PB95-964507
EPA/ROD/R09-95/137
July 1995
EPA Superfund
Record of Decision:
Hewlett-Packard,
620-640 Page Mill Road,
Palo Alto, CA
3/24/95
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RECORD OF DECISION
Hewlett-Packard 640 Page Mill Road Superfund Site
Palo Alto, California
EPA ID# CAD980884209
PART I - DECLARATION
Statement of Basis and Purpose
This Record of Decision (ROD) presents the selected remedial
action for the Hewlett-Packard 640 Page Mill Road Superfund site
(HP-640 PMR) in Palo Alto, California. This document was
developed in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), 42 U.S.C. § 9601 et seq., and, to the extent
practicable, in accordance with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300,
and the laws of the State of California. This decision is based
on the Administrative Record for the site. The Administrative
Record Index appended to this ROD identifies the documents upon
which the selection of the remedial action is based.
The State of California Regional Water Quality Control Board
(RWQCB) is the lead agency that has been responsible for
overseeing the Remedial Investigation and Feasibility Study
(RI/FS) for this site. The state has finalized its selection of
a remedial action for the site in the RWQCB Site Cleanup
Requirements (SCRs). With this Record of Decision, the U.S.
Environmental Protection Agency (EPA) selects and concurs with
the remedy chosen in the RWQCB SCRs. #
Assessment of the Site
Actual or threatened releases of hazardous substances from the
HP-640 PMR 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
Leaks from an underground waste .solvent storage tank resulted in
soil and groundwater contamination at the HP-640 PMR site.
Interim remedial measures included excavation and off-site
disposal between 1987 and 1992 of approximately 10,700 cubic
yards of soil; a soil vapor extraction and treatment system
beginning in April 1994; and extraction and treatment of
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groundwater for seven months in 1982 and again from 1987 to the
present.
These interim response actions addressed the principal threats at
the HP-640 PMR site, soil and groundwater contamination. The
final remedy addresses threats remaining after the interim
measures. The major components of the selected remedy include:
Continued operation of the existing 15-well soil vapor
extraction and treatment system at the HP-640 PMR site until
final cleanup standards are achieved
Expansion and continued operation of the current on-site and
off-site groundwater extraction system to capture and treat
contaminated groundwater until final cleanup standards are
achieved
- Long-term groundwater monitoring
- A deed restriction for the HP-640 PMR site prohibiting the
use of on-site groundwater until final cleanup standards are
achieved
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with federal and state requirements that
are legally applicable or relevant and appropriate (ARARs) to the
remedial action, and is cost effective. The selected remedy uses
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that\employ
treatment that reduces toxicity, mobility or volume as a
principal element.
Because this remedy will result in hazardous substances remaining
on-site, a review of the remedial action will be conducted every
five years after initiation of the final remedial action to
ensure that the remedy continues to provide protection of human
health and the environment.
John C. Wise Date
Deputy Regional Administrator
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PART II - DECISION SUMMARY
Hewlett-Packard 640 Page Mill Road Superfund Site
Palo Alto, California
A detailed analysis of the selected remedial action for the
HP-640 PMR site is contained in the SCRs adopted by the RWQCB on
September 21, 1994. The site information summarized below is
discussed fully in the final RI/FS report. EPA's Record of
Decision concurs with the state's action, and selects the
remedial action alternative proposed in the RWQCB SCRs without
change.
1. Site Name. Location and Description
The HP-640 PMR site is located in Palo Alto, California within
the Stanford Research Park, a light-industrial and research area
owned by Stanford University. Hewlett-Packard Company (HP)
manufactured gallium arsenide- and silicon-based semiconductors
at the property from 1962 until operations ceased in 1986. The
facility consisted of two main buildings (#10 and #11) and a
storage building. Both buildings have since been demolished and
the site redeveloped for an office building with an underground
garage.
Land use in the vicinity of the site is predominantly commercial
and industrial, with smaller areas of residential development.
The nearest residential areas are located approximately 1/8 mile
N/E of the facility. Five municipal backup supply wells drawing
from a deep aquifer are within three miles of the sitse, but are
not currently used. All of the City of Palo Alto drinking water
is supplied by the San Francisco Water Department's Hetch Hetchy
System.
The HP-640 PMR site is located near the western margin of the
Santa Clara Valley. They valley surface in this area is a gently
sloping alluvial plain that extends northeast from the foothills
to San Francisco Bay, located approximately three miles to the
northeast. The area is underlain by interbedded alluvial fan
deposits and fine-grained floodplain deposits.
Vegetation in the area is generally limited to landscaped areas
which incorporate non-native species of grasses, trees and
shrubs. Much of the area is covered by asphalt-paved roadways
and parking lots, concrete sidewalks, and buildings. Animal
species found in the area include small mammals and birds adapted
to an urban habitat.
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The only surface water in the vicinity of HP-640 PMR is Matadero
Creek, located to the east of the site. Matadero Creek is an
intermittent stream that originates near the Los Altos Hills and
flows in a northerly direction through the residential,
commercial and industrial areas of Palo Alto. The creek flows
within a natural channel northward to El Camino Real where creek
waters enter Matadero Canal, a concrete-lined channel. Matadero
Creek returns to its natural channel at the Bayshore Freeway. No
endangered species have been identified in the area.
2. Site History and Enforcement Activities
Volatile organic compounds (VOCs), semivolatile organics and
metals have been found in soil and groundwater at the HP-640 PMR
site. Site investigation began in 1981 after a leaking
1000-gallon underground solvent storage tank was discovered
between Building 11 and the storage building. Sources of metals
were found in Building 10, associated with acid neutralization
sumps, piping and operations areas in the building. The primary
contaminants detected at the site were trichloroethene (TCE);
1,1,l-trichloroethane (1,1,1-TCA); tetrachloroethene (PCE);
gallium; and arsenic.
The HP-640 PMR site was proposed to the EPA National Priorities
List (NPL) in June 1988 and was added to the NPL in February
1990. Since the listing, the groundwater contamination plume
emanating from the HP-640 PMR site was found to be commingled in
part with groundwater contamination plumes associated with other
potential sources beyond the HP-640 PMR facility boundaries.
This ROD addresses soil and groundwater contamination- found at
HP-640 PMR as well as the area-wide commingled groundwater
contamination.
Pursuant to the South Bay Multi-Site Cooperative Agreement and
the South Bay Groundwater Contamination Enforcement Agreement
entered into by the RWQCB, EPA and the California Department of
Toxic Substances Control (DTSC) (formerly the California
Department of Health Services (DHS)), the RWQCB has been acting
as lead regulatory agency for the site.
The RI/FS report was prepared jointly for the HP-640 PMR site, an
adjacent Varian Associates (Varian) facility at 601 California
Street and an HP facility at 395 Page Mill Road. The groundwater
portion of the RI/FS includes the area that has been designated
the California-Olive-Emerson (COE) Study Area. It is bounded by
California Avenue to the west, Olive Avenue to the east and
Emerson Street to the north. An adjacent area has been
designated the Perimeter Area, which extends from Olive Avenue
beyond Matadero Creek to the east (see Figure 1), and represents
the limits of the known groundwater contamination plume. It
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borders another Varian facility located at 611 Hansen Way. The
HP 395 Page Mill Road site and the Varian 601 California Street
site are regulated under the same RWQCB SCRs as the HP-640 PMR
site; the Varian 611 Hansen Way facility is regulated by DTSC.
Interim remedial measures (IRMs) have been conducted since 1982.
Soil excavations at the HP-640 PMR site between 1987 and 1992
removed approximately 7700 cubic yards of contaminated soil to
Class I landfills and approximately 3000 cubic yards to Class III
landfills. Additional areas of the, site were also excavated to
remove above-background concentrations of arsenic, gallium and
several other metals. Residual concentrations of VOCs at the
HP-640 PMR site are being addressed by a 15-well soil vapor
extraction system that went on-line in April 1994. Groundwater
remediation at HP-640 PMR was initiated in 1982 for seven months;
extraction was restarted in 1987 and has continued to the
present.
3. Highlights of Community Participation
Since 1989, five fact sheets have been released describing
activities at the HP-640 PMR site. The Barren Park Association
Foundation, an active community group in the area, has a
Technical Assistance Grant from EPA to assist the community in
reviewing technical documents regarding the investigation and
cleanup of the site. In July 1994 the RWQCB released a Proposed
Plan fact .sheet for the site that described the proposed remedy
for the site. Site documents were made available at the lead
agency office and a local repository, and a public notice was
published allowing 30 days for public comment on the RI/FS and
Proposed Plan. A public meeting was held on July 26, 1994 to
describe the proposed remedy and receive comments. Responses to
comments are found in the Responsiveness Summary appended to this
Record of Decision. The decision for this site is based upon the
Administrative Record prepared for the site and maintained at the
lead agency office.
4. Scope and Role of Remedial Actions
The remedial actions selected in this Record of Decision will be
the final response actions performed at the HP-640 PMR site. As
described earlier, significant IRMs were performed at the site in
the past. These actions addressed the principal threats at the
site. The selected remedy addresses the contaminants remaining
in soils and groundwater at the site.
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5. site Characteristics
The COE and Perimeter Areas are underlain by two primary
aquifers, the upper A Aquifer and the lower B Aquifer. Each of
these two aquifers contains distinct sand zones. The A Aquifer
extends up to 55 feet below ground surface, and groundwater is
first encountered at depths between 15 and 30 feet. Within the A
Aquifer, the Al Upper (A1U) Zone is generally found between
depths of 15 and 30 feet, the Al Zone between 30 and 40 feet, and
the A2 Zone between 40 and 55 feet. The fine-grained aquitards
separating the three zones range from one to 22 feet in thickness
and allow varying degrees of hydraulic communication. The
aquitard between the Al and A2 Zones is generally not present
west of Page Mill Road and beneath the 601 California site.
The aquitard between the A and B Aquifers is approximately 12 to
23 feet thick and is composed of gray silts and clays with fine
sand. Within this aquitard are localized sandy lenses that range
between 0.5 and 2 feet in thickness. These lenses are referred
to as the A2 Deep (A2D) Zone.
Within the B Aquifer, the Bl Zone occurs below an approximate
depth of 60 feet below ground surface. This zone is typically
about 10 feet thick. Where encountered, the B2 Zone begins at
approximately 85 feet below the surface and is between six and 33
feet thick.
The general groundwater gradient in the A Aquifer is to the
north-northeast. Groundwater flow directions are influenced
locally by the preferential flow through relatively thick,
transmissive aquifer sands. In the Al Zone at certain locations,
groundwater and chemicals have been deflected toward the east
along preferential flow paths. This easterly defection of
chemicals is not evident in the A1U and A2 Zones.
The Oregon Expressway Underpass (OEU) serves as a subsurface
roadway beneath the Southern Pacific Railroad tracks, Alma Street
and Park Boulevard. The underpass, built in 1958, extends 24
feet below ground surface into the A1U Zone. A dewatering system
installed beneath the underpass controls natural groundwater
inflow and surface runoff. This dewatering appears to affect
groundwater flow in the A1U, Al and A2 Zones, and does not allow
contaminants to bypass the subdrain to the north.
During low flow periods, the average rate of discharge is
typically 140 gallons per minute (gpm), with total VOC
concentrations ranging between 200 and 300 parts per billion
(ppb), This water is discharged to the City of Palo Alto
sanitary sewer. The discharge during high flow periods consists
of both surface water and groundwater; excess is pumped via
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auxiliary pumps and discharged to the City of Palo Alto storm
drain system.
Groundwater monitoring has been conducted at the HP-640 PMR site
since 1981, and investigation of the off-site area began in 1985
near the HP-640 PMR site. The present groundwater monitoring
network on the HP-640 PMR site consists of 28 wells. In
addition, there are 10 on-site groundwater monitoring wells at
the 601 California site, 18 on-site monitoring wells at the 395
Page Mill Road site, and 91 off-site monitoring wells installed
by HP and Varian.
VOCs are most widely distributed in the AlU and Al Zones.
Maximum concentrations are 17,000 ppb TCE; 30,000 ppb 1,1,1-TCA;
2200 ppb DCE; and 39,000 ppb PCE. The A1U is unsaturated over
much of its western half due to a lengthy drought. Contamination
in the B-Aquifer is minimal — VOCs have been detected at
concentrations below cleanup levels in the COE Area and above
cleanup levels at one location in the Perimeter Area that appears
to be associated with a separate source.
The current groundwater extraction system includes one well at
the HP-640 PMR site and three wells at the Varian 601 California
site. Off-site groundwater extraction was initiated in 1988 on
the adjacent Mayfield school property with the installation of
two A1U wells. These two extraction wells were inoperable for
three years beginning in mid-1991 because the shallow aquifer
zone had become unsaturated in this area; they resumed operation
in spring 1994 after water levels rose.
The treatment system for the HP-640 PMR on-site wells and six
off-site wells is located on the HP-640 PMR site. In late 1992
and early 1993, nine groundwater extraction wells and associated
observation wells were installed as part of the expanded interim
remedial system. Regional groundwater extraction and treatment
in the COE and Perimeter Areas and at the Varian 611 Hansen Way
site will be coordinated when additional extraction wells, to be
located at 611 Hansen Way, come on-line. Treated groundwater
from the HP-640 PMR site treatment system is discharged to the
sanitary sewer according to the sewer discharge permit issued by
the Palo Alto Regional Water Quality Control Plant (PARWQCP).
In addition to the groundwater extraction system, a 15-well soil
vapor extraction (SVE) system was installed at the HP-640 PMR
site and became operational in April 1994. The SVE system is
operating under a BAAQMD permit, and is being monitored 'in
accordance with permit conditions.
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6. Summary of Site Risks
EPA prepared the Baseline Public Health Evaluation (BPHE) for the
HP-640 PMR site. Since all areas of soil contamination had been
or were in the process of being remediated, the BPHE addressed
groundwater contamination only. Because the plume is commingled,
the report addressed known groundwater contamination from other
potential sources in the area as well as from the HP-640 PMR
site.
Risks were calculated for both an average exposure case and a
reasonable maximum exposure (RME) case for each of three areas,
the A-Aquifer (On-Site), B-Aquifer (On-Site) and Perimeter Area
(Off-Site). Four potential exposure scenarios were developed for
groundwater contamination pathways: Current On-Site Worker;
Current Off-Site Resident; Future On-Site Resident; and Future
Off-Site Resident. Because there presently is no residential use
of groundwater in the area, the current potential exposure
pathways are limited to inhalation of indoor air and not
ingestion, dermal contact or inhalation while showering. All
four exposure pathways were evaluated for future use.
No carcinogenic risks above the 10" to 10-' risk range nor
non-carcinogenic Hazard Index (HI) greater than 1 were estimated
for the B-Aquifer under any scenario. Table 1 lists the
carcinogenic risks above the 10" to 10-' risk range and
non-carcinogenic HI numbers greater than 1 in the A-Aquifer and
Perimeter Area that were calculated for the indicated pathways.
The findings of the BPHE suggest that potential human health
risks could result under some land use and exposure scenarios.
If no further remediation took place, if the site wad converted
to residential use, and if the groundwater was used for domestic
purposes, several exposure pathways of concern might exist that
could pose carcinogenic and/or non-carcinogenic human health
risks. The most significant potential exposures identified in
the BPHE are the following:
1) Ingestion of groundwater containing chemicals of potential
concern
2) Inhalation of VOC vapors from the groundwater during
showering and/or other domestic uses
3) Inhalation of VOC vapors inside buildings resulting from
volatilization from groundwater
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7. Summary of Remedial Alternatives
The FS identified a range of general response actions and
remedial technologies for groundwater and soil in order to
develop remedial alternatives for the site. A brief narrative
summary of the alternatives is presented below; each alternative
is described in detail in the FS report.
Boil Remedial Alternatives;
Soil excavation options were eliminated during the FS screening
process based on implementability. Further excavation is not
implementable because of the new building construction that has
already occurred as part of the site development. Thus, only two
remedial alternatives were developed and evaluated for
contaminated soils at the HP-640 PMR site:
Alternative l: No further action
Alternative 2: Continued operation of the existing soil vapor
extraction system and treatment by granular activated carbon
(GAC)
IRMs have already been implemented at the HP-640 PMR site that
have removed a major portion of the VOCs in vadose .zone soils.
However, concentrations of VOCs remain in soil at the site that
do not meet remedial action objectives. The soil cleanup
standard for VOCs at the site is 1.0 mg/kg total VOCs, excluding
acetone. The cleanup standard proposed for acetone in vadose
zone soils is 25 mg/kg. This number was derived using a chemical
transport model that is described in detail in Attachment A-l to
the FS. The total amount of soil requiring remediation is
estimated at 4500 cubic yards. The total amount of VOCs
remaining in vadose zone soil is estimated at approximately 1300
pounds, with acetone as'the major constituent.
Alternative 1 represents current conditions at the site if
operation of the IRM system was discontinued. Alternative 2
would continue the existing in situ remediation of VOCs in soil
by yapor extraction. Extracted vapors are treated by vapor-phase
GAC to control air emissions. It is estimated that this
alternative will require approximately three years to achieve a l
mg/kg total VOCs cleanup level (excluding acetone) and to achieve
a 25 mg/kg acetone cleanup level.
Potential ARARs for the HP-640 PMR site are discussed in detail
in the FS report and are summarized in this ROD for the soil and
groundwater alternatives.
There are no chemical-specific ARARs for soil. In the absence of
ARARs, non-promulgated standards, criteria, guidance and
advisories must be used to provide a protective remedy. In the
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Ground Water Basin Plan Amendments, adopted October 21, 1992, the
RWQCB states that "at this time the Regional Water Board finds
that [1 mg/kg] is an appropriate cleanup level for total VOCs in
the unsaturated zone at sites where ground water is being
monitored and where cleanup to background is unreasonable." EPA
has selected the RWQCB soil cleanup level of l mg/kg for total
VOCs in RODs for many South Bay Superfund sites and agrees that
this cleanup level is appropriate for the HP-640 PMR site.
Action-specific ARARs and TBCs for the soil remedial alternatives
include the following:
Bay Area Air Quality Management District (BAAQMD) Regulation 8,
Rule 47: This rule applies to specified discharges of organic
compounds to the atmosphere through soil vapor extraction
operations during removal of organic compounds from soil.
EPA Office of Solid Waste and Emergency Response (OSWER)
Directive 9355.0-28 (June 15, 1989): This memorandum establishes
guidance on the methods and implementation procedures for control
of VOC air emissions from air strippers and soil vapor extraction
systems used at Superfund sites.
Groundwater Remedial Alternatives:
Three remedial alternatives were developed and evaluated for
contaminated groundwater:
Alternative 1: No further action; continued operation of the
existing IRM extraction and treatment system; continued
groundwater monitoring
Alternative 2: Continued operation of existing IRM extraction
wells, plus construction and operation of new wells abided
primarily at the boundaries of the groundwater contamination
plume; continued groundwater monitoring
Alternative 3: Continued operation of existing IRM extraction
wells, construction and operation of the wells described in
Alternative 2, and construction and operation of new wells
located in selected areas of elevated chemical concentrations;
continued groundwater monitoring
All three groundwater alternatives are based on continued
operation of the existing IRM wells and the OEU dewatering system
as part of the remedy. All alternatives employ similar treatment
and disposal methods and include continued groundwater monitoring
and deed restrictions to limit future use of groundwater.
Therefore, the only significant differences between the
alternatives are in the number and placement of wells.
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All of the final alternatives involve treatment of extracted
groundwater by air stripping followed by granular activated
carbon (GAC). Separate treatment systems for the area-wide
groundwater contamination plume will be located at the facilities
at 640 Page Mill Road, 601 California Avenue, 395 Page Mill Road
and 611 Hansen Way. Options for the disposal of treated
groundwater are: reuse for irrigation and non-potable
consumption; discharge to the local sanitary sewer; and discharge
via NPDES permit to surface water. Reuse of treated groundwater
is preferred over discharge to the POTW or the storm drain, in
accordance with city and state preferences for reuse of treated
groundwater.
Alternative 1 represents a no further action rather than a
no-action alternative. As stated in the NCP (40 CFR
300.430(e)(6), "the no-action alternative may be no further
action if some removal or remedial action has already occurred at
the site." In the case of the HP-640 PMR site and the associated
area-wide groundwater contamination plume, groundwater extraction
wells at 640 Page Mill Road, 601 California and 611 Hansen Way
have been operating since 1982, 1987 and 1991, respectively. In
addition, the OEU subdrain has been operated by the Santa Clara
County Transportation Agency since 1958 and is expected to
operate continuously as long as the underpass exists. The effect
of its groundwater extraction can be considered a permanent
impact in the area and a unique circumstance with respect to
developing alternatives.
The operation of the OEU subdrain and the existing IRM wells
represents more realistic baseline conditions in this area. The
RWQCB SCRs require that HP and Varian submit a workplan and time
schedule for alternate control and remediation of groundwater if
the present OEU remediation system is rendered ineffective in
remediating or preventing the spread of groundwater
contamination.
Chemical-specific'ARARs for the groundwater alternatives are
federal and state Maximum Contaminant Levels (MCLs), excluding
acetone, since there is no state or federal MCL for acetone, the
cleanup level is derived from the EPA Health Effects Assessment
Summary Tables (HEAST, 1992).
Action-specific ARARs for the groundwater alternatives include
OSWER Directive 9355.0-28 described under the soil alternatives.
Hazardous waste regulations relating to the disposal of treatment
residuals that are classified as hazardous waste (e.g., spent
activated carbon) are ARARs for both soil and groundwater
alternatives.
Location-specific ARARs would apply to both soil and groundwater
alternatives. Location-specific ARARs include the fault zone and
flood plain requirements of 40 CFR Part 264.18 and 22 CFR Sect.
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66264.18. The HP-640 PMR site is not within 200 feet of an
active fault, but part of the area of groundwater contamination
is location within the year floodplain of Matadero Creek. Under
state and federal regulations, a hazardous waste facility located
in a 100-year floodplain must be designed, constructed, operated
and maintained to prevent washout of any hazardous waste by a
100-year flood, unless it can be demonstrated that certain
exemptions apply. No construction is planned to be located
within the 100-year floodplain of Matadero Creek except under
groundwater Alternative 3.
8. Summary of Comparative Analysis of Alternatives
Each alternative was analyzed using the nine evaluation criteria
required by the NCP. A detailed comparative analysis is
presented in the FS report and is summarized here.
Soil Remedial Alternatives:
Because concentrations of VOCs and acetone remain in vadose zone
soil at the site, the no further action alternative may not be
protective of human health and the environment. Because the
remaining contaminated soils are found only at depth (at least 15
feet below ground surface) and because they are now covered by
the new building, emissions of chemical vapors and dust from
surface soil do not represent a current or future human health
risk. However, the no further action alternative might not
provide adequate protection of designated beneficial uses of
groundwater (and thus might pose risks to human health and the
environment) because of the potential migration of chemicals from
soil to groundwater that could result in concentrations of
chemicals in groundwater in excess of the cleanup standards.
*
Alternative l does not comply with soil cleanup standards for the
remaining contaminated soil. It may not meet the requirement for
long-term effectiveness1 and permanence, although cleanup
standards might eventually be achieved through naturally
occurring processes over a very long period of time. The no
further action alternative does not involve any further physical
or chemical treatment of soils, and thus does not achieve any
reduction in volume. This alternative could actually result in
an increase in the volume of affected soil and groundwater, as
chemicals continue to migrate vertically. No significant
short-term reduction in the toxicity of chemicals present in the
vadose zone would occur, although toxicity might decrease over a
very long period of time.
The short-term effectiveness of Alternative 1 is low because the
time to reach cleanup levels through naturally occurring
processes would be long with no further action. The no further
action alternative is implementable and there are no capital or
O&M costs associated with it. The no further action alternative
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is not acceptable to either the state or the community.
Alternative 2 meets all nine criteria. This alternative is
protective of human health and the environment because it will
remove chemicals from soil and thus prevent their migration from
soil to groundwater. Alternative 2 is expected to achieve the
soil cleanup standards set for the site and would meet those
ARARs associated with air emissions and treatment residuals from
the treatment system. The potential risk due to air emissions is
negligible as the system has been designed to meet BAAQMD
regulations.
Because Alternative 2 is expected to achieve cleanup standards
and chemicals would be removed from the vadose zone, the
long-term effectiveness and permanence of this alternative is
high. Because Alternative 2 includes removal and treatment of
VOCs, it will result in a reduction in both toxicity and volume
of contaminated soil. Treatment of vapors by GAC filters would
reduce the volume of affected medium by removing VOCs from a gas
stream and sorbing them to a solid. Because construction of the
IRM system has already been completed, the only additional
potential exposure to be considered is from continued operation
of the SVE system. Short-term exposure to workers or the public
is minimal and manageable by proper health and safety measures.
Alternative 2 is considered fully implementable. An SVE Pilot
Study conducted in 1991 confirmed that SVE is an effective
technology for removing VOCs from vadose zone soils at the site.
The capital cost for Alternative 2 is approximately $327,000.
The present-worth O&M cost is approximately $296,000, assuming a
three-year operation period.
Alternative 2 is acceptable to both the state and th^ community.
Groundwater Remedial Alternatives;
All three groundwater remedial alternatives would provide
protection of human health by actively removing chemicals from
groundwater. Under Alternative 1, a portion of the area would
not be actively remediated and would likely not meet MCLs.
Chemicals in this area could migrate to the north or east.
Although the groundwater is not used for human consumption, an
exposure pathway may exist for inhalation of VOCs in indoor air.
In addition, chemicals remaining in these areas could adversely
affect beneficial uses of groundwater and therefore may not be
protective of the environment. Because concentrations above MCLs
would remain outside the capture zone for Alternative 1,
long-term effectiveness may not be achieved.
Under Alternative 1, the toxicity of chemicals would be reduced
by regeneration or disposal of carbon, but would not be total
because not all VOCs would be captured. Alternatives 2 and 3
will reduce the volume and mobility of chemicals by extraction.
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The volume of VOCs in groundwater will gradually decrease as
remediation progresses, and the mobility of the chemicals will be
limited by containment within the capture zones of the extraction
wells. The alternatives will reduce the toxicity of chemicals by
regeneration or disposal of saturated carbon. State and federal
ARARs associated with the storage, handling and regeneration of
spent carbon would be met for all alternatives.
All three alternatives have or will involve installation of a
treatment system and conveyance piping. None of these activities
are expected to have any adverse human health or environmental
impacts. Alternative 1 may require a longer cleanup time than
Alternatives 2 and 3 because it has the lowest total pumping
rate. Differences in cleanup times for the three remedial
alternatives may be negligible, however, given the small
differences in pumping rates, the limited availability of water
in the aquifer system (which may limit the achievable pumping
rates), and the potential for chemical concentrations to approach
asymptotic levels.
Alternative 1 has already been implemented. Access could be
restricted at three potential well locations under Alternative 2
and at five potential well locations under Alternative 3, but is
not expected to be a significant problem. The treatment system
for all three alternatives are commercially available and do not
require any special modifications. This treatment technology
represents a reliable technology that has been applied at
numerous sites. System performance can be easily monitored and
adjustments made, if necessary, to optimize system performance.
Emissions of VOCs into air under all three alternatives would be
controlled by vapor-phase carbon treatment. The treatment
technology is not expected to result in any exposures to
chemicals of concern. s
The estimated present worth costs for the groundwater
alternatives are:
Alternative 1 Alternative 2 Alternative 3
Capital Cost $ 1,692,000 $ 2,919,000 $ 3,304,000
Total O&M Costs 4,808,000 5,072,000 6,241,000
Monitoring Costs 8,013,000 8,013,000 8,013,000
Total $14,513,000 $16,004,000 $17,557,000
State agencies and the community have supported Alternative 2 as
the preferred groundwater remedial alternative.
14
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9. Selected Remedy
Soil Alternative 2 and Groundwater Alternative 2 were selected
for remediation of the HP-640 PMR site. The major components of
the selected remedy are:
Continued operation of the existing 15-well soil vapor
extraction system at the HP-640 PMR site until final cleanup
standards are achieved
Continued operation and expansion of the current on-site and
off-site groundwater extraction and treatment system until
final cleanup standards are achieved
- Long-term groundwater monitoring
- A deed restriction for the HP-640 PMR site prohibiting use
of on-site groundwater for drinking water until final
cleanup standards are achieved
The final cleanup standards are l mg/kg total VOCs and 25 mg/kg
acetone for soil. For groundwater, the cleanup standards are
MCLs for VOCs and semivolatiles, except for acetone, which does
not have an MCL. The groundwater cleanup standards are listed in
Table 1 of the RWQCB SCRs (Appendix A).
The selected remedy provides overall protection of human health
and the environment, complies with ARARs, and provides the best
overall balance of alternatives under the nine selection criteria
of the NCP. The analysis of the selected remedy with respect to
the nine criteria is summarized below:
v
Overall Protection of Human Health and the Environment:
Constituents in groundwater are contained within a defined area
and groundwater is properly treated and released, under permit.
Extraction, treatment and disposal provides for the future
protection of human health and the environment.
Compliance with ARARs: The selected remedy is expected to
achieve the soil and groundwater cleanup levels that were set for
this site. In addition, the selected remedy is expected to meet
action-specific ARARs related to the treatment of chemicals
extracted from soil and groundwater.
Long-term Effectiveness and Permanence: IRMs at the site have
already reduced contaminant concentrations. The selected remedy
will reduce potential future risks once cleanup levels are
reached. The FS estimates that the time to reach groundwater
MCLs is at least 30 years. Soil cleanup is estimated to take 3
years. Treatment residuals will be treated and disposed of
off-site with appropriate controls in permitted facilities. A
15
-------
deed restriction prohibiting residential development will provide
additional assurance of long-term effectiveness. Continued
groundwater monitoring will ensure that further off-site
migration of contaminants does not occur.
Reduction of Toxicity, Mobility or Volume through Treatment:
Expanded groundwater extraction and treatment, along with soil
vapor extraction and treatment, will decrease the volume and
toxicity of contaminated groundwater and soil. The mobility of
the chemicals in groundwater will be limited by containment
within the capture zones of the extraction wells. Operation of
the soil vapor extraction system will remove chemicals from soil
and thus prevent their migration from soil to groundwater.
Short-Term Effectiveness: Risks of worker exposure to chemicals
during system installation and operation are minimal and safety
measures will be implemented to address them. No environmental
impacts or health risks to the community are expected.
Short-term operation of the groundwater extraction wells will
contain the groundwater contamination in a defined area and
result in decreased concentrations. Vapor extraction from soils
will enhance removal of contaminants and prevent additional
groundwater from becoming contaminated. Evaluation of the
effectiveness of extraction, treatment and discharge will occur
periodically in accordance with agency requirements.
Implementability: The groundwater extraction, treatment and
discharge has already been implemented at 640 Page Mill Road and
other sites in the area-wide groundwater contamination plume; the
expansion of the system is readily implementable. The soil vapor
extraction and treatment system for 640 Page Mill Road is already
in place and operational.
Cost: The selected remedy is cost effective. Groundwater
Alternative 2 provides greater assurance of long-term
effectiveness at a reasonable cost; the additional cost of
Alternative 3 was not justified.
State Acceptance: The RWQCB is the lead agency that has been
responsible for overseeing the RI/FS for the HP-640 PMR site.
Comments and responses on the Proposed Plan for the HP-640 PMR
site are included in the attached Responsiveness Summary. After
considering comments from the public, potentially responsible
parties, and other state agencies, the RWQCB finalized its
selection of the remedial action for the site in its final SCRs.
A copy of the RWQCB SCRs, adopted September 21, 1994, is
appended. EPA selects and concurs with the remedy chosen in the
RWQCB SCRs.
Community Acceptance: A public meeting was held on July 26, 1994
to discuss and receive comment on the proposed remedy for the
site. Community members attending the meeting were satisfied
16
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with the selected remedy, and written comments from members of
the community were also generally favorable. Public comments,
along with agency responses, are included in the Responsiveness
Summary.
10. Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with ARARs, and is cost effective. The
remedy uses permanent solutions and alternative treatment
technologies (or resource recovery) to the maximum extent
practicable and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility or volume
as a principal element.
Because the remedies will result in hazardous substances
remaining on-site above health-based levels, a five-year review,
pursuant to CERCLA Section 121, 42 U.S.C. Section 9621, will be
conducted at least once every five years after initiation of the
final remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
17
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EXPLANATION
Study ArtO Boundary
Underpass (OEU)
D»wotenrvj System
OEU Pump Station
OTSC-leod Ar«a
ASSOCIATES
•H HANSEN WAY,
STUDY ABEA-1
-------
Groundwater Exposure
Unit Pathway
A-Aquifer Current;
TABLE 1
Carcinogenic Risk
Carcinogenic Risk
Adult Resident / Adult Worker
(Average/RME) (Average/RME)
Perimeter
Area
Inhalation - Indoor
Air (Study Area)
Inhalation - Indoor
Air (Hot spot)
Future ;
Ingestion
Inhalation -
Showering
Current ;
Inhalation - Indoor
Air (Study Area)
Inhalation - Indoor
Air (Hot spot)
Future;
Ingestion
3xlO'5 2x10-'
NA NA
2xlO-« 1x10°
3xlO'5 2xlO-«
IxlO'5 4xlO-5
NA NA
3x10-' 2x10"'
Non-Carcinogenic
A-Aquifer
Perimeter
Area
Current
Inhalation - Indoor
Air (Study Area)
Future
Ingestion
Inhalation -
Showering
Current
Inhalation - Indoor
Air (Study Area)
Future
Ingestion
Inhalation -
6 9
5 10
7 20
2 2
1 2
1 2
1x10"
1x10-'
9xl05
NA
4x10"
4x10-'
2xlO-»
Risk
0.001
2
NA
0.0004
0.4
NA
4x10-'
3x10-'
4x10"'
NA
7xlO-»
9x10-'
SxlO'5
0.002
4
NA
0.0005
0.7
NA
Showering
-------
PART Hit RESPONSIVENESS SUMMARY
-------
SI AH O( CAllfORNIA
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD /^>:
SAN FRANCISCO BAY REGION (?>i':"
?ICI WEBSTER STREET. SUITF 50C ' >i
OAK:AND. CA 9461?
510; 786 1755
Date: b:P 3 I 1994
File No. 2189.8063B(jmh)
Subject: Response to Comments on tentative Site Cleanup Requirements for
Hewlett-Packard, 640 and 395 Page Mill Road and Varian 601
California Avenue, Palo Alto
To: Mailing list:
The Regional Water Quality Control Board, San Francisco Bay Region, has written a
response to comments (responsivness summary) to interested persons attending
either the community meeting held at Escondido School on July 26, 1994 or
responding in writing during the 30 day comment period. The Board will consider
adopting the tentative Site Cleanup Requirements for the 1501 Page Mill Road site
at 8:30 on September 21 at the Bart Headquarters Building, 2nd floor Meeting
room, 800 Madison Street in Oakland. Enclosed is a copy of the response to
comments.
If you have any questions, please contact John Hillenbrand (510) 286-0671.
Sincerely,
•'Stephen Morse, Chief
Toxic Cleanup Division
Attachment
cc w/attachment: Mailing List
-------
Mailing List
Paula Kakimoto
Stanford Management Company
2770 Sand Hill Road
Menlo Park, CA 94025
Doris Maez
City of Palo Alto
Planning Dept.
50 Hamilton Avenue
Palo Alto, CA 94301
John Joynt
Barren Park Foundation
3589 Laguna Avenue
Palo Alto, CA 94306
Barbara Cook
Dept. of Toxic Substances Control
700 Heinz Avenue Suite 200
Berkeley, CA 94710-2737
Tom Iwamura
Santa Clara Valley Water District
5750 Almaden Expressway
San Jose, CA 951.18
Marie Lacey
U.S. EPA Region IX
75 Hawthorn Street
San Francisco, CA 94105
Dr. Inge Harding-Barlow
3717 Laguna Avenue
Palo Alto, CA 94306
Robin Ross
Hewlett-Packard
1501 Page Mill Road MS 5U
Palo Alto, CA 94304
Bo Gustincic
Varian Associates
3120 Hansen Way MS D-095
Palo Alto CA 94303-0883
Arthur Bayce
1029 Paradise Way
Palo Alto CA 94306
David Chalton
3875 El Centro
Palo Alto 94306
Bob Moss
4010 Orme
Palo Alto CA 94306
-------
RESPONSIVENESS SUMMARY FOR 30 DAY PUBLIC COMMENT PERIOD
FROM
JULY 20, TO AUGUST 19, 1994
REGARDING THE PROPOSED REMEDIAL ACTION PLAN
FOR
HEWLETT-PACKARD 640 AND 395 PAGE MILL ROAD
AND
VARIAN 601 CALIFORNIA AVENUE
SUPERFUND SITE
PALO ALTO, CALIFORNIA
EXECUTIVE SUMMARY
A 30 day public comment .period was held from July 20 through August 19 and a community
meeting was held on July 26. During the public comment period there were five sets of
written comments and one verbal comment submitted to Board staff. Verbal comments and
questions were also received from the community meeting. Most of the comments were
minor and easily addressed. Out of these comments two are considered significant:
1. A community member at the public meeting expressed concern about the risk to
residents who live over the contaminated groundwater in the off-site area. The
concern was over the actual risk level. A risk assessment was done by a contractor
for the U.S. EPA. This assessment indicated that the risk to residents over the
contaminated areas is acceptable given the conservative nature of the assessment. The
response provided below goes into detail about specific calculations and conditions
which emphasizes that the risk is acceptable and was calculated according to
conservative EPA procedures.
2. The Department of Toxic Substances Control expressed concern over the
protectiveness of the 1 ppm total VOCs soil cleanup level proposed in the tentative
Site Cleanup Requirements for this site. The Department suggests that a cleanup
standard closer to .1 ppm for one of the chemicals, 1,1-DCE, may be more
appropriate. Since cleanup at the site is 1 ppm total VOCs and 1,1-DCE is never
found in soil samples above one tenth of any total VOC concentration, the cleanup
level of 1 ppm total VOC concentration is protective.
Written and verbal comments received during the public comment period and verbal
comments received from the community meeting are answered in detail below.
-------
Responsiveness Summary - September 21, 1994
Hewlett-Packard 640 and 395 Page Mill Road and Varian 601 California Avenue
INTRODUCTION
This responsiveness summary reviews comments and questions regarding the tentative Site
Cleanup Requirements, Remedial Investigation/Feasibility Study (RI/FS) and proposed final
cleanup plan (proposed plan) for the Hewlett-Packard Company facilities 640 and 395 Page
Mill Road, Varian 601 California Avenue facility and the off-site COE (California Avenue-
Olive Avenue-Emerson Street) area in Palo Alto. The remedy is presented in the tentative
Site Cleanup Requirements (SCR) and the Proposed Plan Fact Sheet. This summary includes
comments received during the period from the opening of public comment at the Board
meeting on July 20, 1994, through August 19, 1994.
Part 1 contains responses to comments from a public meeting held at Escondido School on
July 26, 1994 and Part II contains the responses to written and verbal comments received
from the following entities:
1. Barron Park Association Foundation
2. Santa Clara Valley Water District
3. Stanford Management Company
4. Hewlett-Packard Company
5. Varian Associates
6. California EPA, Department of Toxic Substances Control
Part I
During the community meeting on July 26, numerous questions were asked about the
proposed plan and were, in general, answered during the meeting (a transcript is available
from the meeting). The one remaining issue from the meeting requiring a further response
is described below:
What is the current and future risk to residents in the COE off-site area?
A Baseline Public Health Evaluation was done for the U.S. EPA in September 1992. This
evaluation indicated that the only current potential exposure pathway in the COE area is
through the inhalation of VOCs that have migrated through the soil to indoor air.
The potential carcinogenic risks from this exposure pathway to a current adult resident ran^e
between 1x10' and 2x10^. This is just below acceptable levels (IxlO"1). The single
chemical that contributes nearly all (96%) of the total risk is vinyl chloride which has been
detected in only 5 samples from separate wells out of approximately 600 sampling events.
With the large amount of conservative assumptions built into the model. Board and EPA s;a!t
believe the current risk exposure in the COE area is acceptable.
pai.v -
-------
Responsiveness Summary - September 21, 1994
Hewlett-Packard 640 and 395 Page Mill Road and Varian 601 California Avenue
In addition, since the off-site hot spot areas (western corner of Lambert and Ash and north of
the caster corner of the HP 395 site) that contain the greatest risk are both non-residential,
the complete pathway does not exist. Also, future risk is acceptable for residential use of the
two hot spot areas because cleanup is currently underway which will significantly reduce the
groundwater contaminant concentrations in those areas. The hot spot on the 395 property
will have an additional site specific risk assessment done before any residences can be built
in the area.
Part II
The following written and verbal comments were received during the 30 day public comment
period:
Baron Park Association Foundation (BPAF)
No comments on the tentative Site Cleanup Requirements were received from the BPAF and
therefore no changes will be made to the document. The BPAF indicated that the RI and FS
were acceptable and had been approved and adopted by the BPAF Board of Directors. A
few additional suggestions and comments needing clarification.
1. BPAF Comment BPAF's consultant suggests that chloroform in the groundwater
may be from leaking water mains in the area and at the Alza site. The source of
these water mains should be examined and the Alza site may require the design and
operation of a groundwater remediation system.
Board Staff Response The Alza site at 1454 Page Mill Road is currently operating a
groundwater extraction and remediation system under Cleanup and Abatement Order
No. 88-1. The spill resulted from a chemical handling area and is not the result of a
leaking water main. The chloroform in the area, other then the Alza site, does not
appear to be significant when compared to other contamination and may be from lab
contamination. This contamination, if present, can be reexamined as pan of the five
year review.
2. BPAF Comment Regional Board staff requested that Hewlett-Packard and Varian
make the Oregon Expressway underpass dewatering system an integral part of the
remediation system and guarantee its operation. No such guarantees appear to have
been provided within the text of the FS.
Board Staff Response Task 29 of the tentative Site Cleanup Requirements requires
within 90 days after a request made by the Executive Officer, Hewlett-Packard ami
Varian submit a workplan and time schedule for control and remediation of
-------
Responsiveness Summary - September 21, 1994
Hewlett-Packard 640 and 395 Page Mill Road and Varian 601 California Avenue
groundwater should the present dewatering system be rendered ineffective in
remediating or preventing the spread of groundwater contamination.
3. BPAF Comment Board staff requested a deed restriction recognizing that a pump and
treat system will probably not cleanup the source area completely. No recognition of
the inability of a pump and treat system to cleanup groundwater in the source areas
has been made in the FS. Hewlett-Packard and Varian should express such a
recognition in the FS and in a subsequent review (perhaps in five years) of
remediation progress.
Board Staff Response Recognition of the ineffectiveness of groundwater pump and
treat technology is discussed extensively in Findings 18 and 20 of the tentative Site
Cleanup Requirements. Hewlett-Packard and Varian have agreed to the substance of
these findings. Board staff believes that because these findings are part of the
Remedial Action Plan (composed of the RI, FS, the Proposed Plan Fact Sheet and the
Site Cleanup Requirements) that the recognition Findings 18 and 20 is adequate.
Also, Task 37 of the tentative Site Cleanup Requirements require a five year status
report and effectiveness evaluation due on June 1, 2000.
4. BPAF Comment Bioremediation should be considered for site cleanup either at the.
normal 5 year review or sooner if advances in technology warrant it.
Board Staff Response Regional Board staff agrees with this request and reiterates that
a 5 year review is scheduled for 2000. Also Task 39 of the tentative Site Cleanup
Requirements states that, at any time upon the request of the Executive Officer, new
technical or economic information relating to remediation must be reviewed.
5. BPAF Comment The BPAF should get a copy of a redline version of the RI/FS that
was given to Regional Board staff to aid in its review.
Board Staff Response Although intended only for Board staff, this document was
given to BPAF's consultant Uribe and Associates by Board staff to help them expedite
review of the RI/FS. In addition, a redline version of the Rl/FS is available as a
public document in the Administrative Record at the Regional Boards Offices in
Oakland. This document can be reviewed and/or copied by any member of the
public. .
Santa Clara Valley Water District
The Water District is in concurrence with, and supports adoption of the tentative Site
-1
-------
Responsiveness Summary - September 21, 1994
Hewlett-Packard 640 and 395 Page Mill Road and Vanan 601 California Avenue
Cleanup Requirements with the understanding that additional work will be required if the five
year review indicates that the selected alternative is not adequate to remediate the
groundwater. No response is needed
Stanford Management Company
The comments from Stanford deal primarily with clarifications of text except for Stanford 's
request to have less then 10% of the Non-Binding Allocation of Responsibility.
All minor clarifications requested by Stanford to tentative Site Cleanup Requirements will be
incorporated. The Non-Binding Allocation of Responsibility will not be changed. A 10%
allocation is a standard allocation for property owners. To make slight adjustment to account
for Stanford owning 2 out of the 3 properties would imply an accuracy that does not exist.
Hewlett-Packard Company
Hewlett-Packard submitted text comments for both companies. These comments were mostly
typographic and clarification modifications and have been made. The only comment
requiring a detailed response is Task IB, the deed restriction. Task IB had asked for
Hewlett-Packard to notify current sub-tenants about locations of hazardous materials in the
subsurface and the potential health hazards associated with such materials. Hewlett-Packard
has notified the current sub-tenant and specified that future tenants will also be notified.
Therefore, the Task will be modified to require that only future sub-tenants must be notified
The companies requested that Task 37, the five year review of soil and groundwater
remediation, be restricted to the groundwater only. This Task will not be changed because
soil remediation is an important topic to be covered in this report.
Varian Associates
Like Task IB for Hewlett-Packard, Task 9B had asked for Varian to notify current sub-
tenants about locations of hazardous materials in the subsurface and the potential health
hazards associated with such materials. Varian has notified the current sub-tenant in a letter
dated August 12, 1994 and specified that future tenants will also be notified. Therefore, the
Task will be modified to require that only future sub-tenants must be notified.
California EPA, Department of Toxic Substances Control
The Department made two verbal comments in an August 20, 1994 phone conversation with
Board staff.
-------
Responsiveness Summary - September 21, 1994
Hewlett-Packard 640 and 395 Page Mill Road and Varian 601 California Avenue
The first involves the reuse of the Hewlett-Packard 395 Page Mill Road site. The
department expressed concern that the health risks to individuals that will reuse the site has
not been addressed. Hewlett-Packard will conduct a risk assessment for the intended use of
the site once the final use is determined.
The second comment concerns the protectiveness of the soil cleanup level of 1 ppm total
VOCs. Department staff has indicated their concern that site specific studies should be done
so that the more mobile and/or toxic substances will be prevented from degrading
groundwater in on-site areas. They specifically cited 1,1-DCE as a chemical that, at some
DTSC sites, requires levels as low as .16 ppm in order to be protective of groundwater.
Board staff believes that for these sites the 1 ppm total VOCs cleanup standard is appropriate
because 1,1-DCE is always found to contribute less then 10% of the total VOCs in the soil
samples at the Varian 601 California Avenue and Hewlett-Packard 640 and 395 Page Mill
Road sites. In addition, the change in chemical composition of the groundwater through time
will indicate whether there is a continuing source. The five year review, as required in Task
37 of the tentative Site Cleanup Requirements, will assess the effectiveness of the
groundwater extraction and treatment system.
-------
APPENDIX A
RWQCB SITE CLEANUP REQUIREMENTS
-------
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
ORDER 94-130
REVISED SITE CLEANUP REQUIREMENTS FOR:
Hewlett-Packard Company
640 Page Mill Road and 395 Page Mill Road
Palo Alto
Santa Clara County
Varian Associates
601 California Avenue
Palo Alto
Santa Clara County
Stanford University
Palo Alto
Santa Clara County
The California Regional Water Quality Control Board, San Francisco Bay Region
(hereinafter called the Board) finds that:
. t
1. Site Location and Description The sites addressed by this Order include on and off-
site contamination from Hewlett-Packard 640 Page Mill Road (640 site), Varian
Associates 601 California.Avenue (601 site) and Hewlett-Packard 395 Page Mill Road
(395 site) in Palo Alto. The 601 and 640 sites are located within Stanford Research
Park, These areas are described below.
Stanford University has owned the Stanford Research Park property since 1885. The
research park consists of 655 acres with approximately 60 tenants. Most of the
tenants have 51- or 99-year ground leases and operate the facilities on their sites.
Hewlett-Packard Company (HP) operated the Optoelectronics Division at 620 and 640
Page Mill Road between 1964 and 1986. The 640 site was primarily used for the
manufacture of gallium arsenide and silicon based semiconductors. HP, which leases
the property from Stanford University, had manufacturing buildings 10 and 11 and a
storage building on site. HP has redeveloped the property and constructed an office
building.
"""'• / •'<' ->
••v / X /
-------
Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian «M California Avenue
Varian Associates Inc. (Varian) operated a business at 601 California Avenue between
1965 and 1991. The site was originally leased from Stanford and operated by
General Electric between 1954 and 1965, and by Varian from 1966 to 1991. The
buildings were sold by Varian in 1991 to Intevac. The on-site area consists of
manufacturing Buildings 8 and 8A.
Hewlett-Packard Company owns and operates property and a fabrication facility at
395 Page Mill Road. The 395 site has been operated by HP •since 1942 and houses
various industrial operations related to the manufacture of electronic equipment. The
on-site area consists of buildings 7A, 7B, 7C, 7D, 8 and 12 and former buildings 7E,
7F and 7G.
The Off-Site Area, which is composed of the Califomia-Olive-Emerson (COE) Area
and the Perimeter Area, is bounded by California Avenue, Emerson Street, Margarita
Avenue and, generally, the boundary with the Varian Associates facility at 611
Hansen Way. The Off-Site Area excludes the 640, 601 and 395 on-site areas as
described above (Figure 2). _
2. Site History
Hewlett-Packard 640 Volatile organic compounds (VOCs), serhivolatile organics, and
metals were detected at this site. The source of VOCs and semivolatiles was
primarily from a 1,000 gallon steel underground waste solvent storage tank located
between building 11 and the storage building. Sources of metals at the site were
found in building 10, and were associated with acid neutralization sumps, piping, and
operations areas. All of these metal sources have been removed. The chemicals
detected most frequently at the site included gallium, arsenic, trichloroethene (TCE),
1,1,1-trichloroethane (1,1,1-TCA), and tetrachloroethene (PCE).
Varian 601 The most frequently detected chemicals at this site include TCE, 1,1,1-
TCA, and 1,1-dichloroethene (1,1-DCE). The sources of these chemicals come from
two main areas. The first is a chemical handling area at the southern corner of
Building 8. An above ground TCE tank was removed from this area in 1981. The
second source was a 2-foot diameter dry well in the courtyard area of Building 8.
The dry well was removed in 1990, at which time material at the bottom was found to
contain 3.6 percent TCE. The Board has not determined whether the dry well was
installed and used during Varian's or General Electric's occupancy of the site, nor has
the Board determined the extent to which the chemicals detected in soil or
ground water at that site were released during Varian's or General Electric's
occupancy.
page 2
-------
, Sitf Cleanup Requirements Order No. 94-130 September 21, 1994
Hewlett-Packard 640. JP5 Page Mill Road and Varian 601 California Avenue
Hewlett-Packard 395 The most frequently detected chemicals at this site include
TCE, 1,1,1-TCA, 1,1-DCE, and PCE. There were several potential source areas, the
most significant of which is located near the northeastern corner of the site. An
extensive excavation program in 1992 and 1993 removed or addressed all soil source
areas by excavation except the area near the northeast comer of the site. This area
will be addressed as part of the final remediation as addressed in mis Order.
Off-Site Area The most frequently detected VOCs in shallow groundwater in the Off-
Site Area include TCE, 1,1,1-TCA, 1,1-DCE, and PCE. Investigations were
completed in 1993 which defined the boundaries of this area. Other than the on-site
areas, the largest contributor of chlorinated solvents to this Off-Site Area is the
Varian 611 Hansen Way facility, which is not a part of this Order. This contributor
has up to three areas of major shallow groundwater contamination that are either very
close to or in the area designated as the Off-Site Area as defined in this Order. The
Varian 611 Hansen Way facility is currently regulated by the California Department
of Toxic Substances Control. Other sites within the Off-Site Area contribute less
extensive contamination (fuel and VOCs) to the groundwater. Some potential sources
in the Off-Site Area are identified in the Remedial Investigation (RI) Report.
In order for the remedial program required by this Order to be effective, all sources
of contamination to groundwater that affect groundwater within the COE and
Perimeter Areas must be identified and controlled. The Regional Board will utilize its
authority under applicable law to require potential sources within the area, other than
the Hewlett-Packard and Varian sites addressed in this Order, to be investigated and
controlled by parties other than HP and Varian and to require those parties to
coordinate their remedial activities with the activities to be carried out pursuant to this
Order. In order to facilitate the effective operation of the remedial systems required
by this Order, the Regional Board will provide Hewlett-Packard and Varian with
information concerning sources and remedial activities that may impact such systems.
3. Adjacent Sites The COE and Perimeter Areas are bordered on the south/southwest
side by research or manufacturing facilities that have or potentially have impacted
groundwater. The other three sides are residential areas that are not known to be
contributing to groundwater contamination. Investigations at the Varian 611 Hansen
Way site and the Aydin State Superfund site under the oversight of the California
Department of Toxic Substances Control have indicated that a significant contribution
of groundwater contaminants is entering the COE and Perimeter Areas from these
sites. Varian is currently developing plans for groundwater extraction at the 611
Hansen Way site, but has yet not completed a formal Remedial Action Plan. Other
sites from outside the COE and Perimeter Areas (including those named in the RI)
page 3
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Site Cleanup Requirements Order No. 94-130 September 21, 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
may be contributing to contamination, but these sites are viewed as not significant for
the purposes of commencing a groundwater cleanup as required in this Order.
4. National Priority List - "Sunerfund" On June 24, 1988, the U.S. Environmental
Protection Agency (EPA) proposed adding the HP 640 PMR facility to the National
Priority List (NPL), subject to the requirements of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA). Final listing was made on
February 1, 1990. The NPL site is defined as the vadose zone and contaminated
groundwater on the 640 site and commingled groundwater in the Off-Site Area.
The groundwater and vadose zone on the Varian 601 site is not part of the NPL site
but is addressed in this order. The vadose zone at the Hewlett-Packard 395 site is not
part of the NPL site but is addressed in this Order. The NPL provisions do not apply
to the areas covered in this Order that are not part of the NPL site.
Pursuant to the South Bay Multi-Site Cooperative Agreement and the South Bay
Groundwater Contamination Enforcement Agreement entered into by the Board, EPA
and the California Department of Toxic Substances Control (then DHS), the Board
has been acting as lead regulatory agency on this site. The Regional Board will
continue to regulate the dischargers' remediation consistent with CERCLA as
amended.
5. Regional Board Orders The Board has adopted the following orders for this site:
Company/Area Order No. (Type) Date Adopted
Hewlett-Packard/395 Page Mill 89-050 (SCR) 4-19-89
Hewlett-Packard/640 Page Mill 90-067 (SCR) 5-16-90
•89-037 (SCR) 3-15-89
•87-164 (SCR) joint 12-16-87
•87-142 (SCR) joint 10-21-87
•86-027 (WDR) 4-16-86
Varian Associates/601 California 90-066 (SCR) 5-16-90
•89-059 (SCR) 4-19-89
•87-164 (SCR) joint 12-16-87
•87-142 (SCR) joint 10-21-87
•87-039 (SCR) 4-15-87
* These Orders have been previously rescinded.
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Sitf Cleanup Requirements Order No. 94-130 September 21. 1994
Hr* kit-Packard 640, 395 Page Mill Rood and Varian 601 California Avenue
6. Geology The entire COE and Perimeter Areas are underlain by interbedded alluvial
fan deposits and fine-grained floodplain deposits. The alluvial fan deposits consist of
a mixture of sand, gravel, silt, and clay soils. The alluvium is derived from San
Francisquito and Matadero Creeks. The alluvial fans of these two creeks overlap
beneath the site and contain coarse-grained channel deposits with different directional
and spatial orientations. The coarse-grained units can be up to 20 feet thick. Both
the coarse-grained and fine-grained alluvial units may extend over distances of
thousands of feet.
The deeper floodplain deposits can be up to 23 feet thick and appear to be continuous
across the Area. The floodplain deposits are predominantly fine-grained and are
usually gray in color.
7. Soil and Source Investigation
Hewlett-Packard 640 Soil investigations began at the 640 site in 1981 after a 1,000
gallon underground solvent storage tank was discovered to be leaking between
building 11 and the storage building. Since then over 120 borings have been drilled
on-site. The contaminated soil was found surrounding and beneath manufacturing
areas, underground tanks, acid neutralization sumps, and storage areas, and resulted
from releases on-site. The chemicals detected most frequently in soil at the site were
arsenic, gallium, trichloroethene, 1,1,1-trichloroethane, 1,1-dichloroethene,
tetrachloroethene, 1,2,4-trichlorobenzene, and phenol.
Varian 601 Investigations were initiated at the 601 site in 1986 after a request from
the Regional Board. This investigation and a later soil gas investigation in 1987 ,
established the courtyard as the major source of VOC contamination of soils. During
this site investigation, 59 borings have been drilled on-site. A dry well in the
courtyard was determined to be the main source of chemicals, and the chemical
handling area in the southern corner of building 8 was determined to be a minor
source. Installation and use of the dry well may have occurred during General
Electric's occupancy of this site. The chemical handling area was in an area of fine-
grained sediments that absorbed VOCs, while the courtyard area was generally more
permeable. The chemicals detected most frequently in soil at the site are
trichloroethene, toluene, ethylbenzene and xylenes.
Hewlett-Packard 395 Soil investigations under the direction of the Board began at the
395 site in 1983 to investigate an underground waste solvent tank. Over 140 borings
have been drilled on-site and analyzed for metals, VOCs, and total petroleum
hydrocarbons. Seven major source areas were identified, including a drum storage
area, manufacturing areas, sumps and a storm drain. The storm drain source area in
D3EC 5
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
640. 395 Page Mill Road and Varian 601 California Avenue
the northeastern comer of the site released VOCs as a dense non-aqueous phase liquid
(DNAPL) to the soil and groundwater. The chemicals detected most frequently in the
soils at the site include trichloroethene, tetrachloroethene, ltl-dichloroethene, and
1,1,1 -trichloroethane.
8. Hvdrogeologv The COE and Perimeter Areas are underlain by two primary aquifers,
the upper A Aquifer and the lower B Aquifer. Each of these two aquifers contains
distinct sand zones. The A Aquifer extends up to 55 feet below ground surface, and
groundwater is first encountered at depths between 15 and 30 feet. Within the A
Aquifer, the Al Upper (A1U) Zone is generally found between depths of 15 and 30
feet, the Al Zone between 30 and 40 feet, and the A2 Zone between 40 and 55 feet.
The fine-grained aquitards separating the three zones range from 1 to 22 feet in
thickness and allow varying degrees of hydraulic communication through them. The
aquitard between the Al and A2 Zones is generally not present west of Page Mill
Road and beneath the 601 site.
The aquitard between the A and B Aquifers is approximately 12 to 23 feet thick and
is composed of gray silts and clays with fine sand. Within this aquitard are localized
sandy lenses which range between 0.5 and 2 feet in thickness. These lenses are
referred to as the A2 Deep (A2D) Zone.
Within the B Aquifer, the Bl Zone occurs below an approximate depth of 60 feet
below ground surface. This zone is typically about 10 feet thick. Where
encountered, the B2 Zone begins at approximately 85 feet below the surface and is
between 6 and 33 feet thick.
The general groundwater gradient in the A Aquifer is to the north-northeast.
Groundwater flow directions are influenced locally by the preferential flow through
relatively thick, transnu'ssive aquifer sands. In the A 1 Zone at certain locations,
groundwater and chemicals have been deflected toward the east along preferential
flow paths. This easterly deflection of chemicals is not evident in the A1U and A2
Zones.
9. Oregon Expressway Underpass This structure serves as a subsurface roadway
beneath the Southern Pacific Railroad tracks, Alma Street and Park Boulevard. The
underpass, built in 1958, extends 24 feet below ground surface into the A1U Zone.
A dewatering system installed beneath the underpass controls natural groundwater
inflow and surface runoff. This dewatering appears to affect groundwater flow in the
A1U, Al and A2 Zones and does not allow contaminants to bypass the subdrain to
the north.
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t Sue Cleanup Requirements Order No. 94-130 September 21, 1994
He*-lett-Padcard 640, 395 Page Mill Road and Varian 6O1 California Avenue
During the summer, the average rate of discharge is typically 140 gallons per minute
(gpm) with total VOC concentrations ranging between 200 and 300 parts per billion
(ppb). The discharge during winter consists of both surface water and ground water.
This significant local hydrologic feature acts to contain further migration of VOCs in
groundwater in the COE area and portions of the Perimeter area.
10. Groundwater Investigation
Hewlett-Packard 640 Groundwater investigations have been ongoing at the 640
facility since 1981 after the discovery of the leaking 1,000 gallon waste solvent tank.
Initial sampling of the groundwater beneath this tank found TCE (1,800,000 ppb) and
TCA (1,300,000 ppb) in the Al Zone groundwater. These concentrations indicate the
strong likelihood of DNAPL at the site at that time. However, DNAPL has not been
observed in either soil or groundwater at this site. Hewlett-Packard has installed and
currently maintains 28 groundwater monitoring wells and has advanced 21 CPTs on-
site. The chemicals detected most frequently in the groundwater beneath the 640 site
include TCE, 1,1,1-TCA , 1,1-DCE and PCE.
The A1U Zone is poorly developed at the 640 site and is currently unsaturated. The
aquitard separating the A1U and the Al Zones is approximately 6 feet thick. In the
central portion of the site, both the Al and A2 Zones are composed of clean sands
and gravel. The aquitard separating the Al and A2 Zones is between 1 and 5 feet
thick and does not exist at a few well locations.
The thick sands of the Al Zone trend east-west across the central portion of the 640
site and provide a preferential pathway for groundwater flow. The Al Zone sands'
grade fine-grained on the northern side of the site, which has the apparent effect of
deflecting groundwater flow and a portion of the VOCs toward the east. In contrast,
relatively thick A2 Zone sands occur below most of the 640 site, and groundwater
and VOCs flow north in the direction of the Oregon Expressway Underpass.
Varian 601 The 601 site initiated groundwater investigations in 1986 by installing
monitoring wells and presently has installed 22 groundwater monitoring wells and
advanced 20 CPTs on-site and on down-gradient adjacent properties. The highest
concentration of chemicals in the groundwater on-site are 43,000 ppb total VOCs in
the main source area and up to 26,000 ppb total VOCs from a well near the former
above ground tank in the chemical handling area. A sludge containing 3.6% TCE at
the bottom of the dry well in the courtyard area indicates that the presence of DNAPL
is possible. The chemicals most frequently detected in the groundwater beneath the
601 site include TCE, 1,1,1-TCA and 1,1-DCE .
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Site Cleanup Requirements Order No. 94-130 September 21.1994
He*-Utt-Padcard 640. 395 Page Mill Road and Varian 601 California Avenue
The A1U Zone is well developed on the eastern half of the property beneath a portion
of the courtyard where the dry well was located and nonexistent on the southwest
portion where the chemical handling area is situated. The Al and the A2 Zones are
in contact with no separating aquitard present. The lithologic data indicate thaf the
A1U and A1/A2 Zones contain a trough-like feature beneath the site which creates a
preferential flow path for groundwater and contaminants.
Hewlett-Packard 395 Groundwater investigations at the 395 site began in 1981 with
the investigation of a 1,000 gallon underground waste solvent tank which indicated no
release to groundwater. Since that time, Hewlett-Packard has installed and currently
maintains 18 groundwater monitoring wells and has advanced 31 CFTs on-site. These
wells have found relatively low concentrations of contamination in the groundwater
across the site, with the exception of the northeastern corner of the site where
DNAPL has been found in one well. Samples from the well where the DNAPL was
found indicate TCA (13,000 ppb) and PCE (39,000 ppb) are present in the A1U Zone
groundwater. The chemicals detected most frequently in the groundwater beneath the
395 site include TCE, TCA, and PCE.
The A1U Zone is present across the 395 site at irregular depths but is abruptly absent
on the northeastern side. Where present, the Al Zone is thin. The A2 Zone is
continuous throughout the 395 site. The Oregon Expressway Underpass dewatering
system, in combination with local irregular aquifer configurations, seems to have a
significant hydraulic influence on the groundwater beneath the site. Contamination in
the A1U, Al and A2 Zones beneath the 395 site appears to be drawn toward the
OEU.
Off-Site Area Investigation of the Off-Site Area began in 1985 near the 640 site.
Since then, 79 groundwater monitoring wells have been installed and are currently
maintained, and approximately 182 CPTs have been advanced in the Off-Site Area.
The chemicals detected most frequently in groundwater in the Off-Site Area A
Aquifer are TCE, 1,1,1-TCA, 1,1-DCE, and PCE. Contamination in the B Aquifer
is very minimal. The two main features other than the regional gradient that control
the distribution of contaminants in the A Aquifer are the Oregon Expressway
Underpass and the preferential flow paths created by the distribution of highly
transmissive zones within the aquifers.
VOCs are the most widely distributed in the A1U and Al Zones and together, the
extent of VOCs in these two zones defines the outline of the Off-Site Area covered by
this Order. The A1U is unsaturated over much of its western half. This unsaturated
portion has fluctuated with the amount of recharge and has been low in recent years
due to a lengthy drought.
moe
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8
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page MM Road and Varian 601 California Avenue
VOCs in the A1 Zone are present in the northern and southern halves of the Off-Site
Area with a region in the middle that is free of contaminants because of its low
permeability. The contaminants in the northern half are primarily derived from the
601, 640 and 395 sites. The contaminants on the southern half are derived primarily
from the 640 and Varian 611 Hansen Way sites.
The distribution of VOCs in the A2 Zone is more limited than the above Zones and is
primarily in the northern half of the Off-Site Area. The non-fuel VOC contamination
on the northern half is derived primarily from the 601 and 640 sites. The southern
half has limited contaminants that are derived from Varian 611 Hansen Way in
addition to other possible sites.
11. Interim Remedial Actions
Hewlett-Packard 640 Soil excavations between 1987 and 1992 have removed
approximately 7,700 cubic yards of contaminated soil to Class I landfills and
approximately 3,000 cubic yards to Class III landfills. Metal-contaminated soil at the
site has been excavated to background throughout the entire vadose zone where it was
present. All semi-VOCs above 10 ppm have been excavated. Residual VOCs remain
at the site above the remediation goal of 1 ppm and are being remediated by the 28-
well soil vapor extraction system which went on-line in April 1994.
Groundwater remediation on-site was initiated in 1982 for seven months. Extraction
was restarted in 1987 and has continued up to the time of this Order. During
redevelopment, temporary extraction wells were used in order to maintain continuous
contaminant removal. Groundwater extracted from on-site extraction wells EW-4, '
EW-5, and EW-7 in addition to off-site wells discussed below will be treated at the
640 site.
Varian 601 In 1990, the dry well in the courtyard, dry well contents, and soils in the
vicinity of the dry well were removed. In 1991, soil vapor extraction was initiated in
four wells to address contamination in the courtyard area. This was expanded in 1992
with 8 additional wells and in 1993 by adding two more wells in the area of the
chemical handling area. The use of one well was discontinued due to cleanup of
surrounding soils.
Groundwater extraction began at the 601 site in 1987 near the source area in the
courtyard. In 1991, an extraction well was installed near the former above ground
solvent tank in the chemical handling area. A third well was installed in a
downgradient area off-site in 1992. A fourth well is scheduled to begin extraction as
part of the off-site phased groundwater extraction program.
9
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Sue Cleanup Requirements Order No. 94-130 September 21. 1994
Medial-Packard 640, 395 Page Mill Road and Varian 601 California Avenue
Hewlett-Packard 395 Soil remediation at the ate was initiated in 1986 with the
operation of a SVE system at the 1,000 gallon underground storage tank. This
system was shut down in 1989 after concentrations of contaminants in the soil
dropped to acceptable levels. Site-wide soil excavation was conducted in 1992 and
1993 and removed 2,100 cubic yards. Additional contaminated soil exists and will be
remediated with the DNAPL area in the northeastern comer of the property as part of
future cleanup activities. Additional cleanup activities may be conducted during site
redevelopment scheduled to begin by 1995.'
Groundwater extraction well EW-11 was installed in 1992 in the northeast comer of
the site to remediate the A1U and Al Zones. Discovery of 12 inches of PCE and
TCA DNAPL in one of the nearby observation wells caused EW-11 to be abandoned
since it penetrated two aquifer zones. Since that time, the DNAPL- containing
observation well has been pumped to remove the DNAPL, and groundwater extraction
in this area has been temporarily delayed pending reevaluation of cleanup
methodologies. When groundwater treatment is initiated, it will likely take place at
the 395 site.
Off-Site Area Groundwater extraction in the Off-Site Area was initiated in 1988 on
the Mayfield school property by the installation of A1U wells EW-1 and EW-2. Off-
site extraction wells EW-8 through EW-11 and EW-13 have been installed. The
treatment system for 640 on-site and off-site wells EW-1, -2, -6, -8, -9, and -10 is
located on the 640 site. Extraction well EW-6 was placed in the A1/A2 Zone beneath
the Mayfield school property in 1992 to address elevated (10,000 ppb TCE)
concentrations of contaminants. Phased groundwater extraction for all off-site wells
is currently under way and is scheduled to be fully implemented by September 1994.
Groundwater from EW-13 will be treated at Building 1 at the Varian 611 Hansen
Way site. Regional groundwater extraction in the COE and Perimeter Areas and at
the Varian 611 Hansen Way site will be coordinated when additional extraction wells
to be located on-site at the Varian 611 site come on-line after September 1994.
12. Baseline Public Health Evaluation A Baseline Public Health Evaluation (BPHE),
dated September 1992, was prepared by EPA for the COE and Perimeter Areas to
evaluate current and potential future health risks posed by the site. Potential current
risks are estimated based on exposures that may be presently occurring. Potential
future health risks are based on exposures that potentially could occur in the future if
residential development occurs on the site or if untreated groundwater was used for
human consumption. To ensure that human health is protected, the BPHE
incorporated conservative assumptions. Therefore, it is very unlikely that the actual
risks posed by the site would be greater than estimated. Average case and maximum
case scenarios are presented in the BPHE. This finding refers to a 70 year duration
in -
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
He* leu-Packard 640, 395 Page Mill Road and Varian 601 California Avenue
exposure. The BPHE found that potential current exposures at the ate do not result
in a carcinogenic risk greater than 1 x 10"4. These exposures include inhalation of
indoor air on and off-site that could result from volatilization off of groundwater.
The potential noncarcinogenic hazard index estimated in the BPHE for inhalation of
vapor volatilizing off the groundwater ranged from less than 1.0 to 9. EPA
recommends that excess cancer risk not exceed a range of 1 x 104 to 1 x 10* and that
the non-carcinogenic hazard index not exceed 1.0
Potential future exposures if no cleanup were to occur could include ingestion of
groundwater, inhalation of vapor volatilized from on-site soil and groundwater or
inhalation of VOCs from domestic use of groundwater. Without cleanup, the..
maximum carcinogenic risk estimated in the BPHE to a future on-site resident (adult
or child) from ingestion of groundwater, inhalation of VOCs from the use of
groundwater and inhalation of vapor from volatilized soil and groundwater would be 1
x 10"3. The total potential noncarcinogenic hazard index for ingestion of shallow
groundwater and inhalation of VOCs from the use of groundwater was estimated to be
30.
Actual future risk is likely to be lower than these estimated potential risk numbers
because the assumptions on which these calculations are based are likely to
overestimate exposure. For example, these estimated risk calculations assume that the
highest chemical concentrations from the entire site area can be found in every well.
Therefore, for most of the plume area, including the Off-Site Area, chemical
concentrations actually measured are much lower than the concentrations used to
estimate these risks.
Finally, even using the conservative exposure scenarios of the BPHE, the actual risk
from exposure to groundwater will be much lower than the estimated risks because
HP and Varian are currently cleaning up the groundwater. HP and Varian's
comments on the BPHE are presented in Appendix L of the RI.
a. Chemicals of Concern Of the 34 chemicals detected in groundwater during the
Remedial Investigation, the chemicals of concern are those found to be present in
groundwater at concentrations exceeding maximum contaminant levels or detected at
concentrations that exceed the upper bound excess carcinogenic risk and/or exceed
non-carcinogenic health based values.
b. Toxicitv Classification of Chemicals of Concern The final list of chemicals of
concern for target cleanup levels in soil and groundwater are identified in the table
below.
page 11
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Siir Cleanup Requirements Order No. 94-130 September 21, 1994
Hewlett-Packard 640, 395 Page Mill Road and Varian 601 California Avenue
The EPA categories for carcinogenic classification as applied to the chemicals of
concern are: A (human carcinogen with sufficient evidence in human epkSemiological
studies), B2 (probable human carcinogen, with inadequate human evidence and
sufficient evidence from animal experiments), and C (possible human carcinogenL
limited evidence of carcinogenicity in animals with inadequate human data).
chemical
CARCINOGENS class
arsenic*
benzene A
1,1-dichloroethane (1,1-DCA) C
1,2-dichloroethane (1,2-DCA) B2
rir-l,2-dichloroethene (cw-l,2-DCE) C
methylene chloride B2
tetrachloroethene (PCE) B2
1,1,2-trichloroethane C
trichloroethene (TCE) B2
NON-CARCINOGENS
acetone
1,2-dichlorobenzene
1,1 -dichloroethene (1,1 -DCE)
mms-1,2 dichloroethene (trans-1,2 DCE)
freon 113
1,2,4-trichlorobenzene
1,1,1-trichloroethane (1,1,1-TCA)
toluene*
total xylenes*
* Chemical found only in soil
13. Remedial Investigation / Feasibility Study / and Final Remedial Action Plan
Hewlett-Packard and Varian Associates completed a first draft Remedial
Investigation/Feasibility Study (RI/FS) in April 1991. After additional work, a
second draft was submitted in June 1993. Comments by Board staff have been
incorporated in a final Rl/FS dated May 1994. The technical information contained
page 12
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
He*-lett~Padtard 640. 395 Page Mill Road and Varian 601 California Avenue
in the RI/FS is consistent with the Health and Safety Code requirements for a final
remedial action plan and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) requirements for a RI/FS. Regional Board staff have
determined that the technical information contained in the Feasibility Study is
acceptable for developing a final cleanup plan for the site. The FS contains an
evaluation of ARARs, a discussion of interim remedial actions, an evaluation of final
remedial actions, and proposed remedial standards. The final Remedial Action Plan
for the site will consist of this Order, the Remedial Investigation/Feasibility Study,
and the Regional Board Proposed Plan Fact Sheet.
14. Remedial Alternatives The Feasibility Study identified a range of general response
actions and remedial technologies. Three remedial alternatives were developed and
evaluated: 1) no action, 2) continuation of current groundwater and soil vapor
extraction, and 3) additional groundwater extraction and continuation of soil vapor
extraction. All scenarios include continued operation of the Oregon Expressway
Underpass. A complete description of these alternatives is contained in the Feasibility
Study.
15. Summary of Evaluation Criteria EPA's National Contingency Plan identifies nine
evaluation criteria to be used to evaluate remedial alternatives (40 CFR 300.430). The
RI/FS contained a detailed evaluation using these nine criteria as well as similar
criteria found in Section 25356.1 of the California Health and Safety code. The nine
criteria are:
Overall protection of human health and the environment This criterion addresses ,
whether a remedy provides adequate protection of human health and the environment.
Compliance with applicable or relevant and appropriate requirements (ARARsI This
criterion addresses whether a remedy will meet all of the ARARs or other Federal and
State environmental laws. ARARs for the site are discussed in detail in the RI/FS.
Long-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.
Reduction of toxicity, mobility or volume This criterion refers to the anticipated
performance of the treatment technologies a remedy may employ.
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
He*-leti-Packard 640. 395 Page Mill Head and Varian 601 California Avenue
Short-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.
Implementability This criterion refers to the technical and administrative feasibility of
a remedy.
Cost This criterion includes estimated capital and operation and maintenance costs,
usually presented in a 30 year present worth format.
Support Agency Acceptance This criterion addresses EPA's acceptance of the
selected remedy and any other EPA comments.
Community Acceptance This criterion summarizes the public's general response to
the alternatives.
16. Selected Final Remedy The selected remedy is Alternative 2, for the reasons stated
in Finding 17. Alternative 2 includes the following elements:
a. Soil The chosen alternative consists of operating the existing vapor extraction
wells at the 640, 395 and 601 sites. Additional soil vapor extraction wells may be
needed in the northeastern comer of the 395 site. The soil vapor wells will continue
to operate until levels of 1 mg/kg total VOCs are achieved, unless the discharger can
demonstrate that a proposed alternative level will be protective of human health and
the environment. In addition, when areas beneath existing structures at the 395 and
601 sites become accessible, additional characterization and reevaluation of
alternatives to meet the 1 ppm total VOC cleanup standard may be required.
b. Groundwater Operation of the current groundwater extraction system will
continue with additional wells to capture and treat contaminated groundwater until
drinking water quality is achieved, or until groundwater cleanup standards are
modified as described in Findings 19 and 20. As outlined in the Feasibility Study,
additional extraction wells will be added near the Lockheed-occupied site and near
Lambert and Ash and Portage and Ash. The estimated time to achieve groundwater
cleanup is unknown. The estimated 30 year present worth cost is $15.5 million.
Groundwater will be treated at the 640 site, the 601 site, the 395 site, and the Varian
611 Hansen Way site. Reuse of water will be attempted as much as possible in
accordance with Board Resolution 88-160.
14
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Site Cleanup Requirements Order No. 94-130 September 21, 1994
He* leu-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
Long term monitoring will be required after cleanup levels are achieved. The duration
and complexity of the monitoring will be determined at that time.
A deed restriction will be filed by HP for the 395 site and by Stanford University for
the 640 site and the 601 site in their capacity as landowners, prohibiting use of on-site
groundwater for drinking water until final cleanup standards are achieved.
17. Remedy Selection Rationale and Statutory Determinations
a. BASIS FOR REJECTION
Alternative 1: Continued Operation of Current Extraction Wells; Groundwater
Monitoring; No Further Action Regarding Vadose Zone Soils
This alternative has been rejected because it may allow some groundwater containing
chemicals above cleanup standards to migrate beyond the estimated capture zone of
the overall remediation system. In addition, chemicals remaining in soils may
migrate downward and impact groundwater.
Alternative 3: Expanded Groundwater Extraction and Treatment
Groundwater Monitoring Continues.
This alternative has been rejected because the additional cost of implementation is not
justified.
b. BASIS FOR ACCEPTANCE
Alternative 2; Expanded Groundwater Extraction and Treatment and Existing
Soil Vapor Extraction. Groundwater Monitoring Continues.
Overall Protection of Human Health and the Environment
Constituents in groundwater are contained within a defined area and contaminated
groundwater is properly treated and released, under permit. Extraction, treatment, and
disposal provides for the future protection of human health and the environment.
Compliance with ARARs
The cleanup goal for groundwater cleanup is the State or Federal MCL, whichever is
more stringent. The goal of this remedial action is to restore groundwater to its
beneficial uses.
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hf^lett-Packard 640, 395 Page Mill Road and Varian 601 California Avenue
Long Term Effectiveness
Once chemical concentrations in groundwater and soils are reduced to cleanup
standards, potential long-term risks identified in the BPHE are reduced. Treatment
residuals are treated and disposed of off-site with appropriate controls in permitted
facilities, thus reducing the potential risk of exposure. Long term management plans
include continued groundwater monitoring. The FS estimates that the time to reach
MCL standards in groundwater is at least 30 years.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Expanded groundwater extraction, treatment, and soil vapor extraction facilities will
decrease the volume of the chemicals of concern in the groundwater and the toxicity
of the groundwater.
Short Term Effectiveness
Risks of worker exposure to chemicals during system installation and operation are
minimal, and safety measures will be implemented. No environmental impacts or
potential risks to the community are expected. Short term operation of the
groundwater extraction wells will contain the groundwater contamination in a defined
area and result in decreased concentrations of the chemicals of concern. Vapor
extraction from soils will enhance removal of contaminants and prevent additional
groundwater from becoming contaminated. Evaluation of the effectiveness of
extraction, treatment, and discharge will occur periodically in accordance with the'
agency requirements.
Implementability
The groundwater extraction, treatment, and discharge alternative is being implemented
at the 640 and 601 sites and in the Off-Site Area. Implementation in other areas is
also achievable.
Cost
Present value costs for the selected alternative as presented in the RI/FS are
$15.5 million over 30 years, which includes installation of additional wells and
operation and maintenance of the entire system.
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Silt Cleanup Requirements Order No. 94-130 September 21. 1994
He*-len~Packard 640. 395 Page Mitt Road and Varian €01 California Avenue
Support Agency Acceptance
Groundwater and soil vapor extraction, treatment, and discharge will likely be
acceptable to all involved agencies.
Community Acceptance
Community response to groundwater extraction and treatment, and soil vapor
extraction were considered in choosing the proposed alternative. Hie community
supports these methods of treatment.
18. Cleanup Standards The groundwater cleanup standards for the site are U.S.
Environmental Protection Agency MCLs, California Department of Health Services
MCLs or, for acetone, a target level based on toxicity characteristics published by
EPA. Applicable MCL Goals (i.e., greater than zero) are met by the cleanup
standards required by this Order.
Groundwater extraction will continue until drinking water quality is achieved, if
feasible. If these standards are determined to be infeasible, groundwater extraction
shall continue as long as significant quantities of chemicals are being removed through
groundwater extraction. Achieving drinking water quality is an ARAR for this site.
If drinking water quality cannot be achieved, the dischargers must demonstrate to the
satisfaction of the Regional Board and EPA that the conditions for waiving an ARAR
are met (e.g., that meeting the ARAR is technically impracticable from an
engineering perspective) and that the alternative proposed will be protective of human
health and the environment. The Order will then need to be modified by the Regional
Board and, to the extent the modification affects the NPL Site, the US EPA Record of
Decision (ROD) will need to be modified by EPA to allow a less stringent
groundwater cleanup level.
The soil cleanup standard of 1.0 mg/kg for total VOCs is intended to prevent leaching
of VOCs to groundwater at a level which would result in concentrations of VOCs in
groundwater in excess of MCLs, thereby protecting groundwater quality.
19. Risks Associated with Cleanup Standards The selected remedy is protective of
human health and the environment, as required by Section 121 of CERCLA. EPA
considers a carcinogenic risk range of 1 x 10"* to 1 x 10"6 as acceptable. If the
noncarcinogenic Hazard Index is less than 1, EPA considers the combined intake of
chemicals unlikely to pose a health risk.
The cleanup standards for the COE and Perimeter Areas are protective of human
health, have a carcinogenic risk that falls within a range of 1 x 10"4 to 1 x 10*. and a
naee 17
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Sue Cleanup Requirements Order No, 94-130 September 21, 1994
He»-lett-Packard 640. 395 Page Mill Road and Vartan 601 California Avenue
Hazard Index of less than 1. The method and assumptions used to obtain the
Carcinogenic Risk and Hazard Index associated with the cleanup standards are
contained in the RI/FS and the BPHE.
20. Uncertainty in Achieving Cleanup Standards The goal of this remedial action is to
restore groundwater to its beneficial uses. Based on information obtained during the
RI and a careful analysis of all remedial alternatives, the Board believes that the
selected remedy will achieve this goal. However, studies at other sites suggesfthat
groundwater extraction and treatment 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 MCL-based groundwater quality standards
using this approach. If it becomes apparent during implementation of this system that
contaminant levels have ceased to decline and are remaining at levels higher than the
remedial standards, or if the data otherwise suggest that achievement of the standards
is technically impracticable or cannot be achieved within a reasonable time frame, the
standards and remedy may be reevaluated.
21. Future Changes to Cleanup Standards If new information indicates cleanup
standards cannot be attained or can be surpassed, the-Board and EPA will decide if
funher final cleanup actions, beyond those completed, shall be implemented at this
Site. If changes in health criteria, administrative requirements, site conditions, or
remediation efficiency occur, then the dischargers may, or at the request of the
Executive Officer shall, submit an evaluation of the effects of these changes on the
cleanup standards defined in Specification B.3 and 4.
f
The Regional Board recognizes that the dischargers have already performed extensive
investigative and remedial work and that the dischargers 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 Regional Board recognizes 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 Regional 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 Regional Board has considered and balanced these important considerations, and
has determined that the remedial actions ordered herein represent the Regional
page »o
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
Board's best, current judgment of the remedial actions to be required of the
dischargers. The Regional 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 Regional Board, are
discovered after adoption of this Order, or (2) new information is received by the*
Regional 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 Regional Board will also consider technical practicality, cost effectiveness, State
Board Resolution No. 68-16 and other factors evaluated by the Regional Board-in
issuing this Order and in determining whether such additional remedial actions are
appropriate and necessary.
22. Named Dischargers Hewlett-Packard Company (herein referred to as a discharger)
is a discharger because of the release of chemicals that have resulted from its facilities
at 640 Page Mill Road and 395 Page Mill Road, and because it owns the property at
395 Page Mill Road. Varian Associates (herein referred to as a discharger) is a
discharger because of the releases of chemicals that have occurred at 601 California
Avenue. Stanford University (hereinafter referred to as a discharger) is a discharger
because it owns the property at 640 Page Mill Road and 601 California Avenue.
Stanford University (secondarily responsible) will be responsible for performance of
Tasks 1A, 2A, 9A, 10A, and 17 below and for compliance with the remaining Tasks
associated with the 640 site, 601 site and off-site area only in the event that Hewlett-
Packard and/or Varian Associates (primarily responsible, as applicable) fail to comply
with the requirements of this Order.
f
If additional information is submitted indicating that any other party caused or
permitted any waste to be discharged in the COE or Perimeter Areas or in any
adjacent area where the waste entered or could have entered waters of the State, the
Board will consider adding that party's name to this Order.
23. Joint Order This Order is written as a joint Order for 640 Page Mill Road, 601
California Avenue, and 395 Page Mill Road because the groundwater plumes from
these source areas have commingled. The dischargers are encouraged to submit joint
reports for the Off-Site Area. If joint reports are not submitted, the individual
dischargers are still responsible for the joint tasks in this Order.
24. Potentially Responsible Parties Results of the Potentially Responsible Party (PRP)
search pursuant to Health and Safety Code Section 25356.1 are that Hewlett-Packard
Company and Varian Associates are potentially responsible parties (and therefore are
named as dischargers) associated with the releases of pollutants previously discussed
naoe 1Q
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page Mitt Road and Varian 601 California Avenue
in this Order. Stanford University is also a potentially responsible party (and also a
named discharger) because it both (i) is the current owner of the 601 California
Avenue and 640 Page Mill Road properties at which pollutants are currently located
and (ii) was the owner of the above mentioned properties where the previously
discussed releases of pollutants have occurred in the past. However, nothing in these
findings or in this Order shall limit the rights or abilities of these parties to identify
other potentially responsible parties for purposes of cost recovery under any
applicable law.
25. Non-Binding Allocation of Responsibility (NEAR) Section 25356. 1 of the ..
California Health and Safety Code requires a final remedial action plan (RAP) to
include a non-binding allocation of responsibility (NEAR) among all identifiable
potentially responsible parties at the site. Any potentially responsible party or
combination of parties assigned more than 50% of the liability in the NEAR may seek
binding arbitration to allocate the costs of implementing the selected remedy (see
Section 25356.3).
26. 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 amended) by the Regional Board, EPA, and DTSC, the Regional
Board has been acting as the lead agency. EPA is expected to agree with the remedy
selected and issue a Record of Decision following adoption by the Regional Board of
the final remedy for the site. The Regional Board will continue to regulate the
dischargers1 remediation and administer enforcement actions in accordance with
CERCLA (as amended by SARA), the California Water Code, the California Health
and Safety Code, and regulations adopted thereunder.
27. Deed Restrictions By a letter submitted by Hewlett-Packard dated September 7,
1994 and a letter from Varian dated August 12, 1994, both companies have notified
current tenants and will notify future tenants as to the location of hazardous materials
in the subsurface and the potential health hazards associated with such materials.
28. Administrative Record The Administrative Record for the NPL site has been
prepared in accordance with EPA guidance, has been made available for public and
PRP review, and provides the backup documentation for recommendations of staff
and decisions by the Board. The administrative record is available for review at the
Water Board offices in Oakland and important documents are available at the US
Geological Survey, 345 Middlefield Road in Menlo Park.
29. Community Involvement An aggressive community involvement program has been
ongoing for the Hewlett-Packard and Varian sites named in this Order. The Board
20
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Silt Cleanup Requirements Order No. 94-130 September 21.1994
He*-leti-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
published a notice in the July 15, 1994 issue of the Palo Alto Weekly announcing the
proposed final Remedial Action Plan and opportunity for public comment at the Board
hearing of July 20, 1994 in Oakland, and announcing the opportunity for public
comment at an evening community meeting to be held at the Escondido School in
Palo Alto on July 26, 1994. A presentation of the proposed final cleanup plan was
made at the September 21, 1994 Board meeting and the July 26, 1994 evening
community meeting. The 30 day comment period was from July 20 to August 19,
1994.
Since 1989, five fact sheets have been mailed to interested residents, local
government officials, and media representatives. Fact sheet 1, mailed in September,
1989 summarized the contamination problems at 640 and described interim cleanup
actions. A second fact sheet published in January 1990 listed revisions to the original
investigation and cleanup schedule and included 601 information. The third fact
sheet, published in December 1991, summarized the results of additional investigation
at the site as well as interim cleanup actions. The fourth fact sheet of October, 1992
described the health assessment and the further definition of the plume. Fact sheet 5
was mailed out in June and explained the final proposed plan for site cleanup.
The Barren Park Association Foundation, an active community group in the area, has
been given a Technical Assistance Grant by the US EPA to help assist the community
examine technical documents regarding investigation and cleanup of the site.
30. State Water Resources Control Board Resolution No. 68-16 On October 28, 1968,
the State Board adopted Resolution 68-16, "Statement of Policy with Respect to
Maintaining High Quality Waters in California." This policy calls for maintaining'the
existing high quality of State waters unless it is demonstrated that any change would
be consistent with the maximum public benefit and not unreasonably affect beneficial
uses. The original discharge of waste to groundwater at this site was contrary to this
policy. Therefore, the groundwater quality needs to be restored to its original quality
to the extent reasonable. Shallow groundwater at the site is designated as a potential
source of drinking water. For this reason, MCLs are acceptable as concentrations
that meet the intent of Resolution 68-16.
31. Regional Board Resolution No. 88-160 This resolution strongly encourages the
maximum feasible reuse of extracted groundwater from groundwater remediation
activities, either by the discharger or by other public or private water users.
Currently, treated groundwater from interim groundwater remediation at 640 Page
Mill Road and 601 California Avenue that is not reused for irrigation and/or gray
water is discharged to the sanitary sewer, and is available for reuse as effluent from
the Palo Alto sewage treatment plant. Hewlett-Packard has conducted a reuse study
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Site Cleanup Requirements Order No. 94-130 September 21, 1994
Hr*-lt:t-Packard 640, 395 Page Mill Road and Varian 601 California Avenue
for its existing and planned groundwater treatment facilities at 395 and 640 Page Mill
Road, and Varian has conducted a similar reuse study for 601 California Avenue.
The Board will assess future compliance with this resolution if and when the
dischargers apply to discharge treated groundwater to surface waters.
32. Water Quality Control Plan The Board adopted a revised Water Quality Control
Plan for the San Francisco Bay Basin (Basin Plan) on December 17, 1986, and the
State Board approved it on May 21, 1987. The Basin Plan contains water quality
objectives and beneficial uses of surface and ground waters.
The existing and potential uses of groundwater underlying and adjacent to the site
include:
a. Industrial process water supply
b. Industrial service water supply
c. Municipal and domestic water supply
d. Agricultural water supply
Shallow groundwater underlying and adjacent to the site is currently not used for any
of the above uses.
33. The dischargers have caused or permitted, and threaten 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.
t
34. 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 California
Environmental Quality Act (CEQA) pursuant to Section 15321 of the Resources
Agency Guidelines.
35. The Board has notified the dischargers and interested persons and agencies of its
intent under California Water Code Section 13304 to prescribe Site Cleanup
Requirements for the discharge and has provided them with the opportunity for a
public hearing and an opportunity to submit their written views and recommendations.
36. The Board, in a public meeting, heard and considered all comments pertaining to the
discharge.
oage 22
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Site Cleanup Requirements Order No. 94-130 September 27. 1994
Hewlett-Packard 640. 395 Page Mitt Road and Varian 601 California Avenue
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
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 transport to
waters of the State is prohibited.
3. Activities associated with subsurface investigation and cleanup which will
cause significant adverse migration of pollutants are prohibited.
B. SPECIFICATIONS
1. The storage, handling, treatment, or disposal of soil or groundwater containing
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 determined 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 plume migration, additional
characterization of the pollutant plume may be required.
3. Groundwater cleanup standards for all SMP wells are set forth in Table 1.
4. The soil cleanup standard is 1 ppm for total VOCs.
5. The dischargers shall implement the final cleanup plan as described in Finding
16.
6. Cost Recovery: Pursuant to Section 13304 of the California Water Code, the
dischargers are hereby notified that the Board is entitled to, and may seek
reimbursement of, all reasonable costs actually incurred by the Board to
investigate unauthorized discharges of waste and to oversee cleanup of such
waste, abatement of the effects thereof, or other remedial action, as required
by this Order.
oaee 23
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Site Cleanup Requirements Order No. 94-130 September 21.1994
He*-len-Padcard 640. 395 Page Mill Road and Varian 601 California Avenue
C. PROVISIONS
1. The dischargers shall comply with the attached Self-Monitoring Program.
2. The dischargers shall comply with this Order immediately upon adoption and
shall comply with the Prohibitions and Specifications described above in
accordance with the following tasks and compliance dates. With regard to the
640 Page Mill Road site, the 601 California Avenue site, and the Off-Site
Area, in the event that Hewlett-Packard and/or Varian Associates, as
applicable, fail to comply with this Order, the Executive Officer may notify
Stanford University and Stanford University shall be responsible for
compliance.
3. HEWLETT-PACKARD 640 PAGE MILL ROAD ON-S1TE
(Hewlett-Packard and Stanford University)
a. COMPLETION DATE: December 1, 1994
TASK1: PROPOSED CONSTRAINTS: Stanford University shall submit a
technical report acceptable to the Executive Officer documenting procedures to
be implemented for a deed restriction for the 640 site prohibiting the use of
on-site contaminated groundwater as a source of drinking water. The
Executive Officer may approve an alternative mechanism if it accomplishes the
same function as a deed restriction. Constraints shall remain in effect until
groundwater cleanup standards have been achieved and pollutant levels have
stabilized in the aquifers beneath the site. '
b. COMPLETION DATE: Before building occupancy by new tenant
TASK 2: PROPOSED CONSTRAINTS: Hewlett-Packard shall submit a
technical report acceptable to the Executive Officer documenting that Hewlett-
Packard has notified future tenants as to the locations of hazardous materials in
the subsurface and the potential health hazards associated with such materials.
page 24
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Siif Cleanup Requirements Order No. 94-130 September 21. 1994
He»-lett-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
c. COMPLETION DATE: 60 days after Executive Officer's approval of
above task.
TASK 3: IMPLEMENT CONSTRAINTS: Stanford University shall submit
a technical report acceptable to the Executive Officer documenting that a deed
restriction or alternative approved constraints have been implemented.
d. COMPLETION DATE: July 1, 1995
TASK 4: EVALUATE EFFECTIVENESS OF SOIL VAPOR
EXTRACTION SYSTEM: Hewlett-Packard shall submit a technical report
acceptable to the Executive Officer which documents implementation of the
approved SVE system, which is described in the Feasibility Study, evaluates
effectiveness of the entire soil vapor extraction system, and proposes
modifications to the system, if necessary, and a time schedule to accomplish
the cleanup standard. This evaluation should include the installation of soil
vapor monitoring devices needed to assess the effectiveness of the soil vapor
extraction system.
e. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer.
TASKS: START-UP OF MODIFICATIONS TO SOIL VAPOR
EXTRACTION SYSTEM: Hewlett-Packard shall submit a technical report
acceptable to the Executive Officer documenting completion of any
modifications identified in the above Task.
f. COMPLETION DATE: 60 days prior to proposed curtailment of any
soil vapor extraction well or soil vapor
treatment system.
TASK 6: SOIL VAPOR WELL EXTRACTION CURTAILMENT
CRITERIA AND PROPOSAL: Hewlett-Packard shall submit a technical
report acceptable to the Executive Officer containing a proposal and time
schedule for curtailment (i.e., termination or significant reduction of pumping
rate) from any soil vapor extraction well(s) or piping and the criteria used to
justify such curtailment. If the reason for curtailment is achievement of final
cleanup standards, then the report shall include a proposal indicating the
page 25
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Siic Cleanup Requirements Order No. 94-130 September 21, 1994
Hewlett-Packard 640. 395 Page Mitt Road and Varian 601 California Avenue
methods for determining concentrations of VOCs remaining in the soil. The
proposal may include termination of soil vapor extraction well operation for
an extended period of time to study the effects on chemical migration prior to
well abandonment. The proposal shall include a schedule for implementation.
If the dischargers claim that it is not practicable to achieve cleanup standards
through continued soil vapor extraction in all or any portion of the
contaminated soil area and that significant quantities of chemicals are not being
removed through soil vapor extraction, the dischargers shall evaluate the
reductions in chemical concentrations and alternative cleanup standards that
can be practicably achieved. The report shall evaluate alternative means of
achieving cleanup standards, whether meeting the cleanup standard is
technically impracticable and whether the alternative cleanup standard
proposed will be protective of human health and the environment.
g. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer
TASK 7: IMPLEMENTATION OF CURTAILMENT AND
COMPLETION OF SOIL REMEDIATION: Hewlett-Packard shall submit a
technical report acceptable to the Executive Officer documenting completion of
the necessary tasks identified in the technical report submitted for the above
task. This report shall include the results of any chemical analyses performed.
h. COMPLETION DATE: 60 days prior to proposed curtailment of any
groundwater extraction well or groundwater
treatment system.
TASK 8: GROUNDWATER EXTRACTION CURTAILMENT
CRITERIA AND PROPOSAL: Hewlett-Packard shall submit a technical
report and time schedule acceptable to the Executive Officer containing a
proposal for curtailing pumping from any groundwater extraction well(s) and
the criteria used to justify such curtailment. This report may include data to
show that groundwater cleanup standards for all VOCs have been achieved and
that pollutant levels have stabilized or are stabilizing, and that the potential for
pollutant levels rising above cleanup standards is minimal. Curtailment of
groundwater extraction means final shutdown of the system, a phased approach
to shutdown, elimination of pumping in selected wells (including pulsed
pumping), or a similar significant change to the system. In the case of final
page 26
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Siif Cleanup Requirements Order No. 94-130 September 27. 1994
Hewlett-Packard 640. 395 Page Mitt Road and Varian 601 California Avenue
shutdown of any portion of the system, the report shall identify the basis for
the time frame that will be used to confirm that groundwater concentrations
have stabilized at or below final cleanup standards and that the potential for
increases above cleanup standards is minimal in that portion of the system.
Any proposal to implement final shutdown of the system is subject to approval
by the Board, and any proposal to implement a phased approach to shutdown
or to eliminate the pumping in selected wells shall be subject to the approval
of the Executive Officer and, if requested by the Executive Officer, the Board.
If the dischargers claim that it is not practicable to achieve cleanup standards
through continued groundwater extraction in all or any portion of the
groundwater plume area, the dischargers shall evaluate the reductions in
chemical concentrations, the mass quantities being removed through
groundwater extraction, and alternative cleanup standards that can be
practically achieved. The report shall evaluate alternative means of achieving
cleanup standards, whether meeting the cleanup standards is technically
impracticable, cost effectiveness and whether the alternative cleanup standard
proposed will be protective of human health and the environment.
i. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer
TASK 9: IMPLEMENTATION OF GROUNDWATER EXTRACTION
CURTAILMENT: Hewlett-Packard shall submit a technical report acceptable
to the Executive Officer documenting completion of the necessary tasks
identified in the technical report submitted for the above task.
4. VARIAN 601 CALIFORNIA AVENUE ON-SITE
(Varian Associates and Stanford University)
a. COMPLETION DATE: December 1, 1994
TASK 10: PROPOSED CONSTRAINTS: Stanford University shall submit
a technical report acceptable to the Executive Officer documenting procedures
to be implemented for a deed restriction for the 601 site prohibiting the use of
on-site contaminated groundwater as a source of drinking water. The
Executive Officer may approve an alternative mechanism if it accomplishes the
same function as a deed restriction. Constraints shall remain in effect until
page 27
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Siie Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640, 395 Page Mill Road and Varian 601 California Avenue
groundwater cleanup standards have been achieved and pollutant levels have
stabilized in the aquifers beneath the site.
b. COMPLETION DATE: 30 days following reciept of written notice to
Varian of building occupancy by new tenant.
TASK 11: PROPOSED CONSTRAINTS: Varian Associates shall submit a
technical report acceptable to the Executive Officer documenting that Varian
has notified future tenants as to the locations of hazardous materials in the
subsurface and the potential health hazards associated with such materials.
c. COMPLETION DATE: 60 days after Executive Officer's approval of
above task.
TASK 12: IMPLEMENT CONSTRAINTS: Stanford University shall
submit a technical report acceptable to the Executive Officer documenting that
a deed restriction or alternate approved constraints have been implemented.
d. COMPLETION DATE: July 1, 1995
TASK 13: EVALUATE EFFECTIVENESS OF SOIL VAPOR
EXTRACTION SYSTEM: Varian Associates shall submit a technical report
acceptable to the Executive Officer which documents implementation of the
expanded SVE system, evaluates effectiveness of the entire soil vapor
extraction system, and proposes modifications to the system and a time
schedule, if necessary, to accomplish the cleanup standard and a time
schedule. This evaluation should include soil vapor monitoring devices
needed to assess the effectiveness of the soil vapor extraction system.
e. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer.
TASK 14: START-UP OF MODIFICATIONS TO SOIL VAPOR
EXTRACTION SYSTEM: Varian Associates shall submit a technical report
acceptable to the Executive Officer documenting completion of any
modifications identified in the above Task.
page 28
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Site Cleanup Requirements Order No. 94-130 September 21, 1994
Hewlett-Packard 640. 395 Page Mitt Road and Varian 601 California Avenue
f. COMPLETION DATE: 60 days prior to proposed curtailment of any
soil vapor extraction well or soil vapor
treatment system.
TASK 15: SOIL VAPOR WELL PUMPING CURTAILMENT CRITERIA
AND PROPOSAL: Varian Associates shall submit a technical report
acceptable to the Executive Officer containing a proposal for curtailment (i.e.,
termination or significant reduction of pumping rate) from any soil vapor
extraction well(s) or piping and the criteria used to justify such curtailment. If
the reason for curtailment is achievement of final cleanup standards, then the
report shall include a proposal indicating the methods for determining
concentrations of VOCs remaining in the soil. The proposal may include
termination of soil vapor extraction well operation for an extended period of
time to study the effects on chemical migration prior to well abandonment.
The proposal shall include a schedule for implementation.
If the dischargers claim that it is not practicable to achieve cleanup standards
through continued soil vapor extraction in all or any portion of the
contaminated soil area and that significant quantities of chemicals are not being
removed through soil vapor extraction, the dischargers shall evaluate the
reductions in chemical concentrations and alternative cleanup standards that
can be practicably achieved. The report shall evaluate alternative means of
achieving cleanup standards, whether meeting the cleanup standard is
technically impracticable, cost effective, and whether the alternative cleanup
standard proposed will be protective of human health and the environment.
g. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer
TASK 16: IMPLEMENTATION OF CURTAILMENT AND
COMPLETION OF SOIL REMEDIATION: Varian Associates shall submit
a technical report acceptable to the Executive Officer documenting completion
of the necessary tasks identified in the technical report submitted for the above
task. The report shall include the results of any chemical analyses performed.
29
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page Mitt Road and Varian 601 California Avenue
h. COMPLETION DATE: 60 days prior to proposed curtailment of any
groundwater extraction well or groundwater treatment system.
TASK 17: GROUNDWATER EXTRACTION CURTAILMENT
CRITERIA AND PROPOSAL: Varian Associates shall submit a technical
report acceptable to the Executive Officer containing a proposal for curtailing
pumping from any groundwater extraction well(s) and the criteria used to
justify such curtailment. This repon shall include data to show that
groundwater cleanup standards for all VOCs have been achieved and that
pollutant levels have stabilized or are stabilizing, and that the potential for
pollutant levels rising above cleanup standards is minimal. Curtailment of
groundwater extraction means final shutdown of the system, a phased approach
to shutdown, elimination of pumping in selected wells (including pulsed
pumping), or a similar significant change to the system. In the case of final
shutdown of any portion of the system, the report shall identify the basis for
the time frame that will be used to confirm that groundwater concentrations
have stabilized at or below final cleanup standards and that the potential for
increases above cleanup standards is minimal in that portion of the system.
Any proposal to implement final shutdown of the system is subject to approval
by the Board, and any proposal to implement a phased approach to shutdown
or to eliminate the pumping in selected wells shall be subject to the approval
of the Executive Officer and, if requested by the Executive Officer, the Board.
If the dischargers claim that it is not practicable to achieve cleanup standards
through continued groundwater extraction in all or any portion of the
groundwater plume area, the dischargers shall evaluate the reductions in
chemical concentrations, the mass quantities being removed through
groundwater extraction, and alternative cleanup standards that can be
practically achieved. The report shall evaluate alternative means of achieving
cleanup standards, whether meeting the cleanup standards is technically
impracticable, cost effectiveness, and whether the alternative cleanup standard
proposed will be protective of human health and the environment.
ih. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer
TASK 18: IMPLEMENTATION OF GROUNDWATER EXTRACTION
CURTAILMENT: Varian Associates shall submit a technical report
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Site Cleanup Requirements Order No. 94-130 , September 21. 1994
Hr*-lett-Padcard 640. 395 Page Mill Road and Varian 601 California Avenue
acceptable to the Executive Officer documenting completion of the necessary
tasks identified in the technical report submitted for the above task.
COMPLETION DATE: 15 days following written notice to Stanford
University of planned building demolition
TASK 19: NOTICE OF PLANNED BUILDING DEMOLITION:
Stanford University shall provide the Executive Officer and Varian Associates
with written notice of planned building demolition on the 601 site.
k. COMPLETION DATE: 45 days following receipt of written notice from
Stanford University of planned building
demolition (or as determined, in coordination
with proposed redevelopment activities).
TASK 20: PROPOSAL FOR INVESTIGATION OF AREAS EXPOSED
BY BUILDING DEMOLITION: Varian Associates shall submit a technical
report acceptable to the Executive Officer proposing a sampling schedule for
areas which have previously been inaccessible beneath on-site buildings
because of physical or operational constraints. This includes areas which could
potentially impact groundwater or the environment and were difficult to sample
prior to this Order.
5. HEWLETT-PACKARD 395 PAGE MILL ROAD ON-SITE
(Hewlett-Packard)
a. COMPLETION DATE: February 1, 1995
TASK 21: PROPOSED CONSTRAINTS: Hewlett-Packard shall submit a
technical report acceptable to the Executive Officer documenting procedures to
be implemented for a deed restriction prohibiting the use of the contaminated
groundwater as a source of drinking water. The Executive Officer may
approve an alternative mechanism if it accomplishes the same function as a
deed restriction. Constraints shall remain in effect until groundwater cleanup
standards have been achieved and pollutant levels have stabilized in the
aquifers beneath the site.
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
b. COMPLETION DATE: 60 days after Executive Officer's approval of
above task.
TASK 22: IMPLEMENT CONSTRAINTS: Hewlett-Packard shall submit a
technical report acceptable to the Executive Officer documenting a deed
restriction or alternative approved constraints have been implemented.
c. COMPLETION DATE: February 1, 1995
TASK 22: REMEDIATION OF NORTHEASTERN CORNER OF SITE:
Hewlett-Packard shall submit a workplan and time schedule acceptable to the
Executive Officer for remediation of the vadose and groundwater zones near
Building 12 that have been impacted by contaminants. This area is known as
Area X (ten). The workplan will justify any proposed modifications to the
remediation alternatives for Area X currently recommended in the COE
groundwater and 395 Site soils Feasibility Study.
d. COMPLETION DATE: September 1, 1995
TASK 24: EVALUATE EFFECTIVENESS OF SOIL VAPOR
EXTRACTION SYSTEM: For any area of the site where SVE is
implemented as the selected remedial alternative, Hewlett-Packard shall submit
a technical report acceptable to the Executive Officer which documents
implementation of the approved SVE system recommended in the Feasibility
Study, evaluates effectiveness of the soil vapor extraction system, and proposes
modifications to the system, if necessary, and a time schedule to implement
those proposed modifications. This report should include an evaluation of soil
vapor monitoring options needed to assess the effectiveness of the soil vapor
extraction system.
e. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer.
TASK 25: START-UP OF MODIFICATIONS TO SOIL VAPOR
EXTRACTION SYSTEM: Hewlett-Packard shall submit a technical report
acceptable to the Executive Officer documenting completion of any
modifications identified in the above Task.
page
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640, 395 Page Mill Road and Vartan 601 California Avenue
f. COMPLETION DATE: 60 days prior to proposed curtailment of any
soil vapor extraction well or soil vapor
treatment system.
TASK 26: SOIL VAPOR EXTRACTION CURTAILMENT CRITERIA
AND PROPOSAL: Hewlett-Packard shall submit a technical report
acceptable to the Executive Officer containing a proposal for curtailment (i.e.,
termination or significant reduction in pumping rate) from any soil vapor
extraction well(s) or piping and the criteria used to justify such curtailment. If
the reason for curtailment is achievement of final cleanup standards, then the
report shall include a proposal indicating the methods for determining
concentrations of VOCs remaining in the soil. The proposal may include
termination of soil vapor extraction well operation for an extended period of
time to study the effects on chemical migration prior to well abandonment.
The proposal shall include a schedule for implementation.
If the discharger claims that it is not practicable to achieve cleanup standards
through continued soil vapor extraction in all or any portion of the
contaminated soil area and that significant quantities of chemicals are not being
removed through soil vapor extraction, the discharger shall evaluate the
reductions in chemical concentrations and alternative cleanup standards that
can be practicably achieved. The report shall evaluate alternative means of
achieving cleanup standards, whether meeting the cleanup standard is
technically impracticable, cost effective, and whether the alternative cleanup
standard proposed will be protective of human health and the environment.
g. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer.
TASK 27: IMPLEMENTATION OF CURTAILMENT AND
COMPLETION OF SOIL REMEDIATION: Hewlett-Packard shall submit a
technical report acceptable to the Executive Officer documenting completion of
the necessary tasks identified in the technical report submitted for the above
task. The report shall include the results of any chemical analyses performed.
page 33
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Site Cleanup Requirements Order No. 94-130 September 21, 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian 001 California Avenue
h. COMPLETION DATE: 60 days prior to proposed curtailment of any
groundwater extraction well or groundwater
treatment system.
TASK 28: GROUNDWATER EXTRACTION CURTAILMENT
CRITERIA AND PROPOSAL: Hewlett-Packard shall submit a technical
report acceptable to the Executive Officer containing a proposal for curtailing
pumping from any groundwater extraction well(s) and the criteria used to
justify such curtailment. This report shall include data to show that
groundwater cleanup standards for all VOCs have been achieved and that
pollutant levels have stabilized or are stabilizing, and that the potential for
pollutant levels rising above cleanup standards is minimal. Curtailment of
groundwater extraction means final shutdown of the system, a phased approach
to shutdown, elimination of pumping in selected wells (including pulsed
pumping), or a similar significant change to the system. In the case of final
shutdown of any portion of the system, the report shall identify the basis for
the time frame that will be used to confirm that groundwater concentrations
have stabilized at or below final cleanup standards and that the potential for
increases above cleanup standards is minimal in that portion of the system.
Any proposal to implement final shutdown of the system is subject to approval
by the Board, and any proposal to implement a phased approach to shutdown
or to eliminate the pumping in selected wells shall be subject to the approval
of the Executive Officer and, if requested by the Executive Officer, the Board.
If the discharger claims that it is not practicable to achieve cleanup standards
through continued groundwater extraction in all or any portion of the
groundwater plume area, the discharger shall evaluate the reductions in
chemical concentrations, the mass quantities being removed through
groundwater extraction, and alternative cleanup standards that can be
practically achieved. The report shall evaluate alternative means of achieving
cleanup standards, whether meeting the cleanup standards is technically
impracticable, cost effectiveness, and whether the alternative cleanup standard
proposed will be protective of human health and the environment.
i. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer.
TASK 29: IMPLEMENTATION OF GROUNDWATER EXTRACTION
CURTAILMENT: Hewlett-Packard shall submit a technical report acceptable
page
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Silt Cleanup Requirements Order No. 94-130 September 21. 1994
Hf*'leti-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
to the Executive Officer documenting completion of the necessary tasks
identified in the technical report submitted for the above task.
COMPLETION DATE: 30 days prior to building demolition.
TASK 30: PROPOSAL FOR INVESTIGATION OF AREAS EXPOSED
BY BUILDING DEMOLITION: Hewlett-Packard shall submit a technical
report acceptable to the Executive Officer proposing a sampling schedule for
areas which have previously been inaccessible beneath present on-site buildings
because of physical or operational constraints. This includes areas which could
potentially impact groundwater or the environment and were difficult to sample
prior to this Order.
6. OFF-SITE AREA
(Hewlett-Packard, Varian Associates, and Stanford University, as applicable)
a. COMPLETION DATE: 90 days after request made by the Executive
Officer
TASK 31: MAINTENANCE OF OREGON EXPRESSWAY UNDERPASS
GROUNDWATER CONTROL AND REMEDIATION SYSTEM: Hewlett-
Packard and Varian Associates shall submit a workplan and time schedule
acceptable to the Executive Officer for alternate control and remediation of
groundwater if the present Oregon Expressway Underpass remediation system
is rendered ineffective in remediating or preventing the spread of groundwater
contamination.
b. COMPLETION DATE: 60 days prior to proposed curtailment of any
groundwater extraction well or groundwater treatment system.
TASK 32: GROUNDWATER EXTRACTION CURTAILMENT
CRITERIA AND PROPOSAL: Hewlett-Packard and Varian Associates shall
submit a technical report acceptable to the Executive Officer containing a
proposal for curtailing pumping from any groundwater extraction well(s) and
the criteria used to justify such curtailment. This report shall include data to
show that groundwater cleanup standards for all VOCs have been achieved and
that pollutant levels have stabilized or are stabilizing, and that the potential for
pollutant levels rising above cleanup standards is minimal. Curtailment of
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Siif Cleanup Requirements Order No. 94-130 September 21. 1994
HfH-len-Padumt 640. 395 Page Mitt Rood and Varian 601 California Avenue
groundwater extraction means final shutdown of the system, a phased approach
to shutdown, elimination of pumping in certain wells (including pulsed
pumping), or a similar significant change to the system. In the case of final
shutdown of any portion of the system, the report shall identify the basis for
the time frame that will be used to confirm that groundwater concentrations
have stabilized at or below final cleanup standards and mat the potential for
increases above cleanup standards is minimal in that portion of the system.
Any proposal to implement final shutdown of the system is subject to approval
by the Board, and any proposal to implement a phased approach to shutdown
or to eliminate the pumping in selected wells shall be subject to the approval
of the Executive Officer and, if requested by the Executive Officer, the Board.
If the dischargers claim that it is not practicable to achieve cleanup standards
through continued groundwater extraction in all or any portion of the
groundwater plume area, the dischargers shall evaluate the reductions in
chemical concentrations, the mass quantities being removed through
groundwater extraction, and alternative cleanup standards that can be
practically achieved. The report shall evaluate alternative means of achieving
cleanup standards, whether meeting the cleanup standards is technically
impracticable, cost effectiveness, and whether the alternative cleanup standard
proposed will be protective of human health and the environment.
c. COMPLETION DATE: According to the schedule in the above Task
approved by the Executive Officer
TASK 35: IMPLEMENTATION OF GROUNDWATER EXTRACTION
CURTAILMENT: Hewlett-Packard and Varian Associates shall submit a
technical report acceptable to the Executive Officer documenting completion of
the necessary tasks identified in the technical report submitted for the above
task.
d. COMPLETION DATE: November 1, 1995
TASK 34: INSTALLATION OF ADDITIONAL MONITORING WELLS:
Hewlett-Packard and Varian Associates shall submit a technical report
acceptable to the Executive Officer documenting installation of any remaining
groundwater monitoring wells, CPTs, or hydropunches needed to assess: the
effectiveness of the groundwater extraction system, the vertical and lateral
te.
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Site Cleanup Requirements Order No. 94-130 . September 21. 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
distribution of the current groundwater plume and the future changes in plume
dimensions as identified in a September 7, 1994 letter from Hewlett-Packard
and Varian to Board staff.
COMPLETION DATE: December 1, 1994
TASK 35: WORKPLAN FOR INSTALLATION OF EXPANDED
GROUNDWATER EXTRACTION AND TREATMENT SYSTEM:
Hewlett-Packard and Varian Associates shall submit a workplan and time
schedule acceptable to the Executive Officer for installation of the expanded
groundwater extraction system, as outlined in the selected final remedy
(Alternative 2) described in the Feasibility Study and for evaluation of capture
area. The workplan shall contain the final construction schedule through
submittal of the start-up report.
f. COMPLETION DATE: Twelve months following approval of the
workplan
TASK 36: START-UP REPORT FOR GROUNDWATER EXTRACTION
AND TREATMENT SYSTEM: Hewlett-Packard and Varian Associates shall
submit a technical report acceptable to the Executive Officer documenting
installation of the groundwater extraction system described in the above Task.
The report shall contain as built construction drawings of the entire system and
the first two weeks of monitoring data.
g. COMPLETION DATE: Nine months following date of start-up report
TASK 37: EVALUATE CAPTURE AREA OF IMPACTED
GROUNDWATER AND PROPOSE ADDITIONAL EXTRACTION
WELLS IF NECESSARY: Hewlett-Packard and Varian Associates shall
submit a technical report acceptable to the Executive Officer documenting
implementation of the expanded groundwater extraction system and containing
an evaluation of the capture zones of all groundwater extraction systems that
impact groundwater in the COE and Perimeter Areas. The capture zones must
affect on- and off-site groundwater with chemical concentration above the
cleanup standards that originates from the sites. This evaluation must also
propose additional extraction wells, if necessary, and an implementation
page 37
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Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Padurd 640. 395 Page Mill Road and Variaa 601 California Avenue
schedule. This report shall contain data from the on-site areas and the Off-Site
Area.
h. COMPLETION DATE: According to a schedule set In the above Task
approved by the Executive Officer
TASK 38: START-UP OF MODIFICATIONS TO GROUNDWATER
EXTRACTION AND TREATMENT SYSTEM: Hewlett-Packard and
Varian Associates shall submit a technical report acceptable to the Executive
Officer documenting completion of any modifications identified in the above
Task.
7. ALL AREAS
(Hewlett-Packard, Varian Associates, and Stanford University, as applicable)
a. COMPLETION DATE: June 1, 2000
TASK 39: FIVE YEAR STATUS REPORT AND EFFECTIVENESS
EVALUATION: Hewlett-Packard and Varian Associates, as applicable, shall
submit a technical report acceptable to the Executive Officer containing the
results of any additional investigation; an evaluation of the effectiveness of
installed final cleanup measures and cleanup costs; additional recommended
measures to achieve final cleanup objectives and standards, if necessary;
projected costs necessary to achieve cleanup objectives and standards; and the
tasks and time schedule necessary to implement any additional final cleanup
measures. This report shall also describe the reuse of extracted groundwater
and evaluate and document the cleanup of contaminated groundwater. If
cleanup standards in this Order have not been achieved on-site and are not
expected to be achieved through continued groundwater extraction and/or soil
remediation, this report shall also contain an evaluation addressing whether it
is technically practicable and cost effective to achieve the cleanup standards,
and if so, a proposal for procedures to do so.
b. COMPLETION DATE: 90 days after request made by the Executive
Officer
TASK 40: EVALUATION OF NEW HEALTH CRITERIA: Hewlett-
Packard and Varian Associates, as applicable, shall submit a technical report
1C
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
HfH-lat-Packard 640. 395 Page MM Road and Varian 601 California Avenue
acceptable to the Executive Officer which contains an evaluation of how the
final plan and cleanup standards would be affected, if the groundwater or soil
cleanup standards listed in Table 1 of this Order change as a result of
promulgation of revised drinking water standards, maximum contaminant
levels or action levels or other health based criteria.
c. COMPLETION DATE: 90 days after request made by the Executive
Officer
TASK 41: EVALUATION OF NEW TECHNICAL INFORMATION:
Hewlett-Packard and Varian'Associates, as applicable, shall submit a technical
report acceptable to the Executive Officer that documents an evaluation of new
technical and economic information which indicates that cleanup standards or
cleanup technologies in some areas may be considered for revision. Such
technical reports shall not be required unless the Executive Officer or the
Board determines that such new information indicates a reasonable possibility
that the Order may need to be changed under the criteria described in Findings:
18 through 21.
8. The submittal of technical reports evaluating final remedial measures will
include a discussion of the cost, effectiveness, and impact on human health,
and the environment with the guidance provided by Subpart F of the NCP (40
CFR Pan 300); Section 25356. l(c) of the California Health and Safety Code;
CERCLA guidance documents; and shall be consistent with the State Water
Resources Control Board's Resolution No. 68-16, "Statement of Policy witty
Respect to Maintaining High Quality of Waters in California."
9. If the dischargers are 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, and the Board may consider revision to
this Order for such delays.
10. Technical status reports on compliance with the Prohibitions, Specifications,
and Provisions of this Order shall be submitted quarterly to the Board
commencing on October 15, 1994 (for June, July and August), and covering
the previous quarter: Reports shall be submitted on a quarterly basis, until
one year after implementation of the expanded groundwater extraction and
treatment system. The technical reports may then be submitted semi-annually
after the second and fourth quarters thereafter, or as required by the Executive
Officer. These reports shall consist of: (1) a summary of work completed
page 39
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Si if Cleanup Requirements Order No. 94-130 September 21, 1994
Hr»-leit-Packard 64O. 395 Page Mill Road and Varian 601 California Avenue
since submitted of the previous report and work projected to be completed by
the time of the next report, (2) identification of any obstacles which may
threaten compliance with the schedule of this Order and what actions are being
taken to overcome these obstacles, and (3) include, in the event of non-
compliance with any Provision or Specification of this Order, written
notification which clarifies the reasons for non-compliance and which proposes
specific measures and a schedule to achieve compliance. This written
notification shall identify work not completed that was-projected for
completion, and shall identify the impact of non-compliance on achieving
compliance with the remaining requirements of this Order.
These reports shall also identify any problems with or changes in the
extraction and treatment system. Additionally, the reports shall include, but
not be limited to, updated water table and piezometric surface maps and plume
maps for all affected water-bearing zones as specified in the current
groundwater self-monitoring program requirements, and appropriately scaled
and detailed base maps showing the location of all monitoring wells and
identifying adjacent facilities and structures. These reports may be combined
with quarterly SMRs required per Provision C.I.
11. On an annual basis beginning with the report due January 31, 1996, or as
required by the Executive Officer, the status report shall include an evaluation
of the progress of cleanup measures such as hydraulic control of the plume,
performance of the remedy, estimation of capture zones influenced by
extraction wells, establishment of cones of depression using field data, and a
discussion of water quality data relevant to the evaluation of the progress of
cleanup measures. The report shall also evaluate the effects of operation of
existing extraction wells on groundwater levels and an estimate of the amount
of chemicals removed via the extraction systems. These reports may be
combined with quarterly SMRs required in Provision C.I. No such report
needs to be filed in 2000.
12. Non-Binding Allocation of Responsibility: The cost of implementing the
selected remedy should be allocated to Hewlett-Packard (45%) Varian
Associates (45%) and Stanford (10%). These parties reserve all of their rights
against and with respect to any other potentially responsible parties under any
applicable law, including those named previously in this Order;
13 All technical reports or technical documents shall be signed by or stamped
with the seal of a registered geologist, engineering geologist, or professional
engineer.
rv»p*»
I—fa-
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page Mitt Road and Vartan 601 California Avenue
14. All samples shall be analyzed by State certified laboratories or by laboratories
accepted by the Board using approved EPA methods, where available, for the
type of analysis to be performed. All laboratories shall maintain quality
assurance/quality control records for Board review.
IS. 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.
16. Copies of all correspondence, reports, and documents pertaining to compliance
with this Order or proposed changes to this Order shall be provided to the
following agencies: .
a. Santa Clara Valley Water District
b. U.S. Environmental Protection Agency, Region 9 (H-6-3)
c. California EPA/DTSC Site Mitigation Branch
The Executive Officer may additionally require copies of correspondence,
reports, and documents pertaining to compliance with this Order to be
provided to a local repository for public use.
17. 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 exist,
consistent with the site Health and Safety Plan, or upon premises in '
which any required records relevant to this Order are kept.
b. Access to copy any records required to be kept under the requirements
of this Order.
c. Inspection of any monitoring equipment or methodology implemented
in response to this Order.
d. Sampling of any groundwater or soil which is accessible, or may
become accessible, as pan of any investigation or remedial action
program undertaken by the dischargers.
18. If any hazardous substance, as defined by Section 13050 of the California
Water Code, 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
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Site Cleanup Requirements Order No. 94-130 September 21. 1994
Ht»leti-Padcard 640, 395 Page Mitt Road and Varian 601 California Avenue
the state, the dischargers shall report such discharge to this Board, at (510)
286-1255 on weekdays during office hours (8 am to 5 pm) and to die Office of
Emergency Services at (800) 852-7550 during non-business hours. A written
report shall be filed with the Board within five working days and shall contain
information relative to: the nature of waste or pollutant, quantity involved,
duration of incident, cause of spill, SPCC plan in effect (if any), estimated size
of affected area, nature of effect, corrective measures taken or planned,
schedule of such measures, and persons/agencies notified.
19. Hewlett-Packard shall provide written notification of any changes in sjtc
occupancy or ownership associated with facilities at 395 Page Mill Road and
640 Page Mill Road (so long as Hewlett-Packard is a current occupant or
owner of such facilities) described in this Order within one month after such
changes. Stanford University shall provide written notification of any changes
in site occupancy or ownership associated with facilities at 601 California
Avenue and 640 Page Mill Road (so long as Stanford University is a current
occupant or owner of such facilities) described in this Order within one month
after such changes.
20. The Board will review this Order periodically and may revise the requirements
when necessary.
21. This Order supersedes and rescinds the following Board orders:
Discharger/Area Order No.
Hewlett-Packard/395 Page Mill Road 89-050
Hewlett-Packard/640 Page Mill Road 90-067
Varian Associates/601 California Avenue 90-066
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 21, 1994.
Steven R. Ritchie
Attachments: Executive Officer
Self-Monitoring Program
Site Map
Table 1 Ground water Cleanup Standards
page 42
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TABLE 1
SITE CLEANUP REQUIREMENTS
GROUND WATER CLEANUP STANDARDS
HEWLETT-PACKARD 640 PAGE MILL ROAD
VARIAN 601 CALIFORNIA AVENUE
HEWLETT-PACKARD 395 PAGE MILL ROAD
CHEMICAL
Acetone
Benzene
1 , 1 -Dichloroethane
1 ,2-Dichloroethane
1,1-Dichloroethene
cis- 1 ,2-Dichloroethene
trans-l ,2-Dichloroethene
Methylehe Chloride
Tetrachloroethene
1,1,1 -Trichloroethane
1 , 1 ,2-Trichloroethane
Trichloroethene
Freon 113
1 ,2-Dichlorobenzene
1,2,4-Txichlorobenzene
CLEANUP STANDARD ug/L
3,500
1
5
0.5
6
6
10
5
5
200
3
5
1,200
600
70
For all chemicals except Acetone, cleanup standards for groundwater are federal or state
MCL's, whichever is lower: For acetone, there is no federal or state MCL and the cleanup
standard is based on the EPA reference dose and a hypothetical maximum exposure rate.
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^•K* ' X
S.L -\ ,-' >
%y&
HEWLETT-PACKARD
1?OO ("col
i/:' MIIC
STATE OP CALIFORNIA
REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
Hewlett-Packard 640 Page Mill Road
Yariar. Associates 601 California Avenue
Hewlett Packard 295 P^e Mi!! »OJM»
Palo Alto
Figure 1 Site Vicinity
DRAWN BY' i"* |DATE'
IDRWGMO.
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COE STUDY AR6AJJpyNPARY.
—
Varun 611 Hinicn Way
(DTSC lead)
STATE OP CALIFORNIA
REGIONAL WATER QUALITY CONTROL BOARD
SAN fr*tAMd«en BAV
Hewlett-Packard 640 Page Mill Road
Varian Associates 601 California Avenue
Hewlett-Packard 395 Page Mill Koad
Palo Alto
Figure 2 Site Detail
OEU '<**
€ N V I R ON
DRAWN BY- i"* I DATE' 9/21/94
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CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
GROUNDWATER SELF-MONITORING PROGRAM
FOR
HEWLETT-PACKARD COMPANY
640 Page Mill Road Facility
Palo Alto, Santa Clara County
395 Page Mill Road Facility
Palo Alto, Santa Clara County
VARJAN ASSOCIATES
601 California Avenue Faculty
Palo Alto, Santa Clara County
ORDER NO. 94-130
Adopted on September 21, 1994
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CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
HEWLETT-PACKARD COMPANY
640 Page Mill Road
395 Page Mill Road
VARIAN ASSOCIATES
601 California Avenue
Palo Alto, Santa Clara County
GROUNDWATER SELF-MONITORING PROGRAM
A. GENERAL
-.. Reporting responsibilities of waste dischargers are specified in Sections 13225(a),
13267(b), 13268, 13383 and 13387(b) of the California Water Code and this Regional
Board's Resolution No. 73-16.
The principal purposes of a monitoring program by a waste discharger, also referred to
as self-monitoring program, are: (1) to document compliance with waste discharge
requirements and prohibitions established by this Regional Board, (2) to facilitate
self-policing by the waste discharger in the prevention and abatement of pollution arising
from waste discharge, (3) to develop or assist in the development of effluent or other
limitations, discharge prohibitions, national standards of performance, pretreatment and
toxicity standards, and other standards, and (4) to prepare water and waste water quality
inventories.
B. SAMPLING AND ANALYTICAL METHODS
Sample collection, storage, and analyses shall be performed according to the EPA
Method 8000 series in "Test Methods for Evaluating Solid Wastes, Physical/Chemical
Methods," dated November 1990; or other methods approved and specified by the
Executive Officer of this Regional Board.
C. REPORTS TO BE FILED WITH THE REGIONAL BOARD
1. Violations of Requirements
In the event the discharger is unable to comply with the conditions of the site
cleanup requirements and prohibitions due to:
2. Maintenance work, power failures, cr breakdown of waste treatment
equipment, or
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Groundwtcr SMP Order No. 94-130 September 21, 1994
Hewlett-Packard 640. 395 Page Mitt Road and Variait 601 California Avenue
b. accidents caused by human error or negligence, or
c. other causes, such as acts of nature, or
d. poor operation or inadequate system design,
the discharger shall notify the Regional Board office by telephone as soon as he
or his agents have knowledge of the incident and confirm this notification in
writing within 5 working days of the telephone notification. The written report
shall include time, date, and person notified of the incident. The report shall
include pertinent information explaining reasons for the noncompliance and shall
indicate what steps were taken to prevent the problem from recurring.
2. The discharger shall file a written technical report to be received at least 30 days
prior to advertising for bid (or 60 days prior to construction) on any construction
project which would cause or aggravate the discharge of waste in violation of
requirements; said report shall describe the nature, cost, and scheduling of all
action necessary to preclude such discharge.
3. Self-Monitoring Reports
Written reports shall be filed regularly for each calendar quarter (unless specified
otherwise) and filed no later than the fifteenth day of the following quarter. The
next quarterly report is due October IS, 1994. The reports shall be comprised
of the following:
/
a. Letter of Transmittal; -
A letter from the discharger transmitting self-monitoring reports should
accompany each report. Such a letter shall include a discussion of
requirement violations found during the reporting period and actions taken
or planned1 for correcting any requirement violations. If the discharger
has previously submitted a detailed time schedule for correcting
requirement violations, a reference to this correspondence will be satisfac-
tory. Monitoring reports and me letter transmitting reports shall be signed
by a principal executive officer or a duly authorized representative of that
person.
The letter shall contain a statement by the official, under penalty of
perjury, that to the best of the signer's knowledge the report is true and
correct.
page 3
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Croundwaier SMP Order No. 94-130 September 21, 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
b. Results of Analyses and Observations
(1) Results from each required analysis and observation shall be
submitted in the quarterly self-monitoring regular reports.* Results
shall also be submitted for any additional analyses performed by
the dischargers at the specific request of the Board. Quarterly
water level data shall also be submitted in the quarterly report.
(2) The quarterly reports shall include the groundwater extraction rates
from each extraction well, water level data from the extraction
wells, the results of any aquifer tests conducted during the quarter.
(3) The quarterly reports shall include a discussion of unexpected
operational changes which could affect performance of the
extraction system, such as flow fluctuations, maintenance
shutdown, etc.
(4) The quarterly report shall also identify the analytical procedures
used for analyses either directly in the report or by reference to a
standard plan accepted by the Executive Officer. Any special
methods shall be identified and should have prior approval of the
Board's Executive Officer.
(5) The discharger shall describe in the quarterly Self-Monitoring
Report (SMR) the reasons for significant increases in a pollutant
concentration at a well. The description shall include:
a) the source of the increase,
b) how the discharger determined or will investigate the
source of the increase, and
c) what source removal measures have been completed or will
be proposed.
(6) Original lab results shall be retained and shall be made available
for inspection for six years after origination or until after all
continuing or impending legal or administrative actions are
resolved.
(7) A map or maps shall accompany the quarterly report, showing all
sampling locations and plume contours to final cleanup levels.
page 4
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Croundwater SMP Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page MM Road and Varian 601 California Avenue
(8) The discharger shall describe in the quarterly monitoring report the
effectiveness of the actions taken to regain compliance if com-
pliance is not achieved. The effectiveness evaluation shall include
the basis of determining the effectiveness, water surface elevations
and water quality data.
(9) The annual report shall be combined with the fourth quarter
regular report and shall include cumulative data for the current
year. The annual report for December shall also include
minimum, maximum, median, and average water quality data for
the year, a summary of water level data, and GC/MS results. The
report shall contain both tabular and graphical summaries of
historical monitoring data.
d. SMP Revisions:
Additional long term or temporary changes in the sample collection
frequency and routine chemical analysis may become warranted as
monitoring needs change. These changes shall be based on the following
criteria and shall be proposed in a quarterly SMR. The changes shall be
implemented no earlier than 45 days after the self-monitoring report is
submitted for review unless approved in writing.
Criteria for SMP revision:
(1) Discontinued analysis for a routine chemical parameter' for a
specific well after a two-year period of below detection limit
values for that parameter.
(2) Changes in sampling frequency for a specific well after a two-year
period of below detection limit values for all chemical parameters
from that well.
(3) Temporary increases in sampling frequency or changes in
requested chemical parameters for a well or group of wells because
of a change in data needs (e.g., evaluating groundwater extraction
effectiveness or other remediation strategies).
(4) Add routine analysis for a chemical parameter if the parameter
appears as an additional chromatographic peak in three consecutive
samoles from a narticular well.
samples from a particular well.
(5) Alter sampling frequency based on evaluation of collective data
base.
pageS
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Groundwtuer SMP Order No. 94-130 September 21. 1994
Hewlett-Packard 64O, 395 Page MM Road and Varian 601 California Avenue
D. DESCRIPTION OF SAMPLING STATIONS
All existing and future monitoring and extraction wells as appropriate. See Table I and Figure
2 (attached) for monitoring and extraction wells installed at the time of the adoption of this SMP.
E. SCHEDULE OF SAMPLING AND ANALYSES
1. The schedule of sampling and analysis shall be that given in Table I (attached).
2. In addition, if a previously undetected compound or peak is detected in a sample
from a well, a second sample shall be taken within a week after the results from
the first sample are available. All chromatographic peaks detected in two
consecutive samples shall be identified and quantified in the quarterly report.
3. Groundwater elevations shall be obtained on a quarterly basis from all wells at
the site and submitted in the quarterly report with the sampling results.
4. Well depths shall be determined on an annual basis and compared to the depth of
the well as constructed. If greater than ninety percent of screen is covered, the
discharger shall clear the screen by the next sampling.
I, Steven R. Ritchie, Executive Officer, hereby certify that the foregoing Self-Monitoring
Program:
/
1. Has been developed in accordance with the procedure set forth in this Regional Board's
Resolution No. 73-16 in-order to obtain data and document compliance with site cleanup
requirements established in Regional Board Order No. 94-130
2. May be reviewed at any time subsequent to the effective date upon written notice from
the Executive Officer or request from the discharger, and revisions will be ordered by
the Executive Officer or Regional Board.
3. Was adopted by the Board on September 21, 1994
Steven R. Ritchie
Executive Officer
Attachments:
Table 1 - Sampling Schedule
Figure 1 - Site Vicinity
e 2 - SMP ?.w!! other
page 6
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TABLE 1
SELF MONITORING PROGRAM
SAMPLING SCHEDULE
HEWLETT-PACKARD 640 PAGE MILL ROAD
VARIAN ASSOCIATES 601 CALIFORNIA AVENUE
HEWLETT-PACKARD 395 PAGE MILL ROAD
WELL
NUMBER
017B
F21A1U
F22A1U
F23A
O27A1
O28A1
F29A1U
F30A1U (2)
F32A
F33B
F34A
F35B
F36A
F37A
F38A
F39A
F40A
F42A1
F43A1U (2)
F44A
F45A1U (2)
F46A1
F49A1
F51A1
8010 + Freoo
S
Q
Q
Q
S
Q
S
Q
S
Q
S
Q
S
S
Q
Q
Q
Q
Q
Q
Q
Q
S
8020+ Acetone
S
-
Q
8240 + Fnsoo
(1)
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
8270
orTPH
,«
8270, A
- f
-------
WELL
NUMBER
052A2
F53A1U
F54A1U
F57A1U
F58A
F59A1U
F61A1U
F62A1
F63A1U/A1
F64A1
F65A1U
F66A
O67A2
068A1
O69A2D
O70A1
F73A1
F74A
F75A1U
F76A2 (3)
F77A1U (3)
F78A1
F79A2D
F83AIU
F84A1
F85A1
F86A2
F87A2
F88A1U
8010 + Fraoo
Q
S
S
Q
S
Q
Q
Q
Q
Q
Q
S
Q
Q
Q
Q
Q
Q
Q
Q
S
Q
s
Q
S
Q
8020 -f Acetone
S
Q
8240 + Freoo
(1)
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
8270
orTPH
/
•
-------
WELL
NUMBER
F89A
F90A1U
F91A1
F92A2
F93A1U
F95A
F97A
F98A
O100B
F101B
F102B
F103B
O104A1
O105A2
F106A1
F107A2
O108A1
O109A2
O110A1
0111A2
O112A1
0113A2
O114A2
O115A1
O116A1
O117A2
O118B
O119A1
O120A2
8010 -I- Fraoa
Q
Q
s
s
s
s
Q
Q
S
s
s
s
s
s
s
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
8020+Acetooe
S
S
S
S
S
S
s
s
s
s
s
s
s
s
s
s
8240 + Freoo
(1)
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
8270
orTPH
.
*
f
8270, Q
8270. S
8270, A
8270. S
8270, S
-------
WELL
NUMBER
0121A2
O122A2
F123A1
FI24A2
F125A1
F126A2
F127A1
F128A
F129A1
F130A1U
F131A1
F132A2
F133B
F134A1
F135A1
F136A1
F137A1
F141A1U
F142A1
F143A1U
F144A2
F145A1
F146A1U
F147A1
EW-4
EW-5
EW-«
EW-7
EW-g
8010 + Fnoo
S
S
Q
Q
Q
Q
Q
S
S
Q
Q
S
S
Q
Q
S
S
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
8020+Acctotto
S
S
8240 + Freoo
(1)
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
8270
orTPH
-
••
f
-------
WELL
NUMBER
EW-9
EW-10
EW-11
EW-13
V8-1
V8-2
V8-2X
V8-3
V8-4
V8-S
V8-6
V8-7
V8-8
V8-8X
V-9
V-9X
V-10
V8-13B
V8-14X
V8-22
V-23
V-33A2D
W-3A1U
W-4A1U/A1
W-5A1
W-6A1U
W-7A1U
W-8A1U
W-9A1U/A1
8010 -I- Ficon
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
S
Q
Q
Q
S
S
S
S
Q
Q
Q
S
Q
Q
S
Q
S
S
8020+Acetone
S
S
•
8240 + Freon
(1)
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
8270
orTPH
-
»•
/
TPH, A (4)
TPH, A (4)
-------
WELL
NUMBER
W-10A1U
W-11A1U
W-12A1U
W-13A2
W-UAlU/At
W-16AI
W-17A2
W-19A2
W-20B
BP-3 (3)
BW-4
MB-2
SH-1
VB-1
OEU-MANHOLE
8010 + Fraon
Q
S
Q
Q
Q
Q
Q
S
Q
Q
S
Q
Q
Q
8020+ Acetone
8240 + Freon
(1)
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
8270
orTPH
TPH. M4)
'
-
Q = quarterly
S= semiannually
A = annually
8010 -t- Freon « EPA method 8010 and Freon 113
8020 + Acetone = EPA method 8020 and Acetone
8240 = EPA method 8240 + Freon 113
8270 - EPA method 8270
TPH = EPA method 8015 and 5520/413
Well Numbering scheme
O = 640 OD-site well
F = COE or perimeter well
EW = Extraction well, HP associated or off-site
X = Extraction well, Varian 601
V = Varian 601 associated well
W • HP 395 on-site well
A = A zone well
Al = Al zone well
A1U = Al Upper zone well
A2 = A2 zone well
A2D = A2 Deep zone well
B = B zone well
OEU = Oregon Expressway Underpass
(1) Annual EPA Method 8240 analysis is in place
of (and not in addition to) quarterly EPA Methods
8010 and 8020 analysis.
(2) Not currently sampled; resume sampling when
the A1U zone resatuntes.
(3) Not currently sampled; resume sampling if
access is obtained.
(4) Sample only if TPH is left behind in soil at
concentrations greater than 100 parts per million
after site redevelopment
-------
1200 Fed
I/? Milo
STATE OP CALIFORNIA
REGIONAL WATO OUAUTT CONTMOL BOAtO
•AN PRANCIBCO BAY REGION
Hewlett-Packard 640 Page Mill Road
Varian Associates 601 California Avenue
Hewieu-Fackard 395 Page Mill Road
Palo Alto
Figure 1 Site Vicinity
DRAWN BY' i"* JDATE' vriw IORWG.Ml~i
-------
STATE OF CALIFORNIA
REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
€ NVJRON
Hewlett-Packard 640 Page Mill Road
Varian Associates 601 California Avenue
Hewlett-Packard 395 Page Mill Road
Palo Alto
Figure 1 SMP and Other Wells
DRAWN BY' I DATE' ***** |QRWG NO 2
-------
,TATf Of CAtffORNIA
HTf WIISON.
:ALIFORNIA REGIONAL WAT
.AN FRANCISCO BAY REGION
'ioi wtasn* ST*ECT.~suiTf soo
>A«1ANO. CA »44)2
MO) 2U-I2JJ
QUALITY CONTROL BOARD
Robin Ross
Hewlett-Packard
1501 Page Mill Road MS 5U
Palo Alto, CA 94304
Paula Kakimoto
Stanford Management Company
2770 Sand Hill Road
Menlo Park, CA 94025
Bo Gustincic
Varian Associates
3120 Hansen Way MS D-095
Palo Alto, CA 94303-0883
October 21, 1994
File No. 2189.8063A(JMH)
.8131
.8249
RE: CORRECTION OF SELF MONITORING REPORT FOR ORDER NO. 94-130, 640
PAGE MILL ROAD, 601 CALIFORNIA AVENUE, AND 395 PAGE MILL ROAD,
PALO ALTO, SANTA CLARA COUNTY
Dear Addressees:
Attached is a corrected copy of the Self Monitoring Report approved at the September 21,
1994 Regional Board meeting. An incorrect, older version of the SMP was inadvertently
sent out with the Site Cleanup Requirements after the Order was adopted. The corrected
SMP is what the Board voted on at the September 21, 1994 Board meeting. Please discard
only the seven page text you currently have (the tables and figures are unchanged) and
replace it with the text provided.
Please call John Hillenbrand of my staff at (510) 286-0671 if you have any questions.
Sine
Steven R. Ritchie
Executive Officer
Attachment
cc w/attachment: Mailing list
-------
Mailing List
Will Beckett
Barren Park Association Foundation
4189 Baker Avenue
Palo Alto, CA 94306
John Joynt
Barren Park Foundation
3589 Laguna Avenue
Palo Alto, CA 94306
Nancy Blair
United States Geological Survey
345 Middlefield Road
Mcnlo Park, CA 94025
Barbara Cook
Department of Toxic Substances Control
700 Heinz Avenue Suite 200
Berkeley, CA 94710-2737
Tom Iwamura
Santa Clara Valley Water District
5750 Almaden Expressway
San Jose CA 95118
Marie Lacy
U.S. EPA Region DC
75 Hawthorn Street
San Francisco, CA 94105
Belinda Wei
U.S. EPA Region DC
75 Hawthorn Street
San Francisco, CA 94105
Dr. Inge Harding-Barlow
3717 Laguna Avenue
Palo Alto, CA 94306
-------
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
GROUNDWATER SELF-MONITORING PROGRAM
FOR
HEWLETT-PACKARD COMPANY
640 Page Mill Road Facility
Palo Alto, Santa Clara County
395 Page Mill Road Facility
Palo Alto, Santa Clara County
VARIAN ASSOCIATES
601 California Avenue Facility
Palo Alto, Santa Clara County
ORDER NO. 94-130
Adopted on September 21, 1994
-------
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
HEWLETT-PACKARD COMPANY
640 Page Mill Road
395 Page Mill Road
VARIAN ASSOCIATES
601 California Avenue
Palo Alto, Santa Clara County
M
GROUNDWATER SELF-MONITORING PROGRAM
A. GENERAL
Reporting responsibilities of waste dischargers are specified in Sections 13225(a),
13267(b), 13268, 13383 and 13387(b) of the California Water Code and this .Regional
Board's Resolution No. 73-16.
The principal purposes of a monitoring program by waste dischargers, also referred to
as self-monitoring program, are: (1) to document compliance with waste discharge
requirements and prohibitions established by this Regional Board, (2) to facilitate
self-policing by the waste dischargers in the prevention and abatement of pollution arising
from waste discharge, (3) to develop or assist in the development of effluent or other
limitations, discharge prohibitions, national standards of performance, pretreatment and
toxicity standards, and other standards, and (4) to prepare water and waste water quality
inventories.
B. SAMPLING AND ANALYTICAL METHODS
Sample collection, storage, and analyses shall be performed according to the EPA
Method 8000 series in "Test Methods for Evaluating Solid Wastes, Physical/Chemical
Methods," dated November 1992; or other methods proposed by the dischargers and
approved by the Executive Officer of this Regional Board.
C. REPORTS TO BE FILED WITH THE REGIONAL BOARD
1. Violations of Requirements
In the event the discharger is unable to comply with the conditions of the site
cleanup requirements and prohibitions due to:
a. Maintenance work, power failures, or breakdown of waste treatment
page 2
-------
Groundwater SMP Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian 601 California Avenue
equipment, or
b. accidents caused by human error or negligence, or
c. other causes, such as acts of nature, or
d. poor operation or inadequate system design,
the dischargers shall notify the Regional Board office by telephone expeditiously
after obtaining knowledge of the incident and confirm this notification in writing
within 5 working days of the telephone notification. The written jeport shall
include time, date, and person notified of the incident. The report shall include
pertinent information explaining reasons for the noncompliance and shall indicate
what steps were taken to prevent the problem from recurring.
2. The dischargers shall file a written technical report to be received at least 30 days
prior to advertising for bid (or 60 days prior to construction) on any construction
project undertaken by those dischargers which would cause or aggravate the
discharge of waste in violation of requirements; said report shall describe: the
nature, cost, and scheduling of all action necessary to preclude such discharge.
3. Self-Monitoring Reports
Written reports shall be filed regularly for each quarter (quarters are three months
in duration with the First Quarter of each year beginning in March) and filed no
later than 45 days after the end of the quarter. The next quarterly report is due
October 15, 1994. The reports shall be comprised of the following:
a. Letter of Transmittal:
A letter from the discharger transmitting self-monitoring reports should
accompany each report: Such a letter shall include a discussion of
requirement violations found during the reporting period and actions taken
or planned for correcting any requirement violations. If the discharger
has previously submitted- a detailed time; schedule for correcting
requirement violations, a reference to this correspondence will be satisfac-
tory. Monitoring reports and the letter transmitting reports shall be signed
by a principal executive officer or a duly authorized representative of that
person.
The letter shall contain a statement by the official, under penalty of
perjury, that to the best of the signer's knowledge the report is true and
correct.
pagf 3
-------
Groundwater SMP Order No. 94-130 . September 21. 1994
Hewlett-Packard 640, 395 Page Mill Road and Varian 601 California Avenue
b. Results of Analyses and Observations
(1) Results from each required analysis and observation made during
the quarter shall be submitted in the associated quarterly self-
monitoring regular report. Results shall also be submitted for any
additional SMP analyses performed during the quarter by the
dischargers at the specific request of the Board. Quarterly water
level data shall also be submitted in the quarterly report in tabular
format. Potentiometric surface maps for the Al Upper, Al, and
A2 Zones, and the B Aquifer shall also be submitted in the
quarterly reports.
A discussion of data presentation techniques shall be included in
the annual report (see Section C.3.b.(9» unless changes in these
techniques have occurred. The quarterly reports may reference the
discussion in the annual report.
(2) The quarterly reports shall include the groundwater extraction rates
from each extraction well, water level data from the extraction
wells, the available results of any aquifer tests conducted during
the quarter.
(3) The quarterly reports shall include a discussion of unexpected
operational changes which could affect performance of the
extraction system, such as flow fluctuations, maintenance
shutdown, etc.
(4) The quarterly report shall also identify the analytical procedures
used for analyses either directly in the report or by reference to a
standard plan accepted by the Executive Officer. Any special
methods shall be identified and should have prior approval of the
Board's Executive Officer.
(5) The discharger shall describe in the quarterly Self-Monitoring
Report (SMR) the reasons for significant increases in a pollutant
concentration at a well. The description shall include:
a) the source of the increase,
b) how the discharger determined or will investigate the
source of the increase, and
c) what source removal measures have been completed or will
be proposed.
page 4
-------
Cnitntfwaier SMP Order No. 94-130 September 21. 1994
Hewlett-Packard 640. 395 Page Mill Road and Varian 601 California A\
(6) Original lab results shall be retained and shall be made available
for inspection for six years after origination or until after all
continuing or impending legal or administrative actions are
resolved.
(7) A trichloroethene (TCE) isoconcentration map for the Ai Upper,
Al, and A2 Zones shall accompany the quarterly report, showing
all sampling locations for the quarter and plume contours to final
cleanup levels. Isoconcentration maps for TCE, 1,1,1-
trichloroethane (TCA), 1,1-dichloroethene (1,1-DCE), and
tetracholorethene (PCE) in the Al Upper, Al, and A2,Zones shall
accompany the annual report and show all sampling locations for
the quarter and plume contours to final cleanup levels. If EPA
Method 8240 results are non-detect for- a well, then the
isoconcentration maps included in the annual, report will use the
lowest reported value or detection limit for the year previous. In
addition, maps showing the results of aromatic and semivolatile
testing in the A Aquifer, and, volatile and semivolatile testing in
the B Aquifer shall accompany the annual report.
(8) The discharger shall describe in the quarterly monitoring report the
effectiveness-of the actions taken to regain compliance if com-
pliance is not achieved! The effectiveness evaluation shall include
the basis- of determining; the: effectiveness, the water surface
elevations and the water quality data.
(9) The annual report shall: bet combined* with the fourth -quarter
regular report and shall include cumulative water quality and water
-: level data for the current year; The'annual report for December
" shall also include minimum, maximum, and average water quality
data-for the yeaiv a summary of water level data, and analytical
results. The report shall clearly reference the location of tabular
summaries of historical' monitoring data.
• ''• "'• • ••-,.-.•
SKIP Revisions:^ ^
Additional' long term or temporary changes in the sample collection
frequency and routine chemical- analysis may; become warranted as
monitoring needs change; Dischargers-may. submit a proposed revision
to the SMP! with the annual report-;
pageS
-------
Croundwater SMP Order No. 94-130 September 21. 1994
Hewlett-Packard 640, 395 Page Mill Road and Varian 601 California Avenue
D. DESCRIPTION OF SAMPLING STATIONS
All existing and future monitoring and extraction wells as appropriate. See Table I and Figure
2 (attached) for monitoring and extraction wells included in the SMP and installed at the time
of the adoption of this SMP.
E. SCHEDULE OF SAMPLING AND ANALYSES
1. The schedule of sampling and analysis shall be that given in Table I (attached).
*•
2. In addition, if a historically undetected EPA Method target compound (according
to the analytical schedule presented in Table 1 for each well) is detected in a
sample from a well, and the following conditions are met, a second sample shall
be taken within two weeks after the results from the first sample are available.
These results will be presented either in the SMR for the current quarter or in a
supplement to follow the SMR, whichever is practical. The conditions requiring
a resampling are as follows:
a) For wells located at the edge of a plume:
i) The historically undetected compound is detected at a concentration at
or above one-half the site cleanup standard for the compound; and
ii) The historically undetected compound is not a recognized laboratory
contaminant.
b) For all other wells:
i) The historically undetected compound is detected at a concentration at
least 10 times the site cleanup standard for the compound; and
ii) The historically undetected compound is not a recognized laboratory
contaminant; and
iii) The historically undetected compound is not a common daughter
product of detected compounds. Daughter products present expected
change, not an unexpected change in the contaminant plume.
This rapid resampling requirement may be waived by RWQCB staff if RWQCB
staff decides, based on information presented by the discharger to RWQCB staff
within the two week period after the results from the first sample are available,
not to require rapid resampling. In this situation, the well would be monitored
for the historically undetected compound in the next regular sampling period.
3. Groundwater elevations shall be obtained on a quarterly basis from all wells at
the site and submitted in the quarterly report with the sampling results.
page 6
-------
Groundwater SMF Order No. 94-130 September 21, 1994
Hewlett-Packard 640. 395 Page Mitt Road and Varian 601 California Avenue
4. Well depths of those wells sampled as part of the SMP shall be determined on an
annual basis and compared to the depth of the well as constructed. If greater than
ninety percent of screen is covered, the discharger shall clear the screen by the
next sampling.
I, Steven R. Ritchie, Executive Officer, hereby certify that the foregoing Self-Monitoring
Program:
1. Has been developed in accordance with the procedure set forth in this Regional Board's
Resolution No. 73-16 in order to obtain data and document compliance with-site cleanup
requirements established in Regional Board Order No. 94-130
2. May be reviewed at any time subsequent to the effective date upon written notice from
the Executive Officer or request from the discharger, and revisions will be ordered by
the Executive Officer or Regional Board.
3. Was adopted by the Board on September 21, 1994
/ Steven R. Ritchie
Executive Officer
Attachments: Table 1 - Sampling Schedule
Figure 1 - General Location Map
Figure 2 -Well Location Map
pagf 7
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