United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-89/033
June 1989
BEPA
Superfund
Record of Decision
San Fernando Valley (Area 1), CA
-------
50272.101
REPORT DOCUMENTATION 1'. REPORTNO. 12-
PAGE EPA/ROD/R09-89/033
3. A8cip1enc'. Acc8aaIon No.
4. TI.. and Subtle
SUPERFUND RECORD OF DECISION
San Fernando Valley (Area 1), CA
Second Remedial Action
7. AuIIIor(.)
5. Report 0818
06/30/89
L
L Pwfonnlng Organization A8pt. No.
.. P8ff0nnklg 0rg8InIahn ..... and AddI-.
10. ProjadlTulllWoril Unit No.
11. ConIr8ct(C) or Gl8I1I(G) No.
(e)
(G)
12- SpoMorIng Or;8nIuIIon ..... and Add!-.
U.S. Environmental Protection
401 M Street,' S.W.
Washington, D.C. 20460
13. Type of Rapott . Period Cov.red
Agency
800/000
14.
15. SuppI8m8nI8ry No,"
IL Ab81r8cI (UrnII: 200 --I
The San Fernando Valley Basin (SFVB) Area 1 site is one of four Superfund sites
(including SFVB Areas 2, 3, and 4) being remediated as one large site. The SFVB lies
within the approximately 328,500-acre Upper Los Angeles River area. This remedial
action is for the Burbank Well Field operable unit of the SFVB Area 1 site, located
within the city of Burbank, California, and addresses a portion of the overall ground
water problem in the SFVB Areas 1, 2, 3, and 4 sites. The. SFVB aquifers is an
important source of drinking water for approximately 600,000 residents in nearby cities
and is also used for commercial and industrial purposes. Contaminated ground water is
difficult to replace in this area because water from the metropolitan water district,
an alternate source of drinking water, may not always be available due to periodic
drought conditions and State and Federal water rights issues. Contaminated ground
water in the SFVB wells was first discovered in 1980. Results of a ground water
monitoring program conducted from 1981 through 1987 revealed approximately 50 percent
of the water supply wells in the eastern portion of the SFVB were contaminated with TCE
and PCE at concentrations exceeding State and Federal drinking water standards. All of
Burbank's production wells have been shut down due to this VOC contamination. In 1987
the primary contaminant TCE was found in concentrations exceeding State Action Levels
(See Attached Sheet)
11. Documant An8Iy8f8 .. De8c:rfplora
Record of Decision - San Fernando Valley (Area 1), CA
Second Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (TCE, PCE)
It. 1d8n1l1l8r8l0pan.End8d Terma
~ COSATI ReIdIGroup
It. AY8II8biIty ~
18. S8c:urfIy Clau (TII18 Report)
None
20. S8c:urfIy Clau (TII18 Page)
Nnnp
21. No. of Pall88
48
22. PrIce
I
(See ANS-Z38.18)
S8ehulTlM:ti- on~-
. FORM 272 (4-77)
(Formet1y NTIS-35)
Department of Commerce
-------
DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCT10NS
Optional Form 272, Report Documentation Page I. based on Guidelines for Format and Production of Scientific and Technical Reports,
ANSI Z39.18-1974 available from American National Standarcl8ln.tltu18, 1430 Broadwliy, New Yortc. New York 10018. Each separately
bound report-for example, each volume In a multivolume .et-ahall have 118 unique Report Documentation Page.
1. Report Number. Each Individually bound report shall carry . unique alphanumeric designation aaaigned by the performing orga.
nlzatlon or provided by the sponsoring organization In accordance with American National Standard ANSI Z39.23-1974, Technical
Report Number (STAN). For registration of report code, contact NTIS Report Number Clearinghouse, Springfield, VA 22161. Use
uppercase letters, Arable numerals, slashes, and hyphen. only, ..In the following examp"': FASEBINS-75187 and FAAJ
RD-75/09.
Leave blank.
2.
3. Recipient'. AcceaaJon Number. Reserved for use by each report recipient.
4. Title and Subtitle. Title .hould Indicate clearly and briefly the subject coverage of the report, subordinate subtitle to the main
title. When a report Is prepared In more than one volume, repeat the primary title, add volume number and Include subtitle for
the specific volume.
5. Report Date. Each report shall carry a clatelndlcatlng at le..t month and year. Indicate the baafs on which It was selected (e.g.,
date of Issue, clate of approval, date of preparation, date published).
6. Sponsoring Agency Code. Leave blank.
7. Author(s). Give name(s) In conventional order (e.g., John R. Doe, or J. Robert Doe). Ust author's affiliation If It differs from
the performing organization.
8. Performing organization Report Number. Insert If performing organlzaton wishes to 888lgn this number.
9. Performing Organization Name and Mailing Address. Give name, street, city, state, and ZIP code. Ust no more than two levels of
an organizational hlerachy. Display the name of the organization exactly as It should appear In Government Indexes such as
Government Reports Announcements a. Index (GRA a. I).
10. ProjectlTaskIWork Unit Number. Use the project, task and work unit numbers under which the report was prepared.
11. Contract/Grant Number. Insert contract or grant number under which report was prepared.
12. Sponsoring Agency Name and Mailing Address. Include ZIP code. Cite main sponsors.
13. Type of Report and Period Covered. State Interim, final, etc., and,lf applicable, Inclusive dates.
14. Performing Organization Code. Leave blank.
15. Supplementary Notes. Enter Information not Included elsewhere but useful, such as: Prepared In cooperation with. .. Translation
of . . . Presented at conference of. . . To be published In . " When a report Is revised, Include a statement whether the new
report superaedes or supplements the older report.
16. Abstract. Include a brief (200 words or less) factual summary of the most significant Information contained In the report. If the
report contains a significant bibliography or literature survey, mention It here.
17. Document Analysis. (a). Descriptors. Select from the Thesaurus of engineering and Scientific Terms the proper authorized terms
that Identity the major concept of the research and are sufficiently specific and precise to be used as Index entries for cataloging.
(b). Identifiers and Open-Ended Terms. Use Identifiers for project names, code names. equipment designators, etc. Use open-
ended terms written In descriptor form for those subjects for which no descriptor exists.
(c). COSATI Field/Group. Field and Group asalgnments are to be taken form the 1964 COSATI Subject Category Ust. Since the
majority of documenta are multidisciplinary In nature, the primary Field/Group asslgnment(s) will be the specific discipline,
area of human endeavor, or type of physical object. The appllcatlon(s) will be cross-referenced with secondary Field/Group
assignments that will follow the primary postlng(s).
18. Distribution Statement. Denote public releasability, for example "Release unlimited", or limitation for reasons other than
security. Cite any availability to the public, with addresa, order number and price, If known.
19. a. 20. Security Classification. Enter U.S. Security Classification In accordance with U. S. Security Regulations (I.e., UNCLASSIFIED).
21. Number of pages. Insert the totsl number of pages,lncludlng Introductory pages, but excluding dlatrlbutlon IIst,lf any.
22. Price. Enter price In paper copy (PC) and/or microfiche (MF) If known.
tr. GPO: 1983 0 - 381-526 (8393>
OPTIONAL FORM 272 BACK
(4-77)
-------
EPA/ROD/R09-89/033
San Fernando Valley (Area 1), CA
Second Remedial Action
16.
Abstract (continued)
(SALs) in 48 percent of the SFVB's 120 production wells, and PCE levels exceeded SALs in
18 percent of the SFVB wells. In 1987 EPA selected a remedy to address another operable
unit in Area 1, specifically the threat of contaminated public water supply wells located
in the city of North Hollywood. The selected remedy for the North Hollywood operable
unit included the construction of an extraction and aeration facility to pump and treat
contaminated ground water in the North Hollywood area. The facility has been operational
since March 1989. The remedy selected for the Burbank operable unit will control the
migration of contaminated ground water in the SFVB where additional downgradient public
water supply wells are threatened by contamination and will aid in aquifer restoration in
the immediate Burbank area. The primary contaminants of concern are VOCs including TCE
and PCE.
The selected remedial action for this site includes pumping and treatment of ground
water contaminated with TCE exceeding 100 ug/l or PCE exceeding 5 ug/l using air or
stream stripping, with vapor phase GAC adsorption units if air stripping is used, and
discharge to the municipal water supply distribution system; and ground water monitoring.
The estimated present worth cost for this remedial action is $69,000,000, which includes
an estimated present worth O&M of $43,900,000 (for a 20-year period).
-------
San ~e1"DaD40 Valley Are. 1
superfund Si~e
Loa Angele. CoUD~, california
RECORD O~ DBCISIOB
for ~h.
BURBUK nLL ~IBLD
OPBRABLB tDI1:T
\
United states Environmental Protection Agency
Region. 9 - San Francisco, California
May, 1989
,
,.
" ", ..
-------
~ft'.
~~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
"EGION IX
215 Fremont Street
San Francisco. Ca. 9410&
Z 6 JUN 1989
MEMORANDUM
SUBJECT:
San Fernando Area 1 Site
Burbank Operable Unit
Record of Decision
Jeff Zelikson,~
Hazardous Wast~~~ent
Division
FROM:
TO:
John Wise
Deputy Regional Administrator
Please find enclosed for your concurrence the Final Recorq
of Decision (ROD) for the San Fernando Area 1 site, Burbank We~l
Field Operable Unit in Los Angeles County, California. We would
appreciate receiving your concurrence by COB Thursday, June 29,
1989 so the ROD can be transmitted to the RA for signature on
June 30. Please have your secretary contact Alisa Greene at
4-9096 so that your concurrence sheet can be collected after you
have signed it. .
Please sign 'below if you are in agreement with the following
statement:
The enclosed Record of Decision package for the San Fernando
Area 1 site, Burbank Well Field Operable Unit in Los Angeles
County, California has been reviewed and I concur with the con-
tents.
'.2". S'1
Date
& .
W '-LL
J Wise
Deputy Regional Administrator
-------
'-8'.
~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San Ff8nciaco. Ca. 94101
;0 1 .",..v .~~~
. I~.~.. .w..-;J
KBKORAHDUX
SUBJECT: San Fernando Area 1 Site,
Burbank Operable Unit Record ot Decision
FROM: dfi~«rrkson, Director
O--Hazardous Waste Management Division
Harry Seraydarian, Director
Water Management Division
TO:
Please find enclosed for your concurrence the Final Record
of Decision (ROD) for the San Fernando Area 1 Site, Burbank
Operable Unit in Los Angeles county, California. This document
was submitted for review by your staff and we know of no un-
resolved issues. If you have any questions about this ROD,
please contact Alisa Greene at 4-8015 or Jon Wactor (ORC) at
4-8042. Alisa would appreciate receiving this concurrence sheet
by COB Wednesday May 10, 1989 so the ROD can be transmitted to
the RA for siqnature. Please contact Alisa at the above phone
number so that your concurrence sheet can be collected atter you
have signed it.
Please sign below if you are in agreement with the following
statement:
;
\
The enclosed Record of Decision package for the San Fernando
Area 1 Site, Burbank Operable Unit in Los Angeles County,
California has been reviewed and I concur with the contents.
~
I I ,qSt:;
1f:zi-kL -eJ::.a. L-
~v Harry Seraydarian, Director
Water Management Division
/
-------
,,~,.
~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San FrancilCo. Ca. 94105
o 1 MAY 1S89
JlBKORANDUH
FROM:
San Fernando Area 1 Site,
Burbank Operable Unit Record of Decision
(~~~kson, Director
,fHazardous Waste Management Division
v
David Howekamp, Director
Air Management Division
SUBJECT:
TO:
Please find enclosed for your concurrence the Final Record
of Decision (ROD) for the San Fernando Area 1 Site, Burbank
Operable Unit in Los Angeles County, California. This document
was submitted for review by your staff and we know ot no un-
resolved issues. It you have any questions about this ROD,
please contact Alisa Greene at 4-8015 or Jon Wactor (ORC) at
4-8042. Alisa would appreciate receiving this concurrence sheet
by COB Wednesday May 10, 1989 so the ROD can be transmitted to
the RA for signature. Please contact Alisa at the above phone
number so that your concurrence sheet can be collected after you
have signed it.
Please sign below if you are in agreement with the following
statement:
The enclosed Record of Decision package for the San Fernando
Area 1 Site, Burbank Operable Unit in Los Angeles County,
California has been reviewed a~d I concur with the contents.
~fo~
Date
David Howekamp, Dir or
Air Management Divis on
-------
~ft'.
~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San FrancilCo. Ca. 94105
'0 1 MAY 193J
JlBMORANDUH
SUBJECT: San Fernando Areas 1 Site,
Burbank Operable Unit Record of Decision
/ ;~.cn:-~ .
~Jeff Zel~kson, D~rector
! Toxics & Waste Management Division
Gail Cooper, Acting Regional Counsel
Office of Regional Counsel
FROM:
TO:
Please find enclosed for your concurrence the Final Record
of Decision (ROD) for the San Fernando Area 1, Burbank Well Field.
Operable Unit in Los Angeles County, California. This document \
was submitted for review by your staff and we know of no un-
resolved iS5ues. If you have any questions about this ROD,
please contact Jon Wactor (ORC) at 4-8042 or Alisa Greene (T-4-1)
at 4-8015. Alisa would appreciate receiving this concurrence
sheet by COB Monday April 24, 1989 so the ROD can be transmitted
to the RA for signature immediately following. Please contact
Alisa so that your concurrence sheet can be collected after you
have signed it.
Please sign below if you are in agreement with the following
statement: .
The enclosed Record of Decision package for the San Fernando
Area 1, Burbank Well Field Operable Unit in Los Angeles
County, California has been reviewed and I concur with the
contents.
b J/'I!~
,
Date
Ga' ooper
Ac . 9 Regional Counsel
Office of Regional Counsel
I
I
I
I
I
I
-------
RECORD OP DSC1:SIOH
DBCLARA'1'1:0H
SITE NAME AND LOCATION
San Fernando Valley Basin Area 1
Burbank Operable Unit
Los Angeles County, California
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the San Fernando Valley Basin Area 1, Burbank Operable
Unit, in Los Angeles County, California, developed in accor-
dance with the Comprehensive Environmental Response, Compen-
sation, and Liability Act (42 U.S.C. Section 9601 ~ ~)
and the National Contingency Plan (40 C.F.R. section 300 ~
~). This decision is based on the administrative record
for these sites.
The State of California concurs on the selected remedy.
DESCRIPTION OF THE SELECTED REMEDY
The Burbank Operable Unit (OU) remedial action is the second
to be taken at the San Fernando Valley Basin (SFVB) Area 1
site. In a September 1987 Record of Decision (ROD)., EPA
selected a remedy to address the public health threat posed
by volatile organic compound (VOC) contamination of the Los
Angeles Department of Water and Power (DWP) public supply
wells located in the North Hollywood area. The North Hol-
lywood OU remedial action has been constructed and became
operational in March 1989. The remedial action selected in
this decision document - - the Burbank Operable Unit - - is
designed to achieve two objectives:
(2)
to partially control the movement and spread of ground-
water contaminants in the Burbank au area, while con-
tributing to aquifer restoration at the SFVB Area 1 Na-
tional Priority List (NPL) site; an~
to address the public health threat posed by contamina-
tion of the City of Burbank's public water supply wells
by providing residents in the area with a water supply
that meets State and Federal drinking water standards.
1)
1
-------
This remedial action for the Burbank Operable Unit addresses
a portion of the overall groundwater contamination problem
in the SFVB Area 1,2,3 and 4 sites. It will control the
migration of contamination in the groundwater basin where
additional downgradient public water supply wells are
threatened by contamination. It will also aid in aquifer
restoration in the immediate Burbank OU area. The basinwide
Remedial Investigation (RI) is currently being conducted by
DWP to define the vertical and areal extent of contamination
in the four San Fernando valley Superfund areas. EPA will
conduct the basinwide Feasibility study (FS) and write the
correspondinq Record of Decision. (EPA also has the lead on
the enforcement activities and community Relations.) The
basinwide RIfFS is expected to be released for public com-
ment in 1992. The remedial action selected in this Burbank
OU decision document will be incorporated in the remedial
action for all four SFVB NPL sites. .
The remedial action selected in this decision document in-
corporates the followinq components:
.
extraction of groundwater from the most hiqhly con-
taminated zones of the underlyinq aquifer using wells
that are strategically located to maximize the
efficiency of the system:
extraction to capture qroundwater containinq 100 ppb
or greater of TCE and 5 ppb or greater of PCE (flow
rate of the system is proposed to be 12,000 qpm);
.
.
constrUction of strippinq (either air or steam) units
to treat contaminated qroundwater:
installation of vapor phase GAC adsorption units to
control VOC air emissions if air stripping technology
is used:
.
.
installation of monitoring wells to be placed on the
border of the contaminant plume to monitor the extrac-
tion reliability of the system:
treatment of contaminated water, at the effluent
discharge point, to contaminant concentrations below
MCLs and SALs: and.
.
.
us. of the treated groundwater as a water supply for
Burbank's Public Service Department's customers by
feeding the treated water directly into Burbank's-water
distribution system. .
2
-------
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and state requirements that are
applicable or relevant and appropriate for this remedial
action, and is cost-effective. This remedy satisfies the
statutory preference for remedies which employ treatment
that reduces toxicity, mobility, or volume as a permanent
solution and alternative treatment (or resource recovery)
technolOCJies to the maximum extent practicable. As part of
the remedy, groundwater monitorinq will be conducted to
track contaminant levels in the Burbank Well Field and to
monitor the performance of the extraction and treatment sys-
tem to ensure adequate protection of human health and the
environment. Periodic reviews will be conducted to analyze
the effectiveness of the system.
M~:~.~
Reqional Administrator
3
-------
RECORD OP DECISION
DECISION SUMMARY
1.0
SITE LOCATION AND DESCRIPTION
The area around the Burbank Well Field, located in the San Fer-
nando Area 1 (North Hollywood) NPL site within the San Fernando
Valley Basin (SFVB), has been designated an Operable Unit (OU).
Figure 1 shows the location of the North Hollywood NPL site
within the SFVB. Figure 2 shows the boundary of the study area
for the OU within the North Hollywood NPL site and the ap-
proximate location of the proposed extraction wells. The entire
Burbank Well Field lies within the political boundaries of the
City of Burbank, California.
The SFVB is located in the Upper Los"Anqeles River Area (ULARA),
which consists of the entire watershed of the Los Anqeles River
and its tributaries. The ULARA encompasses approximately 328,500
acres, of which 122,800 acres are alluvial deposits which fill
the SFVB. The SFVB is bounded on the north and northwest by the"
Santa Susana Mountains, on the northeast by the San Gabriel Moun-
tains, on the west by the Simi Hills, and on the south by the
Santa Monica Mountains. These mountain ranqes are shown in
Figure 1.
Four distinct qroundwater basins are located within the ULARA:
the San Fernando (with 91.2 percent of the total valley fill, the
Verduqo (with 3.6 percent of the total valley fill), the Sylmar
(with 4.6 percent of the total valley fill), and the Eaqle Rock
(with 0.6 percent of the total valley fill). Because the SFVB
Area 1 NPL site is located within the San Fernando qroundwater
basin, the followinq discussion focuses on the San Fernando
qroundwater basin.
The qeoloqy of the SFVB qenerally consists of alluvial deposits
composed of unconsolidated qravels and sand interbedded with
lenses of silt and clay. The overlyinq alluvial deposits ranqe
in thickness from a few inches at the base of the mountains to as
much as 1,500 feet in the center of the SFVB. The Burbank Well
Field is located in the eastern portion of the San Fernando Val-
ley Basin (SFVB), which contains coarser sediments that transmit
water at hiqher rates than the western area of the SFVB. Most of
the production wells in the SFVB are located in this eastern
area. Results of aquifer testinq in the SFVB have shown that
qroundwater velocities in the eastern portion of the basin are
much qreater than in the western portion. Within the eastern
portion of the SFVB, the velocities are estimated to be between
300 "to 500 feet per year with localized velocities of more than
three feet per day near well fields.
1
-------
{).
~
,
J ..1\.
'I r-
; - "\ "J
£ ~..,J,-/
(""
l
,
..,
(
\
J
r-"
i
/
,.,- - "'"
<
\ II'" ItILU
......
)
a,..r \
"'\
(
"
\.,
ooJ ( I""'" "ONIC.. ..OUN' ...NI
/: ... -,..-"",)
"''v'-' "I ,,.,.""--".JV--""-"''''''''J'"'1.,''-
-- - l"..r- "-~
.....,.. IU...... "OU""'.'"
r---' ".....-",
r""'- ~ _r \_/-....
. ) ........__.I'-'w--,\~/ "-
..I \
r ..,- -./ ".J )
"... ,....,.., - - """-
( ,/\
--../ .>
/
cf
)
\
S-.I''-l,..... ..I"")
.- ---' ""---.....
r--"v
" .
/'
~
\
~
1..1t G""UIL "OUN' ....,
SC"lI ... 'I"
o
,
".000
\
"
-,
\
~
f
SOURCE: Jameli M. Montgomery. Consulting Engineers. Inc. 1987
-- ."IIII..ID IOUHDIIY
~ IOGI or YALLIY 'IU
1111 0111.. 'OUHOIIY
8... .., Of LADW"
--
FIGURE 1 lOCATION OF GROUNDWATER BASINS AND NPl SITES IN
UPPER LOS ANGElES RIVER BASIN
-------
:. PSD-18
LEGEND
LOS ANGELES
\:;TC; , =i.j~:;;;'F
il: H80~~=
\\J Aj~rt
% ~ ,"'"
o '"
~ '"
~/
o
o
o
C'
o
~......
...., "'
\
\
\
~\
''''t8\
PSD-12
. 8urbM'lk SupplV Well
E:J BurbM'lk Operabfe Unit Study Area
- - Approximlte Extent 01 TCE and PCE
Concentrltions ~ 100 IJ.g/I (Burbank
OUFS Report, October 19881
I f
-<
I PROPOSED
I EXTRACTION I
\ PSD-14A . / WELL FIELD
. .. ,
\ PROPOSED.'. .'. . ,
PSD-11 \ TREATMENT . .. ............
.PSD~ F~L~ I
~ -- PSD-1 0 -- - .... .... /
~---- ....;
PSD-11 A ....
. VICTORY BOULJEVARD
PSD-12
f"" ~"; .
0" ~,as PSD-6
en' C
- :,:0
, . as
Z. '>
~, :z
m: '
f"" :".'~
m.
en '.,
~
N
I
0 1000 2000 FEET
I , I
SCALE
FIGURE 2 8URBANK OPERABLE UNIT STUDY AREA. LOCATION OF BURBANK
SUPPL Y WELLS, PROPOSED EXTRACTION WELLS AND TREATMENT
FACILITY
-------
Historically, qroundwater recharge to the SFVB has occurred
through both natural recharge from precipitation and artificial
recharge from appli~d water and treated wastewater effluent. The
total storage capacity of the SFVB is approximately 3 million
acre-feet (acre-ft), two-thirds of which is located in the east-
ern portion of the basin. In 1979, the state Supreme Court
granted the City of Burbank the right to extract 20 percent of
the imported and reclaimed water for domestic use. CUrrently,
this 20 percent amounts to an average of 4,700 acre-ft per year.
The City of Burbank also has limited rights to physical solution
water, that is, water normally supplied to other parties but
which may be used by the City of Burbank upon paYment of
specified charges. In addition, the city of Burbank is entitled
to store water in the SFVB and receives a credit for recharging
treated wastewater effluent. As of March 1989, Burbank's water
credits were approximately 38,000 acre-feet.
The City of Burbank's production wells have been shut down be-
cause the water they produce contains trichloroethylene (TCE) and
perchloroethylene (PCE) in concentrations exceeding state and
federal guidelines. Consequently, the City of Burbank now im-
ports 100 percent of its water from the Metropolitan Water Dis-
trict of Southern Ca~ifornia (MWD). In 1987, the City of Burbank
imported approximately 23,100 acre-feet of water.
2.0
SITE HISTORY
"
In June 1986, at the request of the Los Angeles Department of
Water and Power (DWP) and the California Department of Health
Services (DHS), EPA designated four well fields within the San
Fernando and Verdugo Groundwater Basins as National Priorities
List (NPL) hazardous waste sites. Industrial chemicals have been
detected in groundwater from these areas. Although each well
field is listed separately on the NPL, EPA and DWP are managing
the investigation of the four sites as if they are one single,
large site.
The SFVB represents an important source of drinking water for the
cities of Los Angeles, Burbank, Glendale, and La Crescenta, and
provides these communities with enough water to serve ap-
proximately 600,000 residents.
Groundwater from the aquifers in the SFVB is used for commercial,
industrial and residential purposes, and is especially important
during years of drought. The groundwater that has become con-
taminated is difficult to replace. The current water supply from
surface water via the Metropolitan Water District (MWD) may not
always be. available in the future because of periodic drought
conditions and State and Federal water rights issues.
In late 1979, as a result of the passage of Assembly Bill 1803,
DRS requested that all major water purveyors using groundwater
conduct tests for the presence of certain industrial chemicals as
2
-------
part of a statewide groundwater quality surveillance effort.
These initial tests, completed in spring 1980, indicated that
hazardous substances -such as trichloroethylene (TCE) and
perchloroethylene (PCE), were present in concentrations above
state Action Levels (SALs) and Maximum Contaminant Levels (KCLs)
in a number of water production wells in the San Fernando Valley
Basin. Concentration levels in the wells have been increasing
since 1980.
In 1987, the primary contaminant, TCE, was found at concentra-
tions exceeding the state Action Level (SAL) in 48' of the SFVB's
120 production wells. In addition, PCE levels above state Action
Level were present in 18' of the SFVB wells.
At present, the City ot Los Angeles addresses vell contamination
by either shutting down heavily contaminated wells and providing
alternate sources of drinking water, or blendinq contaminated
water with other sources to achieve TCE and PCE concentrations in
the served water that are below state Action Levels and Federal
KCLs. Other communities, like the City ot Burbank, have turned
to the Metropolitan Water District of Southern California for
surface water to auqment their supplies.
In September 1987, EPA signed the North Hollywood OU Record of
Decision to construct an extraction and aeration facility, to
pump and treat contaminated groundwater in the North Hollywood
area within the SFVB Area 1 NPL site. EPA provided funds to DWP
through a cooperative agreement to implement this project. Also,
EPA has joined with DWP and DHS in a Three Party Agreement that
defines specific agency responsibilities, cost sharing, and other
applicable provisions for construction, operation, and main- -
tenance of this treatment system. The plant became operational
in March, 1989.
The Burbank Operable Unit (OU) will be the second OU in the SFVB
Area 1.
3.0
ENFORCEMENT
The SFVB NPL sites were first listed because of contaminated
public supply wells. At the time of listing, the sources of con-
tamination were unknown. EPA and the Los Angeles Regional Water
Quality Control Board (RWQCB) have and are continuinq to conduct
numerous activities to identify sources of groundwater contamina-
tion in-the San Fernando Valley Basin. The two agencies are
working cooperatively in source identification and enforcement
activities.
The RWQCB began source investigation activities in 1987 under the
AB 1803 program. Under this program, an area (typically one
square mile) surrounding contaminated public water supply wells
is established within which a door-to-door industrial survey is
completed. Inspections are conducted at all facilities poten-
ti~lly using solvents. Facilities that may have had a release
3
-------
due to their handling or storage practices are requested to con-
duct a site assessment for their facility. If soil contamination
is found expanded soil and/or groundwater investigations are re-
, .
quired. Later, a cleanup and abatement order may be 1ssued re-
quiring the site to be remediated.
In addition, the
activities under
sessment Testing
proqrams.
Between August 1987 and 1988, EPA issued 145 RCRA section 3007/
CERCLA Section 104 information request letters to tacilities
suspected of being users of chlorinated solvents in the San Fer-
nando Valley Basin. Based on the responses received and informa-
tion in state agency files, EPA issued 34 General Notice letters
informing companies ot their potential liability tor the cleanup
of the SFVB Area 1 and 2 NPL sites. On September 13, 1988 EPA
held an information meeting tor tacilities identified as PRP's
for the Burbank Well Field. To begin negotiations for cleanup of
the Burbank OU area, EPA sent Special Notice Letters pursuant to
CERCLA Section 122 in May 1989. Negotiations with PRP's are ex-
pected to end in september 1989. EPA and the RWQCB will continue
basinwide source identification and enforcement activities
throughout the basinwide RI/FS process.
RWQCB conducts source identification and cleanup
the Underground storage Tank, Solid Waste As-
(SWAT), and Waste Discharge Requirements
4.0
COMMUNITY RELATIONS
The comment period for the OUFS Report and the Proposed Plan
opened on October 19, 1988 and closed December 2, 1988. A public
meeting was held on November 9, 1988 at the Thomas Jefferson
Elementary School in Burbank and was attended by approximately 65
people.
Prior to the beginning of the public comment period, EPA and the
City of Burbank published a notice both in the Los Angeles Times
and the Burbank Leader. The notice briefly described the
Proposed Plan and announced the public comment period and the
public meeting. The notice also announced the availability of
the Proposed Plan and the Draft OUFS Report for review at the in-
formation repositories established at the Burbank Public Library,
California State" University - Northridge Library, Los Angeles
Department of Water and Power Library and the University of
California - Los Angeles (UCLA) Research Library. (See fact
sheet 11 or '2 for the locations.)
A fact sheet describing the Proposed Plan was delivered to the
information repositories. Copies of the fact sheet were also
mailed to the EPA general mailing list tor the San Fernando Val-
ley Basin sites, which included about 800 members of the general
public, elected officials, agency, ,and media representatives.
Fact sheets were also hand-delivered to residents near the
proposed treatment facility location. In addition, the Burbank
Water System Manager made an announcement of the public meeting
4
-------
- -~--_.__.-~-~
and presented the Proposed Plan on local cable television. He
also had fact sheets available for distribution at the Burbank
Public service Department (PSD). Additionally, news stories ap-
peared in the local newspaper, The Burbank Leader, and 1hA ~
Anaeles Times and ~ Dai1y News.
From March 1987 to the present, EPA and DWP have met bimonthly or
quarterly with members of the community Workgroup (CWG). The
members include elected officials, industry representatives,
community-based public interest representatives, and residents
from the San Fernando Valley/Los Angeles area. The purpose of
the CWG meetings have been to discuss technical issues and
management strategies involving the San Fernando Valley Basin
Superfund project. CWG members have been updated on agency
activities and have had the opportunity to express their concerns
about the Burbank Operable Unit throughout the Remedial
Investigation/Feasibility Study (RI/FS) process. EPA transmitted
copies of the OUFS Report to CWG members for their review and
comment.
The minutes of the community meeting were transcribed. The
transcript and the attached response summary provide responses to
the community comments submitted in writing during the public
comment period, as well as oral comments made at the November 9,
1988 public meeting. The public transcript and response summary
are part of the Administrative Record.
\
5.0
SCOPE AND ROLE OF THE OU WITHIN THE BASINWIDE SITE STRATEGY
As discussed in the Site History section, EPA is treating the
SFVB Area 1 - 4 NPL sites as one large site. EPA and DWP are
conducting one basinwide RI/FS for the 4 NPL sites. The RI/FS
for the San Fernando sites was initiated in 1987. The major goal
of the RI is to identify the sources, pathways and receptors of
the contaminants and to characterize the nature and extent of the
public health and environmental problems presented by the con-
tamination. Major components of the RI include soil gas surveys,
installation of monitoring wells, regional and site specific
groundwater flow and solute transport modeling of the basin and
sampling of the groundwater and soil. The FS will evaluate the
necessity for and proposed extent of remedial actions. DWP has
the lead for the RI and EPA has the lead for the FS.
EPA previously selected a remedy to address the public health
threat posed by contamination of the public water supply wells
located in the city of North Hollywood which lies within the SYVB
Area 1 NPL site. The North Hollywood OU project was designed to
control the migration of contaminants in the groundwater, while
initiating aquifer restoration in the area. The contaminant
plume has already affected numerou~ groundwater production wells
in Area 1 of the SFVB and has precluded their use for public
water supply. Construction and operation of the Burbank project
is intended to further address the immediate problem in Area 1
5
-------
while a more complete investigation of the Valley's overall
groundwater problem is being done through the overall Remedial
Investigation/Feasibility study (RI/FS) process.
The Burbank response action is designed to achieve two objec-
tives:
.
To partially
contaminants
tributing to
Basin Area 1
control the movement and spread of groundwater
in the Burbank Operable Unit area, while con-
aquifer restoration in the San Fernando Valley
NPL site.
To address the public health threat posed by contamination
of the City of Burbank's public water supply wells by
providing residents in the area with a water supply that
meets State and Federal drinking water standards.
All of the City of Burbank's PSD wells are shut down due to the
VOC contamination. Moreover, other downgradient public water
supply wells are potentially threatened by contamination in the
Burbank OU area. The response action selected in this decision
document will be incorporated into the EPA response action for
the entire San Fernando Superfund Areas 1-4.
.
As the operable units are addressing part of the overall problem, ,
the RI/FS and subsequent ROD are intended to address the 4 SFVB \
NPL sites and the areas which impact these sites.
6.0
SUMMARY OF THE BURBANK OU SITE CHARACTERISTICS
Contamination of groundwater from the San Fernando Valley Basin
wells was first discovered in 1980. Since then, various monitor-
ing programs have been implemented. Results of LADWP's
groundwater monitoring program conducted from 1981 through 1987
revealed that TCE and PCE had contaminated approximately 50 per-
cent of the water supply wells in the eastern portion of the
SFVGB at concentrations exceeding State and Federal drinking
water standards. Figure 3 presents the approximate location of
the TCE and PCE plumes in 1987.
The City of Burbank's wells are sampled routinely as part of the
monitoring of 112 wells in the San Fernando Valley Basin. The
concentration ranges of TCE and PCE found in the Burbank wells
are presented in Tables 1 and 2. Several other VOCs have also
been detected in the Burbank wells, including acetone, toluene,
methylethylketone, carbon tetrachloride and trihalomethanes
(THMs) which include chloroform, bromodichloromethane,
dibromochloromethane, and bromoform. The concentrations of these
other VOCs have not exceeded State Action Levels (SALs) or
Federal MCLs. The Burbank wells have also been sampled for trace
metals and other water quality parameters. Although groundwater
6
-------
/
"
//
(
,,-.
,I""'."' I
!~ ~ I
)
!
\
\,
-.
",............
"
-,
\
NOITH !ll.l.nQDO
,
\
\
I
'- !
,~
"
.
i""
-.
"-
-',
.
~,
~.......... .
. - ----
-
--
.'
"
L£HIID
/'..
.'.I.L'CIC 1"."1'
rlueus
/V
/v
"L ...."I. (s
@
c::J IIII.CI "'C,,,
C3 '"7 rC[ 'IUD( ()MCL. 5PC1t11
c::J '"7'C[ '\11'( I:>SAL.4 PCItII
.
-
-
-
-....
./
FIGURE 3 SAN FERNANDO VALLEY
1987 TCE AND PCE PLUMES
- . ~;~.
. ",,-:. .
.. .
'.',:" ,', -;"" '.'
- ~ .'.. " .
-------
from one well had elevated concentrations of iron, the quality of
the treated water from these wells is expected to meet Title 22
drinking water standards for metals.
The tables can be summarized as follows;
o
TCE and PCE are the principal contaminants of concern. TCE
and PCE are industrial solvents commonly used in the metal
degreasing and dry-cleaning industries. Both are animal
carcinogens and are suspected ot being carcinogenic t~
humans. The Federal MCL tor TCE is 5.0 ug/L. The SAL for
PCE is 4.0 ug/L and the proposed State MCL is 5 ug/L.
o
Other VOCs detected in trace quantities include methylene
chloride, toluene, acetone, carbon tetrachloride,
methylethylketone, and the THMs (chloroform, bromodichloro-
methane and dibromochloromethane). Methylene chloride is an
industrial solvent commonly used in laboratories. It is
carcinogenic in animals and is also a suspected human car-
cinogen. The SAL for methylene chloride is 40 ug/L.
Toluene is an industrial solvent and a gasoline additive.
It is carcinogenic in animals and is also a suspected human
carcinogen. The SAL for toluene is 100 ug/L. Acetone is
used as an industrial solvent and in the production of
lubricating oi1s. A SAL for acetone has not been estab-
lished. Carbon tetrachloride is an industrial solvent. It
is carcinogenic in animals and is a suspected human car-
cinogen. The Federal MCL for carbon tetrachloride is 5.0
ug/L and the Federal MCLG is set at 0 ug/l.
Methyethylketone is used as a solvent in nitrocellulose
coatings and vinyl film manufacturing and in cements and
adhesives. A SAL has. not been established for
methylethylketone. Most THMs found in finished drinking
water are unwanted by-products caused by the chlorination
process. THMs are formed by the chemical attack of
hypochlorite on fulvic and humic acids. Chloroform also has
a variety of industrial uses, including use as a solvent in
lacquer manufacture. Chloroform is a suspected human car-
cinogen. The MCL for the sum of THMs is 100 ug/L. .
The wells with the shallowest perforated intervals (PSD 10
and PSD 12) and the ones that are the furthest upgradient
(PSD 9, PSD 10, PSD 1lA, PSD 13, PSD 14A, PSD 17) have his-
torically had the highest concentrations of TCE and PCE. In
contrast, PSD 6, PSD 7 and PSD 15 have low or nondetected
concentrations of VOCs. PSD 6 is likely at the edge of the
lateral extent of th~ VOC plume, and PSD 7 and PSD 15 are
likely at the leading edge of the plume. For relative loca-
tion ot w~lls see Figure 2.
"
o
7
-------
TABLE 1
SUMMARY OF VOLATILE ORGANIC CHEMICALS DETECTED IN
BURBANK PUBLIC SERVICES DEPARTMENT WELLS
6A
7
9
'J.'Ct; t'Ct;
Range of Range of
Concentration Concentration
(ug/L) (ug/L)
ND-1.0 ND-1.0
ND--4.9 ND-}. 0
15-61. 6 144
110-1800 56~590
10-21 18-35
0.7-38 1. 0-33
0.1-34 NO-52
76 140
ND-4.1 ND-1. 0
5.8 5.3-8.3
ND-38 ND-63
other (ug/L)
Notes
Burbank.
PSD
Well. No.
Two data points
(1981 , 1984) then
well abandoned
10
11A
12
Carbontetra-
chloride 3.4
Trend tiward
ncreas ng contamin-
ation s nce 3/83
Trend ttWard
ncreas ng contamin-
ation s nce 4/85
Average of 19
samp~es analyzed by
Lockheed
.13
Chloroform
2.0,
14A
15
17
18
Trace concentrations
of Chloroform
Dichlorobromomethane
TCE - Trichloroethene
PCE = Tetrachloro~then~
NO = Below Detection Limit
Sources: 1. LADWP, Re~edial Investigation of San Fernando Valley Groundwater Basin,
Current Situat on Repor~, January 29, 1988.
2. JMM. GC,MS Analysis of Volatile Organics for Selected Burbank Wells.
1987-19 8. .
--
-------
"
TABLE 2
SUMMARY OF VOLATILE ORGANIC CHEMICALS DETECTED
DURING CONTINUOUS MONITORING
CITY OF BURBANK
'l'l:~ l"l:~ veje~t:lon
,sam~lin9 Concentration Concentration L m ts
Da e (ug/L) (ug/L) Other (ug/L)
6/3/87 ND ND 0.5
7/2/87 ND ND 0.1
8/4/87 ND ND 0.1
9l'3~87 ND ND 0.5
101 '87 ND NO 0.5
10/2 '87 ND NO 0.1
12~1' 7 NO ND --- 0.1
ND NO 0.1
~~9~8a ND ND 0.5
5/29'87 3.7 ND 0.1
7/71 7 4.9 1.0 0.1
8/4/87 1.0 ND 0.1
9l'3~87 1.0 ND 0.5
10/ /87 0.5 ND Methylethylketone 0.5
10/28'87 0.8 ND (1.2) 0.1
12~lL 7 0.8 ND 0.1
1/ /88 0.4 ND Toluene 0.1
2/9/88 ND ND (0.8) 0.5
7/2/87 1800 590 10
10/28'87 31 29 1.0
12/1/ 7 22 17 Carbon Tetrachloride 0.5
(3.4)
1/5/88 38 31 Chloroform 1.0
(1. 2t
2/9/88 24 16 Carbon Tetrac loride 2.5
(3.3)
6/3/87 1.3 1.3 0.5
7/2/87 10 15 Carbon Tetrachloride 0.1
Chloroform
Well
No.
6A
7
10
12
13
1 No value r~po~ted ~eans that the VOC was detectable, but not quantifiable
2 Sompl ng dlrflcultles on this date make results questionable. Use data wIth
tloh.
TCE = Trichloroethene
PCE = Tetrachloroethene .
NO = Below Detection Limit
Source = City of Burbank (Analyzed by Montgomery Laboratories)
qualifica-
-------
TABLE 2 - continued
SUMMARY OF VOLATILE ORGANIC CHEMICALS DETECTED
DURING CONTINUOUS MONITORING
CITY OF BURBANK
'l'Ct; }lCt; ue~
Concentration Concentration L m ts
(ug/L) (ug/L) Other (ug/L)
21 25 Chloroform 1.0
(2.0)
Acetone
34 52 (43) 12.5
---
24 43 Methylethylketone 2.5
24 48 1.0
20 38 0.5
22 37 1.0
0.4 ND 0.1
1.0 ND 0.1
1.0 0.2 0.1
1.0 ND 0.5
0.9 ND 0.5
1.0 0.2 0.1
0.9 NO 0.1
0.7 NO 0.1
0.5 NO 0.5
ND 0.5 0.5
0.9 0.4 0.1
13 32 1.0
37 58 12.5
38 63 , MethIlethYlketone 5.0
33 10 Bromod chloromethane 1.0
20 35 Bromod chloromethane 0.5
Chloroform
6.0 13 Dibromochloromethane 1.0
Chloroform
Bromodichloromethane
2.3 2.9 Toluene (0.51 0.5
Methylene Cfilor de
(0.9)
"
"'-.
Well
No.
Sampling
Date.
8/4/87
15
913/87
10/.5/87
101.211187
12/1'87
1/5/ 8
5/.27'87
7/2/. 7
8/4/81
9L3/87
10/.5/87
101.28'81
12/1/ 7
1/.5/.88
2/9/88
6/.3'/.87
71.2/87
81.71.87
9L3/87
1015'87
101.2 '87
12/1/ 7
1/5/882
18
2/9/88
1 No value r~ported ~eans that the VOC was detectable, but not quantifiable
2 S,mpl ng d1Yficult1es on this date make results questionable. Use data with
t10n.
TCE = Trichloroethene
PCE = Tetrachloroethen~
ND = Below Detection L1mit
Source = City of Burbank (Analyzed by Montgomery Laboratories)
qualifica-
.-'
-------
7.0
SUMMARY OF SITE RISRS
The purpose of the risk assessment is to evaluate the public
heal th and environmental risks posed by the Burbank OU site. For
the risk assessment evaluation, both a baseline risk assessment
and a risk assessment for Alternative 5, phase 1 were conducted.
This section describes the risk assessment process and results.
Baseline Risk Assessment: Analytical results from groundwater
samples collected from City of Burbank production wells (PSD 6,
7, 10, 12, 15, and 18) between May 1987 and June 1988 form the
groundwater database that were used in the Baseline Risk Assess-
ment. In the Baseline Risk Assessments the current risks posed
by domestic. use of groundwater from the Burbank Well Field were
estimated. The well field is currently not in use as a water
supply. As a result, no receptors are currently being exposed.
A quantitative risk assessment was developed for two exposure
source terms. One source term, "the potential average exposure,"
or the "most likely case" assumes that groundwater concentrations
in the Burbank Well Field are at the geometric mean levels
(averaged by well) and averaged across wells (arithmetic mean of
geometric mean£). The other source term is a nplausible worse-
case" and assumes that the receptor is exposed to the maximum
contaminant level detected in anyone well.
Assuming that groundwater from the well field is used for a
lifetime, an individual receptor would be exposed to an excess
cancer risk range (i.e.4 above the na~ural background risk) of
approximately 2.0 x 10- to 1.7 x 10-. These risk values are at
the highest range allowed by most regulatory ag~ncies. For c9m-
parison, a lower excess risk range of 1.0 x 10- to 1.0 x 10- ,
with 10-6 departure, is used in CERCLA as a site remediation tar-
get.
The Baseline Risk Assessment concluded that, under the conditions
postulated in the exposure assessment, the use of untreated
groundwater from the Burbank Well Field as a domestic water
supply for a lifetime would present an unacceptably high cancer
risk. This conclusion assumes that the existing chemical
analytical database sufficiently characterizes the groundwater
contamination present.
It should be noted that the highest concentration levels
found in the area were not used for the baseline risk assessment.
In 1987, monitoring' wells located near the Burbank well field
showed concentrations as high as 18,000 ug/l for PCE and 3600
ug/l for TCE. Moreover, in February 1989, Lockheed Aeronautical
Systems Company (LASC) was extracting' groundwater with concentra-
tions as high as 10,000 ppb for PCE and 2000 ppb for TCE at their
11
-------
treatment facility located within the Burbank OU area. If these
concentrations observed at LASC had been used, the baseline risk
assessment would have' shown even higher risk.
Alternative 5. Dhase 1 Risk Assessment: A risk assessment was
performed for Alternative 5, phase 1 (extracting and treating
12,000 qpm with dual stage air strippinq and vapor phase GAC).
Both LASC monitoring well data and Burbank production well data
were used. (See the Burbank OUFS report for tables and more
information.) The contaminant mass was calcul!ted from estimates
of the concentrations in the groundwater (uq/M ) which would
likely be extracted and treated by the system. The expected
chemical mass discharged to the atmosphere (g/sec) was calculated
with respect to the three different air pollution control op-
tions. The expected chemical mass discharge was input to an at-
mospheric dispersion model which calculated concentrations of the
chemicals in the air (ug/MJ). The concentration in the air was
modeled to be spatially distributed in a two-mile radius sur-
rounding the proposed air stripper location (see Figure 2). The
population estimated to reside within two miles of the site in
1990 is 94,195. The 2010 population is expected to be slightly
lower at 93,765.
In the health risk assessment, three air stripping air emission
control options for Phase I of Alternative 5 were examined:
"
o
o
No air pollution control;
air emission controls leading to 90 %
removal of VOCs; and
air emissions control leading to 99 ,
removal of VOCs.
o
Two types of carcinogenic risk calculations were performed. The
first type is independent of population and is termed the maxi-
mally exposed individual (MEI). The MEI is the site of highest
estimated potential exposure calculated. The MEI is independent
of whether the site is inhabited. The total cancer risk to the
MEI is examined by the South Coast Air Quality Management Dis-
trict (SCAQMD) to ascertain if6a proposed project is expected to
exceed a total risk of 1 x 10-. The air modeling results con-
clude that the MEI occurs at a distance 0.1 to 0.2 miles from the
site. The total excess estimated cancer risk (to the MEI) for
the three different air emission control options are as follows:
o no air pollution control: 5.98 x 10-6
o 90' removal of VOCs: 4.07 x 10-7
o 99 % removal of VOCs: 4.07 x 10-8.
The second type of risk calculation presented was for a popula-
tion. For the population risk, the,individual risk level is mul-
tiplied by the size of the potentially exposed population. The
air .concentrations generated by the air model, expressed as the
associated risk, are superimposed on the 1990 and year 2010
population data for a two-mile radius. The predicted total ex-
12
-------
cess population cancer burden in a two-mile zone under conditions
of the various air emission control options estimated for the
1990 population data are as follows:
o No air pollution control: 0.04 cancers/population:
o 90t removal of VCcs: 0.003 cancers/population: and
o 99% removal of VOCS: 0.0003 cancers/population.
Thus, less than one excess cancer would be expected to occur in
the population due to the emissions from the project.
Non-carcinogenic risks or the "Hazard Index" (HI) were calculated
by an approach similar to that used for carcinogens. The rule of
thumb is that HI should not exceed one. The HIs calculated are
several orders of magnitude less than one, for any of the three
air emission control options examined. As a result, the pre-
dicted exposure to receptors due to the non-carcinogens emitted
from the air stripping towers were concluded to be insignificant
from a human health perspective. (See the Burbank OUFS report for
more detail on the risk assessment analaysis.)
Although uncontrolled emissiogs are near EPA's acceptable excess
cancer risk number of 1 x 10- , it is unacceptable to not control
emissions because of the poor air quality in the Burbank area.
Moreover, emission controls would be needed to comply with re-
quirements of the SCAQMD Regulation 13. See section 9, Com-
pliance with ARARs for a more detailed'explanation of the ARARs
and other information To Be Considered (TBC).
\
8.0
DESCRIPTION OF ALTERNATIVES
Many technologies were evaluated based on these criteria during
the Feasibility study. Treatment technologies that may be ap-
plicable to groundwater contaminated with volatile organic com-
pounds, primarily TCE and PCE, were screened based on two
criteria: (1) their ability to meet the remedial' response objec-
tives; and, (2) the applicability and feasibility of the technol-
ogy to the site conditions.
After the initial screening, six alternatives were evaluated
using the following superfund guidance criteria: technical and
adminstrative feasibility, capital costs, operation and main-
tenance costs, environmental impacts, protection of public health
and the environment, compliance with federal and state regula-
tions, and community and state acceptance.
The following is a list of the alternatives analyzed and compared
during the FS and found in the Burbank OUFS Report:
Alt 3
No action
Extract from
and Reuse
Extract from
Reuse
existin~ wells/Treat/Reinject
new wells/Treat/Reinject and
Alt 1 -
Alt 2 -
,
13
-------
Alt 5 -
Extract from new and existing wells/Treat/
Spread and Reuse
Extract from new and existing wells/
Treat/Reuse
Extract from existing wells/Treat/Reuse.
Alt 4 -
Alt 6 -
The following descriptions give a summary of the alternative fea-
tures. See the Burbank OUFS Report for more detail.
Alternative 1 - No Action Alternative
The No Action alternative served as a basis for comparing the
other remedial alternatives. This alternative is evaluated to
determine the risks that would be posed to public health and the
environment if no action were taken to treat or contain thecon-.
tamination. This alternative would include quarterly monitoring
of the ten existing Burbank Public Service Department (PSD)
wells. The monitoring program would help to ensure that
groundwater would not be used when concentrations of VOCs exceed
MCLs and SALs. It should be noted that currently all of the City
of Burbank's wells have been shut down due to the VOC contamina-
tion and the City buys all its water from the Metropolitan Water
District (MWD).
The Federal and State MCLs are relevant and appropriate in the
aquifer.
Alternatives 2 - 6
Alternatives 2 through 6 include extraction of groundwater,
treatment with air stripping with vapor phase GAC adsorption
units, and discharge of the treated groundwater. The following
is a description of the treatment system proposed in the
Feasibility Study Report.
Air stripping (or aeration) is a method that removes VOCs from
water by volatilization at the air-water interface. The pumped
groundwater is run down through a vertical column which contains
a packing medium. The medium provides surface area over which a
countercurrent flow of air is introduced. The contaminant is
transferred from the water to the air and thus removed from the
water. 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 and is commonly used to -
treat groundwater.
Dual stage air stripping uses two airstripping towers in series
to remove contaminants from water. ' Treated water from the base
of the first air stripping tower is pumped to. the top. of the
second air stripping tower and aerated a second time. Dual stage
/
14
-------
air stripping is preferable to single stage air stripping because
the contaminated water here is expected to have high levels of
TCE and PCE.
Air stripping has two drawbacks with respect to public health and
the environment. First, there is the possibility of low-level,
longterm cancer risk to the local POPUlation due to the release
of volatilized contaminants into the air. Secondly, this release
of contaminants also contributes to air quality degradation which
in turn affects human health and the environment.
Therefore if dual stage air strippers are used as the treatment
technology, vapor phase GAC adsorption units will be installed to
remove 90 - 99% of the vacs discharged to the air. Air emission
controls would minimize the negative impact on public health and
the environment. (See Section 9, Compliance with ARARs, Com-
munity Acceptance and State Acceptance, for more detailed support
documentation.)
It has been determined that pure product in the form of TCE and
PCE (U210 and U228) are contained in the groundwater making RCRA
Section 261.33 applicable for this action. The groundwater also
contains spent TCE and PCE that was used in degreasing. The
listing in 40 C.F.R. Subpart D Section 261.31 that pertains to
spent halogenated solvents used in degreasing is FOOl. This
listing requires knowledge of the percent solvent by volume
before use. This information is unavailable for the Burbank au
making the RCRA FOOl listing not applicable but relevant and ap~
propriate for this action.
In Alternatives 2-6, the spent carbon is considered a RCRA waste
or it is a mixture of the solid waste carbon and the RCRA listed
wastes FOOl, U210, and U228 (40 C.F.R. Section 261.3(a)(2)(iv)).
Therefore the carbon must satisfy the requirements of 40 C.F.R.
Part 263 to be shipped off site for regeneration.
The Federal and State MCLs are relevant and appropriate in the
aquifer. Moreover, the MCLs are the ARARs that will be met in
the treated water. This water will be either reinjected, spread,
or reused as a drinking water source.
Alternative 2 - Extract from Existinq Wells. Treat. Reiniect
and Reuse
This alternative includes pumping 16,000 gpm of water from eight
Burbank PSD wells (located west of the highest known TCE and PCE
contamination) to an existing equalization basin, which would be
retrofitted, to provide a uniform feed to the treatment facility.
The water would be treated by eight sets of ,dual stage air strip-
pers (AS) with vapor phase GAC adsorption units for the off-gas.
Treatment efficiency could produce effluent water of a quality
- that meets or exceeds all federal and state applicable or
relevant and appropriate requirements (ARARs). Four thousand
15
-------
gallonS per minute (4000 gpm) of the treated water would be in-
troduced into Burbank's existing distribution system for reuse.
The remainder of the treated water would be injected into the
aquifer downgradient of the VOC plume to reduce VOC movement.
The reinjection would help enhance plume containment and aquifer
restoration. The treated water would be delivered to the injec-
tion field by a new pipeline to be constructed along Victory
Boulevard.
After 20 years of extraction, concentrations of TCE and PCE in
the groundwater would still exceed MCLS. Since the plume migra-
tion would be diverted from its current path towards Burbank's
production wells, the PSD wells could produce groundwater with
higher concentrations of PCE and TCE.
This alternative would be
in the aquifer from 3,200
ternative would partially
plumes.
expected to reduce TCE concentrations
ppb to 590 ppb in 20 years. This al-
arrest the migration of the TCE and PCE
Six monitoring wells would be installed to monitor the perfor-
mance of the system.
Since the groundwater has been determined to contain RCRA listed
wastes, it must satisfy the requirements of RCRA Land Disposal
Restrictions (LDR), 40 C.F.R. Section 268. The LDR defines the \
requirements for reinjection or land disposal. Therefore, the
water must be treated to meet the Best Demonstrated Available
Treatment Technology (BDAT) standards for spent PCE and TCE which
are .079 ppm PCE and .062 ppm TCE (40 C.F.R. Part 268.42). Ap-
proval for reinjection would also be needed from the California
Regional Water Quality control Board - Los Angeles Region.
Approval for reuse would be required by California Department of
Health Services (DHS) and the City of Burbank. EPA, DHS, and the
City have already begun discussions over the possibiltiy of the
City's reuse of the water.
There are some technical concerns over the operation of injection
wells due to the uncertainities of the contamination plumes and
operational effectiveness of injection wells.
Alternative 3 - Extract from New Wells. Treat. Reiniect
and Reuse
This alternative is similar to Alternative 2 except that ten new
extraction wells would be constructed to extract the 16,000 gpm
of contaminated groundwater. Although the cost of installing ex-
traction wells would be greater than pumping the existing wells,
the new wells would be optimally located to maximize the removal
of contaminants from the groundwater. The treatment, disposal,
and monitoring technologies would be the same as those employed
.in Alternative 2.
16
-------
This alternative is estimated to reduce TCE concentrations from
3200 ppb to 81 ppb in the first 10 years, and more thereafter.
It is estimated it would reduce PCE concentrations from over 4000
ppb to 30 ppb'in 20 years. Alternative 3 would be successful in
halting plume migration and in mitigating the VOC contamination
(contributing to aquifer restoration).
Since the groundwater has been determined to contain RCRA listed
wastes, it must satisfy the requirements of RCRA Land Disposal
Restrictions (LDR), 40 C.F.R. Section 268. The LDR defines the
requirements for reinjection or land disposal. Therefore, the
water must be treated to meet the Best Demonstrated Available
Treatment Technology (BDAT) standards for spent PCE and TCE which
are .079 ppm PCE and .062 ppm TCE (40 C.F.R. Part 268.42). Ap-
proval for reinjection would also be needed from the California
Regional Water Quality Control Board - Los Angeles Region.
Approval for reuse would be required by California Department of
Health Services (DHS) and the City of Burbank. EPA, DHS, and the
City have already begun discussions over the possibility of the
City's reuse of the water.
There would be significant gains in aquifer restoration and con-
trol of the plume migration with this alternative.
Alternative 4 - Extract from New and Existina Wells/
. Treat/SDread and Reuse
\
.The major features of this alternative include extraction of
16,000 gpm from 10 new wells and 6,000 qpm from 5 existing wells,
treatment with either dual stage or single stage AS with vapor
phase GAC, reuse of 4000 gpm by the City of Burbank and discharge
of 18,000 gpm to spreading grounds for recharge. Six monitoring
wells would be installed to assess the effectiveness of the sys-
tem.
Alternative 4 was developed to compare the option of groundwater
recharge by spreading with groundwater recharge by injection.
This comparison addresses uncertainties associated with the
capacity, operation and maintenance of injection wells used in
Alternatives 2 and 3, and the overall uncertainties associated
with the characterization of plume contamination.
Because the treated water would not be reinjected into the
aquifer downgradient of the VOC plume as in Alternatives 2 and 3,
the extraction rate of contaminated groundwater would have to be
higher to achieve a similar gradient reversal. In this alterna-
tive, the water from ten new extraction wells and five existing
Burbank PSD wells would be pumped to an existing e4ualization
basin, which would be retrofitted, to deliver two treatment
streams to the treatment facility. The water would be treated by
six sets of dual stage carbon air 'filtering units and five
. single-stage air strippers with carbon air filtering units,
17
-------
depending on the amount of water flowing into the system. Each
treatment module would be designed to treat the water and air to
meet the ARARS and TBCs (see Section 9, Compliance with ARARs).
Since the groundwater has been determined to contain the RCRA
listed wastes FOOl, U210 and U228, it must be treated to "no
longer contain" these listed wastes before being spread for
recharge. (See Memorandum from Marcia E. Williams, Office of
Solid Waste Director, to Patrick Tobin, Waste Management Division
Director, regarding RCRA Regulatory Status of Contaminated Ground
Water, November 13, 1986.)
Approval for reuse would be required by California Department of
Health Services (DHS) and the City of Burbank. EPA, DHS, and the
City have already begun discussions over the possibility Of the
City's reuse of the water. .
This alternative is estimated to reduce TCE concentrations from
3,200 ppb to 122 ppb in 10 years and more thereafter. PCE con-
centrations are estimated to reduce from over 4000 ppb to 39 ppb
in 20 years. There would be significant "gains in aquifer res-
toration and control of the plume migration with this alterna-
tive.
The OUFS Report determined that spreading basins may be more
reliable than injection wells.
Alternative 5 -
Extract from New and Existina Wells/
Treat/Reuse
This alternative uses the same extraction, treatment, and .
monitoring technologies as those specified in Alternative 4.
This alternative is unique in that all of the treated water would
be used for potable water supply. The treated water would be at
or below the federal and state MCLs and SALs (ARARs).
A portion of the treated water would be introduced into the Bur-
bank PSD's existing dist~ibution system for reuse, which would
meet the City of Burbank's current average daily demand (12,000
gpm). The remainder of the treated water (10,000 gpm) could be
introduced into the Metropolitan Water District (MWD) distribu-
tion lines.
Under this arrangement, the parties involved would have to enter
into agreements for this exchange because the San Fernando Valley
Groundwater Basin is an adjudicated basin and the net .extraction
of groundwater in this alternative would exceed the Burbank PSD's
pumping rights. AlSO, MWD does not have any pumping rights.
However, instutitional arrangements could be worked out between
the LADWP and the other parties, since LADWP does have pumping
rights. Preliminary discussions with the City of Burbank and
,.
18
-------
LADWP have been initiated and the parties are in agreement that
adminstrative agreements could be arranged (for the reuse of
12,000 gpm).
Alternative 5 could be implemented in two phases. Phase 1 would
consist of extracting 12,000 gpm from new wells, treating with
dual stage AS with vapor phase GAC, and reusing the treated water
by the City of Burbank. Phase 2 could consist of extracting the
remainder 10,000 gpm (total 22,000 gpm) from new and existing
wells, treating with AS with vapor phase GAC adsorption units and
reusing by MWD customers.
It is estimated that Phase 1 would control most of the plume
migration (100 ug/l TCE plume boundary and 5 ug/l PCE plume
boundary) while aiding with aquifer restoration and the total
project (phase 1 and phase 2) would reduce concentrations to the
same levels as Alternative 4.
Due to the large size of the total project, and the uncer-
tainities associated with the modeling and extent of contamina-
tion, EPA believed it was important to look at phasing Alterna-
tive 5; thereby, initiating the necessary remediation, while
conducting further evaluations to refine technical features in
order to maximize the effectiveness of the total project.
Alternative 6 - Extract from Existina Wells/Treat/Reuse
The technical features of this alternative include extracting
4000 gpm from two existing Burbank PSD wells, treating the water
with dual stage AS with vapor phase GAC adsorption units, and
reusing the treated water by the City of Burbank.
This alternative would not restrict the plume's migration, nor
would it significantly aid in aquifer restoration.
9.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Th~s section provides a summary of the advantages and disad-
vatages of each of the alternatives' performance under the nine
evaluation criteria.
Table 3 provides a summary of the analyses of alternatives. The
alternatives were evaluated based on the following criteria for
conducting feasibility studies:
(1) overall protection of human
environment,
(2) short term effectiveness in
health and the environment,
(3) long-term effectiveness and
protecting human health and
(4) compliance with ARARs,
health and the
protecting human
permanence in
the environment,
/
19
-------
IL --~"-
Tabl. 3
Summary and Costs of AltemaUves ..-
.,:.::}/<::::,=::::::s.:::::::....::.:
.
.
2
a
&ncr ,..ooo~ tam
'0,....... TrMIIIIInC
IIIG dilllOS8l ..,. -
AIIIm8Iive 2. fIha8d
~ ,..., 7ft
CIC*:itY (1 z.ooo pili:
IIIG PtIII8 2. ~ iidIfi.
Iian8I CIIP8ItY. (4.oao
pII)
1
, , ' ' ,
-, " ' , ,
: bncs"''''_-
.. AI8n8Ii¥8'" AIuI8 at
.;'22.IlOO GIft. at .......
.::.-.PtI8I8d~ .
::::~~...,e:.
..
EinI:I 4.IlOO QIIIft !ram
2 ellllling _I. TI'8I1
will'! «*af -1108 AS wlll'l
vapor p"..e GAC.
Aew8 4.000 ;pm of
..... .....
Ein1:11'.1IOO pII tam
10 ,.. WIiII IIIG e.oao
pn tram 5elilling"'"
Trearmentum. .,.,.,.
18iv82far"", ...
2. PtI8I8 2 ......
8n;!e-mveAS. DiIODIII
."-110 grcanII'"
I8UI8 at ..IlOO gpIII.
PtI88d .....,. -
8 AI"'" 3.
em.:r 1'.IlOO QIIIft flam.
UlIano""" .,.. WIfI
cMI~AS_...
-- GAC. Ci8CXII8 '"
iljeDon it '0,.. wall
IIIG I'8U88 01 ..000 gpn.
~ wall. pIacaG ..
eri\8nC8 - ....l11li1&.
.. 8CIIan Inaudn Ite
mah.IDh'liQ 01. UII1III
walla.
.
I
~
i
Slm8u~2.
.... ....... 111ft No
-.dv8 3 ... ",.. ...
.... ... ~.~111
2.
.,., 10,... d....
IIDn. l1li.... ... 01
TCEin"~
wauIcII1iI8IIaeed MCLI.
Hawawr. /III1CII8'8IIOnI
waulcllIe~"'"
tam ... ~ in
AIIIm8Iiw8 2. PUn8 frio
.-an wauId lie ~
.... -1anI - p&8'IIp.
inO CIDIIIinu8d or Ite
....- /MIl''''''
CcrIft8drilll 01 oraurw-
. warer GDftraminuan-
. waulcllIe pr8I8ftL ~
. It InC8 ~ tlallMl¥ on
i !! inaUDNII CIIIft1nII8 ..
a 1R"fII."'"
~I
¥I
=~
loll
Nw 2D )1888 ole...
ion. 18_11"". 01
TCEift~~
would.. --- MCLI.
SinI» pUle .
wauIG tlacMft8c8"1:
CUIT8IIt pall IOW8nSI
BurDank'1 pradUClion
..... .... CIIUIII 118
CIIftI8IIINIId .. IIigII8r
.....
':.:-'.:,:,:,'.;,:"
,':':':', ',:-..:.;'
. .
, " '" '.', '
,..... .._,
.. ....., ",...., ,..,.., n,"
,'''''''' ,..,',' "','" ...,
, ..,..,.. ..
.:.Y,'...:.:';"".,;,:,:,;,',:,:,;
:,:,;;","'::",:.::',;.,:,:, "" ,
,....... '..O" ,
,., ,....', ,
, ,.,..' ,
"... ,
.; I No I'8U:Iion DIiciIy.
t i malliir,.onalurnelinc8
{!:> Nt Ir88IIMftI wauIcI 118
'18 UI8d.
c: .
.a"
)8
,I
II:
S8rna . AJremuva 1
8IDICIC 8dCIIIion8t\o.
c:r88I8 01 CDIIt8IIlII8t'It
QIIo - 4I.aioIliwaulcllI8
8:f'iewd '" ~
. 8III'8I:IIDI\L
E8IinI8d....... TCE
concentration. !ram
3.200 1411 1D 122 '-'
... 10,.... Pbrie
micn*"I WOUld 118...
etfic:tj-y GDftttlMled
... inAlIIm8iw 3.'"
".. ".. eItIc:tiw8Ir
f8nI'OIIId ... in AlI8t-
I8iv8 2.
Ea1iIMIIcI..-- TeE
~.nu.tian- &8m
UOO..qr.. ., UO' 8ftIr
10 yam. PUna niQr80
..... -*1118 eIIIcDWIy
Cllll8'CllIed ... fIIoarW
liquif.r GDftt8lllinauon
would noc 118 .......
ftIirN8d....... TeE
COftC.,.rrarioM ".".
3.200 u~. 5QQ ...
. 20 y.... CcInIiiud
CIIIm8m-- migr8IIan
wauId OCIC&I' burwadclll8
rW.-cIIId .... ~
unaon WIlL
. .
:::.....~~Z;;:::
;:::::f::::::~{:~:::~::;::;::;}~;;:~::{::::::::{:~r', ::: ,::::;:; ::;:: :
.J',. ,'.".',',',',,,,,',','.',','.",',',',','. ' ,,-.','.'. ,','.,',',',,',',".','
':-.':':':'::';':';;':':';'."':';':',':':':':'::'.';',,:"::.,','",,,::;;.::
,,' .,.'".",,'.,.'..' "" """
';:':::::::;:::::;:,:;:::;:;:;::':::;:::::;:.:;:;:::::::,:,:::':::':.:::'::,::';';"
,,,...,.,,, '....'......" ",..,
""',',',..'-',',',,'.', ,"',.,','""-,'..',',',',',-,,',',,',,
',',",', ",'" ,',",",".".','.'.',',"','.,'-,,',',',' "',',,', ,','
:,',::":,:::,;,:::,,,;.:.:.;,:,:,',',:.:.;,,',:,:,:-:.:':':-,::.:::';'.',';
.',',.',', ,',',',."',',','''...'.',','.'.'.'.'.',',','.',-,., ',,",',
'r~:;::~:;~:~~;~;~~:;;~::{:,:;::)::~ :;,;/.~?::f~:~::': :': " ", ':
,.., ",.. ..,..
",.. ' .. ....,
. ~ Would IDt III88C MCt.I
! ~ ... ... - ......
Ii
S8n8 u AIIImaM 2.
S8ma .. AIIiIIrNM 2.
S8n8 u MiIIrII8M 2.
w.. ~ Iram
lie .,...".,., .......
WOIItI l1l8I& ..:u ...
. _-=an....... Emiao
Iion8 Iram AS wauJd 118
CDftI'CIIIId '" GAC.
Ii InatitUtianli contral'
~ I WOUICI camraI nail of
:! inge8tlOft 01 CDIIt8/III.
'0 "ated ground.ater.
Ii -.1! ElM 01 "'*'181 d8QnId8o
f e lion-*! i~ U
is: ~~
It. 111ft .....
Ii
c5
S8ma u AJI8rnuw 2.
In.tltutional controll
wauIcI be -.. AI..
"... 2. £.wv..r_."
..~ CIINd '-
gr88IIy rwdumcIlIIICIIN
plume of g~
Clllm8minalllft WOUld be
I8duc8cI in CDiI8fltl'8lian
IIIG -.L
In8riMianII CIIIIfttraI.
..... tIe- 8"""
r8iv82. En~........-
daQl8d8ian oauId 118
IIIn e~ ~
8'a118d1ft8rl AI18m8Iw 2
llulleu eft8c:IiwIy ....
A/1arn111W113.
In,tltutianal DOntral,
wauId CIOM'GI ri8Ir fI/ it-
081- 0I.....J. "
~lMmaN1Dr
eII8CWI-.oIltI8.,....
menI SJ818f11. en-
rnenf8I C18Q18d8iorIcauIcI
itcn888 - a ZDna in
~ ..,. will .,.,.
endy low /III18ffto.,,1
18 IiC8IIh1IaN oauId 118
CDIIam.~ .. IIig/I8r
.....
..
: .T8d11i118\..._.'"
..I..~':- ~....-
.. . 2 far 8IIftI:o
..... ....---. Ail-
:'; n.~.... .....at88
, ..... nt8d .......
.:...,....... a.,- III
:. IurtI8ftk. UWD. ....
.tADWP8- . '..
~.:a-:':.~lIIat-= .
::..-..ca-~ ::::;...
: ...... 1 ..... t T...-
t.~::,::;;:;- ._'
MoIiDfInQ WlllII WCUd
118 euy .. CIOfI8INCL
$prMd 01 ItI8 ~
~l'II8coufdm..
iUon IIIn dIfI.
CUt in 1te/uUa.
s.m.,,'-'..A'II2.
S8m1_~2
~DMin8
oouId 118 IIIn -,...
... IN ~.....
Same .. All8ma1iYa 2
...... inj8caon ...
....... would M
II88dId II.... eflle.
---.fII ~
~ ~wifI-.aor
pf88 GAC i8 a IIIV~
...., .1OIowJ. AoIInMA far
hooIIup --- bitll88d8d
flam municipailUlflolir,.
~l8IeI!«:IMI-
injecIion .... - De
..... u-
~.
~
.
.a
S
i
E
..
1"
I
i! 0
. ::15
; "0 80
- 0'-
~ 11i 500
"'ct~
. PwwMnt worfI 8V8Iu8t101'1 ..un" '0 II8IQfIt IIWIoI8I ~,.. ... 20 ya8ll1ar INIJRll8ClIif8.
- Toea CDII af PfIue , IIIG PfIue 2.
---A. pr...need in :". Pi~.l Orate operaale Un1e 7ea.1~&liey seudy
18tWln' ((le"~l'tft..r' 1988 I
:.a'ID.71/1J11a.'CD. A8Nn8dDII825,.,ot
.. CIOIt 01 Ah8m8Dw
".,'.. ',' ".'
. ..... 2. Dr 120.450.
. -- IUDO M.2DD
4.400
.....
G.3D
4.2Do
".700
52.100
..IIJIOO 17'-."
"100
11..
8I.ZID
-------
(5) reduction of toxicity, mobility, and volume
of contaminants,
(6) technical and administrative feasibility
of implementation,
(7) state acceptance,
(8) community acceptance, and
(9) capital and operation and maintenance costs.
The nine criteria and the relative performance of the alterna-
tives in relation to each criterion and each other is summarized
below.
OVerall Protection of Human Health and the Environment
Alternatives 3, 4, and 5 provide the best protection to human
health and the environment. Environmental degradation would be
reduced since the plume of groundwater contamination would be
reduced in concentration and extent. Institutional controls
would control the risk of ingestion of contaminated groundwater,
since only treated water would be served. Drinking water would
be provided via surface water from the MWD and/or treated
groundwater from the stripping units.
Alternatives 1, 2 and 6 are not as protective of the environment
because environmental degradation would increase over time. Al-
ternative 1, the no action alternative, would allow the con-
tamination to continue spreading. Although alternatives 2 and 6 i
extract and treat some of the contaminated groundwater, the ex-
traction wells would not be strategically located to capture the
higher groundwater contaminant concentrations. Institutional
controls in Alternatives 1, 2, and 6 for the protection of drink-
ing water would be the same as. in Alternatives 3, 4, and 5.
ComDliance with ARARS
This section will outline the Applicable or Relevant and Ap-
propriate Requirements CARARs) and other information that EPA
considered for this site. Then it will compare the alternatives
with one another regarding these ARARs and To Be Considereds
( TBCs ) .
There are ARARs and TBCs that apply to both the water and air for
this response action. These can be separated into chemical
specific and primary action specific ARARs and TBCs.
Water ARARs and TBCs: There are chemical specific ARARs and TECs
for water which will be described here. First, the ARARs for the
water are the Safe Drinking Water Act Maximum Contaminant Levels
CMCLs). In accordance with the EPA "Interim Guidance on Com-
pliance with Applicable or Relevant and Appropriate Requirements
(OSWER Directive 9234.0-05)," the MCLs are considered the
chemical-specific ARARs because they are the enforceable drinking
- water standards. They are required to be set as close to the
Maximium Contaminant Level Goals (MCLGs) as is feasible, taking
/
/
20
-------
into consideration the best available technology, treatment tech-
niques and other factors (including cost). They are also protec-
tive of pub!lC heal~9 to within EPA'S a7ceptab~e carcinogen ris~
range of 10 to 10 . The MCL of partlcular lmportance for thlS
response action is the MCL of 5 ppb for TCE.
MCLGS, which are based only upon health criteria, are not
directly appliCable as chemical-specific requirements because
they are not enforceable standards.
EPA also considered the California DHS's action levels for VOCs,
a few of which are more stringent than the MCLs or for which no
MCL has been established. While the DHS action levels are not
promulgated standards and are not, therefore, ARARs, they have
been taken into consideration during development of remedial ac-
tion alternatives as allowed for in the National Contigency Plan
(NCP). In addition, DHS has recently proposed MCLs for a number
of VOCs. Of particular significance, the proposed MCL for PCE is
5 ppb, which is just slightly higher than the current DHS action
level of 4 ppb.
Table 4 lists the federal MCLs, MCLGs and SALs for
contaminants detected in the Burbank Operable Unit
remedial action selected will meet the federal MCL
Sppb) and the SAL for PCE « 4 ppb).
the primary
area. The
for TCE «
\
It has been determined that pure product in the form of TCE and
PCE (U210 and U228) are contained in the groundwater making RCRA
Section 261.33 applicable for this action. The groundwater also
contains spent TCE and PCE that was used in degreasing. The
listing in 40 C.F.R. Subpart D Section 261.31 that pertains to
spent halogenated solvents used in degreasing is FOOl. This
listing requires knowledge of the percent solvent by volume
before use. This information is unavailable for the Burbank OU
making the RCRA FOOl listing not applicable but relevant and ap-
propriate for this action.
Air ARARs and TBCs: There are primary action-specific ARARs and
TBCs for the air discharge which will affect this response ac-
tion. In California, the authority to regulate stationary
sources of emissions has been delegated to local air quality
management districts. The Burbank OU is located in the South
Coast Air Quality Management District (SCAQMD). Therefore,
SCAQMD regulations constitute generally applicable, promulgated
state requirements under state environmental law, as set forth in
section l21(d) of the Superfund Amendments and Reauthorization
Act of 1986 (SARA).
EPA considered SCAQMD Regulation XIII (comprising Rules 1300 to
1313), which requires that stationary sources of air emissions
meet best available control technology (BACT) standards. Regula-
tion 13 states that new stationary sources of air contaminants in
th~ air basin that emit reactive organic gases must employ BACT
~ir POllution control devices. These BACT devices are defined as
21
-------
Table 4
Mets, MCLGs and State Action Levels for
Primary Orqanic Contaminants Detected in the
Groundwater Beneath the Burbank Operable Unit Area
Federal
Federal Maximum
Maximum Contaminant
Contaminant Level Goal State Actiog
a (MCLG)a
Level (MCL) Level (SAL)
(ug/l) (uq/l) (ug/l)
Trichloroethene ('l"CE) 5 zero 5
Perchloroethene (PeE) 4c
Carbon tetrachloride (C'1'C) 5 zero Sc
Chlorofonl lood
Notes: '_I Indicates that there is not a set level.
aMet and MCLG are set by the United States Environmental Protection
Aqency.
bSALS are set by the California Department of Health Services (DBS)
cCHS has recently proposed estab~ishinq State MCLs for PeE and CTC of
5 and 0.5 uq/l, respectively.
~alue reported is total trihalomethanes (chloroform, dibromochloromethane,
bromodichloromethane, and bromoform).
" SFR179/0S8
-------
"the most stringent emission...control technique which... is
found... to be technologically feasible and cost effective.. .."
(See the Administrative Record for the Burbank au for a copy of
Regulation XIII.) It is estimated that, if there are no emissions
controlS, the air strippers contemplated for the Burbank au would
emit over 168 po~ds per day of reactive organic gases to the at-
mosphere. For air strippers, SCAQMD considers vapor phase GAC
(with 90 to 99% removal efficiency) devices to be BACT.
EPA also considered SCAQMD Rules 1401 and 1167 as "other informa-
tion to be considered," pursuant to the NCP.
Proposed Rule 1401 - New Source Review of Carcinogenic Air Con-
taminants - specifies limits for individual cancer risk and ex-
cess cancer cases from new stationary sources which emit car-
cinogenic air contaminants. The rule requires BACT for toxic air
discharge for new stationary sources where a lifetime maximum in-
dividual cancer risk of one in one million or greater is es-
timated to occur. TCE is a listed carcinogenic air contaminant.
Results from the public health assessment show that TCE emissions.
after treatment on the vapor phase would meet Rule 1401's re-
quirements.
Rule 1167's purpose is to control vacs as precursor emissions to.
ozone formation in the South Coast Air Basin. The South Coast \
Air Basin is currently in nonattainment status with respect to
the National Ambient Air Quality Standards (~QS) for ozone, and
vacs are known precursors to ozone formation. Rule 1167 is
designed to reduce vac emissions from new and existing air strip-
ping equipment used for treatment of contaminated water. The
rule requires that all air stripping facilities treating con-
taminated groundwater that emit more than one pound per day of
total vac emissions install air emission controls capable of
reducing air emissions by 90%.
Although Rule 1167 was stayed by the California Superior Court
until an Environmental Impact Report is completed, it is con-
sidered in the remedy selection process as a TBC since SCAQMD
fully intends to meet the requirements set by the court judgment
and proceed toward adoption of this rule as a promulgated,
legally enforceable, generally applicable requirement in the near
future.
Installation of an air stripping system with air emission con-
trols is more protective of the environment in that it will
reduce ozone precursor emissions to the atmosphere by 90 to 99%
and will support efforts by SCAQMD to reach attainment status for
ozone in the South Coast Air Basin.
Comcarision of Alternatives: Alternative 1, the no action alter-
native, would meet the drinking water ARARs because institutional
controls would continue to assure that the public was provided
22
-------
with drinking water that meets the federal and state MCLs and
SALs. Also since no system would be in place, the SCAQMD's rules
would not be violated.
Water treated and discharged from alternatives 2 - 6 would meet
the federal and state MCLs and SALs before reuse, injection or
spreading. Air stripping systems would have vapor phase GAC ad-
sorption units to control air emissions to 90 - 99% removal ef-
ficiency to meet the South Coast Air Quality Management
District's rules. Steam stripping would recover the VOCs for
recycling so no air emission control system would be necessary.
However, Alternatives 1, 2, and 6 do no~ do as much as Alterna-
tives 3, 4, and 5 to meet federal and state MCLs in the aquifer.
Alternatives 3, 4, and 5 more effectively aid in restoring the
aquifer (to VOC concentrations at or below the MCLs and SALs) and
controlling the plume migration.
By meeting the federal and state MCLs and SALs before reinjec-
tion, Alternatives 2 and 3 will satisfy the RCRA Land Disposal
Restrictions requirements. By meeting the federal MCLs and SALs,
the groundwater will no longer contain the listed wastes when it
is spread for recharge in Alternative 4.
For Alternatives 1 - 6, the MCLs are relevant and appropriate in
the aquifer. Upon completion of the final remedial action for
the site, this ARAR will be satisfied.
Lona-term Effectiveness and Permanence
\
Alternatives 3,4, and 5 would have the greatest ability to main-
tain reliable protection of human health and the environment over
time. .After 20 years of extraction, copcentrations of TCE and
PCE in the groundwater are expected to still exceed the federal
MCLs and SALs, however they would be greatly reduced as discussed
in the previous section. Plume migration would be controlled and
aquifer restoration would continue as long as the system kept
operating.
Alternatives 1,2, and 6 do not offer long term effectiveness or
permanence. In fact, these alternatives might allow contamina-
tion to spread to clean zones within the SFVB.
Alternative 1 relies solely on institutional controls to prevent
exposure to the contaminanted groundwater. The current water
supply from surface water via the MWD may not always be available
in the future because of peiodic drought conditions and State and
Federal water rights issues.
Reduction of Toxicitv. Mobilitv. or Volume
Alternatives 3, 4, and 5 offer the most reduction of toxicity,
mobility, and/or volume of the coqtamination. The most con-
. taminated groundwater in the Burbank OU area would be extracted
.. and. tre.ated to remove the VOCs from the groundwater, thus the VOC
,,/-
23
-------
contamination in the groundwater would be greatly reduced in
toxicity, volume and mobility. Moreover, the air emission con-
trol units would reduce the mobility of the VOCs to the air.
Alternative 1 woul4 have no reduction in toxicity, mobility, or
volume since no treatment is employed.
Alternative 2 WOUld reduce the volume of contamination by ex-
tracting and treating 16,000 gpm. Alternative 6 would reduce the
volume of contamination by extracting and treating 4000 gpm.
However, the existing wells used for alternatives 2 and' 6 would
not be stratigically located to control migration or capture the
contamination. Therefore, continued contaminant migration would
occur and a lesser amount of contamination would be captured then
for alternatives 3, 4, and 5.
Short Term Effectiveness
For alternatives 3, 4, and 5, no adverse impacts would be ex-
pected during the construction and implementation period or
remediation. Drinking water supplies would be provided from
treated groundwater and/or surface water from the MWD during the
interim before construction complete and during remediation. In-
stitutional controls would -assure that all drinking water would
meet drinking water standards. The plume migration would be ef- i
fectively controlled with these alternatives and aquifer restora-
tion would be initiated in this area.
Alternative 1, the no action alternative, would not be effective
in controlling migration or aquifer restoration. It would allow
the contaminanted groundwater to spread to uncontaminated
downgradient wells. ' There would be sale reliance on institu-
tional controls to prevent exposure via drinking water ingestion.
Alternative 2 and 6 would be more effective than alternative 1.
There would be less reliance on institutional controls for drink-
ing water, since treated groundwater that meets MCLs and SALs
would be served, as a portion of the total drinking water supply
for the affected areas. However, these alternatives would not
be as effective in controlling plume migration and in aquifer
restoration as alternatives 3, 4, and 5.
ImDlementabilitv
Alternatives I - 6 would all be technically implementable.
However,' Alternative 5 appears the easiest to implement with the
- current information, due to the practical uncertainities as-
sociated with injection and spreading and the technical uncer-
tainties associated with plume location and migration.
, Construction of monitoring wells for all alternatives is straight
forward, using well known technology. There are many monitoring
wellS in the SFVB.
, '
24
-------
Alternatives 2 - 6 would employ air stripping with vapor phase
GAC adsorption units (or steam stripping.) which is a proven
treatment technology and relatively easy to implement. Ad-
ministrative-agreements would be needed for the use of treated
groundwater. Approval for hookup to the City of Burbank would
also need to be arranged prior to distribution. Preliminary dis-
cussions have already taken place and no significant problems
have been identified.
Alternative 5 would require agreements between the City of Bur-
bank, LA DWP, and MWD to accomodate the exchange of water-beyond
the City of Burbank's extraction credits. However, preliminary
discussions between EPA and the affected parties regarding the
reuse of the water have shown that the agreements could be ar-
ranged.
The use of injection wells in alternatives 2 and 3 could be dif-
ficult to implement technically due to operational problems en-
countered with injection wells and the unknowns associated with
extent of contamination. Further spread of contamination could
occur if the injection wells were improperly placed.
Spreading in Alternative 4" could be more reliable than the injec-
tion wells. However, there are also uncertainities associated
with possible contamination in the area of the spreading grounds.
An additional load from discharging the water by spreading could
cause further contamination of the area by enhancing movement of i
the contaminants in the soil and/or groundwater. -
Alternatives I and 6 would allow the contamination to spread and
thus make remediation more difficUlt. in the future.
~
Alternative 1 would be the least expensive with an expected
present worth value of $500,000. (Present worth evaluations as-
sume 10% annual interest rate and 20 years for the project life.)
Alternative 2 has an estimated capital cost of $36.6 million and
total O&M of $45.2 million. The expected present total worth
value is $81.8 million.
Alternative 3 has an estimated capital cost of $43.4- million and
total O&M o! $44.7 million. The expected present total worth
value is $88.1 million.
Alternative 4 has an estimated capital cost of $42.3 million and
total O&M of $52.9 million. The expected present total worth
value is $95.2 million.
. * Steam stripping is discussed in Section 10, Documentation of
Significant Changes.
/
"
25
-------
Alternative 5 has an estimated capital cost of $32.1 million
($25.1 M for phase 1 and $7.0 M for phase 2) and total O&M of
$54.2 million ($43.9 M for phase 1 and $10.3 M for phase 2). The
expected present worth value is $86.3 million ($69.0 M for phase
1 and $17.3 M for phase 2).
Alternative 6 is assumed to be 25% of the cost of Alternative 2,
or $20.5 million.
The cost summaries can be found in greater detail in the Burbank
OUFS Report.
Community AcceDtance
Alternatives 3, 4, and 5 received the most community acceptance.
The community generally wants the aquifer restored for beneficial
use and the plume migration halted as soon as possible.
community Workgroup members expressed some concern over reinjec-
tion and spreading due to the uncertainties associated with the
extent of contamination. Their concern was that reinjection or
spreading could contribute to the spread of contamination if the
wells or spreading areas were improperly located. Therefore Al-
ternative 5, the water reuse option, was most attractive to the
community workgroup.
The community feels strongly that air emission controls must be
employed due to the poor air quality in the Burbank area. EPA
addresses this concern with the requirement that vapor phase GAC
adsorption units would be installed if air stripping is used.
The Response Summary (attached) addresses more specific concerns
and comments raised during the public comment period.
State AcceDtance
Like the community, the State (DHS and RWQCB) wants aquifer res-
toration and control of the plume migration initiated as soon as
possible.
They prefer Alternative 5 because they (like the community) have
concerns with regards to the reinjection and spreading options
associated with Alternatives 3 and 4. (See previous discussion.)
They also believe it is important to have air emission controls
on the air stippers. Moreover, the SCAQMD insists that if aera-
tion is used to treat the water that vapor phase GAC adsorption
units (or comparable BACT) be installed.
California DHS has concurred with the Burbank OU remedy selec-
'tion.
,.
26
-------
10.
Documentation of Sianificant Chanaes
The Proposed Plan was released for public comment in October
1988. The Proposed Plan identified Alternative 5, phase 1, ex-
traction, treatment, and reuse, as the preferred alternative.
Dual stage air strippers with vapor phase GAC adsorption units
were chosen as the preferred treatment technology. During the
public comment period, a potentially responsible party, Lockheed
Aeronautical Systems Company (LASC), presented EPA with a similar
treatment technology - steam stripping, more specifically, the
AquaDetox system.
In the Burbank OUFS Report, conventional steam stripping was
screened out because TCE and PCE are highly volatile compounds
which are easily removed from water without input of heat. Fur-
thermore, the expected concentrations of TCE and PCE were not
high enough to warrant the added energy input. Therefore, steam
stripping was not considered cost effective and was not con-
sidered further in the OUFS.
Steam stripping with the AquaDetox system was also screened out
during the Burbank OUFS on the basis that adequate experience did
not exist either for AquaDetox systems without external steam
supply or for the effluent to be used as drinking water.
The AquaDetox process is a proprietary and patented steam strip- \
ping technology developed by AWD Technologies, Inc., which uses
steam stripping under moderate or deep vacuum pressure. While
conventional steam stripping was considered not applicable be-
cause of its higher cost than air stripping, the AquaDetox sys-
tem, may be cost-effective due to the lower energy requirements.
Other claimed advantages of the system are: (1) the VOCs can be
recovered for recycling instead of discharged to the air or car-
bon, and (2) it is a closed loop system and therefore there is
minimal VOC discharge to the air « 1 lb/day, given estimated
groundwater VOC concentrations).
The AquaDetox system under moderate vacuum pressure was selected
by LASC for groundwater treatment at a site within the Burbank OU
area. This 1200 gpm extraction and treatment facility began
operation in January 1989 and should provide performance data
relative to the use of this technology in the removal of the
VOCs.
Information on the influent from the LASC AquaDetox extraction
and treatment system is showing higher concentration levels for
TCE and PCE than estimated in the Burbank OUFS Report. LASC' s
treatment facility is extracting groundwater with concentrations
up to 12,000 ppb PCE and TCE combined (as of February 1989).
Therefore steam stripping may be more applicable (e.g. economi-
cal) than originallY thought due ~o the higher concentrations and
. added stripping efficiency of steam stripping.
27
-------
Since air and steam stripping fall under the same class of treat-
ment - stripping - either technology can be employed to meet the
performance standards, therefore aChieving the stated Burbank
Operable Unit objectives.
Air stripping was used during the discussion of the description
of alternatives and comparision analysis. However, the selected
remedy will be either air or steam stripping, as long as the
steam stripping meets the performance standards and is as effec-
tive as the air stripping in meeting the evaluation criteria.
This allows flexibility during the remedial design to procure the
most cost-effective unit that also protects human health and the
environment.
11.0 THE SELECTED RF.MF.ny
Alternative 5, phase 1, using either steam or air stripping for
treatment, is the selected remedy for the Burbank Operable Unit.
The remedy includes extraction of contaminated groundwater,
treatment by stripping, and reuse of the water by the City of
Burbank for drinking water. If air stripping is chosen during
the remedial design, vapor phase GAC adsorption units will be
needed to comply with the ARARs and TBCs.
The extraction system will be designed to capture groundwater
containing 100 ppb or greater of TCE and 5 ppb or greater of PCE.
The extraction flow rate is currently projected to be 12,000 gpm.
The Federal and State MCLs are relevant and appropriate in the
aquifer. Upon the completion of the final remedial action for
the site, this ARAR will be satisfied.
Although it was estimated in the Burbank aUFS report that extrac-
tion at a rate of 16,000 gpm coupled with injection wells for a
period of 20 years was necessary to fully remediate the Burbank
OU area (i.e. removing groundwater until that left contained con-
taminants to concentration levels at or below MCLs and SALs) , the
decision to pump and treat 12,000 gpm was determined to be the
most appropriate given the amount of technical information cur-
rently available. More information will be gathered during the
basinwide RI, North Hollywood au remedy operation, LASC's extrac-
tion and treatment system, Burbank OU remedial design, and the
operation of the Burbank au treatment system to determine whether
more extraction is necessary to continue aquifer restoration and
controlling the migration of the plume. If additional extraction
is determined necessary, EPA would again go out for public com-
ment with a Proposed Plan before signing another Record of Deci-
sion.
Extraction wells will be strategically placed (both laterally and
ver~ically) to maximize the effectiveness of the system. The
locations presented in the OU may be modified if warranted by new
data. Stripping is the chosen treatment. LASC is conducting a
28
-------
treatability study with its AquaDetox system. This will help
determine whether steam stripping will be used for the au remedy.
Air stripping with vapor phase GAC adsorption units will be used
unless steam strippipg is shown to meet or exceed the treatment
advantages of air stripping with vapor phase GAC. EPA may also
decide to use the two teChnologies together if that would maxi-
mize efficiency.
The vacs - particularly the primary contaminants, TCE and PCE -
in the groundwater must be removed from the groundwater such that
treatment plant effluent concentrations are below the Federal
MCLs and SALs (TCE - 5 ppb and PCE - 4 ppb). The water must also
meet all drinking water standards. This may require further
treatment like chloramination for disinfection purposes, or
reverse osmosis or ion exchange for nitrates.
The treated water will be fed directly into Burbank's distribu-
tion system for reuse by the City's residents.
Monitoring wells will be installed downgradient to monitor the
performance of the system.
The extraction of contaminated groundwater from the Burbank au
area, treatment of groundwater to drinking water standards, and
distribution of the water to the Burbank residents is the most
cost effective and technically sound means of meeting the au ob-
jectives.
\
The selected remedy permanently and significantly reduces the
toxicity, mobility, and volume of hazardous substances with
respect to their presence in the groundwater -- the contaminants
are removed from the groundwater, thereby reducing contaminant
migration in the vicinity of the Burbank au area.
Stripping will result in a small increase in the toxicity,
mobility, and volume of hazardous substances with respect to
their presence in the air. However, the use of steam stripping
recovers most of the vacs for recycling. If dual stage air
stripping is used for treatment, vapor phase GAC adsorption units
will be installed to minimize the amount of VOCs discharged to
the air.
The air emissions are estimated to add a minimal risk to the
project via airborne contaminants, because the air emission con-
trols will remove 90 - 99% of the contaminants before they are
discharged to the air. The addition of vapor phase GAC adsorption
units meets the ARARs and TBCs discussed in Section 9, Compliance
of MARs.
The spent carbon from the vapor phase GAC adsorption system is
considered a RCRA waste or it is a mixture of the solid waste
carbon and the RCRA listed wastes ,FOOl, U210, and U228 (40 C.F.R.
29
-------
section 26l.3(a)(2)(iv». Therefore the carbon must satisfy the
requirements of 40 C.F.R. Part 263 to be shipped off site for
regeneration.
The pump and treat system will operate for an estimated 20 years.
Groundwater monitoring and groundwater level measuring will be
conducted as part of the remedy to track contaminant concentra-
tions in the Burbank OU area, to monitor the performance. of the
treatment system and to determine the efficiency of the system in
restoring the aquifer. The system will be evaluated
periodically to determine the effeciency and necessity of the
remediation in achieving the stated goals. The reviews will al-
low for modification in the system as required.
For reference, the estimated cost of the selected remedy with the
use of dual stage air stripping with vapor phase GAC adsorption
units is $69M (see Table 5). LASC's Remedial Action Alternative
for the Burbank Well Field ODerable Unit gives a cost estimate of
$50.1 Million net present value for the Burbank OU remedy using
the AquaDetox sytem instead of the AS with vapor phase GAC ad-
sorption units. Although LASC's alternative is similar to Alter-
native 5, phase 1 in the Burbank OUFS Report, LASC's alternative
does have some different features. (LASC's report can be found
in the Administrative Record.)
12.0 STATUTORY DETERMI~TIONS
The selected remedy is protective of human health and the en-
vironment -- as required by Section 121 of CERCLA -- in that it
treats the extracted groundwater so that remaining contaminants
are at or below the MCLs and SALs for the contaminants of con-
cern.
Stripping has been shown to be the most cost effective technology
for treating the concentrations of VOCs found in the groundwater
from the Burbank OU area. Although the addition of air emission
controls (GAC) to the dual stage air strippers (if steam strip-
ping fails to pass the treatability studies) will increase the
cost of the selected remedy, it is determined to be justified as
a cost-effective measure for the following reasons:
(1) It meets the requirements of SCAQMD Regulation XIII, the
ARAR for air discharge from the air stripping treatment; (2) It
reduces ozone precursor emissions in a nonattainment area (the
South Coast Air Basin) that has the worst air quality in the na-
tion; and (3) It responds to public comments requesting air emis-
sion controls to minimize the increase in existing air quality
problems regardless of legal requirements.
The selected remedy (either air or' steam stripping) meets the
ARARs and TBCs that apply to this response action. The selected
remedy will meet the Safe Drinking Water Act MCLs and the CA DHS
30
-------
Table 5
Cost Summary for Alternative 5, phase 1
(air stripping, with vapor
phase GAC)
Item/Description
Estimated Cost
($)
CAPITAL COSTS
Extraction and Pipeline to
Treatment System
CAPITAL COSTS
5,125,000
6,740,000
25,000
2,220,000
$14,100,000
4,510,000
6,520,000 \
$25,100,000
Treatment (Dual-Stage as
with Vapor Phase GAC)
Connection to Burbank PSD
Distribution System
Monitoirng Well
Fees and Contingencies
Engineering, Legal,
Administr3tion
TOTAL CAP!TAL P.EOCIREMENT
OPERATION AND MAINTENANCE COSTS
Ex't:rac't:ion
Treatmen't:
Monitoring
Contingencies
793,000
3,465,500
33,:00
TOTAL ANNUAL COSTS
$ 4,300,000
Present Wor't:h of O&M Cos't:s
(Interest rate - 10\: Years
Present Worth Factor. 8.51)
$43,900,000
= 20;
TOTAL PRESENT WORTH COST
S69,000,000
/
-------
1-
State Action Levels in the extracted groundwater that is treated
for reuse. Upon the completition of the final remedial action
for the site, the MCLs will be met in the aquifer.
It will also meet the SCAOMD'S Regulation XIII and Rules 1167 and
1401 by adding air emission controls to the air strippers or
using steam stripping.
Finally, it will meet the RCRA requirements as specified in 40
C.F.R. Section 261 and 263. RCRA Subpart B, 40 C.F.R. 261 -
Criteria for Identifying Listed Hazardous Waste - identifies the
waste as relevant and appropriate to FOOl and applicable for U210
and U228. RCRA Part 263 - Standards Applicable to Transporters
of Hazardous Waste - specifies compliance with the manifest sys-
tem for shipment of the spent carbon off-site for regeneration.
The solvent product generated from steam stripping is not con-
sidered a RCRA waste if in accordance with 40 C.F.R. Section
261.2(e)(i)(ii) materials are not solid wastes when they can be
shown to be recycled by being used or reused as effective sub-
stitutes for commercial products.
The selected remedy permanently and significantly reduces the
toxicity, mobility and volume of hazardous substances with
respect to their presence in groundwater. The contaminants are
removed from the groundwater, thereby reducing contaminant migra- \
tion and restoring the aquifer in the vicinity of the Burbank au
area. The stripping technology will result in a very slight in-
crease in the toxicity, mobility, and volume of hazardous sub-
stances with respect to their presence in the air.
Air stripping with vapor phase GAC increases the volume of con-
tamination in the air by transferring that volume, which is not
trapped into the carbon for regeneration, from the water to the
air. Steam stripping slighty increases the volume of contamina-
tion in the air by transferring that volume, which is not
recovered as product for recycling, from the water to the air.
The VOC volumes released by either method will not exceed the
SCAOMD's limits.
The inclusion of air emissions control (vapor phase GAC adsorp-
tion units) in the selected remedy (if air stripping is used)
reduces the impact of the air emissions in a cost-effective man-
ner to the maximum extent possible. The air emissions are es-
timated to add a minimal risk to the project via airborne con-
taminants. The minimal risk addition is due largely to the
capabilities of the vapor phase GAC adsorption units to remove 90
to 99% of the contaminants in the air discharged to the atmos-
phere from the stripper. With the addition of air emission con-
trols, the selected remedy reduces the potential for ozone forma-
tion.
31
-------
Both air and steam stripping meet the statutory preference for
remedies that use alternative treatment or resource recovery
technologies to the maximum extent practicable. Steam stripping
under vacuum pressure is an innovative technology that recovers
the VOCs for reuse. If the dual stage air stripping with vapor
phase GAC adsorption units is used, the spent carbon from the GAC
off-gas treatment system will be regenerated, instead of being
disposed of in a landfill. Therefore, the VCCs will be collected
for reuse or destroyed.
32
------- |