United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-87/013
July 1987
SEP A
Superfund
Record of
Operating Industries, CA
-------
TECHNICAL REPORT OATA .
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EPA/ROD/R09-87/013 I
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SUPERFUND RECORD OF DECISION cTIIl v 31 - 1 987
Operating Industries, CA .. "'-'''O.''''''C O-'CA""ZA"O'" coo.
First Remedial Action
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U.S. Environmental Protection Agency Final ROD ~ennrt
401 M Street, S.W. I.. S'ONSO"INO AO''''C'' coo.
Washington, D.C. 20460 800/00
II. 'U""'I"INTA"" "'01'1.
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The Operating Industries, Inc. (OII) site, consisting of a 190-acre landfill, is.
located in Monterey Park, California. From 1948 to 1952, the site was used to djspose
of municipal garbage by the City of Monterey Park. Prior to 1948, the site and .,-
.
surrounding areas were quarried for sands and gravels. Between 1952 and 1984, under th
. private ownership of OIl, the landfill received municipal and industrial liquid and
sludge wastes. The construction of a freeway in 1974, split the landfill into a north
and south parcel. By June 1975, waste disposal operations curtailed in the northern
parcel, limiting operations to the area south of the freeway. In 1954, the Regional
Water Quality Control Board permitted disposal of liquids at the site. Some of these'
liquids, and some liquid industrial wastes disposed prior to the Board's permit, are
considered hazardous by current statutes and regulations. In 1975, a 32-acre area in
the southern parcel was permitted to accept Class II-I wastes. Waste disposal
operations ceased in October 1984. In 1979, Getty Synthetic Fuels, Inc.(GSF), having
established a contractual relationship with OIl for the extraction of gas from the
landfill, began gas processing activities (GPA). EPA took over operations of the GPA i
June 1987 following a decision by GSF to abandon activities at the landf ill. EPA has
been conducting site control and monitoring activities at the site since May 1986.
Additionally, EPA has conducted a number of emergency actions to mitigate potential
(See Attached Sheet)
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Record of Decision
Operating Industries, CA
First Remedial Action
Contaminated Media: leachate
Key contaminants: VOCs
II. O"""'IU1'IO'" '1'ATI/I"'."'1' ". 'IC","'T" C..... ,n,"lh"", 21 "'0 0" ""CII
None 36
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EPA/ROD/R09-87/013
Operating Industries, CA
First Remedial Action
16.
ABSTRACT (continued)
threats to public health and the environment. Leachate gene~ated at the site is a
hazardous waste as defined by RCRA regulations and contains VOCs including TCE, vinyl
chloride, benzene, and toluene. .
The selected remedial action for this site includes site control and monitoring
activities. The first control component is operation and consists of opening/closing
valves, starting motors and other mechanical functions. Maintenance is the second.
control component and can consist of repairs to existing systems or preventative
maintenance and improvements. Gas wells and leachate pumping and collection will be
monitored. The estimated present worth cost for this interim remedy is $5,100,000.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION: Operating Industries, Inc., Monterey
. Park, California
STATEMENT OF PURPOSE:
This decision document represents the selected remedial
action for the Operating Industries, Inc. site developed in accordance
with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (~ERCLA), the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous
SUDstances Contingency Plan (NCP) (40 C.F.R., Part 300).
The State of California has concurred on the selected remedy.
STATEMENT OF BASIS:
This decision is based upon the administrative record (index
attached). The attached index identifies the items which comprise
the administrative record upon which the selection of a remedial
action is based.
DESCRIPTION OF THE SELECTED REMEDY:
Full-time Site Control and Monitoring, Levell and 2. This
alternative provides for the continuance of site control and
monitoring activities at the current level of effort, and allows
for future system improvements throughout the project life. The
selected remedy represents an operable unit consistent with the
final remedial action.
Declarations
The selected remedy is protective of human health and the
environment and has been determined to be cost effective
and consistent with the final remedial actlon. As an interim
operable unit, the selected remedy will not be required to achieve
all applicable or relevant and appropriate requirements (ARAR's).
However, the final remedy will address technologies which should
be capable of achieving ARAR's for the site. This remedy satisfies
the preference for treatment that reduces toxicity, mobility, or
volume as a pr~ncipal element. Finally, it is determined that this
remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
Jd:t: W~
Deputy Regional Administrator
U.S. EPA Region 9
,."O\. 87
Date
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STAn "0* CAUFORNIA-HEAlTH AND W£LfARE AGENCY
GEatGE DEUICM£JIAN. eoo--
DEPARTMENT OF HEALTH SERVICES
107 SOUTH BROADWAY, ROOM 7011
LOS ANGELES, CA 90012
213) 620.2380
@
May 8, 1987
Michele Denner (T-4-2)
u.s. EPA, Region 9
215 Frem:mt street
San Francisco, C'A 94105
Dear Ms. Den1er:
SITE CDNrROL AND MJNI'roRING FEASIBILI'IY
mc. ,IANDFILL SITE
We have reviewed the subject study am agree that altemative No.3, as
presented therein, is the preferred altemative. Alternative No.3 is 1IDre
protective of plblic health and the environment than the other altematives,
and we urge that it be in1plemented.
S'IUDY',
OPERATING
INWsmIES ,
Please call me if you wish to further discuss this matter.
h#~~/
H.a.n:y N. Sneh
Assessment and Mitigation unit
Southern California Section
Toxic SUbstances control Division
'" '--
HS:ma
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-------
Decision Summary
Operating Industries, Inc.
Monterey Park, California
July 1987
Prepared by Michele S. Dermer
Enforcement Response Section
Superfund Programs Branch
Toxics and Waste Management Division
United States Environmental Protection Agency
215 Fremont Street
San Francisco, California
94105
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Decision Summary
Operating Industries, Inc. Site
Monterey Park, California
Site Location and Description
The Operating Industries, Inc. (011) site is located
approximately 10 miles east of Los Angeles in Monterey Pa.rk,
California (see Figure 1). The 011 site consists ~f a 190 acre
landfill which was operated from 1948 to 1984, and was used
for disposal of municipal and industrial waste. The landfill
contains hazardous waste and hazardous substances, and was
listed on the Nationa~ ~riorities List in May, 1986.
The Pomona Freeway divides the site into a
parcel and a l45-acre southern parcel. The top
parcel of the landfill is about 150 to 250 feet
surface and the bottom of the landfill is about
ground surface. Elevation of the upper surface
parcel of the landfill is about 620 to 640 feet
Level (MSL).
45-acre northern
of the south
above the ground
200 feet below
of the south
above Mean Sea
The 011 site is presently owned by the former operators,
Operating Industries, Inc. The EPA has been conducting site
control and monitoring (SCM) activities at the site since 011
ceased performing these activities in May, .1986. In addition,
EPA has conducted a number of emergency actions to mitigate
potential threats to public health and the environment. The
site has become.more stabilized as a result of the SCM activities
and the emergency actions.
The City of Monterey Park has a population of 54,338 (1980 Census).
The City of Montebello, which borders the southern parcel of the
landfill has a population of 52,929 (1980 Census). .Several residents
of Montebello are situated in homes immediately adjacent to the
boundaries of the landfill. Within a three mile radius of the
site, there are approximately 53,000 residences.
The perimeter of the southern par~e~ of the landfill is
fenced. Entrance is restricted and 24-hour security is provided.
Several businesses are currently operating on the northern 45-
acre parcel. These businesses have a lease arrangement with the
operators.
Site History
Landfill operations at the site began in 1948. From 1948
to 1952, the site was used to dispose of municipal garbage by the
City of Monterey Park. Prior to 1948, the site and surrounding
areas were quarried for sands and gravels. In January 1952, the
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-2-
site became a privately owned landfill under the ownership of
011. From 1952 to 1984, the site was operated as a landfill for
municipal and industrial liquid and solid wastes. In 1974, the
Ponoma Freeway was constructed. The freeway split the landfill
into a north and south parcel. In June 1975, waste disposal
operations were curtailed in the northern parcel. Operations
were then limited to the area south of the freeway.
On October 6, 1954, the Regional Water Quality Control
Board (RWQCB) first permitted disposal of liquids at 011
(Monterey Disposal Company Dump at that time). Some of these
liquids, and some liquid industrial wastes disposed prior to the
Board's permit, are considered to be hazardous by current Federal
and State statutes and regulations. In 1975, a 32-acre area in
the western part of the southern parcel was established as the
area of liquid waste disposal and permitted to accept Class 11-1
wastes. Waste disposal operations ceased in October 1984.
The 011 site was placed on the California Hazardous Waste
Priority List in January 1984. The 011 site was proposed for the
Federal National Priority List (NPL) of uncontrolled hazardous
waste sites in October 1984 and was finalized on the NPL in May
1986. .
In 1974, Getty Synthetic Fuels, Inc. (GSF) entered into
a contractual relationship with 011 for the extraction of gas
from the landfill for processing and sale to Southern California
Gas Company. GSF's gas extraction system went into operation in
1979. In March, 1986, GSF ceased its gas processing activities
and applied to the South Coast Air Quality Management District
(SCAQMD) for a permit to construct an electrical generating
plant. At that time, GSF began to flare the extracted gas in
an incinerator until final permits for construction of the
electrification plant were issued. GSF also applied for a permit
from the City of Monterey Park for discharge of treated effluent
to the sewer. In January, 1986 the City.Q.f Monterey Park denied
GSF's permit. As a result, GSF decided to abandon their extrac-
tion operations at the 011 landfill as of March 1, 1987. EPA
took over operation of the GSF system in June, 1987.
Over its 36-year life span, the 011 landfill has accepted
the following types of wastes: Residential and commercial
ref~sei water-insoluble, nondecomposable inert.solidsi liquid
wastes; various hazardous wastes including wastewater treatment
sludge from production of chrome oxide geeen pigment; and slop
oil emulsion solids and tank bottom sludges (leaded) from petroleum
refining operations.
-------
-3-
Both landf.ill gas and.leachate are generated by the 011
site. From April 1983 to October 1984, about 25,000 gallons
of leachate per day was collected by OIl's leachate collection
system and disposed of by mixing with the incoming solid waste.
Since then, collected leachate has been stored on-site in
Baker tanks, and transported to a permitted off-site treatment
tacility. .
. The leachate generated at the OIr site is a hazardous waste
as defined by RCRA 261.3 regulations, and contains hazardous
organic constituents, such as vinyl chloride, trichloroethylene,
benzene and toluene.
Land uses around the landfill began to undergo significant
changes in 1974. These changes included construction of the
Pomona Freeway (1974), and increased residential development
within Montebello City limits to the southwest (1975) and
south (1976) of the facility. A residential area is directly
adjacent to portions of the southern and western boundaries of
the landf ill.
Discussion of Past Site Control and Monitoring Activities
A number of site problems have been identified by State and
Federal regulatory agencies. These include:
o
Hazardous leachate seepage and breakthrough on
the landfill slopes.
o
Subsurface and off-site migration of leachate.
o
High landfill gas (methane) levels exceeding the
lower explosive limit in nearby residential areas.
o
Vinyl chloride prese~t in ambient air emissions
and in subsurface gas on-site and off-site.
o
Underground fires and, associated subsidence
on-site. . -
o
Slope instability and erosion problems.
o
Surface runoff from the elevated fill area.
.
Groundwater contamination from leachate and
migrating landfill gas.
.
Noxious and offensive odors on- and off-site.
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-------
-4-
Partial control measure performed on-site by the owner in
prior years include:
o
Installation of a leachate collection system.
o
Development of an air-dike air injection system on
the west side of the site to con~rol subsurface gas
migration.
Installation of gas extraction wells around the
perimeter (except for the air-dike area) of the
site and a gas flaring station.
o
o
Site contourin~,~slope terracing, and vegetation.
Covering refuse with additional fill.
o
The partial control measures instituted by the owner were
insufficient to maintain site integrity and the EPA, therefore,
instituted emergency response actions in order to protect public
health, welfare and the environment. Emergency actions performed
to date by EPA include:
o
Slope stability and erosion control improvements,
including construction of a toe buttress.
o
Surface runoff and drainage improvements.
o
Rehabilitation of the main flare station.
o
Site security.
o
Placement of vented water meter box covers off-site.
The owner/operator's ability to control the environmental
problems and maintain the control systems began to diminish
significantly in late 1984 when it notified EPA and the
California Department of Health Services (DOHS) that it could
no longer afford to truck leachate offsite for treatment. EPA
conducted the leachate trucking and trea,tment for several months,
and then DOHS assumed responsibility for this activity, while 011
continued to attempt to operate and maintain remaining on-site
control systems. On May 19, 1986, 011 notified the State that
they intended to discontinue all site control and monitoring
activities on the site except irrigation. The EPA therefore
assumed these activities on May 20, 1986. SCM activities then
continued to be performed by EPA, with the State DOHS providing
leachate trucking and treatment, and 011 providing on-site
irrigation. On December 15, 1986, the State transferred
responsibility for leachate trucking and treatment to the EPA.
The EPA has also requested that 011 allow EPA to assuae full
responsibility for irrigation of the site, sin~e EPA believes
that 011 has not properly conducted the activity.
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-------
LEGEND
I!J G
.. Control Well
.. Lech.,.
. AIr Injection Well
FIGURE 2
APPROXIMA T
EXTRACTION Es~ERIMETER GAS
OPERATING IN STEM
OUf S-QA S EX ~~~1~IIEO.N INC. LAND
-------
-5-
Current Status of Site Control and Monitoring (SCM) Systems
There are seven major environmental control systems and
activities at the 011 site that require operation, maintenance,
inspection, and monitoring on a continuous basis:
1 .
Gas Extraction and Air Dike System
2.
Leachate Collection System
3.
Irrigation Sy~~~m
Access Road System
4.
5.
6.
Stormwater Drainage System
Site Security
7.
Slope Repair and Erosion Control
Each of these systems and their components are discussed in
the following paragraphs. Recent SCM activities and system
improvements are also presented in the discussion of each system.
GAS EXTRACTION SYSTEM
Landfill gas is extracted by two separate systems, one
installed by GSF and one by 011. The GSF gas collection system
is located on the top of the landfill and extracts gas from the
center of the landfill. This system consists of a network of
piping for conveyance of gas, a matrix of 57 gas wells, and a
series of seven surface collectors. The GSF system was designed
to extract gas for commercial purposes and was operated by GSF
(independent of the 011 gas control systems), until June, 1987.
EPA took over operation of the GSF system in early June,
1987, with GSF providing short-term tec~nical assistance.
The GSF system must now be operated, maintained, inspected and
monitored as part of the routine SCM activities, until the Gas
Control remedy for the site is designed. and implemented.
The 011 gas extraction system (Figure 2) consists of
82 wells located along the perimeter and southern rim of the
landfill varying in depth from 30 to 170 feet. Some of the
deeper wells go into native soil. The wells are constructed
of polyvinyl chloride (PVC) schedule 40 pipe, perforated at
the depth of extraction (about 15 to 25 feet below surface grade
for shallow wells, and 110 to 150 feet for deep wells). The
wells are connected to a PVC pipeline just below the surface,
and the gas is drawn under vacuum to the main flare station where
it is incinerated. Vacuum is produced by three blowers located
at the flare station.
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-------
-6-
The all main flare station is located on the northwest
corner of the landfill adjacent to the GSF gas facility. The
flare station is enclosed by a security fence and consists of
three flare stacks, blowers, flame arrestors, electric motors
and 'instrumentation for control, recording, and monitoring. The
blowers at the flare station draw the gas out of the extraction
wells and pump the gas to the flare stacks where it is incine-
rated to reduce surface and subsurface emissions from the site.
In addition to the main flare station, an auxiliary flare
station with two stacks and blowers is located on the southwest
corner of the landfill ~~ose to the compressor equipment for the
air-dike system. The auxiliary system is operated only when it
is desired to gather' more than 4500 cubic feet per minute (cfm)
of landfill gas from the all gas collection system, or when
needed as a standby to replace units taken out of service at
the main flare station. The capacity of the standby system is
1000 cfm.
When all operated the landfill, continued problems were
experienced at the main flare station due to fouling of the
mechanical systems by condensate. EPA initiated emergency
actions in 1986 to overhaul and repair the main flare station,
and to install a demister and condensate collection tank to
reduce the amount of liquids carried by the gas into the flare
station equipment. During the installation period for this
equipment, rehabilitative maintenance was also performed on the
flare station equipment. It had been inoperative since March,
1986, during which time the auxiliary station was used. The
main flare station resumed operation December 17, 1986.
all AIR DIKE SYSTEM
The air-dike system consists of 26 air injection wells
along approximately 2,000 feet of property line situated at the
southwestern and western borders of the landfill (Figure 2).
The injected air is intended to form a high pressure air barrier
under the ground along the property line,. . preventing migration
of landfill gas off-site. To monitor the performance of the
air-dike system, gas probes have been installed midway between
each of the injection wells. The injection wells are spaced
approximately 100 feet apart and probes are approximately 50 feet
from the nearest well (see Figure 3). The probes are 20 feet deep.
The goal of the air-dike system is to minimize the amount of
landfill gas migration beyond the site boundary. The air-dike
system can be adjusted by opening or closing the individual
throttling valves at each injection well head. Pressurized air
to the injection wells is supplied by the compressor equipment
located on the southwest corner of the landfill, at the auxiliary
flare. .
Additional perimeter probes are located at the perimeter of
the landfill to monitor performance of the all gas extraction
system. These probes are numbered and colored. Probe depths are
usually 5, 15, 25, 35, and 45 feet. However, exact depth may
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LEGEND
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Probe No LOt/ger Monitored
Ex/.tlng Probe.
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FIGURE J 8 MONITORING,
ON81TE LANDFILL :1APPROXIMA TE)
PROBE LOC"DTuIIOT~IEa INC. LANDfiLL
OPERATING IN ,
OUfl-GAI EXTRACTION
-------
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LEGEND
OPERATING INDUSTRIES LANDFILL
. L..cIIot. CoIoctlon Wol
- L..chat. Tranch.., Pipe.
LEACHATE COl1.ECTION SYSTEM
~-==-= COlI
f9n 4
-------
-7-
vary as a result of site-specific conditions,
The locations of air dike wells, monitoring probes, and
perimeter probes are all shown on Figure 3. EPA has instituted
a daily monitoring program to provide for the most effective
operation of the various systems.
Two positive displacement compressors pump water-cooled air
to the air-dike injection wells. Operation of the compressor
equipment is monitored, recorded, and controlled by automatic
instruments. .
. .~
LEACHATE COLLECTION SYSTEM
Interim actions have been undertaken at the landfill to
control and prevent leachate seeps from occuring. A leachate
collection system was installed in the early 1980's by 011 and
subsequently expanded on an as-needed basis in response to on-
and off-site surface seepage. Leachate generated from the site
is collected by a combination of shallow collection drains and
deeper leachate wells. There are five areas on the site in which
leachate collection systems are installed. These are shown on
Figure 4 and detailed below.
Area I
Area I on the southeast side of the site consists of
trenches, perforated pipes and leachate disposal wells drilled
into dry refuse. Liquid waste disposal was not permitted on
this portion of the landfill. However, there have been leachate
seeps. With the installation of the collection system, the
seeps have apparently been controlled. Seismic studies of the
landfill, performed for EPA by Woodward Clyde Consultants (WCC)
indicate the absence of any extensive amounts of liquids in
this area.
Immediately south of Area I, along the base of the landfill,
a toe buttress has recently been constructed to stabilize the
slopes. A continuous drain has been installed within the toe
buttress. Leachate collected by this dr~in is transported to one
of three concrete storage tanks which can be periodically pumped
out by a vacuum truck.
Area. 1 I
The Area II leachate collection system consists of the
six 19uala wells. The 19uala wells were installed to prevent
leachate seeps in the Iguala Park area south of the 011 boundary.
The wells are 70 to 80 feet deep, generally extending through
approximately 10 to 15 feet of landfill rubbish and into the
native earth material. The wells were equipped with electrically
powered submersible pumps. Leachate collected from the wells
is pUDped into a collection manifold pipe connecting the six
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-------
-8-
wells to the ,underground tanks in leachate collection Area III.
There are five other wells in Area II that are not connected to
the collection system. In' the past, leachate has been pumped
from these wells' into vacuum trucks. There is no record of
pumping for the past several years. .
Two new collection wells were installed in 1986 as part of
the emergency response actions for the site. These wells arel
part of the collection system installed to prevent seeps in
the 19uala Park area. The wells are located 50 feet on either
side of well #L-18.
Area III
The leachate collection system in Area III, on the southwest
corner of the site, consists of a series of buried, perforated
pipes and trenches discharging into three buried steel tank$.
The buried steel tanks consist of one 3,500 gallon tank which has
the upper part of both ends perforated, a 8,000 gallon tank and
a 10,000 gallon tank. Each tank can be individually pumped out.
The tanks are resting in a gravel bed which can also be pumped
to remove leachate collected within the gravel bed surrounding
the tanks. The 3,500 gallon tank, with perforations in the upper
part of each end, is for collecting leachate in the gravel b~d
surrounding the cluster of tanks. All three tanks are from old
vacuum trucks and do not meet current regulations for underground
tank s .
Southwest and down-slope of the buried tanks, along the
boundary of 011, is a french drain system which flows to a
36-inch diameter unlined sump. Leachate is pumped from the
sump to the buried tanks. .
Area IV
Leachate collected in the buried tanks in Area III is pumped
to three 20,000 gallon, above-ground storage tanks (Baker tanks)
located in the vicinity of the surge tower in Area IV. Leachate
is removed from the storage tanks by a vacuum truck and trans-
ported off-site for treatment and disposa!. During the period
from April 1983 through October 1984, the leachate was trucked
to and disposed of in the active landfill working area.
The main leachate collection system in Area IV on the
westerly side of the site is similar to the system in Area III,
consisting of perforated pipe and trenChes which feed to an
unlined, 36-inch diameter sump in the vicinity of the surge
tower. The surge tower serves as a standpipe providing adequate
head to gravity flow leachate into the buried tanks in Area III.
- ----,.- -~-"-'-~" ,-.-- ----0- --,':"""""'''''''''-'''''''''~--'.'~<,",_._--,.-.-
-------
-9-
Area V
The leachate collection system in Area V is very similar to
the system in Area I, consisting of trenches, perforated pipe and
leachate disposal wells drilled into dry refuse. It is believed
that leachate seeps occurred in this area during the stockpiling
of dirt immediately up-slope. The existing system in Area V is
apparently controlling surface seeps in this area.
. In December 1986, approximately 97,000 gallons of leachate
were hauled off-site for treatment and disposal. This repre-
sents a daily average generation of approximately 3,125 gallons
of leachate. EPA has initIated emergency response actions to
repair and improve the existing leachate collection system.
These repairs and improvements were necessary to reduce the
potential for groundwater contamination from leaking underground
tanks, and to improve the effectiveness of the collection system
to reduce the potential for off-site migration of leachate.
Additional improvements are still necessary to improve the
existing collection system.
IRRIGATION SYSTEM
011 attempted to landscape
establish a vegetative cover to
aesthetics. A fixed piping and
manually controlled valves, was
vegetation.
the landfill slopes and to
reduce erosion and to improve
sprinkler system, operated by
installed to irrigate the
Irrigation on the landfill must be controlled to reduce
the potential for adverse effects ot the irrigation water, such
as increasing the leachate volume, adding moisture to marginally
stable slopes, or eroding the surface in areas of very heavy
irrigation runoff.
EPA ~as taken actions to minimize irrigation requirements at
the 011 landfill. Where slopes were regraded and compacted, one
area was revegetated, while the other slope received a soil
sealant. The area that was revegetated wi~h indigenous plants
will require light irrigation. The toe buttress will also be
vegetated with drought resistant plants. Both areas will need
regular irrigation.
ACCESS ROAD SYSTEM
. Another SCM task is the maintenance of a network of roadways
which provides access to all sections of the landfill. The road
network is shown on Figure 5. As part of EPAls emergency
response actions at 011, landfill roadways were graded in 1986
and concrete ditches installed to improve surface drainage,
enhance trafficability, and reduce maintenance effort. All roads
on the site are dirt or gravel surfaced. There are no warning or
traffic control signs, and no guard rails installed along any of
the roadways. Continuous maintenance of roadways is a present
and future SCM component.
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-------
-10-
STORMWATER DRAINAGE SYSTEM
The site is split by the Pomona Freeway into no~th and south
parcels. South parcel stormwater outfalls from the north slope
via four storm sewer lines henceforth called lines "An, "B", "C",
and "D". Line A, a 48- to 60-inch diameter pipe, drains storm-.
water runoff from the top of the south parcel, and the west
portion of the north slope of the landfill, channeling it down
the west side of the north slope to a concrete trapezoidal
drainageway paralleling the Pomona Freeway. Line B drains runoff
from the upper and lower terraces midway along the north slope
and also routes it to the freeway channel. Line C, located at
the northeast corner of the south parcel, also drains stormwater
runoff from the upper and .lower terraces and channels it to an
off-site gully which leads to an unimproved freeway drainage
ditch. Line D is a half-round exposed corrugated pipeline which
drains the northeast corner of the landfill. Figure 6 gives
the location of these four storm.sewer lines.
The storm drain lines were designed in 1973 and constructed
in 1975 as part of a proposed landfill closure plan. A sub-
sequent lack of maintenance, in combination with a large sediment
load and slope creep, had separated the joints and filled catch
basins.
EPA completed rehabilitation of the storm drains in 1986,
rebuilding Line D, and cleaning, repairing, and replacing
the joints on Lines A, B, and C. New catch basins were also
installed on these lines. In addition, terrace V-section con-
crete roadside swales {v-ditches}, 6 to 12 inches deep, and
located on the uphill side of each terrace, were installed to
promote the transport of surface water to the storm drains.
Future SCM will require routine inspection of the catch basins
and terrace road V-ditches, cleaning any sediment that may
accumulate, and repairing significant cracks or other damage.
As a part of a separate study, EPA has also initiated a
program to sample and analyze the runoff from the landfill to
determine if there are any contaminants in the runoff waters.
This data should be available in the summer of 1987.
SITE SECURITY
Access to the south parcel of the site is restricted by a
perimeter fence. The gate to the fence is located on the North
Parcel and is manned by a security guard. The guard logs the
entrance and exit of all site visitors and restricts access to
autnorized individuals only. The gate is locked at all times
when the guard is not present. SCM activities include routine
inspection and repair of the perimeter fence and provision of
the security guard services.
-------
-
-
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LEGE NO
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Camp Dr888er & McKe8
LAYOUT OF SITE ROADS
-------
CONCRETE.
TRAPEZOIDAL
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CHANNEL
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OPERATING INDUITRIES, INC. LANDFILL
MONTERE'( PARK, CALIFORNIA
STORM DRAIN LI NE
LOCATION MAP
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CDM
6
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-------
-11-
SLOPE REPAIR"AND EROSION CONTROL
As part of SCM, the site is regularly inspected by EPA
for cracks, fissures, scarps," and similar evidence of subsidence
or slope movement. A toe buttress has been constructed by
EPA on the southeast side of the landfill to improve slope
stability.
In order to reduce surface emissions of landfill gas and
infiltration of stormwater, the slopes must be regraded, recom-
pacted, and/or recovered when cracks, fissures, scarps, etc.
develop on the surface of the slopes.
EPA has conducted .emergency actions to repair severely
eroded slopes on the north face of the landfill. The slopes
were regraded and compacted, and one area was revegetated, while
the other slope received a soil sealant. In addition, some" .
landfill slopes have been landscaped by EPA with natural grasses
and indigenous plants to inhibit erosion.
SCM activities at the 011 landfill will continue to require
inspection and monitoring of slopes for evidence of subsidence
or movement. Areas that begin to be eroded must be repaired.
immediately upon discovery to prevent escalation of the problem,
which could increase surface emissions or, if severely eroded,
expose trash.
ALTERNATIVES EVALUATION
The EPA has been conducting site control and monitoring
and emergency response activities at the 011 site since 011
ceased performing these activities in May 1986. The site has
become more stabilized as a result of these emergency actions.
As a result of EPA's SCM and emergency response actions, the site
SCM activities have shifted from an emergency activity to a more
routine control or remedial activity. By conducting SCM, EPA has
become very familiar with the conditions at the site and has
collected valuable data and information for the overall RI/FS.
In addition, SCM activities are necessary~or the EPA to formulate
and evaluate Site Control and Monitoring alternatives to justify
the continuation of SCM as a Remedial rather than an Emergency
Action.
on-going control and monitoring of the site is necessary
to maintain the site integrity and protect pUblic health and
the .environment until long-term solutions are designed and
implemented. "
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-------
-12-
The following objectives and considerations will guide the
formulation of the interim remedial alternatives for site control
and monitoring. .
o
SCM remedial alternatives must be easily and rapidly
implementable. The interim alternatives must be
consistent with the final solution.
o
Remedial actions which permanently reduce the volume,
toxicity, or mobility of the contaminants at the OIr
site are preferred.
o
Remedial actions must be cost-effective for the interim
(5-year) period..- It is estimated that construction
for the final remedial actions for the site will begin
in 1991.
Long-term remediation will be addressed in the comprehensive
RI/FS study currently being conducted. The RI/FS for the 011
site is expected to be completed in 1989.
Three levels of screening were performed on the remedial
action alternatives. First, an initial technology screening was
performed to eliminate inapplicable, infeasible or anreliable
technologies. Next, an initial alternative screening was per-
formed. Finally, we performed a detailed alternative evaluation
according to the NCP, 40 C.F.R. Part 300.6f(i).
The National Oil and Hazardous Substances Contingency Plan
(NCP) 40 C.F.R. 300.68(f) specifies that to the extent it is both
possible and appropriate, at least one remedial alternative shall
be developed as part of the feasibility study in each of the
following categories:
1.
Description
Alternatives for treatment or disposal at an
off-site facility:
Category
2.
Alternatives which attain'~pplicable or rele-
vant and appropriate Federal public health or
environmental standards;
3.
As appropriate, alternatives that exceed
applicable or relevant and appropr1ate public
.health or environmental standards;
4.
Alternatives that do not meet applicable or
relevant and appropriate public health or
environmental standards but will reduce the
likelihood of present or future threat from
the hazardous substances; and
5.
A no action alternative.
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-------
-13-
Since this study is for an interim remedy, it is not
necessary to develop alternatives that meet or exceed all ARARs.
Section 121 of SARA specifically gives a waiver to meeting
Federal and State ARARs when the remedy under consideration is an
interim remedy. The final remedy developed through the overall
RIfFS will address all ARARs, and all the categories for remedial
alternatives.
Components of Site Control and Monitoring Activities
Site control and monitoring at the 011 site has three
components. The first control component is operation, and
consists of opening/closing valves, starting motors and other
mechanical functions. Maintenance is the second control
component, and can be conducted at a baseline level (level 1)
consisting of repairs to existing systems such as erosion
control and repair of leaks in piping or replacement of small
parts in mechanical systems, or it can be performed at a higher
level (level 2) to also include preventative maintenance and
improvements such as installation of additional gas or leachate
wells, road surface improvements, and other system upgrades to
improve the operational efficiency of the SCM systems. The
third component of SCM is monitoring. Monitoring involves the
collection of data, ~ncluding field measurements of gas wells
and probes, the measurement of leachate pumping and collection
rates, and the routine inspection of all the environmental
control systems on the site. The data collected are used to
adjust the systems for maximum control efficiency. The data is
also used in the on-going gas control and leachate management
operable unit feasibility studies and in the overall RI/FS.
General Response Actions
These three components of SCM were included in the development
of general SCM response actions. The array of general SCM response
actions which have been identified to comply with the NCP guidance
are:
Response Actions
." "-
NCP Category
L
Periodic performance of Site Control and
Monitoring: and
1, 4
2.
Continued SCM with Levell Maintenance
(repairs and replacements without
improvement"s)
1, 4
3.
Continued SCM with Level 2 Maintenance
(including repairs, component replacements
and improvements)
1, 4
4.
No action
5
. --',-- ... ..-', --.. -
.", -:'""-: ~A.-:' ':~::. .
--'."0,,'-'.,
-------
-14-
The first general response action is a reactive mode that
provides less than full-time attention to SCM and limited repair
upon breakdown of any system. 'The next two general response
actions provide for full-time SCM and take a proactive preventive
maintenance posture. The -no action- alternative is considered to
provide a baseline against which other actions could be compared.
Description of Alternatives
At present, SCM is required for both active and passive
systems at the 011 site.~ Active ~ystems include the perimeter
gas extraction air-dike control system, leachate control system
and the irrigation system. Passive systems include the stormwater
drainage system, access road system, site security system and
the slope repair and erosion control systems. The active control
systems may have some passive components. .
Alternative
Frequency
Description
1.
Periodic
Operations
Maintenance - Levell
Monitoring
2.
Full-Time
Operations
Maintenance - Levell
Monitoring
3.
Full-Time
Operations
Maintenance - Levell and Level 2
Monitoring
4.
No Action
Cessation of all SCM activities.
Alternative 1 - Periodic SCM
This alternative represents a reduc"iton from the current
level of effort applied to site control and monitoring activi-
ties. Under this alternative, a full-time SCM capacity would be
reduced to periodic inspections and monitoring of gas probes and
groundwater wells. Mechanical systems would be turned on and
left unattended. System malfunctions discovered during periodic
inspections would be repaired (i.e., cracked or leaking pipes,
or access road deterioration sufficient to prohibit access) but
mechanical systems, would only be repaired or minimally replaced
until the further work could be accomplished as part of the
permanent site remediation. This alternative could allow site
systems to deteriorate to a state of reduced operations depending
on the cost necessary to repair or replace a system and, time
required to achieve the final remediation. The annual cost of
Alternative 1 is estimated at $2.5 million, which includes approx-
imately $2 million for 'offsite trucking and treatment of leachate.
.'''''-.;'',""=C''P:-':-,,'''~'-.':'-,-O::;>:"';~
.-"" -. ~.; ..: :"-"",:-F",.'~~--' '; ,:--- ".
. -, c;':.-, '..' - . ~ 'r. .-",': '0-' -:xc." "-;,.'. 0' '-"",., " - I;;, .
. .---.: -"~.,--='- "~:."< ~-.'- ,.':,:;'.....; : ,'J
~. '" . "..~' ,:~:,--, ''':"~r::-, :~;-"\,--:";-:;~~:i";.' ,.- ,"; ';, -" --,~ ~.~.' .
'-'.-.- .--;~,". -. -;
-------
-15-
Alternative 2 - Full-Time SCM (Levell)
This alternative would allow for the continued full-time SCM -
activities for all site control systems described in Table 1, at
Levell. However, this alternative does not enable improvements
to existing control systems, but merely the repair .and replacement
of existing control systems components to maintain the current
condition. This alternative would not address changing conditions
at the site. All improvements would be deferred to the permanent
remediation of the site as determined by the RI/FS, and any major
replacements or systems modifications would be done only as an
emergency response actlon. This could allow conditions to deteriorate
to an emergency situation before a response could take place,
thereby potentially exposing the community to a hazardous situation.
The annual cost of Alternative 2 is estimated at ~3.57 million.
This annual cost includes an estimated $2 million for offsite
trucking and treatment of leachate.
Alternative 3 - Full-Time SCM (Levell and 2)
This alternative would continue the current level of effort for
the site control and monltoring activities of the site in a full-
time role, providing daily operation, repairs and replacements
of control system components when necessary; and implementing
system improvements ~onsistent with the final remedial action as
such improvements are identified (Table 2). Replacement parts
for the various system needs would be procurred and installed on
a preventative maintenance schedule. System expansions and/or
improvements (such as modifications to the air dike or replace-
ment of underground leachate storage tanks or improvements to
access roads and cover) could be implemented if the expansion or
improvement was identified as a system need consistent with the
final remedial action, or necessary to protect public health,
welfare and the environment. Annual cost for Alternative 3 is
estimated at ~5.l million. This annual cost includes as estimated
$2 million for offsite trucking and treatment of leachate.
Alternative 4 - No Action
The no Action Alternative is defined as the cessation of
operation and maintenance of site systems. In this scenario, the
active gas extraction system would shut down (no electricity to
run the blowers applying a v~cuum to the system) and gas pressure
wou~d continue" to build within the landfill, and surface and sub-
surface emissions could increase. It is anticipated that odors
would quickly rise to an offensive level in the vicinity of the
landfill and explosive gas levels could be reached. The passive
leachate collection system would continue to collect leachate,
and transport it to the underground storage tanks. However,
when these tanks reached capacity, they would overflow. Leachate
would accumulate in this area and could flow offsite as the soil
became saturated. Saturated soils could cause slope failur~s
and mud slides. Irrigation would cease on the landfill site,
vegetation would be stressed to the point of survival, and erosion
would be unchecked. The access roads would revert to 8natura18
.c-.~~.,._~.~~'~ "-~.'
.~~." ;"- . "';' ~<,-:,~-,,~,,:'~'2"-,<~ "''''--:"~ ".n
-." ~:,?,";-v :~=,: ":~ ~~- . -~ ',:
:'-:"',~ - ~'.~' .::~ ,~
. ~ '" -:-
" :..- ", . '.. .':; ~:-.,:;. ~~~'~'"';.< : ;-'C:~/.-'<":' -~::- > ,;,."
:::",:,:,">::,,~,:,~,_.,:~..~~.;,]\..,-,' ..".',-',' .," '. \.
;'T;.:;-=""'O.o:'-_._~.:-,;-.,,- .
" .
-------
Table
l'
Maintenance - Level I
SITE CONTROL AND MONITORING ACTIVITIES
Operation
Ml'niteri,,!!
Mllintenllnl'e - Levcl Z
Aare SI8Ii(\lI:
Wt'll head valve
adjustmenl, Ii~hling
flllres, sliming
blowers and pumps
Gas WcUs:
Adju~lmenl of well.
prc~~ure and gas
velocilY
~:
Slarting C(\ml're~~n
and adjusll1\enl of
injecti(\n air
pres~ure and volume
Slarti"~ IIi,. lift and
electril: pUl1\pS;
arrlln~ing ,.'r Iruch
10 rell1l've lellchale;
~
'.- -"~;~'.'~.'_.':-.;:':-:::"'.""-
. . r.r ~ . .'
. ':'; "., ~'t~:.~;"'* .' ,:)- ':
GIS EauKtion and Air Dille Control Sysu:ms
C1eanin~ r;rin~ anll
screens. n:rail of
burners. blowt'r~ and
comJel1sate relUrn I'UlI1p
Periodic repair (\( well
laterals alld associalt'll
piping
S€-rvkinc IIml repair "f
compresSors 1111<.1 piping
Flare sluck e1"ensions
new instrumenlali,'n Ii.;r
control & recordin~:
silencers ,.';Ih bellcr
IIlIellualion and general
improvemcl1IS as
recommendt'l'. Also provides
(\r fUIurc imprc.wenll:nu as
svslcm dt'lkiencies lire
;i!cntilic.'d, (\r as 5ile
cOlldilions chllngc.
In~1811 additional well~
and n('W piping: m(\re
monilorin~ prObes and
general il11pr(\\"emenls
85 rcc(\rnmeIllJt'lI.
Also provides
f(\r fUlure il11l'r(\vcmcnu as
S\"~Ic.'1I1 dclkicnde~ are
i"l'nl ilkl'. or as sill'
cunc.lilions changc.
Inslallation (\f
adllili(\nlll air dike
""ells amJ prol>cs and
general ill1l'r(\vell1ellls
a~ re<:omrnc.'nded.
AI5<' provides
fN fuwre ill1rrcwements as
S\"5ll'l11 delkienc.:ies are
i,lt'nlilil'tI, or as sill'
condition~ change.
Le8c:hale Coflcr:lion and Tmllment S)'SIeftI
Ser\"king and rc.'pair of
I'll 111 p5 , II1l1il1lcllalll"t' "f
air surf1'~ riping,
repairs 10 Baker lanh
E_pansion of shallo",
,"111:«':1;"11 syslem,
insllll"tli"n IIf
leat:hale COIlC.'I'lh'n
.'eUs. dcwatcrillC of
glls "'ells and pro~s -
and general improve.
ments 115 recolnmendt'll,
A '5<' prov illes
Ii.'r flllllrc ill1l'rCwemt'nls as
~\'Sll'm d("it'it'nl'ic.'s' lire
i\lcnl ilie..1. {\f a~ ,il~'
l't'nc.lili(\n, c.'han~e.
Monilcring l1arl'
ttmperalUrc. emissions,
residence time
Monitor well head
pressllre and gas
velocity and lenlperalUre;
Perimeter anll olrsite
prol>t: monitoring
Dail~' monitoring 01'
methane gas concenlrations
IInc..l pressure in air
dike probes
Inspections for emeq;enl
~IJS, lIIonill" collt:tlc.oc.J
le8chllu~ volunles, inspect
Blkt'r tanks Ii>r leaks,
melt'urt' levels in
leachate /lnd gas wells
~., .~ ,,<>r~:-; ';c:::, ~~'<:'~-:--:-~P-"'.~~.-:" -'.~. -,
-------
- [:~ '.-~~',,"~-"':"'.--, "..'.~'~-r-'~,>--
'. . -'.
. .
Table
1
.(cent'd)
SITE CONTROL AND MONITORJNG ACTIVITIES. continu~
Op:rltion
Monitoring
Mllintenan~ . u..-eJ I
Maintenln~ . Level 2
Mllnllal CIf'l"'Iing IInu
closing of vllves
Not Il1plical'le
Not Ippliclille
Access control II)'
gllllrd
Not 11"I"1ic:aMe
".-,' -''-''"
Vllh-e Ind rire
maintenln~ and repair
Dust control Hnd
,,"Hine grtldi"~
Irri~tion S)'IIem
Install lIu.omllll-U
s~'su:m, purdll5e renl~
I'il~, "rand or redu~-e
S"Slel1l as n~san.
and gt"nera' iml'roVemellu
IS recommended,
Also pro"illes
Ic.r future improvements 15
s"slem delkiencies Ire
icJenlilied. or IS sile
~'Onditions change,
Aca:ss Road S)'IIaII
Surfacing iml'ro\'ements.
Irllllic Cl1l11ro' signs.
i:uardrails IInd
genefll' impro\'ements
as reconlll1enul-d.
AI!oCI pro,'ides
for future improvements IS
svstt"m deficiencies lire
i~lenl inCl!, or liS site
cl1nditiuns change.
SUlrnnraccr Draift8F S)'IICIII
Cleanin~ of dilches.
catc'hllllsins and road
drllinllge chRnne's:
~air of drainage pipe
jllints, ef01iion control
al outfalls. surfll~'e
grading 10 ."aintain
drllinllge I'alterns
Mllintenance and repair
of site perimeter fen~
Instllll ~/iment traJ'lS
at outflllls. reroute
drllinRgl' to redis-
Irillule stomnuter
110.'. coUl'l1 IInu
trellt contaminaled
stormwater and generlll
impro'-emenls as
rt'('ommrnded .
Alo;o prO\'ides
Ic.r fUlllre imprO\'ements IS
5,'stem uc'tidenc:ies are
idenlitil'll. or as site
conditions change.
Site Security
Securi.y lights, alllrms.
inrreR$t' i!lIard hours
and i:eneral improve.
ments 115 recommt"ndt.-u,
Also provides
lor fUlllre iml1rovemenu as
s,'st~'m dc'fidencies lire
identified, or liS Site ~
cOll\litions change,
Slope Repeir and Erosioa Control
Slupr grauini! anu
compan ini:. lilling
cracks anu fissures.
mlintenance of phlnts
- ",,{ <'" .~ -
'-':~' }:~';,'"7'?',}~..7'.'<;~~'" ,,~,:.~: <:'
ImprO\"emenls ui site
cO\'er Ind drainllge
pllltems Ind 5!eneral
imprO''t'mI.'nb liS
rt.'I.'CImmc:ndc'd.
AI!oCI pro,'iut.'S
fl,r future impro"l't11l.'nh liS
s, 'tl'm dt'lkit'ndl" IIrt'
i;It'IIIi/il'll. 01 liS ,itl'
c'l1ndilions l'hlln!=l'.
. '.... '-':),~'" ~'>"'c.
Monitor ve&elllion
stress. insfICCI pipe
for 11:8ks. monitor
irrigation volumes used
ROUI ine in~pecti(\n
lor sii:lIs 0" en'sioll"
01" su t'sidens:e
Inspect V.dltches and
drainlli!e pipes 10.. damage:
II1<\nitC11' rainfall amounts
and runof!' waler quality
Ingress &: egress
roster main'lIinl'll IIv
I;ulrd. in~11eCI perimeter
fen~-e
In~pection l(.r sien~ of
ert'Sion and sl~
mO\'emenl. /iell! I11C1f\ilOrinc:
tOllctt."r01illt' en1i5Sion~ -
from surlitce
.' .~. "C~' ,.
:.-- ':~"~.-:-~~" ,"-;-".-7. :-T'-:)7:~:-? ''''-~'::~~.}-;~~~::::~~.~,i ':~::;-S.:.tt~~'YT;~--" '.:~:'
-------
-16-
conditions, meaning that they could become overgrown with brush,
eroded, and generally impassable. Storm drains would continue to
passively operate, but sediment buildup or materials blocking
drainage to the system would eventually divert drainage to other
patterns, and could cause erosion, ponding, and excessive infil-
tration and run-off of contaminants. In this scenario, all site
i~rovements and the correction of any site deterioration would
be deferred to the implementation of the final remediation.
Continuing investigations at the site could be hindered or
delayed due to access difficulties for drilling, sampling, etc.
There is no annual cost associated with Alternative 4.
SUMMARY OF INITIAL SCREENING
Initial screening of interim remedial SCM-alternatives
was performed to eliminate alternatives which were not effective
in adequately protecting the public health, welfare, or the
environment, did not follow acc~ptable engineering practices,
established EPA guidelines or did not permanently and signifi-
cantly reduce the mobility, toxicity or volume of hazardous.
substances. Alternatives that were deemed significantly more
costly than other viable alternatives were also eliminated.
Various SCM alternatives were reviewed. Based upon the
previous referenced criteria, only two alternatives were found
to be acceptable and were selected to undergo further analysis.
The table below presents a summary of the screening process
performed on the SCM alternatives for the 011 site.
SUMMARY OF INITIAL SCREENING OF SCM ALTERNATIVES
Alternative -
Screening Result
Comment
Alternatives land 4
Eliminated
Do not protect public
health, welfare, or the
.-environmen t.
Alternatives 2 and 3
Accepted for
consideration
Retained for further
analysis.
DETAILED ANALYSIS OF ALTERNATIVES
Description of Alternatives
A.
Alternative 2 - Full-Time SCM (Level 1)
Alternative 2 provides for:
'-=----'---'C-;C"C'~"""~"".~~' '~'--'~'-"~.-~~' '.~-". ~'.,'.<~'':'" -
. ~ _. L '.-," ~-
C'. -.~,-,"'-- '.0 :.--~"T_",~ '-'-::'T:"c..-.-:.,.;,:,:c~~,-co;-...c;'':''';;-.-,.-:'--:;'7:';..o:' -";'; '-'~>""'~ .~..t - '..: -''-'f'-" ..',.J".' ,
.',; !:;;,'," ..:<;.7"::' -:~.'.~.;;' c .,r';c,.;.: '-:c~.~,. -'~ .
-------
-17-
o
Continued SCM of the site systems, including the
repair and replacement of system components as
necessary for both preventative and emergency
ma intenance. .
o
SCM activities are limited to the operation. and
maintenance of systems currently in place and
does not provide for improvements to existing
systems. .
o
Maintains the existing SCM labor force, the
site secuiity, and the capability to optimize
performance of existing systems~
A detailed breakdown of costs associated with Alternative 2
is included in Table 2.
B.
Alternative 3 - Full-Time SCM (Levell and Level 2)
Alternative 3 provides for:
o
Continuance of the existing SCM labor force to
monitor gas probes, manually operate the irrigation
system, maintain roadways and provide on-site
preventative maintenance to the sites operating
systems, plus basic improvements as needed to
conduct SCM.
o
Improvements to the leachate collection system.
o
Interim cover improvements.
o
Interim drainage improvements.
o
Interim improvements. to the gas c~llection/control systems.
o
Undefined future system improvements throughout
the life of the project. Potential improvements
identified during the interim period (before
implementation of the final remedy) will need to
be evaluated to determine if the work should be
done as a repair or as an improvement.
Improvements included in this alternative are intended to
provide for enhanced operational efficiency, reduced threat to
public health, welfare and the environment and improved systems'
reliability. An allowance has been provided for annual systems
improvements as needs are identified through the RI/FS process.
A detailed breakdown of costs associated with Alternative 3 is
included in Table 3.
c;' ,., .'.".',.':'"',':;:;"'-,?7 ,;:_.-::-.;-~ .-;,,..-, ":-.:" .'.'" - - --:: c, :". ,"0<.
~: .~\;;<'''''':''-'. . H'-OJ.:" ":'f'''''>;-:;--- +-'.,-.--
- ..- ,,~:,--:; ;'c-,:::/.~' "':.'" r;c~. .!~, -;, '.' .}~ ,.-~;,;,--.:.,.-: ::i,. '-':;,";-: --;::J':--:" ":'-:':'~t:. '~;.: ',f~' '-.;. t<' 7S,:Y'f"':-'''''- .~' ~~:)' "-~ ..,:", :~~ ~;-' '''':-;-'7~ <. - :f-:(~' ;-: '::,:~-=::(::.: :':-':-: -, ?.;:~ ;~, '":' '" .--;;-
-------
,
J
I
I
. ,
"
..
Table 2
l\tHJAL COSTS - ALTERNATIVE 2 - FULL TIME Sat (Levell)
;
,j
i
\'1
. ,
- .
Cateqory
Number
Hours and Rate
Annual Cost
'"
_i
.;
':1
"
1.
LABQRIII
Office Staff
'~1
,q
:'1
]
.?j
:1
.:~
A
, :.~
:'i"
j
,)
.'.1
'::1
':}
:,~
,~'J
,~
."
Field Staff, Part-time
2 Reports, Data
coq>i1ation,
records, invoices
1 Supervisor 50 hrs/Wk @ $50/hr
2 Laborers 40 hrs/Wk @ $40/hr
1 Laborer 4 hrs/Wk @ $40/hr
1 Security Guard 50 hrs/Wk @ $10/hr
1 Laborer 20 hrs/Wk @ $37/hr
400 hrs;mo @ $50/hr
$ 240,000
,
.~
"
1
Field Staff" Full-time
$ 130,000
$ 166,400
$ 8,300
$ 26,000
$ 38,400
2.
HFAVY EXJUIPftENf
Graders, loaders, trucks
3. LEACHATE TR\'fKI~ AND TREA'l11ENl'
4. GSF System 1 I
5. OVERHEAD
100 hrs;mo @ $100/hr
111$160,000 per mo.
$55,000;mo. x 12 mo.
$ 120,000
$1,920,000
$ 660,000
Field Office, Phone, utilities
121$ 20,000 PER MO.
$ 240,000
$3,549,100
$ 0
$ 24,000
'IOTAL ANNUAL 0&11
i,:.1
,,~'~
"1
I'~
\~
1,';'\
IYJ
,'1
J'#
:~j
I:"
;~J.
:'~
:;~
,'~
,;;~
":J
,,-:I
"
.;:'1
;:;JJ
.'<1
,:j
ri.'
"
\~
. ,~
.~-~
:;~
j'
(Allowance for)
. (Allowance for)
$ 2,000 per mo.
'IOTAL ANNUAL 0&11 COSTS
6.
7.
SYSTEM IMPROVEMENTS
REPLACEMENT PARTS
$3,573,100
(11 Based on CA OOHS budqets for Mar 86 throuqh Dec 86, and USEPA estimates for the period Dec 86 to May 87.
121. Includes irriqation water.
(JI Rates include direct and indirect labor costs plus 10\ fee.
(4), Based on the followinq monthly cost estimate:
~ 0 Labor: I $25,000
o Repair/Upc}rade: 1,000
o Condensate TreatmentjUtilities 24,000
o Continqency 5,000
,
--~_." -~-.-
-------
TABLE 3
ANNUAL COSTS - ALTERNATIVE 3
I
.1
:,1
J
.
'..
"J
JLL TIME SCM (Level 2)
Category
Annual Cost
"
J':J
"
~:, j
:'1
...
,,.
:J
Numbe r
Hours and Rate
1.
LABOR 1 3 )
Office Staff
.;
"~
','
-~
'"
-)
:-:_:~
1"1
t\1
q
,
,~~
'1
':1
;,1
'~
:"~
. :~
::!
",':)
'.'
'~:;
nj
[;~
I":{
::1
',',\
I;i~
~~1
I ,~
i;:~
I,.}~
l'ti
'.
.1
'-f.1
I ::~
1,,-;)
:;~1
~Ji
~\!
:,)
Ii]
.'",1
';11
;: ~
.:1
Field Staff, Full-time
Field Staff, Part-time
2.
HFAVY E)JUIPMENT
Graders, loaders, trucks
3.
4.
5.
6.
LEACHATE TRUCKING AND TRFA'D'tENT
GSF System (4)
OVERHEAD
Field Office, Phone, Utilities
SYSTEM IMPROVEMENTS
Leachate Improvements,
Interim Drainage Improvements
Interim Cover Improvements
Gas Improvements
C
-------
Evaluation of Alternatives 2 and 3
As an interim measure, both alternatives 2 and 3 are cost
effective remedies consistent with the final remedial action,
and both provide protection of public health, welfare and the
environment. Neither of these alternatives would achieve ARARs
for gas emissions. These alternatives are protective of public
. health by allowing for the most efficient operation of existing
systems to minimize the emissions of gas or leachate from the
site. Alternative 3 is more protective of public health and the
environment because it allows for system improvements as system
deficiencies are identified, or as conditions change requiring
expansion or improvement of systems at the site.
Both of the alternatives for interim site control and
monitoring will contribute significantly to the reduction of
mObflity, toxicity and volume of hazardous contaminants at the
011 site because gas will be collected and incinerated, and
leachate will be collected and treated for removal of hazardous
constituents. However, site control and monitoring Alternative 3,
Full-Time SCM - Level I and 2 will further reduce mobility and
volume of hazardous contaminants since improvements can be made
to extract leachate and gas from additional areas as changing site
conditions may require.
The final remedy will address technologies which should be
capable of achieving ARARs for the site. However, our under-
standing of condition at the site is not complete enough to. allow
us to implement these control technologies at this time.
The annual cost of Alternative 2 is $3.57 million and the
annual cost of Alternative 3 is $5.1 million. Both these estimates
include an estimated cost of $2 million for offsite trucking and
treatment of leachate. Depending on the alternative selected in the
Leachate Management Record of Decision, these annual costs could be
revised.
.
An overall summary of the analysis of Alternatives 2 and 3
is detailed in Table 4.
Recommended Alternative
.. ~
The recommended alternative for site control and monitoring
is Alternative 3, Full-Time SCM - Level I and 2. Alternative 3
is more protective of public health and the environment than
Alternative 2 (Full-Time SCM - Levell) because it allows for
system improvements as deficiencies are identified, or as condi-
tions change w~ich require expansion or improvement of systems
at t:he site.
The annual operating costs of Alternative 3 are approxi-
mately $5.1 million which includes $250,000 for recommended
improvements to the leachate collection system, $250,000
-------
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TABLE #4
SCM ALTERNATIVES FOR 011 LANDFILL
Alternative
Annual
SCM
Cost ($1.000)
Capllal Present Worth
6% lilt
Public
Health Concerns
Environmental
Concerns
Technical Concerns8
Public
Concerns
b
Permanency
2.
Full- Time
SCM (Level I)
3.
Full-Time
SCM (Level 2)
. 3."3
5.073
o
15.043 14.257
Prevents exposure
to leachate seeps.
controls gas
migration.
minimizes gas
emissions but does
not uUow lor
conlrol of emissions
due to deliciencies
in present syslems.
or changing sile
conditions
Prevents exposure
10 leachate seeps.
controls gas
migration.
minimizes gas
emissions. and
addresses system
deliciencies Hnd
changing site
conditions
Reduces air
emissions and
controls odors
and dusl
Reduces air
emissions and
controls odors
and dusl
Prevents deterioration
of operaling systems.
Does not address
deliciencies of
presenl systems
Prevents deterioralion
and provides for
improvements to
increase operating
systems' efliciency
and protect public
health
Moderale
Resislance
Low
Resistance
Reduces mobility
and volume of leachate
and gas in areas presently
addressed by existing
systems. but not in areas
of fUlUre emissions
Reduces mobility
and volume
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250
16.152
al These alternatives must maintain site integrity until long term solutions lor the site are implemented.
bl Section 121 of the Superfund Amendments and Reauthorization Act of 1986.
17,14/1
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for undefined future system improvements, $250,000 for interim
cover improvements 'and $250,000 for interim drainage improvements,
and $250,000 for interim improvements to the gas collection systems.
The recommended alternative is both protective and cost-effective
and utilizes permanent solutions and treatment technologies to
the maximum extent practicable.
A detailed cost summary fQr annual cost associated with
Alternative 3 is prov~ded in Table 3.
Consistency with Ap~licable or Relevant and Appropriate Require-
ments (ARAR's)
SARA contains requirements in Section 121(d) which specify
that any "...standard, requirement, criteria, or limitation
under any Federal environmental law..- or any -...promulgated
standard, requirement, criteria, or limitation under a State
environmental of facility siting law that is more stringent
than any Federal standard....- is considered legally applicable
or relevant and appropriate to the CERCLA action.
"
The preamble to the NCP defines applicable laws as those
which would be legally applicable to the response action, if
that action were not taken pursuant to CERCLA. -Relevant and
appropriate- requirements are those which, while not strictly
applicable, are designed to apply to problems sufficiently
similar to those encountered at CERCLA sites. Revelant and
appropriate requirements may also be those which would be
applicable but for jurisdictional restrictions such as the
dates.
SARA also requires that EPA formally set forth ARAR's
in the Record of Decision (ROD). However, in the case of an
interim remedy or operable unit remedial action, a waiver of
this requirements is provided for under Section l2l(d). The
final remedial action for the 011 site will be required to meet
all ARAR's. '
..' '....
Federal ARAR's identified for SCM activities include:
The Resource Conservation and Recovery Act (RCRA), which con-
tains regulations for facilities involved with the treatment,
storage or disposal of hazardous waste (40 C.F.R Part 264) are
applicable to the landfills where hazardous -waste has been
disposed. Add,itionally, the general pretreatment requirements
of the Federal Clean Water Act (40 C.F.R. 403) apply to any
action which involves the disposal of treated waste to a publicly
owned treatment works (POTW).
Applicable state requirements to be considered include
guidance from the South Coast Air. Quality Management District
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-20-
(SCAQMD), the California Waste Manag~ment Board, the Los Angeles
County Sanitary District (LACSD) and the Regional Water Quality
Control Baord (RWQCB).
The South Coast Air Quality Management District Rule
1150.1 mandates installation, operation, and maintenance of a
landfill gas control system "to prevent the average concentration
of total organic compounds over a certain area on the surface
of the landfill from exceeding 50 ppm.. Further the 8maximum
concentration of organic compounds as methane, measured at any
point on the surface of"' the landfill, shall not exceed 500 ppm."
this requirement would be relevant to the landfill control and
monitoring.
The California Waste Management Board regulates landfills
in the state. The Board has established a landfill gas migra-
tion requirement that the concentration of landfill gases at ~
the perimeter of the landfill shall not exceed 5% methane.
The RWQCB regulates NPDES permits under the Clean Water
Act. An NPDES permit may be required for discharges of surface
runoff into the Los Angeles County Flood Control System. EPA
is conducting sampling of surface water di~charges in order to
determine whether an NPDES permit is necessary.
The Los Angeles County Sanitary District regulates discharges
to their sanitary sewer system, which covers the area surrounding
the all landfill site. LACSD sets effluent discharge limits
which must be met for any liquid wastes discharged to their sewer
system in compliance with the Federal Clean Water Act. The LACSD
will therefore require permits for any discharges of treated or
untreated wastes to the sanitary sewer system.
ARAR's identified above are not currently being met by the
current level of effort in site control and monitoring. The
final remedy will be required to acheiveoARAR's. The recommended
alternative will lay the foundation for the achievement of ARAR's
by allowing for the improvement of existing site systems as deficiencie~
are identified.
Community Relations
. A history of the community relations activities at the all
site, the background on community involvement and concerns, and
specific comments on the Feasibility Study and EPA's responses
are found in the attached Responsiveness Summary.
Schedule
o
Approve InterimoRemedial Action
Sign Record of Decision.
° July, 1987
o
Commence Interim Remedial Action
August 1, 1987
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Complete Interim Remedial Action
August 1, 1992
Future Actions
Two additional operable unit Feasibility Studies are
currently underway. The Leachate Management Feasibility Study
examines alternatives for managing the leachate generated
by the landfill. A record of decision for this operable
unit is scheduled for the -4th quarter FY'87. The-Gas Control
Feasibility Study evaluates alternatives for managing the gas
generated at the site. A record of decision for this operable
unit is scheduled for 3rd quarter FY'88.
The overall RI/FS for the site is ongoing. Field activities
under RI Part 2 are currently underway. The final phase RI/FS
Part 3 will address the final remedial action and is expected to
be completed in 1991. At that time a Record of Decision will be
signed to select the final comprehensive remedial action for the
site. An expedited clean-up of the northern 45-acre parcel is
anticipated before completion of final remedy. It is expected
that this northern portion will be deleted from the National
Priorities List in advance of the final site cleanup. -
." ".,...
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