United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-93/100
September 1993
&ER& Superfund
Record of Decision
Hexcel, CA
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50272-101
REPORT DOCUMENTATION 11. REPORT NO. 2. 3. Recipient's Accession No.
PAGE EPA/ROD/R09-93/100
4. Tille and Subtille 5. Report Date
SUPERFUND RECORD OF DECISION 09/21/93
Hexcel, CA 6.
First Remedial Action - Final
7. Author(s) 8. Performing Organization Repl. No.
9. Performing Organization Name and Address 10 Project Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address 13. Type of Report & Period Covered
U..S. Environmental. Protection Agency, . 800/800
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Notes
PB94-964510
16. Abstract (Limit: 200 words)
The Hexcel site is an industrial waste disposal area in Livermore, Alameda County,
California. Land use in the area was originally agricultural and grazing lands, out. is
now composed predominantly of residential and industrial properties. In 1912, the
Coast Manufacturing,and Supply Company (CMS) constructed the first manufacturing
facility at the Hexcel Composite Materials Manufacturing Plant (HMP) and produced black
powder safety fuse, resin-impregnated glass cloth products, and detonation cord. ' In
1968, Hexcel Corporat'ion acquired the CMS plastics division; ceased fuse and
explosives-related production; and has since operated the Composite Materials Plant for
the manufacture of composite materials used in aerospace and 'other structural
applications. Since 1906, the Western Pacific and Union Pacific Railroads has used the
Abandoned Disposal Site (ADS) as a borrow site for embankment construction, during
which time various solid and liquid wastes were disposed of onsite. In 1940, CMS
purchased the area; then in 1968, Hexcel acquired the manufacturing plant. In 1979,
ownership of the site again' was transferred, and during this time, general plant
refuse, employee refuse, industrial and chemical wastes, sewage wastes, and general
,house and construction debris were disposed of at the ADS. As a result of two
documented onsite chemical spills in 1983 at 'the HMP, invoiving 600 ,gallons of
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Hexce 1, CA
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, PC E), metals (arsenic)
b. Identlfl~rs/Open-Ended Terms
c. COSATI Field/GroUp
18. Availability Statement 19. Security Class (This Report), 21. No. of Pages
None 82
Security Class (This Page) 22. Price '
20.
None
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTI8-35)
bepartment of Commerce
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EPA/ROD/R09-93/100
Hexcel, CA
First Remedial Action - Final
Abstract (Continued)
industrial solvent and 1,200 gallons of methyl ethyl ketone (MEK), as well as various
discharges at the ADS, a number of investigations were conqucted, which revealed elevated
levels of benzene, xylenes, phenol, and lead in the soil; and VOCs, including TCA, PCA,
toluene, xylenes, and phenol in ground water. In 1983, a removal action was conducted to
address remediation of previous spills that occurred at HMP, and consisted of removal of
contaminated soil and ins~allation of temporary wells to recover methylene.
chloride-contaminated ground water. In addition, in 1986, a treatability study was
performed to determine the capacity of the Livermore POTW to handle ground water
discharged from the recovery well; and in 1991, acetone- and MEK-contaminated soil was
removed under a State work plan. The contaminated area of this site has been divided into
two OUs for remediation: the HMP OU and the ADS OU. This ROD addresses a first and final
remedy for the HMP and the ADS OUs. During the RI, soil and debris' contaminants wer~
found to be less. than background levels, although COCs in.the subsurface soil may still
contribute to ground water-contamination in some areas of the HMP OU. The primary
contaminants of concern affecting the ground water are VOCs, including benzene and PCE;
and metals, including arsenic. . - .
The selected remedial action for this site includes treating acetone-, MEK-, and
benzene-contaminated soil and debris onsite using in-situ vapor extraction, soil aeration,
and sparging to enhance aerobic biodegradation; disposing of between 65 and 95 55-gallon
drums of organic-contaminated soil offsite at an appropriate landfill, with treatment
using venting; dewatering this soil during certain periods of the year, if needed, with
pretreatment and discharge to the industrial sewer under Hexcel's existing industrial
discharge permit; pumping and treating ground water onsite, as needed, using a treatment
to be designed later, with offsite discharge to a POTW; further delineating the area where
PCE has affected ground water; filling and regrading the site areas; monitoring ground
water and subsurface methane concentrations; providing a contingency for additional
methane control measures, if required; and implementing institutional controls, including
deed restrictions. The estimat~d present worth and annual O&M. costs for this remedial
action were not provided. .
PERFORMANCE STANDARDS OR GOALS:
Soil and ground water cleanup goals are based on health-based standards. The
chemical-specific soil cleanup goal is total VOCs 1 mg/kg. Chemical- specific ground
water cleanup goals include acetone'770 mg/kg; arsenic 50 mg/kg; barium 1,100 mg/kg;
benzene 1 mg/kg; methyl ethyl ketone 1,100 mg/kg; and PCE 5 mg/kg.
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HEXCEL
LIVERMORE, CA
RECORD OF DECISION
1993 FINAL
-------
RECORD OF DECISION
1993 FINAL .
HEXCEL
LIVERMORE, CA
DECLARATION STATEMENT
SITE NAME AND LOCATION
Hexcel Superfund site
10 Trevarno Road
Hexcel composite Manufacturing Plant
and Abandoned Disposal site Operable
Alameda County, Livermore, CA
Operable Unit (HMPOU)
Unit (ADSOU)
STATEMENT OF BASIS AND PURPOSE~
This Record of Decision (ROD) presents the selected remedial
action for the Hexcel Site located in Livermore, California,
developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, 42 U.S.C.
section 9601, (CERCLA) and the National oil and Hazardous
Substances Pollution Contingency Plan, 40 C.F.R Part 300, 55 Feb.
Reg. 8666 (3/9/90) (NCP). The 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 ROD, may present an imminent and substantial
endangerment to public health~ welfare, or the environment.
DESCRIPTION OF THE REMEDY
EPA has determined that the following remedy is required to
ensure protection of human health and the environment. For the HMP
OU the remedy consists of removing sources of organic compoung,s
(acetone, methyl ethyl ketone, and benzene) in two locations by in-
situ soil vapor extraction, soil aeration, and sparging to enhance
aerobic biodegradation. The remedy also includes pumping in a
third area to capture groundwater containing tetrachloroethylene
wi th disposal to the Livermore publicly owned treatment works
(POTW), and continued groundwater monitoring.
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For the ADS OU the remedy consists of monitoring
concentrations of methane in the subsurface soils with a
contingency for methane control measures if necessary, regrading
the surface to prevent ponding and excess infiltration of water,
continued groundwater monitoring, and a deed notification
identifying areas of buried waste.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, and complies with federal and State requirements that
are legally applicable or relevant and appropriate (ARARs) to the
remed~al action. EPA's determination of ARARs is attached.
This remedy is cost effective and utilizes permanent solutions
and alternative treatment or resource recovery technologies to the
maximum extent practicable and satisfies the statutory preference
for selecting remedies that employ treatment as a principal element
and that significantly and permanently reduces the toxicity,
mobility, or volume of the hazardous substances.
o
A review of the remedial action will be conducted within five
years of implementation of the remedy to insure that the remedy
continues to provide protection of human health and the
environment. Complete cleanup will likely take more than five
years to attain.
'~2~~
Date
n)
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APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
HEXCEL CORPORATION SUPERFUND SITE
September 1993
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HEXCEL
LIVERMORE, CA
RECORD OF DECISION
1993 FINAL
* * * * Table of Contents * * * *
1.
Declaration Statement
2.
Determination of ARARs
3.
Order No. 93-111 issued by the California Regional Water
Quality Control Board, San Francisco Bay Region, September 15,
1993 .
4.
Executive Summary; Responsiveness Summary
5.
Administrative Record Index;
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I.
INTRODUCTION
The Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), as amended by the Superfund Amendments
and. Reauthorization Act of 1986 (SARA), requires that remedial
actions at a Superfund site achieve a level of remediation that
protects human health and the environment. In addition, the
remediation must attain legally applicable or relevant and
appropriate requirements (ARARs). ARARs are standards, criteria
or limits promulgated under federal or state law. Only those
state standards that are promulgated, identified by the State in
a timely manner, and are more stringent than federal requirements
may be considered ARARs (40 CFR Part 300, S400(g) (4».
The definition of "applicable" and "relevant or appropriate"
requirements is derived from the National Contingency Plan (40
CFR section 300.5):
"Applicable requirements means those cleanup
standards, standards of control and other
substantive requirements, criteria, or limitations
promulgated under federal environmental or state
environmental or facility siting laws.that
specifically address a hazardous substance,
pollutant, contaminant, remedial action, location,
or other circumstance at a CERCLA site. . . ."
"Relevant and appropriate requirements means those
cleanup standards, standards of control, and other
substantive requirements, criteria,. or limitations
promulgated under federal environmental or state
environmental or facility siting laws that, while
not "applicable" to. a hazardous substance,
pollutant, contaminant, remedial action, location,
or other circumstance at a CERCLA site, address
problems or situations sufficiently similar to
those encountered at the CERCLA site that their
use is well-suited to the particular site. . . ."
, .
SARA provides that on-site response actions carried out in
compliance with Section 121 of CERCLA may proceed without
obtaining federal, state or local permits [see CERCLA Section
121(e»). This permit exemption allows the response actions to
proceed in an expedient manner, free from potentially lengthy
delays for administrative approvals from regulatory agencies.
This permit exemption applies to all administrative requirements,
whether or not they are actually "permits."
Federal and state nonpromulgated standards, policies, or
guidance documents, and local requirements are not ARARSi
however, these are criteria to be considered when,determining
actions necessary to protect human health and the environment.
These nonpromulgated, nonbinding criteria are called "To Be
Considered" or "TBC" criteria.
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ARARs typically fall into three categories:
.
Chemical-specific requirements are health- or
risk-based numerical concentration limits for
specific hazardous substances or chemicals.
Maximum contaminant levels (MCLs) and Maximum
contaminant Level Goals (MCLGs) are examples
of chemical-specific requirements.
.
Location-specific requirements impose
restrictions on activities because a site is
in a special location such as a floodplain,
wetland, or historical area.
.
Action-specific requirements are technology-
or activity-based limitations to address
particular circumstances at a site, such as
Clean Water Act requirements applicable to
disposal of dredged or fill material.
I '
Identification of ARARs is dependent on three factors:
chemicals of concern; 2) environmental media affected by
chemicals of concern (i.e., air, water, or soil); and 3)
potential and actual use of affected media.
1)
II.
ARARS
A.
Chemical-Specific Reauirements
1.
Groundwater
*
Federal Primary Drinking Water Standards (40
CFR Part 141)
Chemical-specific drinking water standards
have been promulgated under section 1412 of
the federal Safe Drinking Water Act (42
U.S.C. S 300g-1). Maximum contaminant Levels
(MCLs) are enforceable standards for public
drinking water systems when the water is
directly provided to 25 or more people or 15
or more service connections. 'In accordance
with the National contingency Plari ("NCP"),
MCLs, or federal MCLGs above zero, are
relevant and appropriate standards for
groundwater at this site.
Maximum Contaminant Level Goals (MCLGs) above
zero are also considered chemical-specific
ARARs under the NCP. When MCLGs are equal to
zero (generally, for any chemical considered
to be a carcinogen), the MCL is considered to
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be the chemically-specific ARAR, instead of
the MCLG.
*
State Drinkina Water Standards 22 CCR ~64401
et sea.
The State of California has under its Safe
Drinking Water Act (California Health and
Safety Code Div. 5, Part 1, Chapter 7, S 4010
et seq.) established enforceable primary
drinking water standards, which are
applicable. The appropriate remedial
standard for groundwater is the current
'federal or state MCL, whichever is more
stringent. The cleanup levels are listed in
Section 19.2, page 23 of Order Number 93-111
issued by the California Regional Water
Quality Control Board (CRWQCB) incorporated
in this ROD.
2.
Soil
There are no federal or state promulgated
chemical-specific requirements that prescribe
remediation levels in soil.
B.
Location-SDecific Reauirements
No location-specific ARARs have been identified.
C.
Action-Specific Reauirements
1.
Hazardous Waste Identification. Generation and
Disposal
Effective August 1, 1992 the state of California
was authorized by EPA to implement the hazardous waste
program within California by implementing and enforcing
the California hazardous waste regulations in lieu of
the federal RCRA regulations. The EPA authorization
covers RCRA regulations adopted through December 20,
1990; permitting and enforcement based on regulations
and programs adopted after December 20, 1990 are still
the responsibility of EPA. Therefore the California
hazardous waste regulations, and not the federal
hazardous waste regulations, are applicable.
*
Hazardous Waste Identification
Regulations at 22 California Code of
Regulations (CCR) Div. 4.5, Chapter 11 relate
to the identification and listing of
hazardous waste. These regulations ar.e ARARs
for the determination of whether excavated
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2.
soils or treatment residuals are hazardous
waste.
*
Hazardous Waste Generation
The substantive provisions of California
regulations relating to generators of
hazardous waste (22 CCR Div. 4.5, Chapter 12)
are ARARs if hazardous wastes are generated
during the remedial process.
*.
Hazardous Waste DisDosal or Treatment
The substantive provisions of the California
hazardous waste regulations, 22 CCR Div. 4.5,
Chapter 14, which relate to hazardous waste
treatment, storage, and disposal ("TSD")
facilities will be ARARs if the remedial
actions involve the activities addressed by
these regulations, such as the on-site
treatment of hazardous wastes or the storage
of hazardous waste in containers onsite for
more than 90 days.
The use of granular activated carbon (GAC)
for remediation of VOCs triggers requirements
associated with the regeneration or disposal
of the spent carbon. Regulations relating to
the off-site disposal or treatment of
hazardous wastes are ARARs depending on the
method of disposal or ultimate treatment of
VOC-containing soil or activated carbon.
Air Emissions from Remedial Actions
*
Bay Area Air Oualitv Manaqement District
(BAAOMD) Reaulation 8. Rule 47
This rule, which applies to specified
discharges of organic compounds to the
atmosphere through air stripping and soil
vapor extraction operations during removal of
organic compounds from soil and groundwater,
is applicable. .
Section 8-47-300 Standards states:
Emission '. Control Requirement, Specific
Compounds: Any air stripping and soil vapor
extraction operations which emit benzene,
vinyl chloride, perchloroethylene, methylene
chloride, and/or trichloroethylene shall be
vented to a control device which reduces
emissions to the atmosphere by at least 90%
by weight. .
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Organic Compounds: Any air stripping and soil
vapor extraction operations with a total
organic compound emission greater than 15
pounds per day shall be vented to a control
device which reduces the total organic
compound emissions to the atmosphere by at
least 90% by weight.
3.
Manaqement of Solid Waste DisDosal site
*
California regulations relating
waste disposal sites, primarily
Article 7.6, and 23 CCR Div. 3,
are applicable.
to solid
14 CCR
Chapter 15,
4 .
Gradinq
*
Substantive provisions of the California
State Water Resources Control Board's general
permit for storm water discharges associated
with construction activity (Order No. 92-08-
DWQ), promulgated under the authority of the
federal Clean Water Act, which relate to
clearing, grading, or excavation that results
in soil disturbance of at least five acres of
total land area, are applicable.
III. OTHER ARARS
A.
San Francisco Bav Basin Plan
The Basin Plan, developed by the RWQCB,
establishes ambient surface and ground water
quality objectives and an implementation plan to
. achieve and maintain water quality for beneficial
uses.
The Basin plan states that, unless otherwise
designated by the RWQCB, all ground water is
considered as suitable, or potentially suitable,
for municipal or domestic water supply. The Basin
Plan incorporated criteria in SWRCB Resolution No.
88-63 ("Sources of Drinking Water") for making any
exceptions.
B
DisDosal of Extracted Groundwater from Groundwater
CleanuD Pro;ects (Resolution 88-160)
RWQCB Resolution 88-160, approved by SWRCB
Resolution 89-21, urges dischargers of extracted
groundwater from groundwater cleanup projects to
reclaim their effluents to the extent technically
and economically feasible, and when reclamation is
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not technically and economically feasible, to
discharge to the POTW.
C.
EPA Reaion 9 preliminarv Remediation Goals (PRGs)
PRGs are health-based concentrations which can be used as
starting points for determining site-specific cleanup standards.
PRGs combine EPA toxicity values with conservative (health-
protective) exposure assumptions to estimate contaminant levels
in environmental media which correspond to a lifetime cancer risk
of 1 x 10-6 .
risk and/or hazard index of 1 for noncancer concerns. PRGs have
been selected as performance standards (rather than ARARs) for
certain chemicals shown on page 23, Section 19.2 of order Number
93-111 of the CRWQCB. .
IV.
other Leaal Reauirements
The following requirements apply to the remedial action,
although they are not ARARs:
*
Emplovee Safetv Standards
Regulations regarding employee safety standards
relating to hazardous waste operations and
emergency response are set forth at 8 CCR 55192.
Occupational Safety and Health Act (OSHA)
requirements for worker protection, training and
monitoring (29 U.S.C. 5651 et seq., 29 CFR
51910.120) are also applicable.
*
Hazardous Materials Transportation
Both federal and state laws and regulations
governing transportation of hazardous wastes (40
CFR Part 263, 49 CFR Part 171-179), California
Hazardous Waste Haulers Act, California Health &
Safety Code 25167.1 et seq., 13 CCR 5 1160 et
seq.) are applicable if the selected remedy
involves off-site transportation of hazardous
waste.
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- -~-"-- . - ----- -~-~-~_.-. --.-- ~- ..-.--.
. . .. .
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
ORDER NUMBER 93-111
RESCINDING ORDER NO. 91-165
REVISED SITE CLEANUP REQUIREMENTS FOR:
HEXCEL CORPORATION
10 TREV ARNO ROAD
LIVERMORE
ALAMEDA COUNTY
HEXCEL CORPORATION, DONALD AND SUZANNE
SMITH,ANDF&PPROPER~
ABANDONED DISPOSAL UNIT, NORTH MINES ROAD
LIVERMORE
ALAMEDA COUNTY
The California Regional Water Quality Control Board, San Francisco Bay Region (hereinafter
called the Board) finds that:
1. SITE LOCATION AND DESCRIPTION:
1.1 This Order presents the selected fmal remedy for the Hexcel Superfund Site (the
"Site"). Consistent with the National Contingency Plan ("NCP") policy ~ 40 C.F.R.
~ 3oo.430(a){1)(ii» for purposes of remedy selection and remedial planning, the Site
has been separately divided into the "Hexcel Composite Materials Manufacturing Plant
Operable Unit (HMP OU)" and "Abandoned Disposal Site Operable Unit (ADS OU)".
The HMP OU is located at 10 Trevamo Road, Livermore, Alameda County (Figure 1).
The ADS OU is located at the southerly end of North Mines Road. The Site is located
in the Livermore region of the Amador-Livermore Valley, on a gently north-sloping
plain broadly bounded by Arroyo Mocho to the southwest, Arroyo Seco to the east, and
1-580, the Spring Basin and Arroyo Las Positas to the north. This area was primarily
agricultural and grazing lands but is now comprised primarily of residential and
industrial property development. Residential developments are separated from the HMP
OU by vacant land. Residential developments are separated from the ADS OU by the
railroad right-of-way.
1.2 The ADS OU is about 3,000 feet long by 400 feet wide. It is an unlined site,
which has received waste disposal without authorization from this Board. The existing
cover is inadequate for appropriate surface drainage and surface development. The
wastes may contain pollutants, which under ambient environmental conditions, could
be released at concentrations which could cause degradation of waters of the State.
2. SITE HISTORY
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2.1 HMP OU
. 2.1.1 Coast Manufacturing & Supply Company (CMS) constructed the first
manufacturing facility at the HMP OU in 1912, CMS manufactured: black powder
safety fuse between 1912 and 1968; resin-impregnated glass c10th products between
1948 and 1968; and detonation cord containing pentaethrytol tetranitrate (PETN)
between about 1966 and 1968. .
2.1.2 Hexcel Corporation purchased the CMS Plastics Division in 1968. Production
of fuse and explosives-related products ceased at that time. The equipment used in the
fuse and explosives manufacturing. processes was purchased by the Apache Powder
Company, dismantled, and removed from the HMP OU. During dismantling of the
equipment, Apache Powder may have deposited debris in the ADS OU. Hexcel has
operated the Composite Materials Plant at the Site since 1968 for the manufacture of
composite materials used in aerospace and other structural applications. The
manufacturing process involves impregnation of various fabrics with resins to produce
a rigid structure.
2.1.3 Two documented chemical releases at the HMP OU have been reported. On
February 15, 1983, approximately 600 gallons of solvent AP-92 (consisting of 74%
methylene chloride, 12 % isopropanol, 11 % dimethyl formamide, and 4 % methyl ethyl
ketone) were spilled from a transfer line leading to Tank G south of Building 19. A
second spill on April 20, 1983 involved approximately 1200 gallons of methyl ethyl
ketone (MEK) which were released inside Building 19 after a valve was inadvertently
left open. Approximately 700 gallons flowed out of the building onto the grounds
surrounding Building 19. The remaining 500 gallons were recovered inside the building
on the day of the spill. The constituents detected in the subsurface at the HMP OU
consisted largely of acetone, "MEK, toluene, butyl alcohol, dimethyl formamide (DMF)
and dichloromethane (DCM) originating from the two accidental spills. After the spill,
site-specific cleanup was undertaken immediately.
2.2 ADS OU .
2.2.1 'The area of the ADS au has been in use since 1906, when this was used as a
borrow site by the Western Padfic and Union Pacific Railroads for construction of the
two adjacent and enclosing parallel railroad embankments. Disposal of various solid
and liquid wastes took place within the ADS. Investigations have detected buried waste
in the western third of the property. . The property inc1uding the ADS may have been
owned by the Palmer McBride Company until 1940.
2.2.2 CMS, Hexcel's predecessor at the HMP OU, purchased the area of the borrow
pit in 1940. Hexcel purchased the manufacturing plant and the ADS from CMS in
1968. .
2
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-. - --_.--.L_---_.~.-
2.2.3 A domestic sewage drain field was constructed in 1955 in the southwest quaner
of the ADS. Industrial and domestic sewage was treated (via Hoffman Tank, thought
to be an anaerobic digester) and then drained into a series of three eastward cascading
evaporation ponds. The volume, consisting mostly of non-contact process cooling
water, ranged from between 2,500 gpd in 1958 to 24,000 gpd in the mid-1970s. The
Regional Board and Alameda County Flood Control District, Zone 7 began monitoring
the leach field area as early as 1959. Sewage disposal continued until 1977, when
Hexcel cOnnected the sewage out-fall to the municipal sewer system.
2.2.4 Hexcel sold the property which contained the former b<;>rrow pit, waste disposal
site and sewage drain field to Donald W. and Suzanne T. Smith in March, 1979.
During the Smith's ownership of the property additional wastes were disposed of at the
Site. The Smiths sold the property to F&P Properties, the current owners, in 1985.
2.2.5 The wastes that may have been disposed of at the ADS fall into five general
categories:
General plant refuse
Employee refuse
Industrial and chemical wastes
Sewage wastes
General household trash and construction debris.
2.2.6 Activities at the ADS OU subsequent to Hexcel's ownership have included
disposal of domestic or commercial trash, and leakage or drainage of lubricating oil,
hydraulic fluid and coolants from vehicles stored on the ADS OU. Discharges from
truck repair and painting activities have occurred at and near Jag's Diesel. In addition,
the central portion of the ADS OU is currently used by Mountain Cascade, Inc. for
storage of construction materials and heavy construction vehicles. The construction
materials observed to be present on the ADS OU include iron pipe, PVC pipe, concrete
asbestos pipe, concrete pipe, culverts, and manholes. Trash, including lumber,
cardboard, automobile batteries, and used oil filters were present in a depression near
the center of the Site in 1991.
2.2.7 The western portion of the ADS OU is occupied by Jag's Diesel, an active
business that performs various truck repairs including painting. The area immediately
to the east of Jag's Diesel is used for storage of Jag's Diesel's salvaged truck bodies.
3. Dischar~ers
3.1
HMP OU
3.1.1 Hexcel is named as a discharger because of their ownership and operation of the
3
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HMP OU and the documented discharges which occurred during the period of Hexcel's
ownership (see 2.1, Site History).
3.2
ADS OU
3.2.1 Hexcel, the Smiths and F&P are named as dischargers of the ADS au because
of their ownership of the property during which time discharge(s) occurred (see 2.2,
Site History).
4. HYDROGEOLOGY
4.1 Groundwater supplies within the Livermore Valley are derived principally from sand
and gravel units within the Quaternary Alluvium and the Livermore Formation. One-third
of the City of Livermore's municipal drinking water consists of groundwater pumped from
zones at depths of 25D-feet or greater, and the other two-thirds consists of imported water.
The closest public water supply well is approximately 3600 feet upgradient from the Site
and produces from water-bearing units at least 200 feet. below the deepest unit in which
chemicals have been detected at the Site..
4.2 The principal waterbearing units at the Site are alluvial sediments of Quaternary and
possibly Pleistocene age that occur between the surface and a depth of about 50 feet. These
alluvial deposits contain a complex sequence of lenticular sands, gravels, silts, and clay.
Five informal lithologic units have been described at the Site, termed the Unsaturated
Fine-Grained Zone ("UFGZ"), Upper Transmissive Unit ("UTU"), Middle Aquitard
("MA "), Middle Transmissive Unit ("MTU"), and Lower Aquitard ("LA"). The most
permeable units are sand and gravel zones of the UTU and MTU that vary from six inches
to about thirty feet in thickness. These shallow alluvial sediments within one-half mile of
the Site are not presently used for water supplies.
4.3 Transmissive units as deep as seven hundred feet are also present within the Livermore
Formation and are tapped by CMS's former fire suppression system wells #5 and #6 located
along the southeastern boundary of the HMP OU. These wells tap a water supply aquifer
for the City of Livermore. These deep confined water-bearing zones are separated from the
shallow aquifers by dense clays of the Livermore Formation. At the present time, the
potentiometric surface in the deep water-bearing zones of the Livermore may be slightly
higher than that in the alluvium.
4.4 Groundwater occurs at a depth of about fifteen feet"at both the HMP and ADS OUs.
The general direction of groundwater flow is toward the north and is influenced by remedial
groundwater pumping at Intel. No water supply wells are known to use these shallow
water-bearing units within one-half mile of the Site.
5. SURFACE WATER
4
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5.1 HMP au The Hexcel plant lies about 535 feet above mean sea level on an alluvial
surface which slopes gently to the northwest at about fifty feet per mile. The land surface
. within the Site is relatively flat and there are no clearly-defined channels. Most runoff
flows northward toward the railroad tracks and then west along the right-of-way to Arroyo
Seco, which is part of the City of Livermore's flood control system.
5.2 ADS OU Most of the ADS OU is characterized by internal drainage. Runoff
accumulates. in closed depressions; where most of it evaporates. The only runoff that leaves
the ADS OU (which is covered by clean fill) enters Arroyo Seco from the eastern portion
of the ADS OU.
6. SOIL AND GROUNDWATER INVESTIGATIONS
6.1 HMP au
6.1.1 Several site assessment -investigations have been performed at the HMP OU since
1983 under the direction of the Board. These investigations have focused on the area
around Building 19 and the chemical compounds involved in the two documented
solvent spills. .
6.1.2 Remedial Investigation (RI) activities performed at the HMP OU between May
and December 1991 included:
1. An investigation of surface features in the Site;
2. A soil gas investigation;
3. Confirmatory drilling and soil sampling;
4. Sampling of existing groundwater monitoring wells;
5. Installation of new wells near the property boundary;
. 6. Characterization of hydrogeologic properties; and
7. Interim remedial actions.
6.1-.3 Quarterly groundwater monitoring has been performed at the HMP OU since
1991. An investigation of the extent of an area in which PCE was detected to the north
. and west of the HMP OU was perfoimed, at the request of the Board, in March 1993
and the results reported to the Board in the first Quarterly Report of 1993.
6.2 ADS OU
6.2.1 Initial site assessment activities began in 1985, with site history and background
reports prepared for Hexcel by Aqua Terra. In 1986, a Phase I field investigation was
performed for Hexcel by Hydro Geo Chern under the direction of the Board. A
Phase n investigation was performed in 1988 by Hydro Geo Chern, also under the
direction of the Board. In connection with F&P's proposed property development, a
geotechnical and soil pollutant investigation was performed in 1988 by BSK &
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Associates. BSK & Associates performed a geotechnical and environmental assessment'
focusing on the western third of the ADS in April and May 1989. This investigation
included test hole drilling, geophysical surveys, and chemical sampling and analyses.
6;2.2 RI activities were performed during the period from November 1991 through
March 1992. These activities consisted of:
1. An investigation of surface features in the Site;
2. A soil gas investigation;
3. Confirmatory drilling and soil sampling;
.4. Sampling of existing monitoring wells;
5. Installation of new wells; and .
6. Characterization of hydrogeologic properties.
6.2.3 A quarterly water level and groundwater monitoring program was begun in
February 1989. ~~nitoring continued through June 1990, when it was suspended
pending resolution of the National Priority List status of the Site. Quarterly
groundwater monitoring was resumed in March 1992. An investigation of methane
concentrations in soil along the perimeter of the ADS OU was performed, at the request
of the Board, in March 1993 and the results were reported to the Board in April 1993.
7. DETECfION OF CHEMICALS IN SOIL
7.1 HMP au
7.1.1 The following chemicals have been detected in the subsurface at the HMP au
at concentrations greater than 1 ppm. The maximum concentration were found in one
soil sample from a depth of 5 feet below surface: acetone (36,000 ppm) and methyl
ethyl ketone (MEK) (83,000 ppm), and another soil sample from a depth of 30 feet
below surface: benzene (1,000 ppm), toluene (75,000 ppm), ethylbenzene
(44,000 ppm), xylenes (190,000 ppm), phenol (2,900 ppm), methyl benzene
(140,000 ppm), and naphthalene (5,500 ppm). Acetone, MEK and benzene were
detected in the vicinity of the Bldg. 19 spill and near the former Recycle Pad on the
north side of Bldg. 101. Toluene, ethylbenzene, xylenes, methyl benzene and
naphthalene are components of gasoline and other petroleum hydrocarbons. These
constituents were detected in soil at concentrations exceeding 1 ppm in the vicinity of
a suspected gasoline spill or leaking underground storage tank on the north side of
Bldg. 101. Phenol was detected in one soil sample near Bldg. 19.
7.2 ADS OU
7.2.1 No volatile organic compounds were detected in soil samples during the RI at
concentrations greater than 1 ppm. Acetone was detected in samples from borings in
the vicinity of the former sewage lagoons at concentrations less than 100 ppb.
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7.2.2 Three semi-volatile compounds, dibenzofuran, fluorene, and phenanthrene, were
detected at concentrations of 3000 ppb, 2800 ppb, and 17000 ppb, respectively, in one
surface soil sample collected near Jag's Diesel. These compounds are polyaromatic
hydrocarbons often associated with used motor oil.
7.2.3 Bis(2-ethylhexyl)phthalate was the only semi-volatile priority pollutant detected
in soil samples analyzed prior to the RI. This compound was detected in boring EB-3
at 1100 ppb, boring L-2 at 460 ppb, and in L-3 at 230 ppb.
7.2.4 Copper, zinc, and nickel were metals detected in soils at concentrations which
may be higher than background. The maximum concentrations of these metals were
all detected in soil samples from P-14 on the north side of Jag's Diesel.
7.2.5 The following constituents were detected in an extractant liquid from a sample
of resin taken from the former Resin Pit that was analyzed by the toxic characteristic
leach procedure (fCLP): .
Barium
Lead
Cadmium
Total Chromium
0.644 mg/l
0.425 mg/l
0.076 mg/l
0.011 mg/l
7.2.6 Methane was detected in soil gas samples collected throughout the central portion
of the ADS. The highest methane concentrations were found in the vicinity of the
former solid waste disposal area in the IS-foot samples which were C9llected close to
the saturated zone. Concentrations in this area ranged from less than 1.5 part per
million volume (ppmv) to 190,000 ppmv. Soil gas samples collected along the
perimeter of the ADS OU in March 1993, contained only very low concentrations of
methane (less than 75 ppmv gas).
8. DETECTION OF CHEMICALS IN GROUNDWATER
8.1 HMP OU
8.1.1 Fifteen volatile organic compounds and five. semi-volatile compounds were
detected during the RI. Two volatile compounds, carbon. disulfide and
1,2 dichlorobenzene, were detected only once and at concentrations of 3 and 5 ppb,
respectively. Other volatile organic compounds detected in groundwater during the RI
at the HMP included vinyl chloride (maximum 5 ppb), methylene chloride (maximum
62 ppb), 1,1 dichloroethane(maximum 10 ppb), t-l ,2dichloroethene (maximum 3 ppb),
c-1,2 dichloroethene (maximum 26 ppb), trichloroethene (maximum 3 ppb),
tetrachloroethene (maximum 74 ppb), acetone (maximum 6600 ppb), methyl ethyl
ketone (maximum 24,000 ppb), vinyl acetate (maximum 13 ppb), benzene (maximum
120 ppb), toluene (maximum 760 ppb), ethylbenzene (maximum 130 ppb), and.xylenes
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(maximum 310 ppb).
8.1.2 Semi-volatile compounds detected were phenol (maximum 3 ppb), 2-methyl
phenol (maximum 8 ppb), 4-methyl phenol (maximum 28 ppb), 4 chloroaniline
(maximum 8 ppb), and methyl benzene (maximum 198 ppb).
8.1.3 The non-chlorinated solvents detected in groundwater were acetone, MEK and
toluene. Toluene is also a fuel hydrocarbon constituent. The highest concentrations
of these constituents were detected in well M-3 which is in the area affected by the
Building 19 solvent spills. Lower concentrations were detected in well Bl007 which
is near the Recycle Pad and in an area where chemicals have been detected in soil.
8.1.4 Six chlorinated volatile organic compounds have peen detected in groundwater
at the HMP au during the RI. In order of decreasing maximum concentration, these
are: tetrachloroethene (PCE) (74 ppb), methylene chloride (38 ppb),
cis-l ,2 dichloroethene (26 ppb), 1,1 dichloroethane (10 ppb), trans-l ,2 dichloroethene
(3 ppb), and trichloroethene (3 ppb). With the exception of methylene chloride,
chlorinated volatile compounds were detected only in samples from wells HEX-13S,
HEX-13M, and HEX-14S. Methylene chloride was detected in samples from
wells M-l, M-3, and M-5 near Building 19.
8.1.5 PCE was detected in well HEX-14S at a concentration of 74 ppb during July
1991, and at 34 ppb in November 1991.PCE was detected in an area extending
northwest from the HMP au in March, 1993. The concentrations. of PCE in that area
range from about 20 ppb down to less than 5 ppb. TCE was detected at 3 ppb in only
the first sample from this well.
8.1.6 Volatile fuel hydrocarbon constituents detected in groundwater consist of
benzene, ethyl benzene, toluene, and xylenes (BTEX). The highest concentrations of
these constituents were detected in well Bl007. Toluene and xylenes were detected in
well M-3 near Building 19. Benzene has been detected sporadically at concentrations
ranging from 5 to 10 ppb in other monitoring wells near Building 19.
8.1.7 Five semi-volatile priority pollutants have been detected in groundwater samples
from the HMP au. In order of decreasing maximum concentration, these are: toluene
(198 ppb), 4-methyl phenol (28 ppb), 4-chloroaniline (8 ppb), 2-methyl phenol (8 ppb),
and phenol (3 ppb). The phenols were detected in wells M - 3 and B I 007 at
concentrations of less than 10 ppb.
8.1.8 4-chloroaniline was detected in wells M-3, M-7, and HEX-5 near Building 19
at concentrations ranging from 3 to 8 ppb.
8.1.9 Seven priority metals were detected in groundwater samples from the HMP au.
In order of decreasing maximum concentration, these are: nickel (2960 ppb) ,barium
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(1640 ppb), zinc (629 ppb), arsenic (112, ppb), and total chromium (29 ppb). The
maximum barium and arsenic concentrations occur in wells near Bldg. 19. The other
metals were detected in well HEX -13S.
8.2 ADS OU
8.2.1 The volatile compounds detected in groundwater samples collected during the
Phase I and II investigations and quarterly monitoring prior to June 1991, included
, benzene, toluene, xylenes, and some chlorinated compounds. Concentrations of the
detected aromatic and halogenated organic compounds were typically less than 10 ppb
. with the exception of 1,2 dichloroethane which was detected in P-3 in the 50 to 60 ppb
range. '
8.2.2 No volatile or semi-volatile compounds were detected in water samples collected
and analyzed during the RJ in 1991. Acetone was detected at 200 ppb in one water
sample analysis from well P-l1 during quarterly monitoring subsequent to the RJ in
June 1992. Chloroform was detected at 2 ppb in one sample from well P-14 in June
1992. Well P-14 has been sampled since June 1992; no chloroform has been detected
in samples taken subsequent to June 1992. ,,'
8.2.3 Bis(2-ethylhexyl)-phthalate has been detected sporadically in groundwater
samples collected subsequent to the RJ at a maximum concentration of 22 ppb.
8.2.4 The following seven priority pollutant metals were detected in water samples
collected during the RI and subsequent to the RJ: arsenic (maximum concentration
51 ppb); barium (1520 ppb); chromium (total 15 ppb and hexavalent 11 ppb); lead
(7 ppb); nickel (61 ppb); and zinc (68 ppb). Only' barium and arsenic have been
detected consistently.
8.3 Other Sites
8.3.1 Two other sites adjacent to the ADS OU are known to have groundwater
pollution. They are: Intel Corporation Fab ill facility about 300 feet northwest from the
west edge of the ADS OU, and, the former Industrial Ladder facility (Calico Lumber
and Supply) about 100 feet to the north of the ADS OU. '
9. REPORTS AND STUDIES
9.1
HMP OU REMEDIAL INVESTIGATION/FEASIBILITY STUDY/FINAL RAP
Hexcel submitted a Remedial Investigation (RI) report to the Board and EPA on April 23,
1992. On June 30, 1993, Hexcel submitted a Feasibility Study (FS) satisfying the
requirements of Order No. 91-165. Board staff found both the RI and FS acceptable. The
Proposed Plan (Cleanup Plan Proposed for Hexcel Superfund Site) contained the proposed
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final remedy for the HMP OU. The technical information contained in the RI, the FS, and
the Proposed Plan is consistent with the requirements of Section 25356.1 of the California
Health and Safety Code for RAPs and with the requirements of the National Contingency
Plan (NCP) for RIs and FSs. The final RAP for the HMP OU consists of this Order, the
RI, the FS, and the Proposed Plan.
9.2
ADS OU REMEDIAL INVESTIGATION/FEASIBILITY
STUDY/FINAL RAP. ADS OU
Hexcel submitted an RI Repon to the Board and EPA on May 15, 1992. On June 30, 1993,
Hexcel submitted an FS satisfying the requirements of Order 91-165. Board staff found
both the RI and FS acceptable. The Proposed Plan (Cleanup Plan Proposed for Hexcel
Superfund Site) contained the proposed fmal remedy for the ADS OU. The technical
information contained in the RI, the FS, and the Proposed Plan is consistent with the
requirements of Section 25356.1 of the California Health and Safety Code for RAPs and
with the requirements of the National Contingency Plan (NCP) for Ris and Fss. The final
RAP for the ADS OU consists of this Order, the RI, the FS, and the Proposed Plan.
9.3 RISK ASSESSMEtIT
EPA Region 9 prepared a Screening Risk Assessment (SRA) dated April 21, 1993. Cenain
risk calculations have been updated to represent the best, currently available data on site
conditions.
9.3.1 Contaminants of Concern
Contaminants of concern CCOCs) are those chemicals identified as being. most likely to
contribute significantly to' Site risk. The COCs for the Site were selected from those
potentially toxic chemicals that were detected in soil or groundwater at concentrations
above background levels and in more than 5% of the samples analyzed. EPA selected
the COCs from the analyses reponed in the RI reports for the HMP OU and the ADS
OU. Based on a pathway analysis that identified potential exposure to contaminated
groundwater as being the principal health risk, the following COCs detected in
groundwater were selected; arsenic, barium, acetone, MEK, benzene, and PCE. The
presence of methane in portions of the ADS OU was also identified as posing a
potential physical risk through the possibility of explosion if it accumulated in confined
spaces such as buildings.
9.3.2 1roxicitY Assessment
9.3.2.1 The COCs were evaluated for potential noncarcinogenic and carcinogenic
toxicity through groundwater ingestion. The hazard quotient is the ratio of the
maximum concentration of the substance detected in groundwater at either the HMP or
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ADS OU to the EPA toxicity value. Hazard quotients of less than 1 indicate that
routine consumption of water containing the substance at the maximum concentration
is likely to be without appreciable health risk.
9.3.2.2 Benzene and PCE were the only COCs identified in the SRA as a carcinogens.
The toxicity values are for drinking water concentration associated with a one in a
million risk of developing cancer over a 70 year exposure.
. 9.3.3 Exposure Assessment.
9.3.3.1 Soils: The SRA found that the surface soil concentrations were mostly at or
below background concentrations (for inorganic constituents) and below human health
effect thresholds (organics and inorganics) at both the HMP and ADS Ous. For this
reason, no cacs were identified for soils. COCs in the subsurface soil may contribute
to groundwater contamination in some areas at the HMP OU. The SRA also identified
potential physical hazards associated with methane and buried materials in the ADS au.
9.3.3.2 Groundwater: The SRA assessed the dominant Site risk of ingestion of
contaminated groundwater. The hazard quotients are estimates of the non-carcinogenic
risk of long-term consumption of groundwater that contains the maximum
concentrations of the COCs detected at the HMP OU. Hazard quotients greater than
1 indicate that the concentrations in groundwater may pose a health concern. Arsenic,
acetone, and MEK are in this category. Acetone and MEK were detected. in
groundwater at the HMP au only. Arsenic was detected in several wells in the Bldg.
19 area at the HMP OU and in one well at the ADS OU. Barium and PCE have hazard
quotients of less than 1.
9.3.3.3 Based on the maximum concentrations found in groundwater during the
investigations, the hazard quotient for all COCs is 23.9. Based on the average
groundwater concentrations, the hazard quotient for all COCs is 1.6.
9.3.3.4 The cancer risk of 1 x 10'" is an estimate of the upper-bound probability of an
individual developing cancer as a result of drinking water for 70 years with the
maximum concentration of benzene detected at the HMP OU. The excess cancer risk
for the PCE is 1 x 10"'. Benzene and PCE were not detected in groundwater samples
collected at the ADS OU either during or subsequent to the RI.
9.3.4 Summary of Potential Hea1th Risks
9.3.4.1 The Site's future potential risk to human health was assessed by evaluating
the exposure to drinking water derived from the Upper and Middle transmissive zones.
9.3.4.2 As stated in the SRA, the selection of the drinking water scenario may serve
to underestimate the site risk, as domestic use of water would also include showering,
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cooking, and recreational uses such as swimming. However, ingestion would be the
most dominant and frequent exposure scenario.
9.3.4.3 The SRA identified arsenic and MEK as the primary contaminants of concern
because their maximum concentrations exceeded the hazard quotient threshold of I for
systemic deleterious effects to adult residential receptors. The calculations presented
in the FS indicate that the hazard quotient for acetone also exceeds I. The cancer risk
associated with ingestion of benzene and PCE at the maximum concentration detected
at the HMP OU was calculated to be I x 1~. .
9.3.4.4 Potential physical hazards identified at the ADS OU were: the accumulation
of explosive concentrations of methane developing in on-site or off-site buildings, and
the excavation of buried materials in the landfill.
10. REGULATORY STATUS
10.1 The HMP OU was included on the National Priorities List (NPL) in August 1990 (55
FR 35502). Activities conducted at the HMP OU since that time have b~n performed
pursuant to Superfund guidelines.
10.2. In March, 1991 (letter dated March 6, 1991), EPA concluded that the ADS is part
of the NPL Site (8facility8), which is defined as 8any site or area where a hazardous
substance has been deposited, stored, disposed of, or placed, or otherwise come to be
located 8 . .
10.3 The Board is lead agency for the Ous and will continue to regulate the dischargers'
investigation and remediation work and administer enforcement actions in accordance with
CERCLA as amended by SARA (Superfund) based upon the South Bay Multi-Site
Cooperativ~ Agreement between EPA and the Board.
10.4 Hexcel has filed a petition in the U.S. Court of Appeals for the District of Columbia
Circuit requesting that the Court order EP A to remove the Hexcel Superfund Site from the
NPL. Should Hexcel prevail in its petition, the Board will retain lead for oversight.
10.5 Investigations at the HMP OU were required by Order 90-074 and investigations at
the ADS OU were required by Order 90-121. Order 91-165, which rescinded
.Orders 90-074 and 90-121, applied to both the HMP OU and ADS OU.
10.6 Hexcel has submitted the following documents, for both Ous, which have been
deemed acceptable by Board staff: Comprehensive Data Summary, Sampling and Analysis
Plan, Health and Safety Plan, RIfFS Work Plan, Data Validation Package, the
Administrative Record, the RI and FS Reports for the HMP OU and ADS OU, Quarterly
Technical Compliance reports, and the Off-Site Methane Survey report.
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11. BOARD ENFORCEMENT HISTORY
The following Board Orders have applied to conditions at the Site:
o
Cleanup and Abatement Order No. 83-003 (Hexcel Plant)
o
Site Cleanup Requirements Order No. 90-074 (HMP OU)
o
Site Cleanup Requirements Order No. 90-121 (ADS OU)
o
Site Cleanup Requirements Order No.91-165 (HMP OU and ADS OU)
12. INTERIM REMEDIAL ACTIONS
12.1 HMP OU
12.1.1 The initial remediation of the spills that occurred in 1983 near Bldg. 19
consisted of removal of soil known to be contaminated and installation of a temporary
well to recover groundwater containing methylene chloride. Well HEX-IO was installed
in 1985 to recover additional groundwater affected by the Bldg. 19 spill. A treatability
study was performed in 1986 to determine the capacity of the Livermore POTW to
handle groundwater discharged from the recovery well. Approximately 800,000 gallons
of water were pumped from this well between February and April, 1987. The water
was discharged to the Livermore POTW under Hexcel's industrial discharge permit.
Remedial pumping of groundwater from Well HEX-I0 has taken place periodically
since 1987 and is also discharged under the industrial discharge permit to the City of
Livermore's sewer system.
12.1.2 Soils containing acetone and MEK were removed from the Recycle Pad near
Bldg. 101 in 1991. These soils were excavated to a depth of approximately 5 feet
under a work plan approved by the Board. Prior to the RI, Hexcel excavated soils with
Bunker C fuel oil during removal of a waste holding tank. These soils were stockpiled
and sampled during the RI. Theywere found to contain MEK (27 ppb in one sample),
toluene (maximum 35 ppb), xylene (maximum 4 ppb), and bis(2-ethylhexyl)phthalate
(160 ppb in one sample).
12.2 ADS OU
Hexcel has not conducted any interim remedial actions at the ADS au.
13. SCOPE OF THIS ORDER
. This Order presents the selected final remedies for the HMP OU and ADS au as
described in 14.1.4 and 14.2.2. respectively. This Order also sets forth a task and time
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schedule for submittal of documents required for design and implementation of the
remedies.
14. REMEDIATION ALTERNATIVES CONSIDERED
14.1
HMP OU
Six alternatives, including the no-action alternative, were developed and evaluated for the
HMP au. . .
14.1.1 Alternative 1: No Action
Alternative 1 is no remedial action and no monitoring. In essence, this alternative
implies that the only change in soil and groundwater concentrations from current
conditions will be as a result of natural processes and human activities, such as remedial
pumping at the Intel Fab nl facility, that are outside of the control of current property
owners.
14.1.2
Alternative 2: Monitorine/Deed Restriction
Alternative 2 consists of monitoring and deed restrictions on groundwater uses. It also
includes additional investigations to further delineate the area of groundwater containing
PCE. Activities in specific areas are discussed below.
14.1.2.1 BIde. 19 Area: Alternative 2 for Bldg. 19 area consists of a deed
restriction on use of groundwater beneath the Hexcel Plant Site for human
consumption and continued monitoring of the area around Bldg. 19 on a
semi-annual basis.. As part of the detailed implementation of Alternative 2, wells
HEX-IO, M-3 and M-S are screened in both the Upper and Middle Transmissive
Units, will be removed to prevent any cross-contamination. Those wells that are
removed will each be replaced with two monitoring wells, one completed in the
Upper and one completed in the.Middle Transmissive Units (MTU).
14.1.2.2 Petroleum Hydrocarbon Area: Alternative 2 provides for a deed
restriction and continued monitoring of the area of petroleum hydrocarbon
contamination. It provides for installation of a monitoring well near Bl007
screened in the MTU. Previous monitoring has indicated that concentrations are
stable and downgradient monitoring wells do not show evidence of benzene
migrating from this area in the Upper Transmissive Unit (UTU). Additional
downgradient monitoring will be provided by installing a well near HEX-14S to
monitor the MTU. Natural processes will be relied on to attenuate benzene
concentrations. These include biodegradation and dispersion.
14.1.2.3 Area with PCE Detections: Alternative 2 involves further refinement and
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monitoring of the lateral extent of the area wherePCE has been detected, and deed ..
restrictions on groundwater use. Delineation of the lateral extent of the area where
PCE has been detected will require access to properties to the west and northwest
of the Hexcel Plant for sampling using the Hydro Punch or similar sampling
technology. Monitoring will. require installation of off-site monitoring wells.
Additional soil sampling will be performed in the vicinity of the Rose Garden in
an attempt to locate the source of the PCE.
14.1.2.4 Other Actions: Existing monitoring wells that are not essential for
monitoring the progress of the remedial actions will be retained and used for
groundwater level measurements only. These wells include: HEX-16S, HEX-17S,
and HEX-18S. Chemical sampling of these wells will be discontinued unless
groundwater flow patterns indicate that they are located in positions downgradient
from known areas of contamination.
14.1.2.5 Contaminated soils generated during the RI and currently stored in drums
on-site will be treated by soil venting on the surface, if necessary, to' reduce
concentrations to meet Federal and State land disposal restrictions. The soil
venting will be performed in a manner to contain and treat all off-gas to meet Bay
Area Air Quality Management District requirements. The treated soils will then
be disposed of in an appropriate land fill. Ninety-five 55-gallon drums of soils are
currently present on Site. Of these, 65 (approximately 12 cubic yards) may
potentially contain soils with concentrations of organic compounds that require
treatment. .
14.1.2.6 Drummed development and purge water currently stored on-site will be
pretreated, if neceswy, and discharged directly to the industrial sewer. The
volume of drummed water is about 600 gallons.
14.1.3 Alternative 3: Source Removal by In Situ
Treatment
Alternative 3 consists of the monitoring and remedial design components of
Alternative 2 coupled with removal of on-site sources of COCs by in situ treatment
technologies (note: removal does not imply complete removal to background of COCs,
rather a reduction in concentrations). It does not include the deed restrictions on
groundwater use contained in Alternative 2. It contains the same provisions for
treatment and disposal of drummed soil and water as Alternative 2.
14.1.3.1 BIde. 19 Area: Alternative 3 consists of removing sources of organic
compounds (acetone, MEK, and benzene) by in situ vapor extraction, soil aeration,
and sparging to enhance aerobic biodegradation. This process will oxygenate the
soil above. the water table thus stimulating biodegradation by indigenous
microorganisms of the organic COCs in the UTU. The process will also enhance
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..
oxygen transfer to the saturated upper transmissive unit and further promote
biodegradation. In the course of oxygenating the soils, the oxygen content of
shallow groundwater will also be increased and concentrations of organic
compounds of organic COCs will be decreased by aerobic biodegradation.
14.1.3.1.1 The process is also expected to lower arsenic concentrations by
precipitating barium arsenate, by reducing the potential for organic
complexation and promoting sorption and co-precipitation of arsenic with ferric
and manganese hydroxides.
14.1.3.1.2 Natural attenuation will. be relied on to reduce benzene
concentrations in the MTU. Partial dewatering of the UTU. may be required
during wet portions of the year. If dewatering is performed, the water will be
pretreated, if necessary, and discharged to the industrial sewer under Hexcel's
existing industrial discharge permit.
14.1.3.1.3 Implementation of Alternative 3 will involve additional soil
sampling to target the area of remediation and a soil venting pilot test. Off-gas
treatment will be achieved by passing the gas through vapor-phase activated
carbon. If the area of soil requiring remediation is found to be sufficiently
small, excavation and on-site treatment with surface soil venting will also be
considered.
14.1.3.2 Petroleum Rydrocarbon Area: Alternative 3 in the Petroleum
Hydrocarbon Area will consist of in situ bioremediation and air sparging or flow
enhancement to remove benzene and associated aromatic compounds, acetone, and
MEK. Alternative 3 also includes installation of additional monitoring wells
completed in the MTU. Implementation of Alternative 3 will involve additional
soil sampling during the remedial design phase to target the area of remediation and
a pilot test. Off-gas treatment will be achieved by passing the gas through vapor
phase activated carbon. .
14.1.3.2.1 The COCs are currently present in saturated, low-permeability
sediments below the water. table where they are not readily accessible to
removal by conventional groundwater pumping or vapor extraction techniques.
The in-situ techniques proposed in Alternative 3 are designed to physically and
biologically remove benzene, acetone, and MEK from the low permeability
sediments.
14.1.3.2.2 The in-situ technique involves injecting air into the MTU beneath
the silty clay and creating an "air-pocket" beneath the clay. This air pocket
will provide oxygen to degrade organic COCs in the MTU and will result in
a flow of air up through the low permeability unit. The air flowing through
contaminated, low permeability sediment will help in displacing non-aqueous
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phase liquid hydrocarbons upward, vapor extract volatile hydrocarbons, such
as benzene and, more importantly, provide oxygen for in-situ biodegradation.
14.1.3.2.3 The final design of the in-situ technique would be based on pilot
tests and additional design studies.
14.1.3.3 Area with PCE Detections: Alternative 3 provides for source reduction
by in-situ techniques along with the further investigation and remedial design
described for Alternative 2. Groun(jwater quality in the off-site portion of the area
where PCE has been detected will be monitored and natural processes, such as
biodegradation, chemical. degradation, and dispersion, relied on to attenuate
concentrations. Implementation of Alternative 3 will involve additional soil
sampling to target the area of remediation and pilot testing. Off-gas treatment wilt'
be achieved by passing the gas through vapor phase activated carbon. The source
area will be located. If it is found to be in the unsaturated sediments above the
water table, the source will be removed by vapor extraction. If the source is below
the water table, it will be removed by sparging in a manner similar to that for the
Petroleum Hydrocarbon Area.
14.1.4 Alternative 4: Source Removal and Capture of Groundwater Containin~ PCE
14.1.4.1 Alternative 4 consists. of the same in-situ technologies for source removal
as Alternative 3 with the addition of groundwater pumping to capture groundwater
containing PCE during the period of remediation. It also includes the monitoring
and further investigation components of Alternative 2. Calculations in the FS
indicate that as little as 3 gpm would need to be pumped to capture groundwater
containing PCE in the area. where it has been detected.
14.1.4.2 Water pumped from the PCE-affected zone would be treated to the extent
. necessary to comply with the discharge requirements of the Livermore P01W.
Final design of the pumping system would be based on delineation of the source
and construction of a numerical groundwater flow model that accounts for
variations in sediment structure and permeability.
14.1.5 Alternative 5: Recovery Pumpine of On-site Sources
14.1.5.1 Alternative 5 relies on groundwater pumping to contain chemicals on the
Hexcel property and to reduce source area concentrations. Water pumped from
affected zones would be treated to the extent necessary to comply with the
discharge requirements of the Livermore P01W. Calculations in the FS indicate
that capture of the sources can be achieved by pumping as little as 2.5 gpm. Water
from the capture wells would be treated to the extent necessary to meet discharge
requirements to the industrial sewer. Additional treatment would consist of
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air-stripping with off-gas treatment by vapor phase carbon.
14.1.6 Alternative 6: Containment Pumpine of On-site Sources and Off-site
Groundwater Containine PCE
14.1.6.1 Alternative 6 relies on groundwater pumping to control the off-site
migration of PCE and to reduce source area concentrations in the same manner as
Alternative 5. Water pumped from affected zones would be treated to the extent
necessary to comply with the industrial discharge requirements of the Livermore
P01W.
14.1.6.2 Calculations presented in the FS indicate that control of both on-site
sources and off-site migration of PCE can be achieved by pumping eight wells at
a total rate of 4.5 gpm. Capture of the off-site groundwater containing PCE is
accomplished by pumping on the northern boundary of the HMP OU.
14.2 ADS OU
One alternative was developed in addition to the No Action Alternative.
14.2.1 Alternative I: No Action
Alternative 1 is no remedial action and no monitoring. In essence, this alternative
implies that the only change in soil and groundwater concentrations from current
conditions will be as a result of natural processes and human activities, such as
remedial pumping at the Intel Fab m facility, that are outside of the control of
current property owners.
14.2.2 Alternative 2: Monitorine/Reeradine/Deed Notification
Alternative 2 consists of monitoring of groundwater concentrations of hazardous
constituents. It also provides for monitoring of subsurface methane concentrations
and methane concentrations in any structure built in the future on the ADS au.
It includes a contingency for additional methane control measures, such as passive
barriers or active recovery, if the need for such measures is indicated by the
monitoring results. It also provides for a deed notification requiring any owner of
the ADS au to contact the Regional Water Quality Control, the Integrated Waste
Management Board, and the City of Livermore Planning and Zoning Department
prior to undertaking any activities that might encounter buried hazards. In
addition, it includes a provision for regrading the surface to prevent ponding and
excess infiltration through the cover.
14.2.2.1 Monitorine: Groundwater concentrations of hazardous organic and
inorganic compounds and soil methane concentrations will be monitored. The
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groundwater monitoring network consists of existing wells. Well P-IOB has been
free of groundwater contamination since it was installed during the RI and is not
needed for water elevation monitoring. It will be properly abandoned. Methane
monitoring will be required for any new structure built on the ADS OU.
14.2.2.2 Deed Notification: The deed notification will require any owner of the
ADS OU to contact the Regional Water Quality Control Board, the Integrated
Waste Management Board, and the City of Livermore Planning and Zoning
Department prior to undertaking any activities that might encounter buried hazards
or change of post-closure land use.
14.2.2.3 Ree:radine: A closed depression exists in the central portion of the solid
waste area. . Runoff accumulates in this area and in a few other shallow
depressions; most of the runoff evaporates. The ADS OU will be regraded to
prevent ponding and reduce infiltration. This regrading will involve approximately
6,000 yd.30ffill in the central depression and an additional 3,000 yd.3 to bring the
rest of the ADS OU to grade. All of the fill can probably be obtained from the
former railroad bed on the north edge of the landfill. The properties of the on-site
fill will be tested and this presumption verified. The flII will be compacted.
15. SummaQ' of Evaluation Criteria
This section summarizes the evaluation criteria developed by EPA and used to compare the
alternatives in the RI and FS Reports for the two Ous. The alternatives were evaluated in detail
with respect to the nine criteria in the RIfFS Reports. Each alternative was also evaluated with
respect to the six state law criteria set forth in Section 25356.1 of the California Health and
Safety Code. A comparative analysis was completed in the RIfFS reports.
15.1 Overall Protection of Human Health and the Environment This criterion addresses
whether a remedy provides adequate protection of human health and the environment.
15.2 Compliance with applicable or relevant and appropriate requirements (ARARs). This
criterion addresses whether a remedy will meet all of the ARARs.
15.3 Lone-term Effectiveness and Permanence This criterion refers to expected residual
risk and residual chemical concentrations after cleanup goals have been met and the ability
of a remedy to maintain reliable protection of human health and the environment over time.
15.4 Reduction of toxicity. mobmty or volume through treatment This criterion refers to
the anticipated performance of the treatment technologies a remedy may employ.
15.5 Shon-term effectiveness This criterion addresses the period of time needed to achieve
cleanup and any adverse impacts on human health and the environment that may be posed
during the construction and implementation period, until cleanup goals are achieved.
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15.6 Implementability This criterion refers to the technical and administrative feasibility
of a remedy.
15.7 CSW This criterion includes estimated capital and operation and maintenance, usually
presented in a 3O-year present worth format..
15.8 Aeency Acce,ptance This criterion addresses the agencies' acceptance of the selected
remedy and any other agency comments.
15.9 Community Acce,ptance This criterion summarizes the public's general response to
the alternatives.
16. Remedy Selection Rationale and Statutory Determinations
16.1 HMP OU
16.1.1 The alternatives evaluated in the FS for the HMP OU consisted of varying
levels of soil treatment and groundwater monitoring with capture and/or treatment
measures as necessary. The rationale for remedy selection is to protect human health
and the environment. The selected remedy meets these criteria. Soil will be
remediated so as to minimize leaching of chemicals to groundwater. The selected
remedy complies with ARARs. In accordance with CERCLA i 121,42 USCA i 9621,
and the National Contingency Plan, 40 CFR Part 300, DTSC will waive any federal or
state permitting requirements for the treatment, storage, and disposal of hazardous
wastes that might otherwise apply to the activities contemplated as part of the approved
remediation. .
16.1.2 Each of the alternatives for the HMP OU was evaluated in terms of the nine
criteria listed in Paragraph 15 and the six State criteria set forth in Section 25356.1 of
the HSC. The costs of the remedial alternatives (except no-action) range from 1.2 to
2.2 million dollars. Based on the evaluation, Alternative 4 achieves all of the remedial
goals in a timely manner. Alternative 6 also achieves the remedial goals, although in
a longer time frame and is the most expensive. Alternatives 2, 3, and 5 will eventually
achieve remedial goals but on a much longer time frame than Alternatives 4 and 6.
Alternative 4 was selected because it reduces source concentrations in a timely manner,
. captures the off-site groundwater containing PCE, and is more cost-effective than
Alternative 6.
16.2 ADS OU
16.2.1 The alternatives evaluated in the FS for the ADS au consisted of no action and
monitoring/regrading/deed notification. The rationale for remedy solution is to protect
human health and the environment. The selected remedy meets these criteria. The
selected remedy complies with ARARs and is consistent with EP A guidance in selecting
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remedies for waste disposal units.
16.2.2 Each of the alternatives for the ADS au was evaluated in terms of the nine
criteria listed in Paragraph 15 and the six State criteria set forth in Section 25356.1 of
the HSC. The cost of Alternative 2 is about 1 million dollars. Based on the
evaluation, Alternative 2 achieves all of the remedial goals in a timely manner.
Alternative 2 was selected because it accomplishes the remedial goals in a cost-effective
manner. .
. 16.2.3 Compliance with ChCij)ter 15. Division 3. Title 23 of the California Code of
. Regulations.
16.2.3.1 Regulatory Status The ADS QU was an unregulated, non-classified,
disposal site as described in the Remedial Investigation Report. A Report of Waste
Discharge has not been submitted to the Board. The ADS au has not previously
met necessary Board requirements or received permits for construction, operation
or closure pursuant to the policies of the Porter-Cologne Water Quality Control Act
(Division 7, commencing with WC Section 13(00), Title 23, CCR, Chapter 15 and
Title 14, CCR, Division 7.
16:2.3.2 Site Characteristics The characterization of the contents of the ADS au
as presented in the Remedial Investigation Report and the Feasibility Study meets
the definition of a nonhazardous solid waste. Actions taken pursuant to Chapter
15 shall comply with the requirements for a Class III waste management unit to the
extent feasible.
16.2.3.3 ~ The existing cOver over the ADS QU was constructed or placed
at different times and no available record exists of when this work was performed
(p. H-ll, Remedial Investigation Report). The discharger believes that waste
disposal ceased in 1979 and the existing cover was placed prior to April 1980. In
1989 additional soil was imported to raise existing grade in the eastern pprtion of
the ADS QU. .
16.2.3.4 Groundwater Monitorine The existing ADS QU is unlined and without
a ]eachate coUection and removal system. Existing conditions are such that there
is less than 5 feet separation between the bottom of the waste and the highest
anticipated groundwater elevation. An adequate groundwater monitoring program
needs to be initiated pursuant to Section 251O(g) of Chapter 15. The monitoring
program shall be in accordance with Article 5 of Chapter 15 to the extent feasible.
If water quality impairment is detected and confirmed, additional portiones) of
Chapter 15 may be required by the Board.
16.2.3.5 Gradinl! and Drainaf:e The existing cover al]ows for ponding of surface
water in depressions resulting in percolation into the underlying waste. The
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average slope of the existing cover is 0.4%. There are no drainage ditches or
culverts over the ADS au or along its periphery (po H-12, Remedial Investigation
Report). Drainage from offsite sources needs to be directed around the ADS au.
The existing cover is inadequate with respect to grading (po H-12, Remedial
Investigation Report) and needs to be regraded and provided with adequate.surface
drainage systems. The ADS OU shall be graded and maintained to prevent
ponding, provide proper surface drainage, and divert surface drainage from covered
waste.
16.2.3.6 Financial Assurance An annual financial assurance letter that provides
sufficient assurance funds are available for annual costs of monitoring and
maintenance of the ADS OU will be required in order to assure that the ADS OU
will not pose an adverse threat to the environment.
17. THE SELECI'ED FINAL REMEDY
17.1
HMP OU
The selected remedial action for the HMP OU is the remedy identified and described as
"Alternative 4" in the FS and Regional Board's Proposed Plan Fact Sheet. Alternative 4,
as discussed. in detail in Finding 14.1.4., consists of removing sources of organic
compounds (acetone, MEK,and benzene) by in-situ vapor extraction, soil aeration; and
sparging to enhance aerobic biodegradation. The alternative would also include groundwater
pumping to capture groundwater containing PCE during the period of remediation,
monitoring and further delineation of the area where PCE has affected groundwater.
17.2
ADS OU
The selected remedial action for the ADS OU is the remedy identified and described as
"Alternative 2" in the FS and Regional Board's Proposed Plan Fact Sheet. Alternative 2,
as discussed in detail in Finding 14.2.2., consists of monitoring of groundwater for
hazardous constituents, monitoring of subsurface methane concentrations and a contingency
for additional methane control meaSures if necessary. It also provides for a deed
notification identifying areas with buried waste and regrading the surface to prevent ponding
and excess infiltration through the cover.
18. Deed Notifications
18.1
HMP au
A deed restriction shall be placed on the HMP OU restricting drilling of wells or 'use of
groundwater until such times that cleanup standards have been achieved. Wells related to
remedial activities shall be exempted from the restriction.
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18.2
ADS OU
A deed notification will be placed on the portion of the ADS OU that overlies the portion
of the ADS OU that potentially contains buried hazards. This deed notification will require
any owner of the property to contact the Board, the Integrated Waste Management Board,
and the City of Livermore Planning and Zoning Department prior to undertaking any
activities that might encounter buried hazards. .
19. CLEANUP STANDARDS
19.1
£Qil
The SRA did not identify chemical concentrations as posing a direct risk to human health.
SoiJ cleanup standards for total volatile organic compounds will not exceed 1 ppm.
19.2
Groundwater
The cleanup standards for groundwater are listed below:
19.3
o
Arsenic: 50 ppb (Cal DOHS MCL)
o
Benzene: 1 ppb (Cal DOHS MCL)
o
Tetrachloroethene: 5 ppb (Cal DOHS MCL)
o
Acetone: 770 ppb (US EPA PRG April 21, 1993)
Methyl Ethyl Ketone: 1,100 ppb (US EPA PRG April 21, 1993)
o
o
Barium: (Due to high background concentrations, barium will be monitored as part
of the remedy. The Cal DOHS MCL for barium is 1,000 ppb.) .
Risk Associated with Cleanup Standards
The SRA divided the groundwater chemicals of concern into carcinogens and
non-carcinogens. The SRA identified benzene as a carcinogen. The lifetime cancer risk
associated with the 1 ppb cleanup standard for benzene is 1 x 1~. IRIS identifies PCE as
a carcinogen and reports that the excess cancer risk associated with the 5 ppb MCL is
1.4 x 10-5. The SRA did not identify arsenic, barium, acetone, or MEK as carcinogens.
The non-carcinogenic hazard indices for chronic exposure to these constituents in drinking
water at concentrations equal to the cleanup standards are:
o
arsenic - 5
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o
barium - 0.4
o
acetone ~ I
o
methyl ethyl ketone - I
19.4. Uncertainty in AChievine Clean-up Standards
The cleanup standards set forth in this remedial action are intended to restore groundwater
to its beneficial uses. Based on information obtained during the RI and on a careful analysis
of all remedial alternatives, the Board believes that the selected remedies will achieve the
cleanup standards. However, studies suggest that in-situ remedial technologies and
groundwater extraction will not be, in all cases, completely successful in reducing
contaminants to health-based levels in the aquifer zones. The Board recognizes that
operation of the selected extraction and treatment system may indicate the technical
impracticability of reaching health-based groundwater quality standards using this approach.
If it becomes apparent, during implementation or operation of the system, that contaminant
levels have ceased to decline and are remaining constant at levels higher than the cleanup
standards, that standard and the remedy may be re-evaluated.
19.5. Future Chanees to Clean-up Standards
. The Board recognizes that a number of conditions may affect the performance of the in-situ
vapor extraction system and groundwater extraction system. These factors may include:
(1) the heterogeneity of the shallow and intermediate zones; (2) the transmissivity of the
aquifers; (3) the sustainable yield from the aquifers; (4) the adsorption of chemicals onto,
and the rate of desorption from, vadose and aquifer soils and aquitard materials; and (5) the
possible existence of sources in off-site areas, the precise location -of which cannot be
identified. The Board further recognizes that, as a result of these factors or other factors,
achievement of all the remedial standards set forth in this Order may not be practicable.
Consequently, this Order calls for periodic evaluation of the remedial standards and
. consideration of adjustment of the. remedial standards for portions or all of the Site if
achievement of such standards is no longer practicable.
If new information indicates clean-up standards cannot be attained or can be surpassed, the
Board and EPA will decide if further final clean-up actions, beyond those completed, shall
be implemented at this Site. If changes in published and adopted health criteria (Le.
MCLs), administrative requirements, Site conditions, or remediation efficiency occur, the
dischargers will submit an evaluation of the effects of these changes on clean-up standards.
The Board recognizes that the dischargers have already performed extensive investigative
and remedial work and are being ordered hereby to perform additional remedial tasks. It
. is in the public interest to have the dischargers undertake such remedial actions promptly
and without prolonged litigation or the expenditure of public funds. The Board recognizes
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that an important element in encouraging the dischargers to invest substantial resources in
undertaking such remedial . actions is to provide the dischargers with reasonable assurances
that the remedial actions called for in this Order will be the final remedial actions required
to be undertaken by the dischargers. On the other hand, the Board also recognizes its
responsibility to protect water quality, public health, and the environment and that future
developments could indicate that some additional remedial actions may be necessary.
The Board has considered and balanced these important considerations, and has determined
that the remedial actions ordered herein represent the Board's best, current judgment of the
remedial actions to be. required of the dischargers. The Board will not require the
dischargers to undertake additional remedial actions with respect to the matters previously
described herein unless: (1) conditions on the Site, previously unknown to the Board, are
discovered after adoption of this Order, or (2) new information is received by the Board,
in whole or in part after the date of this Order, and these previously unknown conditions
or this new information indicates that the remedial actions required in this Order may not
be protective of public health and the environment. The Board will also consider technical
practicality, cost-effectiveness, State Board Resolution No. 68-16 and other factors evaluated
by the Board in issuing this Order in determining whether such additional remedial actions
are appropriate and necessary.
20. DATA VALIDATION
Development of the Board's final remedy was based on the Board's evaluation of water quality
data.' Data has been validated using EP A validation guidance. The Board finds that there is
sufficient acceptable data to make cleanup decisions.
21. COMMUNITY RELATIONS
Community Relations activities conducted in conjunction with the FS/RAP have included the
following:
21.1 Distributing the Proposed Plan Fact Sheet to all addresses in the vicinity of the Site
and local government officials.
21.2 Placing the FS/RAP in the local information repository located in the Livermore
Public Library;
21.3 Publishing notices in the Valley Times and Tri-Valley Herald announcing the proposed
final RAP and opportunity for public comment at the Board hearing of July 21, 1993 in
Oaldand, and announcing the opportunity for public comment at an evening public meeting
at Jackson Elementary School, 554 Jackson Avenue, Livermore on July 22, 1993. A
presentation of the final cleanup plan was made at the July 21, 1993 Board public hearing
and the July 22, 1993 evening public meeting. The comment period was from July 12 to
August 12, 1993.
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22. ADMINISTRATIVE RECORD
The Administrative Record was prepared in accordance with EP A Guidance, has been made
available for public review and for review by interested parties, and provides full documentation
for the recommendations of staff and decisions by the Board. The record has been updated
periodically. Copies of significant reports and an index were available for public access at the
Livermore Public Library. The full Administrative Record is available for public access at the
office of the San Francisco Bay RWQCB.
23. POTENTIAL RESPONSffiLE PARTIES
23.1
HMP OU
23.1.1 Hexcel is identified as potentially responsible patty (pRP) under the federal
Superfund (CERCLA/SARA) for the HMP OU. However, nothing in these findings
or Order shall1imit any PRP's right and ability to identify other PRPs for the purposes
of cost recovery under any applicable laws.
23.2
ADS OU
23.2.1 Hexcel, the Smiths and F&P are identified as potentially responsible panies
(pRPs) under the federal Superfund (CERCLA/SARA) for the ADS OU. However,
nothing in these findings or Order sha11limit any PRP's right and ability to identify
other PRPs for the purposes of cost recovery under any applicable laws.
24. LEAD AGENCY
Pursuant to the South Bay Multi-Site Cooperative Agreement and the South Bay Ground Water
Contamination Enforcement Agreement, entered into on May 2, 1985 (as subsequently amended)
by the Board, EPA and DTSC, the Board has been acting as the lead agency for the Site. EPA
is expected to agree with the selected remedy and issue a Record of Decision following adoption
by the Board of the final remedy for the Site. The Board will continue as appropriate to regulate
the dischargers' remediation and administer enforcement actions in accordance with CERCLA,
as amended by SARA, the California Water Code, Health and Safety Code, and regulations
adopted thereunder.
25. In 1989, the Regional Board adopted resolution #89-39 "Sources of Drinking Water" which
defines a groundwater basin as suitable or potentially suitable for ~omestic or municipal use
as that which; 1) has a total dissolved solids (TDS) content of less than 3,000 mg/l, and,
2) has a minimum transmissivity such that one well can pump at least 200 gallons a day.
The groundwater basin at the Site falls within this category.
26. The Board adopted a revised Water Quality Control Plan for the San Francisco Bay Basin
(Basin Plan) on December 17, 1986. The Basin Plan contains water quality objectives and
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benefiCial uses for the Amador-Livennore Valley and contiguous surface and ground waters.
27. The existing and potential beneficial uses of the groundwater underlying and adjacent to the
Site include: .
a. industrial process water supply;
b. industrial service water supply;
c. municipal and domestic water supply; and
d. agricultural water supply.
28. The existing and potential beneficial uses of Arroyo Seco include:
29.
30.
31. .
32.
33.
a. groundwater recharge;
b. recreation;
C. warm and cold fresh water habitat;
d. wildlife habitat; and
e. fish migration and spawning.
The Board's Resolution No. 88-160 encourages maximum feasible reuse of extracted
groundwater from remediation projects. The Board will consider the feasibility of
reclamation, reuse or discharge to a publicly owned treatment works (p01W) of
extracted groundwater.
The dischargers have caused or permitted, and threatens to cause or permit waste to be
discharged or deposited where it is or probably will be discharged to waters of the State
and creates or threatens to create a condition of pollution or nuisance.
This action is an order to enforce the laws and regulations administered by the Board.
This action is categorically exempt from the provisions of the CEQA pursuant to
Section 15321 of the Resources Agency Guidelines.
The Board has notified the dischargers and interested agencies and persons of its intent
under California Water Code Section 13304 to prescribe Site Cleanup Requirements for
the Site, and has provided them with the opportunity for a public hearing an~ an
opportunity to submit their written views and recommendations.
The Board, in a public meeting heard and considered all comments pertaining to the
Site.
IT IS HEREBY ORDERED, pursuant to Section 13304 of the California Water Code and
Section 25356.1 of the California Health and Safety Code, that the dischargers shall cleanup and
abate the effects described in the above findings as follows:
A.
PROHIBITIONS
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1. The discharge of wastes or hazardous materials in a manner which will degrade
water quality or adversely affect the beneficial uses of the waters of the State is
prohibited.
2. Further significant migration of pollutants through subsurface transpon to waters
of the State is prohibited.
3. Activities associated with the subsurface investigation and cleanup which will cause
significant adverse migration of pollutants are prohibited.
B. CLEANUP SPECIFIC A TlONS
1. The storage, handling; treatment or disposal of soil or groundwater con.taining
pollutants shall not create a nuisance as defined in SeCtion 13050(m) of the
California Water Code.
2. The dischargers shall conduct monitoring activities as outlined in the accepted
sampling plan, approved by the Executive Officer to define the current local
hydrogeologic conditions, and the lateral and vertical extent of soil and
groundwater pollution. Should monitoring results show evidence of pollutant
migration, additional characterization of pollutant extent may be required.
3. Pursuant to Water Code Section 13304(c), the dischargers are hereby notified that
the Board is entitled to and may seek reimbursement for all reasonable staff
oversight costs incurred relating to cleanup of waste on this Site, abating the effects
thereof, or taking other remedial action.
C.
PROVISIONS
1. The dischargers shall comply with this Order upon adoption and the dischargers
shall comply with the Prohibitions and Specifications described above, in accordance
with the following tasks and compliance time schedules:
1.1 HMP OU
TASK: REMEDIAL DESIGN AND REMEDIAL ACTION WORKPLAN
DUE DATE: November 1, 1993
a.
Description: The dischargers shall submit a workplan acceptable to the
Executive Officer containing an outline and a schedule for completion of all
elements of the selected remedy including but not limited to: the remedial
design, construction, operation and maintenance (O&M), and groundwater
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monitoring.
b.
TASK: PROPOSED DEED RESTRICTION
DUE DATE: NOVEMBER 30,1993
Description: . The dischargers shall submit a proposed deed restriction
acceptable to the Executive Officer. The restriction shall restrict use of
groundwater on the HMP OU property until cleanup standards are
accomplished. .
c.
TASK: DEED RESTRICTIONS RECORDATION
DUE DATE: 90 days after approval by the Executive Officer
of proposed deed restriction/notification (TASK b.)
Description: The Dischargers shall submit to the Board a copy of the
notarized and properly recorded deed restriction document for the HMP OU
as described in task (b).
d.
TASK: NON-BINDING ALLOCATION OF RESPONSIBILITY (NBAR)
DUE DATE: JANUARY 31, 1994
Description: The dischargers shall propose an NBAR acceptable to the
Executive Officer for the HMP OU.
1.2 ADS OU
The tasks for the ADS OU are pursuant to Title 23, CCR, Chapter 15 and Title 14,
CCR, Division 7 and are equivalent to the requirements for a Class III waste
management unit to the extent feasible.. .
a.
TASK: REMEDIAL DESIGN AND REMEDIAL ACTION WORKPLAN
. DUE DATE: November 1, 1993 .
Description: The dischargers shall submit a workplan acceptable to the
Executive Officer containing an outline and a schedule for completion of all
elements of the selected remedy including but not limited to: the remedial
design, construction, operation and maintenance (O&M). Elements of the
remedy such as the methane monitoring program, contingency plan for
methane migration, grading plan, and post-earthquake plan may be
submitted as individual documents or combined into the design,
construction, and O&M documents for the entire OU. A proposal for a
deed notification will be submitted. as a separate task under this Order.
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'g.
b.
TASK: FINANCIAL ASSURANCE
DUE DATE: November 1, 1994
Description: The discharger shall submit to this Board and to the California
Integrated Waste Management Board, an annual financial assurance letter
that provides sufficient assurance funds are available for annual costs of
monitoring and maintenance of the ADS OU.
c.
TASK: GROUNDWATER MONITORING PLAN.
DUE DATE: JANUARY 31,1994
Description: The discharger shall submit to the Board, for approval, an
adequate groundwater monitoring program pursuant to Article 5 of Chapter
15 to the extent feasible.
d.
TASK: PROPOSED DEED NOTIFICATION
DUE DATE: NOVEMBER 30, 1993
Description: The dischargers shall submit a proposed deed notification
acceptable to the Executive Officer. The notification shall notify all present
and future owners, tenants or other users of the ADS OU that a designated
the portion of the property overlies the landfill. The deed notification shall
require any owner, tenants or other user of the ADS OU to contact the
Board, the Integrated Waste Management Board, and the City of Livermore
Planning and Zoning Department prior to undertaking any activities that
might encounter buried hazards.
e.
TASK: DEED NOTIFICATION RECORDATION
DUE DATE: 90 days after approval of proposed deed
notification (TASK d.)
Description: The Dischargers shall submit to the Board a copy of the
notarized and properly recorded deed notification document for the ADS as
described in Task Cd). .
f.
TASK: PROPOSED DEED RESTRICTION
DUE DATE: NOVEMBER 30, 1993
Description: The dischargers shall submit a proposed deed restriction
acceptable to the Executive Officer. The restriction shall restrict use of
groundwater on the ADS OU property.
TASK: DEED RESTRICTIONS RECORDATION
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DUE DATE: 90 days after approval by the ~ecutive Officer
of proposed deed restriction (TASK f.)
Description: The Dischargers shall submit to the Board a. copy of the
notarized and properly recorded deed restriction document for the ADS as
described in Task (f).
h.
TASK: NON-BINDING ALLOCATION OF RESPONSIBILITY (NBAR)
DUE DATE: JANUARY 31, 1994
Description: The dischargers shall propose an NBAR acceptable to the
Executive Officer for the ADS OU. ..
2. The dischargers shall submit to the Regional Board acCeptable reports on
compliance with the requirements of this Order that contain descriptions and results
of work and analyses performed. It is not the Board's intent. to duplicate any
reports due under other Orders therefore any reports due concurrently under this
Order may be combined. These reports shall include those prescribed below:
2.1 The dischargers shall regularly submit reports to the Board on results of
groundwater monitoring. The reports shall be submitted in accordance with the
schedule set forth in the Remedial Design report and acceptable to the Executive
Officer. All compliance and monitoring reports shall include at least the following:
1)
Tabulated results of water quality sampling analyses for all
groundwater monitoring wells specified in the SAP, and updated
groundwater contour maps based on these results.
2)
A cumulative tabulation of all well construction details, water level
measurements and updated piezometric maps based on these results.
3)
Reference diagrams and maps including geologic cross sections
describing the hydrogeologic setting of the Site, and appropriately
scaled and detailed base maps showing the location of all groundwa-
ter monitoring wells and extraction wells, and identifying adjacent
facilities and structures.
3.
ON AN ANNUAL BASIS, technical reports on the progress of compliance
with all requirements of this Order shall be submitted to the Board,
commencing with the report due January 31, 1994, and covering the
previous year. Annual reports may include any monitoring reports due
concurrently. The progress reports shall include, but need not be limited to,
progress on the Site investigation and remedial actions, operation of final
remedial actions and/or systems, and the feasibility of meeting groundwater
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4.
5.
6.
7.
8.
9.
and soil cleanup standards.
If the dischargers may be delayed, interrupted or prevented from meeting
. one or more of the completion dates sPeCified in this Order, the dischargers
shall promptly notify the Executive Officer. If, for any reason, the
dischargers are unable to perform any activity or submit any document
within the time required under this Order, they may make a written request
for a specified extension of time. The extension request shall include a
justification for the delay, and shall be submitted in advance of the date on
which the activity is to be performed or the document is due. The Board
staff may propose an amendment to the Order and bring the matter to the
Board for consideration.
All technical plans, specifications, reports and documents shall be signed
by or stamped with the seal of a registered geologist, registered civil
engineer, or certified engineering geologist.
All samples shall be analyzed by State certified laboratories, or laboratories
accepted by the Board, using approved EPA methods for the type of
analysis to be performed. All laboratories or the consultant shall maintain
quality assurancel quality control records for Board review for a period of
six years.
The dischargers shall maintain in good working order, and operate, as
efficiently as possible, any facility or control system installed to achieve
compliance with the requirements of this Order.
Copies of all correspondence, reports,. and documents pertaining to
compliance with the requirements of this Order shall be provided to the
following agencies:
a.
b.
c.
d.
Regional Water Quality Control Board
Alameda County Flood Control District, Zone 7
City of Livermore
U.S. Environmental Protection Agency, Region IX, H-6-5
The dischargers shall permit the Board or its authorized representative, in
accordance with Section 13267(c) of the California Water Code:
a.
Entry upon premises in which any pollution sources exist, or may
potentially exist, or in which any required records are kept, which are
relevant to this Order.
Access to copy any records required to be kept under the terms and
conditions of this Order.
b.
32
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10.
11.
12.
13.
c.
Inspection of any monitoring equipment or methodology implemented in
response to this Order.
Sampling of any groundwater or soil as part of any investigation or
remedial action program undertaken by the dischargers.
d.
The dischargers shall file a report in a timely manner on any changes in
Site occupancy and ownership associated with the facility described in this
Order.
If any hazardous substance is discharged in or on any waters of the state,
or discharged and deposited where it is, or probably will be discharged in
or on any waters of the state, the dischargers shall report such discharge to
this Regional Board, at (510) 286-1255 on weekdays during office hours
from 8 a.m. to 5 p.m., and to the Office of Emergency Services at (800)
852-7550 during non-business hours. A written report shall be filed with the
Regional Board within five (5) working days and shall contain information
relative to: the nature of waste or pollutant, quantity involved, duration of
incident, cause of spill, Spill Prevention, Control, and Countermeasure Plan
(SPCC) in effect, if any, estimated size of affected area, nature of effect,
corrective measures that have been taken or planned, and a schedule of
these activities, and persons/agencies notified.
This Site Cleanup Order rescinds SCO 91-165.
The Board will review this Order periodically and may revise the require-
ments when necessary.
I, Steven R. Ritchie, Executive Officer, do hereby certify that the foregoing is a full, true and
correct copy of an Order adopted by the California Regional Water Quality Control Board, San
Francisco Bay Region, on September 15, 1993. .
.~
/ Steven R. Ritchie
Executive Officer
33
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...
..
..
"
..
..
HWY 580
..
" .
~<90
.. :rO
"
/
\
\
)
,
!
"
0-
lDOO'
I SITE LOCATION' MAP I
Figure 1 Site location map
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SUBJECT:
Discussion:
~ATE OF CALIFORNIA
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
EXECUI1VE SUMMARY
HEXCEL CORPORATION, DONALD AND SUZANNE SMI11I, AND F&P
PROPERTIFS, HEXCEL COMPOSITE MATERIALS MANUFACTURING PLANT,
(}IMP OU) AND ABANDONED DISPOSAL SITE (ADS OU), LIVERMORE, ALAMEDA
COUNTY - Responsiveness Summary, Proposed FinaJ RemediaJ Action Plan, Pursuant to
FederaJ and State Superfund Requirements.
Comments received during the public comment period, which opened on July 12 and closed on
August 12, 1993, include written and oraJ comments from the July 21 public hearing and July
22 community public meeting in Livermore. Comments were received from Hexcel, F&P
Properties, 10caJ residents, Tri-VaJley Cares and the City of Livermore. Some minor
modifications were made to the Tentative Order for clarification and/or correction in response
to the comments. No changes are proposed in the RemediaJ Action Plan.
Silmificant Comments and ResDonses Include the Followinl!:
o
Hexcel's comments requested minor language changes in the Board's Tentative Order
for both the HMP OU and the ADS au and objections to the applicability of Titles 14
and 23 CCR to the ADS OU. Tbese comments were considered and the issues resolved
with Hexcel for both the OUs. The plan still includes actions equivaJent to those
required for a Class ill site at the ADS OU, to the extent feasible.
o
The comments from F&P Properties, the current owner of the ADS OU, addressed only
the ADS OU. F&P Properties do not agree with the proposed plan and believe that the
plan and the FS are inadequate. They believe additionaJ investigation is required and
that additionaJ possible aJternatives should be considered such as removaJ of aJl or
portions of the waste. Agency review and response to F&P's comments finds that the
investigation has been adequate to define the threat and problem with some minor
supplementary investigation needed for finaJ design of remediation. Agency staff believe
the FS satisfactorily meets the requirements of the federaJ NCP and the CaJifornia state
law. The Agency aJso finds that containment of waste in place' is protective of the
public heaJth and the environment and that removaJ, partiaJ or whole, is too costly.
o
Comments from the City and 10caJ residents were generaJly favorable and reCommended
immediate implementation of the proposed plan for both the HMP OU and the ADS OU
and implementation of the ADS OU plan in the most timely manner in order that
construction may proceed on the North Mines Road overcrossing. We concur and
expect implementation of the proposed plan for both OUs in a timely manner.
o
Tri-VaJley Cares' comments, related to both OUs, concerned the inadequacy of the
investigative work and the need for more public involvement. Their additionaJ
comments for the ADS au stated that the proposed plan was not a cleanup action and
additionaJ remediation should be addressed. Agency review and response found the
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Attached :
I
I .
investigative work is adequate for the purpose of preparing the proposed final
remediation plans for both the OUs and that the proposed RAP will be protective of both
public health and the environment. Minor supplementary information will be developed
for the preparation of the remedial design and remedial action workplan. Monitoring
will be required to confirm compliance after implementation of the remediation. Public
involvement, although not as extensive as the larger Lawrence Livermore Laboratory
Superfund cleanup, met legal requirements.
Further discussion on the significant comments and responses to all comments have been
addressed in the attached Responsiveness Summary.
Responsiveness Summary
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RESPONSIVENESS SUMMARY
HEXCEL SUPERF1JND SITE
LIVERMORE, ALAMEDA COUNTY
THE FOLLOWING ARE COMMENTS RECEIVED AT TIlE JULY 22.1993 PUBLIC MEETING
COMMENTER 1: MS. DAY, REPRESENTING TRJ-VALLEY CARES
Ms. Day: my name is Judy Day, and I'm a co-founding member of Tri-
Valley Care, citizens against a radioactive environment in the valley. And I have lived in Livermore
with my.husband for 22 years. We raised our three children here and we have a vested interest in
the community. . We're very involved in community activities and we really are concerned about
what happens. Also my husband works at Hexcel and he's worked there for five years. So I have
kind of an extra concern for him.
One of the initial things I would like to say is that about a year ago I received a phone call, because
I was interested in this process, from the Water Quality Control Board, but then I didn't hear
anything again until about a week ago regarding this meeting, and I think that it wasn't very
expedient and there was a big lag in time.
One comment I also want to make before I read our official paper is that I have a questiori as to
why is Hexcel - I guess I'm just kind of a naturally questioning kind of person about certain things
- why they are so concerned about getting it - I understand they want to get it cleaned up right
now, but is there something possibly more than what we are being told, that is a possibility of
contamination at the site? That question just crossed my mind tonight.
I know at my husband's work they now have in the plant where he works they have a water cooler,
a water company, Alhambra, but initially they didn't. When he first started working there they
did in the office, but not in plant, and he wouldn't drink the water there because it was really bad,
he and several other people. And also someone, I don't know who it was, someone had told him
that the water that is piped in for the coffee is still piped through contaminated pipes into the plant.
Okay. These are questions that Tri-VaUey Cares in particular would like to submit: no. 1,. 1.1
Regarding the Hexcel plant clean-up, PCE contamination, we are concerned that the source point
of the contamination plume is still unknown. As I had mentioned
. 1.1 - Superscripts indicate comments, questions, and reference responses to follow.
before, this leaves open the possibility that there may be as yet undiscovered hot spots of PCE in
the soil or groundwater.
Additional source investigation is needed immediately, and ideally this should occur before the
record of decision is finalized as new findings could alter the clean-up strategy.
U Also we note that PCE is a sinker and that Hexcel and the regulatory agencies need to be certain
that the bottom of the contamination plume is adequately mapped. Thus a thorough vertical as well
as horizontal investigation is needed. 1.3 Questions we have include knowing the number of
monitoring wells in the region of the PCE plume and whether or not they are screened, and if so
at what intervals. 1..4 At what depth do the monitoring wells come up clean? 1..5 At what rate is the
1
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groundwater moving? U Does the proposed sparging clean-up proposal include a barrier approach
and adequate methods to guide the contaminated water to the sparging wells?
1.7 Regarding the ADS, the Abandoned Disposal Site, what contaminants has Hexcel analyzed for? .
The site should be analyzed for everything that Coast Manufacturing as well as Hexcel have used.
Further there's a need to analyze for breakdown products of materials used by both. For example,
at the ADS where explosives manufacturing had taken place, nitrates and nitroglycerine have been
Cound in soils and groundwater. 1.8 At a minimum the placement of a clay cap, not dirt, but a clay
cap and adequate trenching to prevent rain water from leaching through the disposal site should
be instituted, I.' and additional steps including some excavation may also be required.
1.10 Regar:ding the methane gas build-up problem here, adequate venting would be a must. We note
that neither of the proposed options, no action or monitoring, for the disposal site or abandoned
disposal site is a clean-up option. 1.11 Some remediation may be in order, and at a minimum this
should be addressed as a possibility in the Record of Decision.
These are our general comments pertaining to both sites. I.U More site investigation appears to be
needed. 1.13 Much improvement is needed to ensure an adequate level of public participation in the
clean-up decisions. At a minimum, information and contact with members of the interested public
needs to occur earlier in the process. The process needs to become a two-way street so that the
public has a meaningful say in decisions. .
I.I4Also workers need to be brought into the process. Their institutional memory is a key component
of site investigation and clean-up. Extra steps must be instituted to ensure their participation is safe
and doesn't become politicized. Perhaps confidential interviews of long time employees along with
a random sampling of workers could be conducted by agency personnel.
The clean-up time line contemplated here is 30 years. 1.I5How has that number been arrived at?
Will that be codined in the Record or Decision? 1.I'How will you ensure that the goal is met?
1.I7How will the public be involved? l.I'What published milestones will exist? 1.I'WiII there be mass
removal milestones which codify the treatment or a specific volume or contamination during a
specific period of time? Will there be contaminant milestones which will codify a specific reduction
in concentration or contaminants over time? l.2Ofr not, what guarantee does the public have that at
the end or 30 years the clean-up actually will be complete? 1.21 Are possible current sources and
practices that could pollute the site receiving adequate attention?
We note that in general groundwater remediation is a science still in its infancy. Therefore, we
suggest it could be beneficial to the development of improved clean-up techniques and technologies
if starr from the various sites around Livermore, along with relevant regulatory personnel, met on
a regular basis to share information and results. Such meetings would likely include Lawrence
Uvermore National Laboratory, Sandia National Laboratory, Hexcel and Intel, and could be
conducted.
And I just had one little host to add, and that is that I understand that there has never been a
successful water contamination clean-up accomplished. Thank you.
2
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- -~_.__. --. .--- - ..-. ~-
RESPONSE TO MS. DAY, REPRESENTING TRI-VALLEY CARES:
Note: The numbering system reflects superscript numbering of questions contained in the above text.
1.1
The proposed remedy for the PCE area of the HMP OU contains a component of investigation
which shall better define the extent and try to determine the source of the PCE. Should a source
of the PCE be discovered, removal of that source shall be evaluated and implemented, if
appropriate.
1.2
The investigation proposed as it component of the remedy and discussed in 1.1 above shall add
to the already existing data to more completely define the extent of PCE pollution.
1.3
The PCE area was defined using 6 monitoring wells and 7 bydropunch locations. This data is
listed below and their locations can be found in Figures 3.7 and 3~8 in the FS:
TABLE 1
Monitoring Well Location and Screen Interval
WELL NO.
HEX-13M
HEX-13S
HEX-14S
HEX-15S
HEX-12
Bl007 30 ft.
TOTAL DEPTH
50 ft.
'21.6 ft.
24.6 ft.
23.2 ft.
28.5 ft.
SCREEN INTERVAL HG UNIT
29.5-49.5 ft. MTU
16-21 ft. UTU
14-24 ft. UTU
18-23 ft. UTU
16-26 ft. UTU
15-25 ft. UTU
TABLE 2
Hydropunch Sampling Location and Interval
LOCATION
SCREEN INTERVAL HG UNIT
CPT-l 17-22 ft.
CPT -1 34-40 ft.
CPT-2 18-22.5 ft.
CPT-2 25-29.8 ft.
CPT-J 20.5-25.5 ft. MTU
CPT -4 21-26 ft.
CPT -4 28-30 ft.
CPT-5 21-26 ft.
CPT-5 27.3-29.3 ft. MTU
CPT -6 23-27 ft. UTU
CPT -6 35-40 ft. MTU
CPT-' 21-24 ft. UTU
CPT -, 35-40 ft. MTU
Legend for Tables Above:
HG UNIT = Hydrostratigraphic Unit
UTU = Upper Transmissive Unit
MTU = Middle Transmissive Unit
UTU
MTU
UTU
MTU
UTU
'MTU
UTU
3
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1.4
1.5
1.6
1.7
1.8
1.9
1.10
1.11
1.12
1.13
1.14
1.15
The vertical extent of the PCE has not been defined in detail. The plume appears to be limited
to a small area. The full vertical extent will be defined during the design of the remediation
system. .
The horizontal rate of groundwater movement at the site ranges from 12 to 60 feet/year
(horizontally), but varies over different areas of the site.
The proposed remedy for the PCE area includes groundwater pumping to prevent further
migration and draw the plume back toward the HMP au. This pumping shall also draw the
affected water into the zone of influence of the sparging wells.
Groundwater at the ADS au was analyzed for volatile organics, semi-volatile organics (both
priority pollutant and tentatively identified compounds), metals, total organic carbon, and major
inorganics (i.e. Na, Ca, nitrate, sulfate, etc.). The occurrence of nitrate in the water is attributed
to past agricultural practices in the area and not to breakdown of black powder or other explosive
products associated with Coast ManufactUring's processes. Nitroglycerine was never analyzed
for because it was never used at the site. No compounds that could be associated with breakdown
products of pentaethrytol tetranitrate were detected among the tentatively identified compounds.
The cover design for the landfill shall be equivalent to those required by Chapter 15, Div.3, Title
14 CCR.
Excavation of the ADS au was not considered necessary to achieve a protective remedy.
While significant methane is not expected, the proposed plan calls for methane monitoring with
a contingency plan for action to prevent offsite migration. The plan also calls for agency
approval, more specifically the Integrated Waste Management Board, for any change in post-
closure land use. This would allow for agency review and approval of any development plans
for the site. At this point it will be determined by the agency if additional methane monitoring
or collection is necessary, based on the development proposed.
At this point remediation of methane is not necessary to achieve protectiveness. Should
monitoring detect offsite migration, additional action may be required. Additionally, should site
use change (i.e. new construction) methane impacts and corrective measures must be evaluated.
Board staff believe that enough data exists to develop a proposed plan considering the threat and
magnitude of the site..
In the CERCLA process the public is made aware of activities via fact sheets and public meetings
such as the one to introduce the Proposed Plan. AJI comments received are considered and
addressed in the Responsiveness Summary which details comments and responses.
Board staff agree that in many cases past and present employees can playa key role in site
investigations. Their first hand knowledge of site and chemical use histories have been used by
both the agencies and the companies in determining releases on sites.
The cleanup time of 30 years is used to estimate in groundwater cleanup programs and to set
4
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1.16
1.17
1.18
1.19
1.20
1.21
baseline costs. Actual time may vary and in some cases it may be more and in others less. To
ensure the cleanup program is effective, yearly progress reports as well as comprehensive five
year reviews are required. Should the proposed plan not appear to be working, additional actions
may be taken.
To cease remediation, the cleanup standards adopted in the Board Order and the EPA Record of
Decision must be achieved. .
Public involvement was sought early in the development of the Community Relations Plan
(October 1991). An infonnation repository was established in the Livennore library in order to
. allow the public to review infonnation about the Site. Public comment usually occurs during the
public comment period such as this one. An documents submitted to the Board are considered
public infonnation and are open for review. In some cases members of the public or groups
routinely review the fues on specific projects to keep track of their progress.
The proposed milestones will be documented in the Remedial Design and Implementation reports
as well as the monitoring, annual summary reports and five year reviews (see also 1.15). These
are available for review at the Board offices in Oakland.
In the case of this specific site, there will be no milestone for mass removal during a designated
period of time. Evaluation of the progress of remediation shall be measured by a perfonnance
standard (Le. Cleanup Standards in the ROD). The reduction in concentration of the
contaminants of concern (COCs) in groundwater will be documented in the groundwater
monitoring reports. It is expected that most mass removal will take place within the first or
second year of operation.
Refer to 1.16 and 1.20.
Current chemical handling practices include proper handling and disposal (including recycling)
to prevent contamination. There is a chance as there would be in any chemical handling
operation that contamination could occur by an accidental discharge, but standard procedures
when followed should not cause a problem.
COMMENTER 2.: MR. HOENIG
Mr. Hoenig: yes, sir. My name is Clarence Hoenig. I live at SS8 Tyler in Livermore. I
would first like to say that Tri-Valley Cares does not speak ror me. I believe there has been an
adequate presentation to the public. I reel like I have been very well inrormed tonight. I also
believe, and rrom discussions with personnel here, that one or the standards which is one part per
billion in water which has been drunk by a person over seven years is an overly cautious standard,
and that rrom what I have heard tonight I believe the site has been well characterized. We certainly
don't need a day cap over the top or this thing to prevent rain water percolation. I think that's
overkill. I think it's that type or an attitude which has caused huge expenditures or money and
carpet money which is wasterul. I think we should characterize the site and that has been done.
I'd like to recommend to the Regional Water Quality Control Board, to EPA, to the rederal
gov~ment, that in all likelihood no rurther work needs to be done here, the site needs to be
identified so that any ruture utilization or the site, people are advised or what the problems are, and
S
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that somehow the two to three million dollars be given to some public cause ir "excel can't use the
money to orrset their second quarter loss. Thank you.
COMMENTER 3.: MR. Palesek
Mr. Palasek: Good evening, my name is Bob Palasek, I live on Sarah Court; which is about
a block north or here and two blocks east. And I estimate that's six or eight blocks, a third or a
mile, from the "excel property. I wish to thank the agency and Hexcel for doing what they are
doing and moving toward remediation or this problem and I have the rollowing comments: I have
lived in my house on Sarah Court for two years where I bought it new, and berore that I lived a
mile further east on Hazel Street for twelve years.
On still momings when I step outside to get the newspaper at 6:00 a.m. Often times once or twice
a month I can smell what I think is phenol in the air. I'm not absolutely sure it's phenol, but it
smells something like that and I wanted to pose a question. J.1Does the EPA Feel that there is no
hazard of out gassing from these waste sites and is that not a problem to me? 12 And is there a
possibility that this odor or phenol is coming from those sites? 3.3 And the related question is, is.
phenol hazardous? Does it subject me to respiratory problems or anything else?
the second comment I would like to make is to the audience to imagine intuitively what a part per
million or a part per bilfion means. And I think I have got a good intuitive model that I would like
to share. A part per million, you can imagine a kernel or com, something the size of a kernel or
com in the volume or the size or your washing machine. If you cut that kernel or com into ten
pieces, one or those pieces is 100 parts per billion. And if you cut that into fourths that's 25 parts
per billion. You can put that on your fingernail and still see it and still play with it. IC you put a
chemical in a volume or water the size of your washing machine in that amount, some chemicals you
can detect with taste and smell. People are capable of distinguishing that. There are stories or
moths that can detect chemicals or even a lesser concentration.
The fact that you can smell or taste those things means that there is a biological or chemical
reaction going on within you, and so even though you can say these seem like an awful small
amount, these things may be significant. Just to say that there's a small part or 25 parts per billion
is not enough. You have to go further and wonder what's toxic and what's not. That concludes
my comments. Thank you.
RESPONSE TO MR. PALASEK:
3.1
The out-gassing which would occur from a former landfall would generally consist of methane
which is generated by decomposition of the buried waste. The predominant hazard from the
methane occurs when it collects in structures built over a flJl without methane controls. In this
case methane might collect in the structures and at high concentration posing a potential threat
of explosion or suffocation. In many cases to construct over a fall would require methane
monitoring in the structure and/or possibly a methane coJlection system which would prevent
collection of the gas in the building.
3.2
Phenol was not one of the COCs identified at the site. The odors which you detect early some
mornings may be related to some other nearby industrial activity.
6
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3.3
Referencing the NIOSH Pocket Guide to Chemical Hazards, which should be available in the
public library, inhalation of phenol could cause eye; nose and throat irritation. The target organs
listed include skin, eyes, respiratory system, and central nervous system. For further information
on exposure routes etc., you might want to refer to the pocket guide referenced above.
COMMENTER 4.: MS. CARPLUK
Ms. Carpluk: I just want to say I'm happy you are here too and that something is finally
being done. As I said, I've been here for 28 years and all my neighbors really want to see that road
go through. My name is Diane Carpluk and I live at 1117 Roxanne Street and our tract has been
going down to Maple and over to First and back up for all these years and we are very anxious for
you to go ahead and get the study done and make the road through.
COMMENTER 5.: . MR. KING
Mr. King: I'm Don King. I live at 1020 Delores Street. I happened to be walking in the
area of Hextel today and I came up and came past two very large water tanks. . 5.1 I would like I
haven't heard anything about that this evening, but I suppose they're well, John Hines here has told
me they are Cal Water storage tanks which seems there is a well near there so that can't be very
far from the superfund site here. 5.2 So I would like to have some answer to that in further
investigation, some comments about whether there are wells there or if they are threatened at all
by this contaminated site?
RESPONSE TO MR. KING:
5.1
The two water tanks are used for storage of Cal Water. The water stored in these tanks is
imported water sold to Cal Water by Zone 7 of the Alameda County Water District.
5.2
According to Hexcel's studies the nearest well is 3600 feet upgradient.
THE FOLLOWING ARE COMMENTS SUBMITnm BY F&P:
August 12, 1993
Regional Water Quality Control Board Clerk
2101 Webster Street, Suite 500
Oakland, CA 94612
Re:
Proposed Revised Site Cleanup Order Rescinding Order No. 91-165
Hextel Feasibility Study
Hextel Superfund Site
Livermore, California
Prepared by Hydro Geo Chem, Inc.
7
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Dear SirlMadam:
This letter is submitted on behalf of F &P Properties who is the current owner of the ADS
OU referenced in the subject Final Draft FeasibiUty Study (FS) document. The following are F &P's
comments regarding the adequacy and contents of the FS and consequently, the Proposed Revised
Site Cleanup Order. Because F&P does not own any part of the lIMP OU, it has restricted its
comments to those portions of the Final Draft which deal with the ADS OU.
F &P purchased the property on which the ADS is located in 1985 from Donald" Suzanne
Smith. At the time of the purchase, F&P was advised by Hexcel that the ADS did not constitute
a problem 'to F&P's stated plans for the property and further that Hexcel would fully investigate
and remediate the ADS in accordance with the then pending schedule. Obviously, Hexcel did not
live up to its promise. Clearly, as evidenced by the Final Draft, Hexcel has attempted to leave the
impression that the problems presented by the ADS are minimal with the best solution to do
virtually nothing to eliminate the hazards presented by the waste which Hexcel placed in the ADS.
This non-solution is designed to push the cost of any errective solution into the future leaving
potential environmental risk for others to cope with in' perpetuity.
F&P points out in the following sections that the.minimal action proposed by Hexcel for the
ADS creates a fatal fiaw in the FS because:
(a) The study does not meet its own stated purpose;
(b) The study does not meet its own stated objectives;
(c) The alternatives selected do not meet the required threshold and balancing
criteria; and
The analysis contains errors and naws in' the facts and logic;
(d)
Based upon the foregoing, the FS should be rejected and returned to Hexcel for revisions
to the sections which deal with the 'ADS OU.
(A) The Studv Does Not Meet Its Own Stated PurDose
The FS states as its purpose "To evaluate' alternatives to final remediation of soil and
groundwater contamination." With respect to the ADS OU, the FS neither evaluates all available
alternatives for the remediation of known hazards at the ADS nor does it adequately review
measures which are designed to "finally" remediate the ADS. Rather, the FS focuses upon
monitoring which amount to virtually no action with respect to a final solution and ignores the data
which indicates the need for present action. The FS ignores potential changes in site use, potential
changes in the ambient conditions and even falls short in its analysis of identified substances such
as arsenic, acetone and others. An amended focus must be implemented directing attention toward
a final remediation measures rather than a simplistic wait and see approach.
(8) The Studv Does Not Meet Its Own Stated Obiectives
The stated objectives of the FS with respect to the ADS OU are to (1) reduce the
concentration of contaminants of concern (COC); (2) prevent explosive concentrations of methane;
and (3) limit contact with buried hazards. TheFS attempts to meet these objectives through
8
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suggested monitoring, gas collection and deed restrictions.
Methane
While the proposed gas monitoring may be adequate ror the present use, it does not
present a final solution due to the likelihood of changes in use of the property in the ruture. There
has not been adequate study of the errect or ruture uses on lateral gas migration which may indeed
be the largest threat. Of course, as the FS points out, lateral gas migration does not presently exist
at a level which presents a threat or explosion. However , if the proposed fill is placed over the ADS
thus reducing permeability to any degree, lateral migration will be increased, thus increasing the
hazard. The analysis does not meet the objective or "preventing explosive concentrations or
methane" unless all potential conditions are fully studied and addressed in a final complete design
which is then implemented.
Contaminants or Concern (COCs)
The proposed regrading and monitoring does not adequately address a final
remediation or the identified COC's. Regrading completely ignores other contaminants identified
in the ADS.
. The FS assumes, without analysis, that the proposed regrading will somehow reduce
subsurrace infiltration to a degree that COC migration will be eliminated or reduced to a level that
it is equivalent to a final solution. This speculation is unacceptable. The two COC's addressed on
the ADS OU are Arsenic and Barium. Although other significant substances such as acetone,
toluene, chyrsene and 1,2 dichloroethane (among others) have been identified and ignored,: this
discussion or COC's will be limited to Arsenic and Barium to remain consistent with the terms of
the FS.
Although Arsenic has been identified as having the highest hazard quotient, thus
representing the highest risk or harm, and further, despite the fact that Arsenjc was determined to
exist on the ADS in quantities significantly higher than the accepted safety levels, the FS proposes
to do nothing to eliminate that substance from the ADS. Proposed regrading, will not result in its
remediation. Monitoring will also not contribute to a final remediation. In fact, due to the
intermittent nature or monitoring, a significant change in the levels or migration or Arsenic may
not be detected until significant variances and thus harmful errects have occurred. Monitoring is
by its nature an after the fact action that is not proactive nor designecJ to meet the stated objective
or "Reducing" COC's. .
The FS identifies Barium as a COC but goes on to rationalize its presence as a
naturally occurring phenomenon. Buried in this logic, the FS points out that Barium concentrations
at the site which exceed accepted background levels are the result of waste at the site. The FS notes
that buried organic wastes and resins at the ADS have resulted in elevated barium concentrations.
Despite this admission, nothing is proposed to either reduce or finally remediate the elevated levels
or Barium at the ADS.
These will be discussed in a later section on how to reduce the existence or the source or the Arsenic.
9.
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Buried Hazards
The FS proposes to limit contact with buried hazards through the imposition of deed
\ restrictions. A deed restriction is nothing more than a notation filed away with the County
Recorder. While this note may be melul to lawyers, title companies, government agencies or others
similarly interested in abstract paperwork, such bureaucratic steps do nothing to prevent physical
encounters with the buried hazards. Investigatory drilling, digging holes, fence posts, sumps or
swimming pools in the vicinity all have risks associated with the buried hazards. It should be kept
in mind that the buried hazards are not limited to chunks of resins or possible degenerated
explosives, but also other unaddressed and more migratory substances such as BIS (2 ethylexyl)
phthalate, copper, nickel, zinc and acetone. .
While a deed restriction is not a bad idea, it clearly does nothing to finally remediate
or prevent someone from coming into contact with all of the varied hazards at the site.
(C)
The alternatives selected do not meet the reouired threshold and balancim! criteria
Threshold Criteria
The threshold criteria of overall protection of human health has not been met. For
example, monitoring will only advise those concerned after a problem has occurred. Hexcel has
clearly demonstrated that the time frame for action is extra ordinarily long. After a problem has
been identified, by the time Hexcel has studied, planned, and devoted resources to take any action,
significant harm to human health or property may have occurred. This is illustrated by the
proposal to leave unaddressed elevated levels of Arsenic, with the highest hazard quotient, in place
with the unfounded hope that regrading will somehow make it disappear. It is clear that Arsenic
exists, it is a threat to human health, Bnd nothing is proposed to be done to eliminate it.
Human health is left unprotected in other ways. The FS leaves unaddressed possible
changes in the ambient protection from unregulated activities at the ADS, and does not provide any
protection from substances identified such as acetone, toluene nickel, copper, zinc, 1, 2
dichloroethane and others.
The FS does not address all varieties of possible response actions. Of those available,
treatment, containment, diswsal and partial removal were left unaddressed. Became of the virtual
wait and see approach, human health is left Bt risk and the threshold criteria is not met. .
Balancine Test
The FS places inordinate weight upon cost and not enough weight on long-term
effectiveness and permanence or reduction of toxicity, mobility or volume.
Obviomly, there is a great disparity between the estimated cost of total removal and
the estimated cost of the suggested approach in the FS. While total removal of all of the ADS may
not be the most reasonable approach, the FS has apparently been focused upon the lowest cost
alternatives which also have the lowest chance to finally remediate the ADS. In order to meet the
stated purpose and objectives with respect to COC's and buried hazards, active not passive
measures are required. As we have already pointed out, treatment, containment partial removal
10
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. and disposal will all undoubtedly have higher costs than the passive proposal. However, the FS does
not address these approaches. Significantly, it is these solutions which are likely to result in meeting
the objectives.
The alternatives addressed in the FS do not achieve any response of long term
effectiveness or permanence.
The implementation of monitoring merely postpones, for further day, addressing the
origin of the risk. For example, no treatment process is analyzed for either COC's, buried hazards
or other identified materials at the ADS. There is no analysis of treatment, removal or containment
of reduced volumes of material which would result in a great reduction in risk to the community.
There is no question that the proposed measures are temporary in nature and thus completely
IIreversibie". There is no confirmed reduction in toxicity, mobility or volume from the measures
suggested and thus no weight can be given to that portion of the balancing criteria.
The short term effectiveness criteria was also inadequately analyzed. The effect of
the weight of the suggested overburden on the underlying ADS, the effect of water added to
moisture condition placed overburden or the permeability has not been analyzed. Further, the
possible toxicity or availability of the suggested fill source has not been reasonably investigated.
Finally, the effect upon schedule, community or workers has not been investigated
for measures directed toward final remediation. The effects referred to in the FS are of limited
imagination or inquiry in that they are no broader than those which would be experienced in any
routine construction activity on the project. Indeed, the City's proposed construction of an overpass
will on a comparative basis have an incrementally larger impact on the community and laborers
than anything suggested by the FS. Certainly the other uninvestigated, approaches would have a
lesser effect than the construction of the City's overpass.
As previously pointed out, there is a remarkable lack of analysis of implementability.
Certainly, the proposed limited measures are easily implemented. However, they have low
reliability; have no relevance to verification or ease of construction for they do not address any
direct action toward final remediation. Thus, little or no weight was given to implementability.
Because the balancing criteria have not been given appropriate weight, the FS should
not be accepted and must be redone. .
(D)
The analvsis contained within the FS contains errors and naws in its facts and lo~ic.
The following will highlight several serious flaws in the logic and facts contained in
the FS. While one may argue that the existence of anyone does not necessitate the rejection of the
FS, it is the existence of them collectively which should cause alarm with the reviewing agency
necessitating the rejection of the FS and generating a request for further work.
Arsenic
The FS reaches erroneous conclusions regarding arsenic due to a factual error
contained in its logic. The FS states at Page 49 that arsenic exceeds acceptable standards in the
ADS. It further concludes that its existence need not be of concern regarding the ADS because
11
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monitoring well P-8 is screened in the Middle Transmissive Unit and thus "may not be directly
affected by the presence of solid waste. Thus, excavation is not necessary to reduce chemical risks
at the ADS OU." (At Page 50) Upon closer review, this statement, is incorrect based upon Figure
4 which indicates the screening for monitoring well P-8 in the upper' Transmissive Unit. This
signincant difference voids the mnclusion in that the Upper Transmissive Unit is in closer proximity
to the solid waste and thus excavation or focused excavation and disposal or containment are
realistic alternatives.
Barium
The FS admits at Page 49 and elsewhere that Barium at the ADS exceeds acceptable
levels. It further concludes that the solid waste has it direct casual effect regarding Barium because
'of "reducing conditions associated with the presence of organic materials in the solid waste." (page
49) The FS does not address any final remediation of this errect through localized excavation,
treatment, containment or other direct methods. Rather, the FS inappropriately dismisses the
existence of Barium as allegedly within the acceptable background levels. 'This is incorrect based
upon Appendix A, Page A-30 which attributes Barium not only to organic waste but also to resins.
Methods to reduce barium such as introduction of oxygen into the substrate or removal of organics
as suggested on A-30 have not been analyzed.
Drillin2 Pattern
The FS admits that the ADS has not been fully investigated. This startling admission
calls into question the quality and thoroughness of the entire study. It is clear that the investigation
was careful not to explore the ADS perhaps for' the reason it may find material or quantities which
it would rather leave unaddressed. For example, Figure 4 illustrates the irregular and signincantly
disbursed drill pattern used. The referenced BSK investigation was not calculated to examine the
depth, breadth nor the range of issues which are required by the FS and thus may not be relied
upon for that purpose. We are unaware of any non intrusive testing such as electromagnetic,
seismic, ultrasound, or x-ray was used. Examination of additional non-intrusive or for that matter
intrusive testing should be investigated. .
InW
The FS refers to the innuence of the Intel pumping on present hydrological
conditions. There was no analysis performed regarding forecasted changes in hydrology after the
Intel pumping eeases or varies. Indeed, signincant changes in the existing hydrology which may
. effect volume, exposure pathways and thus transmissibility could take place. Asa result, the
signincance of the existing conclusions which deal with groundwater are flawed and should be
rejected or expanded.
Materials found but not anslned
The following materials were identified by the FS as located on the ADS OU but are
not analyzed in any respect nor are suggested remediation measures analyzed. They are:
1,2 Dichloroethane
Acetone
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Copper, Zinc and Nickel
Bis (2-ethylexyl) phthalate
Chyrsene
Toluene
The FS states at Page 23 that many volatile and semi-volatile compounds were found
in the water prior to the current round of sampling. There has been no analysis of these observed
deviations (Table 3.3 and 3.4) nor have there been explanations regarding proposed final
. remediation of the above substances.
If, as illustrated by the FS, there are large variances in the data then why is there
no analysis to reassure that the clearly observed materials will not reappear in the future. This
omission jeopardizes ones ability to rely on the FS as an analysis for final remediation.
Well Locations
The FS at page 47 concludes that offsite migration of COC was unlikely based upon
its review of OW-I. In addition to the previously mentioned concerns, the fact that no COC was
detected in OW-I in one sample in March of 1993 does not justify the conclusion stated that COC
migration does not exist and monitoring is sufficient. OW-I is not the only possible now path.
Additionally, variations may occur as seen in the data variation. The conclusion reached is
unsupported.
Buried Hazards
The FS refers to the possibility of the existence of PETN and other harmful waste
in the ADS although it has not been confirmed nor fully characterized. As stated, BSK's work
cannot be relied on for the purposes imd objectives defined in the FS. By admission insufficient
work has been done to address the true nature of the ADS particularly regarding PETN, (See Page
48)
Methane
Th.e FS states that methane gas exists in volumes which exceeds acceptable limits and
may risk explosion in confined areas. The FS also discusses the fact that lateral migration is limited
due to the vertical permeability. This does not reconcile with the suggestion to place additional fill
which the FS assumes is less permeable and if after analysis is indeed found to be may increase
lateral migration of methane. .
Further analysis of the effectiveness and necessity of vertical perimeter barriers must
be performed to coordinate the gas remediation with other proposed measures.
Excavation Remedial Action
The FS concludes that because its total estimated volume of the ADS OU is 136,000
C.Y. that excavation is not a USEPA preferred remedy. The FS, somewhat disingeniously argues,
because the "guidance document states that a volume of 100,000 C.Y. or less of waste can be
considered a hot spot" (page C.IS) that the ADS need not be excavated because its TOTAL volume
13
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exceeds the 100,000 C.Y. amount. This conclusion is illogical, If not ridiculous. The two values are
not comparable and the analysis exposes the intention to avoid any true action to remove or
remediate any part of the ADS. The FS does not analyze possible "Hot Spots" within the ADS. Nor
does the FS identify the volume of possible "Hot Spots". It is clear that something less than a total
excavation and removal program may significantly benefit the site and the public and therefore
must be analyzed. Because methods of excavation have been determined by the FS to be safe, they
must be considered in detail Including partial excavation. '
Conclusion
Based on the limited time to review in detail all of the material contained in the FS, F &P
orrers the foregoing as a partial listing of inadequacies of the FS. Based only on these, the FS as
written must be rejected with direction for further work addressing these problems.
Because of the natural errort by the prime PRP to reduce the amount of work required and
because of the obvious naws in the ADS OU materials, there should be a healthy skepticism toward
the#material for the lIMP QU. TIme does not be protected from sloppy, inadequate or incomplete
remediation. '
Finally, it is apparent throughout the FS that the proposed remedial action does not achieve
a level or standard of control at least equivalent to the ARAR. Any argument that Section 121(d)(4)
of CERCLA as amended by Sara enables CRWQCB to nevertheless accept the proposed remedial
action should be rejected. The reason is that the various condition which would permit such a
waiver do not exist. This is especially true since the proposed remedial action is not protective of
human health and the environment.
F &P further requests the CRWQCB to reject the proposed revised order pending completion
of the above.
RESPONSE TO F&P COMMENTS:
(A) The Study Does Not Meet Its Own Stated Pumose
The FS addresses the contaminants of concern (arsenic and barium) and the methane hazard
identified in the Screening Risk Assessment (SRA) prepared by EPA. Although other constituents were
they did not pose a threat due to their low concentration and/or limited frequency of detection.
(B) The Study Does Not Meet Its Own Stated Obiectives
The only contaminants of concern detected in groundwater at the ADS at concentrations above
the MCL were arsenic and barium. Arsenic was detected in only two wells (P-I and P-8). The arsenic
concentration in P-I was 16 uglL. The most recent sample from P-8 reported in the Quarterly Technical
Compliance Report for the second quarter of 1993 contained arsenic at a concentration of 21 uglL, less
than the MCL of 50 ugll. Arsenic was not detected in any downgradient monitoring wells at the lntel
Fab m facility. Barium was detected in P-I at a concentration of 1520 uglL, above the California
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~~~~-
'.. ..'
Department of Health Services MCL of 1,000 uglL but below the Federal MCL of 2,000 uglL. Barium
concentrations in downgradient wells were below both MCLs. Active remediation of barium in
groundwater and soils is not required.
Methane
The approaches to methane control presented in the FS are cOnsistent with those normally applied
to landfills. Methane concentrations in the subsurface present no immediate hazard under current site
conditions. The FS provides for methane monitoring to detect any off-site migration and active methane
control if necessary. Additional methane controls may be needed if structures are built on the ADS in
the future.
With regard to the proposed cover increasing the rate of lateral methane migration, that
contingency is addressed by monitoring and active control, if necessary.
Contaminants of Concern (COCs)
The SRA identified the following Contaminants of Concern (COCs): benzene, acetone, MEK,
tetrachloroethene (PCE), arsenic and barium. The COCS were identified for the Hexcel Superfund Site
as a whole based on their presence in groundwater. Benzene, MEK, and PCE were not detected in any
groundwater sample collected at the ADS OU during the RI or subsequent monitoring. Acetone was
detected in one sample from well P-11 at a concentration of 200 uglL, well below the cleanup standard
of 770 ug/J.
The occurrence of arsenic at the ADS OU was discussed previously. The highest concentration
of arsenic in groundwater was 51 uglL, only 1 uglL higher than the State and Federal MCL of 50 ug/l.
With regard to barium, the MCL in groundwater was exceeded in only one well at the ADS OU,
P-l. Barium concentrations did not exceed the MCL of 1,000 ug/l in any downgradient well.
The FS does not attribute elevated barium concentrations in groundwater to resins. Although
barium occurs above naturally occurring concentrations and may be associated with the presence of buried
organic matter, the fact remains that barium concentration onJy exceeded the MCL in one well on-site
and not in any downgradient wells.
Buried Hazards
The situation at the ADS OU is no different than that at other landfills with respect to future land
use. With regard to the hypothetical intrusive activities mentioned in the comment, investigatory drilling
was safely performed during the preparation of the Environmental Impact Report (EIR) performed for
F&P. Activities such as digging holes, installing fence posts and sumps are not likely to encounter buried
waste because the area of the landfill containing industrial solid waste is or will be covered with .
approximately 5 feet of clean fill. The scenario of installing a swimming pool is unrealistic because the
site is zoned industrial.
(C)
The alternatives selected do not meet the required threshold and balancinl! criteria
Threshold Criteria
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Once again, arsenic and barium each exceeded their respective cleanup goals in only one well.
There is currently no evidence to suggest an off-site plume of either constituent. With regard to the other
constituents mentioned in this comment (acetone, toluene, nickel, copper, zinc and 1,2 dichloroethane),
none of these were identified by EP A as occurring at concentrations that would pose a health risk. There
is no current human exposure and a deed restriction on well construction will prevent future exposures.
Balancinl!: Test
As discussed previously, the only risks identified by EPA at the ADS OU were the presence of
arsenic and barium in groundwater and the presence of methane in the subsurface soils. Arsenic and
barium each exceeded their respective cleanup goals in only one well. At the latest sampling, the arsenic
concentration in well P-8 was below State and federal MCL. Barium was not detected above the MCL
in any off-site well and there is no evidence that the presence of barium at the ADS OU poses a health
risk. The methane risk at the ADS au is. no different than that at other solid waste landfalls. It is
adequately addressed through monitoring and the contingency for active control. .No other materials have
been identified at the ADS that pose a risk and so no reduction in risk would be achieved through
removal or other treatment activities.
With regard to the effect of the regrading on the landfall, much of the site has already been
regraded by past and current owners without adverse effect on the environment. The current owners used
borrow from the former railroad berm to regrade the eastern two-thirds of the site.
Regarding the effect of the proposed remediation on the community, we concur with the comment
that they are no broader than any routine construction activity.
The FS presents analyses demonstrating regrading will accomplish the goal of reducing infiltration
to the landfill. Developing the details of the proposed remediation activities are properly deferred to the
Remedial DesignlRemediation Action stage of the project.
(0)
The analysis contained within the FS contains errors and flaws in its facts and 101!:ic.
Arsenic
As stated in the FS and described in detail in the RI Repon, well P-8 is screened in the Middle
Transmissive Unit. The confusion regarding well P-8 apparently originates from the fact that the
screened interval of P-8 was omitted from Figure 2.5 in'the FS Repon.
Barium
The occurrence of barium concentrations exceeding the state MCL is limited to one well, there
is no off-site plume, and remediation of barium is currently unnecessary.
Drillinl!: Pattern
Drilling activities during the RI were designed to investigate those ponions of the site not covered
by drilling and sampling performed during the EIR. The investigations performed during the EIR were
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designed to identify environmental risks associated with development of the site. (geophysical surveys
were performed as part of the EIR.. The RJ activities were designed to identify the health risks associated
with the site as it currently exists. The impacts and risks associated with the site were adequately
evaluated based on the results of both investigations. The EIR. can be relied upon to supplement the RI
activities.
~
The proposed remedy at the ADS au does not rely on continued pumping at the Intel Fab ill
facility. .
Materials found but not analyzed
The constituents listed in this comment were detected in soil and groundwater at concentrations
that were determined by the U.S. Environmental Protection Agency in the SRA as posing no significant
health risk.
Volatile and semi-volatile compounds detected in pre-RI groundwater sampling events were not
detected during the RI. Additionally, the concentrations of these constituents was also observed to be
decreasing during the pre-RI samplings.
Well Locations
The only constituent detected at both the ADS au and the Intel Fab ill was barium. Barium
concentrations at Intel were less than the California MCL of 1,000 ug/l.
Buried Hazards
Page 48 of the FS report states that the rumored presence of PETN in the subsurface at the ADS
au is unconfirmed, not that investigation has been inadequate.
Methane
The high concentrations of methane exist only within the limits of the ADS au. Should offsite
migration occur, it would then exceed acceptable liinits and a response action would be needed.
The fill placed on the portion of the site containing elevated methane concentrations will not
significantly affect lateral methane migration. Lateral methane migration will be monitored and
appropriate actions taken if adverse migration is detected.
Excavation Remedial Action
Based on data contained in the RJ Report, the SRA concluded that the only hazards at the ADS
au were methane in the subsurface and the detections of arsenic and barium in one well. No "hot-spots"
worthy of excavation are known to exist at the ADS au. Excavation to remove methane'sources at
landfills is not a standard engineering practice.
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COMMENTS SUBMITI ED BY HEXCEL:
July 20, 1993
(415) 393-2625
VIA FACSIMILE
Mark Johnson
CaIiCornia Regional Water Quality
Control Board
San Francisco Bay Region
2101 Webster Street, Suite 500
Oakland, CaIiCornia 94612
Revised Site Cleanup Requirements Cor Hexcel Corporation
10 Trevarno Road. livermore. Alameda Countv. and
Hexcel Corporation. Donald and Suzanne Smith and
F &P Properties. Abandoned Disposal Unit. North Mines
Road. Livermore. Alameda Countv
Dear Mr. Johnson:
We have reviewed the draft Order which contains the Revised Site Cleanup
Requirements for the Hexcel Composite Materials Manufacturing Plant Operable Unit ("lIMP OU")
and the Abandoned Disposal Site Operable Unit ("ADS OU") oC the "excel Superfund Site. From
our conversations, I know that you are aware of some of "excel's concerns about this draft Order.
In particular, "excel is concerned about the Board's specific task regarding evidence of financial
assurance (m Comment 14 below). In addition, "excel wants a provision in the Order for a
reevaluation of the requirements of the Order in the event that Hexcel prevails in its petition to the
U.S. Court of Appeals Cor the District of Columbia Circuit requesting removal oC the "excel
Superfund Site from the National Priorities Ust ("NPL") - Comment 1 below).
. Following are "excel's comments on the draft Order. As you will see, many of the
comments are designed to improve the accuracy or clarity oC the draCt Order.
1. "excel has filed a petition in the U.S. Court of Appeals for the District of
Columbia Circuit requesting that the "excel Superfund Site be removed from the NPL. "excel
requests that the following task be added to Paragraph 10 ("Regulatory Status of the Order") on
page 12:
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"10.3. Hexcel has filed a petition in the U.S. Court of Appeals for the District of
Columbia Circuit requesting that the Court order EPA to remove the Hexcel
Superfund Site from the NPL. Should Hexcel prevail in its petition, the Board will
review the requirements of this Order to detennine whether the requirements of this
Order are still appropriate and necessary for the Site."
2. Pages 1, 27-28. Hexcel requests that all references to Title 23 CCR and
Title 14 CCR (paragraph 1.2, page 1; B. CLEANUP SPECIFICATIONS, 4, page 27; and C.
PROVISIONS, 1.2, page 28) be deleted from the Order. Hexcel be6eves that neither Title 23, CCR,
Chapter 15, nor Title 14, CCR, Division 7 apply to the ADS au landfill because we have been
informed that the landfill was covered with clean fill in early 1980 ~, e.g., aerial photograph
dated April 30, 1980). ~ 23 CCR t 2510, 14 CCR It 17760, 18250, and 18280.)
As set forth in the Feasibility Study submitted to the Board on June 30, 1993,
Hexcel intends to perform groundwater monitoring, methane monitoring, and regrading at the ADS
OU landfill. In addition, Hexcel will prepare a deed notification for the property. Such tasks will
be performed in a manner agreed to by Hexcel and the Board.
3. Paragraph 1.1., page 1. We have not seen Figure 1, and therefore cannot
comment on its accuracy. We would appreciate receiving a copy of the Figure.
4. Paragraph 1.2, page 1. The fourth sentence of paragraph 1.2 ~hould be revised
as follows:
"The wastes may contain pollutants which under ambient environmental conditions
could be released at concentrations which might cause degradation of waters of the
State. " .
5. Paragraph 5.2, page 5. The last sentence of Paragraph 5.2 should be revised as
follows:
"The only runoff that leaves the ADS OU (which is covered by clean fill) and enters
Arroyo Seco is from the eastern portion of the ADS OU."
6. Paragraph 8.2.2, page 9. The following sentence should be added to the end of
Paragraph 8.2.2:
"Well P-14 has been sampled since June, 1992; no chloroform has been detected in
samples taken subsequent to June, 1992."
7. Paragraphs 14.1.3 through 14.1.6, pages 15-18. Remediation Alternatives 3,
4, 5, and 6 for the lIMP OU involve source reduction rather than source removal. All references
to source "removal" in the discussion of Alternatives 3, 4, S, and 6 should be changed to source
"reduction. "
8. Paragraph 14.2.2.2, pages 18-19. The last sentence of this Paragraph states:
liThe owner will be required to prepare a worker Health and Safety Plan and an Emergency
Response Contingency Plan governing the work to be performed." This sentence is not in the
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Feasibility Study and should be deleted from the Order. As stated in the Feasibility Study, any
owner of the ADS OU that plans to undertake any activities that might encounter buried hazards
will have to contact the Board, the Integrated Waste Management Board, and the City of Livermore
Planning and Zoning Department prior to undertaking any such activities.
9.
14.2.2.3, page 19. The fourth sentence of Paragraph 14.2.2.3 should be revised
as follows:
"In order to preserve future land use, the ADS OU will be regraded. "
10. Paragraph 17.1, page 11. The last sentence of this Paragraph currently reads:
"The alternative would also include groundwater pumping to capture groundwater containing PCE
during the period of remediation, monitoring and further delineation of the PCE plume." The
sentence should be changed to read as follows:
"The alternative would also include groundwater pumping to capture groundwater
containing PCE during the period of remediation, monitoring and further delineation
of the area where PCE has been detected."
11. Paragraph 18.1, page 11. The reference to uproperty" in this Paragraph
should be changed to "lIMP OU. U .
12. Pages 17-28. All references to the ADS OU landfill as a "Class II" unit should
be deleted from the Order. These references appear on page 17 under "B. Cleanup Specifications,
4," and on page 18 under "C. Provisions, 1.2." Both of these paragraphs are discussed in more
detail in Comment 1 above. However, if the Board insists on retaining these two paragraphs, they
should be rewritten to eliminate any reference to a "Class II" unit.
Hexcel does not believe it appropriate or necessary to classify the ADS OU landfill as
a Class II unit. The ADS OU should be referred to as an unclassified waste management" unit, or,
if the Board seeks to give the unit a classification, the unit should be classified as a Class III unit.
13. C. Provisions, 1.1 lIMP OU, Task d, page 28. Reference to "ADS OU" should
be changed to "lIMP OU."
14. C. Provisions, 1.2 ADS OU, Task b, page 29. Hexcel requests that this Task
be deleted from the Order because Hexcel is negotiating the acquisition of the ADS OU and will
request that the City of Livermore revise the subdivision map to include the ADS OU in Hexcel's
Composite Materials Manufacturing Plant property. Because the specific irrevocable trust fund
requirements of the regulation do not apply to the ADS OU ~ comment No.2 above), this task
should be removed from the Order.
IS. C. Provisions, 1.2 ADS OU, Task d, page 29. The word "restriction" should
be deleted from this task. At the ADS OU, as set out in the FS, a deed notification will be
established, not a deed restriction.
Hexcel appreciates your consideration of its comments and requested revisions to the
draft Order. Please call me if you have any questions. .
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'.
Very truly yours,
McCurCHEN, DOYLE, BROWN & ENERSEN
By
Kathryn V. Freistadt
August 2, 1993
ADDmONAL COMMENTS SUBMnTIill BY HEXCEL:
(415) 393-2625
VIA FACSIMILE
Steven Morse
California Regional Water
Quality Control Board
San Francisco Bay Region
2101 Webster Street, Suite 500
Oakland, CA 94612
Revised Site Cleanup Requirements for Hexcel Coq>oration
10 Trevamo Road. Livennore. Alameda County. and
Hexcel Cotooration. Donald and Suzanne Smith and
F&P PrQperties. Abandoned Disposal Unit. North Mines
Road. Livennore. Alameda County
Dear Mr. Morse:
We have reviewed the draft Site Cleanup Requirements Order (-Order-) that contains the
Revised Site Cleanup Requirements for the Hexcel Composite Materials Manufacturing Plant Operable
Unit ("HMP OUR) and the Abandoned Disposal Site Operable Unit (- ADS OU-) of the Hexcel Superfund
Site. On behalf of Hexcel Corp. rHexcel-) we submitted infonnal comments on the draft Order to Mark
Johnson of your office on July 20, 1993 (letter enclosed). On Tuesday, July 27, Bill Nosil of Hexcel and
I met with Patti Collins ofEPA and Mark Johnson to discuss Hexcel's comments. Mr. Johnson and Ms.
Collins agreed with the majority of Hexcel's comments. With r~pect to Comments 2, 12, and 14 in our
July 20, 1993 letter, Mr. Johnson and Ms. Collins requested that Hexcel present to you in writing a
discussion of issues for your consideration before Hexcel meets with you to discuss them.
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This letter as well as our July 20, 1993 correspondence to Mark Johnson are intended to
present Hexcel's positions for the purposes of discussion with Board staff. Hexcel is not requesting that
the Staff or the Board formally respond to these comments. Regarding those comments for which a
satisfactory resolution among Board staff, EPA and Hexcel has not been reached by the time the public
comment period ends, Hexcel intends to submit formal comments to the Board for its consideration.
,
Following is a discussion of issues raised in Comments 2, 12, and 14 of our July 20, 1993
letter and suggested revisions to the provisions of the draft Order addressed in those comments. Please
refer to the attached July 20, 1993 letter for the substance of each comment. For your convenience, I
have also attached pages of the draft Order with handwritten revisions reflecting only the comments
discussed in this letter. I have not noted on the attached pages of the Order other revisions that we
suggested in other comments made in our July 20, 1993 letter.
1. Comment No.2 of July 20. 1993 letter to Mark Johnson.
Comment No.2 of our July 20, 1993 letter requested that all references to Title 23 CCR
and Title 14 CCR be deleted from the Order. Following is a discussion of each paragraph where such
references appear in the Order.
a. Para~lU'h 1.2. pa~e 1 of draft Order.
The last sentence of Paragraph 1.2 states:
The appropriate standards, to the extent feasible, as described in Chapter 15, Anicle 3,
Title 23 of the California Code of Regulations (Chapter 15) shall apply.
Title 23, CCR, Chapter 15 became effective on November 27, 1984. We understand that the ADS OU
landfill was covered in early 1980 and that no solid waste disposal occurred after it was covered.
Therefore, Title 23. CCR. Chapter 15. Ankle 3 does not apply to the ADS OU.
Thus, the last sentence of Paragraph 1.2 should be deleted. (See b. below for discussion
of the oneponion of Title 23, CCR, Chapter 15 which may apply to units that were closed, abandoned
or inactive on the effective date of the regulations.)
b. B. CLEANUP SPECIFICATIONS. 4. Da~e 27 of draft Order.
This specification begins with the following statement:
The remedial actions at the ADS OU shall implement applicable provisions of Chapter 15
to the extent feasible for a Class n waste management unit.
(See below under 2 for further discussion regarding classification of the ADS OU as a Class n unit.)
As noted above, Title 23, CCR, Chapter 15 became effective. after the ADS OU was
covered. The only provision of Title 23, CCR, Chapter 15 that may apply to the ADS OU landfill is
section 2510(g) which provides that persons responsible for discharges at units that are closed,
abandoned, or inactive on the effective date of the regulations "may" be required to develop and
implement groundwater monitoring in accordance with Anicle 5.
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-~~ ~~-=
. In preparing the final draft Feasibility Study for the ADS QU, Hexcel's consultants, Hydro
Geo Chern, working with staff from the Board and EP A agreed on groundwater monitOring and on the
groundwater monitoring netWork of wells which would be part of the preferred alternative for the ADS.
To establish groundwater sampling frequencies and protOcols, Hexcel will submit a proposed groundwater
monitoring program to the Board as part of its Remedial Design and Remedial Action Workplan. Given
that agreement has been reached on the groundwater monitOring well netWork and on the implementation
of groundwater monitoring as part of the preferred remedy, there is no need for the Board to require a
monitoring program under Article 5. Furthermore, Hexcel has worked cooperatively with the Board and
EPA staff and intends to continue to be cooperative in the future regarding matters relating to this site.
If, in the future the Board wishes to change the groundwater monitoring program, the Board can effect
such changes by modifying the Site Cleanup Requirements Order or by exercising its authority under
Section 2510(g). Thus, there is no need to state in the Order that the remedial action shall implement
provisions of Chapter 15, to the extent feasible. Hexcel believes that this approach best meets the mutual
interests of the parties. -
Therefore, Hexcel requests that B. CLEANUP SPECIFICATIONS 4, on page 27, be
deleted in its entirety.
c. C. PROVISIONS. 1.2 ADS OU.Da2e 28 of draft Order.
The introductory paragraph of C. PROVISIONS, 1.2 Am Ql! states:
The tasks for the ADS OU are pursuant to Title 23, CCR, Chapter 15 and Title 14, CCR,
Chapter 7 and are equivalent to the requirements for a Class II waste management unit.
~ below under 2 for further discussion regarding classification of the ADS QU as a Class II unit.)
As noted above, for the ADS QU, only a portion of the Chapter 15 regulations I!lU apply.
Because RWQCB Staff, EP A Staff, and Hexcel have reached agreement that groundwater monitoring will
be implemented at the ADS OU, there is no need for this statement regarding Chapter 15.
We do not believe that Title 14, CCR, Division 7 (we believe that the reference in the
Order to Chapter 7 is a typographical error; the reference should be to Division 7) applies to the ADS
OU landfill because we understand that it was covered in early 1980 and that no solid waste disposal has
occurred at the ADS OU landfill since it was covered. However, staff at the Integrated Waste
Management Board ("IWMB") have informed us that Articles 7.1 (sections 17601~17617) and 7.6
(sections 17701-17751) of Chapter 3 of Title 14, CCR, Division 7 apply, to the extent the sections are
relevant, to sites that bave been closed.
. For the reasons stated above, Hexcel's preference is that the Board delete the introductory
paragraph under C. PROVISIONS 1.~. If the Board will not delete the paragraph, it should
be revised as follows: "The tasks for tWrADS OU include tasks pursuant to Title 14, CCR, Division
7, sections 17601 - 17617 and sections 17701 - 17751, to the extent such sections are relevant to the ADS
QU."
2. Comment No. 12 of July 20. 1993 letter to Mark Johnson.
Comment No. 12 of our July 20, 1993 letter requested that references to the ADS OU
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landfill as a .Class n. unit on pages 27-28 of the Order be deleted.
As discussed above, the only sections of Title 14, CCR, Division 7 that arguably apply to
the ADS OU are sections 17601-17617 and 17701-17751, and the only section of Title 23, CCR, Chapter
15 that may apply to the ADS OU is section 251O(g) w~ich provides that persons responsible for
discharges at units that are closed, abandoned, or inactive on the effective date of the regulations may
be required to develop and implement groundwater monitoring in accordance with Article 5. None of
these sections refers to classes of units. Therefore, there is no need for the Board to classify the ADS
OU landfill. If the paragraphs on pages 27 and 28 that contain references to a .Class n. unit are deleted
as requested in lb. and lc. above, the reference to Class n will similarly be deleted. However, if the
Board does not delete those paragraphs, the ADS OU should be referred to as an .unclassified waste
management unit.. .
3. Comment No. 14 of July 20. 1993 letter to Mark Johnson.
Comment No. 14 of our July 20, 1993 letter requested that Task b (requiring financial
assurance) on page 29 be deleted from the Order.
Hexcel requests that the task regarding financial assurance for the ADS OU be deleted from
the Order. Were the Article 5 financial assurance requirement to be applicable to the ADS OU, it should
be noted that this financial assurance requirement applies only to "corrective action for all known or
reasonably foreseeable releases from the waste management unit." (23 CCR Section 2550.0(b» Hexcel
believes that this financial assurance requirement is unnecessary and unreasonable. First, as noted above,
Hexcel and Board staff have already agreed on groundwater monitoring and on the groundwater
monitoring network of wells which would be part of the preferred alternative for the ADS. To establish
groundwater sampling frequencies and protocols, Hexcel will submit a proposed groundwater monitoring
program to the Board as part of its Remedial Design and Remedial Action Workplan. Therefore, the
financial assurance requirement of Article 5 would not apply. Second, there is no known release and it
is not believed that in the future there will be any releases from the ADS OU landfill because new wastes
will not be disposed of at the landfill and the site will be graded and maintained with the runoff directed
to the Arroyo Seco. Finally, Hexcel is negotiating the acquisition of the ADS OU. Once the property
is acquired, Hexcel expects that the City of Livermore will revise the subdivision map to include the ADS
au in Hexcel's Composite Materials Manufacturing Plant property, providing reasonable assurance that
the site will be properly maintained.
For the reasons stated above, Hexcel requests that Task b regarding financial assurance
under 1.2 ADS OU on page 29 be deleted from the Order.
Bill NosH of Hexcel wants to meet with you to discuss these issues after you have had an
opportunity to review this letter. Because the public comment period is rapidly drawing to a close,
Hexcel requests a meeting during the first week of August.' We look forward to resolving these issues
to the satisfaction of the Board and Hexcel.
Very truly yours,
McCUTCHEN, DOYLE, BROWN & ENERSEN
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iOi...=..-'
By
Kathryn V. Freistadt
ADDmONAL COMMENTS SUB,"... I ED BY HEXCEL:
August 11, 1993
(415) 393-2625
VIA FACSIMILE AND U.S. MAIL
Steven Morse
California Regional Water
Quali~ConttoIBo~d
San Francisco Bay Region
2101 Webster Street, Suite 500
Oakland, CA 94612
Revised Site CleanuD Requirements for Hexcel COI:poration
10 Trevamo Road. Livermore. Alameda County. and
Hexcel Cor:poration. Donald and Suzanne Smith and
F&P Pro!>erties. Abandoned Disnosal Unit. North Mines
Road. Livermore. Alameda County
Dw Mr. Morse:
Hexcel had hoped to meet with you prior to the close of the public comment period to
resolve the issues raised in its informal comments submitted on July 20, 1993 to Mark Johnson and on
August 2, 1993 to you (copies of both letters enclosed). However, M~k Johnson has informed us that
you will not be able to meet with Hexcel until after the close of the public comment period.
Although Mr. Johnson and Ms. Collins of EPA agreed with the majori~ of Hexcel's
comments in its July 20, 1993 letter, we have not yet received a revised version of the draft Order
showing that those changes have been made. In addition, Hexcel has not been able to meet with you to
discuss the comments that Mr. Johnson and Ms. Collins deferred to you for your consideration.
Therefore, Hexcel wishes to inform you by this ttansmittalletter that it is submitting the comments made
in its wlier two letters (July 20 and August 2, 1993) as formal comments to the Board.
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Hexcellooks forward to meeting with you and your staff to resolve these comments at your
convenience. Please caU Mr. Nosi! or me if you have any questions.
Very truly yours,
McCUTCHEN, DOYLE, BROWN & ENERSEN
By
Kathryn V. Freistadt
Enclosures
cc: A. William Nosi!, Hexcel
Gary Walter, Goo Chem
Gregory Walker, RWQCB
Mark Johnson, RWQCB
Patti Collins, EP A, Region IX
bc: Mr. Strohbehn
RESPONSE TO HEXCEL COMMENTS:
Board staff have reviewed the comments presented by Hexcel in their letter of July 20 and August 2,
1993. The letter of July 20, 1993 states specific comments with reference to the Tentative Order (TO)
and the letter of August 2, 1993 clarifies the basis for the comment. Board staff concur with several of
the comments as they add clarity to the TO. To further clarify the TO some of the comments have been
slightly modified by Board and then incorporated. Below is a list of those comments which Board staff
concur: and have incorporated either word by word or with slight modification (the first number references
the comment in the July 20, 1993 letter and the second, the section(s) of the TO where it has been
incorporated):
Comment #1., Sec. 10.3; #4., Sec. 1.3; #S., Sec. 5.2;#6.,8.2.2; #7.,14.1.3 through 14.1.6;
#8.,14.2.2.2; #9.,14.2.2.3; #10.,17.1; #11.,18.1; #13., C. Provision 1.1, Task d.; #15., C. Provision,
1.2, Task d.
The following comments Board staff do not concur with and are responded to below:
Comment #2. Section 251O(g) of Chapter 15, Division 3, Title 23 CCR does apply to the ADS OU.
Section.2510(g) allows the Board to require groun~water monitoring pursuant to Article 5 of Chapter 15.
The Board may require that additional portions1l£::hapter 15 be implemented to the extent feasible,
should monitoring detect and confirm groundwateJiiDpairment.
Title 14, Division 7, Articles 7.1 and 7.6 are applicable for all disposal sites as defined in Section 40122
of the Public Resources Code. .
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Comment #12 Board staff have considered this comment and bave agreed not to formally classify the
unit as a Class n or ill waste management unit, but rather require that actions taken (Le. monitoring,
corrective actions, etc.) be equivalent to those of a Class ill site to the extent feasible.
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