£EPA
United bates
Environmental Protection
Agency
Office of -
Emergency and
Remedial Response
EPA/ROD/R09-83/005
July 1983
Superfund
Record of Decision:
Stringfellow Acid Pits
Site, CA (IRM)
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TECHNICAL REPORT DATA
(Please read Instrucrions !}n the reverse before completing)
,. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R09-83/005
4. TITLE AND SUBTITLE 5. REPORT OATE
SUPERFUND RECORD OF DECISION: 07/22/83
Stringfellow Acid Pits, CA (IRM) 6. PERFORMING ORGANIZATION CODE
7. AUTHORCSI 8. PERFORMING ORGANIZATION REPORT NO.
a. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EL.EMENT NO.
". CONTRACT/GRANT ~O.
12. SPONSORING AGENCY NAME AND ADORESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 14. SPONSORING AGENCY CODE
lWashington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Stringfellow site is located in Riverside County, approximately five miles
northwest of the City of Riverside and one mile north of the community of Glen Avon.
The Stringfellow site which encompassed approximately 17 acres, potentially affects
the Chino III ground water basin which is used for industrial and agricultural pur-
poses and as a domestic drinking water supply for approximately 40,000 residents.
During the site operation from 1956 to 1972, approximately 34 million gallons of
toxic waste were disposed of at the si te . Past disposal techniques included dis-
charging liquid wastes, mainly acids and heavy metals, to ponds for solar evaporation
and spraying liquid wastes into the air to accelerate evaporation. Substances dis-
posed of include heavy metals such as chrorni urn and cadrni urn, acids including sulfuric
acid, and organics including DDT and TCE. The selected remedial alternative involves
initial remedial measures to fence the site, and maintain the existing cap, and
control erosion; interim source control for off-site disposal of leachate extracted
above and below the on-site clay barrier darn, and reimbursement to the State for
source control measures.
17. KEY WORDS AND DOCUMENT ANAL.YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA TI F ield/Group.
Record of Decision
Stringfellow Abstract .
Contaminated media: gw, sw, soil
Key contaminants: pesticides (DDT), sulfuric
acids, heavy metals, organics
1B. DISTRIBUTION STATEMENT 19. SEcuRITY CL.ASS ,Tllis Report) 21. NO. OF PAGES
None 30
20. SECURITY CL.ASS (Tllis pagel 22. PRiCe
None
EP" ,- 2220-1 (R...4-">
PREVtOUS EOITION " OSSOL.ETE
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INSTRUCTIONS
1.
REPORT NUMBER
Insert the (PA report number as it appears on the cover of the publil:ation.
2.
3.
LEAVE BLANK
RECIPIENTS ACCESSION NUMBER
Reserved for use by Ul:h rrportrel:ipient.
4.
nTLE AND SUBTITLE
Title should indicate deally and brieny the subjr~tl:overa~ I)f the report. and be displaycd promin~'nlly. S~'I sllhlitl~'. if 1I>'I.'d. In smalier
type or otherwise subordinate it to main title. When.. report is pr~"arrd in more than line volume. re""iltth~ primary title. ildd v
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R~CORD O? :~CISIO~
RE~iSD=AL A~7SRNAT!\;E SEL3CTION
C"~I'9"I-'.
_'!.It....
Strir:;f?11o\O.7
eel i f 0 1- n i a
Acid Fits, Gle~ Avon, ;.ivs~~i~2
C.:':..J!l:'y,
A~A~YSIS RSVIE~~ED:
I h c. \i ere \~ i e t~.1 e d t !'-~ e f 0 ~ !. CI .~ ~ i ~.;
c s,c t:.;:'"~e ~ t s
i..~hic~
c::~ =.. J ~T Z e t ~ e
s~t~ con~itions ~~~ the c~~st-,~~fecti~eness
at the Stringfellow Acid Pits:
cf ~er~~~igl ~:tsr~~t~ves
Stringfellow Technical Audit Report
Bl~ck and Veatch Report
July 1983
Engi'r.eeri!1g S':'.!dy cf String fell:)',.,. Class
H---ro'ou'- r"a'c'-c. "-n-gerrQnl- Spml' n-r
~c.~<#c. .:y... yy .;.1 -.- L'~,=;. .c;. I l- '- - L ~
James Montgorn~ry Engineers (JMM)
I Dis?os&l Site -
;.L~gUSt 1930
Report on Phase II Por~~ fo!.- Closur8 of Stringfello\7 Class I
Hazardous Kiste Dis?osal Site - Eydrogeologic Eve~uation
JMM M~y 1981
An E~21uation of Gro~!1d
Clo~'.Jre ~;oni toring for
Disposal Site
JMH
W2te= Dis~0521 Alternatives and Post-
Strin~fellow Class I Haz2r6ous Waste
O:::tober- 1961
Staff
SUIT:.T.::.ries
aud R2:::oIT~endations
Five additional engineering studies which were completed by
James M. Montgomery Consulting Engineers, Inc. prior to August
1980, and are related to the Stringfellow site.
COMPONEt--:TS
OF SE:LECTED
OPTION
Initial Remedial Measures
Fencing
Erosion Control
Interim Source Control
Continued hauling and disposal
Storage tanks
o & M Plan
Ongoing Site Maintenance
Interim Offsite Measure
Contaminated ground water mitigation
..
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, '\.;
,;/...
-2-
Source Control (reimbursement fo~ partial measures)
Neutralization of acidic solids
Removal and offsite disposal of DDT contaminated mate~ial
Clay Cap
Barrier dam
Gel-injection wall into bedrock
;~ystem of moni toring, interceptor and extraction wells
Run-off abateme~t system
DECL~R.~.TION S
Based on my review of the above documents, I have determined
that the source control reriedial actions performed at the
Stringfellow site were selected following analyses consistent
with those analyses outlined in sections 300.68(f)-(i) of the
National Oil and H~zardous Substances Contingency Plan (~CP) an1
comprised a cost-effective remedy that currently is providing
protection of public health, welfare, and the environment. I
have also determined that the proposed interi.m sour-c:e cont~ol and
interim offsite remedial actions are cost-sf~ecti~e an~ necessary
to maintain and safeguard the existing s~urce control remedial
actions. These interim actions are necessary to protect the
public health and environment during the time required to conduct
the long-term remedial investigatio~ and feasibility study that
will identify additional cost-effective remedial actions th2t
may be required to effectively mitigate and mini~ize damage to
and provide adequate protection of public health, welfare and
the environment consistent with section 300.68(j) or the NCP.
have ceterrni.ned that the proposed initial reDediaJ mea!::1-1.res ar-e
consistent with section 300.68(~)(1) of the NCP, being cost-
effective and necessary to limit the threat of exposure to a
significant health hazard.
I
Consistent with section 101(24) of t~e Comprehensive
Environmental Response, Compensation, and Liabilitj Act of 1980,
I have d~te~lined that the offsite dispos~l of the material
contaminated with DDT was more cost-effective than the oth8r
remedial options for dealing with the material. The continued
in~er:~ or:site (is~osal of cc~t3~:n~ted leachate i2 ~ts c~~y
feasi~le ~ethod, prier to ire~le:Je;1tatic~ of fut~l=e
-:. 2r~~e<5 ~ a 1
acti~ns, to pro~ect t~e public hsalth,
from a present or potential risk.
l;;e1 rare aDd t71Eo
e ~ v i. r 0 nr:-. e n t
I have taken into account the public cc~~ents regarding the
selection of the remedial actions approved in this Record or
l\eCl'~l'cn ",~hilc;. -'''r-'/ P\'bl~- ,-,-,""'-r:o-'r'- C:"D¥"'\""'-""'Q.~ C~f~.;~-~ r-anC'''''o''''~
/oJ ;::, .. 1,.1_.:..- .1..;;:. \- -.. --- ....~d....,'..:._;::, -'-'::-::''-'- '--- "'-;;;;>""-". -... ,--:=- ... "-
and d i spcsal at sll contaminated ma terials, I have de ten:li n.ee
that the iDfor~~tion on this site a~d rel~ted analyses ttat
pres2n~ly exist would not support ~ decision under section lOl(2~
authorizing cffsite trans?o~t 2~d disposal of all ccnta~in.ated
material at this ti!!',e. The re:r.eciz:l investigation a:1G feasibilJ."!!IIJI
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s~~~y to ~e cc~~~cted by t~e St~te
sGcitional sou=ce con~rol meaSU=ES
~ill ~n21y=e the riesj fer
anj ~e~su~es tc ~i:i;5te the
offsi:.e co~rt.=.r;:i~1c:tej grc>v.r1d '~.:2.tsr plu!7:e, =';"1<: CC\r:-.;I\~:-e tr~c:.:' '...;i.t.h
ether res€~i21 m~~su~s£( i~clu=j~g cf~site t~~~s"po~~ a~~ dis?osal
of all contamiuztec sateri~l. Because t~e :~n~l re~sci=l ~easure
has not bEen selEcted for t~is site, anc additional r~~edisl
nE:-2.SL'.:::-2,S n1a.~' t:s r~E::ss~.c:.r"l, I \:.i"j.l er-Js~:~e thz.t aC:'2q'...1E:t'2 o~;:-.\:;rt:.lniti'2s
z.re provics::5 fCJr~ pL\~l:.= CO:T~~;=:its 2.:....6 cor:sice:-=.tic:-l or: t~cse C~:'i~ler:t.s
in the selecticn of ~~y 2ddi~io~al :enedisl actio~~. To tha~
ene, ! 2:j~ rE.~~i!"in~ tr-;z~ c. CC!7L-r.t.::-;i~J' !"",=-l~..:ioJ.s :;:>lz.:: :Je. i:-:~~'~rc..ted
..~,"I-, '"h.r:,
~.._"'.I. \",.....-
:-e:1:EG~21
invs.st.i;c~is;n/
fs~si~ili~y s~u~y.
~~ "--~~-,
Office of
L.ee t-:. Thcm,,- s
Assist8nt Admini~trator
Solid Waste ar\d E~E=gsn=~r
Re~f.'O:ise
-/h~/J'u
Date
..
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I .
.'1
':
! .
STRINGFELLOW SITE
Briefing
for Record of Decision
Materials
5ACKGROUND
A.
Site DescriDtion
The Stringfellow site is located in Riverside County,
approxi~ately five miles northwest of the City of
Riverside and one mile north of the Community of
Glen Avon. The site is situated in a canyon on the
southern slopes of the Jurupa Mountains. It lies in
the natural drainage path of approximately 270 acres
of the canyon watershed at the he~d of Pyrite Creek.
The Stringfello'-" site potentially a:fects the Chino III
Ground Weter Easin, a domestic drinking water supply
for approxim~tely 40,000 potentially affected residents.
The ground water supply is also used for ir.dustri~l
and agricul~ural purposes.
B.
Si te Histor\'
.
During the site ope=2tion fro~ 1956 to lS72, 2pprcxi~Ete~
34 million gallons of toxic waste were disposed of a~
the site. Fast disposal techniques included discharging
liquid w~stes, mainly acids and heavy ffietals, to pones
for solar evaporatio;1 and spraying liquid w~stes into
the air to accelerate ~vaporation. During operation,
the site consistec of 3.5 acres of evapora~ion ponds
and 5.6 acres of land :contaminated by aer~tion
operations. The total land area is approximately
22 acres. Substances disposed of include heavy metals
such as c11romi u:-;! en:: cacmi urn, ac ids ins 1 ud i ng 51.1 1 fur ic
acid and organics, including DDT and TCE.
In 1956, Stringfellow Quarry Company, Inc., opened a
haza~dous waste disposal site pursuant to a l~nd use
varianc9 iss~ed ty t~e Riverside Count~' ?la~ni~g
C::mLi'. i S5 icn.
?rom 1957
r.azardous
th~~ugh 1553, the site oper~ted as a Class I
~~ste di5p~sal site.
In 196), during a heavy rainsto~m pe~:od, an uncGntrolled
release of che~ically contaminated water occur~ed.
This material dischar~ed d~wn Pyrite Creek and through
the Cc~munitv of Glen Avon, located ao~roximatelv one
mile dowGst~eaD. After this incident:-the loccl-
cOIT~~nity be9a~ to seer. the closure o£ the site. In
November 1972, the site was voluntarily closed by the
-
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2
StrinQ~ellow Quarry Cornp~ny, ~nc. In lS7~! the
Ri'\le=-£ice CCtl~1t:{ ~'1=-nrl:'j"1g C0:7:.:':.issi0U :s\:ookt:::": ~:-:'2 ~iters
land use ~~~ia~ce( ~~d in 1975, the ?~;i~~~: ~~~3=
Ouality Control 30a~d (RWQCB) was no~i~~~~ tv the
cor?o~i~ion that it was financi~lly u~Eble t; continue
IT.Z-l::":.€l1c..:"1'::.:? c.f t~:.':: sitlS. ~.~.::-:.~H~::el].~:-,v.- C:~:.:""::;::l C:)::~~c.~:!{
Inc. f2j.led tQ P&y ?~00er~y taxes 2f~e~ ~isc~l y£sr
lS73-1S7~.
- 10-- "
.!. n -, I ~, cr!€
r:\'r~C3
cE::l=.:rec
the £ite
. . .
c. ;:'...!':-~-'lC
r-n.: :!32.~ce
~s 2 no~o~er~ti~~ ir.d~E~=Y.
T :-l i s c. c t ~ :: ~~
cl~Cv..:EC ~hE
2~:.~JCS :'0
~egi~ i~s st~cy of
t~le s~ te 2:--40
'::0 ~):'c.cE:
for si~e closure
liE:ns on
actions.
the pro~erty for costs i~currsc
~he RWQC3's consultaf}t, Ja~es ~. :~O~~tgoffiery ~nginee=s,
Iilc: . (J~1M), producE.d a report in 1977, r2C:Ql~iler.~iing the
encapsulation of material onsite by: 1) injecting
gel into fissu~es in the underlying ~edrock;
2) installing fficnitori~g and intercsptor wells to
loca~e and e~tract the down~trearn contamin&ted plume:
and 3) installing a clay cap over the sitE:.
In 1978, the State le9islature appropriated funds for
atate~ent a=tiviti~s at the Stringfellow site. Before
these activities could be initiated, heavy rainf~ll in
the spr iog of 1978, on(;e c.gc~ in, caused the site to
overflow into pryite Creek and downstream through
Glen Avon. In order to prevent a catastrophic release
fro~ the site, approxiillately 800,000 gallons 0: chemically
conta~inated water was discharged to tha Creek under
the supervision of the RWQCB.
Between 1978 and 1981, the RWQCB contracted for the
removal of approxinlately 6.5 lLli11ion gallons or liquid
wastes and the DDT-cont~~inat~d material fro~ the
site. These wastes were hauled to Class! hazardous
waste disposal sites in southern California. .
. .
In March, August, and September 1980, the Federal
Regional Response Team (RRT), with the assistance of
the u.s. Coast Guard Pc.cific Strike Team, was req~ested
by the RWQCB to assist in preventing a third surface
discharge. This response effort resulted in the
removal of over ten million gallons of chemically
contaminated water, reinforcement of the containment
barriers, and improvement of the truck loading area.
.
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3
In 1980, the property was acquired by the S~ate and
Riverside County by tax deed. In 1981, the State
purchased the County's interest i~ the property in
order to facilitate the site's cleanup. Restrictions
on the future use of the property have been recorded
in the title to prevent future disturbances 0: the
site.
Following a public hearing on July 2, 1980, during which
° six alternatives for abating the problems at the site
were discussed, RWQCB adopted Resolution No. 80-142,
which called for implementing the alternative of complete
removal of all liquid and solid wastes from the site.
In December 1980, because it was apparent that f~nding
for the total removal alternative would not be granted,
RWQCB adopted Resolution No. 80-219, which stated that
an interim abatement program should be im~lemeTlted to
provide protection from leaching or washout of the
waste material. In addition to protecting residents
downstream and the environment, this interim ~rogra~
would facilitate the total removal of m~terial once
financing became availalbe.
The RWQCB was awa~ded a grant from the State ~ater
Resour.ces Control Board (SWRCB) to acco~?lish 2.n
interim abatement program for onsite con~ain~ent of
wastes. In 1981, geological aha hydrological
in v est i get ion s \J ere con d u c t e d . I n ~1 c. y 1 9 8 1, R C E...\
funds were provided by EFA to the RWQC3 for cesign
and construction engineering activities for the interi~
abatement program.
The interim ~batement program was designed to contain
the wastes onsite and minimize the risk of further
contaminant migr~tion until funding for total removal
was available. The program was aimed at red~cing the
amount of contained waste, neutralizing the pH of the
remaining waste, eliminating surface flow co~tan'ination
~y ca~?i~g, reducing ~nd treating the existin~ gr~und
w.ate!" l::onta~.ir1atior;. ;.. detai2.ed s':.HnI.i2ry 0: tr:e ir:teri:-.1
ab2teme~c p=ograrn is prese~ted in Ap~en~i:~ 13.
The State's expressed interest in participatin~ in the
Super:und pro~ram resulted in Gove~nor Bro~n designating
Stringfellow as the State's top priority site iD ~ovem~er
1981. In order to continue the activities at the stte
and to qualify for CERCLA funds, the State re~uesteG
a deviaticn fro~ EPA's grant reg~lations in July 198~.
Additionally, the State re31ized that all actions
take~ would need to be consistent with CERCLA and the
draft NCP. Therefore, offsite disposal of haza=dous
wastes would have to be evaluated and determoned to
be more cost-effective than other remedial a~tions.
.
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T~ .::-~i1
-.. h;J- - -
and Jur;e
lSS2 tl1e
St~te r~c~~~e~~~c to S?A thct
tr.;e 0:-15: te
.ccnt~i~~e~t ?r:g~'~ffi, ~i~~ ~d~iti~~~: ~~~sures
i~rs effectiveness, ~~s the cos~-~~~ec~iv~
~o e r::-ic.j41::e
re: !7~E G~: .
C:1 JU:~' 2, lS52, t~s C~li~2=~~2 r2~Lr~T~~t of ?~~l~h
S2~~icES (~a~S) submitte6 ~n ap?lic~tio~ ~o= 2 ccc;er~tive
c.;.reCT~L~:~t to EF:-.. T~~ D0::8 ~~qufS~,~€d r'e:~;l:t>Jr=.€:T~2~t
cf $3.6 !~~illio:l :or- t~~ F;,~:.~QC2!5 i:1t-2~:TI~ ;::'-:::';-r~;-I:. In
~~~i~ic~1 DCES =e~~s~te~ S2.E ~~llic~ to 2C~~~~~ the
?~~'~::;C=.fS il;te.~i:n ~=-cC;::-2.;:: =~' C:e~i£:-.::':-1;: 2:~j i::~~.=:ll~~:~
c..rjj:.:.ic:'""4=.1 ~loi1:":'Qr::'rlg c..f"::j in:':-2=ce~-:o~ 'y~',~:"12 ~r~j t)~."
co~ducting feasibility stucies fo= u?gr~dier.t g~ound
~eter diversion, onsite con~ainrnent of contami~ants
and downgr~dient plume Ebatement.
In August, while the applic~tion fo~ the July cooperative
~gree::,s;l~ lI.'as beir:g p:-ocess;;:;d: E?~ co,,',plst'2d ?i1intensive
inv~~tig~tion which yielded goed evidence linking "
responsible p~rties to the Stringfellow sitE. Eased
in part on this evidence and an is~ue ccncer~in] the
State IS cost share, EPA suspended procEssing ~he July
applic~tion.
In Au;ust an~ Octob~r 1982, S?A issued over 200
com~ination CSRCLA section l04/Notice Letters to
responsible parties. The govern~ent nego~iating team
which consisted of SPA, the State, and Department of
Justice (DOJ) held a general weeting with ~es?onsible
parties in Novewber 1982. The purpose of this meeting
~~s to :nitinte enforcement ciscussions with responsible
parties to recover pas~ and future cos~s of cleanup.
The government team met with the rssponsible party
ste~ring co~~ittee on four subsequent occasions to
discuss settlement. An acceptabl€ settlement was not
offered by responsible parties. On April 21, 1983,
DOJ and the State of California filed a civil suit\in
ths United States District Court for the Central:
District of California. Eighteen generators, 4
transporters, and 9 owner/operators were named as
defendants in the lawsuit. The complaint seeks to
obtain funds from the defendants to abate the hazards
at the site and to reimburse the government for all
funds. expended by it. .
On April 22, 1983, a Congressior.al hearing was held in
the Co~~unity of Glen Avon. At that hearing the
Director of the Office or Emergency and Remenial
Response (OERR) discussed the projects to be con.pleted
und€r the proposed cooperative agree~ent.
On May 4, 1983, the Director of OERR signed the Action
Memorandum authorizing remedial planning work at the site.
.
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L__-
5-
On June 15, 1983, a final coope~ative
received in EPA nead~uarters from the
ag reem'2n t ",Ias
State of Califvrnia.
C.
Recent Immediate Removal Actioas
On or about May 16, 1983, liquid was discovered seeDing
into the surface several hundred yards below the
Stringfellow Acid Pits barrier dam. The flow mixed
with an ongoing stream of water which is channelled
around the site, and eventually leaves the site via
Pyrite Creek. Because of heavy inflow to the site in
recent months, the liquid level behind the ba~rier dam
remains high. Because of the hydraulic head behind
the dam liquid which manages to escaps t~e barrie~
raises the water level significantly below the dam,
forcing it to the surface.
An initial emergency measure taken by the California
Department 0= Health included digging a pit approximately
10 x 20 feet, fcur feet dee~, from which the liquid
could be removed several times daily with a vacuum
truck. The direct contact threat has been alleviated
by the installation of a french drain in the seepage
area, with a sump to collect li~uids and an automatic
pump to retu~n liquids to the holding tanks. Grading
and rechannelling have been cOQpleted to divert
uncontaminated water around the area of seepage.
Security of the site has been enha~ced by installation
of a partial fence alo~g the r~ad leadi~g to the site
gate, and repair of an existing fence across the creek
~hich runs through the site.
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6
II.
SU~M~~~ O~ R~~EDIA~
oz,. C!' 10:\ S
T~:e Stzte hc:s s~=::~i.:t~c 2. cC:';:~:_"E~~i\/~~
C:;:"-.£.'2:~.=r::. ~:) f;"'!1j
sever~l re~e~i~l =es~onse acti7j.tiss.
~his ~~~t:c~ d8~C~ib~s
both the ~xisting and propo5~d sctions for ~hich funding is
being rec:.uE::stso. l:.dcitio~.=.l :-e:-.;-=:G:=..J.. ;;l=.l"~:-:i=--.g ~c~~.\:,~~i'?s
(RI/FS), \:iilc:-, ~~-e 2~S:') 2. y2';.-t of the cco::,s::c::.i";'2 a:i.e~,;T~ent,.
~~e dis=~ssed i~ Ss~ticn III.
A. S~c==~ C~~~~ol ~~~~s~~es
-.-----
D"rl'n- ~~g -~~:_~ =~-~ lo~~ ~~ .l'Qc;~O ~..p Ch=;~ _~:lt~...~~'_:~:t-.-~ -
~ .'~ 4......1- ~":::'..J.V.- ....-,-'.., ;";'-"""'" ",. '-.....- -'--'-- -- -- - - c::. .
series of s~ginee=ing inv~~tig~tions and st~d:~s to ~v~lu2te
altern~tives for ~batement of the risks posed by the Stringfello~
site. The ccnclus ion 2.;,:6 !:"€:C8IT'C,:Gnc.c. t ions of t;-,E::' p;:-ocess 2.re
sum~arized here. A se~ies of reports resulted in t~e c~~sijEr~tion
of 6 altern~tives in the December 1979 report prepared ~y James
t~. r-10rlt;om.~r~: Engineers (J~'::.i). Tljes-2 alt.er,,"la~i\-"es c:.r-2 s:..:rr::-;&~ized
below; howev~rr a detailed description of the 8ar~iEr e~ginEering
effort a.nd th.~ re;:,edial actions act\.:2.J.ly c:-ns;:::'..lct-3C, is ;;:-e~2r,ted
in Appendix 1. The alternatives we~e: '
Altern~ti'.;re
Desc=iDtion
Co~o t
r <:: .... ; ..- " to - 1 f
-.J.J~-...I~_~ ,
1. Remove liq~ids (offsite ci~posal),
level ?on~s an~ g~a~e site, install
clay cap, d~ain2.ge and leachate collection.
$2.:i.O,OOQ
2. 5e.me as No.
of soils
1 with kiln dust.neutre.lization
$990,000'
3. Neutraliz2.tion of liquids and solids onsite,
level ponds and grade site, clay ca?,
d=ainage and leachate collection
$910,000
4. Same as No.3 with bctto~ sealing
of site
$ 1 , 2,4 0 , 000:
5. Chemical fixation of liquids and solids,
level ponds and grade site, cl2.Y cap,
drainage and leachate collection
$1,780,0:00 to
$2",850,000
6. Removal of liquids and solids, (offsi~e
disposal) level ponds and grade, clay cap
$11,600,.000
1/ 1979 cost ~stimates
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7 .
The alternatives were evaluated for cost and tec~nical feasibility
The effectiveness of each alternative in controlli~g the release
of wastes into the environment was a1so evaluated. Alternative
No 3., onsite neutralization and containment of solid and
liquid wastes, appeared to be the most cost-effective; however,
alternatives 3, 5 and 6 were evaluated in more detail to imDrove
the cost estimates and account for worsening sit~ conditions.
The revised cost estimates for the remaining alte:natives were:
Alternatives
Cost Estirr.ate2/
No.3.
$2,496,000
No.5
$4,036,000
No.6
$21,000,000 to
$41,000,OOO~/
A public hearing was held on July 2, 1980, to discuss the various
alternatives considered. Comments from the lo=al com~unity
stror.gly favored the removal and disposal of li~~ids and solids
(alternative No.6). The RWQCB passed a resolution sU9Porting
the removal alternative (No.6) and requesting fun~ing from
the SWRCB. Ho~ever, due to the high cost or removing and
disposing of liquids ~nd solids, the RWQCB subseque~~ly approved
construction or th8 onsite neutralization and =ontainment
e.lternative (No.3) as an interim measure until funding for
removal could be obt2in~d.
On April 9, lS82, the RWQC3 reevaluated the ~roposed site
remedies in light of the proposed NCP and CE~CLA cost-effective
requirements and reco~:end~d alternative No.3 to the State DOBS.
In June 1982, the State recoIT~ended to EPA th~t onsite containment,
witr.out future re~oval of solids was the cost-ef~ectivG rern~dy.
This recommendation w~s based on the following factors:
1. Onsite containment was the least cost alternative to
adequately abate the public nuisance and the threat of
discharge cf tcxic ~aterials. Ttle meaS~~2 s~1o~ld also
iJrese:1t.
~o ~dV~=S3 er.v:ronrn3ntal
i~?acts.
2. Acverse impacts created pri~r to the re~eGial a=tion
would be mitigated by clos~re ~nd mainten2~ce o~ the:
site (e.g. operation of dOwnstream extraction ~ells).
3. Additior.al me~sures to maxi~ize the
cont~in~ent should be evaluated.
r e 15. a j i 1 ). t Y 0 f
2/ 1980 cost estimates
~/ Cost r3nce was based
- faciliti~s
on actual
q'..lotatior.s
froT7!
disposal
..
-------
8
;.-.t-.E St.~:.S'S ceci£iC'~J tc;c:~~ t~s c:::~::.L':-;:t~Jts C-=5~.~e2 ir:~o
account concer~ing their p~eference for the tot~~ rs:~oval
o?tic~. The ~~~lYEis cf th2 ~ltet'~~~~~s5 indicated ~~~: the
~~5~ cC5t-E~~~cti~e 501ction to contr~l t~e Eource c~ ~~z2r~~u5
w2ste ~as onsits cc~t2i~rn~~t.
r~O~.....:E:'~~~E' r- ,
tf.E. St.c..t~ls ~evie~.~ 0:
. the of!site c~~t2i~~iE~~ ~r0j~ct indicated tt~t ~~6~tio~E: ~e~~U~2S
8~Y ~~ ~es6e~. T~:~~sfor~, in =EEpcnse.t2 t~S~E C8~ce~~~s, t~e
S:2~E ~~C~?~S~ ~ lc'~~-~e~~ ~E~:~~~al. ~~~~sti~a~io~ ~:.~ f~~2iji~~t~.
st~cy ~o e:rec~:vely ~lt:;~te ana ffiln~~l=e c~~age to anc ~~OV1C€
adequate prctec~i0n to public healt~, welfa~e or the en~ironm~nt.
This evaluation will include additional source control ~easures,
including offsite t=ansport and dis?osal of all contaminated
r:\c.t.erial, 2nd r.;~c:SL:res to mitigate the offsite cOiY.:2:.r~{inated
£round wa~~= plume.
To thcL. ~nd, .::; Co:r.r.-:unity r:e1at ~o::s Pl=.n ',,:111 be iJT,;::lf:r:,en::ed
~y A~gust. 22, 1903, p~i0r to initiation of field activities.
The plan ...'ill re~ui;.:-e tha:. cOIT.znunity re1c.tions ac~ivities b-=
inte;rat.ed with the ~eme~ial investigation and fe~sibility
study activities. Adquate OrPQ~tunity for public CCro~EDts
. c o:-! c e r r~ i r; ~ t be sea c t i v i tie s y,' i 11 be p :.- 0 v ide d for a r,d c :: ,,'jT,.~ r: t s
wi:l be a~21vzed and inte~=ated into the selection of anv
edditional =~~~a:al measures.. ~
S. Offsite
D::D052..1
CO~Donents of the Containment Alternative
1. Liquid Waste Removal.
Onsite n~utralization of liquid wastes contained in the onsite
ponds was p2.=t of the recommended containment alte~native.
Eow~ver, before the State could impleDent this a~tion, E?A's
Regional Rcspon~e Team and the Coast Guard removed o~er 10
million gallons of liquid waste on an emergency basis. This
eliminated the need for liquid neutralization as a pa=t of the
remedial action.
2. DDT Removal
A Dart to the onsite containment alternative involved the
seiective removal and cffsite disposal of DDT contaminated
material. Since the material was cQnfined to the northern.
portion cf the site end due to its highly toxic nature, this
material was disposed of separately from other conta~inants.
The State evaluated both onsite fixation and offsite disposal
as feasible alternatives. Proposals we=e requested for
both alternatives. Evaluation of the proposals indicated
that complete re~ov~l was the most cost-effective approach.
.
-------
9 ".
This decision was based on the following
cos t proposal s: "
Alternati've
Cost Quot2tion
Onsite fixation
$398/CY to $632/CY
$l39/CY
Off site disposal
3. Leachate Collection and Disposal
The onsite containm~nt alternative included facilities
for collection and extraction of leachate, including
extraction wells and a gravel collEction syste~. Operation
of the two extraction wells located upstream o~ the clay
barrier in the gravel collection system is rsquired to
maintain the integrity of the cl~y barr.ier ar.d to help
prevent leachate seepage from the site (Note: The clay
barrier and gravel collection system were added to the
alternative since actual site conditions did not prevent
lateral migration of leachate as was pr~vio~sly ttought).
The ex tract ion well :loca tad in the northern pc\rt ion of
the site collects contaminated water from seeps, sprir.gs,
and bedrock fractures in the area. Well IW-l is pumped
because it is located in an area of high conta~in~nt
concentration, and removal or contaminated w2ter froD
this well will reduce the downstream ~igration of cont3m-
inants. The pu~ping of these four wElls a~d hauling the
waste cffsite to an ap~roved disposal f~cility is the
only preser.tly available method of disposal. The most
co s t - e f fee t i 'J e a 1 t e r'n a t i ve . for 1 0 n 9 - t e rill d i S P 0 S 3 1 v," i 11
be deterillined in the Feasibility Scudy.
. :
-------
I I I.
10
?RCPOS2D RE~'~S~IAL ?L~~:~I~G
ACTI\7ITIES
.
.. .
C~~~~-~~ivc ~~-~=m="~
_.:::":':::'.:'-- - '-- - C":.':: -..... -....,,-,.,-
T~!e St~te h~s s~~~itt~d 2 CO~~£~~~ive 2;reS~~~t ~8
fu~d several re~~dial res;cnse ac~ivities! in=luding
~~st ~nd ?roposed ~0medi~1 cCti0~S, &~C func:~~ for
r~~e~izl pla~n~ng. r~)e £e~e~~l c~jecti~~ of t~2
=s~e~i21 in~es~i.Q~tic~/~e~si~ili~y st~~~' (~!/FS) is
to ~E~elo~ ~ cos~-ef~ective ~e~e~i21 &ction f~= fin~l
si~e cl=5u~e 2~ ~~e 5t=i~;~ellc~. ~aci:i:l =~~sistent
'no";":" C.'-:::'-::. ;::,....:,
- ......L - '--'-- -..-.
Fe~e~~l ~c~iciES ~~~ ~~i~E~~~€S ~~
?rotect public health, wel:are, anj the e~vi=cnNent.
The contr~c~or will review background i~f2~s2tion,
collect and analyze additional eata, establish
evalu2tion criteria, identify and select the cost-
effec~ive alter~ative, and develo~ precesi~~ criteria.
The remedi~l i~vestig&tion/feasi~ility st~cy includes
th~ee major areas of t~e site: 'u?gr~die~t, cnsite,
a ~ j GO v..'n;; r 2. die n t . The 0 b j e c t hr e s 0 f . L 1-: e ~ <2 S P ~ c i fie
ar~&s are ~s follows:
U?GR~DIENT: lde~tify 2~d evaluate ~ethods to
preve~t or ffi~n~ge upstreaffi grou~j vater and sur~ace
water entering the site.
Oh'C'ITt:'. Ir.""...\!- ; t=., "'no' e\r-lu'at-e me"'hoo's ...0 "'r"O'Jent
.." -- ~ ,. - -... - - .£- J ~. &. C. - 1 L.... \... t:"' - - i
the mig~ation 0: existing hazardous substances
offsite.
DOvmGRADIS~~T: Identify and e\'aluate aquifer
characteristics, the extent of the existing plume,
and methoGs of controlling pollutant migration in
the ground water dow~gradie~t o£ t~e site.
B.
Federal
S't u d y
Lea,d Fast-Tr-ack Re!'.1ec ial
Investication/Feasibilitv
. -.,0.. -
The State requested that an EPA-lead fast-track remedial
investigation/feasibility st~dy be conducted to identify
and evaluate alternative methods of controlli~g the
mi]ration of contaminated ground water in the downgradient
area. This project is expected to require two to
three months arid will resul t in a recor:l!nended' technology
for treatment of contaminated ground water in accordance
with the approved interim off-site measures.
..
-------
1:1:
C.
EPA Technical Review of Past
Remedial Actions
The firm of Black and Veatch was hired to conduct a
review of past site activities and conduct a tech~ica1
audit of work performed since the passage or CERCLA.
The review cr:teria used by Black and Veatch included:
1 )
Consistency with the NCF,
2)
Implementation of work in a logical and orderly
manner, resulting in a reasonable site response
approach, a~d
3 )
Conformity with standard engineering and construction
practices in effect at that time.
The past S9urce control actions (May 1981 to date of
award of the cooperative agreement) were found to be
consistent with the three review criteri~. Expe~jitures
for these actions were claimed by the State for reim-
bursement under a deviation from the Federal grant
regulations (40 CFR 30). Based 00 the outcome of
this review by Black and Veatch and a fiscal audit by
the BPA Inspector General, EPA has concluded that the
State will~e reimbursed for the majority of the
claimed expenditures in the a~arc of f~nding for t~e
cooperative agreem~nt.
D.
ProDcsed Interim R2~edial
-
!',ctivities.
The State has requested
These include:
fundii1Q
for several ne'd
activities.
1 )
2)
Initial Remedial
r-le2.sure:s.
Interim Source Control Measures.
3)
InteriI1
Off-site Measures.
~hese in~er:m ~e~sures are suppl~~2nta~ C8ffi?C~ents 0:
existing work done at the site, a~d as s~ch are ~ot
r.ew remedial ac~ior.s. E2Ch ~ctivit1 is discussed
below.
-------
12
1.
Initial 2s~e~i21 Me25u~es
This R£c8rd of D~cis~o~ zpproves f€n=i~g of th2 ~~t~=e
site to li~it the :~rs2t 0: ci=e~~ contcct 2nd e~~siQn
control me~su=es to mi~i;~te d2rn~gs C3UEe~ ty s€vcr~
,~£~the~ con~~ticns t~ the sitc. T}~sse ~~££~;~es ~:e
a9?ro?ri~ts ~~:d c~~s~stE~~ ~ith t~e N~tic~2~ C8n~i~ge~cy
Plz.n «0 C:-;" 200.63 (e)(l)(1) E:.:!c (ii)j.
r~~ci:1'; ,,::.11
~S~Er u~~ut~~~i:c~ ~==e5S tc ~~~S
£i~s
.?nc.
li~it the Po~€~~~al ~== ~~=€C~ co~~~c~ \:ith ~2Z2~~~~S
5u~st~nc~s. 7his ~ction ~~ll ~~3C prc~i~~ sscu=ity
for materials and e~~i~sent stored. at the site during
sitE. ir1\.TEstigatior:s and rem-:dial actions. Fencir.g is
also considered cost-effective when compared on a
life cycle bas:s to other security measures such as a
24-hour 2 day security guard.
Erosion control h2S b~en p~opc5ed as ~n app~opri2te 1RM
in acc~rdanc~ v:ith Section 300.68(8)(1)(ii) of the ~CF.
Flaceme~t of a clay cap with a one foot native soil cover
\>!e,s pal.t of the p~evious onsite contc.inr:.cnt act.i:)i1.
Eo~ever, the native soil layer ~as not seeded to help
prevent erosion ~nd the heavy rains during the win~er sn6
spring o~ 1982-1983 caused erosion problems at the site.
Erosion control measures a~e considered necessary to ~revent
erosion through the native soil and clay layers with the
. possible washout of contami~ated rn~terial, and to maintain
the integrity of the perimeter drainage citches. There
are no other feasible alter.natives :or the IR~1 because the
proposed activities supple~ent and are required to maintain
the effectiveness of. the drainage controls installed during
the previous remedial action.
2.
Interim Source Control
This Record of Decision approves the hauling and off-
site disposal of leachate extracted above and below
the clay barrier da~ onsite. This measure is necessary
to maintain the effectiveness of the clay barrier dam
and no other effecti'e interim alternatives currently
exist. This measure will be funded during the time
required for the State to complete the long-term
remedial investigation/feasibility study (currently
estimated to take 18 months). The long-term RI/FS
will evaluate alternatives to reduce leachate generation
onsite.
. .
-------
. -1-"
"
13
The above activities are consistent with source control
measu~~s as defined in NCP section 300.68(e)(2) because
they are necessary to prevent or minimize the migration
of hazardous substances from the site. These activities
are considered i~terim because they are necess~ry to
supplement the existing remedial measures until the
reme~ial investigation/feasibilty study can be completed
and allY add~tional remedial actions recommended by the
study can be i~plemented.
These interim measures have been found to be cost-
effective 06 the basis that no other feasible alternatives
are available. These interim measure are not distinct
remedial actions but are components needed to maintain
and enhance existing site controls. .
This Record of Decision a150 certifies that ccntinued
interim offsite dispos~l is necessary to protect public
health and the environment in conformance with CERCLA
section lOl(24).
3.
Interim Offsi~e Measures
This Record of Decision approves interim offsite
measures to mitigate offsite contaminated g~ound
wate~ migration. In accordance with the NC?t offsite
measures can be implemented to mitigat~ the effects
on public health, welfare, or t~e environment when
contaminati9n has migrated beyond the area where
hazardous subs~ances were ori~inally located. This
situation exists at the site since a plume of contaninated
ground water is migrating from the site toward areas
where ground water is used for potable water supplies
In the application for the cooperative agree~ent the
State requested funding for pumping of ground water from
offsite wel~s IW-2 and IW-3, to mitigate this pr~blem.
EPA has de~1ed funding of this task for the following
reasons. A: study recently cOTI".pleted, etJalua~ ingt~e
effects c~ purnning IW-2 and IW-3 on the exis~i~g
con~arninant pl~~e, concluded th2t ope=a~ing thes8
wells woul~ n~t significantly effect the movement o~
the plume Cecause the l'?adin9 edge or the pluzL€ was
past the influence 0: the wells. Therefore, it is
not recoIT~ended that these wells be Dumped until
further evaluation has been completed. .
EPA has aooroved aooroximatelv $2 million for interim
offsite m~~sures o~-the condiiion that the fast-track
RI/FS is completec and reco~~ends such rneasures. The
fast-trQcK :RI/FS l;,Ii11 determine the loca t ions of ne'''''
interceptor wells and technology required to dispose
of contaQinateJ water .umpsj froQ the wells. .
-------
T ,-
- ..; .
FU7JK~ ~CTIVITIES
T;:c
!:'e::.'::ci2:.1
DO ~l S \;: i 2.1
RI/'F8. ~:: II
c..d::~€s.s
t!1:-ose
J. .(
-~
- -
C --- ~ ' -'';-' --. '-'
Va\,:.:---t:::" I....'';::--.l
i~ve8~~;2ti~~/fs22i~j.l~ty
~ :1
. . .
2..PP:-C»: ::"1':'&2 te :...~."
e.,,: 21 ~~ te
c.rE '::S
2r.Q
r 2: C '::~l-:e ~ c:
rSTt:ec i ~ 1
1 - }-: ;:. 9 L- c ::; i f. :-: ~. ;
£2c~ic';i
cn
:'~.:e
site:
~t:L~.:~/
('2:'~~~C tee
1 S !L":':;:. ~h~'.
. .
~ c -:. ~. 0 ;-: oS
c.nd
I:
3-d::l"'~:Lg:-C:...jit2;!~ (tl-~e:;'.e 'n:cre CiSC'.J25€C ~rj
~~~itioD~l re~e~i~l Ecti0~S a~e recu~rE0
~C1 i;:.,p ~ove
rE.licjili.~y.
.,... i 1.1
2G.
~:-e;:~:-ed.
Z.:7: -=: ~~ ~ -s ::..
~.=- ~;
t..:-: '=: ~~
~p;.:- 0\:-02 C.
c:
t:1'~
:'-==
re:C,ES::"2:.:'
E:c:~ftin;
:-~'~'';; 2. S;J:-e S I
..,-. -
....\"""l.
E~'~:'.. z~:~:'-oY~l.
C:~
~':::. -,,-,....--
~.... - ... ..., - -
c::
"-~
... ,-'
t:-;s
,- ,
~ :::-.;:-~ € :-'-:2:; 7- ~. : ;..:.:-:
':' ~: E:
CC':::;-:':- ~ L:. t~:E.
::~r:::
--~...~---
c::....... ..... ~ \..'~ 1 ~ .
..
bj'
'I'he
to
2-0:-lS i te;
I:i:I J)
- . .
L .~. \: J. S 1 C n
E C = '2 ~. :-.~I":;' n t
t;,.!_~
-------
. .
STRING~ELLOW RECORD OF DECISIO~
APPENDIX 1
HISTORY 02 ENGINEERING EVALUATION FOR PAST REMEDIAL ACTIONS
A.
Enaineerinc Evaluation
- .
In late 1975, the RWQCB requested funds from the State
Water Resources Control Board to investigate abatement
alternatives. James M. Montgomery Consulting Engineers,
Inc. (Jl1M) was selected to study and recomrnend abateI:1ent
alternatives. Alternatives for opening the site were
also required by the State Board to assess the
comparative costs.
The primary purposes of the initial JMM report, submitted
in 1977, were to develop and evaluate alternatives for
either reopening or permanently closing the site and to
provide future operating procedures and monitoring
require:r.ents.. The report also presented a history of
site operations, operational criteria, and administrative
actions; a description of the site physical characteristics
and the basic geologic and hydrologic setting of the
Region and the site; and, a summary of ground water
quality monitoring for the area downstream of the site.
The review of the ground water quality data revealed
degradation of ground water quality downstre2ffi of the
site which led JMM to question the previous cssu~pticn
that the bedrock under the site was imperrn~a~le and
concrete barrier prevented contaminant migr~Lion from
the site. Three measures were incorpora~ed in each of
the alte~natives for reopening or ?er~~nsn~ly closi~g
the site to provide protection of downstream ground
water users from contaminant migration:
o
Construction of a bedrock sump downstrec;.;<, of the
concrete barrier to collect leachate s:sping unde~
the barrier.
o
P:.essure groutin~ the bed~ock both under the concrete
barrier and at both ends of the barrie~.
o
I~s~~llatio~ 0: inte==ep~c=
:,,~ -e II s
Gow~s~=e~~ or t~e
co~ta~inant plume.
concret8 ba~rier to intercept the
The alternatives evaluated for site closure are su~~arized
below. The actions described in Altern~tive A (MinimaJ
Improvements) are incorporated into all of. the subsequent
alternatives for site closure.
o
Alternative A, Minimal ImDrovexents: Consists of the
three measures disc~ssed above plus removal of -
contaminated soil downstream 0: the e~istina SUffiD,
replacement of the northeast corner of the peripheral
-------
...
L.
s.i~e be:-::l v..'ith a c~c.y D8rmr c:'sp~sc.l c:: 'w.ate::-
ext::2.~;~~'::' frC,:7l t:"1e in~e~CE?t:)::..- ~-ell.sr c.nd
i~st~llc~~c~ 0: ~~~i~~~iD~ ~~lls. (:~~i~~~sc
-- ~l?O,OOO).
cast
o
~~~2~~eti~~s Sf Le~el ?0n~s ~~d Ccve= 5ite: Co~sis~s
cf Minim~l !~~~ovem~~tsr ~e~oval cE cont2ffiin~ted
l~~~id, lev€~i~g of ~~=~S witl1in the site, ar1d
~:~CCE:~~t c~ ~ s~:~2ce C2~. (~3~i~~t~d c=s~ (51)
__"0 ~37C:,OC'O).
c
~~ts~u~:iv; C, rill tv G~Sd2 a~c Cov~= Si~e:
Consists of ~inirnal Irn~rovement£, re~oval of
contaminated liquid, placement of fill to level
the peripheral be~ns, and place~ent or a surface
cap. (Estimated cost (C1) -Sl,~lC,OOO).
o
Alternative D, Encapsulate ~ate~ial: Consists o~
~~iniD.al Imprcvements, rer.\o\'al of ccntE.c"inatec lic;:uic,
e~ca?5~lation cf co~taminat~d soils and sludges,
a~d place~ent of surface cov~~. (Esti~&te~ cost
(D:) -$850,000).
o
~lternative E, Renove Co~ta2inated Materi&l: Ccnsists
of Minimal I~prove2ents, removal of contaGinated
li~uid, removal of conta~iri&ted soil, and placement
of a cover ove~ or preparation of bedrock surface.
(Estimated cost (El) -- $3,700,000).
The e7aluation process ,weighed the advantages and
CiscGvcnt&ges along ~ith the cost-effectiveness 0: each
alternative. The recoIT~endEd alternative for site
closure was Alternative 3, Level Ponds and Cov~r Site.
The California Departmsnt of Health Services (DOHS),
V,arch 1979 repcrt suggested, amor:g othsr rccc:Tlne-ndations
that pH of the site material be raised to prevent
possible detericration of the clay cap. In the JMM
Dece~ber 1979 report the recommendations by DOHS to
alter the waste pH were addressed. .
The primary purpose of the December 1979 report was to
reevaluate alternatives for site closure, developed
previously in the January 1977 JMM Report. However, a
number of site conditions had changed or w...:re discovered
in the intervening period which changed or allowed
refinement of the assumptions used in the previous
study.
The report compared the existing site conditions and
available data with those reported in the earlier study.
Based on this new information, JMM developsd a program
of interim remedial activities, evaluated the technical
..
-------
3
and econcmic feasibility or chemical fixatien and
neutralization of contaminated liquid and solid wastes,
and performed a fe~sibility analysis of six closure
alternatives.
Changes in site conditions required reevaluation of
previous recommendations as noted below:
o
The volume of liquid contained onsite had increased
from 300,000 gallons in 1977 to more than 3 million
gallons in 1979, as a result of heavy rainfalls
during this period. The increased liquid volume
significantly increased the cost of tr.e alternatives
in the 1977 report which included hauling the
offsite disposal.
o
The previous assumption of minimal subsurface inflow
to the site through the bedrock was bas~d on the
observations.of concentrated vegetation in the
upper portion of the site during the dry period.
The observance of actual seeps and springs in
these areas during a wet period implied a more
fractured bedrock and a more substantial subsurface
inflo~ than had previously been considered.
o
Ground water monitoring data accumulated in the
period between the 1977 and 1979 reports indicated
seepage f~om the site ~as affecting downs~~eam
water quality. This suggested a more serious
problem than was previously anticipated.
Remedial measures had been recommended in the previous
report (JM~!, January 1977). Additional measures and
modifications to previous remedial measu~es recoITmended
as a resu 1 t of the ne'"" infor-ma t ior. a.re r.oted be 1o,,",:
o
Reinforcement of the berms to provide additional
contair.ment volume was re~o~~e~ded to pr.eve~t future
surface discharge of contaminated li~uid.
o
A~ exte~sio~ of the gel injection p~~;=2~ ;ro~csed
in J:-l;.';'s 1977 re:9ort '..;a5 recom.,ll'?ndsd to :9ro'v.ija a
wider and dee;er see:9age barrier.
o
Additional monitoring wells wer: reco~~ended to
further define the extent of the pollutant plume.
A planned program of water sampling was also
recoriunenced.
Six (6) new alternatives were developec fer closure of
the site. The alternatives incorporated the chemical
fixaticr. and neu~ra1ization data a1so developed in the
report.
..
-------
4.
o
Alter~~tive 1 -- ~e~~vs
2."Q C;::\7S::-
$32.0,COO)
sit -2 ,..: i t.. h
(.;';.="".l
cont2.ffiin~~e~ li~ui~, g~ade
s82.1. (:::=ti:::E.~:~G C0:=.~ --
o
Alter~~tive 2 -- ;~2~O-7e c~~t~3i~2ted J.i;~id,
n2u~r~~1~S s81id~, a~d CQvsr s~t~ wit~ c12~- seal.
(E2~~~2cej cost -- $SSC,OOQ)
o
t\.lt.~r:-~2.":.:i\:'G 3 --- l~.:-:ut:.~li::'-2; liC::".lic,
CI 2::':'~
c..:-':c cov'= r
Sl.~~.
(~E~~~~~~~ c~s~ -- SSlO,OOJ)
c
;_::. ~ -= :- 7""J ~ ~.: i \,~ e ~ - - t ~ ~ t.: ~ ::- =:. ~ i z. ~ 1 i r~ u ie,
g:-c.:::..e
s::..t.e,
enca~sulate in kiln dust and cove~
(Estimated cost -- $1,240,000)
,-,,'i th
:::l=.y
layer.
o
Altsrnati'ys 5 u- Che..-,ical fixation, grade site a:1d
~over site with c121 layer. (Estisated cost --
$1,7S0,000 to $2,850,000)
o
Altsr"ative 6 -- RemovG conta~inated
(Sstimated cost -- $11,600,000)
ffi2ter.-ial.
The alter:1ative selected (~u~ber 3) was basically
alternative 3--1 in t.be ,]1';:'1 J.o:nuc..:-y 1977 rs~o:ct, with
modifications for providing drainage for sur~2ce water,
inter:::eption of water from the springs at the northern
end of the site, neutralizing ~iquid at the site with
. kiln dust, and installing a kiln dust cover layer to
provide additional neutralization if any water should
infiltrate from the su~face through the clay cap. The
modifications suggested in this report were basically
refinements to the original proposal and were based on
new infor~ationand environmental changes, such as the
DORS (1979) report and the increase in the volume of
contaminated ground ~ater at the site after two very
wet winters.
As Phase I work got underwc..Y new unexpected problems
were discovered and the closure plans had to be revised
again. The major problem, discovered since the JMM
December 1979 report was that, during excavation to
prepare for the gel injection in the assumed rock
fractures underneath the existing concrete 0am, it was
discovered that the darn was not keyed into bedrock at
t£e ends, but was in fact built over alluvial material
which allowed considerable seepage of waste out of the
site.
The April 1980 JMM report updated the December 1979
draft report to analyze the subsurface conditions
discovered during the Phase I construction activities.
the report also ref.ined two of the alternatives
ider:tified in the previous report.
..
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. .
,
!
5
The large amount of seepage and high degree of bedrock
fractures discovered during the excavation of the
concrete barrier raised serious questions about the
integri ty of the uneerly ing bedrock". The recommenda t ions
in the report include additional geologic studies and
interceptor well construction to confirnl the extent and
mitigate effect of seepage through the fractured bedrc~k.
Two of the six (6} alternatives developed in the previous
report (JMM December 1979) were developed in more detai~.
o
Alternative 2 -- Neutralization (Revised estimated
cost -- $2,496,000)
o
Alternative 5 -- Chemical
cost -- $4,036,000)
Fixation (Revised estimated
The report concluded that the neutralization alternative
offered the "best pra=ticable technology" while the
chemical fixation alternative was the "best available
technology". Neu1:.:-e.lization was c.eter:r,in.s:d to be the
cost-effective solution.
Following a public hearing on July 2, 1980 during which
the six alternatives for abating the problems ct the
site ""'ere discussed, R~';QCB adopted Resolutio'1 NQ. 80-142
which called for implementing the alternative of complet~
removal or all liquid and solid wastes from the site.
In a report to RWQCB dated December 1980, JMM examined
this alternative in gre~ter detail and evaluated the
various locations which would accept the Stringfeilow
site wastes. The esti~ated cost for total removal was
between $21 and $41 million depending on the site
selected for disposal.
In December 1980, because it was apparent that funding
for the total removal alternative would not ba granted,
RWQCB adopted Resolution No. 80-219, which stated that
an interim abatement program should ~e i~plernented to
provice protection from lea~hing or washo~t of the
waste material. In addition to protec~ing res:cent2
downstream and the envircn~ent, this in~eri~ pro;r~ffi
would facilitate the total rem8val of ~at=rial cnce
financing became av~ila~le.
B.
Interim Abate~ent Proqra~
The RWQCB was awarded a grant from the SWRC3 of
$4 Qillion to accomplish the Interi::7l Abat~r;:2:1t Program.
In 1981, initial geologic and hydrologic ~nv&stigations
were conducted during the predesign phase, In May
1981, a $95,000 Resource Conservation and Recovery
. .
..
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6
;;c ~ (?C ::-.\ )
c\,-."::..==-srj t2
t~. e ~,,~::.~<= ~ f:.::
~ :- .= n:. \-: c: s
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2. :-l j~ C S f. ~ t :: ~'. c :. i :J::
~'n2.li 2"_:; e:ne:-l t
G. C t :. \~ i :. i f= S .
T'~:.2 pl.-:~g:-~'.~:1 \.,"C:':2 C:'2~ :.~;~~~d
~~~ :~~;1~~i2S t~E =is}~ C~
t 0 c: ;'':' n ~. 2.. ~;;. t ~ .2
'"."::.3'::~S
C:':::,: :-,2
f~~~~s~ c~~t~~.~~~~t ~~icr2tic~.
T'~l2 l='r-:'.:;:::-'::::-:'-t ",:2:.5 =.:.;:-.ec. a.t ::-€C'J::~;:.; ~r:~:: C:7:0'~:;-:'': c.: COL:":'f..i~E~
~'-~,~~.,:e~~.~.'.'~-'c.~.-.t,..f.~'~~'~_'=l:O~:,~.I;,' ~1~.:~ Cr~~,,'.',..~._~~_~:_.i..~_.._:~.~,',-..._~,~a~ter =E~~S~~'g ~u~fEce
.... - -- - - -- - - - - Ls.j\.:ci:~~ =.:Pj.:, ~::-';;c:..t.ir.9
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~11 E.}:=:::'~CI:':.S ::0:- O:-:E"::'J,:,? ~C';--~:':2:.n!t.E:-.t. :~::~~;"'.=,~:.~: ;--?:"'C'=-':0:='€~'
::.~,.. :..:c.~.;:;G-:.-:;-::~:::-. S:--:;.:.:.-=.~=-s \.~'~:h c::.r-.=c. ~~.?j(;~ ::~i':'~":-:..
"= ~~ ~:
. . ... - .
~~~~~~~~~~~~ ~~~~O~=~~::d~~~~~~~~~~~~~~~~~:~~~ ~~:!
d i spas c.l sitE: v,'c.s r~cC'!T-rnEnded
cont~mi~c.nt mi;ration.
to m~nimizs 12teral
El'2:-:~8r1:"S o£
t~E: progr2.?:l
i"cluded:
J.)
~H ~su~raliza~i0n of ~bo~t 7S
p2rcent
of ~2ste ~~terial;
., \
~ I
instzl!~ticn of conc~et2 gcttsrE
to~ surface r.~~off abc.temsnt;
cnc: .;:..:.n j t.-:::
c ~&r:r,e ls
3 )
gl~Gd ing the
site for:- proper
d:::-air:aoe
cont.rol;
/. ,
.." I
i~stallc.tion of a one-fcot kiln
t~o--~oot clay C2P:
under- a
l.c..~;e ::
cust
5 )
installation of 14 monitoring wells, 3 extraction
~slls upstream of t~e barrier cC.m, one extraction
wsll do~~stream or the barrier dam, and 3 interce?tor
'''''.:::lls.
6 )
gel injection
c~nsisting of
ZO:1C sand t....,o
of the bedrock below the barrier dam
ene curtain in Doderate to lo~ fracture
curtains in high frecture zo~es;
7 )
construction of a gravel collection system and a
clay core barrier Ga~ downstreuffi of the disposal
site;
8 )
construction of a pretreatment plant to treat
extracted and intercepted flow; and
9 )
construction of a one-mile pipeline to hook up
with the Sant3 ~na Regional Inte~ceptor (SARI) for
ultimate discharge through a seven-mile outfall into
the Pacific Ocean
The RWQC3 completed all elements of the Interim
Abatement Program except for the design and construction
of the pretreatment plant and the pipeline. Leachate
is currently being pumped from the extraction wells
and rrom the first downstream interceDtor well for
hauling and disposal at a Class I facility.
.
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!
7
c.
.~ucmen ta t ion
~
In June 1982, DOHS stated in a letter to E?A, Region IX,
that onsite containment is the most cost-effective
solution for final site mitigation with the completion
of an additional augmentation program. The augmentation
program was designed to maximize the relia~ility of
each element of the onsite containment measures.
Additional wells were to improve the ability to monitor
and manage the contaminated plume. A feasibility study
was to examine the cost-effecti~eness of tntercepting
and diverting ground water around the site and upgrading
the barrier da~ and gel injection elements. A second
feasibility study was to examine the characteristics of
the offsi~e plume. These activities will be includ8d
in the RI/FS proposec under the cooperative agreement.
..
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co~.~!< ~ £.; I'I'"f
81 ~F.:: :.~G:- S 1.. LC)\':
;~.::c:b?jJ C:'
D~CIS=Ot~
.!:.P? E~~DIX 2
LE: I.;," I I 0 ~.; :;,
C::~:.Cj~~C ~O~ ~
A..
1956 -1979.
:'U t 1 ice c ~ ~ =- ~ ~
.\...~ i ~h
S ~: :: ~ ~~;. ;: ~ l :- (; ~...
. .
:=~.7:~
:-:7:-:: ~;-1
- "':. - r" - J-
G. .J.- i t -':- L
:.. ; ~ L..
j.::::~':~~iz.::sl~:.r z.z::.£~ t::::? 8i~~ ~.cs C?~.:;-=.d i.:'1 lS:-G..
T';.:?
?<:.:.~=-:t~- C.: .]i.-'r~;;c., 1~2.j :,~1 ?,L"':'~ ~i::-~\; . \' 1- . 1- ..-.....
~r;c2 "::::~~:'€:-. :..;::-.} ls':~srs :;: ::..:;:.~::.., ~':~~:';:';'=~~-~~~~~~':
of£icicJ.s c:s~:i~..;- -~;-.=.-: 2':J;:-.s:~:r.l; t:s :C:i""lE ~:::>~\:. t.:-J'':; si:e.
Over t~( years they h~ve helj a 1ar;e nu~~er of ~u21ic
and group meetings concerning the dis?osal area. Many
pec?le believe the Parents of Jurupa were responsible
fo~ t~e site's closure in 1972. Ths grc~p w~s i~cor-
porated in 1973,' and presently has a core m2~bership
of ~bout twenty people.
1'1': v 1972
-.""
A sc~ple f~~m the ~~tcr supply well for the Glen Avon
Schcol contained a small cDount of hexavalent chromium.
T1-:.e cO::1:~,unity ".'2:5 alc:.r,~,9d by this findir.g. ?,sgior.a.l
board officials later attributed the contc:mina~ion to
surfa=e floo~ing. The Gle~ Avon well was su~sequently
closed.
November 1972
The Stringfellow
site is
closed.
July 1973
The Farents of Jurupa filed a petition with the State
Board stating that the actions or the RWQC3 were im-
proper and irlappropriate. The cOITu:1unity grqup Vlanted
the site closed permaneDt~y.
March 1974
The Riverside County Board of Supervisors declared
the site a public nuisance, and ended all attempts
to reopen the area for dumping. The Parents of
Jurupaconsidered this a victory for the group.
March 1978
Representative George Brown held the first public
meeting in the Glen Avon co~~unity. Formerly, all
hearings were in downtown Riverside. A number of
State and Regional water and air officials spoke
..
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2
abou~ the Stringfellow site proble~ on SeD~e~~er 9,
1978, five months after the flooding of the w~stewater.
Residen~s of the surrounding cO~uunities, notably
Parents or Jurupa m~mbers, als~ voiced their concerns.
1979
A second cOIT~unity group was for~ed. The group is
called the Concerned Neighbors in Action (C~A). The
group was formed with the assistance 0: the California
Campaign for Economic Democracy. A number of other
communi~y organizations were instrumental in organizing
CNA. They include:
Jurupa Junior Women's Club;
Glen Avon Babysitting Coope~ativei
Glen Avon Crime Watchi
Pedley Women's Club;
Glen Avon ?TA; and
West Riverside County Businessmen's
Association
Like Parents of Jurupa, CNA favors co~~lete removal
of the site. The group has a core memDe~s~i~ of about
fifteen citizens and is actively inte=ested in the site.
Penny Ne'..;man is the leader of the or';;c\r.iZE\t.i8:1.
B.
1980 - fJresent
March 1980
CNA held a meeting in the c01llii:unity
the film "The Killing Ground" which
wastes.
ci~ter ~nd showed
focused on haza~do~s
Me'.! 28,
1980
Nine re~rese~tatives o~ the co~nunity 2tte~ded a State
Water R~sources Control Board hearing in Sacramento.
They asked fo~ funding for tOLsl ~e~o~~l.
J\.:J.'J 2,
19SG
R\;QCB held a b~arir.g te r.?vie'ri al~2!'L2.tiv8;; fer abate-
ment 0.:: i-h- ""'''''~''''}o.r.,s:;>i- ""'::' C:'--inr';:;::.', '0" S:'-<:- ~ '1;<:::-
J. .l. "",.:.:: ,t-1-.Vi.J__.d..... -"'-' \.0'.- """"-~_.;"::J""-"'- H 1.'--.. ..- .J,."--,,-
of six e..lterr12t.i\,"'es '{y"E:.?t p::-epz.::-ed 8~i J'c.rt:ss l'.;.8 ~1cntgCITLe:-:zT.t
Consul ting E:ig ineers. S t af f of t.he board recoj:T:\ended
re!r.c:-v.~2.. of thE: li.qui.= 1~2":.ste 2.r:d c: cl-?~y cO\-"2~ifl~. The
Board, i~ respons~ to the cOIT~~nity's co~c€rns, passec
-------
3
~esol\~tic~ 88-142
!:'"e::CITJ7le~21~g
;~l :.e:--::2. ~ i ":-e
\,.- ,"
t:;.~ .:-.1
r e IT: ~ \' 2.]. ,
~o ~~e Eta~a ~:~~Er ~sE~~rces C=n~=~l
=- ,-;=' ,-.-::
~---v-.
;.~:. t:-l Co t 1:1'::: e t. i.:1g t
si.x ~illio~ ~~l}.~=s
.~. ~- S ~ ',,1 :: ;:;;: :.
c: = :':-.'2
cast.
€stirE2.t'2
fer total rE2ov~1.
.:ruly 15,
1980
c:'~_:- ~-=:c ~. :;.t.:::-li.c :l.'2E~_i:->:, c~~c. t[~C; e\'t2:-~~ \":=.5 ',,:::'j,l G.t"::::.:-~':~'':'.
La i 5 G i :"::. £ f :- C:-:-t :: ~ ~: r:i i:: :1 C. 1: <.: ?: r, ~. ~:' ~..: e f,.~. =: r. I :: !:'" s ~ i .:~;:: :-; t c' ::
C~'~::..: =;C~~S c...t ~~s ;:-~s~-:i:-.~. 'I~:-=- ;::~':".:::':'.; ','.:~ 2~~:'-2~:-:(6~
=~. ;-.sc.;,:e :ro~~: t~!E- C~:7'~:.L:!1i ty I
2.:1 c.ije to
Cc:-:-;: eS2olc.:l
GeorgE:
i3rO\'ln,
~Dd sev2rF-l ms~be~s or
t:-1S p:-ess.
J..ucust 16,
-----c-._-
1980
State Senato~ Robert P=esley, who had been inst=u~enta1
i~ ~p;~a?riat~ng special State funds for Stringfellow
,.. 1 ~ - n" ..... \.-, c , d . a pu b 11' C ""' - e - ; .. g 0,-.. '.. -" '" '- 1 - ) " 8 r.
-~"-';" Ll".:~, !-\W~. ~. ..:.t\:; '-_1~ :l C-'~~""--"- 0, ;; v.
Tne E?A Region IX h2zar~ous waste can~~ct ~erson,
reFrcSE:nt~tives fro~ the S~at0 3card and Dep2r~~8nt
of Eealthr and Regional ~nd county officials presented
the f2C~S of the Stringfellow site as t~EY unge~stccd
ths:-n a.:1d 2.ns','ered ques t ions f r017l c.re a res iden ts .
OctobE.r 1981
..
The State Legislature passed the
cor.tffiunity ''''c:.s very involved \...ith
State Superfund Law.
State SupE.~fund. The
the passage of the
Noo:en:be r 5,
1981
The County Press Enterprise published an article on a
"Giant Underground LSe:k in the Stringfellow Acid Pits."
ADril 9,
.
1982
The RWQCB went o~ record in recowmending a remedy for
interim abatement, containment and leachate .control
that would cost approximately rour million collars.
The ultimate decision concerning site mitigation was
transferred to the DOHS.
June
1982
DOHS developed the Co~~unity Relation Plan.
..
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4,
June 15, 1982
DOKS met with the community groups and briefed them
on DOHS activities concerning the site, including
their selection of the onsite containment remedy.
April 1983
DOHS met with the State and local officials, community
groups and the press, to discuss recent sampling data.
April 22, 1983
Congressional Committee on Science and Technology held
a hearing in Glen Avon. The Director of the Office of
Emergency and Remedial Response discussed the proposed
cooperative agreement and proposed scope of work for
the site.
May IS 83
Penny Newman of CNA requested that $25,000 be included
in the Community Relations Flan for a technical
consultant to review work done onsite.
June 15, 19 S3
Final cooperative agreement application from State
received in Headquarters, including funOir.c request.
for corrjivunity' s technical consultant.
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