United States
Environmental Protection
Agency
Office ot
Emergency and
Remedial Response
April 1984
EPA
Superfund
Record of Decision:
McColl Site, CA
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TECHNICAL REPORT DATA
(Please read Instructions on Me rel'ene before completing)
1. REPORT NO. /2. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R09-84/002
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION: 04/11/84
McColl, CA 6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Fin.ql Ron .
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The McColl site is located approximately 20 miles southeast of Los Angeles in
a residential area of Fullerton, California. The site was previously used as a dis-
posal area for acid sludge wastes from the production of high octane aviation fuel
during World War II. Oil field drilling muds were later disposed of on the acid
sludge. The waste is characterized by low pH and high sulfur content. Arsenic,
benzene, and organic sulfur dioxide (502) and tetrahydrothiophene were also identified
in the waste and soil. Gases produced from the material include benzene, 502,
hydrogen sulfide and various odorous hydrocarbons.
The cost-effective remedy for the McColl site is excavation and redisposal of
the waste's. Total capital costs are estimated to be $21,500,000.
Key Words: Cleanup Criteria, RCRA On- Site Disposal Requirements, Seismic
Activity, Ground Water Contamination, Public Exposure, Off-site
Disposal
17. I
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1.
INSTRUCTIONS
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, 5.
8.
PERFORMING ORGANIZATION CODE
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AUTHORISI
Give name(s\ in c->nvcntional order (Jolin R. Doe. J. Rolx." Do('. ("!'.). list author's aflilial10n i.. it ,lith'lS rrum tll\' I'crfunuillj: ",~alli.
zation. '
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Give name. street. city, state, and ZIP code. List no more than two levels 0" an or~anil.aliunal hireardlY.
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Include ZIP code.
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Indicate intetim final. etr,. and if applicable, dates covered,
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Insert appropriate code.
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Enter information not included elsewhere but useful, such as:
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16. ABSTRACT
Include a brief (200 words or less) factual summary of the most si~nilkanl information ,'untaim'" ill 111\' '\'11\111. It Ih,' "'Pllrl '"111;1111\ a
significant bibliography or literature survey, mention il here.
Prepared incoopcration with. 'I ,anslallllll III', 1',.."'111,.,, al ,'0111\'1"11\" III..
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS. Select from the Thesaurus of Engineerir.j! and Sdentifil- Terms Ihe pruper aulhorrA'd I~"m' Ilial Idcnlify th~' majm
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(b) IDENTIfiERS AND OPEN.ENDED'TERMS. Use identifiers for project nam". code names, ctjuipmcnt dnl!!nalurs. ct~. Use "I'ell-
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jority of documents are multidisciplinary in nature. the Primary held/Group assignmclltls) will bc sl~l'ill\' disuplinc. arca uf human
endeavor, or type ofphyskal object. The appJication(s) will be cross.referenccd with se('undary Ild"/CirtJul' ..,,,!!nmelils thai 11,111 lullo"
the primary posting(s).
18. DISTRIBUTION STATEMENT
Denote releasabilit)' to the public or limitation for reasons other than security for c"anll'le "RclcaS\' 1;lIlIllIil~'II." ('j1\' allY a~ilililhilil)' Itl
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19." 20. SECURITY CLASSIFICATION
DO NOT submit classified reports to the National Tcchnicallnformation service.
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Insert the total number of pages, including this onc and unnumbered pages. but c"cIude distributiun list," any,
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Insert the price set by the National Technicalln£ormation Scrvice or the Govcrnmcnt Printing OlTice, if known.
EPA Form 2220-1 (R.... ~-77) (R...,..)
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R£CCii\D
Or' DECISIO~
~E~~~~!~L ~L~~~~A~IVE S2LSCTION
c-rr::".
\,0...:....:..-..1"
!".icC.:::.ll '::i~~-,
!U~:~~ton, C~li:orni=
[;'C.CU~'~E:!\TS RE-vI :::~'~2D
I hc.\i€ -=€"iie~,:Ed t..:-1'2 fcllc,~,::.r~c.; .joC~TI'ie:-~t.s Gesc~i::'i:--;-. t.~.1e
zn~lysis cf c~~~-~~~E:~i~e~€£s of ~E~€j~al ~l~e~~~~~~E~ ~~- the
p'Jc~cll sit€:
/.::Cc 2. 2.
S:.~e
t:-. s::. £ :: i ~l
:~vE;s~i.;~t.:"C:1
2nvi~onment~l AsseSSDient of
hlternatives for th~ McColl
C=lifornia
the Remedial Action
Site, Fullerton,
Cost-Sffe=tiveness Ev~luation of Remedial Action
Altern2~iv~s for the M~Coll Site, Fullerton,
C~liforni~
Review of Feasibility Study at the
~u11e'r"on C=>ll':::o""ni=> C.' M ~..l'll
r - -\",. 1., --.. J- _l_~, t:2 [1
~1cColl
Site,
SUr.'JT1ary or
R~rnedial Alternative
Selection
DESCR:!:?'!'ION OF
SELECTED RS\:E:JY
All waste will be excavated and disposed of at an approved
RCRA disposal facility. Any hazardous 50i1 up to a depth of one
foot below the waste will be removed to a RCRA disposal facility.
DE:CLARATIO~S
Consistent with the Comprehensive Snvi~orum~ntal Res~onse,
Comp~nsation, 2nd Liability Act of 1930 (CERCLA), and the National
Contingency Plan (40 CPR P2rt 300), I have determined that the
excavation 2nd redisposal alternative at the McColl site is a
cost-effective remedy and provides acequate 9rotection or public
health, welfare, and the environment. The State or Californ:a
has been consulted and agrees with the approved remedy.
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I have also determined that the action being taken is
appropriate when balanced against the availability of Trust Fund
monies for use at other sites. In addition, the off-site transport
and redisposal is more cost-effective than other remedial action,
and is necessary to protect public health, welfare, or the
environment.
;::f,- ~~~~~~ro
Assistant Administrator
Office of Solid Waste and Emergency
Respons e
l[-L/) ld'lf
/ Da e
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SUr-:~:_~F~~ OF
?£X~~!AL ~~~SR:~~TIV~
S=:~~C7!C~~
~~e"'.'\r' c: T'T't:"
."_"'-_.:.....0--'; .........--
Fu~ler~o~1 C~~i:o~nia
1.
SI~E LOCATION ~~D DESCR~?~!ON
The McCcll site is located ap?rcxi~a~ely 20 ~iles scct~eas~
of Los ADg~les i~ :ulle~~on, O~an;e Ccunty, C~lif~~~i=. The si~e
is sou~~ cf Rcse=~~~s ~7e~ue ~~d ~est ~f S~~~y Ri~~~ J~~vs. The
site :s civid~c int~ t~c p~~~els:
tj2 7-~c~e ~~~~~~:2 ;~~ce~ t~
~2E e~s~ ~~t ~~~ ~.5-~c~e :~S C~y=~ss ;2~=e: :2 ~~e ~~5~.
:: ::::-: E-:;
~or~;!:" r.t~E ?...=..."71;Jc:-:'s si:--: :::. :..-.e E=:S~ =.r:d 5::>U:'::.
:-~-':.5 -:- 2=::' C:€ :-~:. i a~
area of ap?roxima~ely l,200 people c~n~2ins homes ji~2C~~Y adjacent
to the site. The Lcs Ccyo~es parcel underlies the Los Coyotes
Country Club Golf Course. There are six s~mps on each parcel
containing an estimated 3S,COO cubic yards of ~aste (2i;~re 1).
This site is located in an earthquake zone 4, denoting the highest
level of earthquake activity.
I I .
SITE: HISTOi'.':::'
The site was created as 5 disposal area for acid sludge
wastes fr08 the production of high oct~ne aviation fuel during
World War II. In 1942 Eli McColl had 12 pits constructed in
what was then a r~ral area 0: Orange County. NorLh of ~he site
were oil fields; a hog far~ operated to the south; and the area
to the southeast was devoted to agriculture. Mr. McColl arranged
to haul away acid wastes of refiners producing high octane fuel
in the area. From 1942 to 1946, these wastes were dU8ped in the
McColl sumps.
Following the war, Mr. McColl wanted to improve the property
by covering the sumps so that the land could be developed for.
other future uses. At that time drilling muds from oil production
activities in the area were plentiful. He received the necessary
local pe~its and arranged with several oil companies to dispose
of drilling muds. From 1951 to 1962 drilling muds were deposited
on-site, mainly in the lower R~~parts sumps. The acid sludge
and drilling mud combination was not stable; the drilling muds
sank into and combined with the sludge.
In 1957, the Los Coyotes Golf Course and Country Club was
constructed over the western six sumps. In the 1960's, developers
began to build homes in this area of Orange County. In the mi~-
1970's, ho~es were built immediately adjacent to the eastern aQd
southern borders of the Ramparts parcel. In July 1978, Orange
County received the first complaint of odors from McColl area
res idents .
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-2- .
In Novembe~ 1980, the EFA Field Investigation Te~~ (FI~)
conducted a backg~ound investigation or the McCcll site wt.ich
identified potential ~esponsi~le parties based on the types of
waste in the sumps. In December 1981, EFA, the State, local
agencies, and four oil companies (Shell, Union, A~CO, and Texaco)
signed a memorandum of agreement to study the McColl site.
On-site work commenced in March 1982 and a f:nal ~eport was
received in November. This remedial investigation was funded
.by the oil companies, which contributed $800,000, and the
. State of California which contribu~ed 5150,000.
In September 1982 the same participants em.ered into a
memorand~m of ag~eement to conduct a feasibility study. This
feasibility study was funded by the State at a cos~ or 5350,000.
In addition, Shell Oil Co. funded a pilot excavation p~oject
which took place du~ing May 1983, and demons~ratsd ~hat excavation
was feasible without g~eat inconvenience to area residents. The
feasibility study began in October 1982, and a final re?o~t was
published in June 1983. Based on this study, the State selected
excavation and ~edisposal of the waste and cor.t~~nated soil as
the cost-effective alternative. They immediately contracted
for the design of an excavation.and redisposal pcoject. The
project was opened for bidding on October 17, 1983; bids were
received by December 2, 1983; and a contractor will be selected
by the State in April or May 1984.
III.
CUR~Err!'
S I':E ST'_;TUS
There are approxi~~tely 139,000 c~jic ya=ds of waste and
contam:nated soil at the site. The wast'e i.:3 chare.cte::-ized by
low ~H (as low as 0.7), high sulfur content. and hi;n organic
content. Levels of benzene, sulfur dioxide and tet~3hycrothiophene
were round in tl1e '...;aste and soil. Gases pcocucec [;:,on t~je material
include benzene, sulfur dioxide (S02)' hydrog~n sulfide (~2S),
and varicu5 odorous hydrocarbons. In adciticn, a~s2nic tas been
found i r, one of the lo'....er Ramparts SUr.1;:s. T:le ;7,.s.j:::: ;:.=:.::v,;ays
for exposure are through direct contact and inhalation.
~he da~3 int~cate the corrosivi~y of the ~2stef ard
t:iat ;;H
~s :ess ~2~:1,~ (~~;t~=~
. . .... .
l~ C~3 S~!l t;~~~ :; ~~~
'.. :..;.'-', ~ .=.
._.-.' . - .
::i:-::c'C.
c::; r-:. :::.C~:
-;:':~:. :.:'-:- ~'::..=-~:~'" ~c:..'~:'-= :.-:1=~::r:~~
. :. ." -. '-. ~.~ ~. - -~. -. ,'.
- '- _... - -.., - ....
-::;'./-:2
-
a~c s~i:J. :'::-:: 5C..=.:2 .12.:':. cpplied 2 L-2:'!"~~~'::~:::,,'J C~'.J:::':~ ~.:: -:'i:-;c.:;~:.~C
mar.e~i2~ 2:-;:: .so~.l ~::J th~: r;~2J1t~.3.r-r..s f'o~":i'::'i""1 '':: ;:r~(::: 2: i.~.-2f .f~:i-..:..2.e
this has tempo=a~ily ~itigat9d scme of t~~ threat, ~~S~2 seeping
to t:1e .5,-l.C:.::'';~l e~?ec~lally on the golf CQ1"::-SE:;" ccnc.j.n~_:~3S L~;
C re:a"c e a c i.:: 2-::~-C.::; il1: :.c t h az a:-d .
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.,
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The mai!1
;:::--cu no
'.;;'12te~
::ccy Cot
~ r~ e ~~ c C CJ 11
si~~ is
~~.) :8 250
f :2 et
beJ.c~ tje l~~~ surf~ce. ?9~ched ~ater a~ 25 ~= ~~ ~ee~ ~as
:<:Jl1:1G unce::-l~i:r~r; tje ~~-:-~;;.::.~-rs si~e. r:c)\~:e\~e';:-, ~:-;is ;)E.~che,j
bee:!
zone
b.::oS:1
is ~ct USEd 2~t ~~ co~~ec~icn t~
~:-le ~e;::.on2l
2..~~"': i = -2:~ :125
C e::lO ~s t.:- 2. ~ ~L. .
Gr~un~ ~~~er fl=~ is ~e~E~~l~~r
i:C: :'~!-2 E.::)ut.h.
T;-le ;:erc:-~~~ g:::-C\1:1C '",.'c..~e~ hc.s :'o::S:1 s2I~'.;;lec j~.1 ~~~-=
c: .;... = t- =.
-.... -'- -,
2nd
shews ve~! low p~, 2nd ~igh sul~ates anj arsenic. ~hese c8nsti~~~nts
~ay be 2t~~ij~t~bls to ~he ~'~~~e de;osited on-si~e. ~=~eve~,
~:ater ~2.:rl;les :-: -::!~ :::-e~:.on.c.l c.qL:.:fe~ f:::-o:"1 c~~e .;~C)~;'...: v.'c:.~2~
:i1cr;it.::-=i~'; ....,~:..~ ~:.'': ::::..:~ ~:"C.~. '.,'£~.:.::: 2C.'';~:-::: ~:-:-= £::~:
.=::. ~'...:
. .. . - .
~~~~=~~ ;~ ~~c ~2 ~~e"~~~e:
.. . - "
-- e "."; -= - =. c: c :: :-. :. z...-:.:. :-. .=. :-. : E
:.:"-.::: :-:1..2_:, ;:~
t~acec to ~~E site.
The State analyzed soil samples below the ~aste to a depth
of ever 100 feet in two cores. Soil below the ~as:e showed a pH
gre2ter than 2. T~ace amounts or metals and sulf~r-containing
cOffipounds were found in the sails. However, these are not in
con~e:1trations that would pose ha~ to the public or the
enviro~~ent. If the waste is pre~erly controlled to p~event
r~ture leachin~, there should be little or no threa~ 8£ ground
wate~ contamination from the site.
A~senic in most 2reas or the ~cColl site does no~ Ex~eed
backg~ound levels. Eoweve~, su~iace s~~pling from one of the
R~~pa~ts sumps revealed an a~senic concentration or 10,100 ~pm.
~rser.ic enters t~e body prim2~ily by ingestion or in!1212~ion.
The California Department of nealt~ Services has estimated
that ingestion of a few g~ams or arsenic-contaminated soil at
concentrati0:15 found on a portion of the McColl site (10,100
ppm) could produce acute poisoning, especially in children.
Arsenic i!1 concent~atior.s of 0.35 mg/l has been measured in
storm water runoff from the sit~. This is seven times the Federal
d~inking water standard of 0.05 mg/l. Ho~ever, since runoff
does not ente~ any drinking water supplies, this is not presently
a health threat.
The most obvious problem from the McColl site 2re its odors
and toxic ai~ emissions. Sulfur-containing hydrocarbons are
emitted from the site at levels detectable to the ~esidents.
Because odors prompt public complaints, air samples have been
analyzed for odorous compounds such as 502 and te~rahyd~otniophene.
The following table indicates the concentrations of gases that
have been measured from the site.
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Cont2Ii1inants
Undisturbed
(On-site)
Dis~urbed
(On-site)
Disturt)ed
( COrth"'"] un i t Y )
Benz Ene
5°2
2500 p~b
42,000 ppb
thousands
of ppm
170 ppb
u;:> to 1000 ppm
The State Department of Health Services conducted a health
survey of the McColl site from July 1981 to March 1982. The
symptoms reported by area residents (headaches, nause~, dizziness
and respiratory irritation) increased wi~h the proximity of the
residence to the site. These symptoms could be attrijuted to
the types of air emissions coming from the site.
Ambient levels of benzene in the rlcCo1l area are no higher
than benzene levels in other parts of the Los Angeles Basin.
However, the potential for exposure exists should the site or the
cap be disturbed. Chronic benzene poisoning is manifested by
symptoms such as fatigue, headache, dizziness and loss of appetite.
Sulfur dioxide (502) gas is emItted from t~e McColl site,
especially during site disturbance. ThIS gas classi:ied is an
eye and respiratory irritant in low concentrations (6-12 ppm)
and can be fatal in high concentrations. In co~bination with
other air pollutants, such as particulate matter and ozone,
502 has caused an increase in the death rate duri~g smog incidents.
As expected, the elderly ana those witj heart and lu~g disease
are more susceptible. Orange County has not reac~ec 2tt~in~ent
with National Amt)ient Air Quality Standards for particulate
matter and ozone, although it is in attainment with S02 s~andards.
In sum, the major pathways for exposure are air ane direct
contact. Disturbance of the site can cause the release of benzene
and 502 in high concentrations. Although the site has been
fenced, children are attracted to the area to searc~ for golf
balls. The fence has not deterred this activity. The teDpora~y
cover applied by the State to the R~~parts parcel has reduced
the danger from direct contact and air emissions. However, the
cover is only a temporary measure. Waste seepi~~ to t~e surface,
especially en the ~ol£ course, still crea~es a ~aZ2rc.
:'1 .
~ >1 ZC:?_(-: ::.! ~::-:;-::
In 1980, EPA sen~ RCRA section 3007 lecte~s to seven ?cte~ti-
ally ~esponsit)le parties (PRP's). 1:1 1981, fu~the.:::- sec:ion 300.'7
lette~s were sent to nine PRP's requesti~g additicnal in~or~ation.
As a result of that effort, a Partici;:>ants Commictee ~as formed
of EPA, the State, local agencies ane PRP's. Uneer t~is C~mmi~~ee's
oversight the re~edial investi~ation and :easi=i~ltj study we~e
cone~cteG. On July 22, 198~, 16 additional section lC~/30Ci
letters were sent in an 2~tempt to identify other ?~P's. ~otice
letters were sent to eight PRP's on August 12, 1983.
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1:1
J'une 19:33, c: ne;Q~i~t2.;1~ c~'rr.r:-~i~~ee {ccrnpcsc.c: cr ::~'.;, tne
1 0 C :=.1 =. Q ~ :-: c: :.. e s, = e~.i -: :-.::.1 c i l. c ~:>!:": p c. l1 i e S j .=.. ;1 c:. 2. =. r:.: :: '.: ;-. -= :.- ==) .~. c. 5
c:."" -~ ....
.......-....c.l..'::r
:crillec to ciscu~s
i~;le~e~~~~icn C~ t~e fe~~iji~~ty
s ::''..2C:~.~ ::::C=:>~::-
u.e~'::.::.~i.on. D~-:in; t::e i:;iti2.1 ~teet:..;:~s, L~-= ~2Ei.::.i::..=.= E~:;::--=~'':' to
an additicnal ~£f2~t t~ loc~te ot~e~ PRFr~. ~~ ~~t~:~C~r 1: was
Ggreed th2~ ~o colla~ a::s~ co~lc be ~~ce un~i~ t~e 5~2~~ ~efi~ec
the ccs~ of the ;~c~ect ~~~in~ tE£~;~. 7hs 8~~~EIS ~~,~~~ ~esign
w~s ~ace ~~blic i~ Octcbe~ 1983.
C' n :.~c \~ -2IT.j e~ 3,
1'?S2,
~:'~2 F~?I S
rite.de c t..:.~/:.:.::.::i\'e S'2t:..lt2~..:;~i':' c.ff'2:- c.£ 51.0 IT~:llic~1 2.€'~-= :::::.=..:1 50
percenc of tne es~~~~ce~ ~=t~l ccst cf ~~e c~~a~L~1 ~~~~ ~~~
7'.,-..:: ;:
- '--..-'
~;~i:--.::::' ::--:.~-='::-~::
~.--..=:' :-: z s:-.
In ~ddition, ~?A arjj GOES cl~ri~ie~ :~e~~ pcsi~i=n ~~ the
arnount of an offer ~ecessar! to al:o~ negotiacions to c8ncinue
(no less than £0 percent of the tot~l c1e~nu9 cose) and on
settleme:1t issues raised by the P~?'s. T~is ~ositicn was conveyed
to the PRP's at a meeting on January 31, 1984. The PRP's were
informed that negotiations would be terminated on M&rch 8, 1984,
unless signi£ic~nt progr~ss was bEing ~ade. On cejr~ary 16,
1984, the f~P's submitted a written o~fer of Sl~ ~i1li~n. EFA
and DOES are currently eval~ati"g that offer.
At the same time, EPA, t~e State, and PRP's have met to
discuss langu2ge for a ?ro~osed consent decree. Al~nough there
h~s been progress tow~re settlement, Region 9 is ~re~aring a
CCffiprehensi';e En?ironrne:l::al Response, COIT:;;ensati8n, and Liability
Act of 1980 (CERC~A) sec~ion 106 oreer to be issued to t~e PRP's
should settlement not be reached. It is antici;;ated that the
order will be issued in early May giving the PRP's 2n opportunity
to respond before the cooperative agreement is awarded.
v.
STATE'S COST-EF?ECTIVEKESS
E:V.~LU~.TION
Bac!-:ground
A.
EPA and the State investigated the site and sent Resource
Conservation and Recovery Act (RCR~) section 3007 letters in
late 1980, prior to the passage of CERCLA in December 1980. An
initial meeting with PRP's and other interested parties was held
in April 1981. From t~at point, the State took the lead in the
remedial action with ~PA remaining as a member of the Participants
Committee. In December 1981, the Participants Committee entered
into a memorandum of ag~eement for remedial investigation of the
site. The remedial investigation commenced in March 1982, at
the same time as the National Contingency Plan revisions for
Superfund were proposed. After completion of the remedial
investiaation, the ParticiDants entered into another memorandum
of agreement to conduct a feasibility study. The feasibility
study ~ecoIT~ended excavation to be the cost-effective alternative
for cleaning up the site.
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I
-6:'"
In June 1983, when the final feasibility study ~eport was
published, the State considered the need for Federal Superfund
money to fund the cleanup. At that time, EPA asked CH2M Eill to
review the State's feasibility study to determine compliance
wi th the NCP.
Concurrent with our review of the State's feasibility study,
the State contracted for design of the excavation and redisposal
alternative. The design was completed by Black and Veatch and
the project was opened for bidding on October 17, 1983. Bids
were received December 2, 1983, but a contract has not yet been
awarded.
Throughout the process of remedial investigation, feasibility
study and design, the State held numerous public meetings and
sent letters and bulletins to the McColl area residen:s to keep
them informed of activities at the site. EPA remained a member
of the Participants Cow~ittee and reviewed all remedial investiga-
tion and feasibility study documents produced by the State.
During the feasibility study, 82 potential'technologies for
~ite cleanup were considered. These technologies fall into the
following categories: excavation/waste handling, emission control
during remedial alternative, long-term emission con~rol, trea~-
ment of solids/semi-solids, treatDent of l::.quids/runoff, in situ
t reatment/pret~eatr:lem:, red isposal, tr 3.nsport ati on, su~f ace
water control, contair.rnent, recovery/recycle/reuse, and dust
control. Using the State's selection criteria, technologies
were assessed to eliminate those not a~9ro9riate for the ~cCall
site: applicability to tne McColl site; ability to meet DOES
cleanup criteria; envirorunent-al, health, and safety impacts;
ti~e and/or cost requirements; usefulness with intermingled
wastes; technology status; reliabili:y and implemen~abili:y; and
usefulness as part or a system of technolo~ies.
In the State's evaluation, technologies that ~ere applicable
to the McColl situation were incorporated in the development of
six remedial alternatives (three involving containmen: and three
involving removal). These six alternatives were fur~her re:ined
~c one csntai~~en~ 5ce~ario a~G one ~e~ov~l scenc~io.
A. ~Ci:~D:'~c:~:'~i:
- -
.:: ~C~~~:~~E~~ ~: ~2~~e 2~ c~s ;2~=e~.
~.--:: ::"2:":'".::;',:: =:.~
......:; '.~ .:::'2 -: 2':: C::
a~c~~e~ N2S ~132 cC~5ice~ed.
evaluated i~ d2~ai~.
T~1,J.sr
c.j~e~
a. J.. ~ 2"~ ~ 2. ::. .:. "/ e 5
'.";~-:' e
Before the Sta~e evaluated the cost-ef:ectiveness c~iteria,
the State ccnsicered any enviro~uent3.1 impac~s impcsec ~y tne
remedial alternatives. All t~ree alternatives were considered
~y th~ State to have lcn~-:e~~ fositive impac~s. 7~e concai~rnenc
alter71ative had the;;reatest lonr;-te:::!'. potential -::-i51< of failure
and also the l.~',yes: sr.o~t-te~~ im.pact: fer ccrr~--:iU!11t:~' ex;:c's\J~e.
While the potential for short-ter~ community ex?cs;j~e '"as greatest
with t~e excavation alternative, t~e potential far :cn;;-ter~
impacts Nas to 8e eliminated.
-------
-/-
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Figure
3-1.
Xatrix Class Syst~~.
I
I
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.,
!
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-------
-8-
However, C52M Hill deter~ined that the extent of the
problem at the site has not been fully defined in two respects.
The first is ground water contamination. Only one downgradient
well exists for this site. Though liI:1ited sa.rnple data from this
well indicate that it is not contaminated, insufficient data
exist to conclude that the waste has not yet cor.taminated the
ground water. The State has undertaken a study to investigate
the ground water. However, the existence of contaminated ground
water would not alter the selection of the source control remedy.
The second area of concern to CH2M Hill was the extent of
soil excavation required using the State's cleanup .criteria.
Very limited data have been collected on the extent of soil
contamination. The State bored five cores in five different
sumps. A total of 11 samples from varying depths were analyzed
for volatiles, base/neutrals, priority pollutant metals, and pH.
Substances such as tetrahydrothiophenes, cycloparaffins, and
organic sulfides were measured in the ppm range. Heavy me~als
and phenols were a130 detected. In calculating the total density
of waste, CH2M Hill reco~~ended that the density figure used
by the State (0.88 tons/yd3) be revised upward to 1.35 tons/cubic
yard, based on an assumption that the State's analysis was based
on e5 t imat es r ath er than erLlp i r-i cal d at a.
CH2M Hill subsequently reexa.~ined its reco~e~datior.s i~
light or density measurements of the soil and wastes concucted
by Radian. They concluded that the weighted average of the
waste was 1.04 grams per cubic centimeter. This is eq:uivaler.t
to tte 0.88 tor.s/cubic yards (see attached Radiar. su~~ary of
density analysis). CH2M Hill confirmed this estimate. Therefore,
based on these data, EPA acce9ts the density figure used ~y the
State.
VII. EPA'S COST-EFFECTIVENESS EVALUATION
EPA decided, based on the findings of CH2M Hill, ttat an
independent cost-effectivess evaluation was necessary. Cost
estimates developed by the State's contractoc and CH2M Hill we~e
evaluated. Based on the cleanup criteria described below, E?A
~edefi~ea t~e SC8~? c~ t~a exc~v~ticn an~ =~dis;cs~l ~.~:e~~a:i.!e.
:.:1 ::C:C::'Cl.:.r:, ::?~:.. 2..l-3.~ :::~\.:o~~::;:e':: ~2.:e=:-~~:.:';~s :~~ :"';';;;~2C.-='': s~~:..:.::-~-r:.2~1:'
~ ces i:;ned
t~ d=at.~c:: c<;ai~st ea.=-::-lq~2;..:..e .jc...~~c.-;;e) .::rlC 2: ?,,(:?_~ o:l-5i~2
E?A cost e5t~~ates f~~ f~u~ ~ey altec~2:i~es (see
facilit~/.
Table 1). The fo\..!:: alte~:1ati'i~s ar2: 1) containment, 2) upg::-aded
contain~ent, 3) excavation and redispcsal, and 4) ~ RC~~ on-sice
dispcsal facility.
-------
-9-
r- .
Cl~an~? C~ite~ia
Becccse the~e is ~o ev:cen2~
- ~ -....
L.. C. '-
Ii 2.2 c-~c.o~ S
t, 2..': e
S~0S:::.=.:-:C~S
!:1i~::-=.:.es f~:)!f~ :::-..e ~.i:.e e;:::e~.t. ',::'2: t.:}E Eir ;:'='~~'l'~;=Y/ a. S.:"":~,:2
con~~cl ~e~s~i~l ~ction 25 des=~ib€d in t~e NC? is ~~~ ~~~r2~~i~te
cle~nup ~e~~oc. T~Ese c~ite~i~ csc~ess ~ct~ shcr~-te~~ C~C
1:: ng - t E ::.-:n
?~:-C:'ECt.:C~ C)f
he2.1~j anc t::~ e~'.;i.~:.~c:.-=:-:~.
1
.... .
2.
;JL::.li..:
~J,:a~e~
- .
Gr-~''''::'"":C
~<~2.:S~
c ~~~i~~ize s~~~~i~;
wc.ts;:"
b.
Surf ace 'ilater
o short-term criteria for benzene,
arsenlC, sulfates and pH
toluene,
xylene,
o over the long-term, no run-off f=om the
c8ntain satistically significant le~els
site may
of any
constituents attricuted sol~ly
above background levels.
to the site
..;i r
a.
Odor: The South Coast Air Quali~! Ma~agement
District (SCAQMD) has cevelcped an oeor monitoring
plan for the McColl site. During tj~ cleanup
distinct, easily noticeaole oGors Nill not be
allowed beyond the site pe~imete~. Over the
lo~g-term, faint odors will ~e allowed directly
ove~ the sice, but no detecta~le oGor is allowed
beyond the site pe~imeter. A SCAQMD inspector
~ill assess odor intensities during cleanup.
b.
S02: 24-hour, I-hour and 5-minute standards
have been set. The 24-hour standard is tne
sa.me as E?A's 24-hour National Ambi.ent. Air
Quality Standard. The l-hour and S-mir.~te
standards are approximately half of similar
standards set by the puget Sound Air Pollution
Control Agency (one of the few regulatory
agencies with similar standards). Because the
Orange County area is nonattai~~ent for particulate
mat~er and ozone, and because the health effect
of 502 is exacerbated in combination with
particul~te matter and ozone, stringent standards
are warranted. The long-term standard requires
no statistically significant 502 concentration
increase across the site.
-------
- lC)--
c.
Benzene: The fence-line standa~d is 2 ppm unde~
the most stable (or worst case) me~eorolagical
conditions - no wind and low 501a~ radiation.
The standard provides protection below the
one-in-one-million cancer risk level.
d.
Soil and Waste: Excavation or containnent of
waste and all obviously contaminated 50il up to
one foot below the sump.
The State's cleanup criteria used during development of the
feasibility study we~e far more stringent regarding soi1 ~emoval
than those detailed above, if literally applied. These criteria
included: removal of all soils with pH les~ than or equal to 2,
and all soil with arsenic at or above hazardous concentrations.
Soils meeting C31i£0~nia definitions of hazardous waste were
also to be removed, as well as soils with chemical concentrations
above those specified in the California Assess~ent ~anual.
Soil sampling below the sumps indicate the~e is minimal
cont ami nat ion of soi Is, ext endi ng app~ox imately -50 to 70 feet
below the sumps- These contaminants have mig~ateG app~oximately
one to two feet pe~ yea~ and are not expected to pose a threat to
the ground water. The States's remedial investigation showed a
distinct break between the waste and underlying soils. Excavation
of the wastes would remove 99 percent of all site contaminar,ts.
Soil removal under the SUDpS would not provide additional ~rotectic
EPA's cleanup criteria have be~n presented to the
State has agreed that these c~ite~ia are accepcable.
State.
The
Description of Alternatives
B.
1.
No-Action Alternative
Selection of the no-action alternative is not acceptable
for several reasons. First, there is the th~eat of emissions to
residences adjacent to the McColl site. The entire cOIT~unity has
been subjected to odors primarily from uncovered wastes in the
lowe~ P_ampar-:'s area. Sig:1ificant potential exists f~~ ai::-
indicated tna~ p~cxi~ity
of the resident~.
c:: rl ~ ~:; i :1 Co:::' 2~:'.3 3 :..: t S (-= . .; ., ::'~ 2 =';'.2 =: e :-: z ::::: ~.; :.~ .:-: ~ -= 5::'::' ~
dist~rbaG~2s. A haElt~ eE~ec~s 3~~~Y ccndL~C~et~ =~ :~e 2:~:e
to t~e si~e w~s li~xec tc acv~~se
-:-2s;Jcnses
Direct contact is the second conce~n at the site.
Waste materials have seeped to the surface in the Los Coyotes and
RQupa~~s a~eas. ~~senic has bes~ founc at high concent~~tions
(up to 10,000 ppm) which can cause acute ~oisoning. ~lso direct
ccn~ac~ wi~h the acidic waste ~an cause eye an~ skin bu=ns.
-------
, -
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=:: \..:-.2
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Ec~h cf t~~~se
~:~!:"ec.ts
!".'c.t.1ld
~)e c:::::-~;-.o1..1 ;-:::ej 2S
Co ~-2S;..ll":. ':;r
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SO~ ~~d ct~~~ h~=a~~~~s c~~stit~e~ts.
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C::' :-; :. :: ~. :.."':"'. €. ~ -:: ;'.2.:. -= ~ :-: 2 ": :. v s
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t~e w~ste ~~C cont.2~m:'~~t.ec ~~t.erial in ~lace 0:1 bct.~ ?o:-t.ions of
the site (Ram9arts anc Los Coyotes). Cont.ainment walls of acid
and sulfate resistant conc:-ete would be placed arounc both areas
cf the site. Reinforced conC:-'2t:.e ''''ould ce put in the "jowr.hill"
portion of the walls for st~~ctural integ~ity and seismic protection.
The ~em:ini~~ porticns of the structu~e would be s~cnca~d slur~y
construction. S~,issions co:.t:-::>l d~~::'ng tr'2nc~i:-,~ '",'oul::: incluce:
mechar.ical collection c.r,:j dis:;:e:-sion, fO~2S, s9':",ys an::: deccc:-ants.
A ccve~ would preve~t:. r:ln infiltration, su:-face ru~-of:, and
would cont:in gaseous emissions. A gas collec~ion system would
be installed below the cove:- in a gravel ~ec and emlss:ons captu:-ed
with a t~eat~ent:. syste~. The contair~ent system wculc not. t:.ie
into an im~e:-vious laye~.
A monitoring system would ~e installed to monitor ai:- ~uality
during const:-uction. A seismic monito~ing system would also be
installAd and water quality monitoring would be conducted at the
rate of rou~ samples per year per well.
All trenching mate~ials and cont2ITLinatea overburcen wot.:ld
be removed and sent to a Class 11-1 landfill. The total to be
~emoved is estimated to be 20,650 cubic yards. The synthetic
cover would ~e overlaid by sand and to~ soil and seeded. Below
these, two layers of construction fabric, a layer or gravel would
be installed. The ~einfo~ced concrete would have an average
depth of 45 feet and would be 3 feet wide. The slu:-:-y wall would
have an average depth of 40 feet and be 1.5 feet wide. A synthetic
membrane would be installed as an additional bar~ie:- to the
reinforced wall.
In evaluation of the seismic risk to the containment alterna-
tive, the State's consultant predicted that the construction of
the walls b~ried in place would not result in collapse in the
event of an earthquake. However, displacement or separation of'
the walls could occur, resulting in some ~elease of materials
near the surace. In steeply sloping areas, small scale slumping
and near surface rotational displacement could also take place.
The State's consultant stated that it would be unlikely that
la~ge scale slumping or la~ge scale releases or waste would
occur.
-------
-1_-2 -
3.
Upgraded Contai~~ent Alternative
As a result of the threat of an earthquake at t~e site, E?A
developed an upgraded contair~ent option to approach t~e s~~e
protection afforded by excavation and redisposal off-site. The
upgraded containment remedy would be improved in two respects.
First, a second liner would be placed in the cap to increase the
reliability of the gas control system. Should there be a failure,
the second liner would capture emissions. The cost of this
component is $360,000.
The wall of the containment system would not tie into an
impervious layer. Therefore, a ground. water control system,
comprised of six wells, approximately 80 feet deep, also would
be added .to the upgraded containment remedy to prevent migration
bAlow the cut-off walls. The wells would pump ground water
whenever necessary to insure that the contained waste was not
saturated. The possibility of future migration of waste would
be further minimized. The protection and reliability of upgraded
containment closely approaches that of excavation and redisposal.
However, reliability of the system nonetheless would be less
because of the inability to predict the itensity and effects of
seismic activity.
Excavation and Redispcsal Alternative
4.
The State also developed the "excavation and ::::-edisposal"
alternative, involving removal of all waste and obviously
contaminated material from both pa::::-cels. Waste includes the
black or dark-covered tar-like asphaltic material disposed in
the 12 pits, and obviously contaminated material up to one foot
below the sumf:s.
The quantities of waste material in the sumps to be excavated
are estimated to be 85,000 cubic yards. Berm materials between
the sumps to be excavated are estimated to be 25,000 cubic yards.
Contaminated overburden to be excavated are estimated to be
21,000 cubic yards. Clean overburden of 13,650 cubic yards
would be excavated and then replaced on-site. The one foot of
soil to be excavated jelow the sumps is escimated to t~cal 3,000
c'~jic 2/~'~::~"
?-=::3~C~2.l 8:
.~. 2£ ~ e :".5
to:) :2.~.S ?~=.c:e
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?: ::-~..\
Class I ~2cili~j.
"T'Ih ~ - oj - ::::a
-~..- '::>-'--
I..;oulc j~
~e~racsd
:..ll :':1 .3C:':
= ',: a}~ 1. ':'0 ~ :2
cr!-si~e.
Emissions will ~e monitor.ed during excava~ion ar.d H:ll be
controlled using f~ams, sp~ays and mechanical collec~ion.
~C~~ On-Site Disposal
5.
T~e RC~\ an-si~e disposal alternative entails the excavation
and te~90rary storage cr waste ~aterial anc contaminated soil.
Lined disposal cells would then be constructed and the wastes
and soils placed in~o t~e cells. The cap over the cel13 Noule be
lined and a gas collection syste~ installec.
-------
-~]-
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cost 0: £l2,?3'IOJO
e~:=~v~~i=~ 2nj ~ed~5DCS~~ ~a~
:: ;:::::-.~-:::::":. ',:z.l:..:e
CC:7,::' t.= 2'='
~Q t~c.~ .:;~ c~~C..=.\7:;': :.c':; =..~~C
:: c.::' ~ :;:'05 al
:)f S18,306,vCO.
C::.~t e~:::':-:.C::7~
- .
- - - ~ :-. ~.
. .
e:: ~ -= \." :: : :. c ~ ::. L.::
. . .
,- :::,-" -= pO - =. :=
- ---"-",, --"---
-: == :. ~ ':: -. = ~ =2
~--=
..:""'" - -
-, . -....
- . .
---'-',-
- .
- - - -.. .... '-'
- - . ....., .... - .
_.._.. -----...-
- ..... ,- - - .-
.- - - _. - .... . - -
- -.., - _. .. - . .--
-,,' - - .. - -,
. -
'- '- - _... . '-
.... -. - -,...
-... - '--
.. - -,'. - .
:~2 cc~~:e:~=~ =~ ~2S~;~ ~~~ ~~~~~:~; c~
:~~~ te~~;~ :y ~~~ S~~te.
Cost es~i3ates fer t~le ~e~ai~i~~ th~Ee ~~~io~s ta"le v~=yi~g
degrees of retinernen~ as reflected in tns =ange es~ima~es on
Table 1.
The S t .= t.;: I s con t a i run e n top tic n c:) s t s a r:- e e ): ~ eeL. E j toe e f 1 e c t
the r:-eliability of a feasijility study esti~ate. T~e c~g=aded
contai~"en:. op1:.:.on sho\<.'s additional costs fer ground ',let.8r'
pro t e c t ion a" d ace: i n 9 t j e c C;. 5 1:. 0 fad 0 u .: 1 e 1:':-1 e ~ tot :-: e c a ~ .
These cost estimates nave similar reliability to the Sta~e's
cOritai~L:-nE.~t 09Ci.0!'1. :'~le esti~.~r.es fo~ c. ~C?-.; cn-:::it-2 :~cility
are far less r:-efinec becacse L.~e original State feasibill1:.Y
study cid nct consider this c~ti:)n. Fur:-ther analysis wo~ld ~e
r:-equired to ref:.ne r.his estimar.e.
The SPA confldence level is highest for the COSi: estima1:.es
developed for:- the excavation and redisposal alternative. Should
contai~~ent be selected, wider cost variations would 88 expecr.ed.
D.
Evaluation of Effectiveness
The effectiveness of the four alternatives
is discussed
below.
D~r:-ing Construction
1.
a.
Contai nrnent
construction of the containment structure would entail
trenching and removal of a limited amount of hazardous material
~rior to installation of t~e barrier walls, liner and cap. A
very limited amount of air emissions would be expected and control
of these emissions would occur by the use or foams. ~o exposure
of the adjacent community would be expected.
A shorter const=uction time compared to excavation and
redisposal is anticipated due to the moce limited sC:)ge or the
work. However, time for design and procurement would add
considerably (i.e., 9-12 mont~s) to the antici~ated schedule.
EPA estimates that ac~ual const=uction would ~oc c:)~uence before
early 1985.
-------
I),~ j'JII:
(!'Jer :j i U" I.:
H. wi i dll:
~il dll~:
:;III~ I'rq)(Hdli()II:
CII~d'llp Co:.:;L::>:
1\ '111110 "Cdp:
(;I()u(~1 ~-JdtUt' OIllLrc>l:
'("I\.d ('''piLd
( \1,1'1:
AIII.It:t! :
Cn,; I ::>:
1'11~:;l~l\l. Veil lie:
'Ii I' it! I'Il~:;elll V"dlle:
Hell ~JU:.;:
-IO!/,
I '1 ~; !l.
ConI' d i 11111 :,,1
--- - --'-.
750,1)t)t)
'.nO, Ol)t)
1 '20, ()Ill)
..0 -
I'J, j~)~),(J()1)
I i) ,hi)', (l1Jt)
'- rJ ,(1111)
1., '/..)1 , 0(1)
1 ~i: )92; i)iil)
1 ~) ,(,'ii, ()()()
11.<1'/'.1,01111
(H3TS OF ('RUlHi,.:n HEMEIHES AT fvlCCOI.I.
------- ------ ---_._----- ------_._---
lIpU/:£ll.h.x1 C:onldillnenL
-----'/ ~)()-,li(J'{f- ----
~cavat ion an.! Ht=l.1 ispo::;al
---3'36-; OlIC)'
«.no ,000
l'/..(),(I()O
-0-
1/
13, Y)5, UI)O
j liO , UOO
500,000
- ------,--_.
tons
I::xcavatioll
OVetT)lU:(rl~l\
Wct::;te & Sui L
So i 1
'!'E~?!~l~!:,~~!~ i or~
\'1,,61:1]
Soi I
Oll-S Ile
Ho:1 i::;I)OSdl
ii~i~;"l.'c' CO
-------
1/
.;-i/
J/
('
IL~.
(
L>
Sou!.,--,"
ot th~e e3timales i~) CII2fvl lIill evaluation of
ot these tii lily:..
of these rough estimates is ClI2M Iii LI.
I l. f~d:; i hi liLy study e~j L i.JI\el' ".
Jl xl II tel docul1lcnLs to U \l~ :'; I .,1, 1.:.-
-------
-14-
b.
Upg~aded Contai~~e~t
To afford increased protection to the containment option,
EPA considered two additional components to the State's containment
remedy. A second liner would be installed and a ground water
interceptor system would be installed around the site. BPA
expects that these additional. components would extend the schedule
for construction by at least t~o months.
The remaining advantages and\disadvantages during the
construction period are identical to those discussed above for
the State's containment option.
c.
Excavation and Redisposal
This alternative entails excavation, handling, transportation
and redisposal of 85,000 cubic yards of waste material. Substantial
emissions are expected to result during this operation. The State
has designed an extensive program for emissions cont~ol, using
foams, special enclosures, and monitoring systems. In addition,
large quantities of cont~minated overburden and' soil would be
removed froQ the site. A lesser degree of air emissions are
expected from these materials.~
A higher temporary risk of exposure to the residents, compare~
to the containffient alternative, would be anticipated for this
alternative due to the large quanti~ies of waste to be removed.
construction of this alternative would be expected to extend
to 19-20 months. However, design and procurement for this alterna-
tive have already been completed.by the State.
RCRA On-Site Disposal
d.
This alternative would require excavation followed by
short-term storage of wastes and contaminated materials, during
liner installation. The advantages and disadvantages during
contruction are similar to the excavation and redisposal option
with a few exceptions. An increased ris~ 0: exposure to t~e
acj.::'C2;1~ c:::r:'"I:1I~:-'.:':'::. o.'f4c.t.:l,:. ::S5\.:':':'
~eC2~2~ ~~s:e ~~0:Jl~ =~ 3~=~2~
a~c\' e ;;:::-::uJ~c
~'""'--i",;:,
-J,~ ~_Io.._'
:- 2£11 2:" :"'ll r.c;
... - "I .
~~~:- :~s~al~~~:C~ ~~
:..~~ _:..~s::-
is complete.
BPA esti~ates tjat c~nst~~ction time wculc extend 4-6 mon;hs
beyond that estimated fo~ excavation and redis;~sal. ~o design
or procurement for this alternative has be8n developed.
-------
-15-
~
.::. .
='::~~
CCLst:::-:Jc-cicn
=-.
C.: i::' = i ~~ e ~ t
r,: - c: ~ -
\\ c.- - t::::
~2~~~i=~s ~ocl~ ~e~~~~
C:;:-::~"C.~
p e ::-:-t. c: .:1 :' :-. ~ -. -.:- .
::: .:::.r-:- i e::.-
~~lls w~u~~ ~ot ~e ~ie~ to ~~ i~;e~v~o~s ~ayer. ~e~~~:~~ ~~;~~ti8n
cf sor::e c~~:t2.IT.i:1=-1.t.S c..t 10\\" lc-...-els :;c:.s OCC'...L~:-:::-2-.j to e. C~~ -:h of
50-100 ieec, A:~~c~ch ~nE~~ll~tion of ~~e C~; V~~:~ ~~ e~:?~c~ed
to li~tit ~_i;-r2r.i.Gn c.::'': tr-:e ~2r~:e!" '''.~clls :r.7culc :.:=- -s:'.:;;~c!.~j t.:)
p:::-s~en~ ~~y ~1orizc~~21 ~~;~~ci.~~,
. - .
::.~..=\." .",.cu_c
nc; ~ s :.C~.~ .::: ~
V-2'::":.icic:l
Ii: i :; :::- Co. :. i 8:1 .:) £ C S i::' ~::-. :. :-:~.:. .:..,:: ~. .
:': :. :: i ::. .::.1
:::- i s ~:.
:. 8 : ~'l i ~
=.: :..: :. :: -= '.:
, .
','.:C~J..C
o c :: '..1 ~ .~::.: :-:
- . -
:= ~ ~. -2 ~ :: :. ::.:~ :. ::
:.-4:' ~
c;:~:..:)~:.
A gas c~ll~c~ion S~'S:S~ wo~ld ~~ :~s~~~:et DE~~~ t~e :a~ :~
collect gases ~elow the was-ce. This system would ~e connec~ed to
a caustic scrubbe:::- and carbon absorption unit aoove t~e cap.
Seismic activity could disrupt tte unit causing ~ech2nical failure,
liner or containIT.ent wall failure, or failure of ~he collection
system. Gaseous emissions could occu:::- as a ~esult of these
fzilures. The c~~~unity adjacent to the si~e wc~ld immediately
be exposed to these toxic Eillissions.
The design life of the co~tai~~e"t st:::-ucture is ap?roxi~ately
30 yea:::-s. Without signi~icant seismic activity, an evalua-cion cf
t~is st:::-ucture at the end of this ~eriod would je conducted and
majcrrenovation of the st:::-:Jcture may be required. Wich seismic
activity, da.r;'.age to the st~-uct'...1re could cause :::-epai:::-s of varying
extents. Repai:::- or small c:::-acks are esti~ated LO cost 550,000.
Although unlikely, major failu:::-e could cost up to 59,vOO,OOO to
repair.
Land use post-construction of the containment alternative would
be :::-estricted to passi~e uses (e.g. g01£ ccu:::-se).
Upgraded Contair~ent
b.
The addition of a second liner to the cap would be expected
to provide further protection against possible gas e~issions.
This would not, however, prevent all such migration. The gas
collection system would be the same as that envisioned under the
original contai~~ent option. However, the possible disru~tion
and gas escape caused by seismic activity would be more limited
by the second liner. Disruption of the scrubbe:::- system, however,
would remain the sarne as that detailed above. The additional
ground water interceptor system would, however, avoid ground
water contact with cont~~inants in the soil, providing a much
higher level of protection.
Risks to the barrier walls from seismic activity would also
be the same as discussed in the basic contair~ent option.
-------
.'
-16-
Excavation ar.j Redisposal
c.
Removal of all waste and obviously contaminated materials
afford the highest level of protection to the adjacent community.
More tha~ 99 percent of the waste would be removed in this option
leaving minimally contaminated soils.
The likelihood of significant migration of contaminants
toward the ground water aquifer is minimized by the removal of
the source of such contaminants.
With this option, the threat of direct contact or ex~osure
to gaseous emissions would be eliminated. In addition, seismic
activity would not increase the threat or exposure to emissions
or direct contact with this option.
The likely redisposal facility is loc~ted in a zone with
lower levels of seismic activity than the zone in which McColl
is loc at ed .
RCRA On-Site Disposal
d.
The RCRA on-site facility :would be expected to present a
much lower risk of vertical and horizontal migration of contaminants
to the aquifer because of the placement of a dcuble synthetic
liner below the was~es. Th~ installation of a leacha~e collection
system would also provide additional protection to tne possi~le
migration of contaminants to the ground wa~er. Some periodic
evaluation of the synthetic liners integrity migh~ prove necessary.
Seismic activity affecting the functioning 0: a gas collection
and treatment system would be expected to be the same as the
effects detailed in the containment option discussion.
VI.
COMMUNIT~ RELATIONS
Background
A.
The State has taken
the lead on
co;n:,lunity
relations throughout
~:;.is
;""'-"""~Q'-~
~ - " -' ....., - '- ..
It je~lelc?e~ a ;~~ces3 f8r ~el3y~r:~ ~~~C~~2~~O~
t~ t~e ;U~ll~ ~n 52=1; 1922 ~ne~ :~e ~emetia: i~~es~~ga=:~~ Ge~~n.
Using census da~a and door-~c-door canvassing, a ma~li~g lis~ of
approxiT.a~ely 350 area residents Has develo~ed. The Stcte no~ified
these reside:.ts by letter and bulletin or meetings, 2nd also of.
any upcoming activities at the site. DOHS chaired th~ n~merous
public meetings. Local newspapers were r.~ti£ied of mee~ings at
the same time as area residents. vihile the State did not place
formal n;;ublic notice" ad'f,le~tisements ii1 t~le papers, :l"1e pape::-s
fre~uently ran articl~s an~our.cing tne upcc~ing ~ee~in;s.
-------
--17 ~
T!l e f i ~s t
!71 E: -2 t l!1; '",. z.s
r.:e:l:: rEb~'J.z.::-y 4,
~ c ): '/
- - -- - ,
tv :':.::=~::l t:ie
. . .
~~= :c.ents t.r~c.:'
2n ~g~~~~Lerl~ ~~~ ~ee~ ~e~c~ej ~i~~
~~~e c~: ~2~c~~ies
fer ~e~e~i~l i~;-sst~;~~icn of
~:--i ~ ~::.:: e .
I;1 :'~2~:-C~
l S ~~: 2
2. ?~s:..:e:--:~s I
C8::-.l:'.itL.'2:E 'J.~c.S :8::--:L~e': c,f
a=e~ ~es:6~~~5 ~;hG ;:2~~ed
~c~e :~\:~~,~le~ent
t.tl~n trJe ;-ene~21 p~~lic. -:~}is ccr:-~~:itLe-2 ~let se\:e.~c.~ ~l;l~~S
tje Stzte i~tEpe~(2~~ly of tte gsne~~l f~~lic ~eet~n;s.
..; ....',....
W ..... ,-_l
At e2~j pt~=e cf tt2 p~cje~t DOES
i~~~r:J .t~e ~sside~~s o~ ~~og~ess ~~.g.
r1~.!.C! 2.
~c~lic ~e2ting t8
t.:) ci.~.::u~s ::2:l.~.ji~1
i~vestiQ~~icnr h~~lc~ ~~~~~2E,
r; ::. \. e -; e !1 ~ ~- 2.1
.=~=.\:.~S ~.
;' .;:::.c;- ~ r,-C
.................:. ..'::,-
~!~=e C~ ~~e =e=G~~.
- ...
.-.:. e ~:::-: ~~ oS "2:' 2.. ;::- -:. :--.: '2 :: ~ :. - :....: -..'.= ::
- -
.: :. -: € ~- ~ ~..: e
cppo~t~:~i~! ~= ~~~e
- .
C':-.=..l. 2..l"i':: '.,..; ':: ::. : ~ -2~; : :::: :7L-:-. -2 :.-. :. ~ .
- \...;. ..:... = ~- "; ..
_.; "- ............ --
~:s.=:.i ;":;~
~?83,
WE~e held at t~e F~ller~an :':ain Li~~a=j.
Or. ?e::"-:-~ c..~~. 2~,
the rneeLing location cnanged to Parks Junior ai;n Sc~ool. At
tnis meeLing three remedial alternatives were prs3enced and
de£crijed to ~he a~p~oxima~e~y 200 resiGer.~s in attendance.
The State informed the public that it would deterQine the
cost-effective re~edy following evaluation of p~~li~ co~nent.
O~ A~ril 7, 1983, tje State met with the residents t8 inform
them that it h~d selected excavation as ccse-eff~ctive. At tte
same time th€ residsnts were inf8r~ed that a test excavation
would be cond~cted during May to ensure that DOES emissions
control criteria could be met. The final meeting on chis ?hase
c: the project was held June 2 when the results of the tese
excavation were ciscussed.
;.t e'lery mseti;;g the pu::,lic ,",ias encoura.;;ed to cor,-",:\ent on
the State's planned activities. Under the State's procedures
copies of each report developed during the feasibility st~dy
were sent to two local libraries (the Fullerton Xai.. and Hunt
Branch) at the same time the documents were submitted to DOHS
a:ld EPA.
Articles published in the Daily News Tribune and the Daily
Star Progress following the June 2, 1983, public ~eeting descrlbed
the rcsiden~s' reaction to the Sta~e's announce~ent. The
overwhelming co~~unity consensus was an endorsement of the
excavation alternative. No written COIT~ents were received by
the State.. State Community Relations staff telephoned individual
members of the community advisory committee to solicit written
comments. Members con~acted stated that they felt the pUDlic's
oral comments in favor of excavation were clearly stated during
the public meeting. The residents primary concern was focused on
removal of the waste to eliminate the threat of hazardous emissions.
'Na concern was expressed regarding removal of the soil.
-------
-18-
Responsiveness
Su:nmary
B.
All meetings were recerded.These records and neWSDaoer
articles clearly indicate that the public favors excavatio~.
Because no written comments en the alternatives were received,
no formal sUIT~ary is required.
VI I I. CONSIS'!'ENCY WITH OTHER ENVIRONMENTAL UJ.;'S
There are two environmental regulations with whic~ the
McColl cleanup is required to comply: Clean Air Act and Resource
Conservation and Recovery Act (RCRA).
As required by the Clean Air Act, EPA has promulgated National
Ambient Air Q~ality Standards for criteria pollutants such as
S02' particulate matter, and ozone. Primary standards are designed
to protect the public health. Secondary standards are designed
to protect the public welfare. Under the Clean Air Act, States
have the authority to set standards which are stricter than
national standards. The State of California in conjunction with
the South Coast Air Quality Management District,'has set ~~bient
air standards for 502 that must be met during the McColl excavation.
The excavation has been designed to use foams and a containment
structure to ensure that the standards are met. However, sheuld
the standar~s be exceeded, excavation could be delayed.
Authority to implemen~ RC~~ has been delegated to the State
of California with the exception of permitting for sur~~ce
impoundments, incineration and land disposal. Since t~e State
is acting as the generator during cleanup, ~hey will co~ply with
their own regulations. RCRA generator standards will apply to
the excavation. The State will comply with all regulations,
including manifesting, recordkeeping, and reporting.
IX.
RECOMMENDED ATSRNATIVE
Section 104 (c) (4) of CERCLA states that EPA shall select
the most "cost-effective" remedy. In addition, Section 101(24)
of CERCLA states that off-site transport of hazardous substances
is r.ct a9pr.:;p-::-iat..~ '...l::.less i~ :'5 'I:nore cost--:f:ec.~:....;,: t:-~:3.!"";. ~t:jer-
~?~e'~:21 2.c:.iC,~S" c::- "n2ces.sa-:::/
~a 9~8t~C~ ~U~~~= ~~~~~~ ~r
"Ilel£are or- C:ie enV:"-:Or'"'LlL1t2nt: f~cm a p~ese~t o-c ~o~e!;L.i2.l "::i3k
Nhich may be created by fur~~er exposure to the conti~wed ?~esence
of such substances." T~ese provisio~s a~e ex?lai~ed fut~er in
the National Contingency Plan. See sections 300.68(j) ane
300.iO(c).
EPA has ca~efully reviewed the State's cost-ef~ecti?~ne5S
evaluation and t~e CH2M aill ~eview of tne Sta~e's feasibility
study, as discussec above. 3ased on E?A's indeper.cen~ cost-
effectiveness evaluation, excavation and redispesal is the most
cost-effective remedy.
-------
-19-
3cth C8:Jt.::.:;-.:-~~e;jt o;.ti~r..s ?:-.~\ii':,~ g:-e=:.e~ p':-8~e':~:cr: sf
I.=:L:jlic heel::1 -:u!:i:-:g c::;:13L.:-~cticn. Ec\',.:e~le~, ~:--:-= S:>:'.:..\;'2~;.:;:1 C:~C
=S':::':"S:>CE c.~
- .
=- ..!.. :. -2 :: ~. E:' .:. ....... ~
;:- :-c"v"::..c e
cl-.e ::::.:he:=::.
C-=::~S2 c:::
;'~-::'~'':::'~Qn
- .
~~LE= cs~st~~ctlcn.
8s~::T.~t.es
_.::: -.:....,...
\..; - '-..':'-=
CCS:. Co!
CO:1'.:.c2.:)",e:1':.
~ 2. r.C' ,3
r:-:::~
S2.S,f:2,000
to
S2.3,"; /9, ~:)OO i
excc.\:-2tio~
cos~s ~a~~~ ~=o~ S~3,:C~r000 ~o
S21,9E7,200. Ccsts esti~5~~C fer ~n ~~;=c~ec co~~~i~~~~~
~lte~na~iv~ r~~Qe f=Q~1 S12,937,000 to S25,563,CJO. Fc~ cc~;~=~son,
C-c:--c
v- '--
.: ':' .:- =. C:J:-::' c i ! ..:'T~ e ;-: \: :: ~ ':: i 1 i "c ~.7 C S ~ .:~. n e.,,:
:: :: c ?:. ~ ~: , ? ': -5 ! :- C. 0 ~ ',:: S ~ 5 , ! ~ ~ , C 0 C. .
:'8 c:-:::;: l~.t
" . : ~:-. :.. :. ::~..~.
:= ~ r-~::- -=
7~e ~;~~=ced :c~:.~i~~~n~ 2p~ic~ ~s
. .
--.=,-.=--..=.--
-- "---.....-
cec2.:":sc ~-
, .:::,
six pe~cen~ mo~e ex~ensive than excava~ion a~d ~edispcs21 a~d dees
not provide the sa;:,e level of long-te~:n prc~ectio" as Ex::avation.
Similarly, the RC?_'; on-site alternative is signi:ican:.ly :nore
expensive than excavation and similarly ?rovides t~e 1cng-ter~
pro'.:.ec~ion of upgraded contzinme~~. In this caSE, EPA's ev~l~ation
indicated that excavation is cose-effective fer the fcl~c~irg
reasons.
1. ?ltr-,ough there is no evidence of an eart.h~l\a;~e f 3.ult.
directly un.:er ~he sitE, t.he F\.lllertCin a~ea is in the highest
~isk ear~hquake zone in Cali~ornia (Zone 4) as desi~naced by
':.ne Unifc~ Buildin; Codes. While the precisE deg~ee or ~isk is
~~cle~r, there is some risk of public ex;osu~e to haza~Gocs
substances, es~ecially gases, sho~ld an ea~th~uake dist~~~ the
contai~~ent system. Because the communitj is adjacent to the
site, exposure would be rapid and witho~t attention. The likely
redisposal site (Casmalia) is in a lowe~ risk ea~th~~a!~e zone
(Zone 3).
2. The contai~~ent system is not tied to an impe~vious layer
beneath the site. Thus, the potential for ground water cont~ui-
nation from leachate from the site remains. rlvailable data indicate
that several constituents f~om the waste have migrated approximately
50 feet or more below the land surface. while the conce~'.:.~ction
found at these de9ths are not hazacdous, theic pcesence indicates
the vertical mobility of the waste.
3. the public has been info~med of the short-term ~isks of
excavation, and it supports the selection of excavatiCin. The
containment alternative would not have a high level of acceptance,
because it would be difficult to gua=antee such a system against
possible failure. The State supports excavation, has designed
the remedy, accepted bids for the cleanup, and is ready to award
the cleanup contract. .
-------
-29-
All of the alte~natives evaluated in detail were designed to
be p~otective of health, '..;elfare and the environme;lt. The EPA
therefore rejected the highest cost alternatives -- an on-site
RCRA disposal facility and upgraded contai~uent. Although the
basic containment option was slightly less expensive than
excavation, EPA's evaluation concluded that the long-term risks
of containment and the long-term benefits of excavation justify
the small cost differences (4 percent) between containment and
excavation. The State, and EPA staff recommend the selection of
excavation and redisposal as the cost-effective ~emedy. Total
capital costs are expected to be $21,500,000, which includes a 20
percent construction contingency.
Hazard~:;
Informat
US EPA f
Philddelr
--.~ -- -
------- |