United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-87/014
September 1987
3 EPA Superfund
Record of Decision:
San Fernando Valley, CA
-------
TECHNICAL REPORT DATA
rtaii (ntrmcttoHt on tie wtnt btfart
1. RIPORT NO.
EPA/ROD/R09-87/014
$ ACCtSS.C«« NO
4. TITLI AND SUWTLI
SUPERFUND RECORD OP"DECISION
San Fernando Area I, CA-
First Remedial Action
OATI
September 24, 1987
t. »fR»ORMiNG ORGANIZATION COOt
7. AUTMORISI
• . PERFORMING ORGANIZATION MPQRT SQ
•. MRPORMINO ORGANIZATION NAMI AND AOORISI
10. PROGRAM «k.CMtNf NO
11 CONTM AWT/GH AN T NO
13. SPONSORING AGfNCV NAM! ANO AOOMfSS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13.
OP HtPONT ANO MRlOO COV(H(Q
Final ROD Report
14. SPONSORING AOINCV COOI
800/00
It.
NOTIS
IT. ATTRACT
The North Hollywood - Burbank Well Field (NHBWF) is one of four NPL sites in San
Fernando Valley, CA. It is located within the San Fernando Valley Ground Water Basin,
which can provide drinking water for approximately 500,000 people residing in the San
Fernando Valley and Los Angeles. The NHBWF, operated by the Los Angeles Department of
Water and Power (DWP), provides drinking water to the City of Los Angeles. In 1980 TCE
and PCE were discovered in 25 percent of DWP's wells. In July 1981 DWP and the Southern
California Association of Governments began a two-year study funded by EPA. The study
revealed the occurrence of ground water contamination plume patterns that are spreading
toward the southeast. Following the completion of the study, DWP began a program to
control the spread of contamination, which included preferential pumping and blending of
the contaminated ground water with uncontaminated surface water supplies. The primary
contaminant of concern to the ground water is TCE with PCE and other VOCs present.
The selected remedial action for this site is ground water pump and treatment using
aeration and granular activated carbon - air filtering units, with discharge to the DWP
Pumping Station for chlorination and distribution. Spent carbon will be removed and
replaced with fresh carbon, with the spent carbon scheduled either for disposal or
regeneration. The estimated capital cost for this remedial action is $2,192,895 with
present worth O&M of $2,284,105.
KIT WOAM AMD OOCUMINT ANAk*«IS
b.lOtNTl*liR»/OMN iNOtO T|RM» C. COSATI
Record of Decision
San Fernando Area I, CA
First Remedial Action
Contaminated Media: gw
Key contaminants: VOCs, PCE, TCE
J1 NO Of*AGiS
70
it. DISTRIBUTION STATIMIMT
if. SiCUlRiTY CLA4* < riut Kiforti
None
20. SICUDlTV CLASS i Hiu 0«f*i
2J
I*A
-l (*••• 4-77) »«€viOu» COITION >•
-------
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
North Hollywood/Burbank Well Field Area 1 of the San Fernando
Valley Sites, Los Angeles County
STATEMENT OF PURPOSE
This decision document represents the selected remedial action
for this site developed in accordance with CERCLA, as amended
by SARA, and to the extent practicable, the National Contingency
Plan.
The State of California has concurred on the selected remedy.
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 SELECTED REMEDY
The purpose of this project is to mitigate t e observed rapid
spread of groundwater contaminants in Area 1 by extraction and
hydraulic containment. The selected remedy includes a groundwater
collection and conveyance system of shallow groundwater extraction
wells and collector pipeline, aeration facility for volatile
organic chemicals primarily trichloroethylene (TCE) and perchloro-
ethylene (PCE) and granular activated carbon-air filtering
units. The contaminated groundwater will be treated down to
the Maximum Contaminant Level (MCL) for all observed or expected
volatile organic substances at Sppb for TCE and the State
Action Level for PCE at 4 ppb. Treated groundwaters will be
conveyed by gravity via an existing pipeline to the Los Angeles
Department of Water and Power's North Hollywood Pumping Station
for chlorination and distribution. Spent carbon from the tower
will be removed and replaced with fresh carbon, with the spent
carbon scheduled either for disposal or regeneration.
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate and is cost effective.
This remedy satisfies the preference for treatment that reduces
toxicity, mobility, or volume as a principal element. Finally,
it is determined that this remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable.
SEP 2 4 1987 , _ „ c
-------
SUMMARY OF REMEDIAL ALTERNATIVES
SELECTION, OPERABLE UNIT FOR THE
NORTH HOLLYWOOD-BURBANK WELL FIELD
OF THE SAN FERNANDO VALLEY SITES
August, 1987
-------
LIST OF FIGURES
Following
Figure Page No.
1-1. Vicinity Map of the San Fernando 1
Valley
3-1. Location of Wells Containing TCE 3
in excess of NCL and State Action
Level
Table
3-1. Levels of TCE Contamination in North 3
Hollywood/Burbank area Wells
5-1 Cost Summary of Final Alternatives 9
8-1 Cost Summary of Final Alternatives 20
-------
1.0 SITE LOCATION AND DESCRIPTION
The North Hollywood-Burbank Well Field is located within the
North Hollywood National Priorities List (NPL) Site, which is one
of four NPL sites in the San Fernando Valley. It is also located
in the San Fernando Valley Groundwater 3asin. The sites were
proposed for inclusion on the NPL because of the discovery of
trichloroethylene and other volatile organic contaminants (VOCs)
in the groundwater. The San Fernando Valley Groundwater Basin
comprises 112,000 acres of valley fill situated among the Coastal
Ranges within the Los Angeles metropolitan area (Figure 1-1).
The area is used for residential/ commercial, and industrial
purposes. Groundwater from the basin is distributed by various
municipalities and water districts to the residents of the
metropolitan area. The Los Angeles Department of Water and Power
(DWP) operates the North Holiywood-Burbank Well Field to provide
drinking water to the residents of the City of Los Angeles,
located to the south of the San Fernando Valley.
The North Hollywood-Burbank Well Field is situated in the part
of the San Fernando Groundwater Basin with the best aquifer
characteristics and therefore provides a large proportion of the
groundwater produced from the basin. The eastern half of the
basin, which includes the 'North Holiywood-Burbank well Field, is
underlain by alluvial deposits consisting of coarse materials/
such as sands and gravels, interbedded with localized lenses of
clays and silts. As a result, the area is characterized by high
soil permeabilities and excellent aquifer quality. The North
Holiywood-Burbank Well Field provides 30% of the groundwater that
DWP produces from the San Fernando Valley Groundwater Basin.
This accounts for approximately 10% of DWP,s total water supply.
The San Fernando Groundwater Basin can provide drinking water
for approximately 500,000 people residing in the San Fernando
Valley and Los Angeles. In times of water shortages, the ground-
water shoreig* can be drawn upon to supply about one million
people. It^is also an important source or water for the Cities of
Burbank, Glendale, and San Fernando.
-------
2.0 SITE HISTORY
Investigation of contamination in the North Hollywood-Surbank Well
Field began with the discovery, in 1980, of trichloroethylene
(TCE) and tetrachloroethylene (PCE) in one quarter of OWP's
wells in San Fernando Valley Groundwater Basin. In July, 1981,
DWP and the Southern California Association of Governments
(SCAG) began a two-year study funded by EPA. The study revealed
that the contamination occurs in plume patterns and is spreading
with the flow of groundwater toward the southeast, at a rate of
approximately 300 feet per year. Following the completion of the
study/ DWP began a program to control the spread of contamination;
this involved preferential pumping and blending of the contaminated
groundwater with uncontaminated surface water supplies. In 1984,
the North Hollywood area, including DWP's North Hollywood-Burbank
Well Field, was proposed by EPA, along with three other well
field sites within the San Fernando Valley Groundwater Basin, for
inclusion on the National Priorities List (NPL).
In 1985, EPA and its contractor, Camp Dresser i McXee Inc.
(CDM), evaluated existing data concerning the North Hollywood
NPL Site and concluded that adequate information was availaole
to justify a Fast-Track evaluation of the North Hollywood-Burbank
Well Field. In March of 1986, a cooperative agreement was signed
between EPA and DWP, authorizing DWP to perform a Fast-Track
evaluation by preparing an Operable Unit Feasibility Study (OUFS).
The objective of the OUFS is to recommend an interim remedial
measure, consistent with the final remedial solution, that will
slow down or halt the migration of contamination in tne groundwater
prior to the Remedial Investigation/Feasibility Study (RI/FS)
process. An OUFS report was prepared documenting the decision
process in recommending a remedial alternative for the well
field. The DWP recommended the extraction of contaminated
groundwater and its treatment, using aeration and granular activated
carbon, to lower contaminant levels to State Action Levels and
Federal Maximum Contaminant Levels (MCLs) before combining the
groundwater with other water supplies.
-------
San Fernando
Valley
La Crescenta
Burbank
10 is
VICINITY MAP OF THE SAN FERNANDO VALLEY
MILES
-------
3.0 -CORRENT STATUS
The following describes the type and extent of contamination that
is presently known about the site on the basis of preliminary
investigations. Because the RI/FS has not yet begun, the contami-
nation has not been fully characterized, however enough monitoring
information exists to justify an operable unit for the North
Hollywood/Burbank area.
According to preliminary investigations, TCE is the primary
contaminant present in the North Hollywood-Burbank Well Field;
PCE is also present/ but to a lesser extent and in lower
concentrations. Scanning results for 45 volatile organic compounds
(VOCs) indicate that trace quantities of other contaminants are
present as well. However/ the measured concentrations of all
other detected contaminants varied considerably according to
sampling location and time/ and exhibited no discernable pattern
of contamination.
As of August, ln?5, water from 27 of DWP's wells within the North
Hollywood arna exceeded the State Action Level and federal MCL
for TCE, which is five parts per billion (ppb). In several of
the wells, the level exceeded 40 ppb. PCE is present in water
from four wells in the area at levels exceeding the State Action
Level of four ppb. The locations of wells exceeding Action
Levels are indicated on Figure 3-1. Levels of contamination by
TCF, in we'.Is of the North Hollywood area are presented on Table
3-1. The highest TCE level found was 1500 ?nb. This contamination
problem affects approximately 500,000 people.
Plume patterns extend from the northern limit of the well field
toward the southeast. Historical data indicate that the contamination
plumes have migrated approximately 1,100 feet in four years/ a rate
that approximates the flow of groundwater in the region. At
present/ water from 27 of the wells in the field contain TCE in
levels greater than the State Action Level and MCL. At the
current rate of plume migration, another 5 to 10 wells may reach
contamination levels greater than the State Action Levels and MCL
within th«MMxt two years.
-------
The public «ay be exposed to contaminants within the groundwater
of the North Hollywood-Burbank Well Field through drinking water.
Water from--the field is extracted and then blended with surface
water supplies. This water is then delivered to approximately
one million people served by LADWP. Groundwater from this centrally
located well field can be distributed to many parts of the City
of Los Angeles through various reservoirs and supply lines.
Because TCE and PCE are suspected carcinogens/ the California
Department of Health Services (DOHS) has set Action Levels for
these compounds of five ppb and four ppb, respectively. EPA has
adopted a corresponding Maximum Contaminant Level (MCL) of five
ppb for TCE. Additionally, EPA has set the Maximum Contaminant
Level Goal (MCLG, previously called Recommended Maximum Contaminant
Level, or RMCL) for TCE at zero ppb and has proposed a MCLG of
zero ppb for PCE. There is no proposed MCL for PCE.
Under normal conditions, groundwater from the North Hollywood-
Burbank Well Field provides only ten percent of OWP's water
supply and, because of dilution, water delivered to DWP customers
contains TCS and PCE at levels less than the State Action Levels
and MCL. During periods of drought or high demand, however,
groundwater contributes a greater proportion of the water destined
for DWP customers. During these situations, well water composes
20 to 30 percent of demand, and DWP may be forced to serve wacer
that exceeds State and Federal standards. Evaluation of water
usage and contaminant levels during previous periods of drought
and high demand indicates that the result could be TCE concen
trations of 8 to 13 ppb delivered to the customer tap.
4.0 ENFORCEMENT
In August 1985 EPA's contractor compiled a list of Potential
Responsible Parties (PRPs) for the four areas within the San
Fernando Valley. A priority list of 59 facilities was developed
based on facility size, operation type, use of chemical solvents
and disposal practices. Types of facilities include electroplating,
aircraft and, light manufacturing industries.
-------
.«•
„,•<-""'"
•NSET MAP
Sin FtrntnOo I
S»n Fwnindo
Kill Cr«sc»nl. .
[airbini. ENLARGED AREA I
City of
Smll Monica V-Ot Ang«l««
• PROPOSED AERATION
TOWER
I * BASED ON MEAN OF ALL TCE
SAMPLES 1MO-
- - ^ L *L I
AVERAGE* TCE CONCENTRATIONS SAN FERNANDQ^CALLEY
P«j«d«n.
g 1 I I LI I JJ
GROUNDWATER BASIN WELLS
-------
EPA plans to send RCRA 3007/CERCLA 104 information gathering
letters to these facilities to determine the extent of their
responsibility for the contamination problem in the San Fernando
Valley. The responses will be analyzed and the facilities will
be prioritized based on currently available evidence. §122(e) of
SARA requires that special notice be given to PRPs whenever such
notice would facilitate negotiations for response actions. In
this case, PRPs have not yet been identified and evidence on
potential sources has not been developed. Therefore, it is
inappropriate to issue special notice letters at this time.
5.0 ALTERNATIVES EVALUATION
This is a source control measure rather than an offsite measure
because the plume will be contained and treated on-site.
5.1 OBJECTIVE
The objective of the Operable Unit is to slow down or arrest the
migration of the contamination plume at the Morth Hollywood-3urbank
Well Field as an interim measure while the San Fernando Valley
RI/FS is being performed. Unless actions are taken quickly, more
wells will be lost to contamination, which will impact the ground-
water supplies of the DWP, the City of Burbank, the City of
Glendale/ the City of San Fernando, and the Crescenta Valley
County Water District.
5.2 SCREENING
5.2.1 SCREENING ALTERNATIVES
In evaluating alternatives for a Superfund remedial action, the
first step is to evaluate those technologies or operational
strategies that may be effective for the site. The following
remedial action alternatives were considered:
£•
No action
Containment of the Plume
Extraction and Disposal
Extraction and Treatment
Extraction and Blending
-------
Initial consideration of the approaches that could be used at the
Morth Hollywood-Burbank Well Field resulted in the decision to
utilize extraction. The No Action alternative was eliminated
from consideration because it would not meet the objective of the
Operable Unit; the contamination plumes would continue to migrate
downgradient, rendering additional wells unuseable. The containment
alternative was not given further consideration because it was
infeasible due to the great areal extent of the plumes and the
depth to the water table (approximately 200 feet).
Extraction is considered necessary because it will .preserve a
valuable natural resource, clean water/ by preventing the loss of
additional wells to contamination. Once extracted/ the groundwater
may be disposed of/ blended with uncontaminated water, or treated.
These three options are discussed below.
The disposal option was eliminated from consideration because it
would constitute the loss of water supply and because of the
possible expense involved in disposing of the water. DWP would
have to replace the pumped groundwater with alternate water
supplies, which are not assured during times of drought. The
groundwater could be discharged directly into sewers or storm
drains if contamination levels are low. Should contamination
levels exceed limits set by the Los Angeles Regional Water Quality
Control. Board and the Los Angeles County Sanitation District, who
are responsible for permitting such discharge/ however, disposal
would require pretreatment or the use of an approved hazardous
waste facility/ either of which would be expensive.
Blending of contaminated water with uncontaminated supplies was
also removed from consideration. This is because adequate supplies
of uncontaminated water may not always be available with which to
blend the contaminated supplies. Should contaminant levels in
the well water exceed approximately 40 ppb, the quantity of
blending water will exceed the available supply of uncontaminated
water or the hydraulic capacity of the collection system.
The third option/ treatment of the extracted groundwater/ meets
the objective of the Operable Unit and preserves the water resource.
It was therefore decided to extract groundwater from the contaminated
plume at a rate that would arrest the migration of the plume,
treat the water and distribute the treated water to DWP customers.
-------
TABLE 3.1
WELL NAME
•MEAN, LOWEST, AND HIGHEST TCE LEVELS IN
NORTH HOLLYWOOD-BURBANK AREA WELLS
NH-2
NH-5
NH-10
NH-U
NH-13
NH-14A
NH-lS
NH-16
NH-17
NH-13
NH-19
MM-20
NH-22
NH-22
NH-73
NH-24
NH-25
MH-2A
NH-27
NH-28
NH-2?
NH-30
NH-31
NH-34
NH-35
NH-36
NH-37
MM-38
' -NH-39
NH-40
NH-41
NH-42
NH-43A
NH-44
NH-45 :
WH-1
UN-2
WH-3
WH-4
WH-S
WH-6A
WH-7
WH-S
WH-9
WH-10
EW-1
EW-2A
NUMBER OF
SAMPLES
1980-86
.
38
46
14
27
6
30
16
10
20
32
10
•>w
22
10
13
59
16
16
49
13
10
17
68
13
39
12
14
39
44
14
58
43
22
S
w
3
16
30
49
27
16
17
9
12
11
8
11
41
MEAN TCE
LEVEL
1 980-86
(PPB TCE).
4.63
61.60
262. 57
96.41
pjL "*"*
O O • w ^.*
22.45
7.74
1.06
4.07
3.68
60.33
16.71
46.29
0.77
1*25
73.97
1.65
1.65
- 10.99
67.95
0.62
11. as
0.83
10.04
0.80
0.87
19.24
14.16
16.11
10.11
1.64
1.61
0.58
0.17
27. 50
25.51
10.67
5. 11
2. 19
0. 17
0.79
2.77
1.O1
1. 17
2.21
2.27
LOWEST TCE
LEVEL
1980-86
-------
EW-3 * - - •
EW-4
EW-S
EW-6
EW-10
PSD-6
PSD-9
PSD- 10
PSD-11A
PSD- 12
PSD-13A
PSD- 1 4A
PSD- 17
PSD- 18
«** Total ***
39
11
36
8
*»•»
.»*»
20
6 -
18
5
IS
18
1
»j
15
S.3S
0.74
12. 33
0.46
0.49
0.35
S3. S3
593. SO
15.80
7.29
2.72
44.00
3.82
0.43
0.00
0.00
0. 00
0.00
0. 00
0.00
15.00
110.00
10.00
0.70
0. 10
44.00
1.70
0.00
9.46
3.00
62.00
1. BO
8.40
1.00
73.00
1500.00
21.00
22.00
12.00
44.00
5. SO
1.00
1347
-------
5.2.2 SCREENING OF TREATMENT TECHNOLOGIES
The National Oil and Hazardous Substances Contingency Plan (NCP)
states that a reasonable number of alternatives must be developed
for remedial action activities. EPA currently considers a range
of treatment levels when evaluating alternatives. In this case
the applicable technologies are all capable of operating through-
out the treatment range. Therefore, the initial screening stages
evaluated various technologies, using cleanup to the State Action
Level or MCL for cost comparison purposes.
The following five methods were considered for treating the
extracted groundwater:
Aeration
Granular Activated Carbon (GAC)
Aeration Combined with Vapor-Phase GAC
Selective Resin Adsorption
Ultraviolet Irradiation/Ozonation
Of these five, two treatment methods were rejected for reasons
discussed below, and three treatment methods became components of
the alternatives developed for detailed 'evaluation (see Section
5.3)
The selective resin adsorption treatment method was eliminated
from consideration on the basis of cost and effectiveness. T.'iis
is a mechanism by which contaminants are removed from water by
adsorption on synthetic resin/ which the water passes over. The
cost of the resin is orders of magnitude greater than the cost
for carbon, which is used in a similar method (GAC), discussed
in detail in Section 5.3.3. Additionally, che disposal of spent
resin is expensive. Spent resin must be transported to and
disposed of in an approved hazardous-waste disposal facility,
at a rate of several dollars per pound. Also, the applicability
of this technique to volatile-organics removal has not been
demonstrated; the process is presently limited to small-scale
treatment of electronic circuit board processing water and
pharmaceutical manufacturing. Because it is an unproven technology,
it was not considered suitable for this operable unit.
The ultraviolet irradiation/ozonation treatment technique was also
rejected due to expense and effectiveness. In this method,
volatile organic compounds in the pumped groundwater are broken
down by ozonation. The efficiency of the process is enhanced by
irradiation of the influent with ultraviolet light. Due to the
corrosive nature of the gas, much of the process hardware must be
ozone resistant, necessitating high capital costs. Like selective
resin adsorption, this technology is unproven for this application.
Ultraviolet irradiation/ozonation is currently in use for disin-
fecting water, but it is not known whether the method is effective
in oxidizing TCE and PCE. Since it would require a lengthy pilot
program, the technique is not appropriate for a Fast-Track action.
-------
5.3 DETAILED ALTERNATIVE EVALUATION
The three alternatives that remained for consideration were
subjected to detailed evaluation. These alternatives are listed
below:
Extraction and Treatment by Aeration
Extraction and Treatment by Granular Activated Carbon
(GAG)
Extraction and Treatment by Aeration Combined with Vapor-
Phase GAC
This section describes each of the alternatives and presents an
evaluation of each on the basis of cost, technical concerns/
public health concerns, and environmental impacts. Because
extraction of the groundwater and conveyance to the treatment
plant is a component of each alternative, and because this com-
ponent constitutes the majority of the expense for each alternative,
the extraction and conveyance plan and costs are presented first.
5.3.1 EXTRACTION AND GROUNDWATER CONVEYANCE
Computer-aided modeling of the hydrogeology of the North Hollywood
area indicated that eight extraction wells would be sufficient to
create a drawdown zone toward which the contaminated groundwater
would flow, thus preventing offsite migration of the plumes. The
modeling used a transraissivity value of 20,000 gpd/ft., based on
an aquifer test performed at North Hollywood Well No. 5, and a
storage coefficient of 0.03, assuming unconfined aquifer .conditions.
Transmissivity and the storage coefficient were assumed to be
constant over the entire well field. The analysis determined the
drawdown zone that would be created after each of the eight
extraction wells was pumped at a rate of 300 gallons per minute
over a period of 180 days. For several sets of conditions and
several arrangements of pumping wells, the model computed the
groundwater flow gradient that would result from the combined
effects of pumping-induced and natural groundwater flow gradients.
The modeling revealed that the exact location of each of the eight
wells was unimportant as long as they are spaced somewhat evenly
across the contaminated area and arranged approximately perpendicular
to regional groundwater flow, which is toward the southeast. An
arrangement was then developed whereby the wells could be situated
within an existing DWP powerline right-of-way.
-------
Costs presented for the wells include drilling and casing, as well
as equipping, each with a submersible pump capable of providing
the necessary lift to transport 250 gallons per minute to the
surface and through the collection pipeline to the point of
treatment. The array of wells will produce a total of 2,000
gallons per minute and the combined system of pumps will lift the
groundwater a total of about 400 feet, including pipe friction
losses.
Once extracted, the groundwater will be conveyed to the treatment
site. On the basis of hydraulic and routing studies, it was
determined that a collection pipeline consisting of approximately
11,000 feet of 12-inch steel pipe constructed through portions of
DWP properties and under dedicated streets would be-adequate.
The costs of building, operating, and maintaining the extraction
and conveyance system are provided below. Also, the present
worth of extraction and conveyance is presented for comparison
with those of the three final alternatives on Table 5-1..
Capital Costs for Extraction and Conveyance
Extraction Wells S 300,000
• Inlet Line 1,091,044
Outlet Line 72,202
Subtotal . . S 1,463,246
Contingencies (20%) 292,649
TOTAL $ 1,755,895
Annualized Capital Cost (15 yr., 10%) $ 230,354
Continued. Operations Costs
Annual
Energy S 151,300
Labor S 5,000
Contingencies (30%) S -0-
TOTAL $ 156,300
Present Worth (15 yr, 10%) $ 1,188,830
Total Cost
Annual $ 387,154
Per 1000 gallons $ 0/368
Present Worth $ 2,944,725
-------
TABLE 5-1
COST SUMMARY OF FINAL ALTERNATIVES
Extraction and Conveyance Only 4
Aeration Alternative2
GAC Alternatives 2, 3
Aeration/GAC Alternative 2, 3
Capital
Cost
($)
1,755,895
-
277,000
493,000
437,000
O&M
Present 1
Worth ($)
1,188,830
419,856
2,745,795
1,095,275
Total
Present 1
Worth ($)
2,944,725
696,856
3,238,795
1,532,275
1 Present Worth calculations are based on 15-Year annualization,
discounted at 10%; all costs are in 1986 dollars. The fifteen
year time period, or the useful life of the facility, was
estimated from a review of literature available primarily for
facilities somewhat larger than this one. Several researchers
report that 20 years may be reasonable and assumed a low
amortization return rate (7.3%). As a compromise, an estimated
life of 15 years was used with a higher amortization rate
(10%) for the proposed facility and the facility present worth
was calculated accordingly.
2 Values given for alternatives are the high-side estimates.
3 Costs for GAC alternatives assume virgin-carbon supply and
disposal-
4 Total
-------
5.3.2 EVALUATION OF TREATMENT ALTERNATIVES
Extraction and Treatment by Aeration
This is a method whereby volatile organic compounds (VOCs) are
removed from groundwater by volatilization at the air-water
interface. The pumped groundwater' is run through a vertical
column containing a packing medium. The medium provides great
surface area over which a countercurrent flow of air is introduced.
The contaminant is transferred from the water to the air and
subsequently removed. The efficiency of the process is dependent
on the nature of the contaminant, its influent concentration, the
rate of air flow, and the available surface area afforded by the
packing material. For TCE and PCE, removal efficiencies can
exceed 99 percent. Aeration is a proven method, commonly used
for treating groundwater.
This alternative has two drawbacks with respect to public health
and the environment. There is the possibility of low-level, long-
term cancer risk due to the release of volatized contaminants
into the air. This release of contaminants also contributes to
air quality degradation.
The following costs correspond to a facility consisting of a
single aeration column shell 12.0 feet in diameter and 48.0 feet
in height, a packing depth of approximately 20.2 feet, column
pad and supporting structure, 15-hp blower and influent pump,
demister, dehumidifier, and related appurtenances. These costs
were developed with the assumption of an extraction flow rate of
2,000 gallons per minute, treatment to State Action Levels (MCL's),
and maximum expected influent TCE and PCS concentrations of 650
and 100 ppb, respectively. For comparison with the other two
alternatives, capital costs and annual continued operations costs
are provided that do not include extraction and conveyance. The
total cost and present worth, however, refer to the entire system,
including extraction, conveyance, and treatment.
11
-------
Low High
Capital Costs
Treatment Plant $
Contingencies
TOTAL
Annual Continued Operation Cost
Power
Chemicals for biofouling
and corrosion
Maintenance
TOTAL
Total Cost (Including Extraction
Annual $
Per 1000 Gallons
116,500 $
10,000
126,500
(Treatment Plant)
8,200
37,000
5,000
50,200
and Conveyance)
453,985 $
0,432
Present Worth (15 yr. , 10%)
(including extraction and conveyance)
$3,453,050 $ 3,
247,000
30,000
277,000
8,200
37,000
10,000
55,200
478,772
0,455
641,581
Extraction and Treatment by Granular Activated Carbon
In this alternative, contaminated groundwater is passed through a
bed of granular activated carbon. Volatile organics are removed
by direct adsorption onto the carbon particles. Removal efficiency
of this treatment method exceeds 99 percent.
The spent carbon generated by this process must be either disposed
of at an approved hazardous-wasie facility or regenerated.
Disposal of spent carbon is the only disadvantage of this alter-
native with respect to public health and the environment;
regeneration of spent carbon would minimize the impact of the
process upaifr public health and the environment.
*$230,854 •»• $156,300 + [($126,500 x .13147 CR* - 10%) - $16,631]
N ' 15%)
* 50,200 - $453,985
**$230,854 + $i56v¥oO +' [($277,000 x .13147) - $36,417] + $55,200
..,..,_ - - --so'.-..-.., ... ' • , $478,772
12
-------
The following costs, correspond to a facility consisting of two
fixed contactors having a combined volume of approximately 3,500
cubic feet/ along with appurtenant electrical, mechanical and
civil elements. Costs for continued operations were developed
for two scenarios: the first assumed the use of virgin carbon
and its disposal, the second involves offsite carbon regeneration.
These. costs were developed with the assumption of an extraction
flow rate of 2,000 gallons per minute, treatment to State Action
Levels and federal maximum contaminant levels. For comparison with
the other two alternatives, capital costs and annual continued
operations costs are provided that do not include extraction and
conveyance. The total cost and present worth, however, refer to
the entire system, including extraction, conveyance, and treatment.
Low _ High
Capital Costs
Treatment Plant $ 305,000 $ 425,000
Pilot Study -0- 10,000
Contingencies 20,000 58,000
TOTAL 325,000 . 493,000
Annual Continued Operation Cost (Treatment Plant)
I virgin Carbon and Disposal
Power "0- -0"
Carbon 178,500 210,000
Disposal 100,000 126,000
Maintenance 5/000 20,000
TOTAL 283,500 356,000
II Regenerated Carbon
Power -0- -0-
Carbon 94,500 94,500
10% Ma*« Op 9,450 9,450
Maintenance 5,000 20,000
TOTAL 108,950 123,950
13
-------
Total Cost (Including Extraction and Conveyance)
Annual $ 713,383* $ 807,971 (I)
Per 1000 Gallons 0.679 0,769
*$230,854
+156,300
+ 42,728 (325,000 x .13147)
+203,500 $ 538,833 $ 575,921 (II)
§713,382 0.513 0.548
Present Worth (15 yr., 10%)
(including extraction and conveyance)
I Virgin Carbon and Disposal
$ 5,426,049 $ 6,145,489
II Regenerated Carbon
$ 4,098,407 $ 4,380,499
Extraction and Treatment by Aeration Combined with Vapor-Phase GAC
This alternative is exactly the same as the aeration alternative,
except that instead of releasing contaminants directly to the
atmosphere, they are removed from the aeration-tower gases by
vapor-phase GAC. The aeration tower gases, comprising mainly
water vapor and contaminant, are dehumidified and then directed to
a gas-phase granular activated carbon unit for final processing.
By this means, the two public health and environmental concerns
related to the aeration alternative are eliminated; the public is
not exposed to possible carcinogens in the atmosphere and air
quality is not degraded.
Because of the use of granular activated carbon, this alternative
involves the disposal of spent carbon, which is a concern with
respect to public health and the environment. As was discussed
above, the impact of the GAC process upon public health and the
environmentwould be minimized by regeneration of spent carbon.
Vapor-phas«f GAC differs from the liquid-phase GAC process evaluated
above in being more efficient. The method, therefore, uses less
carbon and could result in the generation of a smaller volume of
spent carbon.
Removal efficiencies of the aeration treatment method can exceed
99 percent for TCE and PCE. Additionally, the efficiency of the
vapor-phase GAC in removing contaminants from the aeration-tower
gases is greater than 99 percent. The following costs correspond
to a facility identical to that of the aeration alternative with
the single exception that a GAC unit is added to the aeration
14
-------
column off-gas to prevent venting of contaminants to the atmosphere
Costs for'continued operations were developed for two scenarios:
the first aaaumes the use of virgin carbon and its disposal, the
second involves off-site carbon regeneration. These costs were
developed with the assumption of an extraction flow race of 2,000
gallons per minute, treatment to State Action Levels, and federal
Maximum Contaminant Levels. For comparison with the other two
alternatives, capital costs and annual continued operations costs
are provided that do not include extraction and conveyance. The
total cost and present worth, however, refer to the entire system,
including extraction, conveyance, and treatment.
Low High
Capital Costs
Aeration Costs $ 126,500 $ 277,000
Carbon Contactors 100,000 120,000
Pilot Study -0- 10,000
Subtotal 226,500 407,000
Contingencies 10,000 30,000
TOTAL 236,500 437,000
Annual Continued Operation Cost (Treatment Plant)
I Virgin Carbon and Disposal
Carbon 40,000 45,000
Pump Power -0- -0-
Disposal 15,000 21,000
Energy 8/50Q 8,500
Carbon Handling -0- 17,500
Maintenance 5,000 10,000
Chemfcpals 37,000 37,000
TOTAL 105,500 139,000
15
-------
II Regenerated Carbon
Pump Power -0- -Q-
Carbon . 17,000 45,000
Make up Losses 4,500 7,000
Freight 7,000 7,500
Energy - 8,500 8,500
Carbon Handling -0- 17,SQQ
Maintenance 5,000 IO,QOQ
Chemicals 37,000 37,000
TOTAL 79,000 132,500
5 497,248 S 577,108 (II)
0.473 0.549
Total Cost (Including Extraction and Conveyance)
Annual $ 523,748 $ 583,608 (I)
Per 1000 Gallons 0.498 Q.555
Present Worth (15 yr., 10%)
(including extraction and conveyance)
I Virgin Carbon and Disposal
$ 3,983,666 $ 4,438,970
II Regenerated Carbon
$ 3,782,105 $ 4,389,531
16
-------
6.0 COMMUNITY RELATIONS
In December, 1986 EPA and DWP held a community meeting on the
OUFS report. The meeting went well, panel memoers from LADWP and
EPA addressed community questions and several community members
verbally delivered prepared comments. Approximately 15 residents
attended plus a number of agency and media representatives.
A Community Work Group (CWG) was formed that is comprised of
residents, public interest groups, business and elected officials.
The CWG meets regularly on a bimonthly basis to discuss issues
associated with the San Fernando Valley Superfund sites.
7.0 CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) requires that remedies selected meet or
exceed all applicable or relevant and appropriate requirements of
federal and State environmental laws.
The following is a discussion of the requirements that are
applicable or relevant and appropriate to this action and now
they will be met by each remedial alternative.
Safe Drinking Water Act
Waters of the United States as defined in 40 CFR 230,
Subpart E, does not exist in the North Hollywood Burbank Areas.
The applicable Federal environmental statute is the Safe
Drinking Water Act. Under this law, EPA established drinking
water regulations for contaminants through a two-step process.
First/ EPA promulgates health-based levels, termed Maximum
Contaminant Level Goals (MCLG, previously called Recommended
Maximum Contaminant Levels, or RMCL) under the Safe Drinking
Water Act Amendment of 1986. MCLGs are set at levels at which no
adverse public health effects would occur and are set at zero for
known or probable carcinogens, since there is no safe level of
exposure tg* a carcinogen. Because MCLGs are unenforceable health
goals, public water supply systems are not required to meet them
in water they deliver to their customer. EPA then establishes
Maximum Contaminant Levels (MCL) taking into account the availability,
cost and technical feasibility of water treatment technologies
that can be used to reduce the concentrations of the contaminant
in public water supplies. MCLs are enforceable standards that
must be met by public supply systems.
17
-------
The State of California has developed State Action Levels which
in most cases parallel CPA's MCL's and MCLG's. For the contaminants
in question, the following levels apply:
Contaminant MCLG MCL SAL
TCE 0 5 ppb 5 ppb
PCE 0 4 ppb
Section 121(d) of CERCLA, as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), requires that Fund-financed
remedial actions comply with requirements or standards under •
Federal and State environmental laws. The requirements that must
be complied with are those that are applicable or relevant and
appropriate (ARAR) to the contaminants at the site. It has been
determined that the MCL's for TCE and PCS are applicable to this
remedial action. This ARAR is a chemical-specific requirement.
An MCL is an appropriate standard because it is the legally
enforceable standard for drinking water, which is set as close
to che health-based MCLGs as feasible. The MCL of 5 ppo for TCE
and State Action Level (SAL) of 4 ppb for PCE is the appropriate
cleanup level for the San Fernando Valley Ground Water Basin.
The agency believes that MCLs are protective of public health.
As the legally enforceable standards under the Safe Drinking
Water Act/ the MCLs represent the level of water quality that EPA
believes is acceptable for Americans to consume every day from
public drinking water supplies.
All of the final remedies were designed to meet the MCL for TCE
and the State Action Levels for TCE and PCE. This will ensure
that the treatment plant does not cause a violation of any standards
at the tap.
18
-------
Resource Conservation and Recovery Act (RCRA)
This legislation relates to the alternatives only as regards the
disposal of spent carbon, generated by the GAC process, at a RCRA
Class I disposal facility. Spent carbon will be disposed of at
an appropriate facility. Pursuant to CERCLA section 104(C)(3)(B),
the State is required to assure the availability of a hazardous
waste facility. The DWP, in its invitation for bids for the
remedial action, will require respondents to provide adequate
capacity for waste disposal at a facility that meets all applicable
requirements of the Resource Conservation and Recovery Act and
that is consistent with EPA's off-site disposal policy. A RCRA
compliance inspection shall be completed by EPA or the State for
the waste facility within six (6) months prior to "the receipt of
the designated wastes from the site. The EPA Regional office in
which the facility is located will review the results of the
compliance inspection and other available information to determine
if the facility meets the criteria set forth by EPA.
Clean Air Act
In California, the authority for enforcing the standards established
under the Clean Air Act has been delegated to the State. The
program is administered by the South Coast Air Quality Management
District (SCAQMD) in Los Angeles. DWP worked with the SCAQMD
to develop alternatives that would comply with their regulations.
The uncontrolled aeration facility alternative was found not to
pose a significant health risk by the SCAQMD. However, due to
overwhelming citizen concern over release of any additional air
pollutants into the South Coast Air Basin , the recommended remedy
includes air pollution control on the off-gases from the aeration
facility.
The carbon air filtering units will provide additional protection
of human health and the environment by reducing TCE and PCE air
emissions. Given the concentrations of contaminants in the ground
water, it is estimated that 16'lbs/day of TCE and 2.5 Ibs/day of
PCE would be emitted into the air without carbon air filtering
units. With the addition of carbon air filtering units, it is
estimated tftfct there will be 100 percent capture of the
contaminant*^ in the vapor phase. DWP's permit with SCAQMD requires
a 90 percent, removal efficiency for air emissions.
This technology is consistent with EPA's Office of Air Toxics
policy of requiring carbon adsorption emission controls on all
aeration facilities. This technology is also supported by SARA
which expresses a preference for treatment that significantly and
permanently reduces the volume, toxicity, or mobility of the waste
to the maximum extent possible.
19
-------
8.0 RECOMMENDED ALTERNATIVE
SARA, in addition to Section 300.68(1) of the National Contingency
Plan (40 CFR Part 300), defines the appropriate extent of remedial
action. Remedies must be protective of human health and the
environment. Remedies that actain or exceed applicable or relevant
and appropriate requirements (ARARs) are protective. The selected
remedy must also be cost-effective; that is, it must confer a
level of protection that cannot be achieved by less costly
alternatives. SARA expresses a preference for treatment that
permanently and significantly reduces volume, toxicity or mobility
to the maximum extent practicable.
EPA has determined that the cost-effective interim remedy is
extraction and treatment by aeration combined with vapor-phase
carbon adsorption. All three alternatives that were considered
are capable of attaining the ARARs (MCL and State Action Levels)
and protect human health. All three alternatives are technically
implementable and currently available for installation. The
long-term risk is highest for the aeration only facility. This
plus overwhelming public concern over air emissions caused EPA
to select the aeration with carbon adsorption on the off-gas
alternative. This alternative, although more costly than aeration
by approximately $835,419 (see Table 3.1), provides an additional
level of protection that is not achieved by the aeration only
alternative. The remedy reduces the mobility of the contaminants
in that air contaminants are adsorbed by the carbon filter.
As discussed in Section 7.0 above, the recommended cleanup level
is the MCL for TCE and the State Action Level for PCE. These
levels were selected because they are attainable, and they provide
a level of protection of public health which is equivalent to
that required in all. public drinking water systems.
•
Once the remedy is operational, it is estimated that 3200
acre/feet/year of groundwater will be treated and consumed.
The value oit-the treated water is estimated to be $300,000/year.
20
-------
-TABLE 8.1
COST SUMMARY OF FINAL ALTERNATIVES
Capitol Continued Operations
Cost (S) Present Worth ($)
Total
Present Worth (s
Aeration Alternative
2,032,895
1,608,686
3,641,581
GAC Alternative
2,248,895
3,934,625
6,183,520
Aeration/GAC
Alternative
2,192,895
2,284,105
4,477,000
9.0
CONTINUED OPERATIONS
The proposed groundwater treatment facility, will be under
automatic operation 24 hours a day. Contingencies, such as
blower failure or excessive aeration column head loss have been
provided for in the project design. Groundwater extraction pumps
will automatically shut down if the aeration column floods or if
there is" a sudden loss of pressure in the collector line due to
a leak or break. Maintenance of the facility will consist of
scheduled checks of the aeration column and chlorine and sodium
hexametaphosphate injection equipment, which will include periodic
maintenance of all moving equipment and parts on an as-needed
basis. The granular activated carbon emissions control contactors
should require only minimal maintenance; however, the air emissions
from the contactors will be monitored on a regular basis to
ensure that aeration contaminants are not emitted to the atmosphere.
The aeration facility will be constructed by the DWP under a
cooperative agrement with EPA. Before entering into the cooper-
ative agreement, EPA will ensure that a 3-party agreement between
EPA, the California Department of Health Services (DBS), and DWP
is signed which delineates each agency's role. As required by
CERCLA/SARA^. DBS will assure 10% of the construction funds and
10% of the Continued operations costs. Although the State is
responsible for the cost share for continued operations, the
political subdivision, DWP, agrees to provide the 10% DBS cost
share. DWP and the State must assure full responsibility for
operations and maintenance.
21
-------
EPA will share 90% of the construction and continued operations
costs until the final remedial action for Area 1 is selected.
After that/ the extent of any future EPA participation will be
determined.
10.0 SCHEDULE
Approval of ROD
Amend Cooperative Agreement for
Design and Construction
Complete Design
Start Construction
Complete Construction
August 31, 1987
August 6, 1987
August 1987
August 1987
December 30, 1987
11.0 FUTURE ACTIONS
The overall Remedial Investigation for the entire area is expected
to begin in August 1987, and will take approximately 2 years to
complete. There may be additional operable units in the other
three areas before the final remedial action is determined.
22
-------
RESPONSIVENESS SUMMARY
FOR
THE NOVEMBER 1986 OPERABLE UNIT FEASIBILITY STUDY
AT THE
SAN FERNANDO VALLEY BASIN SUPERFUND SITE
SEPTEMBER 1987
-------
SAN FERNANDO VALLEY BASIN SITE
RESPONSIVENESS SUMMARY
FOR THE
OPERABLE UNIT FEASIBILITY STUDY
SUMMARY OF MAJOR COMMENTS AND RESPONSES
INTRODUCTION
From November 20 through December 22, 1986, the Los Angeles Department of
Water and Power (DVP) and Che U.S. Environmental Protection Agency (EPA) held
a public comment period on DUP's Operable Unit Feasibility Study regarding a
proposed ground water extraction and treatment facility for the North
Hollywood-Burbank Well Field of the San Fernando Valley Basin (SFVB) in Los
Angeles County, California. In 1980, trichloroethylene (TCE) and
tetrachloroethylene (PCE) were discovered in one quarter of DWP's wells in the
San Fernando Valley Groundwater Basin. DWP began a program to control the
spread of contamination in 1983, which involved pumping and blending of the
contaminated ground water with surface water supplies. The purpose of the
public comment period was to give interested parties the opportunity to review
and comment on the report and allow the agencies to respond to community
concerns.
The North Hollywood-Burbank Well Field has been designated as one of four
federal National Priorities List-(NFL) sites in the San Fernando Valley. The
San Fernando Valley Groundwater Basin comprises 112,000 acres of land situate'
among the Coastal Ranges within -he Los Angeles metropolitan area. DWP,
Burbank, and Glendale draw water from the North Hollywood-Burbank Well Field
to provide drinking water to residents of those cities.
In March 1986, an "advance match" cooperative agreement was signed between EPA
and DWP; subsequently DWP began preparation of an Operable Unit Feasibility
Study (OUFS). The "Operable Unit* is a short-cero action intended to halt
the spread of contamination and reduce its impact on the surrounding community
until a permanent remedy is implemented.
This responsiveness summary is required under EPA policy for the purpose of
providing both EPA and the interested public with a review and summary of
community concerns regarding site issues, and a statement of agency responses
to those concerns. The responsiveness summary is divided into three sections:
I. Background on Community Involvement and Concerns. This section provides
a brftf history of community concerns about site problems and the
proposed project.
II. Overview of the Operable Unic Feasibility Seudv. This section lists and
describes proposed remedial alternatives presented in the draft OUFS, and
identifies EPA's preferred alternative.
-------
III. Svmiry ?f Comments Received and PUP and EPA Responses. This section
categorizes and summarizes written and oral comments received during che
public comment period and provides EPA's and DWP's responses to these
Appendix A contains copies of all written comments on the OUFS received by EPA
and LADWP during the public comment period.
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
In 1981, planning grants were obtained by OVP under Section 208 of the Clean
Vater Act to study the ground-water contamination problem in the San Fernando
Valley. To conduct the study, a Technical Advisory Committee and a Citizen's
Advisory Committee (CAC) were formed to involve local agencies and community
groups. The CAC was composed of representatives from local governments,
public interest groups, business groups, and private citizens. The
recommendations of these committees were incorporated inco the Ground-water
Quality Management Plan - San Fernando Vallev (referred to as the Ground-water
Plan) . In addition to technical recommendations, this report included a plan
for public education and participation in ground-water cleanup programs. The
CAC recommended programs to educate che public on household waste disposal and
hazardous waste management issues including waste disposal, transport, and the
siting of disposal or transfer facilities. CAC members also kept their
respective organizations informed about the progress of che Ground-water Plan
study.
When the CAC was dissolved at che end of the cwo-year study, che Interagency
Coordinating Committee (ICC) was formed to implement recommendations from the
Ground-water Plan. The ICC conduces public information activities through che
Small Quantity Generator/Hazardous Waste Disposal Program and the Public
Education Program. The former program conducted surveys of businesses in the
North Hollywood area regarding waste disposal practices. Through the surveys,
participants became aware of the ground-water contamination problem. The
latter program's goal is to foster community awareness about the importance of
responsible hazardous waste management, treatment alternatives, transportation
safety, siting reliable waste facilities, and preventing new areas of
contamination.
In 1987, EPA and DVP started meeting on a regular basis with a Community Work
Group (CUC) comprised of representatives from involved agencies, elected
official*-, community groups, and environmental organizations. The CWG
meeting* -provide a forum for EPA and OWP to inform che community about current
cite activities and receive feedback and opinions on issues and proposed
activities. Members of the CVG will review site -related documents and reports
and will provide EPA and OWP with comments on technical actions taken at the
site.
-------
II. QVKkVIgg OF THE OPERAJ^E P^TT FEASIBILITY STUDY
The Operable Unit Feasibility Study (OUFS) for the North Hollywood/Burbank
area was conducted by EPA and DWP co identify and evaluate various
alternatives for halting the spread of contamination plumes in the ground
water until a final cleanup remedy is developed. The following three remedial
alternatives were identified for screening in the draft OUFS:
1. Extraction and Treatment by 'Aeration is a method whereby volatile
organic compounds (VOCs) are removed from the ground water by
volatilization at the air-water interface. The pumped ground water is
run through a vertical column containing a packing medium. The medium
provides great surface area over which a countercurrent flow of air is
introduced. The contaminants are transferred from the water to the air
and subsequently removed.
2. Extraction and Treatment by Granular Activated Carbon is a method
whereby contaminated ground water is passed through a bed of granular
activated carbon. VOCs are removed by direct adsorption onto the carbon
particles.
3. Extraction and Treatment bv Aeration Combined with Vapor-Phase
Granular Activated Carbon (GAC1 is exactly the same as the aeration
alternative, except chat instead of releasing contaminants directly to
the ataosphera, they are removed from the aeration-tower gases by vapor-
phase GAC.
EPA received comments and questions on each of the proposed alternatives, as
well as on other aspects of the OUFS. These questions and comments are
summarized in Section III.
III. SUMMARY OF COMMENTS RECEIVED AND DWP AND SPA RESPONSES
For purposes of simplification, EPA has categorized the comments'(and
responses to those comments) as follows:
1. Comments from members of the interested public; and
2. Comments from State agencies.
Each of these categories is further divided into the following subcategories:
1. Policy Issues;
2. Cose Issues;
3. Technical Issues;
4. Remedial Alternative Preference;
5. Process Issues;
6. Health Issues; and
7. Miscellaneous Issues.
-------
III.l - COMMENTS MADE BY INTERESTED COMMUNITY MEMBERS
The bulk of Che comments regarding the Operable Unit Feasibility Study (OUFS)
were received from members of the community. Many of chese comments expressed
concerns about the emissions from the proposed aeration tower. Specific
comments and questions are summarized below.
A. Policy Issues:
1. One community member asked why the aeration tower would be allowed
to emit 2 pounds rather than 20 pounds of contaminants per day.
DVP response:
The aeration tower is designed to remove approximately 20 pounds of
volatile organic compounds per day. However, the South Coast Air
Quality Management District (SCAQMD) air emissions permit requires
that at least 90% (or 18 pounds) of these emissions be captured by
the activated carbon filters rather than be released into the air.
2. Several commenters (Citizens for a Better Environment and Citizens
for Safe Drinking Water) stated that blending of contaminated ground
water with water from other sources should not be used.to reduce
contaminant levels to Maximum Contaminant Levels (MCLs). Levels of
trichloroethylene (TCE) and perchloroechylene (PCE) should be
reduced to the MCLs without blending.
DVP response:
EPA's Record of Decision clarifies that contaminated ground water
will be treated in the aeration tower so that levels of
contamination do not exceed the Maximum Contaminant Level of 5 parts
per billion (ppb) for TCE and the State Action Level of 4 ppb for
PCE. Treated ground water will then be blended with other water
before distribution. Adequate contingencies will be included in the
design of the facility to ensure that these standards will be met.
However, should the facility be unable to treat to these levels,
then either Che operation of the facility will be modified until the
standards are achieved, or the water will not be served. Blending
of treated ground water will not be used as a method of attaining
. the standards.
At the time the May 1986 OUFS draft was prepared, neither treatment
to maximum contaminant level (MCL) nor air emissions control (vapor-
phase GAG) was considered a requirement for EPA funding.
Subsequent to a review of the draft, EPA indicated chat these
concerns would have to be considered if EPA was to fund the project
at all.
-------
- Consequentlyi the original aeration facility design was
extensively reviewed by OVP, its design consultant, and by
EPA's consultant with regard to expected treatment efficiency.
The consensus was chat Che existing design could meec che MCL
requirement given minor modifications (notably, increasing che
depth of packing media). In spite of this consensus, however,
it is meaningless to discuss packed'tower efficiencies beyond
two significant figures; the technology is not that well known.
Should che proposed facility not provide treatment down co MCL
for all observed contaminants, then operational parameters must
be adjusted to provide such treatment or EPA will order the
facility to be shut down. Blending of created ground waters
will not be used as a method of attaining the MCL criterion.
3. The representatives of Citizens for a Better Environment (CBE) and
the Federation of Hillside and Canyon Associations (FHCA) stated
that EPA has set Che Recommended MCL (RMCL) for che chemical TCE at
zero. Therefore, any remedial action proposal should use che RMCL
as its cleanup objective, rather than the MCL.
OVP response:
The Superfund Amendments and Reauchorization Act indicates chat the
Maximum Contaminant Level Goals (MCLGs), formerly RMCLs, should be
considered when determining applicable and relevant or appropriatr
standards for Superfund cleanups. However, in che situation vher<
treated water will be used for drinking, EPA has determined chat cne
applicable standard is the MCL. The MCL is the legally enforceable
standard for drinking water which is set as close to che
health-based MCLG as feasible. EPA believes that the MCLs are
protective of human health and che environment and are, therefore,
the appropriate standards.
4. Citizens for Safe Drinking Water (CSDW) stated chat the communicy
needs an assurance from che government chat the ground water will be
treated to MCLs written into the OUFS.
DWP response:
EPA's decision document, che Record of Decision, assures that
-(round water will be treated co che MCL of 5 ppb for TCE and che
^State action level of 4 ppb for PCS. This is the appropriate
document in which to make the assurance rather than the OUFS report,
which presents a range of options for public consideration. In
addition, one* the facility is constructed, an operation and
maintenance plan will be developed that will ensure that the
facility is properly operated to attain the standards.
-------
5. - CSOtf seated that its fundamental goal for the OUFS is than
protection of public health be the primary consideration in
selecting the remedial action. CSDW believes that the water leaving
che aeration tower oust be cleaned co che maximum possible extent --
that 99 - 99.9 percent of the contaminants be removed -- and that
Che remedial action must not result in cross-media contamination.
OVP response:
EPA's standards for protection of public health are established
under the Safe Drinking Vater Act as the MCLs. The levels are set at
a concentration that is protective of public health rather Chan as a
percent removal so that, regardless of the degree of contamination,
che MCL muse be achieved. Cross-media contamination (the transfer
of contaminants from the ground water to the air) will be minimized
by the use of activated carbon filters on the off-gases from the
aeration facility.
6. CBE commented that EPA should specify that the new aeration tower
operate at maximum efficiency regardless of volatile organic
contaminant (VOC) throughput concentration.
DWP response:
As stated in the response to comment #5, EPA's standard for
protection of public health is che MCL. The aeration facility is
designed to achieve che MCL rather than a percentage of reduceion of
the contamination.
7. One community member commented chat che EPA failed to conduct a
comprehensive evaluation of either the site or alternative remedial
actions for addressing contamination at the site, as required by
Superfund regulations. Specifically, concern was expressed over the
adequacy of DUT's evaluation of current air quality and the health
risks posed by the site.
DWP response:
An air quality/health risk assessment was conducted by a consultant
for the DWP for the aeration-only alternative. On che basis of
_chis study, the Department of Health Services and the South Coast
~*lr Quality Management District approved che project. In addition,
another DVP consultant conducted ambient air quality studies at
and near the project site; these studies indicated that background
(existing) TCE/PCE concentrations in air would not increase
significantly due to an aeration-only facility. Since GAC air
emissions control has been added to the design, however, the impact
of the project on air quality will be negligible. Therefore, a
detailed air quality/public health assessment of che recommended
project was omitted. (See Appendix 9 in Che OUFS report.)
-------
Additionally, EPA considers Che OUFS as a comprehensive evaluation.
fhm primary concern of the Superfund program is the health risk
* posed by air and water releases from the site. If background le-
•f contaminants are high enough to be of concern, EPA may also
consider background levels when conducting risk assessments. In
conducting this OUFS, EPA has determined that the health impacts oc
implementing the three alternatives fall within an acceptable range.
8. A community member stated that EPA should review the adequacy of the
data used by OVP in the risk assessment.
OVP response:
Risk assessment information presented in the OUFS report was
reviewed and approved by EPA.
9. A member of FHCA noted that Section VI, page 117 mentioned that
•preliminary design can be modified to eliminate contaminant air
emissions while achieving treatment efficiencies down to MCL." The
member believes that the use of such cerms as "can be modified" and
•can be tailored* is not sufficiently precise.
DWP response:
The purpose of che OUFS report is to evaluate che relative merits of
several remedial alternatives and co recommend a preferred
alternative. Design parameters will be specified in the remedial
design phase of this project, and operational parameters will be
defined in the operation and maintenance (O&M) plan for che site.
As described in the report, a safety factor is implied in the
facility design. Should the plant capability be exceeded (that is,
if unexpectedly high contaminant concentrations are encountered),
the air-to-water ratio can be increased or selective pumping of the
extraction wells can be implemented as corrective actions. The
addition of the GAC contactors will enhance facility performance.
10. CBE stated that no cumulative impact analysis was performed for the
aeration-only alternative. Without this cumulative analysis, the
conclusions drawn about the health effects of the aeration tower, or
comparisons with other alternatives, are incomplete.
DWP response:
~A cumulative aeration-only health impact analysis is presented in
Appendix 9 of the OUFS report.
In conducting public health evaluations, EPA considers the
cumulative risks from different pathways of exposure, using
appropriate indicator chemicals.
-------
11. CBE seated chat che OUFS should not be limited Co reporting or
discussing only those veils that are contaminated above MCLs.
. Rather, CBE believes the report should provide all the information
collected on ground-water contamination.
OVP response:
The overall Remedial Investigation will provide comprehensive
information on ground-water contamination in the four NPL areas.
12. CBE stated that EPA should make clear its position on blending.
This project is required to meet Superfund standards of employing a
permanent cleanup strategy, which do not include blending.
DVP response:
Under the Safe Drinking Water Act, blending of contaminated
ground water with other sources of water is an acceptable method by
which to attain the standards (MCLs). The goal of the Superfund
program is to comply with applicable or relevant and appropriate
requirements under other environmental statutes. Thus, in some
instances blending may be appropriate. However, for the North
Hollywood aeration facility, EPA has determined that blending will
not be used to attain MCLs. The aeration facility will treat
contaminated ground water to the MCL before the water is introduced
into the distribution system.
13. CBE believes that the statement on page 75. third paragraph, "the
magnitude of the environmental impact of landfilling spent carbon is
probably similar to the magnitude of the health risk from aeration,"
is an insupportable statement and should be eliminated.
OVP response:
Comment acknowledged; an addendum will be added to the OUFS report
to so indicate.
16. CBE stated that the speculation as to what could happen to spent
carbon, on page 76, third paragraph, is inappropriate. It should be
either rigorously supported or deleted.
OVP response:
snt acknowledged; an addendum will be added to the OUFS report
Co so indicate.
IS. CBE asked why hypothetical cost estimates were used for the remedial
alternatives, when actual cost estimates were available. Both FHCA
and CSDV commented that the initial study of the proposed aeration
-------
facility planned co creac between 1,000 and 2,000 gallons per minuce
(fpa). Section II of the OUFS confirmed the 2,000 gpm figure. The
. mailing discussion of costs, however, appears to be based on the
1,000 gpa rate; these groups questioned whether this figure is an
•rror.
DVP response:
Several literature sources provided data for 1,000 gallons per
•inute (gpa) facilities or prototypes. Rather than try to scale
this data up to a 2,000 gpa plant, the preliminary cost estimates
were based on the literature as given for initial comparison
purposes only. This is explained on page 78 of the report. Actual
literature cost data for a 2,000-gpm facility was not available.
16. CBE questioned the last sentence of the second paragraph on page
103, which reads "Implementation of any of the three alternatives
would ultimately attain and exceed the applicable health
standards...." CBE believes that the word "ultimately" is "vague
and confusing," implying that the health standards will be met after
treatment with the use of blending as originally proposed. CBE
suggested that the report state that health standards will be met at
the time of treatment, and chat the vague language in question be
eliminated.
DWP response:
Comment acknowledged. At no time was blending considered as a
viable means of achieving treatment co MCL for the proposed
facility. All three alternatives will attain MCLs after
treatment.
17. CBE believes 'that the discussion of health risks on page 109, second
paragraph, should reference the August 21, 1986 public hearing
report by Eugene Calafato of the SCAQMD. The report concluded that
a cumulative effects assessment should have been done for the
aeration-only alternative. Without this evaluation, the commencer
believes it is premature to say that this project could be
considered safe.
DWP response:
nt acknowledged; August 21, 1986 SCAQMD meeting referenced.
reaedy selected will provide an added measure of protection with
the carbon air filtering units.
B. Cose
18. One community member asked why the DVP representative at the
December 9, 1986 public hearing on the OUFS used the highest cost
estimates in his talk, rather than the ranges discussed in the OUFS
in Appendix 10.
-------
DWP response:
Th« highest reasonable cost estimates were used in order Co provide
* conservative estimate of total project costs. In all probability,
th« actual costs of the ground water treatment facility will not be
that high.
19. One commenter asked whether EPA has made a final decision about
which extraction alternative will be used, and whether this is the
alternative upon which the cost estimates were based.
DWP response:
The extraction alternative discussed at the hearing is the one which
has been chosen as the system to be used in conjunction with the
ground water treatment facility. EPA has reviewed this alternative
and believes it will most effectively halt plume migration.
20. One commenter asked for information regarding the costs of disposal
of spent carbon.
OVP response:
The cost is included in the OUFS report. The carbon costs are
greater for water treatment than for air treatment. The reason is
that the stream of contaminants is less concentrated for the air
system, requiring less carbon to remove the same amount of
contaminants. There is physically more carbon in the water system-,
so the costs are higher for chat alternative. The annual disposal
cost for carbon ranges from $283,500 to $356,000 if the carbon is
not regenerated. If the carbon is regenerated, the annual dispoal
costs range from $108,950 to $123,950.
21. CBE believes that the cost comparison for the three alternatives is
inadequate. The analysis focuses only on the highest cost estimate
for each alternative, instead of on the range of estimates as
presented in Appendix 10.
DUP response:
Any objective method of comparing treatment alternative costs (range
averaging, etc.) would have resulted in the same cost ranking for
each alternative. The OUFS laid out the range of costs, and EPA
:- considered the range in making its decision.
22. CBE noted that only the highest estimated project costs were
presented in the executive summary. CBE believes that the range of
costs should be presented.
DWP response:
The Executive Summary provides a synopsis of the overall OUFS
10
-------
report. The highest costs were used to provide a general indication
o£ overall differences in the cost of various alternatives.
- Individuals interested in more detailed cost estimates should ref
to. the body of the OUFS report. EPA prefers that the highest
reasonable cost estimates be reported in order to provide a
conservative estimate of total project costs. In all probability,
the actual costs of the ground water creatment facility will not be
that high.
23. CBE noted that the cost-effectiveness discussion in the OUFS only
considers che cost of replacing wells chat might have to be replaced
because of future contamination. CBE believes that the cost of the
"no action" alternative should reflect the costs of replacing the
entire ground water supply, which is approximately $20 million.
DWP response:
Comment acknowledged; refer to page 32 of the OUFS report.
24. CBE noted that che OUFS inconsistently uses high or average coses
for the various alternatives. CBE believes che report should
consistently use one set of costs to avoid misleading che readers.
Additionally, CBE stated chat che summary data for Che alternative
treatment costs should be presented as a range of costs per 1,000
gallons, and chat che OUFS should include a discussion on che
variability found in the granulated activated carbon (GAC) cost
estimates.
DWP response: . • -
The purpose of the cost analysis was to develop the probable range
of costs for each alternative and to rank the alternatives
accordingly. As mentioned in the response to comment *21, chis
ranking would not change regardless of how the costs were presented
(range, average, etc.). In fact, probable or potential coses are
not even considered in che Technical Evaluation (section V), nor
are costs discussed in che Summary of Recommended Remedial
Alternatives (Section VIII). A previous draft of the document did
in fact report one set of costs. Cost ranges were added in
accordance with a request from the EPA. The reported cost
variability of virgin activated carbon (18 percent) is not excessive
and does not contribute substantially to che high-end cost of the
GfcC alternative. Therefore, a detailed discussion was not
developed.
C. Technical Issues
- -'. L; >- ' • ^3 "
25. One commencer asked the direction and the rate of movement of the
^ .-re:v contaminant plumes.
11
-------
DVP response:
The plunes in the North Hollywood area are moving in « southeasterly
direction at a rate of 300-500 feet per year. At this race, OVP
expects that approximately two ground water wells per year will
become contaminated, even if action is taken.
26. On* coomenter asked whether EPA has considered using a treatment
•ethod that would remove trihalomethane (THM) precursors as well as
VOCs.
OVP response:
THM precursors are typically organic substances such as decaying
plant matter. THMs result from disinfection processes that
chlorinate these materials. For the ground waters in the study
area, and ground waters in general, THM precursors (and THMs) are
practically nonexistent. Therefore, these chemicals were not
considered in the development of treatment alternatives.
27. One commenter asked which contaminants would not be removed
effectively by the several treatment alternatives described
(aeration, GAC, and ozonation).
DWP response:
Approximately 12 organic contaminants were found in the ground
water, but only TCE and PCE were present in significant
concentrations. TCE is the chemical used as the "indicator
chemical" for the aeration alternative because it is the most
widespread contaminant. For the ultraviolet (UV) ozone treatment
alternative, there is a class of high molecular weight compounds
that are almost completely unaffected by any combination of UV light
and ozonation. Long-chain alkanes (e.g., gasoline) and long-chain
alphatic compounds are examples of this class of compounds.
28. One commenter asked EPA to clarify the difference between the
alternative proposed in the final OUFS and the previous
recommendation.
DWP response:
The project is essentially the same with regard to the design of the
facility, the size, and the environmental effects. Since £?A has
required the Department to meet MCLs, blending has been eliminated
as a method of obtaining MCLs at the tower. The remedy will meet
MCLs without blending.
29. One commenter asked what the rate of water treatment would be.
12
-------
OVP response:
- Tha project Is designed to pump 2,000 gpm through the aeration
facility. The quantity of water is not the significant factor in
the facility, however. The primary objective of the facility is
that the process draws the contaminated plumes away from che
uncontaainated wells and prevents the contamination of other wells
in the area. A side benefit is that the water will be treated and
returned to the distribution system.
30. One commenter asked how long the aeration process would be
necessary.
OVP response:
There is much uncertainty involved in this projection. The Agency
anticipates that the tower may be operating for as many as 15 years.
It took 40 or 50 years for the contamination to become this severe,
and cleanup may take even longer.
31. Several commenters noted chat the earlier model of the GAC vapor
phase was permitted at 90 percent removal efficiency -- that is, it
can emit 2 pounds per day. The commenters asked whether the current
proposal would be permitted at 99 percent removal efficiency.
DVP response:
At the first two public meetings, aeration was che only creacmenc
method discussed. Between che second and third meetings, however,
the DVP Board of Commissioners decided to add che GAC filter on che
airstrean. By adding che GAC filter, che permitted emissions were
reduced to a maximum of 2 pounds per day, which is che amount in che
current SCAQHD permit-. The SCAQMD has permitted the removal
efficiency of che GAC system at a minimum of 90 percent. The
facility will be monitored to ensure that chis removal efficiency or
better is achieved.
The agencies' primary goal is to meet the HCL objective of 5 ppb,
although the design of the aeration tower itself may allow operation
at higher efficiencies. DVP can do that by operating at higher
efficiencies or by controlling the contaminant level chat comes into
the aeration tower. The cower will be operated as efficiently as
^possible.
32. One commenter asked what became of the spent, contaminated carbon
from the GAC process.
OVP response:
The spent carbon can either be disposed at an approved hazardous
waste facility or can be reactivated off-site.
13
-------
33. CSDW expressed concern that, although the OUFS states that MCLs will
be met, there is no change in the facility design to ensure those
levels in the final OUFS.
DVP response:
The design of the facility was changed by adding two feet of packing
material as an additional safety factor to ensure that the MCL will
be attained. -In addition, the operation and maintenance plan for
the facility will specify changes to operational parameters that
will allow the facility to-attain MCLs at all times.
34. CSDU asked how often the tower would be monitored to ensure the
water has been cleaned to MCLs.
DWP response:
Although the monitoring schedule for the facility has not been
completed, it will consist of periodic sampling of plant
influent/effluent contaminant concentrations, air emissions, and
activated carbon. The frequency of this sampling will be detailed
in the Facility Operation and Maintenance Plan now being
developed.
35. CSDW noted that DWP expects the.tower to treat water with
contamination of 200 ppb, although some samples have been caken chat
indicate contaminant levels of 650 ppb. CSDW believes that DWP
should plan for a facility that can creat the more highly
contaminated water to ensure that MCLs are obtained.
DWP response:
The aeration facility is designed to treat ground water from
contaminant levels of 650 ppb to or below MCLs.
36. CSDW and FHCA noted that the top soil under the tower would be very
corrosive to steel, and asked whether this would adversely affect
the aeration cower. The commenter also asked whether DWP had
identified the "wet, sticky, honey-colored substance" that was
contaminating the top soil at the site of the proposed tower.
DWP response:
_Th« top eight feet of soil will be removed prior to construction of
Che aeration facility and replaced with compacted fill. The
remaining soil will have no adverse effect on the aeration tower,
sine* A concrete pad will separate all facility components from the
soil.
The "wet, sticky, honey-colored substance" was analyzed for TCE and
PCE and found to contain neither. If necessary, additional soil
analyses will be conducted.
14
-------
37. CSDW asked whether drilling aore aonitoring wells on che site would
present any probleas with further contamination of ground water d\-~
to excessive drilling.
OOP response:
Hydrogeology will be assessed and studied prior to well installation
to ensure that construction of the extraction system will not act as
a conduit for contamination of the lower ground-water aquifer.
38. One community member asked DWP to continue considering the use of
ozone treatment in future cleanup efforts.
DVF response:
Presently, DWP is working in conjunction with the University of
California at Los Angeles in examining the UV/ozone and
peroxide/ozone technologies as treatment processes. DWP will
continue to evaluate treatment alternatives in order to identify
reliable and efficient methods of treatment.
39. A member of the Sierra Club asked whether DWP had considered
constructing two towers on an experimental basis: one using
activated charcoal in the aeration phase and the other using the
activated charcoal in the water phase. If not, the commenter asked
whether DWP would consider doing so at some cime during the projecc
in order to gain direct experience with these alternative methods.
DWP response:
This type of investigation was not considered, in part, because it
would be costly and constitutes a research activity rather than a
remedial activity. However, Task 5 of the Remedial Investigation
may involve studies of this kind at a bench-scale or treatability
level. Both technologies have been demonstrated to be effective at
removal of contaminants.
40. CSDW asked whether the aeration tower would be able to operate at 99
percent removal capability if contaminant levels exceed the level of
500 ppb that is anticipated.
DWP response:
The facility will be operated to attain MCLs regardless of the
Influent concentration.
41. CSDW noted that the OUTS does not specify the removal efficiency of
the carbon filter. CSDW believes that che carbon filtration system
^ must be designed jto remove the maximum amount of contamination, and
^ that .this desfgn "objective must be specifically stated in the OUFS.
IS
-------
DWP response:
The operational efficiency of the activated carbon air filters is
theoretically 100 percent providing that contaminant breakthrough is
not imminent. Adsorption data provided by several carbon suppliers,
combined with the results of published pilot plant studies, indicate
that the amount of contaminant escaping the proposed facility via
air will be at or about non-detectable levels. However, there is
insufficient evidence to justify a guarantee of 100 percent removal.
The maximum permitted emissions from the SCAQMD is 2 pounds per day.
Although the technology is reliable, the SCAQMD generally specified
removal efficiencies for permitted facilities (notably dry-cleaning
operations) at below 100 percent as a contingency for this
uncertainty. This is an established limit of the technology.
42. One commenter believes that DWP did not perform an adequate
evaluation of other treatment alternatives. Specifically, community
members requested that DWP investigate the possibility of carbon
filtration at the wellhead, which would not result in further
degradation of the air quality at the site.
DWP response:
Wellhead treatment by any applicable technology was not considered
as an option because it is more cost-effective to construct a single
facility to treat multiple supply sources. OW? recognizes,
however, the potential usefulness of this method for a limited
number of wells, and is currently investigating the use of wellhead
carbon treatment at its Headvorks veil field. This alternative viii
be considered in the overall Remedial Investigation and Feasibility
Study. For the OUFS, our goal is to contain and retract the plume.
Wellhead treatment would not achieve this goal.
43. FHCA asked whether the design specifications for the tower of a
2,000 gallon per minute treatment rate would allow sufficient
contact between the charcoal and water for adequate contaminant
removal.
DWP response:
The aeration facility has been designed to meet required MCLs. The
contact time between the ground water and packing media (not
charcoal) has been considered in the design and determined adequate.
44. CBE asked that the word "maintain" be defined in the sentence in the
OUFS, page 25, second paragraph, which reads "...DWP implemented a
program of blending to maintain the ground water supply as much as
possible."
DWP response:
Unlike the cities of Burbank and Glendale, which were forced to shut
16
-------
down numerous wells and purchase replacement water supplies, OVP
implemented a program of blending, approved by the California
~ Department of Health Services, in order to "maintain" previous
ierels of water supply and avoid increased purchases of Metropolitan
Water District supplies. "Maintain* refers to the fact that DV? was
able to obtain the same volume of water from the aquifer, rather
than using other sources of water.
45. CBE asked for the meaning of the phrase, "value of ground water and
how it is being eroded* on page 25, second paragraph, of the OUFS.
DVF response:
During a normal year, DVF extracts an average of 102,000 acre-
feet of groundwater which it serves to approximately one million
customers, making this ground water a valuable resource both
economically and for human consumption. If the spread of
contamination cannot be controlled, then the value of the ground-
water resource is significantly diminished.
46. CBE believes that the opening statement on page 40 of the OUFS,
referring to the "problems associated with the previous methods," is
vague and should be eliminated or clarified with specific examples.
DVP response:
"Previous methods" refers to extraction, blending, and disposal.
The problems associated with extraction, blending and disposal are
discussed explicitly and with examples on pages 35-39. The OUFS
report addendum will clarify this statement further.
47. CBE stated that the last sentence of the first paragraph on page 50
of the OUFS, describing an assumption about the future use of
blending, is an unsupported comment and should be removed.
DWP response:
Under the Safe Drinking Water Act, blending of contamniated
groundwater with other sources of water is an acceptable method by
which to attain the standards (MCXs). The goal of the Superfund
program is to comply with applicable or relevant and appropriate
^requirements under other environmental statutes. Thus, in some
/instances, blending may be appropriate. However, for the North
Bollywood aeration facility, EPA has determined that blending will
not be used to attain MCLs. The aeration facility will treat
contaminated ground water to the MCL before the water is introduced
- into the distribution system.
:.~op. !,~.~> /id- •;;-- .-:'H '"iV '. , • ,<: '. .
48.?- CBE believes that the implementability sections of the OUFS for
liquid phase GAC and GAC/aeration options contain very little data
or supporting references. The commenter believes the information
17
-------
given is insufficient to compare the tmplementabilicy of che chree
options.
DWP response:
The implemencability analysis for each of che alternatives discussed
was necessarily brief due to the sparsity of available information.
The CAC alternative was ranked lowest in implementability primarily
because of project construction and operation constraints, although
DVP acknowledges that future studies may demonstrate that these
concerns are unfounded. At the time of OUFS report preparation, GAC
time constraints were viewed from the following perspectives:
Pilot Studies - Although the ability of GAC systems to remove TCE
and PCE is we11-documented, the degree and efficiency of
treatment for San Fernando Basin ground waters would have co be
determined by pilot studies. In every example of this technology
that DWP reviewed, GAC treatment involved a pilot study. Such
studies are necessary to establish single* and multiple-component
adsorption and reaction rate constants for each ground-water
contaminant. The primary difficulty is that even a long-term (six
months or more) pilot study will generally not experience the full
range of expected contaminant concentrations, so that data
extrapolation must be used to estimate GAC concentration. This
results in a considerable degree of uncertaincv with regard co
activated carbon life and removal/disposal/regeneracion schedules.
It is only fair to remark that the same concerns attend the
Aeration/GAC alternative. - However, in che aeration/GAC process, che
quantity of GAC required is orders of magnitude less and che air-
phase contaminant removal mechanism is better-known than its liquid-
phase GAC counterpart.
Carbon Supply - As of this date (August, 1987), DWP has
experienced difficulty in finding a carbon supplier chat will
guarantee either a long-term supply of activated carbon or carbon
disposal/regeneration services. The amount of carbon required for
the GAC alternative is on the order of hundreds of thousands of
pounds per year. Uncertainties in the supply or removal/disposal/
regeneration of this material translates into implementation
problems for the GAC alternative.
D. Reaadiml Alternative Preference Issues
"f - -
49. ~CBE believes that liquid-phase GAC is che best treatment option
because it most consistently reduces contaminant levels to the
RMCLs.
18
-------
DWP response:
int acknowledged, however, the DWP considers the RMCL
treatment clala to be unsubstantiated. Please refer to comment *4t>
for elaboration on liquid-phase GAC technology.
SO. C8E believes the GAC system should be permitted at 99 percent
removal efficiency, and that thorough monitoring be conducted to
ensure that the system is working as it is permitted.
OVP response:
The SCAQMD has permitted the removal efficiency of the GAC system at
aninimua of 90 percent. The facility will be monitored to ensure
that this removal efficiency or better is achieved.
51. CSDV and CBE asked whether EPA or DWP had considered several recent
studies indicating that inhalation and skin absorption of TCE and
PCE can result in significant health effects.
" response:
.e exposure pathways were considered as equivalent to the
^ngestion pathway in terms of health impact.
52. A spokesperson for City Councilman Wachs stated that the Councilman
supports the proposed aeration tower with the addition of carbon
filters, although he doubts the system can halt the spread of
contamination.
DWP response:
Comment acknowledged. Modelling-indicates that the pumping
configuration will halt or retard the spread of contamination.
53. A spokesperson for Los Angeles City Councilman Bernardi expressed
the Councilman's support for the GAC filtration system for treating
air emissions. The Councilman believes that an Environmental Impact
Report (EIR) is still needed for the project, to conform with State
requirements and to prevent possible litigation and accompanying
delays.
t&t response:
Comment acknowledged. DWP has determined that this project will not
have a significant impact on air quality and thus felt justified in
considering a Negative Declaration for the proposed project. In
addition, EPA, has determined that the OUFS process is substantially
equivalent to the National- Environmental Policy Act (NEPA), which is
the federal equivalent of the California Environmental Quality Act
(CEQA).
19
-------
54. FHCA believes chat the only viable treatment alternatives are the
GAG methods and the aeration tower, since the ultraviolet/ozone
tr««taent is not feasible at the design levels required by DWP. The
- cooaenter further stated that it will be necessary to monitor the
flow from the shallow wells to ensure the proper treatment rate is
maintained.
DVP response:
OVP agrees that the UV/ozone treatment process is not appropriate
for the design of this facility, although DWP will continue to
monitor or conduct studies to better understand the ozone
technologies for future use at the design level.
The flow from the shallow wells will be consistently monitored to
ensure that a proper flowrate is maintained.
55. A representative of Heatherdale Home, a senior citizen complex near
the site of the proposed aeration tower, stated that a recognized
toxicologist views the air emissions from the tower as a threat to
public health. The commenter believes DWP should respond co this
health threat and place the air filters on the aeration tower
accordingly.
OUT response:
Comment acknowledged. The proposed remedy includes carbon air
filtering units co control air emissions.
56. A representative of the Universal City-North Hollywood Chamber of
Commerce supports the construction of che aeration tower with the
addition of the carbon filtration system.
DWP response:
Comment acknowledged.
57. CBE stated that qwo potential benefits of the GAC alternative were
not addresed by Che OUFS. First, the use of a centralized GAC unit
would compare favorably to several decentralized units when
considering the extensive ground-water extraction that will be
necessary to clean up the numerous plumes in the San Fernando
Valley. Second, the use of GAC to treat effluent from che aeration
rtow«r would enhance DWP's ability to operate a large-scale GAC .
treatment unit. The commenter believes that if these benefits had
been considered, the use of GAC to treat the effluent from the
extraction system would have been the chosen alternative, rather
than the aeration/GAC alternative.
DVP response:
The use of a centralized treatment facility is very attractive, and
20
-------
Che OVP acknowledges a preference for Chis type of approach. The
£in*l remedial solution for the four NFL sites may indeed involve
- centralized treatment facility. Being an interim action, however,
die. aeration/GAC project is proposed to halt further spread of
contamination. By preventing further degradation of the ground
water basin, this action may permit a subsequent central facility to
be considered. However, the scope of the problem makes it mandatory
that a major effort be delayed until the Remedial Investigation is
completed.
A related comment concerns a proposal to treat all OVF ground vacars
nov rather than treat just the most contaminated supplies, so that
all blending operations could be dispensed with. The OVP feels that
this scheme is probably the preferred solution to the problem, but
oust be based on a Basin-wide Remedial Investigation and Feasibility
Study. EPA must select a cost-effective remedy for the project that
is consistent with the North Hollywood/Burbank operable unit. The
overall remedy may be different from the operable unit remedy.
58. CBE believes that the health effects from the aeration-only
alternative were not sufficiently assessed. Because of the unknown
cumulative effects of the air emissions, CBE believes that the GAG
component of the proposed treatment alternative must be permitted
and operated at 99 percent removal efficiency.
DWP response:
The cumulative aeration-only impact analysis is presented in
Appendix 9 of the OUFS report. Also, see response to Comment *41.
E. Process Issues
59. One conanenter asked what EPA and DWP know about the sources of
contamination; what actions are being taken to locate the sources;
and what enforcement and prosecution actions, if any, are being
taken regarding those responsible for the contamination.
DUP response:
EPA has enforcement authority in this situation. At this point, the
sources are unknown, but EPA has a list of possible sources of
-sJEDntamination that is based on the activities of certain
tibvpanies. EPA has issued requests for information, although the
Agency has not yet identified sources. When sources are identified,
EPA policy is to involve Potentially Responsible Parties (PRPs) in
investigation and cleanup activities, if at all possible. EPA is
not taking any enforcement actions at this time; however, the Agency
will be coordinating with the Regional Water Quality Control Board
to identify and negotiate with PRPs.
60. One community member asked whether DWP is planning any future OUFSs.
21
-------
DVP response:
No other projects are being considered at this time. This short-
tent project, called an Operable Unit, is being conducted this way
because it is an expedient means of stopping the spread of
contamination. At the same time, DVP and EPA are conducting a
remedial investigation of the entire San Fernando Valley. As the
study progresses, if more problems are discovered that could be
remedied with a short-term project such as this one, the agencies
may conduct another OUFS.
61. One commenter asked why the community work group was not chosen
prior to the December 9, 1986 hearing so that group members could
have made a point of attending the hearing.
DVP response:
DUP and EPA first started discussions of the technical and
management committees and the community work group in July, 1936,
to initiate public involvement in the project in accordance with EPA
community relations requirements. Because Superfund had not yet
been reauthorized, OWP believed that development of these groups was
premature due to the possibility that the project would never
receive federal funding. The December meeting was conducted in the
belief that media coverage and public attendance would provide
sufficient bacKground for the project so chat when che community
work group was formed, only a few individuals would lack the
necessary information to comment-constructively on the OUFS report.
DVP acknowledges, however, that this decision created problems and
that an earlier commitment to the formation of che work group would
have been preferred.
62. One commenter asked if future community work group members will
receive the OUFS and be allowed to comment on it, despite the fact
chat the work group will not be formed until after the public
comment period ends.
DVP response:
The agencies believe that potential work group members- and the
community have had sufficient time to comment on the OUFS. as the
DUP has made the OUFS available in many public information
repositories, and sent 90 copies of the study and <*50 letters to the
public, asking if they would like to comment on the study.
63. CBE proposed that EPA and DVP seriously consider, as a next step in
the remediation process, the treatment of all ground water used by
DVP in the GAC liquid phase treatment.
DVP response:
Both the EPA and DVP recognize the potential that GAC treatment
22
-------
has as a preferred treatment process for a final solution Co che
Basin-wide ground-water contamination problem. A Feasibility Studv,
Co be conducted by EPA, will include this alternative in the
•valuation process.
64. FHCA stated that, because the OUFS is similar to an Environmental
Impact Study (EIS), the Federation believes it would be possible to
combine future OUFSs with the requirements of the California
Environmental Quality Act (CEQA), and issue a simultaneous EIR under-
Sections 15165 or 15166 and 15170 of CEQA.
OVP response:
EPA and OVP concur with these suggestions. EPA's Superfund process
was developed to be substantially equivalent to EIR requirements
under the National Environmental Policy Act (NEPA). Opportunities
for public input and review of the decision are equivalent to those
required under NEPA. The State of California is in the process of
making a similar determination for consistency with CEQA.
65. A member of the Sierra Club asked why the community work group
nomination letters were not issued until November 17, 1986. when the
members were to have been appointed by November 15, 1986. The
commenter further asked whether the public comment period could be
extended by three weeks Co December 30, 1986, to allow work group
members to submit their comments.
DVP response:
The Screening and Scoping Committee nominated the work group
members, but the nominations were delayed. Although the comment
period was not formally extended, attendees at the public meeting
held on the draft OUFS were encouraged to submit comments; all of
these comments have been considered. DWP made every effort to
contact each community work group member during the comment period,
and will work with the members to get their input on the OUFS.
66. A representative of CBE noted that the second paragraph of page 12
of the OUFS states that DWP applied for OUFS funding for the North
Hollywood project. On page 13, first paragraph, it is implied that
EPA proposed the OUFS mechanism. The commenter asked which
statement is correct.
•>g-
3SF response:
The statement on page 13 is correct. Page 12 should have referred
to the OUFS as a "fast-crack RI/FS."
23
-------
F. Health Issues
67. On* comaenter asked whether any of the contaminants chat were found
in the ground water were of sufficient concentration to pose a
significant health threat.
DVP response:
The estimated maximum concentration level in the ground water is on
the order of 215 ppb of TCE. The proposed treatment system is being
designed to treat 650 ppb, so there will be no difficulty in
removing the TCE. The same is true for PCS. There are no other
chemicals of significance in this context. In addition, DVP is able
to control the quality of water received at the customer's tap by
blending water from different sources, so the water always meets
relevant health standards.
68. CSOV and CBE believe that the proposed MCLs are too high, because
the only exposure pathway considered by EPA in setting the MCL was
through drinking contaminated water, and several recent studies
indicate that exposure through inhalation and skin absorption can
result in significant health effects. For this reason, the remedial
treatment should result in water at RMCLs to be most protective of
public health.
DWP response:
It is impossible to treat the ground waters to MCLGs (RMCLs)
utilizing any current technology. MCLs were adopted as the next
best criterion. MCLs are the enforceable standard and it is EPA's
policy to meet MCLs.
69. CBE noted that the second paragraph on page 28 of the OUFS contains
a discussion of health risks and treatment alternatives that is
inappropriately placed and should be removed.
DVP response:
The paragraph states that humans will continue to be exposed to
ground-water contaminants in one form or another; the health risk is
not discussed.
70. CBE noted that the second paragraph of page 50 of the OUFS contains
>«ditorializing," which CBE believes is inappropriate. CBE further
stated that scientific evidence, not just public opinion, support
the theory that any concentration of a probable carcinogen contains
a finite and significant cancer risk. CBE believes the statements
should be corrected.
DVP response:
Comment acknowledged; the paragraph on page 50 will be deleted.
24
-------
71. CBE believes that che assumption included on page 111 of che OUFS
Chat there is no difference in potential health impact through
ingestion of contaminants or other pathways is unsupported and
should be documented or removed.
DVP response:
The assumption was made to avoid an elaboration of public health
impacts for all conceivable pathways; such an elaboration would be
beyond the scope of the report. In addition, there is no definite
scientific evidence that contrasts the health risks of exposure
through skin or lung absorption and absorption through the stomach
lining.
72. CBE asked why the OUFS states that the cancer risk due to TCE
ingestion/inhalation at minute levels is insignificant, despite the
face that TCE is considered a probable human carcinogen by EPA and
its MCL goal is zero. CBE further notes that the terms "minute" and
•insignificant* are undefined. The commenter believes this
statement contradicts EPA's current evaluation of the health risk
associated with TCE and that the statement should be eliminated.
DVP response:
The OUFS report does not state that trace quantities of TCE are
insignificant with respect to human exposure and health risk. It
states that current scientific evidence suggests that it is. not
significant. This statement is added for objectivity: indeed, the
top of page 113 rebuts this view and supports che rationale for che
MCLG approach. DVP acknowledges that EPA enforces the "probable
human carcinogen" definition for TCE and federal funding is
contingent in part on this recognition.
73. CBE noted that the statement on page 114 of the OUFS, that the
impact of transportation and disposal or regeneration of spent
carbon from GAC treatment would be much more pronounced than the
impact of emissions at the treatment plant, is "unsupported
speculation" and should be eliminated.
DWP response:
The statement is supported by the fact that liquid-phase GAC
facility operation would result in little public health threat to
tjb* immediate community, whereas spent carbon removal/disposal/
regeneration represents an exposure hazard since the carbon must be
moved from container Co container and the opportunity for
contaminant release is significantly increased.
74. CBE noted that page 114 of the OUFS contains a discussion of
liability issues surrounding the use of GAC without discussing this
issue for the other treatment alternatives. The commenter believes
Che discussion of liability should be eliminated.
'25
-------
0V? response:
Coam«nt noced; the section will be deleted and the OUFS amended.
75. CBE asked why the mbre recent studies noted in the last paragraph on
page 117 vere not referenced or included in appendices co che OUFS.
DWP response:
These studies consisted of DWP and consultant reevaluations of the
recommended project design co include air emissions control.
Documentation of these evaluations was not available at the time of
OUFS preparation.
G. Miscellaneous Issues
76. The President of the Universal City/North Hollywood Chamber of
Commerce expressed support for DWP's efforts to resolve che wacer
problems in che area, and urged EPA to hasten the cleanup process.
DVP response:
Comment acknowledged.
77. The Executive Director of CSDW seated chac she is giad co see rhac
the tenor of the hearing had improved from che meeting held in May.
She further stated chat if earlier meetings had been conducted in
this fashion, che projecc mighc have been scarced much sooner.
DVP response:
Comment acknowledged.
78. CBE requested that the SCAQMD modify the permit issued Augusc 29,
1986 to the DWP for the aeration/GAC project. CBE stated chat che
permit should be modified to ensure that che project operates ac che
VOC removal efficiency rate.of 99 percent; to ensure that the best
available control technology (BACT) requirements for air emissions
are maintained with the GAC unit operating at the maximum efficiency
achievable; and to assure the public that the regulatory agencies
are operating in a consistent, logical manner co procecc human
health and the environment.
DVP response:
Comment noted. The permit issued by SCAQMD is consistent with BACT
and current air quality regulations enforced by that agency. The
permit requires that periodic emission monitoring be conducted to
prevent contaminant breakthrough.
26
-------
79. A CBE representative made Che following specific comments on the
OUFS:
a) The second paragraph of page five of the OUFS reads • in choosi
a ait* location and remedial action for this first OUFS...." CBE
believes this implies other OUFS projects are under consideration.
and should be deleted because this is not currently the case.
DWP response:
The stated wording is not on page 5 and could not be located in the
report. This could have been in the earlier draft, but was deleted.
It should be noted that there may be future operable units in the
other three NPL areas.
b) The first paragraph on page 8 of the OUFS beginning. " In order
to objectively evaluate the relative needs of the two cities....,"
implies that the OUFS proposal can only include action at one site
or that only one OUFS is possible. The commenter believes that this
implication is untrue and should be removed from the report.
DVP response:
Due to the physical differences in the water supply systems of the
two cities discussed, it is true that one operable unit cannot
(directly) serve both cities. The recommendation that che operable
unit be constructed for the North Hollywood site is based on the
fact that sufficient hydrogeologic information to justify such an
action now is available only for this site. There may be future
operable units in the other three NPL areas.
c) The statement on page 10, regarding the implication that "highly
sensitive analytical techniques" are responsible for the discovery
of ground-water contamination, is false and should be removed.
DVP response:
Comment acknowledged. The OUFS will be .amended to delete "highly
sensitive analytical techniques."
d) The last paragraph on page 17 states that only the eastern half
of the San Fernando Basin has widespread organic ground-water
contamination problems. The commenter believes that statement
falsely implies that the Verdugo NPL site is in the San Fernando
Basin, and that the statement should be eliminated.
DVP response:
Comment noted; the OUFS will be amended-to delete the statement.
•»^» >,.i. .:,..,— _,..„
e) The discussion on page 61 of the extraction and conveyance system
does not consider the difference between the two alternatives
-------
detailed in Appendix 7. CBE believes chat che OUFS should scace
explicitly that Alternative 2 of Appendix 7 was chosen as the final
Alternative at the December 9, 1986 public hearing.
DWP response:
Appendix 7 details a preliminary feasibility analysis conducted Co
determine if the general approach could work. The actual citing of
the extraction veils has not been finalized by the OVP consultant.
Consequently, neither alternative was officially adopted.
f) The last paragraph on page 65 is "unsubstantiated speculation,"
and should either be supported or eliminated.
DWP response:
There is a general consensus among many neighboring water utilities
in the Southern California area that the cost-effectiveness of
aeration is hindered or completely overshadowed by the drawbacks
outlined in the paragraph. These difficulties are self-evident and
require no special documentation.
g) The information on page 110 should be added to the discussion of
the aeration alternative; placing the information at che beginning
of the section gives the aeration alternative an unfair bias.
DWP response:
Because the aeration process is an integral part of rwo of :he
alternatives evaluated, it was felt the information was appropriate
for this section.
2. ConnBents Made Bv Government Agencies
1. The California Department of Health Services (DHS), Toxic Substances
Control Division, believes the methods outlined in the OUFS for
creating contaminated ground water are acceptable. DHS believes
that regeneration or recycling of spent contaminated activated
carbon rather than land disposal should be implemented due to the
EPA land disposal restrictions for this type of waste.
DVP response:
is currently investigating contract carbon regeneration at two
U.S. sites. It is unknown at this time (August, 1987) if contracts
can be procured for carbon regeneration on either a short-term or
long-tern basis.
28
-------
1 07/01/83 Oept,. * Voter a
citr o* ie» Angeles
SAN FERNANDO
AMfNISTIATIVe IfCOM
So. Cat Assoc of GoverraMnts
OfSOHPTTOII/SUlJECT
Study: GroundMeter Quality
Mgan Plan San Fernando valley
laffin
PACES
07/09/84 water Qua!
-------
SAN FEIMAMOO
AOMIHISTIUrtVE tECORO
PAG£:
13
1984 Water Oust Ity Division
Oepc. a* Uster < Power
01/04/85 Jaws A. Goodrich
Sltt Mgr.
Casp Dresser C Mcfee Inc.
CoMaittee
Petti Cleary
Regional Sit* Project Office
EPA Region 9
OESCTtPTtOll/SUlJeCT
Innteragencr Coordinating
CoMittee for tht GrouidMiter
Quality MirMgMMnt ?(«n
S«n fernanbo Valley 3a*in
(.•tttr: Work A««i
r«t
12
U
01/10/85 Ptttr «o«al«ky
SFVB Monitoring Mail
Data
IS
01/22/85
Stratharn Pit Monitoring w*( I
Data
16
01/22/85 GQNF-SFVfl
(nt«rag*ncy Coord. Coomitte*
17
02/08/85 Patti Claary
CP« Pro/act M«r.
Caip. Ort«*«r t
03/05/85 Laurent Mcfteynoids CoMitta*
£xae. A«t. to As*t. Can. Mar.
water
19
03/19/85 Exacutfv*
CdMiftta*
20
03/29/85
Minutvt: fntaraganey Coordin-
ating CoMitte*. Grndwater Mgt
Plan Matting Minutn for
V22/8S
PreeuraMcnt taqu««t/0rdtr 'or
Lavci o/ effort [ncreaaa :n
Taeh Uork Hour* for San fcman
Forward Planning Activities
Minute*: Jnteraaency Coordtng.
C
-------
26
27
SAM renuuoo
••• ADMINISTRATIVE RECORD
OATE FROM/OR6ANI2ATION TQ/ORCANIZATtON
04/08/85 Petti Cteary JOBM * Coodridi
feflM Iff* Project Officer Site Naneger
Cwp. Oreaaer * NeCee inc.
PACe:
05/01/85 SCS Enfineera
So Ca( Aaan of Govt.
05/15/85 Laurent Ncfteynoidi Canittee
Cxee. AMI. Gen. Her. • Ueter
05/85 Kelvin l. llevina
Senior Nydrotoaic Engineer
WateraMter, Upper LA
06/05/85 U OWP
CoMittee
letter: In reeponee to Preti*.
Oreft Work *(en leMdlet .
InvMt./FeMibiUty Stuoy in
S*n F«m. CrndMeter B««in
••port: On Mezerdoue Wecte Mgt
Profrea for Swil Quant fty
fieneretore: No. Hodywood
Pilot Stuoy
Nfnutee: Interegercy Coordfntg
CoMiittee CroundMeter Ouelit/
Nget 'ten Sen Fern. VI ly latin
Neetini 3/19/85 lev. 1/22/85
Study: Wetenweter Service in
the Upper loe Aneetee fiver
«ree, upper LA County 10/1/83
to 9/30/84
Agenda: For Neetint between
EM and L* Oept. of water t
Power
28
07/15/85 City Of LA Oept Water < Power EM
••port: City of LA Ueter Qual-
ity Fact Sheet Mo. 1, Surface
and Croundwotera
07/23/85 Robert J. VenArk
Oiran., leojutetiona PSOS
Subcaaaiittee Report
Interegency Coordinating Cam.
Agenda « ••port: For
Meeting end Reg. PSOS SubCo
(•port.
21
30 08/05/85 Jim fioodridi
REH 2 Site
Petti Cleary
CMRCN
>: Preliminary Scope t
ludget for Addtl. Work for the
Sen Fernando Croundueter Study
31 08/06/85 Ceitfi Tetoc*
Chief.
08/08/85 reith Takata
Chief, Superfund Program
•ranch
Merry Sereyderian
Oir., Toxica « Uaatea Ngvt Oiv
tarry Sereyderien
Oir.. Toxica I Waate Ng*t Oiv
: COM work Aaeigrmnta for
San Fernando valley Aree • 1
north NoUyvood, lurbank i
Attached Ooea for Procurement
t Procuraewit Sheets: CON
Work Aaaigneant San Fernando
"Aree SI tee 1«4 Action
33
08/16/85 Ceap, Oreaaer 4 McCee, Inc.
Linda •oomuien
Oeputy Project
New i Attached Awndaant for
Solfcitatione/Nodification of
Contract
-------
34 08/16/85 Heathy MM Vendlinsti
Con. taxations Coordinator
T ox let i West* Ng*t 0
-------
22EJ!
46
47
OAT§ FRON/OgaAIHZATION
10/09/83 Craig MM largon
Supervising Engineer
r. NcXee Ine
10/29/85 (tetter U. Hoy*
Engineer of Design, Oept of
water ft Power, City of U
11/07/8S Laurent Ncfteynoids
Asst. Oii«f Engineer Oept. of
Water
SAM FERNANDO
••• ADMINISTRATIVE RECORD •••
TO/ORGANIZATION
Patti Cleery
logioncl Sfto Projoct Offieor
EPA
CuitOMrs
PACE: S
ifttoa
OESCTfPTIOM/gJiJECT
S«n rvrnonda Art* Fast Track
Evaluation
Lttttr to PUbtfe: Pvtotic Motif
i eat ion U Mpt Water i POHVT
Application for So Coatt Air
Ouat. *vn Pvmit for Tower
Ninutt* t Intaraooncy Coord.
COM. eroi^duattr Quality Mg*t
Plan San Fernando valley taain
28
49
11/22/85 Paula Siaaon Henry Veneoas
Superfund Irancn U OUP
12/20/85 Craig Von taroan Patti deary
Supervising Engineer
>. Oreuer ft NcXee Inc.
Re Telephone Convercation to
Oiacuaa UpcMing COMB. Mtg.
•e San Fern. < M MtlyMd Trt*t
Tower
lie San Fernando Area Feat
Track Evaluation
11
50
01/07/86 Jaws McNeil y.
, OHS
Paul M. Lane
Gen. Ngr., OWP cu
Report: Mortft Hollywood
SrounOMater TreatMent Facility
Operable Unit FS
SI 01/13/86 Laurent NcReynolda
Aaat. Chief Engineer Water
OPW - U
it tree
Minutes - ICC Croundwater
Oaulity Msnauaaint Plan
San Fernando Valley Main
31
52 01/26/86 Craig Von •argon
Ceap, Dresser ft McKo* Inc.
John Randall
Remedial Project Ngr.
US EPA
San Fernando CUPS Review of
Design Plans i SPecs.
53 01/27/86 Keith Tatota
Chief.
•ranch
Mr. Ouane Ceorgeson
Asst. Can. Ngr. Hater. Dept of
Water ft Power
Re Evaluation for San Fernando
Valley water tea in
11
01/86
i. Dresser ft NcCee Inc.
Patti Cteary
US EPA
Cowuiity Relations Plan. San
Fernando Valley Main ft U Co.
CA
45
55
02/05/86 EP»
EPA
Report: Scope of Work, Ground*
water. Node! ing San Fernando
valley Main
10
-------
eoc * DATJ
56 02/86
SAN
tecato
PACE: 6
OESOHPTIOJI/SUejECT
OUP Irochurt lackgrounder re 4
North N'wood lurbank Croundwtr
57 03/18/86 Laurent Ncfeynolds
AMI. Chief En«. OWPCtA
Coast ttee
Minute*: Intersgency Caordntng
Cam. Cmdwtr Quality Ngwt Pin
Sen Fernando Velley l««in
58 03/24/86 Tienthy Jaftn Vendlfnski
COM. lei it ione Coordinator
Toiics ( w««te H0et. Oiv.
ity
Eneloeure
59 03/25/86 Men* r«caU>
tuacs LA
61 OS/02/86 Waittr W. Hey*
Engineer of Oesign
San Fernando VIly ICC
60 03/25/86 Interageney Coora. COMittee l.C.C.
Petti Cleery
US EPA
Ineluetv* of (nteregency Coord
COM* for Inpleoentation of tne
CrndMtr Quality Mgmt PI en, San
Fernando VIIy las in Agenda
Jnterageney Coord. COM*, rttg.
Minute* For Implewntation of
Crndwtr Quality Mg*t Plan, San
Fernano. Valley Sasin
Oeeratole Unit Feasibility
Study
60
57
62 05/12/86 Soutft Coast Air Quality Ngt. SCMW
Oist.
Agenda for Public Hearing
OWP't Proposed Water Stripping
Tower
63 05/12/86 SCAdW
SCAON)
Agenda for Public Hearing
OWP's Proposed Water Stripping
Tower
05/12/86
Public
Staff teport on Proposed Water
Stripping Tower, 5-12-86
65 05/13/86 Inter agency Coor. CflsiittM l.C.C.
Interagency Coord. COMB, for
Implementation of CrndMtr Qual
ngan Plan San Fernando VIly Is
Agenda
66 05/30/86 EPA
Public
EPA Fact Sheet to Irief Elactd
Officials, Cos*, leaders, Int.
lesidents on Progress Invest.
Soil t Cmdwater Contaainetion
13
-------
SSL! DAT!
67 06/02/86 Citizens For A letter
Env4r
06/04/46 Creig Von Iargen
PC, Caap. Dresser * Mere
SAM FEINAMOO
ICCQatO "^^
PAGE: 7
TO/OKCAHrZATlOM
LA OUT
Pstti Ctrary
legions! Site Project Officer
US EM
DESCttPTfOM/StBJECT
aCCC Conaantary Cosnants of
Nark AbrexBwitz, Allen lew *
•endix Env. leseerch an lehelf
of *tCE to LA Oept wtr t Pwr.
Draft Operable Unit f«wibi(ry
Study « ••V(M of Co«Mnt«
69 06/09/86 Paula IfMOA
Oiivf. Star* ProaraM Section
70 06/09/86 Uattar u. Hoy*
Engineer of Oeaion
Henry Veneoea
U Oept of Water • Power
Paula Kaaon
Env. Scientist. Superfund
ProgreM Irancft. Toxic Hgt Oiv
ffe EneioMd I1FS Feat Track
Schedule for S*n Fernando VIly
ftaain H.M'wood, Surbank Area «
Pt Site
Proposed «. N'wood, twrbank
Aeration Facility Aeandad Init
Study A Proposed negative
Declaration
71 06/16/86 Marry Seraydarian
Director, Toxics A Waste MOJK
06/16/86 Harry Seraydarian
Oir. Toxics waste Noxt Oiv.
06/26/86 Laurent Ncteynolda
Asst. Chief Engineer Water
Ouane L. Ceorgeson
Asst. lien. Ngr. Water
City of U Oept Water C Power
Ouane I. Ceorgeson
Asst. Gentl. Ngr. Water
LA OWP
Provide EPA'a CosMents on
the Draft Operadle Unit feas-
ibility Study for N N'wood/
aurtoenft MPL Site, SFV Sasm
IE: EM's CoMents on Orsft
Operable Feasibility Study on
M Hollywood well Field Area
SFV Crounowater Basin
Minutes: rnteragency Coord.
Coex*. firoundwater Oual. MoMt.
Plan. San Fern, vily lasin.
31
74 07/11/86 Dale Cite
Oiairoan, Interagency Coord.
Cos*. SFV Gmdwtr Oual. N0K
ttee
te: Agenda Interagency Coord
i Ntg an July 22, 1986
7*. I 07/11/86 J«MS N.
Consult.
i. Inc.
Waiter W. Hoye
Engj. of Oeaign
U
San Fernando Valley Croundwtr
laein; Analysis of Shallow
Well Extraction Systs*
07/18/86 Ti« Vendlinsci
Pau4a Ifsson
Suggested Agenda Item for
•eeting w/UOU> on 7/22/46
76
07/30/86
Welter Hoye
Engineer of Design
Paul* lisson
Acting Chief, State Program
Section. Superfund EM
Staff Discussion t Further
ledefinjtion of Process to
Perfone the CoMsunity work
-------
OOC * DATE FROM/
77 08/06/8* em
SAN FERNANDO
•*• ADMINISTRATIVE RECOHO
TO/OtCAMfZATIOJI
EPA
PAGE: 3
DESCRIPTtOM/smJECT
Agenda 8/6/86 Meeting OWP (
EPA
P«CE5
2
08/06/86 EPA
EPA
Issues to I* Discussed at the
August 6. 1986 Meeting with
DWP
79
08/06/86 EPA
EPA
Attendance Roster for Meeting
With OWP
80 08/07/86 John (ended
TUMO
Ann Andrew*
FTS 382
Response to Questions on S«n 5
Fernando
81 08/18/86 Ti« vcndlinski
i. leiations Coordinator
82 08/19/86 Crtig von targen
Oavis lemetein Surrnry of Comwiity leletions
teMsdial Project Manager OCA Tasks to be Performed during
OCR Supoort Staff EPA Com* Ctr «y Detail to EPA Meadouarters
8/23/86
John *end*U
The LAOW* Draft Ours
dated 8/1/86
08/22/86 Craig Von largen
John tended
*e: IAQWP Draft OUFS 8/1/86
RevieM Cements
85
08/22/86 Paula iisson Henry Vengas
Chief, State Programs Section LA OWP1
08/27/86 waiter
Paula (isson
Acting Chief, State Programs
Section, Superfund Programs
IE: Endangered Assessaent
Personnel for LAOWP Meeting
With EPA
Missing Enclosure
San Fernando VIly las in Super-
fund Site Coeauiity Work Group
10
86 08/28/86 Patty Priekett
Chairperson for Citizens for
Safe Drinking Water
Sandra Carroll
COM. Relations Coordinator
UStPA
Letter Re Documents I Info
Requested fro* U OWP
87 . 08/86 Ouane L. Ceergeson
Asst 6en Nflr water
Re: CoMaunlty Work Croup for
SFV lasin Supsrfund Site.
10*
-------
ft* • OATJ FtOM/OtCANt2ATIOM
« 09/02/8* Michael Cam
tisaaretrAaaoc. Citizens for
a letter tnvfronaant
SAM FERNANDO
•«• ADMINISTRATIVE tECOtO
TO/ORGANIZATION
Sandra ranefca
Public letations 0«pt.
LAOPV
PACE: 9
OESCflPTlON/SligjECT
Intergovernaantal Coordinating
COBBittee
09/04/86 John 0. lendet (
Project Ngr.
90 09/03/86 Michael K. Woo
Council!
91 . 09/08/86
Ann Fern
US EPA Tel ecosMuticat ions Ctr
Michael Cent
Citizens for A letter Environ*
Sandra Twiaka
Public tvtatio
U W*
SupM-fund Offico
Our Phone Conversation 8/28
Missing Enclosure
Cooperative Agreement EPA i
U OWP
IE: Appointasnt of Patty
Prickett to Citizens Advisory
Coamitte of SFV Gmdnater tin
Superfund Cleanup Prograa ,,
9: Froa Jack U. NcfiraM EPA
OEKC1A T«(aconfaranca
92
09/09/86 EPA
Out(in* for 9/9/86 Meeting
93 09/10/86 Paul M. Lam
C«n. Mgr. < Chief Eng.
LA OWP
•arbara IOSB
Marican «s*oe of university
uorfc Group srv lasin
Sheer fund Site
09/10/86 EPA
EPA
Outline for 9/10/86 Meeting
letween OWP ( EPA
09/12/86 Oat* file
ICC Ott<
°6 09/1S/86 Marry
Oir.. r«
97 09/1*786 U Ot»>
Caaaittae Members
Ouane L. Georgeson
AMC. Can Mgr. LA O
U OMP
Nimte* Interagancy Cbordinatg
CoMittee, CrndMtr Quality Mgt
Plan, SFV Main
Enclosure
EPA's Cosjstnt* on Draft Oper-
able Unit Feasibility Study
For • N'wood Well Field Area
•N/turtonk SFV Ground wtr lasn
•E: Meeting Vttft EPA. Prepar*
ations for CUC Scaping Meeting
11*
09/22^6 Paul N. Lane
Can Mgr * Chief In«i
OMP City of LA
Michael K. Uoa
lMn 13th Olstrict
City of U
Scoping Meeting with Various
Co«a. laps. S Elected Official
ta Determine Size, Struct, i
lea. an the CUB
-------
ooc *• 04re FfOM/otCAi»zAncai
99 09/24/86 Waiter W. Noye
Engineer of Design
SAN FEINANDO
•*• «flm»rSTMTtVt IECOKO «
TO/OiSAMfZATIO*
Paula lUson
Chief, Start Prograa) S«etfon
Super find Irancn, US EPA
PACE: 10
Menaaa«ent t fed» Advisory
Coaafttees SFV las in
Sit*.
100 09/25/86 Pawl N. Lam
Can. Mgr. < Chief Engineer
lay *aay
Pr*>. u Area Oi
of Ce
y Work Grow for
•aain Scperfund Sfte
101 09/29/06
102 09/29/86 EM
EPA
Agenda, Jan Fernando Valley
•aain Siperftnd Site, Scoping
Mtg for Eat. Cowuiity Work
Croup
Agenda I* Ciekoff Meeting
on 12/86
103 09/29/86 EPA
EPA
Agenda (e Scoping Meeting
104 09/29/86 Martha Oavit
Exec. Oir. Mono lake Comnittc
.J5 09/29/86 San Fernando Vally lasin
Co*. Work Group
n« Vendlin«ki
leg. Superfund Cc
Coordinator
SFVISSCUC
•E: Mono Lake Conmittee Con-
lelationa cerns aeout the SFV Baain Site
COMI. teiationa Prograai t Est.
of Comnity Work Group
Attendance for tne Scoping
Meeting for SFV Steerfvnd Site
CoiMrtity work Group 9/29/86
.2
106 09/30/86 J. Winston Porter
Aaat. Adm. us EP«
Patty Prickett
Citizena for Safe Drinking
Water
Letter in lecponae to Ltr. le:
SFV Croundwater Main Super-
Site
J07
10/02/86
li
File
Mem: Press Call Concerning
San Fernando
108
10/06/96 Paula Ifaaon
Terry Wilaon, CCA
Mew le: Phone Call with
Michael latter, U Weekly
109 10/08/86 Ouene I. Georfeaon
Aaat. Can. Mgr. Water
OW» U
Jeffrey Zalikaon
EPA • legion 9
«: Operable Unit Feaaibflity
Stuoy. N. N'MOod/lurbank Area
-------
ooc_9 OATJ
110 10/16/86
111
10/16/86 Sandi C.
SAM FERNANDO
•*» ADMINISTRATIVE tECORO
TO/OR6A*fZATIO»
P*tti i John I.
Tie), Paul*, Patty A John
PAGE: 11
DESCRIPTION/SUBJECT
Not* fro» OWP Water Quality
•reakfaat. Westwood Hottl
Citttans for Safe Drinking
Water
Transarittal Slip and text of
Consent Agreesvnt and Final
Order. Docket* TSCA-09-86-0003
t*
112 10/27/86 Data KM*
dMirwn '86 - 87
Interagency Coordtnatfng
CoMiittee Nanber*
Agenda for the Interageney
Coordinating Com. Meeting
Nov. 4, 1986
113 10/30/86 Craig Von largen
US EPA
113.1 10/31/86 «* City of U, CA
Patti Cteary
1H 11/06/86 Inttraganey Coord. CoMaittae t.C.C.
115 11/04/86 EPA
EPA
Latter of Tranaanttai le: Co»-
aants on N N'Uood well Field
OUFS Connected to CoMMnts an
NN Well Field OUFS
Specification* for Conctructn
of Ho Hollywood-turban*
Aeration Facility
Influent-Effluent Pipelines
Meeting Minutes, Interagcncy
Coord. Conn, for !«pt«mem»tn
of GrndKtr Ouat. Mgait Plan
SFV Basin
tevised OUFS Schedule for SFV
lasin, NH/gurbank Area NPl
Site
116
11/04/86 U Oept. of Water and Power USCM
Meeting Agenda for U OWP C
US EPA Operable Unit Feasibil-
ity Study
117 11/06/86 waiter W. May*
Cnginaw£«tf 0«ign
U
Ccitti Takata
Chief Superfund ProgrMS
•ranch US EPA legion 9
Letter *e: F«nting for KH/lur-
bank Aeration Facility
118 11/10/86 Ouane 1. Georgcon
Asat. Can. Ngr. water
U
Pete logon
Chief Sanitary Eng. •ranch
Oept Nealth Services. CA
letter le: Mgs» i Tech Advis.
CoOTittees SFV lasin
Suparfund Site
119
11/U/86 Petti Cleery
Public vetice: leport on Pro-
posed fimdMater Trtait Plant
Available for Public leview
-------
SAN FERMANOO
«ecow
OOC -9 DATE. Ft«/0».CAM12ATtOM
120 11/17/86 U Oeat. of Water end Poner
T0/0« CAM f?< TK*
121
11/19/86 Walter W. Moye
Engineer of Design
U OUP
reith Takata
Chief, Siperfind Prograia
•ranch, E»A legion 9
Itport fro* U 0t» Opcritot*
Unit F«Mibitity Study UN w*il
Fitid Are* of NM/Burtenk NPL
Sitt, SfV GmoMter Satin
Lttttr It: Pv«e Pirt(eip«cn
in Scpcrfund Aetivitie* t 0«cs
SFV CrotndiMttr Mstn
354
5"
122 11/28/86 Parti Cltary
l Project
farter• ffn*
Chairperson, Ceology, Hydro-
geology ('InfrMtrtxture Canm
123 11/86 EPA
Letter: Request for Jnfometn
Pursuant to Phone Conversation
for Scope of Work from ft!
Superfund
Final Draft Operable Unit
Feasibility Study, leap, to
124 12/K/86 Oale
-------
ooc 9 DATE Ffo»/ot6*i»2AT!OM
131 12/11/86 Paula
SAM FEMANDO
••• AMimSTtAriVE ttCOHO
TO/OtCAIHZAnOM
Pstti
PAGE: IS
OESortPTioii/suiJECT
Letter Frca Ooris L. Iradthew
133
135
136
12/19/86 Nicnael Kent
•esearcn Assoc. Citizens for
e setter Envii
12/19/86 Executive
John lends!!
EPA Toxics t UMtt
12/19/86 Petty Pricxett Mr. Henry venegas
Exec. Olr.. Citizens for Sefe Project Ngr., U OWP
Orinkinf Ueter
12/22/86 lertoere Fine Nenry Veneoee
Chairperson, Geology, Hydro!. ' u OWP
C Infreetructure Cam.
12/22/86 Nieheei Kent
*«eercft Assoc. CS£
137 12/86 U OW»
Public
Coeaittee
Letter: le Meed for Nodifice-
. Oiv. tion to SCAQND Perait for the
Proposed NH Area Aeretion/GAC
Proposal
Executive Suaaary of LADPW
Prepared Operable unit Feasi-
bility Study leport on NM/sur-
bank Wall Field Aree
Letter: le CSOW leview of
Operable Unit Feasibility
Stuoy for HH Weil Field Aree
of NM/turbank NPX Site
Letter: le Caaaents 4 Question
Concerning Operable Unit Feas-
ibility Study for HH wall Fill
Area of NH/Burbank HPL Site
le Opereble Unit FM-
sibility Study for tne NH tfett
Fill Aree of NH/lurbenk NPL
Site
StuoV: Nenegeaent of SFV
CroundMeter le«in
J9
137.1 01/13/87 OPW of City of LA. CA
Specificetions for woltywood-
lurbenk Aeretion facility
Extraction Wells
33
130 01/U/87 Creif «•»
P.I., Si
lendetl
leaediel Project Ngr.
US EPA
Letter le $F Aree levtew of
Air Stripper Design
139 01/20/87 SteMert Abreas
Edison
Ceap Oresser « McKee Ine
Creig Von targen
>: le leview of Air Strippr
Ptsn Specifications
1*0 01/30/87 Welter Hoye
U
Psule tfseon
EM • Region 9
Draft Coop. Agreement Applic.
Package
37
-------
ooc •
141
2*11 gtCM/OMMHZATtOM
02/06/87 Art If.
142
U3
02/13/87 Paul* lisson
Chitf State Program Section
02/19/87 Patti Cleary
Begional Project Manager
SAN FEBHAMOO
•** ADMINISTRATIVE SECORO
TO/OtGAMIZATIOM
John lendall
EPA
Walter W. Hoy*
Engineer of Design
LA OUP
lobby Ofbotd
Begional Coordinator
PAG£: K
OESCBfPTIOM/SmJECT PACES
Telecopy Bequest I Letter: 11
(E the FoilOMup to 1/23/87
Meeting letwe«n OPW i US EPA
Concerning «M Aeration onign
Letter: le 1/23/87 Meeting 10
letween EPA. WP * Our Bespee-
tive Contractor! BE Our Design
* N'Wood Air Stripping Tower
tecord of Oeciiion I
Delegation Analysis San Fern.
Valley Sites
1U 02/27/87 Jeffrey Zelfkson Karl Northole
Acting Oir. Tonics t Waste Mgt Beg. Council Office of Begionl
Ofv. Council
Be Operable Unit Fesst-
bility Study Beport 'or MM/
Surfaank Area t The SFVG W8
16
145
03/10/87
Craig Von largen
P.E. Site Manager
Cam, Dresser t
Patti Cleery
BeoMdial Project Mgr.
US EPA
Letter: Be Beview of Besponse
Fro* LAOWP BE N H'wood Ground-
water Treatment
-6 33/16/87 waiter Hoye
Engineer of Design
LA OWP
Paula lisson
Chief, State Prograr* Section
State Sieerfind Program EPA
Letter, Comments, Sesoonsw t
Data Analysis Be « H'wood
Croundwater Trtmt Facility
04/14/87 Walter w. Hoy«
Keith Takata
Chief Siperfmd Programs Sranc
US EPA
Letter: Be Proposed * H'wood
Surbank Croundwater Treatment
Facility
148 OS/07/87 Mike Hopkins
ICC Chaff
it tee Heaters
Minutes: Interagency Coord.
Com. GroundMater Oual. Mg«t
Plan Meeting 1/20/87
16
149 05/29/87 J. Virwran »«rt«T
Asst. M»9. W EPA
Begional
Be«fon 9
iinistrators
Be Eleventh (enedy
Delegation Beport
149.1
06/02/87 OUP, City of LA. CA
Specification of the Aeration
Facility i the Eaiissiom
Control Facility in M Mollywd,
CA
as
150 06/10/87 Jeff 2elfkson
Acting o
-------
I
OOCJ
151
152
153
154
SAM FEIMAMDO
IECOU
: IS
06/10/87
KeitJt fatata
Chief
06/11/87
Progrew
Paula lisson
Chief. State Programs Section
EPA 9
06/12/87 Duane fieorgeson
U Ol*
I 153.1 07/07/87
07/13/87
Jeff Zetikaon, Acting Dir.
Toxics 1 waate Noiat. Div.
US EPA
N
------- |