United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R09-88/017
November 1987
3EPA
Superfund
Record of Decision
Operating Industries, CA
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50272 -101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R09-88/017
2.
3. Recipient's Accession No.
4. Title and Subtitle
UPERFUND RECORD OF DECISION
Jperating Industries, CA
Second Remedial Action
7. Author(s)
S. Report Da,
11/16 87
6.
8. Performina Organization Rept. No.
9. Performlna Oraanizatlon Name and Address
10. Project/Task/Work Unit No.
11. ContractCC) or Grant(G) No.
(C)
(G)
12. Sponsorina Organization Name and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 Report & Period Covered
Agency
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Operating Industries, Inc. (011) site, consisting of a 190-acre landfill, is
located in Monterey Park, California. The City of Montebello, which borders the
southern parcel of the landfill, has a population of 52,929 residents. Several
residences are located immediately adjacent to the landfill boundaries. Between 1948
and 1984, the landfill was used for the disposal of municipal and industrial waste.
Jver its 36-year life span, the 011 landfill has accepted several types of waste to
include: residential and commercial refuse: water-insoluble, nondecomposable inert
solids; liquid wastes; various hazardous wastes including waste water treatment sludge
from production of chrome oxide green pigment; and slop oil emulsion solids and tank
bottom sludges (leaded) from petroleum refining operations. Beginning in 1979, Getty
Synthetic Fuels, Inc. (GSF) extracted gas from the landfill for processing and sale.
After several permitting denials, GSF abandoned the gas extraction operations in March
1987. EPA took over operations of the GSF system the following month, and has been
conducting site control and monitoring (SCM) activities. In addition, EPA has conducted
a number of emergency actions to mitigate potential threats to public health and the
environment. Both landfill gas and leachate are generated by the 011. site. Since
October 1984, collected leachate has been stored onsite in tanks and transported to a
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Operating Industries, CA
Second Remedial Action
Contaminated Media: leachate
Kev ~Dnt-aminants: VOCs
-'b. rdtiitlfierslUp.,ri."Eniled Terms
c. COSATI Field/Group
8. Availability Statement
19. Security Class (This Report)
None
21. No. of Pages
39
20. Security Class (This Page)
None
22. Price
(See ANSI-Z39.18)
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OPTIONAL FORM 272 (4-77)
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Department of Commerce
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I
DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
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16. Abstract. Include a brief (200 wordl or lesl) factual summary of the most significant Information contained In the report. If the
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~?S : 1383 0 - 381-526 (83931
OPTIONAL FORM 272 BACK (4-77)
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~PA/ROD/R09-88/017
Operating Industries, CA
Second Remedial Action
16.
ABSTRACT (continued)
permitted offsite treatment facility. Approximately 10,000 gallons of leachate will be
collected before implementation of a final site remedy. The leachate generated contains
VOCs including: benzene, TCE, toluene, and vinyl chloride.
The selected remedial action for this site includes onsite treatment of leachate and
other collected hazardous liquids by air stripping and granular activated carbon
adsorption in a facility constructed at onsite location B with discharge to the Los
Angeles County Sanitation District sewerage system. The estimated five-year capital
cost for this remedial action is $1,900,000 with estimated five-year annual O&M of
$700,000.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION: Operating Industries, Inc., Monterey
Park, California
STATEMENT OF PURPOSE:
This decision document represents the selected remedial
action for the Operating Industries, Inc. site developed in
accordance with the Comprehensive Environmental Response, Com-
pensation and Liability Act of 1980 (CERCLA), the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and the
National Oil and Hazardous Substances Contingency Plan (NCP)
(40 C.F.R., Part 300).
-"
The State of California has concurred with the selected remedy.
STATEMENT OF BASIS:
This decision is b~sed upon the administrait~e record (index
attached). The attached index identifies the items which comprise'
the administrative record upon which the selection of a remedial
action is based.
DESCRIPTION OF THE SELECTED REMEDY:
The selected remedy consists of an on-site leachate treatment
using the Alternative IS treatment process at a facility to be
designed and contructed at location B as presented in the
Leachate Management Feasibility Study. The selected remedy
represents an operable unit consistent with the final remedial
action.
Declarations
The selected' remedy is protective of human health and the
environment and has been determined to be cost effective
and consistent with the final remedial action. This remedy
attains the legally applicable or relevant and appropriate
requirements of other Federal and State public health or
environmental laws. 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.
II. ". 87
JOfi.Js~ W~
Deputy Regional Administrator
U.S. EPA Region 9
Date
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Decision Summa~y
Ope~ating Indust~ies, Inc.
Monte~ey Park, California
Novembe.~ 1987
Prepared by Kevin I. Dick
Enforcement Response Section
Superfund Programs Branch
Toxics and Waste Management Division
United States Envi~onmental P~otection Agency
215 Fremont Street
San Francisco, California
94105
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o
1000
2000
3000
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SCALE. tift
.... t,
..-
SITE 0 a'
VIC1NITV ~ IeALI:" Mi. I
OPERATING INDUSTRIES
LANDFILL
OPERATING INDUSTRIES LANDFILL
LOCA TION MAP
Project
---
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Decision Summary
Operating Industries, Inc. Site
Monterey Park, California
Site Location and Description
The Operating Industries, Inc. (011) site is located
approximately 10 miles east of Lo~ Angeles in Monterey Park,
California (see Figure 1). The OIr site consists of a 190-acre
landfill which was operated from 1948 to 1984 and was used
for disposal of municipal and industrial waste. The landfill
contains hazardous waste and hazardous substances and was
listed on the National Priorities List in May, 1986.
The Pomona Freeway divides the site into a 45-acre northern
parcel and a 145-acre southern parcel. The top of the south
parcel of the landfill is about 150 to 250 feet above the ground
surface and the bottom of the landfill is about 200 feet below
ground surface. Elevation of the upper surface of the south
parcel of the landfill is about 620 to 640 feet above Mean Sea
Leve 1 ( MS L ) .
The orr site is presently owned by the former operators,
Operating Industries, Inc. The EPA has been conducting site
control and monitoring (SCM) activities at the site since OIr
ceased performing these activities in May, 1986. In addition,
EPA has conducted a number of emergency actions to mitigate
potential threats to pUblic health and the environment. The
site has become more stabilized as a result of the SCM activities
and the emergency actions.
The City of Monterey Park has a population of 54,338 (1980 Census).
The City of Montebello, which borders,the,southern parcel of the
landfill, has a population of 52,929 (1980 Census). Several residences
of Montebello are located immediately adjacent to the boundaries
of the landfill. Within a three-mile radius of the site, there
are approximately 53,000 residences.
The perimeter of the southern parcel of the landfill is
fenced. Entrance is restricted and 24-hour security is provided.
Several businesses are currently operating on the northern 45-
acre parcel. These businesses have a lease arrangement with the
operators.
Site History
Landfill operations at the site began in 1948. From 1948
to 1952, the site was used by the City of Monterey Park to dispose
of municipal garbage. Prior to 1948, the site and surrounding
areas were quarried for sands and gravels. In January 1952, the
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site became a privately-owned landfill under the ownership of
all. From 1952 to 1984, the site was operated as a landfill for
municipal and industrial liquid and solid wastes. In 1974, the
Ponoma Freeway was constructed. The freeway split the landfill
into a north and a south parcel. In June 1975, waste disposal
operations were curtailed in the northern parcel. Operations
were then limited to the area south of the freeway.
On October 6, 1954, the Regional Water Quality Control
Board (RWOCB) first permitted disposal of liquids at all which
was known as Monterey Disposal Company Dump at that time. Some
of these liquids, and some liquid industrial wastes disposed
prior to the Board's permit, are considered to be hazardous by
current Federal and State statutes and regulations. In 1975, a
32-acre area in the western part of the southern parcel was
established as the area of liquid waste disposal and was permitted
to accept Class 11-1 wastes. Waste disposal operations ceased in
October 1984.
The all site was placed on the California Hazardous Waste
Priority List in January 1984. The all site was proposed for the
Federal National Priority List (NPL) of uncontrolled hazardous
waste sites in October 1984 and was finalized on the NPL in May
1986.
I .
Over its 36-year life span, the all landfill has accepted
the following types of wastes: residential and commercial refuse~
water-insoluble, nondecomposable inert solids~ liquid wastes~
various hazardous wastes including wastewater treatment sludge
from production of chrome oxide green pigment~ and slop oil
emulsion solids and tank bottom sludges (leaded) from petroleum
refining operations.
In 1974, Getty Synthetic Fuels, Inc.. (GSF) entered into
a contractual relationship with 01.1 for the extraction of gas
from the landfill for processing and sale to Southern California
Gas Company. GSF's gas extraction system went into operation in
1979. In March, 1986, GSF ceased its gas processing activities
and applied to the South Coast Air Quality Management District
(SCAQMD) for a permit to construct an electrical generating
plant. At that time, GSF began to flare the extracted gas in
an incinerator until final permits for construction of the
electrification plant were issued. GSF also applied for a permit
from the City of Monterey Park for discharge of treated effluent
to the sewer. In January, 1986 the City of Monterey Park denied
GSF's permit. As a result, GSF decided to abandon their extrac-
tion operations at the orr landfill as of March 1, 1987. EPA
took over operation of the GSF system in June, 1987.
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Both landfill gas and leachate are generated by the 011
site. From April 1983 to October 1984, about 25,000 gallons
of leachate per day were collected by OIl's leachate collection
system and disposed of by mixing with the incoming solid waste.
Since then, collected leachate has been stored on-site in
Baker tanks, and transported to a permitted off-site treatment
facility.
The leachate generated at the 011 site is a hazardous waste
as defined by RCRA 261.3 regulations and contains hazardous
organic constituents such as vinyl chloride, trichloroethylene,
benzene, and toluene.
Land uses around the landfill began to undergo significant
changes in 1974. These changes included construction of the
Pomona Freeway (1974), and increased residential development
within Montebello City limits to the southwest (1975) and
south (1976) of the facility. A residential area is directly
adjacent to portions of the southern and western boundaries of
the landfill.
Discussion of Past Activities
A number of site problems have been identified by State and
Federal regulatory agencies. These include:
o
Hazardous leachate seepage and breakthrough on
the landfill slopes.
o
Subsurface and off-site migration of leachate.
High landfill gas (methane) levels exceeding the
lower explosive limit in nearby residential areas.
o
o
Vinyl chloride present in ambient air emissions
and in subsurface gas on-site and off-site.
Underground fires and associated subsidence
on-site.
o
o
Slope instability and erosion problems.
Surface runoff from the elevated fill area.
o
o.
Groundwater contamination from leachate and
migrating landfill gas.
o
Noxious and offensive odors on- and off-site.
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Partial control measures performed on-site by the owner in
prior years include:
o
Installation of a leachate collection system.
o
Development of an air-dike air injection system on
the west side of the site to control subsurface gas
migration.
o
Installation of gas extraction wells around the
perimeter (except for the air-dike area) of the
site and a gas flaring station.
o
Site contouring, slope terracing, and vegetation.
o
Covering refuse with additional fill.
The partial control measures instituted by the owner were
insufficient to maintain site integrity and the EPA, therefore,
instituted emergency response actions in order to protect public
health, welfare and the environment. Emergency actions performed
to date by EPA include: . .
o
Slope stability and erosion control improvements,
including construction of a toe buttress.
o
Surface runoff and drainage improvements.
Rehabilitation of the main flare station.
o
o
Site security.
o
Placement of vented water meter box covers off-site.
The owner/operator's ability to control the environmental
problems and maintain the control systems began to diminish
significantly in late 1984 when it notified EPA and the
California Department of Health Services (DeHS) that it could
no longer afford to truck leachate offsite for treatment. EPA
conducted the leachate trucking and treatment for several months.
Subsequently, DOBS assumed responsibility for this activity, while
011 continued to attempt to operate and maintain remaining on-site
control systems. On May 19, 1986, 011 notified the State that
it intended to discontinue all site control and monitoring
activities on the site except irrigation. The EPA therefore
assumed these activities on May 20, 1986. SCM activities then
continued to be performed by EPA with the State DOHS providing
leachate trucking and treatment and 011 providing on-site
irrigation. On December 15, 1986, the State transferred
responsibility for leachate trucking and treatment to the EPA.
EPA has also requested that 011 allow EPA to assume full
responsibility for irrigation of the site because EPA believes
011 has not properly conducted the activity.
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CII, 01 Mont.,., ,..,k / '~
NORTH PARCEL " .
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LEGEND
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SCALE" FEET
OPERA TING INDUSTRIES LANDFLL
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LEACHA Tf COLLECTION SYSTEM
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CURRENT SITE CONDITIONS
Interim actions have been undertaken at the landfill to
control and prevent leachate seeps from occurring. In 1980,
both the South Coast Air Quality Management District, and the
California Waste Management Board ordered 011 to construct a
leachate collection system. A leachate collection system was
installed in the early 1980's by all to control surface seepage
that was occurring on- and off-site. The system consists of
shallow gravel trenches which passively collect leachate to
prevent surface seepage, unlined gravel sumps, and underground
collection tanks. Wells were installed by all and EPA above the
Iguala Park area to intercept leachate that was appearing as
surface seepage down-slope in Iguala Park. There are five areas
on the site in which leachate collection systems are located.
These are shown on Figure 2 and are detailed below.
Area I
Area I on the southeast side of the site consists of
trenches, perforated pipes, and leachate disposal wells drilled
into dry refuse. Liquid waste disposal was not permitted on
this portion of the landfill. However, there have been leachate
seeps within this area. With the installation of the collection
system, the seeps have apparently been controlled.
Immediately south of Area I, along the base of the landfill,
a toe buttress was recently constructed to stabilize the slopes.
A continuous drain was installed within the toe buttress. Leachate
collected from this drain is transported to one of three concrete
storage tanks which is periodically pumped out by a vacuum truck.
Area II
. The Area I I leachate collection system in the lowe-r south-
east portion of the site consists of the six Iguala wells. The
Iguala wells were installed to prevent leachate seeps in the
Iguala Park area south of the 011 boundary. The wells are 70 to
80 feet deep, generally extending through approximately 10 to 15
feet of landfill rubbish and into the native earth material. The
wells are equipped with electrically powered submersible pumps.
Leachate collected from the wells is pumped into a collection
manifold pipe connecting the six wells to the underground tanks
in leachate collection Area III. There are five other wells in
Area II which are not connected to the collection system. In the
past, leachate has been pumped from these wells .into vacuum
trucks. There is no record of pumping for the past several
years.
Two new collection wells were installed in 1986 as part of
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the emergency response
part of the collection
the Iguala Park area.
side of well IL-l8.
actions for the site. These wells are
system installed to prevent seeps in
The wells are located 50 feet to either
Area III
The leachate collection system in Area III, on the southwest
corner of the site, consists of a series of buried, perforated
pipes and trenches discharging into three buried steel tanks.
The buried steel tanks consist of one 3,500 gallon tank which has
the upper part of both ends perforated, an 8,000 gallon tank, and
a 10,000 gallon tank. Each tank can be individually emptied
through pumping. The tanks are resting in a gravel bed which can
also be pumped to remove leachate collected within the gravel bed
surrounding the tanks. The 3,500 gallon tank, with perforations
in the upper part of each end, is designed to collect leachate in
the gravel bed surrounding the cluster of tanks. All three tanks
are from old vacuum trucks and do not meet current regulations
for underground tanks.
Southwest and down-slope of the buried tanks, along the
boundary of 011, is a french drain system which flows to a
36-inch diameter unlined sump. Leachate is pumped from the
sump to the buried tanks.
Area IV
Leachate collected in the buried tanks in Area III is pumped
to three 20,000 gallon, above-ground storage tanks (Baker tanks)
located in the vicinity of the surge tower in Area IV. Leachate
is removed from the storage tanks by a vacuum truck and trans-
ported off-site for treatment and disposal. During the period
from April 1983 tnrough October 1984, the leachate was trucked
to and disposed of in the active landfill working area.
The main leachate collection system in Area IV on the
western side of the site is similar to the system in Area III,
consisting of perforated pipe and trenches which feed to an
unlined, 36-inch diameter sump in the vicinity of the surge
tower. The surge tower serves as a standpipe providing adequate
head to gravity flow leachate into the buried tanks in Area III.
Area V
The leachate collection system in Area V is very similar to
the system in Area I, consisting of trenches, perforated pipe and
leachate disposal wells drilled into dry refuse. It is believed
that leachate seeps occurred in this area during the stockpiling
of dirt immediately up-slope. Currently there are no surface
seeps in this area.
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Under the Site Control and Monitoring Remedial Action EPA
will be implementing improvements and repairs to the existing
shallow collection system. The present 011 leachate collection
system is a poorly designed system in various states of disrepair.
These improvements should increase the efficiency of the collection
system and consequently increase the volume of leachate collected.
These improvements include:
o
Replacement of the underground collection tanks. Currently,
tanks from tank trucks which were buried by 011 are used
for leachate collection. These tanks are not suitable for
continued subsurface use. These tanks are probably leaking
and EPA has determined that their replacement is necessary.
Replacement of air com~ressor and increased compressor
capacity. A reliable compressor with increased capacity
will allow for optimum performance of leachate extraction
pumps.
o
o
Replacement or modification of clogged gravel collection
trenches and sumps. Gravels become clogged by oil and
grease in the leachate and no longer collect leachate
effectively.
Modification and improvement of unlined sumps. Currently,
one of the unlined leachate collection sumps which extends
to a depth of sixty feet can only be pumped out of the
upper thirty-five feet. By allowing for the entire sump volume
to be pumped, modification will improve the efficiency of
the sump. In addition, a sump located down-slope of the
underground collection tanks may need future improvements
if replacement of the underground tanks does not control
leachate flow into this sump.
Surface seepage of leachate occurs at the site periodically due
to failure of the existing collection system. Leachate seepage
occurred in the southwest corner of the site in August, 1987.
This supports EPA's contention that improvements to the collection
system will lead to increased volumes of leachate collection due to
improved system efficiency.
o
Leachate was collected by OII at a rate of 25,000 to 30,000
gallons per day during the period from April 1983, to October 1984,
when the leachate was being redisposed into the landfill. Collection
rates showed an initial steep decline after October 1984, which may
reflect the cessation of leachate redisposal. Deterioration of
the collection system may also be reflected in the decline.
Since the initial decline following to cessation of leachate
redisposal leachate collection rates have stabilized. Collection
rates vary throughout the year but average approximately 4 to 6
thousand gallons per day.
Several factors contribute to the continued leachate production
at the site:
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o
Metabolic liquids produced by decomposition of the waste mas5i
o
Liquid infiltration through the surface of the site;
Liquids squeezed out of pore spaces as the landfill settles;
o
o
Approximately 300,000,000 gallons of manifested liquids were
deposited since 1977, and additional large volumes were
deposited historically.
EPA estimates that volumes of leachate and hazardous liquids
collected at all will increase to approximately 10,000 gallons
during the interim period before implementation of the final remedy
for the site. This volume increase will be due primarily to
improvements to the existing collection system (described above)
and to improvements to collect condensate which is currently being
recirculated through the landfill.
Condensate is a hazardous liquid which is generated from the
cooling of moisture-saturated gas during gas extraction. Currently,
limited volumes of condensate are collected at the GSF and OII flare
stations. Drip legs in the gas systems currently re-inject condensate
into the landfill. As collection is expanded to trap the re-injected
condensate, collected volumes could increase to several thousand
gallons per day.
Additional amounts of liquids will be collected as the collection
system is expanded to de-water inundated gas extraction wells and
perimeter gas monitoring probes. Equipment decontamination during
the ongoing RI/FS and construction activities will also generate
minor additional volumes of liquids which may require treatment.
A combination of these factors contribute to EPA's estimate of
interim leachate collection of 10,000 gallons per day. EPA believes
this is the best estimate for formulating remedial action treatment
alternatives and cost comparisons.
In the future, even greater volumes of hazardous liquids could
be collected due the potential need to collect and treat the following:
o
Additional shallow leachate as a source control measure to
prevent contamination of perched groundwater;
.
Additional deep leachate as a source control measure to
prevent groundwater contamination:
.
Additional condensate resulting from expansion of the gas
collection system:
Additional leachate collection to enhance gas extraction.
Contamination has been detected in the groundwater in the site
vicinity. Extraction and treatment of groundwater may also be
required in the future. During the hydrogeological investigation,
the water generated by well development, purging, and pump testing
may have to be treated prior to discharge.
.
-------
LEACHATE CHARACTERIZATION
-9-
Based on the review of over 70 sets of sampling data from the
past 42 months (January 1983 through July 1986), the quality of
leachate obtained from the 011 landfill exhibits a high degree of
variability. No consistent sampling and analysis program extending
beyond a few months has ever been undertaken and data reviewed
illustrate the lack of consistent results and difficulty in assessing
the characteristics of a representative sample of leachate.
Although quality assurance information on some of the leachate
data was not readily available, inclusion of all results to
summarize leachate quality was believed to be appropriate to
fully characterize the potential range of contaminant levels which
may be present in 011 leachate and to therefore evaluate the
degree of flexibility which must be considered for treatment.
The all leachate can be described as a darkly colored liquid with
a moderate petroleum and/or musky odor. Past analysis results
have been highly variable and indicate that leachate may contain
a wide array of organic and inorganic pollutants including oil
and grease, volatile organics, semivolatile organics, sulfides,
a variety of heavy metals, and high levels of chemical oxygen demand,
suspended solids, and total dissolved solids.
A summary of the range of several selected constituents found in
all leachate is presented below:
Parameter
pH
oil and grease
Chemical oxygen demand
Suspended solids
Total dissolved solids
Ammonia
Vinyl Chloride
Methylene chloride
Toluene
Xylene isomers
l,4-Dioxane
bis(2-ethylhexyl) phthalate
Phenol
Sulfides
Chromium
Arsenic
Zinc
Sodium
Calcium
Range of Values
(mg/L except pH)
Minimum
6.6
6
750
62
7,226
720
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.026
0.06
2,200
116
Maximum
8.5
296,800
31,000
62,800
16,300
927
0.50
16.3
10.0
5.0
19.0
60.0
1.8
13.0
4.81
4.52
18.0
4,500
367
ND:
Not Detected
-------
-10-
Many of the EPA Target Compounds (TC) have been identified in OIr
leachate at various times during the past few years. Heavy
metals such as chromium, arsenic, zinc, cadmium, copper, lead,
nickel, mercury, and selenium which are TCs have been found
during elemental analysis of leachate and have ranged from below
detection limits to several milligrams per liter. Average and
median values of heavy metals in the leachate indicate that they
are commonly found in concentrations of less than one milligram
per liter and are represented by common mono and divalent species
such as sodium, potassium, magnesium, calcium and iron. This
conclusion was further substantiatd by the high quality NErc
analysis which identified heavy metals ranging from detection
limits to 340 micrograms per liter and common metals ranging from
16 to 3400 milligrams per liter.
Over one-third of the organic Target Compounds as well as a
variety of non-TCs have been detected at least once in an 011
leachate sample. Organics which have been frequently identified
in leachate include volatile aromatic compounds such as benzene,
dichlorobenzene, ethyl benzene, toluene and xylene isomers,
volatile halocarbons such as l,l-dichloroethane, methylene chloride
and vinyl chloride, and other volatile constituents such as
acetone, methylethyl ketone and dioxane isomers. Several semi-
volatile TCs were also frequently identified including several
phenol species, several phthalate esters, naphthalene, phenanthrene
and 2-methylnaphthalene. These organics, along with many less
frequently detected organic constituents, have been found to be
present in leachate at levels ranging from detection limits to
several milligrams per liter. Average and median values for
organic TCs indicate that they are usually present in concentra-
tions of several hundred micrograms per liter or less. The high
quality NEIC analysis generally substantiated this conclusion
although high levels of 1,4 dioxane (13 mg/l), 2methyl-2-butanol
(1.4 mg/l), 2-methyl-2-propanol (2.0mg/l) and bis (2 ethylhexyl)
phthalate ~l.l mg/l) were identified in this particular sample.
Several analyses for organic constituents in 011 leachate have
indicated the presence of a complex organic matrix which consists
largely of undifferentiated weathered hydrocarbon species which
are not normally identified using conventional gas chromatographic
and gas chromatographic/mass spectroscopic techniques. Occasionally,
analyzing laboratories have estimated the concentrations of organic
acids and n-alkanes present in leachate. One set of results for
a leachate sample taken in June of 1984 reported estimatd levels
of butanoic, pentanoic and hexanoic acids at levels of 1.6, 1.9,
and 3.1 milligrams per liter respectively. Other labs have estimated
the levels of various n-alkanes (from 9 to 31 carbons) on several
occasions and have reported total levels of several hundred
milligrams per liter. The high quality NEIC analysis quantified
the n-alkanes at a total level of 1.4 mg/l. It was also
estimated, based on a total ion count for the chromatograms, that
the total concentrations of hydrocarbon materials in this sample
-------
-11-
were 70 mg/l, most of which could not be specifically identified.
Analysis showed that 68 percent of the dissolved organic carbon
in the NEIC leachate sample could be attributed to organic acids.
In addition to metal and organic pollutant level determination,
the concentrations of many other contaminants have been quantified
in samples of all leachate. The pH of the leachate has generally
been neutral or slightly basic. Oil and grease, chemical oxygen
demand, and suspended solids have been found in highly variable
concentrations with median values of 473 mg/l, 4,690 mg/l and 628
mg/l, respectively. Dissolved solids levels have been more
consistent at mean and median levels of approximately 11,500
mg/l. Ammonia levels in 011 leachate average approximately 820
mg/l based upon the two sets of results reviewed.
Based upon a review of the over 70 sets of available analytical
data characterizing all leachate, this waste was found to have a
high strength character. The results were highly variable with
respect to levels of specific organic and inorganic constituents,
thus making the determination of a -representative sample- of
leachate difficult. However, general categories of pollutants
for which removal through treatment would be necessary were
identified as oil and grease, metals, organics, and sulfides.
Community Relations
A history of the community relations activities at the all site,
the background on community involvement and concerns, and specific
comments on the Feasibility Study and EPA's responses are found
in the Responsiveness Summary.
Alternatives Evaluation
Remedial Action Objectives:
The following objectives and considerations guided the formulation
of remedial action alternatives for management of leachate and other
hazardous liquids collected at 011.
o The remedial action must be easily and rapidly implementable
and have the potential to be integrated into the final remedy
for the site.
o The alternatives must be flexible in order to manage both
short- and long-term variations in the leachate collection
rate and in the chemical characteristics of the leachate.
o Remedial actions which included treatment to permanently
and significantly reduce the volume, toxicity, or mobility
of all leachate contaminants were preferred.
-------
-12-
Initial Screening of Alternatives
EPA identified the following alternatives for managing
leachate and other hazardous liquids collected at the Operating
Industries, Inc. Superfund site:
o No Action
o Off-site disposal without treatment
o Off-site treatment
o On-site disposal without treatment
o On-site treatment
Of these alternatives, only on-site and off-site treatment
remained after performing the initial screening of alternatives
in the -Leachate Management Feasibility Study, Operating Indus-
tries, Inc. Landfill Site-, March 1987.
The no-action alternative, which consists of termination
of pumping from the Iguala Wells, the sumps in Areas III and
IV, and the underground leachate collection tanks, would result
in overflows and off-site seepage into nearby residential areas.
Uncontrolled seeps from the south and southwest boundaries of
the landfill would expose a potentially large number of people
living and working in the adjacent areas to 011 leachate. An
analysis of the target pollutants identified in the leachate
has indicated that exposure to 011 leachate, leachate vapors or
leachate-contaminated soil by inhalation, dermal contact or
ingestion presents a potential human health hazard. The no-
action alternative would endanger the environment surrounding
the site by allowing leachate to contaminate. air, soil, and
groundwater.
-.".'!I...-~....;:
The off-site disposal without treatment alternative for
the all site involves the pumping of the Iguala Wells, sumps,
and underground tanks to the above-ground storage tanks which
would then be hauled a minimum of 200 miles in vacuum trucks to
an off-site RCRA-compliant disposal facility. This alternative
was eliminated from further consideration as its cost exceeds
the costs of other alternatives evaluated without providing
greater protection of public health and the environment.
Additionally, off-site land disposal is not a preferred method
under CERCLA which establishes a preference for response actions
that use treatment, reuse, or recycling. The Superfund Amendments
and Reauthorization Act (SARA) states that the offsite transport
and disposal of hazardous substances or contaminated materials witho"~
treatment should be the least favored alternative technology where "
practicable treatment technologies are available. New EPA land
disposal policy prohibits land disposal of dioxins and solvents
and additional restrictions will be added in the future. Thus,
off-site disposal of free liquids may not be possible over the
long-term.
-------
-13-
The on-site disposal without treatment alternative involves the
continued pumping of the Iguala wells, sumps, and underground
tanks to the above-ground storage tanks. The leachate would then
be pumped to on-site surface impoundments. On-site disposal is not
a preferred alternative as it will not adequately protect
pUblic health because volatile organic constituents present in
the leachate would pass into the atmosphere and pose a threat
to nearby communities. Additionally, there is a proposed
California state regulation forbidding the disposal of untreated
hazardous wastes into evaporation ponds which could prevent
on-site disposal over the long-term.
Two on-site treatment alternatives were eliminated due to
their failure to meet effluent discharge requirements and/or
public health concerns. The first treatment alternative was
developed as a minimal treatment process and included gravity
separation or clarification with discharge of effluent to the
LACSD sanitary sewage system. This alternative would remove
oil and grease but would not effectively remove soluble heavy
metals, sulfides, cyanides, or water soluble organic constituents
which would consequently be discharged to the sanitary sewer.
The second alternative eliminated consisted of the gravity
separation, rapid mix coagulant addition, dissolved air flotation.
and filtration process train followed by air stripping without
off-gas treatment and granular activated carbon adsorption with
sewering of the effluent. This alternative would fail to treat
off-gas from the air stripping tower. Transferring hazardous
substances from the liquid to gas phase is not a permanent
method of reducing the toxicity or mobility of these pollutants.
In addition, uncontrolled emissions could lead to further
degradation of air quality at the site and to the potential for
public health problems. For these reasons, this alternative
was eliminated from further consideration.
A summary of the initial screening of alternatives is
presented in Table 1.
Detailed Evaluation of Alternatives
Off-site treatment and four on-site treatment alternatives were
further evaluated based on the detailed evaluation criteria of
the 8EPA 1985 Feasibilty Study Guidance8 and the factors presented
in Section 121 (b)(l)(A-G) of SARA. These criteria are:
o Technical feasibility (performance, reliability,
implementability)
o Institutional considerations
o Protection of public health
-------
-14-
o Environmental protection
o Cost-effectiveness: Cost-effectiveness over the interim
(S year) period was evaluated.
The SARA Section 121 (b)(1)(A-G) factors are:
A) The long-term uncertainties associated with land disposal.
B) Goals, objectives, and requirements of the Solid
Waste Disposal Act.
C) The persistence, toxicity, mobility, and propensity to
bioaccummulate of hazardous substances and their con-
stituents.
D) Short- and long-term potential for adverse health
effects from human exposure.
E) Long-term maintenance costs.
F) Potential for future remedial action costs if the
alternative remedial action in question were to fail.
G) Potential threat to human health and environment
associated with excavation, transportation, and redisposal
or containment.
Description of Alternatives
Off-site Treatment:
Off-site treatment is the method currently used to manage
leachate and other hazardous liquids generated at the all
site. Leachate is hauled by vacuum truck to an off-site
treatment facility where it is treated, and the effluent is
discharged to the Los Angeles County Sanitation District
(LACSD) sewer system. Two facilities in Southern California
are currently permitted and capable of treating the leachate.
The treatment process used at one of these facilities is
illustrated in Figure 3.
On-site Treatment:
The on-site treatment alternative for managing all
leachate involves the construction and operation of a leachate
-------
TABLEl
SUMMARY OF INITIAL SCRDmN; OF ALTERNATIVES
Alternative
Reason for Elimination
Results of Initial Screening
No Action
Off-site treatment
Off-site disposal
On-site disposal
On-site treatment
Alt.! - Gravity separation sewer disposal
Alt.2 - Gravity separation, coagulation
addition, DAF, filtration, air
stripping with off-gas treatment
sewer disposal
Al t. 3 - Same as Alt. 2 wi th GAC replacing
air strippinq/off-gas treatment
Alt.4 - Same as Alt.3 with air stripping
without off-gas treatment added
prior to GAC
Alt.S - Same as Alt.4 with off-gas treat-
ment added
Alt.6 - Same as Alt.S with UFjRO added and
reuse of effluent
Eliminated
Potential adverse public health and
environmental effects
Consider further
Eliminated
Potential adverse public health
effects, EPA policy, permanency,
cost
Eliminated
Potential adverse public health
effects, peODanency
Eliminated
Potential adverse health and
environmental effects, permanency
Consider further
Consider further
Eliminated
Potential adverse health effects,
permanency
Consider further
Consider further
-------
-15-
treatment facility at the landfill site. The following four
alternative treatment plant configurations were evaluated for
treatment of the leachate:
Alternative .2
Gravity separation --) coagulant addition --) dis-
solved air flotation --) air stripping with vapor phase
carbon adsorption ... discharge
Alternative 13
Gravity separation --) coagulant addition --) dissolved
air flotation --) filtration --) liquid phase granular
activated carbon adsorption ... discharge
Alternative IS
Gravity separation --) coagulant addition --) dissolved
air flotation -->filtration --) air stripping with vapor
phase carbon adsorption --) liquid phase granular activated
carbon adsorption ... discharge
Alternative' 6
Gravity separation --) coagulant addition --) dissolved
air flotation --) filtration --) air stripping with vapor
phase carbon adsorption --) liquid phase granular activated
carbon adsorption --) ultra-filtration --) reverse osmosis
..reuse and/or discharge
Description
The unit processes for removal of oil and grease and heavy
metals are the same for the four on-site treatment alternatives
(Alternatives 2,3,5 and 6). The processes for the removal of the
organic compounds vary between on-site treatment Alternatives
2,3, and 5. A schematic of the Alternative 2 process train is
shown in Figure 4. Without granular activated carbon (GAC)
adsorption following air stripping, it is unlikely that the
treated leachate would consistently meet the requirements for
total toxic organic removal needed for an off-site wastewater
discharge permit. However, this alternative does reduce the
threat from the hazardous leachate and provides significant
protection to public health and welfare and the environment.
On-site treatment Alternative 3, as depicted schematically
in Figure 5, uses GAC adsorption without air stripping. The
-------
Influ.nt V80UU.
ator.g. - Truo"
011 W.t.r OAF a.nd .nd C.rbon
0'8"lt, « Dlnol".d . C.nnl.'.,
Air Ad.orptlon
a.p.r.80, Flot.tlon ) Flit.,.
Air atrlpplng
In
EUlu.nt
-- Holding a...r
T.nk.
OPERA TING INDUSTRIES LANDFILL
OFF-SITE
LEACHATE TREATMENT PROCESS
--- CDM
........ . ----------
rlQll8 3
~~~-~---_... - -.--=-------=--
-------
"...'
I
8..-._--;
OAF unit
I
,
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88ck.....
R.lect8d Effluent R.turp
--------,
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\ I
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L.acha'. Pump8
Cou.cUon
and Pumping
m
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S.parator
Conditioning
Tank
I
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Ra. L.achat.
.tGr818
Atm08ph.r.
r-
I
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- --
-
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:t
. Vapor pha..
~ Carbon Adaorptlon
w
::-:: :::.~.:=::~.::
.. . ..-.- ... .
Pump
Air Stripping
Air Blo..r To..r
Pump
To S8..' "anhol.
OPERA TING INDUSTRIES LANDFILL
ALTERNATIVE 2
ON-SITE TREATMENT PLANT PROCESS
Ettlu.nt 810r8g. Tanka
Pump
--::""'~"':'""'" ,.,nM l ~ , .
Figt..a
-------
I
,
I
,
I
I
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-----
",-......
I ,
I '
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'- _tI'
l
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ru
EUlu..nt atorag. Tan1&8
Pol,m.r ~
Alum ----,
. I' ., M
Oil and
I O,.a..
a.pa,ator
Exl.Ung Ra. Laachat. a. Laachat. I I
L.achal. Pump. .
Collection 101""
.ndPumplng r-----'--~
AtlA08Ph8r8 01
Flare atatlon
I .
1 -
II
Ii
J
.......1
I
DAF ";;.i - - --t
I
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I T"'ck.n.r F"lera ./Awo
Back.....
ReJected En,.....t Ratum
---------
I
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. .-.. .. . .8
-:~. :-,..~".,! ::::
Pump
To 8..., ".nhol.
Pump
----- .
~
011 and
0,....
Conditioning
T.nk
Actlv.t.d Ca,bon P
ump
Filler.
OPERA TING INDUSTRIES LANDFILL
ALTERNATIVE 3
ON-SITE mEA TMENT PLANT PROCESS TRAIN
--- COM
........ . ........... ............
Flgl68
5
-------
-16-
carbon adsorption unit is utilized for the removal of both the
volatile and semi-volatile organics. Since the GAC unit may
not efficiently remove small polar organic constituents, it may
not meet the discharge requirement of 15 ppb vinyl chloride which
is an Applicable or Relevant and Appropriate Requirement (ARAR).
On-site treatment Alternative '5, shown in Figure 6, in-
cludes both air stripping and GAC adsorption. This process train
is configured in order to achieve a level of leachate treatment
that will attain discharge requirements. Air stripping is added
to reduce the organic load on the GAC unit and would extend
the life of the carbon. Air stripping is effective for the
removal of vinyl chloride so the 15 ppb discharge requirement
should be achieved.
On-site treatment Alternative '6, shown schematically in
Figure 7, adds ultrafiltration and reverse osmosis to the pro-
cess train of on-site treatment Alternative '5. These units would
allow for the production of effluent of irrigation reuse quality,
and thus would exceed LACSD standards.
The leachate treatment facilities discussed in previous
sections were sized to treat the liquids collected at a rate
of approximately 10,000 gallons/day. In order to minimize
impacts of plant operations, plant operation is planned for
40 hours per week on weekdays during business hours. If flow
significantly increases, the plant would have the capability of
operating up to 24 hours per day. A forty-hour week operating
period requires process units capable of treating a flow rate
of 30 gallons per minute (gpm). The plant would be capable of
efficiently treating leachate in a flow range of 15 to 35 gpm.
Thus, the plant will have the flexibility of handling variations
in the rate of leachate treatment from 7,200 gallons/day to
. 16,800 gallons/day over an eight-hour workday. The maximum
design capacity for a 35 gpm plant operating 24 hours per day
is 60,400 gallons/day. For planning purposes and consistency
with the final site remedy, flexibility will be incorporated
into the plant layout and space requirements. The flexibility
will accomodate plant expansion to a 60, to a 90, and/or to a
120 gpm plant. Operation of a 120 gpm plant 24 hours per day
defines the maximum design capacity for a 1.5-acre facility of
172,800 gallons/day.
Evaluation
Off-site Treatment:
Off-site treatment was judged to be effective for the
treatment of ott leachate and is readily implem~ntable, but the
long-term reliability of this alternative is questionable. The
CERCLA off-site disposal policy requires a RCRA inspection of
off-site treatment facilities every six months. If significant
violations are found at a facility, that facility can no longer
-------
......--~---
I
I
I
I
I
I
,,--
/ '
I \
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, /
--
Raw Leachat.
PumP8
Exlallng
Leachat.
Collecllon
and Pumping
4:'-
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I '----1
DAF unit I
I SludJ. to Gravity Sand
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R.ject.d Effluent R.lurn
----------- -
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atoraga
011 and
I Gre...'
Separator
I I
-I - - -J
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lei
J
Conditioning
T.nk
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I
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Atmoaphere
-
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:I
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III
Pump
Acll..,e. ce'..~p B
ump
FlUera
Air Stripping
AI, 810we, Tower
Pump
To Sewer Manhole
OPERATING INDUSTRIES LANDFILL
ALTERNATIVE 5
ON-SITE TREATMENT PLANT PROCESS TRAIN
Effluent Storag. Tanka
Pump
---..- COM
........ .~~
figlM'8 6
-------
I
,
I
I
I
I
I
'-_.If
Exl.tlng Ra. Leacl88t.
L.achat. Pumo8
ColI.ctlon
and Pumping
Aa. Leachat.
Storage
011 and
I Gr.a..
S.parator
I I
-I - - -.8
~
t:s
111
Ii
J
Conditioning
Tank
~-----
,,-....
I '
I '
\ I
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I
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Atmolpher.
-
.
:t
. Vapor phal.
-: Carbon Adlorptlon
w
I -I
I DAF ';;;;,,- -1
I SIUd!. to
I Thlcken.r
- AeJected EHluent A.turn
--------
Gravity Sand
Filler. .'Auto
B8ck.a.
Air Stripping
Air Blo..r To.er Pump
BrIne
Acllvated Carbon
Pump
Fill.,.
OPERA TING INDUSTRIE~ lANDFill
Ae ct
Stream
Ultra.lltratlonlAewl.. 08m0eI,
To Se.8I
or DI,po,al
ALTERNATIVE 6
Pump To Irrtgallon ON-SITE TREATMENT PLANT PROCESS TRAIN
and/w Sew...
Manhole
..~~~ rrOM
Figure 7
--~ --. - -~~ <
-------
-17-
be used for treatment of the all leachate. As a private enter~rise,
the off-site treatment facility could cease operation at any
time, especially if it becomes unprofitable. Costs of
leachate treatment at the facility are set by the company and are
therefore out of the control of EPA. If a facility becomes
unavailable for treatment in the future, an alternative off-site
treatment facility would need to be identified. Off-site treat-
ment might then require excessive haul distances and associated
increases in cost and risk. If no alternative facilities are
available, construction of an on-site treatment facility would
then be required. During design and construction of an on-site
treatment facility, on-site storage of significant volumes of
leachate may be necessary. Other leachate management options
may include treatment off-site in violation of the CERCLA off-site
disposal policy or land disposal in potential violation of the
Solid Waste Disposal Act.
Off-site treatment could expose the public to the potential
risk of direct contact with the leachate in the case of a
tr~nsportation accident involving spillage. Leachate spillage
at points of loading and unloading poses the greatest risk,
however the public would not likely be directly exposed to
these spills. Residuals, such as oil and grease, sludges and
spent carbon are not as rigorously regulated at off-site treatment
facilities as they are at Superfund sites. Disposition of .
these residuals from an off-site treatment plant could pose a
potential threat to human health and the environment.
Spillage of leachate during transport could result in
groundwater contamination or contamination of surface waters
such as the Los Angeles River and the Rio Hondo Coastal Basins
spreading ground. In addition, off-site treatment was the most
costly alternative of those alternatives retained for further
evaluation. The present worth cost of five y~ars of off-site
treatment was estimated at approximately $6.8 million. If in-
corporated as part of the final remedy, the present worth cost
over 30 years is $22.2 million.
On-site Treatment:
The four on-site treatment alternatives which underwent detailed
evaluation are all effective in reducing the mobility, toxicity and
volume of hazardous constituents in the all leachate and could
be easily adapted to deal with variable leachate characteristics.
All the processes included in these alternatives are commonly
used in industry and in leachate treatment. The on-site treat-
ment facility would be designed to maximize automation and
is expected to have low maintenance requirements. The unit
processes are standard or pre-packaged units and are readily
implementable. All treated effluent would be batch tested
prior to discharge to insure effectiveness and reliability of
contaminant removal.
-------
-18-
All of the on-site treatment alternatives would discharge
treated effluent to the LACSD sewerage system. This discharge
would be required to meet the discharge requirements of the LACSD.
Anyon-site alternative would be designed to achieve full
compliance with all applicable or relevant and appropriate
requirements (ARARs) of the Clean Water Act (CWA), and the
Resource Conservation and Recovery Act (RCRA). Sewering of
effluent from any of the on-site treatment alternatives should
have no measurable impact on the receiving Joint Water Pollution
Control Plant in Carson, California, or the receiving waters of
the Pacific Ocean.
Industrial Wastewater Discharge permits (IWDP) would be
required from the local sewering agency (Monterey Park or
Montebe110). The City of Monterey Park Sanitary Sewer and
Industrial Waste Code requires approval of the City Council
prior to issuance of an IWDP for discharge of landfill wastes
into the city sewer system. Discharge to local sewers in the
City of Montebe110 would require approval from that city.
Comparison of Alternatives
Off-site treatment is more costly than any of the on-site
treatment options at a cost of approximately $6.8 million for 5
years of treatment. It also poses the greatest potential for
spillage at points of loading and unloading and during transport.
Spillage during transport would pose the potential for direct
human contact and environmental contamination. Off-site treatment
has the least long-term reliability and the greatest potential
for increased future remedial action costs.
The cost of on-site treatment for a five-year period ranged
from $4.1 to $5.3 million for the range of treatment processes.
All on-site treatment alternatives would be constructed to
minimize the potential for spillage, and all spillage could be
contained within the facility. Leachate would be treated to
meet discharge standards, and any air emissions from these
alternatives would be controlled with vapor phase carbon or thermal
destruction technologies to protect public health and the environment.
Concerns about leachate spillage during transport and long-term
reliability would be eliminated by choosing an on-site alternative.
If leachate treatment is incorporated as part of the final
remedy for the site, the cost differential between off-site
and on-site treatment using present worth costs. over a 30-year
period is approximately $10.3 million.
Comparison of On-site Treatment Processes:
Four different treatment processes, Alternatives 2, 3,
5, and 6, underwent detailed evaluation in the FS. Different
treatment processes were used to achieve varying degrees of
treatment, effectiveness, and efficiency. All four alternatives
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-19-
include oil and grease separation, chemical addition, dissolved
air. flotation (DAF), and sand filtration as the initial treatment
processes. The oil and grease separation removes nonemulsified
oil and grease from the leachate. Settleable sludge solids are
also removed in this portion of the process. Coagulants are
then mixed with the leachate to facilitate removal of emulsified
oil and grease and heavy metals. DAF is then used to remove
flocculated oil and grease which are skimmed off the top of the
flotation tank and heavy metals which are collected as sludges
at the bottom. Gravity sand filters are used to capture floc
and other suspended solids not removed by the DAF unit.
Alternative '2:
In alternative 12, air stripping is added to the treatment
process. Air stripping is a unit process in which liquid
and air are brought into contact to remove volatile substances
from the liquids (i.e., volatile organics and sulfides).
Several volatile organic compounds, such as vinyl chloride,
found in 011 leachate have high Henry's Law constants, and thus
would be readily removed. However, the presence of a complex
matrix of toxic organic substances in the leachate, including
less volatile pollutants such as phenols and phthalate esters,
could prevent an air stripping system alone from consistently
meeting LACSD standards for total toxic organics. For this
reason Alternative '2 was not considered as effective as those
alternatives employing both air stripping and granular activatad
carbon adsorption.
Alternative '3:
Alternative .3 employs granular activated carbon (GAC)
adsorption following the initial treatment process. Activated
carbon removes organic contaminants from water by the process
of adsorption. Activated carbon may not effectively remove the
smaller, polar organic constituents in the leachate, such as
methylene chloride and vinyl chloride, due to the existence -of
a complex organic matrix in the waste and the resulting
competitive adsorption effects. Alternative'3 should provide
organic removal as required to meet the LACSD total toxic organic
effluent discharge limitation of 1.0 mg/l. However, GAC alone may
not achieve the 15 ppb vinyl chloride requirement. The use of GAC
without an air-stripping unit would increase carbon usage due
to higher organic loading and therefore increases cost due to
GAC replacement. For these reasons, Alternative .3 was not
considered as effective as alternatives employing both air
stripping and GAC units.
Alternative '5:
Alternative '5 employs air stripping and GAC adsorption
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-20-
after the initial treatment process. This alternative should
reduce carbon consumption and associated costs. This system
provides for protection of public health by capturing toxic
constituents present in off-gases from the air stripping tower
in the vapor phase carbon adsorption column. By utilizing both
the air stripping and GAC processes, this alternative is expected
to achieve the LACSD discharge requirements for both vinyl
chloride and total toxic organics. Thus this alternative is
expected to comply with the requirements of the Federal Clean
Water Act which is enforced by the LACSD. The air emmisions
control systems will be designed to comply with the requirements
of the Clean Air Act which is enforced by SCAQMD, specifically
Regulation 13 regarding new source reviews, and also the state
ARAR Rule 402, entitled the nuisance provision. This alternative
would also comply with applicable requirements of Subtitle C of
the Solid Waste Disposal Act, and with applicable regulations
codified under Title 22 of the California Administrative Code.
This alternative was considered to be effective for achieving
all ARARs.
Alternative '6:
Alternative '6 adds ultra-filtration/reverse osmosis to
the Alternative '5 process train. This process would remove
total dissolved solids from one portion of the treated leachate
and concentrate it in the other portion, creating two products:
irrigation-quality water for use on site and a brine waste high
in TDS requiring disposal in the LACSD sewer system. Due to
the high concentration of dissolved solids in the OIr leachate,
approximately 60\ waste brine and 40\ irrigation quality water
would be produced per unit volume of trea~ed leachate processed
by the UF/RO unit. Due to the additional design requirements
and plant maintenance activities associated with UF/RO and the
additional cost of approximately $500,000 for 5 yrs of leachate
treatment, Alternative .6 was not considered as effective as
Alternative '5. This alternative was also considered to be
effective for achieving all ARARs.
Table 2 presents a summary of the detailed evaluation of
alternatives.
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tAllt
2
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-21-
SITING ANALYSIS OF AN ON-SITE TREATMENT FACILITY
Description of Alternatives:
In considering the construction of a new treatment plant
at the 011 landfill site, five potentially feasible locations
were identified. The approximate locations and direction and
distance to points of sewering are shown in Figure 8.
Location A is on the south parcel on an area south of the
existing GSF facility and flare station. Location B is on the
parcel north of the Pomona Freeway. Location C is on land
owned by Chevron Corporation abutting the eastern boundary of
the landfill site in the city of Montebello. Location D is on
the top of the landfill. Location E is on Southern California
Edison Property adjacent to the western boundary of the north
parcel.
. It is estimated that a site area of approximately 60,000
ft2 (1.4 acres) would be required to provide the space for a 30
gpm facility with room for expansion to a 120 gpm facility. In
estimating the size requirements, the following factors were
considered:
o
Space for unit processes and influent and effluent
storage for a 120 gpm facility.
o
Space for sludge handling.
Provision for a clean area for the laboratory and
office and the unloading of chemical shipments.
o
o
A decontamination area and an area for equipment wash-
down such as trucks leaving the sludge handling area.
The treatment plant processes and unit sizes are the same
for all locations and are based upon on-site Treatment Alter-
native '5.
Site Location Considerations:
Location A was originally considered but was eliminated
because:
o
The site is within 100 feet of residences in the
City of Montebello. Residents are concerned with
the proximity of this site location to their homes.
Major concerns are noise, odors, and safety.
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-22-
o
Construction of facility at this location may
conflict with space requirements for future remedial
actions.
o
The site is the minimum size needed for current
design specifications and provides little room for
expansion.
Location 8 is considered to be a feasible location and is
the preferred location for the following reasons:
o
This location is a flat site located several
thousand feet from residential neighborhoods.
It is buffered from residential areas by the
Pomona Freeway to the south and the Southern
California Edison easement property to the north.
Facility will require approximately 1.4 acres out
of the 45-acre North Parcel. This would allow
for potential future business development by the
City of Monterey Park on property remaining after
the final remedy is completed.
o
o
Leachate may be piped across or underneath the
Pomona Freeway in accordance with Caltrans regula-
tions and requirements.
o
The site is located within the 011 Superfund site
boundaries, and would therefore require no
acquisition of property, access, or permit.
Locati9n C was eliminated as a feasible alternative due. to
the fOllowing factors:
o
This site would require the acquisition of
approximately 1.4 acres of land from the Chevron
Corporation (not including access road). Acquisi-
tion of land and permit requirements could
delay implementation of the remedy.
o
This site is located 3500' to 4000' from the
current leachate collection area. A leachate
pipeline to this site would be located close
numerous residences within the City of Montebello.
Location D was considered but was eliminated for the
following reasons:
o
This site would require a special geotechnical
study to determine a suitable location for the
unit processes and storage tanks.
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-23-
o
Special design considerations would be required to
accomodate anticipated differential settling. The
locations and magnitude of settling are not
predictable and could cause serious problems in
maintaining the integrity of the facility.
This location may not be compatible with the final
remedy for the site.
o
o
Overall, siting at Location D may delay the
implementation of the treatment facility and
add costs to the final remedial action process.
Location E was eliminated as a feasible alternative as:
o
The site is located on Edison-owned property and
would therefore require acquisition of land from
Southern California Edison. Land acquisition and
permit requirements could significantly delay
implementation of the remedial action.
o
A treatment facility at this location could result
in potential disruption of Southern California
Edison power routing as this property is a high
voltage transmission line corridor adjacent to
Edison's Mesa Substation. This substation has
been identified by Edison as a major hub of the
company's electrical grid system.
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-24-
SELECTED REMEDY
Description:
EPA'S selected remedy for leachate management is on-site
treatment using the processes presented in Alternative 15 of
the Leachate Management Feasibility Study. The on-site treatment
facility will be used to treat leachate and other hazardous
liquids collected at the all site during the period before the
final remedy for the site is implemented. The facility will be
constructed at location B located on the north parcel of the all
site as presented in the Leachate Management Feasibility Study.
The treatment facility will be designed to provide the flexibility
required to treat varying qualities of leachate and to allow
for expansion to treat increased volumes of hazardous liquids,
and other liquids requiring treatment. Treatment at the facility
could continue after implementation of the final remedy if it
is included as part of that remedy. .
Prior to initiation of design of the treatment facility
a pre-design study will be performed. Characterization of
leachat~ and condensate will be updated and parameters will
be established to ensure that the treatment facility will
have the flexibility to treat varying qualities of leachate and
potential future liquids from the site. Additional treatability
tests will be performed to determine the proper sizing and
loading of the process units, and to allow optimization of the
treatment plant design. Tests to determine the nature and
proper disposition of oil and grease, sludge, and skimmings
will also be performed.
On-site treatment will be used during the interim
period primarily as source control for treatment of leachate
and condensate from the site. The plant could also be used for'
certain RI-derived wastes, i.e. decontamination water and
hydrogeology pump test water. The plant has the potential to
be used 1n the management of contaminant plume migration in the
future, if groundwater treatment 1s required.
The on-site treatment facility will be constructed as a 30
gallon per minute plant with an operating range of 15 to 35
gallons per minute. The treatment plant process units will be
mounted on individual concrete pads and configured to allow for
plant expansion to 60 gpm, 90 gpm, or 120 gpm. ,The plant
will be constructed on approximately 60,000 ft2 (1.4 acres) to
accommodate future expansion to 120 gpm. Influent leachate
storage of 100,000 gallons will be provided. Treatment plant
effluent will be batched for testing prior to discharge to ,the
LACSD sewer system. Appropriate noise and odor abatement
features and landscaping will be incorporated into the design
of the treatment plant.
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The five-year present worth cost of the selected remedy is
$4.8 million. This represents a capitol cost of $1.9
million and an annual operations and maintenance cost of
approximately $700,000. The selected remedy is the most-
effective remedy since it is the least costly alternative which
should achieve ARARs.
Target treatment level:
Leachate will be treated to achieve the Los Angeles County
Sanitation District (LASCD) Discharge Requirements. Treated
effluent will be discharged to the Joint Water Pollution Control
Plant in Carson, CA. Table 3 lists the LACSD discharge requirements.
Residuals:
If skimmed oil and grease are determined not to be hazardous,
the material will be disposed of by a waste oil company. If the
skimmings are determined to be hazardous, they will be disposed
of at a RCRA facility in compliance with the CERCLA off-site
disposal policy.
Once the carbon adsorptive capacity of the GAC units has
been fully utilized, the carbon will be disposed of or
regenerated. Pick-up of spent carbon and off-site regeneration
is a service frequently offered by suppliers of activated
carbon and could be used for this project.
Sludge is expected to be produced at a rate of approximately
0.5' by volume of total leachate. If the sludge is determined
to be hazardous, it will be disposed of off-site in compliance
with the CERCLA offsite disposal policy. Currently, hazardous
sludges produced through treatment of CERCLA wastes are hauled to
Chemwaste in Arlington, Oregon or USPCI in Murray, Utah. A
California facility may be' available by the time a treatment
plant is constructd.
Air emissions from the facility such as emissions from the
DAF unit and the air stripper will be controlled using vapor
phase carbon adsorption and thermal destruction. Vapor phase
carbon adsorption and thermal destruction technologies will be
evaluated during the pre-design phase of the project. Emissions
from the facility will comply with South Coast Air Quality
Management Districts .New Source Review. requiremenis which
require that emissions pose a risk of less than 10- to the
community.
The treatment facility is intended to be utilized until
implementation of the final remedy for the site, or until
EPA determines it is no longer needed for the treatment of
liquids from the 011 Superfund site at which time the
treatment facility would be dismantled. Only hazardous
liquids and other liquids requiring treatment that are
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TABLE 3
EFFLUEm' DISCHARGE LIMITS
FOR
CENTRALIZED HAZARDCX.1S WASTE TREATMENT FACILITIES
LOS ANGELES caJN'l'Y SANITATIOO DISTRICT
Parameter( 1)
Limitation (mg/l)
(maximum for any time)
Arsenic (total)
Cadmium (total)
Chromium (total)
Copper (total)
Lead (total)
Mercury (total)
Nickel (total)
Silver (total)
Zinc (total)
Cyanide (total)
Sulfides (dissolved)
TOtal toxic organics(~)
Oil and grease
Vinyl OUoride
Radioacti vi ty( ] )
3.0
0.69
2.77
3.38
0.69
2.0
3.98
0.43
2.61
1.20
0.1
1.0
10.0
0.015
(l)LiDdtations for other organic parameters and metals will be set as
needed.
(~'TOtal toxic organics (a list of 111 compounds specified by LACSD)
are to be analyzed using EPA Methods 601 and 602. Additional analysis
using EPA Method 625 may be required.
(3'In accordance with Title 17, California Admdnistrative Code, Section
30287. Generally limited to 400 pCi,IL above natural background.
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generated from the all site will be treated at the facility.
The facility will be designed so that it can be integrated into
the final remedy if continuing treatment of hazardous liquids
is required.
Statutory Determinations
Protectiveness:
The treatment facility will be protective of public health
and the environment. Leachate will be piped directly to the
facility to reduce the risk to public health and environment
associated with truck transport of the leachate. Batch testing
of treated effluent will insure that discharge requirements are
met. Air emissions from the facility will be controlled with
best available technologies and will comply wiih SCAQMD regula-
tions to achieve a risk level of less than 10-. Residuals from
the treatment processes will be regulated under the CERCLA
off-site disposal policy. Construction of the facility will
not pose any significant risk to the community or construction
workers. Safety features at the facility will be designed to
prevent community exposure to leachate spills.
The facility will utilize proven processes and will be
reliable for both short- and long-term use. The potential need
for replacement of this remedy is very low.
Consistency With Other Laws:
Federal ARARs
EPA intends to comply with federal ARARs for any off-site
or on-site treatment or disposal alternative for remedial
actions taken at the all site. The majority of these
laws are administrated by State or local agencies. Subtitle C
of the Solid Waste Disposal Act, entitled the Resource Conservation
and Recovery Act (RCRA), would apply to on-site or off-
site treatment or disposal facilities.
Regulations for new facilities involved
storage, or disposal of hazardous wastes (40
from RCRA, are applicable to any new on-site
or surface impoundment.
The general pretreatment requirements to the Federal Clean
Water Act would apply to any alternative which involves the
ultimate disposal of collected all leachate, whether treated
untreated, to a publicly-own~d treatment works (POTW). Com-
pliance with these standards is enforced by the Los Angeles
County Sanitation District (LACSD).
in the treatment,
CFR 264), developed
treatment facility
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-27-
The applicability of the Clean Air Act to an on-site
treatment or disposal facility was determined to be applicable.
A new source review provision of the act would apply to any new
source of emissions and would be enforced by the SCAQMD.
State ARARs
Applicable or relevant and appropriate state requirements
as well as local requirements for an on-site or off-site leachate
treatment or disposal facilities were identified. It is the
intent of the EPA to comply with state ARARs for anyon-site
or off-site treatment or disposal alternative. These ARARs were
based on input from the California Department of Health Services
(DOHS), California Waste Management Board (CWMB), Los Angeles
County Sanitation Districts (LACSD), South Coast Air Quality
Management District (SCAQMD) and the Regional Water Quality
Control Board (RWQCB).
The California Department of Health Services implements the
California RCRA program which would apply to remedial alternatives
involving the treatment, storage, or disposal of hazardous wastes.
The California RCRA program is very similar to the federal RCRA
program. Regulations are codified under Title 22 of the California
Administrative Code.
The Los Angeles County Sanitation District (LACSD), along
with the local city sewering agency, regulates discharges to
its sanitary sewer system, which serves the area surrounding
the OII site. The LACSD sets effluent discharge standards
which must be met for liquid waste discharges to their sewer
system in order to assure compliance with the Federal Clean
Water Act. In order to obtain approval for connection to the
off-site sanitary sewerage system from the local sewering
agency (Monterey Park or Montebello) and LACSD, hydraulic
capacity must be available and waste treatment capable of
consistently meeting discharge limitations must be provided.
The LACSD discharge limitations for any treatment facilities
are presented in Table 4.
The South Coast Air Quality Management District regulates
emissions to the atmosphere. Several specific provisions have
been identified which would apply to on-site remedial actions
at OII. Rule 402, entitled the nuisance provision, is a general
prohibition against excessive emissions which ~ould cause
adverse effects including odors. Regulation 13 is a new source
review provision which mandates that the net emissions from any
new source cannot exceed 75 pounds of organics per day.
Cost-effectiveness and Utilization of Permanent Solutions:
The selected remedy offers the best combination of
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-28-
effectiveness, implementability, and cost in comparison to the
other alternatives. This is the least costly alternative which
should achieve ARARs. It offers the same, or greater, degree of
protection and reliability than any of the other alternatives.
All treatment process are proven technologies and can be readily
implemented. Off-site leachate treatment will continue as part
of the Site Control and Monitoring Operable Unit Remedial
Action during the construction of the selected remedy.
The selected remedy is cost-effective and utilizes treatment
technologies to the maximum extent practicable.
Implementation Schedule:
Conduct Pre-Design Study 12/87 -3/88
Design Facility 3/88 - 9/88
Construct Facility 9/88 -3/89
Shakedown Test of Facility 3/89 - 4/89
Begin Plant Operation 4/89
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