25DJ r&-.
19 CCR. ChIpIa 2-
s""'" 3.
Sec. 26»""
Heabh a Slfely
Code, DiY. ».
Chapter 6.98.
Sec. 25.570....
HaIIh a S8fely
Code. Diy. 22-
Ch8pIer 13.
Sec. 21740 AlaI.
14 CCR. DIY. 7.
Chapa 3. Sec.
17020 .....
He8IIh a SlffIIJ
Code, See:. 25250
...
R~ A!qllilanents for .
Riease or tIwa8enI!d rdease
of. haZIrdoas malaill. Seta
requiranaU for -Area .....-;
-Bulineu PI...-; the Acutely
H_duaI MIIa'iaII Re.........
form; IIIdthe Rist M..qement
and Prnenlion PIop'Im.
Requirem1s8 8nd prouod... far
plql8l1Iion of entiioel.."",1181
qullilJ 8eIII1IeIIII (en,it...,men18l
audits).
Del'uddu.. of "hu.8dou
. .ubsl8nce- IIId -80Aic-.
Seta the minimum requinmeru
8nd pr:rforman:e IIIndIrdI
for solid wlISIe handlina
and dispon18CIiYitiea.
Rea"" the clonle of nICe
impoundments conlainina h8z8doaJ
WISIe.
A-1'
NoINo
NoINo
Ya/No
Ya/No
Ya/No
Not III AltAR for CERCLA dyiliea.
AppIicIbie 80 hazanIoaJ JDbI&Inca
idedtiIied in !he code.
Applic8llle onIJ if remedJ lmolYs COIIIInIdion
of IOIid Wille landfill.
Applicable 80 the wale pond. TPCA
compIiInce .. been adde¥ecL
-------
T AILI A.2
STATE APPLICAILE OR R!LEVANT AND APPROPRIATE REQIIIRIr.MENTS, CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE
Stalule .r Repl.U..
CII.....
DelerlpUo.
Applicable'
Relnan. and
Approprlale
Co..e.1
Cllifomia Elwiromlaltal
Qulil, Act (CF.QA)
Fish... Oame Repl8lion8
on PoUution
H~ W.. M-e.1.1I
Commiaee Manor....... of
",....d..
FMC-Frftno
"b. Res. C.
DiY. 13. Sec.
14 CCR. DiY. 6.
Sec. 15000 ~
AIh... 0...
Code. DiY. 6.
P.. I. Ch8p8er 2.
Sec. 5650 r&..BII.
Ita ......~ III8de
on Nowanba I.
1983 by the DHS.
CII..... ... CUP
Pnwiclet fw the -...I1.......a1l8l ~
of di8aeIionIry adiom. .
. o.idelina for Implernenlllion of
CF.QA. includin. rsponaibilities
of pubtic aaendes. lead .,mdea.
iniIiaIlt1Idiel, nqn.e dec:1_1tion
decllnbon procaI. EIR-proceII.
lime limi... eonlalll, review. and
appnwal.
Codifie81he prohibition of WIIa
poUution with 81' IU"18IICe or
III8IaiaJ deIdaioullO filII. p18l'
life or lrinllife.
An 8I*ft1Ml be8Wem !he Dep8I-
menu of Health semca.
TnnaportIIion (C8IIf_).'"
California Hilhway PIboIIo
c:oordin8Ie wilb e8Ch oIbr::r
for the Ir8nIpOrtIIion of bqe
qllllllilia of h8z8do8 W8steI
Uc:8Y- from _dolled lila.
A-15
NoINo
NoINo
NoINo
DHS h818bn the poIidon that
CEQA doellppl,. .
,Not 81 ARAR fw remedial
alfanlliya .... CDIIiderlllion.
If 8dected nmedi8I allIm8Iiw8
inyolYa off.lite If_port of I..
quanalia of huardoul .... MOU
may have 10 be canplied wilh. Not
.. ARAR lince it .,Iiea to off-lite
activitia.
-------
TAILE A-2
STATE APPLICAILE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITATIONS
FMC FRESNO PLANT SITE
St.tate .r Repl.tI..
CIt.tI..
Descriptio.
Appllubl,'
R,ltYant and
Approprlat'
Co..,.,
CdifomIa~~18I
HullII and Safety Act
Critaia for
Idmlifialion of
HUIIdoua InII EaRmdJ
HUIIdoua W.... -
TInIhoId Limit
Concmlnlions
w- QuIlt, Objetd'e8
VI.-"",'" Sanae of
H8ZIIdoas Sublllnc:a
Reqaftments
FMC-r
":»
1AIIor Code. Diy.
S. See:. 6300.
ABIla
I C'CR. Chspt.er 4:
S1Ibch1pta 4.
See. lsoo. ~
Sabdlipta 5. lee..
2300 a..a.. S.b-
duipIer 1. See.
3200 I18l1o
22 CCR. Diw. 4.
Chap8a 30. Art. II.
See. 66693-66141
RWQCB CriIIria
HeaI1h a Safety
Code, Diy. 20.
Chapea 6.1. See:.
25280 AJm
23 CCR. Chapcer 16-
See. 2610 d..H!II.
Rqulationllo IIIIft we and
heahhJ wortin. amditionl by
aulhorizin.dIe enforcanenl of
. .......8l1li poadua.
A ddaiIed IIIIIysiI of
c:onstnIdiDn wety Rpl8donl
y t.I/No
A ddaiIed InIIysia of eIectrie8I
.afety rqalllions.
A ddaiIed ....,.. of a-nI
i_.., ufety Rluillionl
includint pnx:ecIure8 equipment
8II!II8I\oo;bICI.
Plumalpled aiIaia 10 delamine
if 8.....criaI iI haurdou.
Includca Soluble Thrahold Limit
ConcenIrllion (S11£I) InII Total
Thraho.. limit Concmlndon
(1TLCs).
NOIINo
Prumul.8d c:ritala-Rllina
c:hemical spec:ific:, CIOIICaJIralion
1eYe18 for a Y8'ieIJ of aea 0'
lpecifie bodia of wata'. Based
on die btnefic:ial uses 0'
IpIIdfied WIIa bodies.
Replationl pemin.dIe
latina. monilOrin. and
repIacina anderpound
laoraF Ianb.
YaJNo
NQ/No
A-"
Worta huIIh and safety is Rpla"" b, boCh
Ftdr:rallnll CAL-OSHA.
sn.c. InII m.c c:hrmical-speciftc Yalaea
RfI«:t peniItence and bio8a:amalllion c:hemic:aI
c:h1rlldaiatic8. The limill 8R not health-b8lC!ll.
Re"'" Wata' QaaIitJ Objecti,ea 8R idenIified
in die Wiler Quality Control P1an Reports
(B.in "'811) of die nine Re.ional W8IU
Quality Control Bolnil. Ma, be II'PIic:able
if poundWIla II mnjected.
NoDlIda......,ldl8lblobel8lllldialedor
instaUed.
-------
TABLE A.2
STATE APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS, CRITERIA, OR LIMITATIONS
"MC FRESNO PLANT SITE
Sta.dar., Requlre.Ht
Criteria, .r LI.ltatlo.
CltaU..
De.crlpUo.
Applicablel
Reln.nt and
Appropriate
Com.e.'
CaliromiJI C"'"
Ac:t of 1916
FMC-Frnno
M. Rei. Code.
om.ion 20,
Section 30,000
AJIII.
GoYema 8diYidea in C.....
Zone.
Nu/No
A-l1
No Klividea in !he CIOIII8I zone.
.' ,,"''(.
";.
-------
T A8LE A.3(1) OTHER
FEDERAL AND STAn: CRITERIA, ADVISORIES, AND GUIDANCE,
TO 8E CONSIDERED
St.tute .r Rel1ll.tlo.
CltaU..
Beurl,Uo.
C.....e..
NIIionaI SerondIry
Drinkinl Wiler
Sllndlnlt
NIIionaI Muim8m
ConIamillllll Lewd
Go8Ia
w- Quality
SIIndInIt
Media CIeInup SIIndIrdI
(MCS)
40 CFR Pat 14]
,.It. L 99-]]9. 100
Sial. 642 (1986)
40 CFR PIIt I] I
55 FR 3079B
Sec. 264~25
Second., muimum coNamiftlftt
Inel. (SMela). Sl8nd8rd to
control chemicala in drirtill8 Wlla
thai primarily .rfectalhe lellhetic
. qualitiea relhllo public
ICCqIUnCC of drinkinl w-I
5«1ondary ....... 1ft not fedenlly enforoeable;
intended . auidelinea for Ihe .1I1a. SMCLa
-e not AltAR. ulilese pmmulilled by .1I1e..
Eatlbliahea drinkinl Wiler quality
JOaI. (MCLGa), 111"el. of no
kmwn or lI1bcip8led Idvme health
effects with .. 8dequ1le m_ain of
..rdy. MCLGs do not take CCIIt
or fe8Sibility into 8CIOOUnt. Under
SDW A. MCW. ue ..aI. not
enfonable .......
See diacaaion In Table A-I. Pile A-I.
NonenfonabIe aitail for--
qaality 10 proIed hum.. health
and 8qU- life. From Ihe wiler
quality aiteri.. uta adopt willa
quality ltIndards thll prolec:t I
-plied ale. A willa quality
II8ndInI ddinra the WIlla qualily
..... 01 I Wlta body throu.h use of
deaiplliml and aitaia 80 proI«t
Ihe -plied uaa.
CERCLA .....- th8I the remedy aelec:1Ird m...
ft!qUire Ilnel or II8ndIId of control which II
least 8II8inI willa quality criteril ell8blished
under Section 304 or JO} of the Oem Wlia
Ad. CERCLA"" .1I1a -in delaminill8
whether or not Illy wiler quality aiteriL..i.
reln-- 8pprOtIri8le...the Praidetc .haII
consider the deaignated or potential use of the
aurface or pound wiler. the enYiommentll
medii affected, the purpow.8 for which the
aitail wac -doped. and the IaIeIt informa-
tion 1.liIable.-
PIoposed amendment to RCRA.
MeSs 1ft established II concenarllions
thai enswe protec:tion of human health and
the en.uOllfltmt. SI8Id8rda 1ft ad for each
medium durinl the remedy selection proceu
The replllionl 1ft pnIpOIed and IhIRfore
TBCJ. When promul.1Ied. the J18nd8rda lie
pocentiII ARAlb.
(I) The ARAR. identificllion and ddenninllion pmceII iI discuued in Section 1.1 of the ten
FMC.P' '0
.\-1°
-------
T A8LI A.] OTHER
nDERAL AND STATE CRITERIA. ADVISORIES. AND GUIDANCE
TO 8E CONSIDERED
SI.I.le .r Repl.llo. CII.U.. Descrlpllo.
Dq.tmmI of HeaIIh 11Ie CaHfomia Site A cIetIiIed IIIdhodoIoIJ for cIeIa-
SaYicelSiIe Mitilliion ....ion mininlthe cleanup leYell for lia
Mitilalion Drdtion TI'IIe ManaaI. M8J 1986, c:ontaminl8ed willi IOU: 10""'"
Tree ,..... by OIlS, and 80 facilil8le the enlulllion
TOD: Subs8ancea of remedill action objrdiYeI.
Control Imilion,
AlIan8IiYe Tecl'iolOloaJ
... PoIic:J 0eYe1opmenl
Sedion.
DHS Applied OIlS Applied Adion u.e" (AALa) deYeIoped
ACIion LeftI8 by the TOlk SublllllCN Coab'OlDiYision.
AALa Ire chemicaII ... media.,mfic.
5'* W.... R8J81a8 8oII'd RaoI8don 11Ie S'* Rodl PoIic:J on mainlaininl
Control RoIId'I Haft. No. 61-16 the hiah quality of Cllifomia WIIaI.
depIaIion PoIicJ
CaHfamia r.,b..III of DHS CrlICria Critl:ria-ldlinl chemicalapecilic aJnCeIt-
HeaIdI Sema:a (DHS) tr.1ion leYell. Numeric:lllimitl cle8ilned
Adimll.eftI8 10 protect _man helllll from chemic:1I
COIIItiluentJ in drinkinl water.
Recommended ea:epl8b1e Iimit8.
Ac:don leY. Ire &inIdna -- elpolure
critaia which Ire implemalted Ihroulh-
OUlthe 1Itate. They are deYeloped by
DHS' Senil8ry Engineainl BrlftCh !O
aappIanaIIthe fedrsll .......
promul18l.ed under the Safe Drintina
Wa.,. Ad, ... often rely on EPA heI1lh
adYisoria . the bail for ..tinl an action left..
OSWER Direc:tin EPA DirediYe EsllblishellUidlllCle on the control of air emisaionl
9355.0-28 form air Itrippers used II Superfund lilel.
Co..e.1
Requifeme,jll of the Site Midladon Dedlion
Tree are not Iqally enfon:able.
AALa Ire not Iqally enfon:abIe criteria.
Mu.. be 8ddI~. a TBC.
. ~ ,'7.
Not enfon:abIe drintina WlMItIIIIIInIa; bat Ire
leYe" II whic:h DHS ItIOnIIJ Draa w8l.e:f
pafYeJOfllo tab: Cuhe..bWe 8ttion 80 reduce the
leyel of c:ontaminltion in the water they lapply.
FMC-Ffftno
A-19
-------
TAILE A-3 OTHER POTENTIAL FEDERAL AND STATE CRITERIA. ADVISORIES. AND GUIDANCE
TO IE CONSIDERED
S..tute or Replan..
clI.n..
Deaerl,tlo.
Co...e..
Hahh AdYiIoria
ConediYe Action ror
Solid Wille M-aanena
. HIUI'Ib8 W-
M......... FIlCilitie8
Si8e-Speciftc Heahh-......
Golla
FMC-F
'0
EPA IIId NIIionaI
Ac8danJ of ScimcI8
(HAS)
40 CFR 264.500 -
264-'fiO, Sabp.. S
~
(PRC, 1991)
Heald! 811wilorie8 cIPeIoped for .hurt It.nn, lon, term,
mllifdime aposans. The 811w-.a 8e c:onsidr.red
10 be pidInDe IIId 1ft nul cnfon:able.
~ I1IIe elllblisla fIw'CdaId IflCllechnicai
RJqUiranents ror impletnenlin8 c:ona:dYe ICIion under
Section 3004(a) of RCRA. The replationl define
RJqUiremenll for conduc:dna ranedial invati,lIions,
eyalualina potential ranedia, II1II selectin, and
implrmmb"l ranedia . RCRA f8Cilitiei.
Prcwilionl of Ihe .,.opo88d I1IIe (e.,.. media cleanup
.18ndanII. conditional ranedia, CIe.) IIIUIt be addrased
II TBCI. .
COIIIaYIlift eoncenIrllion ..... for c:8I'cino8a11
non-am.qa18. Baed on IllRlIricted leIidenliai
deYeiopment of Ihe .ite.
A.7"
-------
TABLE A-4 IDENTInCATION 0' FEDERAL ARAR. FOR GROUNDWATER AND SOIL ALTERNATIVES
St.tat. .r Rep..II.. CU.llo. Grou.d".tu Altern.tln. Soli Alt.r..tln.
Sllc Drintinl Willa Ad 42 U.5.C. '3OOf 3,4,'
...
hb. L 93-5%3
NIIion8I PrimIrJ 40CFR PIII.4. . 3,4,'
Drintinl Willa
S8IndI8dI
MuJmam CcIntIndn8II 40 CRt .4.. 3.4,'
Lftel Go8I8 (MCLOI) . Sabpart F
Ubdt.. ...-8Cl1njedion 40 CFR 4,5
Conlrol Rea.lalion8 PIIII 144.141
Clan Wiler Ad 33 U.5.C. 3. 4. ,
'1251-1376
WllerQuliIJ 40 CFR PIlI 131 3. 4, '
Criteria QuIity Cri8ai8
bWIIa.I916.
19110. 1986
EIIhIenI 0tIide1ine8 ... 40 CFR PIlI 4" 3
S88nd8rdI for Pesticide
Chanical MlllUfldUrina
N8don8I ~~-amad 40CFR 3
SIIndIntI Plit 40J
FMC-Frtlno
A-21
-------
TABLE A-4 IDENTIFICATION OP FEDERAL ARAR. FOR GROUNDWATER AND SOIL ALTERNATIVES
St.t.t. er Repl.U.. CIt..... Groued..fer Aller..Un. Soil Aller..Un.
CIeIn Air Ad 42 U.S.C. 3,4, ~ 3.'
It 74c)l .....
NIIionaI PrimIry'" 40CFR 3,4, ~ 3.'
Second8ry Ambient Air 'lit 50
QaIiI1 StInd8nII
~W-M-ae- 40 CFR PIlI 260 ~,6, 7
mcnI SJIIeIIII General
S..-. Applic:8b1e to 40 CFR PIlI 262 3,4, ~ 6, 7
0aa-..01 H8ZII'doa8
Wille
S..-. Apptic8bIe to 40 CFR PIlI 263 3,4,~ 6, 7
"'....-Itft 01 HIZII'IIoaI
Wille
. 0e8nI Facility 40 CFR 264.10....... 4.'
SIanIIIIdI SabplltB
.~... 40 CFR 264.3Q....... 4.'
A(.,..... S.bpIIt C
. COlldllaenc:y PI-'" 40 CFR 264.~.... 4-'
EmaaaItJ ProceduIs Sabpln D
. Mini'. SJIIem, Record- 40 CFR 264.10..... 3, 4, ~ 6,7
bepin.. and Reportina Subpart E
FMC-'. '0
/r7'
-------
TAILE A-4 IDlNTlnCATION OF FEDERAL ARARI FOR GROUNDWATER AND SOIL ALTERNATIVES
St.tute or Rqul.'''. CII..... Grou.'..ter Alter..tlnl Soil Alter..tlnl
. Relala from Solid 40 CRt 264.90. ClIaI.. 2-5 4,5,6
W.teMIft8IaIIeM SIIbpIrt F
Unitt
. Clalwe and Poa- 40 CFR 264.110, d....IrIII. 4,5,6
CIoare SabpGt G
. FinmdaI ReqaimnmtI 40 CRt 264.140. d....IrIII. 2-5 2-9
SabpGt H
. Tank SJlIemI 40 CRt 264.190, ClIIQ.. 3,4,5 6,7
Sabp8t J
. L8ndfiIII 40 CRt 264.300, ClIIQ.. 3-6
Sabp8t N 0
. klnallOfl 40 CPR 264.340, CI..BIL. 9
SabpGt 0
. MiKdI- 40 CFR 264.600, a..aq. 5-8
UniII S.bp8t X
IIUrira S..... TSD 40 CFR P8t 265, ClIIQ.. :) - 9 (Applia 10 W.te Pond)
FacililJ St8ndIrdI - Sabpat G
CIoRre IIId PoII-OoIare
lind DispoaI 40 CFR Pm 268 5-9
Ra8ric:lions
FMC-Fresfto
A-n
-------
TAILE .\-4 IDlNTlnCATION OF FEDERAL ARAR. FOR CROUNDWATER AND SOIL ALTERNATIVES
Sta..', .r Rep"'''. clt.n.. Crou....',r Alttr..U... Soli AIt.r..U...
~-..pIIiot" Safety ..s 19 U.S.C. 1-5 1-9
HCIIth Act It "1.678
Haunloal MIIaiaIJ 49 CRt'" 3,4,' 6,7
TI8IIIpOIUIion un, nl-In
Replalionl
&ec8tiftOrder, &ec. Order 119118 "> 3-9
Floodplain M.......-a
FMc.r
'0
A-"
-------
TAILE A-5 IDENTIFICATION OF STATE ARAR. FOR GROUNPWATER AND SOIL ALTERNATIVES
8"1.1. .r Rewul.I". CIt..... Grouad..ln AIIK..lln. Soli Allna.Un.
Air Raoan:a Act HaIIh a SafdJ 3,",5 3.9
Code. Di.. 26
Sec. 39000 UJm.
17 CCR. PIIt m.
ChapIer I, Sec.
60000....
Pram County Air PIano C..., Air 3,",5 3-9
Pollution Connl PoU.don CGnIroI
Dislrict Relel and Di8trict R81e8 and
Replllliona Reaelaliona
Air TOIQ -Hot Spoil- HaIIh a SafdJ 3,",5 6-9
Inronnation and Code, Ch~ 1252
Allallllellt Ad S.... 1987
Sec. 4430 JUra.
Clltiromi. Safe Health a serdJ 3,4,5
Drinkina Wa. Ad Code, Di.. "
PIIt I, Ch8pter 7,
Sec. 4010 JUra.
22 CCR, DiY. 4, 3,4,5
Chapte U,
Sec. 64401 ....
Pma Colope WIfB WII« Code. DiY. 1, 3,".'
Qualit, Conlrol Ad Sec. 13000....
FMC-FfftftO
A-2S
-------
TAILE A-' IDENTlnCATION or STATE ARAR. rOR GROUNDWATER AND SOIL ALTERNATIVES
Statute .r Rqulatl.. CUatl.. GrouDd"atu Alter.aUy" Soli Altu..tln.
Parter Colope W*, 2] C'CR.. DiY. ]: 4,5,6
QaIliIJ Control Ad (c:aat'd) . Ch.,aer 9, .
Sec:. 2200"""
. Chlpler 15, 4-1
Sec. 2510"""
W.. WeD SIIndInII: BaI1etin 14~1 3,4,5
Slate of Califomi.
CIIifomII HaunIoa8 HeaI1h A SlfdJ 3-9
W- ConlnJl IAWi Code. Diy. 20,
ChIpIer 6.5,
Sec. 25100. rI.JIII.
22 CCR, DiY. 4 3-9
Ch8pI8 30,
Sec. 66001 ~
Cllifomil HIZII'CIoaI HeaI1h a SlfdJ 3,4,5 3.9
S."18nee A&:>co8n1 Code. DiY. 2D.
Ad/Haz8doaI Ch8pea 6.1, See.
S""" CIanup 25300 II..HII.
Bond Ad
SC8nd8nII for Solid 14 CCR, DiY. " 4,5,6
Wille HIIIdJina IIId ChIpIer 3, Sec.
DiIpouI 11020 r&JaI,
ClliromI8 Toxic He8bh A SlfdJ 3 - 9 (Applie8 10 Wute Pond only)
Pial Clelnap Ad Code. See:. 25250
(TPCA) 4Im.
FMC-F
'0
A-'1/o
-------
TA8LE A.5 IDENTIFICATION 0' STATE ARARI 'OR GROUNDWATER AND SOIL ALTERNATIVES
Sialule or Replallo. ClloU.. Grou.dwoler AliernoU"1 Soil Aller.all"l
Cllifomia Oa:upllional Labor Code. Diy. 2.9 2-9
HaIIh and Safety Au S, See. 6300.
SI.JI&
. CCR, Chapter 4:
SIIbchIpla 4,
Sec. 1500, a..BII.
Subcluipea S, MIC.
2JOO a..ag,. Sa""
c:hlpla 7, See.
3200 WIll.
W.... Quality Objecliva RWQCB CriIeria 4,S
FMC-Freefto
A-'D
-------
APPENDIX B
RESPONSE SUMMARY
I'KC-I'RESNO SITE
The proposed plan for the FMC-Fresno site was issued to the
public on May 6, 1991. The proposed plan described EPA's
preferred alternatives for cleanup of contaminated groundwater
and soil at the site and announced the public comment period from
May 8 through June 7, 1991. On May 28, 1991 EPA presented the
proposed plan at a public meeting and accepted comments on the
proposed plan.
During the public meeting, no written or verbal comments on
the proposed plan were provided by the public. During the public
comment period, EPA received three comment letters on the
proposed plan. One letter, dated June 4, 1991, was provided by
David A. Lewis of the FMC Corporation. A second letter, dated
June 4, 1991, was provided by Georgia K. Sisson, representing the
League of Women Voters of Fresno. A third letter, dated June 6,
1991, was provided by the Fresno Neighborhood Alliance. A sum-
mary of the comments provided, as well as EPA's response to each
comment, is provided below.
Commenter:
David A. Lewis, FMC corporation
1.
Comment:
The narrative of the site history should note that the site
was dropped from theNPL in 1989.
1.
EPA Response:
BPA agrees with the commenter. This issue is discussed in
the ROD, in the section entitled "site History and Bnforcement
Activities."
2.
Comment:
The proposed plan should mention the possible presence of
background groundwater contamination in the region of the site,
and should specify that cleanup levels for any such background
chemicals should not exceed their background levels. Some of the
chemicals that EPA has identified as not "naturally occurring"
may be widespread in groundwaters of the Central Valley. This
comment is especially important for chemicals whose cleanup
levels are set at the limit of quantification. If the limit of
quantification falls in the future, background contamination may
be revealed.
1
-------
'.
2.
BPA Response:
The possibility that upqradient and backqround qroundwater
contamination may exist in the vicinity of the site is discussed
in the "summary of Site Characteristics" section of the ROD.
This section of the ROD indicates that several contaminants
detected onsite and dovnqradient from the site may have
oriqinated, at least in part, from upqradient sources. This sec-
tion of the ROD also indicates that upqradient qroundwater con-
taminant concentrations and backqround levels have not been
thorouqhly characterized.
The implications of the presence of backqround contamination
is discussed further in the "Groundwater Cleanup Standards" sec-
tion of the ROD. If, in the future, backqround contaminant
levels are established to the satisfaction of the requlatory
aqencies, qroundwater cleanup standards vill be modified to en-
sure that the standards are not more strinqent than the back-
qround levels.
3.
Comment:
The maximum concentration of carbon tetrachloride detected
in groundwater as reported in Table 1 of the proposed plan is in-
correct. The correct value is 13 ppb.
3.
EPA Response:
EPA aqrees with the commenter. The maximum concentration of
carbon tetrachloride detected in qroundwater has been corrected
in Table 1 of the ROD.
4.
Comment:
The quantification limits reported for some of the chemicals
in Table 1 of the proposed plan are below the detection limits
listed in Table 3.2.1 of the FS, and are also below the standard
limit reported on analytical data reports generated by the on-
going groundwater monitoring program at the site. The analytical
methods used and their limits of quantification need to be
clarified. For e~amp1e, the current detection limit of monuron
using EPA Method 632 is 4.8 ppbas compared to the quantification
limit of 0.015 ppb as listed in Table 1 of the proposed plan.
4.
BPA Response:
BfA aqrees vith the commenter. The quantification limit for
monuron has been revised from 0.015 ppb to 5 ppb. As discussed
in the "Groundwater Cleanup Standards" section of the ROD, quan-
tification limits represent the lowest level at which a chemical
can be accurately measured with currently available technoloqy.
The selected quantification limits were based on either EPA's
contract Required Quantification Limits or 5 times the currently
accepted detection limit. The detection limits (and hence quan-
2
-------
tification limits) may vary depending on the analytical method
used. Also, the detection limits (and resulting quantification
limits) may change over time as analytical techniques improve.
Detection and quantification limits will be reviewed by the lead
regulatory agency on a biannual basis to ensure the selected
quantification limits are accurate and reasonable. In the ROD/
EPA has not provided a list of the analytical methods to be used
to determine the detection and quantification limits for each
chemical; however/ such a list is provided in the 78 report.
5. Comment:
a. The decision process for establishing groundwater cleanup
levels should be revised to follow the hierarchy:
- Federal MCLs,
- State MCLs,
- State Action Levels,
- Health-Based Goals.
b. If the level established by this hierarchy is less than
the quantification limit for the chemical, the cleanup level
should be set at the quantification limit. The quantification
limit should not be used as a cleanup level in the absence of
other standards (as done for monuron), since there is no scien-
tific basis for defining a level that is protective of human
health. This revised hierarchy emphasizes reliance on standards
which are enforceable and most consistently and widely applied.
These standards are protective of human health.
c. FMC does not believe that EPA can justify the use of
site-specific health-based goals as cleanup levels where other
standards exist since the health-based goals are based on very
conservative assumptions. In addition, institutional controls
prohibiting the installation of additional water wells will be
applied at the site to mitigate the chance of exposure.
d. The effectiveness of the selected groundwater treatment
technology (air stripping followed by carbon adsorption) has not
been fully demonstrated for the specific conditions at the FMC-
Fresno site. The. plan should therefore stipulate that no cleanup
level should be set below the minimum level attainable with the
selected technologies using all reasonable efforts to optimized
treatment performance.
5. EPA Response:
a. EPA agrees with the commenter with regard to the deci-
sion process for establishing groundwater cleanup standards. As
described in the "Groundwater Cleanup Standards" and
"Documentation of Significant Changes" sections of the ROD and as
presented in Table 1 of the ROD/ the hierarchy for selecting
groundwater cleanup standards is as follows.
-------
federal or state KCLs (wbicbever is stricter),
state Action Levels (wben federal or state KCLs do not
exist), .
bealtb-based levels (wben federal or state KCLS or
state Action Levels do not exist),
quant~fication limits (wben federal or state KCLs,
state Action Levels, or bealtb-based levels do not
exist).
b. As is described in tbe "Groundwater Cleanup standards"
section of tbe ROD, quantification limits bave been selected as
interim cleanup standards for tbose cbemicals for wbicb tbe
selected cleanup standards are below tbe quantification limits.
Purtbermore, BPA bas selected quantification limits as cleanup
standards for 5 cbemicals for wbicb no requlatory of bealtb-based
levels exist. Given tbe lack of a suitable cleanup standard,
BPA believes tbis selection is justified. As is described in tbe
"Groundwater C~eanup standards" section of tbe ROD, tbese cleanup
standards may be modified if it is sbown tbey are stricter tban
background levels.
c. BPA bas selected bealtb-based cleanup levels ratber tban
MCLs as clean~p standards for two cbemicals for wbicb MCLs only
acbieve a 10- level of protection (etbylene dibromide and
toxapbene). In tbe proposed plan, BPA bad originally selected
bealtb-based cleanup levels ratber tban MCLs for four cbemicals
(etbylene dibromide, toxapbene, BBC-gamma, and beptacblor).
Bowever, based on furtber review of tbe risk data, tbis list bas
subsequently been revised to include only etbylene dibromide and
toxapbene. Tbis cbange is identified in tbe "Documentation of
significant Differences" section of tbe ROD. As is discussed in
40 CFR 300.430(e) (2) (i) (D), selection of cleanup standards wbicb
are stricter tban KCLs may be considered in "cases involving mul-
tiple contaminants or patbways wbere attainment of cbemical-
specific ARARs will result in cumulative risk in excess of 10-4."
Tbe selection of bealtb-based levels for tbese two cbemicals,
will ensure tbat tbe seleited remgdY is witbin tbe acceptable
carcinogenic range of 10- to 10-. As is pointed out by tbe
commenter, institutional controls will also be used to limit ex-
posure to contaminated groundwater. Bowever, qiven tbat it is
difficult to ensure tbat institutional controls will be main-
tained over time, BPA feels tbat its selection of groundwater
cleanup standards is appropriate in order to provide long-term
protection.
d. Tbe PS report indicated tbat tbe groundwater treatment system
would be capable of meeting MCLs and bealtb-based levels (to cur-
rent detection limits). As a result, BPA assumes tbe treatment
system is capable of meeting ARARs. Sbould tbis not turn out to
be tbe case during RD/RA, BPA will consider a ROD Bxplanation of
significant Differences (BSD) or ROD amendment.
4
-------
,,,,,,:"1"""'-"'" .
,-~ '~. ',.,. :'",';':; J \ -
6.
Comment:
The text of the proposed plan references 12 indicator chemi-
cals, but only 11 chemicals are listed in Table 2 of the proposed
plan.
I.
BPA Response:
In Table 2 of the proposed plan and Table 3 of the ROD, en-
dosulfan I and endosulfan II are presented as a 8ingle listing
(both are presented in the same row of the tables). Both chad-"
cals are considered indicator chemicals for the site, and as a
result the text of the proposed plan and ROD refer 12 indicator
chemicals for the 8ite.
7.
Comment:
FMC believes that the stringent health-based levels selected
for non-carcinogenic contaminants in soil (based on a Hazard In-
dex = 1) ar~ unnecessarily conservative. EPA has selected
cleanup levels for carcinoienic contaminants (based on an excess
carcinogenic risk of lX10- ) and correctly argued thgt the over-
All level of protection would be equivalent to lX10- excess can-
cer risk, "since the preferred remedy includes several methods of
protection (i.e.~ a cap, institutional controls, excavation and
treatment)" in combination. An analogous argument can be made
for the non-carcinogens. For example, suppose the cleanup level
for non-carcinogens is set at a Hazard Index of 10. With capping
and institutional controls implemented at the site, the overall
Hazard Index for exposure to non-carcinogens would be reduced to
less than 1. In risk assessment terms, the additional control
measures would reduce the exposure factor by at least a factor of
10. In summary, EPA should be able to set a cleanup level of
Hazard Index = 10 for non-carcinogens while maintaining an over-
all protection equivalent to Hazard Index = 1.
7.
EPA Response:
EPA believes that the health-based levels selected for non-
carcinogenic contaminants in 80il (based on a Hazard Index = 1)
are appropriate. As is discussed in the .Sf (40 C!I Section
300.430(e), an acceptable risk range of 10 to 10 for car-
cinogenic risk has beet established by EPA. The selected remedy
for soil attains a 10- level of protection by preventing ex-
posure to contaminated soil through the use of a cap and institu-
tiotal controls. Purthermore, the selected remedy provides a
10- level of long-term protection through excavation and treat-
ment of contaminated 80il. Thus the selected remedy is within
the acceptable risk range required by the RCP.
However, this concept of an acceptable risk range does not
apply to non-carcinogenic contaminants. BPA believes that a
Hazard Index in excess of 1 is representative of unacceptable,
non-carcinogenic human health risks. In order to obtain long-
5
-------
term protection of human health, BPA feels it is necessary to
treat 8urface and near-surface soils at the site to a Hazard In-
.dez of less than 1. There i8 no 8cientific 8upport for multiply-
ing the Hazard Indax of 1 by a factor of 10.
8.
Comment:
The cost totals cited in Table 3 of the proposed plan should.
be rounded to two significant fiqures.
8.
BPA Response:
In the proposed plan and ROD, BPA has presented the costs
for the groundwater and 80il alternatives as they appear in the
FS report. The c08ts vill continue to be presented in this man-
ner in the ROD.
9.
Comment:
The statement in the proposed plan that no drinking water
wells are located onsite is incorrect. FMC maintains an onsite
supply well. This well has been thoroughly and reqularly tested
and does not contain measurable levels of contaminants, and its
use should continue.
I.
BPA Response:
The statement that "no drinking vater vells are located on-
site" has been corrected in the ROD. This issue is discussed in
the section entitled "Summary cf Site Characteristics."
The selected remedy for groundwater includes institutional
controls restricting the installation of onsite vel18, ezcept
those used for monitoring and eztraction of contaminated
groundwater. The selected remedy also requires that any vells
that become contaminated vill be replaced, fitted vith vell-head
treatment systems, or an alternative water supply vill be
provided. Furthermore, any vells that adversely impact the
groundwater remedy be replaced by an alternative vater 8upply.
As a result, if it becomes apparent that the PKC supply well has
become contaminated or vill interfere vith the groundwater ex-
traction system, then use of this vell vill be discontinued.
10.
Comment:
With reference to selecting cleanup levels where multiple
contaminants are present, it is suggested that the proposed plan
simply state the total excess cancer risk or hazard index permis-
sible. This approach preserves the flexibility in how the risk
or hazard is distributed among the chemicals present, while en-
suring that the fundamental objectives of the cleanup are at-
tained.
6
-------
..' "
. .
10.
BPA ResponSe:
. As is discussed in the fCP (40 ~ .ection 300.430(e), an
acceptable risk range of 10- to 10- for carcinogenic risk has
been establi.hed by BPA. Furthermore, BPA believe. that. Bazard
Index in excess of 1 is indicative of an unacceptable lifettme,
non-carcinogenic human health risk. Por groundwater contaminants
for which no MiLS exist, BPA has selected health-based levels, -
based on a 10- level of carcinogenic risk and a non-carcinogenic
Bazard Indez of 1, as cleanup standards. The calculations used
to develop these health-based levels account for the possibility
that multiple contaminants, are likely to be present. .
por soil fontamination, BPA has selected cleanup standards
based on a 10-level of carcinogenic risk and a non-carcinogenic
Bazard Indez of 1. Rather than simply state the permissible car-
cinogenic and non carcinogenic risk, as suggested by the com-
menter, SPA feels it is important to calculate specific cleanup
standards for the site. This approach is consistent with the NCP
(40 CPR Sec~ion 300.430(e). The selected cleanup standards for
soil are based on the assumption that only one indicator chemi~al
is present. Bowever, a discussion is provided in the "Soil
CleaDup Standards" section of the ROD which describes how these
cleanup standards will be made stricter in the event that mul-
tiple indicator chemicals are found to be present.
11.
Comment:
Rather than referrinq to a fixed period for qroundwater
monitorinq (ie., 30 years), the proposed plan should call for
treatment and monitorinq until qroundwater cleanup qoals are met,
to be followed by a confirmation period (e.q., one to five years)
of post-remediation monitorinq.
11.
SPA Response:
As is discussed in the "Groundwater Cleanup Alternatives"
and "Selected Groundwater Remedy" sections of the ROD,
groundwater extraction and treatment will be conducted until the
selected groundwater cleanup standards have been met within the
area of attainment of the contaminated groundwater plume.
Groundwater monitoring will be conducted for a period lasting un-
til 5 years after the selected groundwater standards have been
met. Bowever, Parts 264 and 265 of RCRA require that this period
of groundwater monitoring not be less that 30 years.
12.
Comment:
. The proposed plan refers to treatment of water to non-
detectable levels, which is incorrect. The water should be
treated to meet the selected cleanup standards.
7
-------
12.
BPA Response:
. BPA aqrees vi~h ~he co..en~er. As is discussed in ~he
"Selected Groundwater Remedy" .ection.of the ROD, qroundwater
vill be ~reated ~o the .elected cleanup standards prior to rein-
jection or re-use.
13.
Comment:
The proposed plan calls for additional sampling to determine
the extent of dioxin contamination in soil but such sampling does
not appear to be warranted by the existing data. A review of the
dioxin/furan data in the RI report indicates the cumulative ex-
cess cancer rigk due to exposure to dioxins/furans in soil is
well below 10- in all cases. The total excess canJer.risk4due
to exposure to surface soils is on the order of 10- or 10- .
Thus, the contribution of dioxins and furans to the total cancer
risk is negligible and does not need to be addressed further.
13.
EPA Response:
As described in the "Soil Cleanup standards" section of ~he
ROD, EPA has selec~ed a cleanup s~andard of 1 ppb for dioxin in
soil. Althouqh dioxin samplinq conducted durinq the RI/PS vas
very limi~ed, dioxins have been detected in excess of ~his
cleanup standard including BpCDDs (5.1 ppb) , OCDD (27.0 ppb),
RxCDFs (3.8 ppb) , and OCDF (3.3 ppb). As is discussed in ~he
"Selected Remedy for Soil" section of the ROD, confirmation
samples will be taken ~o ensure that the cleanup standards for
dioxin as well as the twelve indicator chemicals have been met.
This approach to dealinq with dioxin in soil as described in ~he
ROD, is somewhat different ~han that described in ~he proposed
plan. As a resul~, ~his difference is explained in ~he
"Documentation of siqnificant Cbanqes" section of ~be ROD.
14.
Comment:
with respect to the evaluation of soil washing, the proposed
plan should explicitly reference cost effectiveness as one of the
evaluation criteria. Cost effectiveness is one of the fundamen-
tal remedy evalua~ion criteria identified in the NCP.
14.
EPA Response:
EPA aqrees vi~h ~he co..en~er. The fac~ ~ha~ ~he selec~ed
remedy for .oil is cost-effective, is explicitly stated in the
"Statutory Determinations" section of ~he ROD. Purthermore, the
cost effectiveness of the selected remedy is also referenced in
~he "Summary of compara~ive Analysis of Alternatives" and the
"Selected Soil Remedy" sections of the ROD.
8
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15.
Comment:
The proposed plan calls for a maximum excavation depth of 15
feet, but provides no basis for selection of this depth. The 15-
foot limit was identified in the Risk Assessment, also without
justification, as the maximum depth to which soil might be dis-
turbed as part of residential development of the site. Based on
conversations with engineers in the Fresno city Public Works
Department and with swimming pool contractors with long ex-
perience in the Fresno area, it appears highly unlikely that any
excavation as part of a residential development would ever extend
more than 12 feet below ground surface. The excavation limit
should therefore be set at 12 feet below ground surface, which is
a protective, defensible limit. A lS-foot limit cannot be jus-
tified.
15.
BPA Response:
BPA believes the selection of . maximum excavation depth of
15 feet is justified. Justification of the selection of a maxi-
mum excavation depth is provided in the "Selected Soil Remedy"
section of the ROD and includes the following:
it is unlikely that future residential users could come
in direct contact with contaminated soils present below
15 feet,
results of the RI/FS indicate that in several areas of
the site, there is a siqnificant decrease in soil con-
taminant levels between 10 and 15 feet below the land
surface,
results of the RI/PS indicate there are only a few
areas of the site where soil contamination is present
in excess of the selected cleanup standards below 15
feet,
cost and technical considerations make it impractical
to excavate beyond 15 feet.
BPA has discussed the issue of excavation limits vith
employees of the City of presno Development section and the
Presno City Public Works Department. EfA was informed that ex-
cavation in exces~ of 12 feet, associated vith construction ac-
tivities and installation of utilities, is possible in the
vicinity of the site. As a result, the maximum depth of excava-
tion vill remain 15 feet, rather than 12 feet as suqqested by
PKC.
16.
Comment:
As discussed in the FS report, the proposed combination of
soil cement/asphalt cap would satisfy RCRA requirements. The
proposed plan should be modified to reflect this.
9
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16.
BPA aespoDse:
. BPA agrees that the 80il cement/asphalt cap will .eet aCRA
capping requirements. Bowever, the "Soil Cleanup Alternatives"
and "Selected Soil aemedy" .ection8 of the aOD 8imply empha8i.e
the point that .ince a aeRA unit (the waste pond) is present on-
.ite, the cap will have to .eet aCRA capping and aonitoring re-
quirements.
17.
Comment:
Because the FMC-Fresno site has been carried through the
CERCLA process, FMC feels it would be appropriate to note in the
plan that the CERCLA waiver from administrative permit require-
mentsfor onsite actions will apply.
17.
BPA aesponse:
In accordance with Section 121(e) of CERCLA, 42 V.S.C.,
'621(e), permits are not required for onsit. actions, if such ac-
tions are conducted under CERCLA. BPA has not addressed the
waiver of permit requirements for onsite actions, because it is
unnecessary to restate the the legal provisions of CERCLAin the
ROD.
Commenter:
Georgia K. Sisson, representing the Leaque of Women
Voters of Presno
1.
Comment:
In the interest of stewardship of the natural resources
available to us, the League of Women Voters of Fresno supports
EPA's remediation plan as far as it goes. We would like to sug-
gest that, if economically feasible, some form of in-situ soil
treatment be implemented at the bottom of the excavation where
soil will be removed to a depth of 15 feet for treatment. The
possibility of this type of treatment was not addressed in the
announcement of the proposed plan issued in May 1991.
1.
BPA Response:
In-situ treatment of contaminated 80ils was presented in the
proposed plan as one of the potential alternatives for soil
cleanup. Specifically, in-situ vitrification was considered for
treatment of contaminated soils. Bowever, it was determined that
this treatment technology is not capable of effectively treating
contaminated 80ils to depths of 70 feet, as is the case at this
site. As i8 discussed in the proposed plan and ROD, in-situ
vitrification was not selected as the remedy for contaminated
80il primarily due to concerns over technical implementability
and cost-effectiveness.
10
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Other forms of in-situ treatment that could potentially be
used to treat the deep soil contaminants were considered during
the initial stages of the Feasibility Study. These included in-
situ bioremediation and in-situ stabilization. However, these
treatment technologies were eliminated from consideration due to
concerns over their ability to treat contaminated soils to depths
of 70 feet, as is the case at this site. Given the depth of the
contamination and the range of contaminants present, EPA has not
identified any in-situ treatment technologies that could effec-
tively treat the contaminated soil in a cost-effective manner.
2. Comment:
Historically in this area of Fresno, groundwater levels have
fluctuated greatly, from levels almost at the surface to levels
below where they are now. The contaminants found in this soil
are both carcinogenic and highly toxic at part per million con-
centrations. Although the upper aquifer now, after five years of
drought, contains little water, in wet years this aquifer will
contain water which will migrate toward city wells. We believe
that every feasible opportunity that is economically possible
should be used to lessen these substantial, health threatening
concentrations of pesticides in the soil above the aquifer. We
recognize that the contaminants at this site have damaged
Fresno's sole source aquifer, and that treatment of the water ex-
tracted in the area of the site is a necessity.
2. EPA Response:
EPA agrees that fluctuations of the vater table in the
vicinity of the site have occurred in the past and are likely to
occur in the future. Although the upper sand zone presently
contains a small amount of vater, the selected remedy requires
extraction and treatment of contaminated groundwater from this
sand zone. The groundwater extraction system will be designed
to accommodate future fluctuations in the vater table.
Furthermore, through the use of capping, institutional con-
trols, and groundvater extraction and treatment, the selected
remedy effectively reduces the possibility of exposure to soil
contaminants that may migrate to groundvater in the future. Con-
tinued monitoring vill be conducted at and in the vicinity of the
site, to ensure that the remedy continues to be protective of
human health. Groundvater extraction and treatment from both the
first and second sand zones vill continue until the selected
groundvater cleanup standards have been met.
Commenter: Fresno Neighborhood Alliance
1. Comment:
The proposed plan includes onsite deed restrictions, but no
offsite deed restrictions are proposed even though the polluted
groundwater plume extends a great distance offsite. Careful con-
11
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",
sideration should be given to deed restrictions on offsite
property as well. One option which should be explored could re-
quire well-head treatment at offsite locations if water testing
showed MCL standards were exceeded. Since Fresno is a sole
source aquifer, we can not afford to simply write-off huge areas
of our groundwater aquifer.
1.
BPA Response:
A requirement has been added to the selected remedy for
groundwater which requires periodic monitoring of all wells lo-
cated within the area of the contaminant plume. Furthermore, if
any of these vells contain contaminants in excess of the selected
cleanup standards, then the vells vill either be replaced, fitted
vith vell-head treatment, or an alternative water supply will be
provided. Pinally, if it is determined that the use of any well
vill adversely affect the groundwater cleanup plan, then use of
this well be be discontinued and an alternative water supply will
be provided to the users of that vell. since these requirements
for offsite wells vere not presented in the proposed plan, a dis-
cussion of these requirements is also presented in the
"Documentation of Significant Changes" section of the ROD. This
.ection explains that these requirements pertaining to off.ite
wells have been added to the ROD in response to public comments
received.
2.
Comment:
Continual reassessment/adjustment of the cleanup program
will be necessary to ensure that:
2.
a.
a.
Chemical breakdown/recombination into more toxic sub-
stances does not threaten the program's validity. .
with the first sand zone going dry, the flushing effect
in the second sand zone will not spread the con-
.taminated groundwater plume.
b.
c.
with future heavy industrial
groundwater overdrafting and
not acqelerate the migration
groundwater plume.
development, heavy
cones of depression will
of the polluted
With future heavy industrial development and resultant
industrial wastewater discharge into the sewer system,
further soil and groundwater pollution will not occur
via sewer facility sludge and greywater discharge.
SPA Response:
d.
As..is described in the "Selected Groundwater Remedy"
section of the ROD, continued groundwater monitoring
will be required at and downgradient from the site.
The groundwater analyses conducted at the sit. to date,
12
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b.
include. vide ranqe of chemicals. This vill continue
to be the case in the future, so that potential
breakdownl~ecombination prod~cts do not qo undetected.
As is described in the "Selected Remedy for
Groundwater" section of the ROD, the qroundwater ex-
traction and reinjection system vill be desiqned durinq
the RD phase. This system vill be carefully desiqned
80 that reinjection does not cause enhanced miqration
of the qroundwater contaminant plumes.
c.
As described above, the desiqn of the qroundwater ex-
traction system vill have to incorporate present and
potential future qroundwater pumpinq in the vicinity of
the site. Furthermore, BPA and DBS vill interact
closely vith the City of Fresno to ensure that
groundwater pumpinq in the vicinity of the site does
not accelerate miqration of the qroundwater plumes.
d.
Future heavy industrial development and resultant vas-
tewater discharqe to the sewer is likely to occur in
the vicinity of the site in the future. Bowever,
requ~ation of this development, wastewater discharqe,
and any associated soil and qroundwater contamination
vill be requlated under the appropriate federal, state,
and local requlations. These issues are not directly
pertinent to the selected remedy described in this ROD,
and .are not discussed in the ROD.
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