United States Off ice of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-90/050
September 1990
c/EPA
Superfund
Record of Decision
Solvent Service, CA
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I REPORT DOCUME~TATION 1'. REPORT NO. 2. 3. Recipient'. Acce..lon No.
PAGE EPA/ROD/RO~-90/050
4. TI1Ie and Sub1l1le 5. Report Date
SUPERFUND RECORD OF DECISION 09/27/90
Solvent Service, CA
6.
First Remedial Action - Final
7. Author(a) 8. Perlo""I"II OrganlZ8t1on Rept. No.
8. Perfonnlng OrgalnlZ8t1on Name and Addre.. 10. PtojectlTaaklWork Un/I No.
.. 11. Conttact(C) or Grant(G) No.
(C)
(G)
12. ~ Organization Name and Adefte.. 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplernenwy No.a
18. Abetract (Umlt: 200 worda)
The 3-acre Solvent Service (SSI) site is an active treatment, storage and disposal
facility in San Jose, California. Land use in the vicinity of the site is industrial
and commercial. Since 1983, SS! has been operated as a treatment, storage, and
disposal facility. Mixed and segregated solvents have been recycled by a variety of
methods including distillation, separation, and blending. Approximately 99% of the
recoverable solvents are recycled and then reused and consumed by industry. After VOCs
were detected in the ground water, the California Water Quality Control Board adopted
Waste Discharge Requirements requiring further site investigations and implementation
of interim remedial measures. In 1988 and then again in 1989, the Board adopted
Revised Waste Disposal Requirements requiring completion of the pollution
investigation, final installation of 50il cleanup measures, and submittal of an RI/FS
and RAP. Interim remedial actions conducted during the 1980s included the removal of
underground storage tanks, paving storage, unloading, and spill containment areas,
placing berms in the treatment and storage areas; and changing operational procedures
to minimize the risk of additional contamination. SS! is currently operating a
containment/extraction system for the ground water plume. The primary contaminants of
(See Attached Page)
17. IIoa8Mnt Analyata .. DncrtpIora
Record of Decision - Solvent Service, CA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes)
b. 1danlilier8l00000EncIed Te.....
Co COSA 11 FieIcIIGroup
18. Av8llabiBry Statement 19. S.curity CIa.. (Thia Report) 21. No. 01 Page.
None 142
20. Security CI... (Thia Page) 22. Price
None -.
.- (4-77)
50272.101
(See ANSl-ng.18)
s.e Inatrucllons on RsVlifSfl
(Formerfy N1IS-35)
Department 01 Commerce
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EPA/ROD/R09-90/0S0
Solvent Service, CA
First Remedial Action - Final
Abstract (Continued)
concern affecting the soil and ground water are VOCs including benzene, PCE, TCE,
toluene, and xylenes.
The selected remedial action for this site includes capping the entire site with
asphalt; operating a steam injection and vacuum extraction (SIVE) system for the removal
of VOCs from soil; extracting ground water via three excavation trenches and five ground
water extraction wells, and treating the ground water using bio-treatment, carbon
adsorption, and air stripping; soil and ground water monitoring; and implementing deed
restrictions. The estimated capital cost for this remedial action is $948,000 with an
annual O&M cost of $1,172,000.
PERFORMANCE STANDARDS OR GOALS: A soil remediation goal of 1 ppm total VOCs has been
set to protect the ground water from future VOC leaching. Inorganic soil cleanup goals
have not been established due to uncertainty surrounding the natural occurrence of
metals in soil in the South Bay area. Ground water remediation goals include benzene
1 ug/l (State MCL), PCE 5 ug/l (State MCL), TCE 5 ug/l (State MCL), toluene 1000 ug/l
(Federal MCL), and xylenes 1750 ug/l (State MCL).
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION'
1235 MISSION STREET
SAN PRANCISCO, CA '4103
RECORD OF DECISION
DECLARATION STATEMENT
SITE NAME AND LOCATION
Solvent Service Superfund Site
San Jose, California
STATEMENT OF BASIS AND PURPOSE
This declaration document presents the selected remedial action
for the Solvent Service Superfund site located in San Jose,
California, which was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980,
42 U.S.C. Section 9601, as amended by the Superfund Amendments
~nd Reauthorization Act of 1986, (CERCLA), and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 C.F.R.
Part 300, 55 Fed. Reg. 8666 (NCP). This decision is based on the
administrative record for this site.
The State of California concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an im-
minent and substantial endangerment to public health, welfare, or
the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Solvent Service site addresses the
principal threats posed by the site, ground water and soil con-
tamination. The primary chemicals of concern include
trichloroethene (TCE); l,l,l-trichloroethane (l,l,I-TCA); cis-
1,2-dichloroethene (cis-1,2-DCE); and acetone. A complete list-
ing of chemicals of concern is found in the California Regional
Water Quality Control Board (RWQCB) Site Cleanup Requirements and
Staff Report. Several interim response actions were performed at
the site by Solvent Service. This action represents the final
remedial action to remove contaminants from ground water and
soil. The major components of the selected remedy are:
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o Capping of the entire site surface .with asphalt to limit
surface infiltration and to limit air emissions.
o Operation of a steam enhanced vacuum extraction system for
removal of volatile organic compounds (VOCs) from the area of
highly contaminated soil.
o Operation of three ground water extraction trenches and five
ground water extraction wells to remove contaminant mass from the
ground water and to contain contaminated ground water at the
facility. The extracted ground water will be treated by air
stripping, carbon adsorption and biologic treatment systems prior
to discharge to the sanitary sewer.
o continued monitoring of ground water and soil to verify con-
tainment of the contaminated ground water and attainment of
cleanup levels.
o Deed restrictions to prevent on-site use of ground water and
residential development of the property until cleanup standards
for soil and ground water are achieved.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the en-
vironment, complies with federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable for this
site, and satisfies the statutory preference for selecting
remedies that employ treatment that reduces the toxicity,
mobility, or volume of the hazardous substances.
A review of the remedial action will be conducted every five
years after commencement to ensure that the remedy continues to
provide protection of human health and the environment.
q. '2.1.40
Date
/.
~W~
~ Daniel W. McGovern
. Regional Administrator
EPA Region IX
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Table of Contents
Declaration
Decision Summary
I . site Description......'~.......................
II. Site History and Enforcement Activities.......
III. Community Participation Activities............
IV. Scope and Role of Response Action.............
V. Summary of Site Characteristics...............
VI. Summary of site Risks.........................
VII. Summary of Alternatives.......................
VIII. Comparison of Alternatives....................
IX. The Selected Remedy...........................
X. Statutory Determinations......................
Responsiveness Summary .
Appendices
A. RWQCB Site Cleanup Requirements
B. RWQCB Staff Report
C. RWQCB Staff Memo: Cleanup Standards
D. Correspondence
E. Maps
F. Administrative Record Index
1
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1
2
2
3
3
4
7
8
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION'
1235 MISSION STREET
SAN FRANCISCO, CA .4103
DECISION SUMMARY
The u.s. Environmental Protection Agency ("EPA") and the
California Regional Water Quality Control Board, San Francisco
Bay Region ("Regional Board"), have worked together to select the
remedy for the Solvent Service ("SSI") site. consequently,
portions of the documents by which the Regional Board has
embodied its selection of the remedy under State law reflect the
efforts of both agencies to investigate the site, to assess the
risks which it poses, and to evaluate and compare possible
remedial alternatives. Particularly, certain portions of Order
No. 90-120, which was adopted by the Regional Board on August 15,
1990, referred to hereafter as the "Order," and the Internal Memo
dated August 6, 1990, referred to hereafter as the "Staff
Report," accurately set forth the views and rationale of EPA.
consequently, this Decision Summary will refer to portions of
those documents (both are attached), and by such reference they
are hereby deemed to be incorporated into this Decision Summary.
I.
SITE DESCRIPTION
Finding 1 (first paragraph) of the Order and Section 2.0 of the
Staff Report describe the Solvent Service site. Regional and
site maps are found in Appendix E of this Record of Decision
("ROD"). The estimated residential population within a one-half
mile radius is approximately 2000, and increases to approximately
10,000 within a one-mile radius of the site. The SSI site is
within one mile of a cluster of five deep aquifer wells that are
part of the municipal water supply for the area.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Findings 4, 7 and 8 (first through third paragraphs) of the Order
and Sections 3.0, 4.0 (first two paragraphs), and 5.0 of the
Staff Report provide a history of site activities and state and
federal enforcement activities at the site.
III.
COMMUNITY PARTICIPATION ACTIVITIES
Finding 16 of the Order and Section 6 of the Staff Report
describe how the public participation requirements of CERCLA were
met in the remedy selection process. A response to comments
received during the public comment period is included in the
Responsiveness Summary, which is part of this Record of Decision.
1
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IV.
SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy addresses the principal threats posed by the
site, ground water and soil contamination, as described in the
Order. Since achieving background concentrations is considered
to be infeasible, consideration was given to using the
non-carcinogenic hazard index (HI) less-than-one and the 10-6
excess cancer risk number (ECRN) concentrations to establish
cleanup goals. However, this approach may also not be practical
or technically feasible. Less ..stringent cleanup standards may be
appropriate due to the following considerations: 1) the existing
practical detection/quantification limits for some chemicals do
not presently permit measurement by standard methods of such low
concentration (however, technology development may eliminate this
factor in the future); 2) there are no water-tap exposures above
health-based levels actually occurring in the vicinity of this
site at present and it may be possible to quarantee that none
will occur in the future; 3) the potential for human exposure
from pathways other than future potential drinking water
ingestion or inhalation is minimal to none; 4) there are no
sensitive populations or special environmental receptors in the
immediate vicinity of the site. The standards proposed are
health protective, protective of the environment, and will meet
or exceed all applicable or relevant and appropriate requirements
(ARARs) or other quidance to be considered (TBCs).
While the cleanup objective is to restore ground water quality by
removing as much of the chemicals in the ground water as is
technically feasible, another objective of major importance is to
remove the potential threat to human health or the environment
posed by the presence of cancer-causing chemicals at this site.
The process of removing carcinogens will result in the removal of
non-carcinoqens as well and will eliminate the potential exposure
to vapors resulting from volatilization from the ground water.
Finding 7 of the Order describes interim remedial actions at the
SSI site and evaluates their effectiveness in capturing, removing
and treating contaminated ground water and in reducing
contaminant migration to ground water by means of vapor
extraction and treatment of contaminated soils. Contaminants
removed from both soil and ground water are captured and
permanently destroyed, significantly reducing the toxicity,
mobility or volume of the hazardous substances in both media.
V.
SUMMARY OF SITE CHARACTERISTICS
Findings 2, 5 and 6 of the Order and Sections 2.0 (second through
fifth paragraphs) and 4.0 (second through last paragraphs) of the
Staff Report describe site hydrogeological conditions and the
nature and extent of contamination. The latter section lists the
maximum concentrations of organic chemicals in soil and ground
water at the site. In addition, two inorganics, arsenic and
nickel, were detected in ground water at the SSI site at
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concentrations greater than ARARs. Appendix E of this Record of
Decision includes a map showing the areal extent of soil and
ground water contamination.
VI.
SUMMARY OF SITE RISKS
EPA policy and guidance require that the potential risk to human
health and the environment be evaluated under a No-Action
scenario. This scenario assumes unrestricted access to site
contaminants (including soils and groundwater) and assumes that
all on-going treatment and/or mitigation measures are terminated
immediately. The information provided by the baseline risk
assessment is then used to characterize the current and potential
threats posed by the site to human health and the environment.
No exposure pathways with an ECRN greater than the
range or a non-carcinogenic HI greater than 1 were
under current site conditions. Table 1, attached,
pathway exposures under future use scenarios.
10-4 to 10-6
identified
presents
Finding 10 of the Order and section 8.0 of the Staff Report
(excluding the next to the last sentence) summarize the results
of the baseline risk assessment. These sections discuss the
derivation and use of the cancer potency factors and reference
doses. Appendix C, a Board Staff Memo on "Cleanup Standards
Solvent Service, Inc." (August 6, 1990) presents the assumptions
used in the exposure assessment and uncertainties in the risk
characterization for the SSI site.
No critical habitats or endangered species were identified for
the site. The potential for migration of contaminants to any
bodies of surface water is minimal. The potential for future
ecological impacts at this site is determined to be low.
VII.
SUMMARY OF ALTERNATIVES
In accordance with CERCLA Section 121, the National Contingency
Plan ("NCP"), and the Interim Guidance on Superfund Selection of
Remedy, December 24, 1986 (OSWER Directive 9355.0-19), a range of
soil and ground water remediation options for the SSI site was
developed and initially screened based on the criteria of
effectiveness, implementability and relative cost.. Next, a
detailed analysis of the remaining alternatives in relation to
nine evaluation criteria was conducted. Section 10 of the Staff
Report identifies the nine evaluation criteria and provides a
description of the proposed alternatives.
3
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The remedial alternatives for soil and their associated costs
are:
soil Remediation Alternatives
1. No Action
Containment
2. Asphalt Cap
3. Concrete Cap
In-Si tu Treatment ..
4. Vapor Extraction
5. SIVE
$231,000
463,000
675,000
706,000
1,110,000
The remedial alternatives for ground water and their associated
costs are:
Ground Water Remediation Alternatives
1. No Action
containment
2. Asphalt Cap/Hydrodynamic Control
3. Concrete Cap/Hydrodynamic Control
Collection. Treatment and DisDosal
4. Pumping/Air stripping
5. Pumping/Adsorption
6. Pumping/Biological Treatment
7. Pumping/Combination Treatment
In-situ Treatment
8. Permeable Treatment Bed
$
711,000
2,030,000
2,242,000
1,111,000
1,497,000
1,373,000
1,567,000
2,049,000
VII!.
COMPARISON OF ALTERNATIVES
This portion of the ROD presents a comparison of the alternatives
using the nine evaluation criteria.
Protection of Human Health and the Environment
The no action alternative poses the greatest threat to human
health and the environment because contaminated ground water
could migrate off-site. The alternatives involving pumping and
treatment systems provide protection from off-site migration of
contaminated ground water but do not address the soil
contamination, which provides a continuing source of
contamination to ground water if untreated.
ComDliance with ARARs
All of the alternatives would eventually achieve cleanup
standards. However, the cleanup' standards for ground water would
eventually be reached under the no action alternative by natural
attenuation (estimated at 50 - 100 years), and ground water
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I--
I
degradation would occur to presently uncontaminated areas as the
contaminants migrated. Chemical-, location- and action-specific
ARARs identified for the SSI site include:
Federal:
Air Act
Safe Drinking Water Act, Clean Water Ac~, RCRA, Clean
state: Porter Cologne Water Quality Act, Safe
Act, Clean Air Act, California Hazardous Waste
Board Resolution 68-16, State Board Resolution
incorporated in the Water Quality Control Plan
Francisco Basin Plan
Drinking Water
Control Law, State
88-63 as
for the San
Local: Bay Air Air Quality Management District Regulation 8,
Rule 47 ("Air Stripper and Soil Vapor Extraction Operations
TBCs for the SSI site include OSWER Directive 9355.0-28 ("Control
of Air Emissions from Superfund Air strippers at Superfund
Groundwater Sites").
Finding 11 of the Order discusses ARARs for the SSI site in
further detail.
Lona-Term Effectiveness and Permanence
The vapor recovery and SIVE alternatives provide a higher degree
of residual protection than the other soil alternatives since the
contamination is removed from the soil and treated. Residual
risk from the permeable treatment bed is uncertain, but may be
higher than the pump and treat ground water remediation
alternatives. All of the alternatives are reliable, and ground
water extraction and treatment and SIVE systems currently exist
on-site. The adequacy and reliability of the permeable treatment
bed would have to be demonstrated with a pilot scale test.
Reduction of Toxicitv. Mobilitv or Volume Throuah Treatment
The no action alternative provides no active reduction of
toxicity, mobility and volume of the contaminants. Capping with
hydrodynamic control will reduce the volume and mobility of
ground water contamination. Ground water treatment alternatives
will reduce the volume, toxicity and off-site migration of
contaminants, although some treatments such as air stripping,
carbon adsorption and permeable treatment beds simply transfer
contaminants to another media. The SIVE system will reduce the
volume and toxicity of soil contaminants by removing and treating
the vapors, thereby eliminating soil as the source of continuing
ground water contamination. On-site bio-treatment, air stripping
and carbon adsorption of condensed vapors and water will reduce
toxicity and allow disposal of treated water to the sewer system,
which is preferable to off-site disposal options.
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Short-Term Effectiveness --
The capping alternative could be implemented within six months
and would reduce dust and surface erosion as well as minimizing
infiltration and recharge. Direct exposure to contaminated soil
and vapor would be eliminated. The pumping and treatment
alternatives would take considerably less time than the no action
alternative, which relies on natural processes to reach cleanup
standards. (This assumes that soil and ground water are being
remediated simultaneously). The soil vapor recovery system would
take an estimated four years to remediate soil VOC concentrations
to 1 ppm, while pilot tests indicate the SIVE system would take.
six months of continuous operation to reach this level. It is
estimated that remediation using the permeable treatment bed
would take about as long as the pump and treat alternatives.
All of the alternatives have some impact on the community and
on-site workers, but can be mitigated in all instances. The no
action and soil treatment only alternatives have the potential to
pose adverse environmental impacts if the contaminated water
migrated off-site. The capping alternative would cover the
vegetation on-site, thus reducing the habitat for wildlife. The
treatment systems may cause minor air impacts and spent carbon or
filter bed material would require disposal.
ImDlementabilitv
The no action alternative is technically and administratively
feasible. The alternatives that are part of the interim remedial
program (hydrodynamic control, the combination ground water
treatment system, and the SIVE system) have been proven to be
technically feasible with services and materials readily
available. The administrative requirements have already been
met. Installation and operation of a permeable treatment bed is
technically feasible provided a pilot scale test determines its
effectiveness for site conditions; however, availability of
services and materials is dependent upon the selected filter bed
material which is probably available locally.
Cost
The cost estimates for the soil and ground water alternatives
were presented above in Section VII. The asphalt or concrete
capping with hydrodynamic control alternatives are relatively
high in cost, but are very effective in controlling and reducing
ground water contamination. The pumping and combination
treatment alternative provides the greatest adequacy for meeting
the different treatability requirements of the contaminant
mixture. The cost effectiveness selection process favors interim
remedial programs since they already exist; the effectiveness of
these measures is known and they appropriately address the
remedial objectives.
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SupDort Aqencv AcceDtance
The state of California concurs with EPA's preferred alternative.
Community AcceDtance
No objections to the Proposed Plan were received by the Board
from the community.
IX.
THE SELECTED REMEDY
A combination of soil and ground water treatment is considered
the best alternative after considering the nine evaluation
criteria. The selected remedy is outlined in Findings 9 and 12
of the Order and Sections 11 and 12 of the Staff Report. The
selected remedy consists of:
o
o
Capping of the entire site surface with asphalt
operation of the Steam Injection and Vacuum Extraction
(SIVE) system for removal of VOCs from soil
operation of three ground water extraction trenches and
five ground water extraction wells
Bio-treatment, carbon filtering and air stripping of
extracted ground water and soil vapor
Continued monitoring of ground water and soil
o
o
o
In addition, the selected remedy includes deed
prevent development of the SSI site that might
development or the use of on-site ground water
attainment of cleanup standards.
With this remedy, the estimated time to achieve ground water
cleanup is 30 years; the estimated time to achieve soil cleanup
(with continuous SIVE system operation) is 6 months. Although
the selected remedy was not specifically designed to remediate
metals in ground water, any ground water extraction performed
will removed suspended metals as well as VOCs. Also, the SIVE
system may mobilize to some extent the metals adsorbed to soil.
restrictions to
allow residential
prior to the
The goal of this remedial action is to restore ground water to
its beneficial use. Based on the information obtained during the
remedial investigation and on a careful analysis of all remedial
alternatives, EPA and the state of California believe that the
selected remedy will achieve this goal. It may become apparent,
during implementation or operation of the ground water extraction
system and its modifications, that contaminant levels have ceased
to decline and are remaining constant at levels higher than the
remediation goal over some portion of the contaminated plume. In
such a case, the system performance standards and/or the remedy
may be reevaluated.
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The performance of the ground water extraction and treatment
system will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during
operation. Modifications may include:
a)
at individual wells where cleanup standards have been
attained, pumping may be discontinued;
alternative pumping at wells to eliminate stagnation
points;
pulse pumping to allow aquifer equilibration and to
allow adsorbed contaminants to partition into ground
water; and
installation of additional extraction wells to
facilitate or accelerate cleanup of the contaminant
plume.
b)
c)
d)
CleanuD Standards
The final cleanup standards for some chemicals in ground water at
the SSI site have been reduced to levels more stringent than
ARARs. These modifications were necessary in order to be
protective of human health in consideration of exposure to
multiple chemicals. A conservative remediation goal of 1 ppm for
total VOCs has been set for soil. The Risk Assessment indicated
that the risks for direct soil contact for the average case under
two future use scenarios was minimal. Therefore, specific
remedial actions and cleanup standards for inorganics in soil
were not presented.
Finding 11 of the Order and Section 9 of the Staff Report present
the final cleanup standards for the site. Promulgated MCLGs
serve as the ground water cleanup standards for those chemicals
of concern with MCLGs greater than zero. MCLGs are the ground
water cleanup standards for three chemicals of concern at Solvent
Service: 1,l,1-trichloroethane (l,l,l-TCA); 1,4-dichlorobenzene
(1,4-DCB); and 1,l-dichloroethene (l,l-DCE). In these three
instances, the California AL or federal or state MCL that has
been chosen as the cleanup standard is either equivalent to or
more stringent than the federal MCLG.
x.
STATUTORY DETERMINATIONS
In accordance with section 121 of CERCLA, the selected remedial
action is protective of human health and the environment,
complies with ARARs, is cost effective, and utilizes permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent possible. In
addition, the selected remedy satisfies the statutory preference
for remedies employing treatment that reduces toxicity, mobility
or volume as a principal element.
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Und~r. the c~osen remedy, future risks a~. the site fall within the
10- to 10- carcinogenic' risk range and the less-than-one Hazard
Index for non-carcinogens for all exposure pathways. Soil is
remediated to a .level that will protect ground water from future
contamination from untreated soils. The selected remedy complies
with federal and state ARARs. Implementation of the remedy will
cause no unacceptable short-term risks or cross-media impacts.
The selected remedial action is cost-effective. This remedy is
not the most costly of the alternatives that were considered, nor
is it the least expensive treatment. The estimated time to reach
soil cleanup standards is the shortest period of any of the
alternatives. Ground water cleanup times were not a factor for
comparison of alternatives since ground water extraction was the
only active ground water remedial action considered. The
combination treatment system has the advantage that it allows for
efficient treatment of a wide variety of pollutants.
Treatment is used as a principal element for the selected remedy.
Soil vapor extraction and treatment and ground water extraction
and treatment are permanent solutions and significantly reduce
contaminant toxicity, mobility and volume at the site.
The proposed ground water extraction system was not designed for
the removal of inorganics. However, it is believed that it will,
by the removal of ground water contaminated with VOCs, also
remove ground water contaminated with inorganic constituents.
The concentration of inorganics allowed in the system effluent is
regulated under permit from the San Jose Water Pollution Control
Plant.
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RESPONSIVENESS SUMMARY
for COMMENTS and QUESTIONS RECEIVED FROM
JUNE 20, 1990. to AUGUST 8, 1990
REGARDING THE
THE PROPOSED FINAL REMEDIAL ACTION PLAN
FOR
SOLVENT SERVICE, INC.
2201 BERRVESSA ROAD, SAN JOSE, SANTA CLARA COUN1Y
Introduction
This responsiveness summary reviews comments and questions regarding the Remedial
Investigation/Feasibility Study (R1IFS) and Proposed Final Ceanup Plan (proposed plan) for the
proposed Superfund site, Solvent Service, Inc. (SSI). This summcuy will include comments received
during the period from the opening of public comment at the Board meeting of June 20, 1990
through the close of public comment on July 20, 1990. In addition this summcuy will address late
comments received after the close of the comment period through August 8, 1990. The proposed
plan for the SSI facility includes six components:
1.
Steam Injection and Vacuum Extraction (SIVE)
Bio-treatment, Carbon Filtering, and Air Stripping of Extracted Groundwater,
Surface Water, and Vapor
2.
3.
Capping of the Site by Paving
4.
Groundwater Extraction
s.
Continuation of the Groundwater Monitoring Program
6.
Deed Restrictions to Control Residential Development of the Property until
Ceanup Standards for Soil and Groundwater are Achieved
Verbal comments and questions were received from the public at a community meeting held at
the San Jose City Hall on June 'D, 1990. The only written comments received during the public
comment period were from the discharger and the Santa Cara Valley Water District (SCVWD).
Additional written comments were received after the close of comment from the California
Department of Health Services, Office of Drinking Water (ODW) and SCVWD. Additional verbal
questions were received after the public comment period from the operator of a nearby trailer
park, EP A Region IX staff toxicologist and the EP A remedial project manager (RPM). No agency
or individual requested an extension of the comment period therefore the official public comment
period was closed on July 20, 1990. No comments regarding the components of the proposed plan
Page 1 of 7
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were received. Therefore no modifications to the proposed plan are included.
Background
No comments were received during the initial public hearing at the June 20, 1990 Board meeting.
A community meeting was held in San Jose on June 'D, 1990. This meeting was attended by
representatives of the City of San Jose, the Regional Water Quality Control Board, EPA Region
IX, S5I, and three individuals representing the interests of a neighboring property owner. The
individuals asked many questions regarding the site history and cleanup activities, however
comments centered on two concerns: 1) the possibility of contaminated surface water reaching
or having reached the neighboring property and 2) the potential impact of the cleanup activities
and deed restrictions on the value of the neighboring property.
The comments from the discharger concern corrections, clarifications, proposed language changes
and issues related to a groundwater plume of fuel components from an offsite source. The
comments from the EP A toxicologists were concerned with the calculation of the hazard index
for noncarcinogenic effects of the contaminants at the 551 facility. The significant comments from
the EP A RPM are language clarifications, a request for an expanded comparison of alternatives
in the staff report, and a request for the inclusion of Bay Area Air Quality Management District
(BAAQMD) rules as an ARAR.
The comments from 5CVWD express three central concerns:1) the status of the DIE zone which
is used as a domestic supply, 2) the methodology for the calculation that the proposed cleanup
standards are health protective, and 3) that the goal for cleanup standards for carcinogens should
be at the 10" (1 in 1,000,0(0) level. The comments from the ODW are similar with the additional
concerns that offsite cleanup is included only as a contingency and that new regulations
establishing representative public health levels (RPHLs) will differ significantly from the standards
proposed by this Order.
The questions from the operator of the trailer park revolved around the possibility that
contamination of a drinking water supply well in the trailer park could occur and the replacement
of this supply if the well would become contaminated.
A summary of the significant comments or questions and a response is included below. Recent
EP A guidance established a two part approach to responsiveness summaries. Under this guidance
the first part of the summary would include general response to all significant questions and
where warranted a more technical response to specific questions or comments would be included
in the second part.
The Administrative Record, containing all the documents that provide the background for the
actions proposed for this site, is available at the 5an Jose Public Ubrary and at the Regional Board
offices.
Page 2 of 7
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Community Involvement Activities
The major community relations activities are listed below:
August 1988
December 1989
Fact Sheet No.1
Fact Sheet No.2
June 1990
June 1990
Fact Sheet No.3
Community Meeting No.1
Part 1, General Response to Commenta
Local Community Comments
The majority of questions at the community meeting were concerned with site history and actual
activity at the site. This questions were answered in the meeting and had also been addressed in
the Fad Sheets, particularly Fact Sheet No.3. The major concerns expressed at the community
meeting was the possibility of overland flow of contaminated water as a result of the local surface
topography and the impact on property values. The other questions from the comm~ty carne,
verbally, from the operator of a nearby trailer park on July 28, 1990. Again the majority of
questions concerned the site history and extent of the problem. However, the main concern was
potential contamination of a domestic supply well at the trailer park. The questions regarding the
site history and activities were covered in Fact Sheets Nos. 1 and 2 and summarized in Fact Sheet
No.3. The individuals asking the questions had received at least Fact Sheet No.3.
Response
The questions regarding overland flow of contaminated water to the neighboring property was
addressed in three phases at the community meeting: 1) future runoff will be captured and
contained by the site storm water control plan as detailed in the site RCRA permit, 2) in the recent
past, approximately 2 years, a new driveway was installed between the facilities which was
elevated and would prevent surface runoff from migrating to the neighboring property, and 3)
the possible historical occurrence of runoff of contaminated water from the S5I site onto the
neighboring property could not be adequately answered during the community meeting.
Therefore staff and representatives of 5S1 agreed to provide a site tour for the individual that had
expressed this concern. In addition, staff has reviewed the files to verify that the storm water
control plan would capture storm water runoff on the site and reviewed the location of the
driveway. Review of a site investigation completed in 1985 prior to the purchase of another
neighboring parcel of land Oackson-Shaw Properties) included evidence for an absence of
contamination on any of the property surrounding S51. This was based on the results of a shallow
soil gas survey and soil samples collected during the installation of monitor wells. The individual
that had expressed this concern has been unavailable to complete the site tour. A representative
of the City of San Jose indicated that it was probable that the area near S51 would remain zoned
for commercial use only. The cleanup activity will not be apparent outside of the site and should
not have any impact on local property values.
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The well in question,located at the Trailer-Tel trailer park was identified in the potential conduit
survey completed by SSI. This well is located approximately 2000 feet downgradient of the 551 site
and may be withdrawing groundwater from the DIE zone. Contamination in this zone has only
been detected in two wells within the last two years, with the most recent sampling indicating
the presence of only two chemicals, 3 ppb Freon 113 and 3 ppb Dichloroethylene. These levels are
detected in the center of the site and do not represent a risk to human health or the environment.
Monitor wells do exist between the site and the supply well. These wells are currently non-detect
and have not, historically, detected any levels of contamination. The WC zone, which immediately
overlies the DIE aquifer, shows higher levels of contamination, however there is no indication of
communication between or migration from the BlC zone to the DIE aquifer. Comparison of the
results of analysis for inorganic constituents from the DIE aquifer and the BlC zone indicates that
the DIE aquifer and the WC zone are not connected. The maximum lateral migration of
contaminated groundwater is in the A aquifer, above the WC zone. This extends downgradient
from the site to the west-northwest for a minimum of 90 feet and up to 150 feet. This is still more
than 1800 feet laterally and over 75 feet vertically from the supply well. The groundwater in the
area west northwest of the SSI site moves very slowly and it is estimated that groundwater moves
less than 53 feet per year in this area. Therefore it is probable that contaminated groundwater,
if no groundwater extraction was performed, would take more than twenty years to reach. the
supply well in question. If the well were to become contaminated an alternative, commercial
supply of drinking water is inplace and available. Since the operator of the trailer park provides
water to the tenants from the onsite supply well without charge the concern is not with the 1055
of supply but rather with the financial consequence of being required to purchase water to
replace the lost supply. In similar situations in the South Bay the dischargers have paid for the
cost of the installation of replacement water supplies without question. This is dependent upon
the action of the discharger and might require legal action by the trailer park.
SCVWD and ODW Comments
Verbal comments were received from the California Department of Health Services, Office of
Drinking Water (ODW) regarding the proposed cleanup standards and the concerns regarding
domestic water supply wells in the area. Written comments from ODW were received on August
I, 1990. Santa Cara Valley Water District (SCVWD) has submitted written comments on the
proposed Order twice, first on July 20,1990 and again on August 3,1990. All of the comments
referenced above are included in Appendix C of the Order. The comments from both sources can
be summarized into two categories 1) concern with the manner in which risk due to exposure to
carcinogens was evaluated and the resulting proposed cleanup standards, and 2) concerns with
the levels of contamination in the units below the A aquifer.
Response
The methodology utilized for the calculation of the potential increased occurrence of cancer after
cleanup by the proposed plan is formalized in several EPA guidance documents and is widely
accepted in the risk assessment community as being the current "state of the art". The differences
in the methodology employed in the review of cleanup standards in this Order and that preferred
by ODW and SCVWD was reviewed in a meeting on July 24, 1990 with the representatives of
ODWand SCVWD. No consensus was achieved regarding the conflicting methods of calculating
the carcinogenic risk related to proposed cleanup standards.
Page 4 of 7
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Written comments were received from ODW following this meeting. The methodology proposed
by ODW would include the comparison of the proposed cleanup standard to some reference level,
probably a maximum contaminant level (Met) as defined by California or Federal law. These
comments still expressed the same concerns. Staff believes that the methodology utilized, which
compares a projected intake of a chemical at a specified concentration to a potency factor, is the
most scientifically defensible approach available. The methodology proposed by ODW would
produce lower cleanup standards, but the actual risk level related to these standards is uncertain
due to the inclusion of technical and economic considerations in the assessment of MCLs.
Additional written comments received from SCVWD indicate a willingness to accept the
methodology, however SCVWD would prefer cleanup goals that would result in a 1 in a 1,000,000
risk level. This would result in cleanup standards that are below detection limits for seven of the
8 carcinogens. This is not a technically achievable or practical goal.
Staff has modified the language that. would allow the reassessment of cleanup standards when
standards change. The intent of this modification is to clarify that this will occur should RPHLs
be codified or MCLs or other standards change. In addition staff has modified the Order to make
it more apparent that cleanup of the WC zone and offsite groundwater contamination is not iust
a contingency. Ceanup of the offsite WC zone groundwater contamination will be required, but
cleanup will be delayed until remedial actions for the onsite A aquifer has reached lower
concentrations. This is to prevent the remedial efforts from increasing the migration of
contaminated groundwater both into deeper aquifers and further offsite. A task is included in the
Order for the discharger to provide a specific plan and methodology for detennination of the
startup of the offsite and deeper aquifer remedial actions.
As discussed above the DIE zone contains levels of contaminants that are below current drinking
water standards. As suggested in the comments from SCVWD received on July 20 contaminants
in the DIE aquifer were remediated as a result of purging the wells during an intensive sampling
program in 1988. Therefore the conclusion that the contamination in the D.E aquifer is the result
of leaky well bores, not migration through the clay layer separating the DIE aquifer from the HlC
zone. The wells suspected of acting as conduits have been destroyed under pennit and
supervision of the SCVWD. The same general scenario is true of the WC zone, however the levels
of contamination that leaked along the well bores are higher therefore remediation of the HlC
zone will be required.
ODWalso expressed a concern that water supply utilities will be required to treat water extracted
from these aquifers prior to use to meet ODW standards that are calculated by different
methodologies or the RPHLs that will promulgated in the future. This ignores the fact that any
contaminants remaining in the groundwater would continue to undergo degradation, dispersion,
diffusion and attenuation that would greatly reduce the concentration of contaminants present
prior to the groundwater reaching any offsite wells. Deed restrictions are included as part of the
proposed plan to prevent wells from being installed onsite until cleanup standards have been
achieved. In addition, SCVWD regulations currently prohibit the installation of any wells in the
A aquifer or BlC zone and there is no evidence of migration of contaminants into the DIE zone.
The suggestion that results of analysis acquired under AB 1803 for nearby supply wells will be
monitored closely as suggested by the SCVWD.
Further discussions with representatives of ODW on August 6,1990 indicated that presenting the
risk at the proposed cleanup standards does not present an accurate picture .of the true risk
Page 5 of 7
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expected after cleanup: and that ODW feels that expressing the total risk as the sum of the
maximum allowable concentration gives the public an inaccurate representation of the true risk
that will remain after cleanup of the groundwater contamination. This is a result that, in general,
some chemicals are present in the groundwater at much higher concentrations than other
contaminants. Therefore, by the time the remedial actions reduce the chemicals that occur at high
concentration to the proposed cleanup standards, chemicals that originally occurred at lower
concentrations will then occur at concentrations lower than the proposed cleanup standards.
While the risk might be presented in a more realistic manner by this description it does not
address the difficulties of predicting the manner in which chemicals will move from soil to
groundwater. Due to the large number and variety of types of chemicals detected at 551 staff does
not believe that a technically accurate prediction that describes this process site can be made for
the 551 facility. This approach and other suggestions from ODW will be given careful
consideration in the description of risk and the establishment of cleanup standards in future
cleanup projects.
EPA Re~on IX Comments
Comments from EP A Region IX toxicologist indicated that the toxic effects of carcinogens must
also be considered in the evaluation of potential health effects from the groundwater after
cleanup. The Remedial Project Manager (RPM) indicated that a discussion of BAAQMD
regulations for discharge to the air should be included in the Order and staff report. Discussion
of the cleanup alternatives considered for site cleanup was considered to be inadequate.
Response
The calculation of the hazard index for the possible toxic health effects due exposure to the
groundwater after cleanup was recalculated in the staff report. The proposed cleanup levels in
the Revised Tentative Order and attached staff report reflect changes made as a result of
considering the toxic effects of additional chemicals. Discussion of the potential risks at the site
from air exposure were included in the Remedial Action Plan submitted by the discharger. A
discussion of the existence of the BAAQMD regulations and the permits required for air discharge
at the site has been added to the Revised Order and 5taff Report. An expanded comparison of the
remedial alternatives considered has been included in the revised staff report.
Dischar~er Comments
Written comments from the discharger are included in Appendix C of the Order packet. The
majority of these comments concern language changes. The one comment of concern is the
change of some guidance standards to more appropriate health based standards as opposed to
standards based on human taste and odor thresholds.
Re!iponse
Some standards were changed to more appropriate, health based guidance. This change did result
in higher concentrations for the proposed cleanup standards for some non-carcinogenic chemicals.
As a result, to maintain health protective cleanup standards, proposed cleanup standards for other
non-carcinogenic chemicals had to be reduced to lower concentrations for the 551 facility. The
discharger requested the deletion of the deed restriction from the proposed plan since 5CVWD
Page 6 of 7
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regulations prohibit the installation of wells in the HlC zone or A aquifer. Due to the possible
length time required to achieve groundwater cleanup and the uncertainty of enforcement of
regulations or possible changes in regulations staff did not delete the deed restriction from the
proposed plan. The discharger also requested that the requirement for offsite and HlC zone
remediation be clarified. Modifications have been made in the Revised Order and staff report to
address this concern.
Conclusion
Since no comments or questions were received that suggested changes to the proposed plan or
that could not be addressed by the RIIF5 or proposed plan no changes to the proposed plan are
recommended. Further, since no changes to the proposed plan are recommended Part 2 of the
Responsiveness Summary is not considered to be necessary.
Page 7 of 7
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APPENDIX A
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CALIFORltIA UGIORAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
ORDER No: 90-120
SITE cLEANUP REQUIREMENTS FOR:
SOLVENT SERVICE INC.
1021 BERRYESSA ROAD
SAN JOSE
SANTA cLARA COUNTY
The California Regional Water Quality control Board, San Francisco
Bay Region (hereinafter called the Board) finds that:
1.
Location and ResDonsible Party solvent Service Inc. (S5I),
hereinafter called the discharger, owns and operates a
treatment, storage, and disposal facility at 1021 Berryessa
Road, San Jose, santa Clara county for the purpose of waste
treatment and recycling. The site occupies 3.2 acres and is
located approximately 10 miles southeast of San Francisco Bay
and approximately 1/3 mile southwest of the confluence of
Upper penitencia Creek and coyote Creek. The site is near the
intersection of Berryessa Road and the Bayshore Freeway (see
attached map). This is an area of industrial and commercial
developmentand SSI has been in operation at this location
since 1973. Prior use of the area was for agriculture.
Pu~suant to Health and Safety code Sections 25356.1 (c) and
(d), the discharger is the only identified responsible party
associated with the release of non-petroleum contaminants to
the subsurface at this location and has accepted
responsibility for the cleanup of the site solely as it
relates to non-petroleum related contaminants. The discharger
has not assumed responsibility for the petroleum related
contaminants that form a plume along the site's southwestern
property line. Further the discharger has not assumed
responsibility for the VOCs, if any, associated with the
groundwater plume in this area.
'hemicals Detected Volatile organic chemicals (VOCs) were
first detected in groundwater in 1983 in the vicinity of
underground solvent storage tanks, the spill control
facilities, the barrel storage area and the solvent tank truck
unloading zone. The solvents detected included xylene,
acetone, 2-butanone, 1,1,1-trichloroethane (l,l,l-TCA), 1,1-
dichloroethane (l,l-DCA) and cis-1,2-dichloroethylene (cis-
1,2-DCE). Some of the chemicals detected most frequently and
. in the highest concentrations based on analytical results from
the January 1987 - July 1989 period (see attached.map) show
the ~resence in onsite groundwater of: acetone at 19,000,000
2.
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parts per billion (ppb), trichloroethylene (TCE) at 150,000
ppb, 1,1,1-TCA at 100,000 ppb, and cis-l,2-DCE at 67,000 ppb.
A recent onsite samplinq (December 1989) also detected levels
of inorganics in groundwater above the maximum contaminant
level (MCL). Arsenic was detected at a maximum level of 119
ppb and zinc at a maximum concentration of 25,400 ppb. other
inorganics detected were below the established MCLs.
Additional groundwater data was collected February and March
1990 for inorganic analysis. The results of this data, as
discussed in the staff report, indicate that most inorqanics
are not present at concentrations that are of concern.
VOCs and inorganics are identified as either carcinogenic
(cancer-causinq) or noncarcinoqenic (not cancer-causing). The
VOCs found in the subsurface at this site include several
compounds which have been included by the EPA in one of the
categories of human carcinoqens as follows: (1) known human
carcinoqen (Class A) -benzene, vinyl chloride, and arsenic;
(2) probable human carcinoqen (Class B1 and B2) - chloroform,
1,4-dichlorobenzene (1,4-DCB) , TCE, tetrachloroethylene (PCE) ,
l,l-DCA and methylene chloride: (3) possible human carcinogen
(Class C) - 1,1-dichloroethylene (l,l-DCE), and isopborone.
Lead Aaencv Pursuant to the South Bay Multi-Site cooperative
Agreement (MSCA) and the South Bay Ground Water contamination
Enforcement Agreement, entered into on May 2, 1985 (as
subsequently amended) by the Reqional Board, EPA and DHS, the
Reqional Board has been actinq as the lead regulatory
agency. The Regional Board will continue to regulate the
discharger's remediation and administer enforcement actions in
aceordance with CERCLA as amended by SARA.
3.
4.
NPL and Orders The site has been proposed for inclusion on
the National Priorities List (NPL) and has been requlated by
Reqional Board Orders, as indicated herein:
Reqional Board adopted Waste
Discharge Requirements.
a. March 1986
b. April 1988
c. June 1988
d. April 1989
Reqional Board adopted revised
site Cleanup Requirements.
site proposed for the NPL.
Reqional Board adopted Revised
site Cleanup Requirements.
5.
Ad;acent site Chevron Inc. (Chevron) owns and operates a fuel
distribution terminal at 1020 BerryesSa Road, San Jose, santa
Clara County. This facility provides hydrocarbon products for
Page 2 of 23
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the South Bay area. Subsurface investigations at this site
have revealed the presence of benzene, toluene, xylene, and
ethylbenzene (BTX&E) in soil and groundwater beneath the site
including separate phase hydrocarbon product (HCs). The
occurrence of separate phase hydrocarbon has been documented
in the subsurface at the Che~~on facility since at least 1984.
Dissolved and separate-phase HCs, which appear to have
migrated from Chevron, were detected by SSI during
investigations along the southwest 5SI site boundary, on the
neighboring Jackson-Shaw property, in 1988. In addition, low
levels of VOCs have been detected in some wells in this area.
Based on current data collected by SSI and Chevron the HC
plume apparently continues beyond the SSI site to the
northwest.
6.
Hvdroaeoloav SSI is in the Santa Clara Valley which is a
sedimentary basin filled with unconsolidated heterogeneous
alluvial material, interspersed with layers of marine clay.
The alluvium is a mixture of permeable, water-bearing sands
and gravels, interbedded with less permeable silts and clays.
The soils are extremely variable over short distances, both
horizontally and vertically.
S5I is underlain by three distinct hydrogeologic units.
Aquifer A is an unconfined, low permeability aquifer that
occurs from the ground surface to a depth of 20 to 25 feet (50
to 75 feet MSL). The A aquifer is currently locally dewatered.
It consists of sandy silts, clay, and a thin, continuous
poorly sorted sand layer at its base. Aquifer A is underlain
b~ a clay layer which is typically 6 to 16 feet in thickness.
This clay layer may be as thick as 60 feet in some locations
on site. The clay layer may impede vertical downward migration
of groundwater. Ancestral stream channel deposits have a1so
been identified along the southwestern margin of the site in
the A aquifer.
Zone B/C consists of lenses of sands, silts, and clays. It
extends to 50 feet below the upper clay layer (0 feet MSL) and
appears to be laterally continuous across the site. Water
levels in this zone are 1 to 2 feet lower than Aquifer A but
little vertical leakage is believed to be occurring. The B/C
zone is probably not representative of an aquifer and will be
referred to as a zone not an aquifer in this Order. A clay
layer, 2 to 10 feet thick, occurs at the base of Zone B/C.
The third zone, Aquifer DIE, consists of an upper member - a
thick sequence of silts and sands underlain by a thin clay
layer - and a lower member - two sand layers separated by a 2
to 5 feet thick silt layer. A clay layer occurs at the base of
this zone, 150 feet below the ground surface (-75 feet MSL).
Zone DIE is believed to be very permeable and has'b~en used
Page 3 of 23
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historically for domestic water supply.
7.
Interim Remedial Actions Three underground storage tanks used
for solvent storage, spill control, and waste solvent storage,
were removed in or about 1982. Adjacent soil was also removed,
however this is not well documented. The highest levels of
pollutants in soil remain 'beneath the existing concrete pad
that presently underlies the major treatment and storage area.
The solvent truck unloading area, the barrel storage area, the
spill containment facility, and other treatment and storage
areas were gradually paved with concrete by 1984. CUrrently,
most of the treatment and storage area is paved. Additional
interim remedial measures have included the placement of berms
in the treatment and storage area and changing operational
procedures to minimize risk of additional contamination.
SSI currently operates a containment/extraction system for the
groundwater plume. The system includes 5 recovery wells and 3
extraction trenches. Extracted groundwater is being treated by
a biological treatment system, air stripping, and carbon
adsorption. Treated water is used in the SSI cooling towers
and is subsequently discharged into the sanitary sewer under
authorization from the sanitary district. This system appears
to be effective in containing migration of pollutants
originating onsite and of removing pollutants from the
extracted groundwater. However, some pollutants have migrated
to and slightly beyond the property boundaries. These
pollutants are believed to have migrated beyond the location
of the trenches prior to installation of the trenches.
SSI has also been operating a steam injection/vacuum
extraction system since December 1989 as an interia remedial
.action, for onsite in-situ soil remediation, to address the
highly contaminated soils that remain inplace beneath the
concrete pad.
8.
Remedial Investiaation/Feasibilitv Studv and Remedial Action
nAIl The discharger has submitted a Remedial Investigation and
Feasibility Study (RI/FS) Report which satisfies the
requirements of Regional Board Order No. 89-51, Site Cleanup
Requirements, adopted by the Board April 19, 1989. The FS
report includes a detailed screening of five alternatives for
soil remediation and eight alternative groundwater remedial
actions, a baseline risk assessment, and a proposed final
remedial action plan (RAP).
The RI/FS Report, originally dated October 17, 1989, was
revised and updated and submitted to the Board on January 19,
1990. Additional revisions to RI/FS were required and a the
second revised RI/FS was submitted to the Board on May 30,
1990. The final draft RI/FS Report and its revisions .have been
Page 4 of 23
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available for 'public review since May 31, 1990.
The proposed final Remedial Action Plan (RAP) was received by
Board staff May 31, 1990. A proposed final cleanup plan was
presented to the Regional Board for informational purposes at
the Board Meeting of June 20, 1990. A Public Meeting to obtain
comments on and public input to the proposed final RAP is
scheduled for the San Jose City Hall on June 27, 1990.
The RI/FS identifies Applicable or Relevant and Appropriate
Requirements (ARARs) and To Be Considereds (TBCs) according to
CERCLA guidance documents. Appropriate ARARs/TBCs for this
site are listed and discussed in Finding 11, Final Cleanup
Standards.
The RI/FS also summarizes the potential human health and
environmental effects that may result from the presence of
chemicals in the soil and groundwater as presented in the
Baseline Public Health Evaluation prepared by ICF/Clement
under contract to the Board. The effects of exposure on the
environment were determined to be negligible. Impacts upon
human health were determined to be unlikely under current use
conditions.
The RI/FS has evaluated no-action alternatives for soil and
groundwater, four (4) alternative soil cleanup plans, and (7)
alternative groundwater cleanup plans. From among these
alternatives that were selected for detailed screening the
Remedial Action Plan (RAP) submitted by the discharger
recommends in-situ steam injection/vacuum extraction (SIVE)
for soil remediation and groundwater extraction and treatment
as' a final remedial action for groundwater. These elements
have been combined with eventual "capping" of the site by
asphalt and continued groundwater monitoring in the final RAP.
The Board concludes that SIVE for the soil remediation, and
extraction and treatment of groundwater can both remove VOCs
from the target media. Extraction and treatment of groundwater
will take a long period of time to achieve cleanup standards.
However, in conjunction with SIVE, for soil remediation, the
VOC removal will be accelerated. The Board further concludes
that additional investigative work is necessary to
appropriately assess the potential effects of inorganic
chemical concentrations and to establish naturally occurring
concentrations or "background" and to install remedial actions
for inorganic chemical concentrations in soil and groundwater
to "background", if necessary.
The groundwater extraction/treatment system has been installed
at an estimated capitol cost of $399,000. The annual cost of
operation and maintenance is estimated to be $884,000. The
SIVE system is currently inplace onsite, the estimated capitol
Page 5 of 23
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~
expenditure for this installation is $549,000. The annual
operation and maintenance cost for this alternative is
estimated to be $288,000. If it is determined that it is
necessary to operate the. SIVE system in vacuum mode to achieve
soil cleanup standards operating and maintenance cost will be
reduced to $250,000 annually.
Final CleanuD Plan Based primarily on information submitted
by the discharger in the RI/FS Report, RAP, and
review/comment, this Order provides for a final cleanup plan
that includes:
9.
a.
Groundwater containment/Removal - continued groundwater
extraction from the A aquifer will be required until
chemical concentrations are reduced to levels that will
meet ARARs and are protective of human health. The
rationale for these standards are detailed in Finding 10
and the actual standards are listed in Finding 11. As
with any technical project there is uncertainty in the
attainment of these standards. However, groundwater
extraction is a proven technology for the removal of mass
of contaminants from groundwater and it bas been
demonstrated that the system in place will contain
polluted groundwater onsite.
contaminated groundwater from the offsite portion of the
contaminant plume may be "pulled" back and recovered by
the extraction trenches, however this has not been
demonstrated by current data. Therefore extraction from
A aquifer offsite may be required, however this will be
delayed until levels of pollution in onsite soil and
groundwater are reduced to specified limits acceptable to
the Executive Officer. The purpose of the delay in the
startup of off-site extraction is to prevent off-site
migration from being accelerated by off-site pumping.
continued monitoring of groundwater in the A aquifer, B/C
zone, and D/E aquifer will be required and extraction
from the B/C zone may also be required. .
b.
Evaluation of groundwater extraction from the offsi te
portions of the A aquifer, B/C zone, and D/E aquifer will
also be required
Soil Cleanup - SSI will operate a steam inj ection
vacuum extraction system (SIVE) to remediate the onsite
soil contamination. Vacuum extraction is a proven
technology for soil remediation and is widely used at
other South Bay sites. The enhancement of vacuum
extraction has been demonstrated in an onsi te pilot
project that indicated that this technology would reduce
the levels of VOCs in soil by up to two orders of
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magnitude 'in coarse grained sediments in a short time
period. The advantage that the SIVE system provides over
vacuum extraction is reduced time to cleanup, however the
system is designed to allow continued operation in the
vacuum mode should steam enhancement not provide any
advantage.
Cleanup standards for polluted soils are less than one
part per million (1 ppm) total VOCs and semi-volatile
organic chemicals (SOCs). The system will be operated
until these levels of soil pollution are attained. A
different soil cleanup level for VOCs may be acceptable
if: (1) the Executive Officer determines that higher
levels of total VOCs can remain in soils without
adversely affecting groundwater resources now or when
groundwater extraction is terminated, or (2) the
Executive Officer and EPA determines that it is
infeasible to achieve the cleanup standard and that
public health and the environment will be protected.
Information obtained from tests conducted on source area
soils will be considered in determining if a different
soil cleanup level should be established. Based on
current data summarized in the Baseline Public Health
Evaluation, inorganics in the shallow soil vill not
constitute a human health hazard through direbt contact
with the soil. Since these inorganics are Dot very
mobile, migration into groundwater is considered to be
unlikely. Therefore no cleanup standards will be proposed
for soil inorganics.
containment - In addi tion to the above eleaents the
proposed cleanup plan will include the capping of the
site with asphalt. This will eliminate potential fugitive
dust emissions and will limit infiltration of surface
water into the subsurface through any contaminated soil
during soil remediation and will limit leaching of any
soil contamination that may remain following cleanup. In
addition, the capping of the site may improve the
efficiency of the SIVE system. This portion of the
proposed plan is dependent upon city approval for
construction.
c.
Water Reuse - It is the goal of this plan to continue the
100' reclamation and/or reuse of 'the groundwater that is
extracted and treated. This standard bas been aet during
the operation of the interim actions and is contained as
part of the proposed cleanup plan.
Monitoring - Moni toring of groundwater will continue
during the operation of the remedial systems. Long-term
monitoring beyond projected cleanup times may be required
if stability of cleanup levels cannot be demonstrated for
d.
e.
Page 7 of 23
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10.
f.
one year after standards are achieved.
Insti tutional Controls - Deed restrictions to prevent the
development of the 551 property in a manner that might
allow residential development or the use of onsite
groundwater prior to the attainment of cleanup standards
will be required as a"protective measure.
Hazard Indices and Cancer Risk Numbers The Hazard Index (HI)
is the method used by the Board to assess the public health
risk associated with the presence of multiple, non-
carcinogenic chemicals. The health risk related to exposure to
carcinogens is evaluated through the use of excess cancer risk
numbers (ECRN). The use of the HI as a ratio between CDI and
RfD for noncarcinoqens and estimation of increased population
cancer risk for carcinogens is detailed in the EPA Risk
Assessment Guidance (July 1989).
The calculation of excess cancer risk numbers (ECRN), the
product of a cancer slope or cancer potency factor and the
chronic daily intake (q* x CDI), is the method used to
evaluate the potential risk of increased cancer incidence due
to exposure to carcinogenic chemicals at this site. There is
no "zero-risk" level associated with the threat of exposure to
carcinogens. The total ECRN for a group of chemicals is
calculated by summing each individual chemical's ECRN. A
number of assumptions have been made in the derivation of
these values, many of which are intentional overestimates of
exposure and/or toxicity. The actual incidence of cancer is
likely to be lower than these estimates and may even be zero.
These tools were used by Board staff to determine appropriate,
health protective, cleanup standards for soil and groundwater.
.An HI of less than 1 would indicate that no adverse health
affects would be expected from exposure to the noncarcinogenic
chemicals considered. An ECRN in the 10-4 to 10-' range is
required for Superfund sites under the National Contingency
Plan (NCP) adopted March 9, 1990. These are the minimum goals
for cleanup standards at the 5SI site. The calculations for
this site are detailed in the attached Staff Report.
The HI and total ECRN are much greater than what would be
considered an acceptable risk due to the presence of the
chemicals identified in useable groundwater and in soil for
the no-action alternative. The chemical concentrations in
groundwater can be further reduced, and may be reduced to, or
below, drinking water applicable, relevant, appropriate
requirements and other non-codified regulatory guidelines to
be considered (ARARs/TBCs) by remediation. The chemical
concentrations in soil can be further reduced by in-si tu
remediation to achieve background levels and to restore
groundwater to its original use-suitability' .within a
Page 8 of 23
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reasonable time 'frame: and, if required, to provide an extra
margin of protection for human health and the environment.
Therefore, appropriate cleanup standards must be established.
The exposure point concentration, HI, and total ECRN result
from a hypothetical scenario, the possibility that water from
this site might be consumed as drinking water. These numbers
are intended to be used as tools to evaluate the severity of
risk or hazard that a site might represent. While the vater is
currently not used as drinking water the associated residual
chemical concentrations expected to be present in the future
and the potential health hazard presented by current
concentrations are sufficient cause to pursue a remedial
alternative other than no-further-action. It is the intent of
the actions planned for this site to preserve the potential
beneficial uses of the water, which include use as a source of
drinking water, and to eliminate any possible concern of
migration of chemicals into drinking water aquifers.
.
Using the HI-less-than-one and the 10.6 ECRN concentrations to
establish cleanup standards would attempt to approximate
primary cleanup objectives, but may not be practical for all
chemicals. Less stringent cleanup standards for some chemicals
may be appropriate due to the following considerations: (1)
the practical detection/quantification limits for some
chemicals do not permit measurement by standard methods of
such low concentrations: (2) there are no water-tap exposures
above health-based levels actually occurring in the vicinity
of this site at present or expected in the future: (3) the
potential for human exposure from pathways other than future
potential drinking water ingestion or inhalation is minimal to
none: (4) there are no sensitive populations or special
environmental receptors in the immediate vicinity of the site;
(5) the levels of arsenic required to be health protective may
be below local background arsenic levels.
final CleanuD standards The cleanup standards for Aquifer A
and the B/C zone are the California CHS Action Level (AL),
non-zero Maximum contaminant Level Goal (MCLG), or Maximum
contaminant Level (MCL), whichever is more stringent, for
drinking water, or a standard based on other health-related
reference information as described herein.
11.
state Board Resolution 68-16 will also be considered as an
ARAR. It is the intent of this order and the proposed cleanup
levels to protect all beneficial uses of the groundwater.
Since one identified beneficial use of the groundwater is as
a potential source of drinking water, the cleanup objective is
to restore groundwater quality by removing the maximum amount
of chemicals in the groundwater as is technologically
feasible. In adfdition the economic benefit to the people of
the state of CAaifornia shall also be considered. Another
Page 9 of 23
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objecti~~ _jor importance is to remove the potential
threat ~ by ~e presence of cancer-causing chemicals at
this si1a'fhe process of removing carcinogens will result in
the reme81 af DOn-carcinogens as well.
For ev8l&~ion of ~otal risk due to the ingestion of
ground~ from the si~e i~. each of the two categories
(carcidIPD and non-carcinogen) initial cleanup standards (in
~g/l) ~:~e site were established based on:
a.
oIi'farnia DHS AL or MCL values for non-carcinogens: 1, 2-
DCI (5), cis-1,2-DCE (6), trans-1,2-DCE (10),
e~en~ene (1750), 1,1,1-TCA (200), Freon 113 (1200),
s81nium (10), and xylenes (1750): and for carcinogens:
a~ic (50), benzene (0.7), 1,4-DCB (0.5), 1,1-DCA (5),
1~ (6), methylene chloride (40), PCE (5), TeE (5),
all yinyl chloride (0.5).
~ BCL yalues for copper (1300) and zinc (5000), and
~ne (2000).
b.
c.
'.18 Applied Action Level of the DHS Toxic Substances
Q8&rOl Division for chloroform (6).
~ EPA In~egrated Risk Information system (IRIS) oral
~rence dose for acetone (3500).
'lW EPA National Ambient Water Quality criteria for
~ic Beal th Effects for antimony (14), isophorone
~O}, nickel (154), phenol (3500), and thallium (1).
d.
e.
f.
~ EPA Drinking Water Health Advisory for Naphthalene
(5100) .
Some aI these s~andards have been reduced to concentrations
lower $An ARARs, 'rBCs or other guidance. These modifications
were .-cessary to be protective of human health in
consi~ation of exposure to multiple chemicals. setting of
stand'- for 80me compounds described as chemicals of concern
in the 8PHE bas been deleted following staff review of current
groun~ter data (see Appendix A). Health protective guidance
has not been established for some chemicals. Proposed final
cleanup standards based on this review depart from the above
standaidS as follows:
CleanuD staadard Lower than 1RARs/TBCs
Acetone - 400 ~g/l
Naphthalene - 2000 ~/l
1,1-DCI - 1 ~g/l
EthylbenZene - 400 ~g/l
Page 10 of 23
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Methylene Chloride -
Nickel - 80 ~g/l
Phenol - 2000 ~g/l
Toluene - 1000 ~g/l
30 ~g/l
No Guidance currentlv Established
2-Butanone - 20 ~g/l
4-Meth.-2-pent. - 10 ~g/l
Deleted
Antimony, Arsenic, copper, Isophorone, Selenium, Thallium,
1, 2, 4-Trichlorobenzene, and Zinc
12.
The soil remediation standard is 1 ppm for total VOCS.
An additional concern that is discussed in the FS and the
Remedial Action Plan (RAP) is the potential contamination of
the air at the solvent service site. The appropriate standards
for this consideration are the regulations of the Bay Area Air
Quality Management District (BAAQMD) Regulation 8, Rule 47
which is an ARAR for the SSI facility. The air stripper system
and vapor extraction systems at the SSI site are regulated by
the BAAQMD. The air emissions from these units do satisfy the
ARAR cited above as regulated by the BAAQMD.
Uncertainitv in Achievina CleanuD Standards The goal of this
remedial action is to restore groundwater to its beneficial
uses. Based on information obtained during the RI and on a
ca~eful analysis of all remedial alternatives, the Board
believes that the selected remedy will achieve this goal.
However, studies suggest that groundwater extraction and
t~eatment will not be, in all cases, completely successful in
reducing contaminants to health-based levels in the aquifer
zones. The Board recognizes that operation of the selected
extraction and treatment system may demonstrate the technical
impracticability of reaching health-based groundwater quality
standards using this approach. If it becomes apparent, during
implementation or operation of the system, that contaminant
levels have ceased to decline and are remaining constant at
levels higher than the remediation goal, that goal and the
remedy may be reevaluated.
The selected remedy will include groundwater extraction for a
period of up to 30 years, during which the system's
performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during
operation. Modifications may include:
a)
discontinuing operation of extraction wells in
areas where cleanup standards have been ~ttained:
Page 11 of 23
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13.
b)
at
wells
to
eliminate
c)
alternating pumping
stagnation points: and
pulse pumping to allow aquifer equilibration and
encourage adsorbed contaminants to partition into
groundwater.
Future Chanaes to CleanuD Levels If new information
indicates cleanup standards cannot be attained or can
reasonably be surpassed, the Regional Board will decide if
further final cleanup actions beyond those completed shall be
implemented at this site. If changes to the cleanup standards
or amended cleanup standards are proposed, due to the claimed
technical infeasibility of attaining the standards, adopted by
this order, a new Order will be submitted to the Board for
consideration and to EPA Region IX for their concurrence. If
changes in health criteria, administrative requirements, site
conditions, or remediation efficiency occur, the discharger
will submit an evaluation of the effects of these changes on
cleanup levels as specified under Provision C.1.i.
The Regional Board will not require the discharger to
undertake additional remedial actions with respect to the
matters previouslY described herein unless: (1) conditions on
the site, previouslY unknown to the Regional Board, are
discovered after adoption of this Order, or (2) new
information is received by the Regional Board, in whole or in
part after the date of this Order, and these previously
unknown conditions or this new information indicates that the
remedial actions required in this order may not be protective
of public health and the environment. The Regional Board will
also consider technical practicality, cost effectiveness,
state Board Resolution No. 68-16 and other factors evaluated
by the Regional Board in issuing this Order in determining
whether such additional remedial actions are appropriate and
necessary.
14.
Groundwater conservation The Regional Board strongly
encourages, and requires to the extent allowed by law, the
maximum reclamation or reuse of groundwater feasible either by
the discharger or other public or private water users. These
measures include reinjection, reuse, or reclaaation of
extracted groundwater. The discharger's interim groundwater
extraction and treatment system includes treatment of
extracted groundwater then reuse in the site cooling tower
prior to release to the sanitary sewer system under permit
from the San Jose Water Pollution control Plant.
15.
~aluation of Final Plan In accordance with the Health and
Safety Code Section 25356.1, section 121 of CERCLA, the final
remedial action plan (including the RI/FS Report submitted by
the discharger and this Order) is equivalent to a feasibility
Page 12 of 23
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16.
study: satisfies the requirements of the california Water Code
section 13304 and is protective of human health and the
environment: attains Applicable or Relevant and Appropriate
Requirements (ARARS): utilizes permanent solutions and
alternative treatment technologies and resource recovery
technologies to the maximum extent possible for short-term
effectiveness: is implementable: is cost effective: is
acceptable based on state regulations, policies, and guidance:
and reduces toxicity, mobility, and volume of pollutants.
~ommunitv Involvement An aggressive community Relations
program has been ongoing for all santa Clara Valley superfund
sites, including the SSI site. A notice was published in the
San Jose Hercury News on June 14, 1990 announcing the proposed
cleanup plan and opportunity for public comment at the Board
Meeting of June 20, 1990 in Oakland, and at an evening public
meeting to be held at the San Jose city Hall in the city of
San Jose on June 27, 1990. Fact Sheets 1 and 2 were mailed to
interested residents, local government officials, and media
representatives. Fact Sheet 3, dated June 1990 described the
proposed final RAP, announced opportunities for public comment
at the Board Meeting and the Public Heeting, and the
availability of further information at the Information
Repository at the San Jose Public Library.
Public concerns expressed at the Regional Board meeting of
June 20, 1990 in Oakland and at the public meeting of June 27,
1990 in San Jose, and in comments received by the Regional
Board through July 20, 1990, the close of the public comment
period, have been considered in this revision of the Tentative
order. Public comment did not generate any significant changes
to'the proposed plan. comments received after July 20, 1990
and at the Regional Board meeting of August 15, 1990, will be
addressed by review and evaluation, and incorporated by
appropriate response in the final Order.
pat a oualitv Development of the Board's final Remedial Action
Plan was based on the Regional Board staff evaluation of
almost eight years of water and soil quality data. Random
samples have been collected and analyzed by the Regional Board
to confirm the validity of data generated by the discharger.
Data has been validated using EPA validation guidance. The
data was judged to be acceptable for qualitative purposes.
This judgement, in combination with the internal consistency
and size of the data set and comparison to duplicate data
collected by Board staff and analyzed by the Board's contract
lab, indicates that the data has been used in a manner
consistent with its quality.
17.
page 13 of 23
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18.
19.
state Board Resolution 68-16 On October 28, 1968 the state
Board adopted Resolution No. 68-16, "statement of Policy with
Respect to Maintaining High Quality Waters in California".
This policy calls for maintaining existing high quality of
state waters unless it is demonstrated that any change would
be consistent with the maximum public benefit and not
unreasonably affect beneficia.l uses. The original discharge of
waste to the groundwater at this site was in violation of this
policy: therefore, the groundwater quality neecls to be
restored to its original or background quality to the extent
reasonable. A return to background quality means achieving a
restored groundwater throughout the site that has no
detectable concentration of any VOC or SOC and inorganics at
the local background level. Even if this condition were
achieved for one or more VOCs or SOCs temporarily, it appears
unlikely that all VOCs and SOCs can be completely removed
permanently without the removal of all existing polluted soil
and groundwater on the site. It may not be feasible to remove
all the polluted soil and groundwater at this site: therefore
it may not be feasible to expect to achieve this water quality
objective.
Since it is probable that return of the groundwater quality to
background is technically infeasible, cleanup standards have
been selected that meet or exceed ARARs and are protective of
human health and the environment. In this manner beneficial
uses are protected.
20.
state Board Resolution 88-63 On March 15, 1989, the Regional
Board incorporated the SWRCB Policy of "Sources of Drinking
Water" into the Basin Plan. The policy provides for a
Municipal and Domestic Supply designation for all waters of
the State with some exceptions. Groundwaters of the state are
considered to be suitable or potentially suitable for
municipal or domestic supply with the exception of: 1) the
total dissolved solids in the groundwater exceed 3000 mg/L,
and 2) the water source does not provide sufficient water to
supply a single well capable of producing an average,
sustained yield of 200 gallons per day. Based on data.
submitted by the discharger, the Regional Board finds that
neither of these two exceptions apply to the groundwater at
5SI. Thus, the A aquifer at SSI is a potential source of
drinking water.
The Regional Board adopted a revised Water Quality control
Plan for the San Francisco Bay Basin (Basin Plan) on December
16, 1986. The Basin Plan contains water quality objectives and
beneficial uses for South San Francisco Bay and contiguous
surface and underground waters.
Page 14 of 23
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21.
22.
23.
24.
The existing and potential beneficial uses of the groundwater
underlying and adjacent to the facility include:
a.
b.
c.
d.
Industrial process water supply
Industrial service water supply
Municipal and domestic water supply
Agricultural water supply
The discharger has caused or permitted, and threatens to cause
or permit, waste to be discharged or deposited where it is or
probably will be discharged to waters of the state and creates
or threatens to create a condition of pOllution or nuisance.
Final containment and remediation measures need to be
implemented to alleviate the threat to the environment posed
by the plume of pollutants.
This action is an order to enforce the laws and regulations
administered by the Regional Board. This action is
categorically exempt from the provisions of the CEQA pursuant
to section 15321 of the Resources Agency Guidelines.
The Board has notified the discharger and interested agencies
and persons of its intent under California Water Code Section
13304 to prescribe site Cleanup Requirements for the discharge
and has provided them with the opportunity for a public
hearing and an opportunity to submit their written views and
recommendations.
25.
The Regional Board, in a public meeting, heard and considered
all comments pertaining to the discharge.
.
IT IS HEREBY ORDERED, pursuant to section 13304 of the California
Water Code, that the discharger shall cleanup abate the effects
described in the above findings as follows:
A.
PROHIBITIONS
1.
The discharge of wastes or hazardous materials in a
manner which will degrade water quality or adversely
affect the beneficial uses of the waters of the state is
prohibited.
2.
Further significant migration of
subsurface transport to waters
prohibited.
chemicals through
of the state is
3.
Activities associated with the subsurface investigation
and cleanup which will cause significant adverse
migration of chemicals are prohibited.
Page 15 of 23
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B.
SPECiFiCATiONS
2.
The storage, handling, treatment or disposal of soil or
groundwater containing chemicals shall not create a
nuisance as defined in section 13050 (m) of the
California Water Code.
The discharger shall conduct monitoring activities as
needed to define the current local hydrogeologic
conditions, and the lateral and vertical extent of soil
and groundwater containing chemicals. Should monitoring
results show evidence of continuing pollutant migration,
additional plume characterization may be required.
Health protective, final cleanup standards for all
groundwater, both onsite and offsite, shall be set as
follows:
1.
3.
CHEMICAL
CONCENTRATION (~g/l)
400
20.0
5.0
6.0
10.0
400
1200
10.0
2000
2000
200
1000
1750
1.0
6.0
0.5
5.0
30.0
1.0
5.0
5.0
0.5
ACETONE
2-BUTANONE
1,2-DCB
cis-1,2-DCE
trans-1,2DCE
ETHYLBENZENE
FREON-113
4-METH.-2-PENT.
NAPHTHALENE
PHENOL
1,1,1 TCA
TOLUENE
XYLENES
BENZENE
CHLOROFORM
1,4-DCB
l,l-DCA
METH. CHLORIDE
l,l-DCE
PCE
TCE
VINYL CHLORIDE
Groundwater cleanup obj ecti ves are: (1) restore the
quality of a polluted water source to its potential
suitability as a drinking water supply, (2) prevent
exposure to polluted water, and (3) prevent migration of"
polluted groundwater to the deeper aquifers which
presentlY supply water for domestic (drinking) and other
beneticial uses.
4.
Page 16 of 23
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5.
The discharqer shall implement the final cleanup plan
described in Findinq 9.
C.
PROVISIONS
1.
The discharqer shall comply with prohibitions A.l., A.2.,
and A.3., and specifications B.l., B.2., B.3., B.4, and
B.S. above, in accordance with the followinq time
schedule and tasks. Any reports, includinq quarterly
reports, due concurrently may be combined in a sinqle
submission:
ONSITE TASKS/COMPLETION DATE:
GROUNDWATER EXTRACTION AND TREATMENT SYSTEII:
a.
Submit a technical report acceptable to the Executive
Officer documentinq construction and implementation of
qroundwater extraction and treatment systems as approved
by the Reqional Board in the Remedial Action Plan.
COMPLETION DATE:
November 31, 1990
b.
SOIL REMEDIATION SYSTEM:
Submit a technical report acceptable to the Executive
Officer documentinq construction and implementation of a
soil remediation system as approved by the Reqional Board
in the Remedial Action Plan.
COMPLETION DATE:
November 31, 1990
c.
REVISED SAMPLING AND ANALYSIS PLAN
Submit a technical report acceptable to the Executive
Officer containinq a proposed Samplinq and Analysis Plan,
as described in CERCLA/SARA quidance. This plan should
include a schedule for soil and qroundwater sampling
durinq operation of the SIVE system and a description of
wells that will be sampled to monitor migration of
chemicals in the subsurface durinq operation of the SIVE
system. This plan should al~o include analysis by
appropriate EPA series 8000 analysis techniques.
This report shall also contain a second schedule for
samplinq and analysis that will followinq the attainment
of soil cleanup standards. This plan should include a
schedule for soil and qroundwater samplinq followinq
cessation of operation of the SIVE system and a
description of wells that will be sampled to monitor
miqration of polluted qroundwater in the subsurface and
wells that will sampled and analyzed to verify that
paqe 17 of 23
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cleanup standards for groundwater have been achieved.
This plan should also include analysis by appropriate EPA
series 8000 analysis techniques.
COMPLETION DATE: DECEMBER 15,1990
d.
PROPOSAL TO TERMINATE OPERATION OF THE SOIL cLEANUP
SYSTEM. . .
Submit a technical report acceptable to the Executive
Officer and the EPA containing a proposal for ter1ainating
operation of the soil remediation system and criteria
used to justify this action. This report shall include a
proposal indicating the locations of borings and sampling
intervals to determine concentrations of VOCs remaining
in the soil.
COMPLETION DATE:
30 days prior to expected
termination of soil cleanup
e.
COMPLETION OF ONSITE SOIL REMEDIATION.
Document in the appropriate quarterly report the
completion of the necessary tasks identified in the
technical report submitted for Task C.l.d including the
results of chemical analyses of samples from the soil
borings.
COMPLETION DATE:
Due date for quarterly status report
for the quarter in which operation
of the soil remediation system is
terminated.
f.
ONSITE WELL
PROPOSAL.
PUMPING
CURTAILMENT
CRITERIA
AND
Submit a technical report acceptable to the Executive
Officer containing a proposal for curtailing pumping from
onsite groundwater extraction welles) and trenches) and
the criteria used to justify such curtailment. This
report shall include data to show that cleanup standards
for all VOCs have been achieved and have stabilized or
are stabilizing, and that the potential for pollutant
levels rising above cleanup standards is minimal. This
report shall also include an evaluation of the potential
for pollutants to migrate downwards to the DIE aquifer at
this location. If the discharger claims that it is not
technically feasible to achieve cleanup standards, the
report shall evaluate the alternate standards that can be
achieved. cessation of pumping will require the
concurrence of the Regional Board and EPA, should either
Page 18 of 23
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party not concur, continued pumping will be required.
COMPLETION DATE:
90 days prior to proposed
implementation of onsi te groundwater
extraction curtailment
g.
IMPLEMENTATION OF ONSITE CURTAILMENT.
Submit a technical report acceptable to the Executive
Officer documenting completion of the necessary tasks
identified in the technical report submitted for Task
C.l.f.
COMPLETION DATE:
30 days after the Regional Board
approves onsite curtailment
.
h.
FIVE-YEAR
EVALUATION.
STATUS
REPORT
AND
EFFECTIVENESS
Submit a technical report acceptable to the Executive
Officer containing the results of any additional
investigation including the soil remediation study: an
evaluation of the effectiveness of installed final
cleanup measures and cleanup costs: additional
recommended measures to achieve final cleanup ebjectives
and standards, if necessary: a comparison of previous
expected costs wi th the costs incurred and proj ected
costs necessary to achieve cleanup objectives and
standards: and the tasks and time schedule necessary to
implement any additional final cleanup measures.
This report shall also describe the reuse of extracted
groundwater, evaluate and document the cleanup of
polluted groundwater, and evaluate and document the
removal and/or cleanup of polluted soil. If safe drinking
water levels, through the removal of the chemicals for
which this Order specifies cleanup standards, have not
been achieved onsite and are not expected to be achieved
through continued groundwater extraction and/or soil
remediation, this report shall also contain an evaluation
addressing whether it is technically feasible to achieve
drinking-water quality onsite, and if so, a proposal for
procedures to do so.
COMPLETION DATE:
August 21, 1995
1.
EVALUATION OF NEW HEALTH CRITERIA:
Submit a technical report acceptable to the Executive
Officer which contains an evaluation of how the final
plan and cleanup standards would be affected, if the
concentrations as listed in specification B.4. change as
Page 19 of 23
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I~
a result of changes in source-document conclusions or
promulgation of drinking water standards, maximum
contaminant levels or action levels.
60 days after request made by the
Executive Officer
OFFSITE TASKS/COMPLETION DATES:
COMPLETION DATE:
j.
SUBMIT A WORKPLAN FOR REMEDIATION OF
DOWNGRADIENT OFFSITE GROUNDWATER POLLUTION:
THE
Submit a technical report acceptable to the Executive
Officer summarizing the extent of offsite groundwater
pollution northwest of the site in the vicinity of well
102A where VOCs have been discovered. This report should
include an evaluation of the impact of groundwater
extraction in the downgradient area on the onsite plume,
methods for the determination of when to begin operation
of groundwater extraction in this area, and a proposed
implementation schedule for the startup of extraction in
the downgradient offsite area.
2.
COMPLETION DATE: February 28, 1991
The submittal of technical reports evaluating immediate,
interim and final remedial measures will include a
projection of the cost, effectiveness, benefits, and
impact on public health, welfare, and environment of each
alternative measure. The remedial investigation and
feasibility study shall be consistent with the guidance
provided by Subpart E of the National oil and Hazardous
Substances Pollution contingency plan (40 CFR Part 300):
section 25356.1 (c) of the California Health and Safety
code: CERCLA guidance documents with reference to
Remedial Investigation, Feasibility studies, and Removal
Actions: and the state Water Resources Control Board's
Resolution No. 68-16, "Statement of Policy with Respect
to Maintaining High Quality of Waters in California".
3.
If the discharger is delayed, interrupted or prevented
from meeting one or more of the completion dates
specified in this order, the discharger(s) shall promptlY
notify the Executive Officer and the Board may consider
revision to this order.
4.
Technical reports on compliance with the prohibitions,
Specifications, and Provisions of this order shall be
submitted to the Board on a quarterly basis, according to
the schedule below, commencing on october 31, 1990 and
covering the previous quarter. 'l'he quarterly reports
shall include, but need not be limited to, the following
page 20 of 23
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information:
a. A summary of work completed since the previous
quarterly report,
b. results of water quality sampling analyses.
c. updated water table and piezometric surface maps
(second and fourth quarters only) for all affected
water bearing zones, and.isoconcentration maps for
key pollutants in all affected water bearing zones,
d. a cumulative tabulation of all well construction
details, groundwater levels, and chemical analyses
results,
e. A cumulative tabulation of volume of extracted
groundwater, estimates of pounds of pollutants
removed in groundwater, and chemical analyses for
all site groundwater extraction wells,
f. a cumulative tabulation of volume of liquid and
vapor removed by the SIVE system and an estimate of
the total pounds of pollutants removed by the SIVE
system,
g. geological cross-sections describing the
hydrogeological setting of the site,
h. appropriately scaled and detailed base maps showing
the location of all monitoring wells and extraction
wells, and identifying adjacent facilities and
structures,
1. identification of potential problems which will
cause or threaten to cause noncompliance with this Order
and what actions are being taken or planned to prevent
these obstacles from resulting in noncompliance with this
Order,
j. in the event of noncompliance with the Provisions
and specifications of this Order, the report shall
include written justification for noncompliance and
proposed actions to achieve compliance, and
k. the report for the fourth quarter of each calendar
year shall contain the data for the quarter and shall
serve as a summary report for the calendar year
containing a summary tabulation of all data for the
preceding year.
SCHEDULE FOR REPORT SUBMITTAL:
~r~:eI1!;~~:~~r! ~~fn¥:~ 13~~E:~;: \ :~~~~~:r
Page 21 of 23
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9.
s.
All hydrogeological plans, specifications, reports, and
documents shall be signed by or stamped with the seal of
a registered geologist, engineering geologist or
professional engineer.
6.
All samples shall be analyzed by State certified labora-
tories or laboratori~saccepted by the Board using
approved EPA methods for the type of analysis to be
performed. All laboratories shall maintain Quality
assurance/quality control records for Board review.
The discharger(s) shall maintain in good working order,
and operate, as efficiently as possible, any facility or
control system installed to achieve compliance with the
requirements of this Order.
7.
8.
Copies of all correspondence, reports, and documents
pertaining to. compliance with the Prohibitions,
Specifications, and provisions of this Order, shall be
provided to the following agencies:
a.
b.
Santa Clara Valley Water District
Santa Clara County Health Department
City of San Jose
u. S. Environmental Protection Agency,
6-3
Region IX H-
c.
d.
The Executive Officer may additionally require copies of
correspondence, reports and documents pertaining to
compliance with the Prohibitions, Specifications, and
Provisions of this Order to be provided to the U. S.
Environmental Protection Agency, Region IX, and to a
local repository for public use.
The discharger(s) shall permit the Board or its
authorized representative, in accordance with Section
13267(c) of the California Water Code:
a.
Entry upon premises in which any pollution sources
exist, or may potentially exist, or in which any
required records are kept, which are relevant to
this Order.
b.
Access to copy any records required to be kept
under the terms and conditions of this Order.
c.
Inspection of any monitoring equipment or methodo-
logy implemented in response to this Order.
Sampling of any groundwater or soil which is acces-
sible, or may become accessible, as part of any
investigation or remedial action program~dertaken
d.
Page 22 of 23
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10.
11.
12.
by the discharger.
The discharger(s) shall file a report on any changes in
site occupancy and ownership associated with the facility
described in this Order.
If any hazardous subs~ance is discharged in or on any
waters of the state, or discharged and deposited where it
is, or probably will be discharged in or on any waters of
the state, the discharger shall report such discharge to
this Regional Board, at (415) 464-1255 on weekdays during
office hours from 8 a.m. to 5 p.m., and to the Office of
Emergency Services at (800) 852-7550 during non-business
hours. A written report shall be filed with the Regional
Board within five (5) working days and shall contain
information relative to: the nature of waste or
pollutant, quantity involved, duration of incident, cause
of spill, Spill-Prevention, Control, and Countermeasure
Plan (SPCC) in effect, if any, estimated size of affected
area, nature of effect, corrective measures that have
been taken or planned, and a schedule of these
activities, and persons/agencies notified.
The Board will review this Order periodically and may
revise the requirements when necessary.
I, Steven R. Ritchie, Executive Officer, do hereby certify that the
foregoing is a full, true and correct copy of an Order adopted by
the California Regional Water Quality Control Board, San Francisco
Bay Region, on August 15, 1990.
A
.' ,1, D /,-
;/ \ I{~
stev~- R. Ritchie
/ Executive Office
Page 23 of 23
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APPENDIX B
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REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANQSCO BAY REGION
STAFF REPORT
SOLVENT SERVICE ,INC.
1021 BERRYESSA ROAD,SAN JOSE,
SANTA CLARA COUNTY
To:
SRR
From: RCG
Date: August 6, 1990
Subject:
Staff Report for the Site Cleanup Requirements, Solvent Service Inc., 1021
Berryessa Road, San Jose, Santa Oara County
1.0
PURPOSE AND SCOPE
The purpose of this Order is to introduce the results of the Remedial Investigation,
Feasibility Study (RlIFS), and the Remedial Action Plan (RAP) proposed by the discharger.
In addition, the staff report and Tentative Order will discuss modifications to the plan
that may be proposed by staff and goals for cleanup of the polluted soil and groundwater
and soil at the site. The initial presentation of this item at the June Board meeting
marked the opening of the public comment period on the above items. The revised
Tentative Order and this staff report address comments received from the discharger,
other interested agencies, and the public.
2.0
OCATION
DE
Solvent Service Inc. (5S1), hereinafter called the discharger, owns and operates a
treatment, storage, and disposal facility at 1021 Berryessa Road, San Jose, Santa Oara
County for the purpose for the purpose of waste treatment and recycling. The site
occupies 3.2 acres and is located approximately 10 miles southeast of San Francisco Bay
and approximately 113 mile southwest of the confluence of Upper Penitencia Creek and
Coyote Creek. It is in an area of industrial and commercial development and has been in
operation since 1973. Prior use of the area was for agriculture.
SSI is in the Santa Clara Valley which is a sedimentary basin filled with unconsolidated
heterogeneous alluvial material, interspersed with layers of marine clay. The alluvium is
a mixture of permeable water-bearing sands and gravels interbedded with less permeable
silts and clays. The soils are extremely variable over short distances, both horizontally and
vertically.
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~
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SSI is underlain by three distinct hydrogeologic units. Aquifer A is an unamfined, low
permeability aquifer that occurs from the ground surface to a depth of 20 to 25 feet (50
to 75 feet MSL) and is locally dewatered. It consists of sandy silts, clay, and a thin,
continuous poorly sorted sand layer at its base. Aquifer A is underlain by a 6 to 16 foot
thick clay layer which may impede vertiCal downward migration of groundwater.
Ancestral stream channel deposits have also been identified along the southwestern
margin of the site in the A aquifer.
The Zone B/C consists of lenses of sands, silts, and clays. It extends to 50 feet below the
upper clay layer (0 feet MSL). Water levels in this zone are 1 to 2 feet lower than Aquifer
A but little vertical leakage is believed to be occurring. A clay layer, 2 to 10 feet thick,
occurs at the base of Zone Ble. The sands, silts, and clays in the BlC zone tend to be
discontinuous. Consequently this unit locally may function as an aquifer or an aquitard.
Therefore this unit will be referred to as a zone, not an aquifer, both in this report and
the accompanying Order.
The third zone, Aquifer DIE, consists of an upper member- a thick sequence of silts and
s
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proposed for the Federal National Priorities List (NPL). In April 1989, the Board adopted
Revised Waste Discharge Requirements requiring completion of the pollution
investigation, final installation of soil cleanup measures, and submittal of the Remedial
Investigation/Feasibility (RJIFS) Report and the Remedial Action Plan (RAP).
Interim remedial actions implemented at S.~I include the following: Three underground
storage tanks used for solvent storage, spill control, and waste solvent storage, were
removed on or about 1982. These tanks were replaced with new and larger tanks.
Subsequently, these larger tanks were removed along with some soil, however, this is not
well documented. The actual volume of soil removed is unknown as are the levels of soil
pollution remaining inplace following the excavation. Based on more recent
investigations, high levels of pollutants in soil remain beneath the presently existing
concrete pad that underlies the major treatment and storage area. The solvent truck
unloading area, the barrel storage area, the spill containment facility, and other treatment
and storage areas were gradually paved with concrete by 1984. Currently, most of the
treatment and storage area is paved. Additional interim remedial measures have included
placing berms in the treatment and storage area and changing operational procedures to
minimize risk of additional contamination. In 1989 and 1990 17 B/C zone wells and 2 DIE
aquifer wells were destroyed. These wells were destroyed due to suspected cross-
contamination along well seals or conflicts with the installation of the steam injection
; vapor extraction system.
Groundwater investigations were conducted between 1983 and 1986 by Applied Earth
Consultants (AEq. During this time period 56 monitoring wells, an interim extraction
trench, and 2 interim recovery wells were installed. In 1986, Groundwater Technology Inc.
(GTI) installed a second interim extraction trench, 5 recovery wells, and 10 monitoring
wells. In 1987, Todd Engineers Incorporated (Todd Engrs) installed 10 monitoring wells,
2 recovery wells, and another extraction trench. In 1988, Todd Engrs installed 16 more
monitoring wells. During 1988, 126 soil samples were collected at S51 by Todd Engrs.
S5I currently operates a containment/extraction system for the groundwater plume. The
system includes 5 of the recovery wells and the 3 extraction trenches. Extracted polluted
groundwater is being treated by a biological treatment system followed by carbon
adsorption and air stripping. Treated water is discharged into the sanitary sewer under
permit from the sanitary district. This system appears to be effective in containing
migration of pollutants..originating onsite and of removing pollutants from the extracted
groundwater. However, some pollutants have migrated to and slightly beyond the
property boundaries. These pollutants are believed to have migrated beyond the location
of the trenches prior to installation of the trenches.
As part of the RI process 55I also performed a pilot study of steam injection/vacuum
extraction system for soil remediation in October 1988. The results of the pilot study were
encouraging based on an up to two order of magnitude reduction of concentration of
VOCS in coarse-grained soils. A full scale system was installed in the Fall of 1989 as an :
3
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interim remedial action "for in-situ soil remediation. The system was located and designed
to address the polluted soils beneath the concrete pad as explained above. The system has
been operating as a vacuum extraction system without steam injection since early
December 1989 and is removing large volumes of contaminants, though no confirmatory
soil sampling has been completed at this time.
SSI followed approved Quality Assurance"and Sampling Plans. Data submitted to the
agencies was subjected to data validation analysis and detennined to be "qualitatively
acceptable". The body of data, due its size and consistency of results, is to some degree
self-validating. Since the data set has been ascertained to be acceptable for qualitative use
and the data set is internally consistent it is judged to be acceptable for use in
determining the magnitude of pollution and appropriate cleanup levels.
551 submitted a Remedial Investigation and Feasibility Study (RJIFS) Report which
satisfies the requirements of Board Order No. 89-51, Site Oeanup Requirements. This
report includes five alternative soil remedial actions and eight alternative groundwater
remedial actions, an evaluation of remediation alternatives, a baseline risk assessment, and
a proposed final remedial action plan (RAP).
The RIlFS Report, originally dated October 17, 1989, was revised and updated and
submitted to the Board on January 19, 1990. Additional revisions will be required to
produce a final report acceptable to the Executive Officer. The revised documents which
this Order will approve were received May 30, 1990.
4.0
NATURE AND EXTENT OF CONTAMINATION
551 is a waste treatment and reduction facility and site operations include handling of a
large number of chemicals. Mixed and segregated solvents are recycled by a variety of
methods including distillation, separation,. and blending. Approximately, 99% of the
recoverable solvents are recycled. The resulting products are then reused and consumed
by industry. Corrosive liquids are treated by methods including neutralization,
precipitation, oxidation, and filtration in order to detoxify the material. Acids and metal
sludges meeting certain parameters are recycled for reuse.
During 1988, 126 soil samples were collected at 55!. Half of these soil samples have
detected soil pollution greater than 1000 ppb total VOCs. The highest concentrations are
located directly beneath a concrete storage pad, referred to as the "hot spot" which
extends about one acre. The soil is polluted from the ground surface to depths of about
20 feel The following chemicals were detected in soil at the maximum concentrations
listed below:
4
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'. .... .....,. ... .
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OiEMiCAL
CONCENTRATION (PPB)
19,000,000
3,600,000
2,900,000
1,700,000
1,650,000
total xylenes
ethyl benzene
l,2-dichlorobenzene
I,I,I-trichloroethane
acetone
Acetone and other ketones may provide a solvent for dispersion of other organic
chemicals that are transported more easily in the subsurface when dissolved in a ketone.
These ~sults indicate that hazardous wastes have been released at the SSI site.
Since 1983105 monitoring wells, three extraction trenches, and two recovery wells have
been installed. Over 71 tentatively identified chemicals have been identified during the
site investigations. At least twenty distinct priority and non-priority pollutants have been
identified. Chemical concentration data was reviewed for validity by the California
Department of Health Services. The data was considered to be usable for at least
qualitative purposes. As was discussed above due to the internal consistency and size of
the data base the data was considered to be adequate for the purposes of identifying the
'scope of the problem and choosing a final remedy. The chemicals detected in
groundwater in the highest concentrations and the most frequently are listed below:
CHEMICAL
CONCENTRATION (PPB)
acetone
2-butanone
cis-l,2-dichloroethane
cis-l,2-dichloroethylene
dichJoromethane
6,600,000
730,000
70,000 -
67,000
11 0,000
FREQUENTLY DETECTED:
1,I-dichloroethane .
cis-l,2-dichloroethane
xylene
I,I,I-trichloroethane
2,300
70,000
47,000
58,000
Sampling results from wells screened in Aquifer A and located along the southwest
perimeter of the site indicated floating fuel product and dissolved concentrations of
benzene, toluene, xylene, and ethylbenzene (BTX&tE) over 10,000,000 ppb. This plume of
BTX&E probably originates at the adjacent Chevron site. The BTX&E contamination is
apparently restricted to a relatively narrow band of sediments that may represent coarser
sediments deposited in an ancestral stream channeL
5
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The highest levels of pollution are located in Aquifer A and are confined to the site. A
few constituents have been detected in the down-gradient direction and along the
southwest margin. The VOC's that are detected in the southwestern portion of the site
are detected at low concentrations.
Groundwater pollution in Zone BlC included 21 priority and non-priority pollutants. The
total number of pollutants recently detected in this zone is about 13. The maximum
concentration of total VOCS ever detected was 300,000 ppb. Recently the concentration
has been reduced to 868 ppb. This pollution is reported to be due to cross-amtamination
during drilling, field sampling and laboratory analyses, and leakage along well casings.
Most of the Zone B/C pollution is reported to have been remediated by purging the wells
during an intensive sampling program and the majority of wells were this is suspected
have been properly destroyed and abandoned.
Ten priority and non-priority pollutants have been detected in Aquifer DIE. The chemicals
detected in the rughest concentrations include acetone (210 ppb), total xylenes (110 ppb),
and ethylbenzene (16 ppb). Currently, only one well has detectable levels of VOCS (6
ppb). The pollution is also reported to be due to cross-contamination and is currently
below the proposed cleanup standards.
5.0
ENFORCEMENT
As discussed above investigation of soil and groundwater pollution at the SSI facility has
been ongoing since 1983. The site is on the National Priorities List (NPL), however the
Regional Board has been acting as the lead agency in directing investigation and remedial
actions for 55I. The Board has taken enforcement and regulatory action through Regional
Board Orders, as indicated herein: .
a.
March 1986
Regional Board adopted W ute Discharge
Requirements.
b. April1988
c. June 1988
. d. Aprill989
Regional Board adopted revised 5ite Oeanup
Requirements.
,
5ite proposed for the NPL.
Regional Board adopted Revised 5ite Oeanup
Requirements.
A potential responsible party (pRP) search has not been completed for the 55I site,
therefore 55I is considered to be the sole responsible party for this site. SSI has accepted
the responsibility for site cleanup actions.
6
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6.0
COMMUNITY INVOLVEMENT
An initial "fact sheet" was completed by SSI, in consultation with RWQCB and DHS, and
sent to public agencies and community members in August 1988. This initial fact sheet
described the site geology, groundwater flow, and current site (August 1988) conditions.
A second fact sheet, completed by the Board. community relations staff, describing current
site conditions and the projected schedule of events for site cleanup was completed and
mailed in December 1989. This Board meeting will mark the opening of the public
comment period on the completed RIIFS report and the proposed Remedial Action Plan
(RAP). An additional fact sheet describing the proposed plan for final site cleanup will
be mailed in June 1990. This will be followed by a public meeting at the San Jose City
Hall qn June 27, 1990. The public response to actions at the SSI site and the proposed
plan will be compiled and attached to the Tentative Order adopting a final RAP,
scheduled for consideration by the Board at the August 15, 1990 meeting.
7.0
ORDER SCOPE
The Order proposes cleanup standards for soil and groundwater. Since achieving
~ackground concentrations is considered to be infeasible consideration was given to using
the HI-Iess-than-one and the 1~ ECRN concentrations to establish cleanup goals. But this
approach may also not be practical or technically feasible. Less stringent cleanup goals
may be appropriate due to the following considerations: (1) the practical
detection/quantification limits for some chemicals do not permit measurement by standard
methods of such low concentrations; (2) there are no water-tap exposures above health-
based levels actually occurring in the vicinity of this site at present or expected in the
future; (3) the potential for human exposure from pathways other than future potential
drinking water ingestion or inhalation is minimal to none; (4) there are no sensitive
populations or special environmental receptors in the immediate vicinity of the site. The
standards proposed are health protective (see Section 11 and attachment), protective of
the environment, and will meet or exceed all applicable or relevant and appropriate
requirements or other guidance to be considered.
Final Oeanup Levels. The cleanup standards for Aquifer A and the B/C zone are based
on the California DHS Action Level (AL) or Maximum Contaminant Level (MCL),
whichever is more stringent, for drinking water, other guidance, or are defined by health-
related reference information or ca1cu1ations as described in Section 9.
While the cleanup objective is to restore groundwater quality by removing as much of
the chemicals in the groundwater as is technologically and economically feasible, another
objective of major importance is to remove the potential threat to human health or the
environment posed by the presence of cancer-causing chemicals at this site. The process
of removing carcinogens to the extent feasible will result in the removal of non.
carcinogens as well and will eliminate the potential exposure to vapors resulting from
volatilization from the groundwater. .:
1
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. . - .- ,-.. .'
. . .,.
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For evaluation of total risk in each of the two categories (carcinogen and non-carcinogen)
cleanup levels (in J4g11) for the site have been established based on the following
standards or ARARs:
a.
California DHS AL or MCL val,uesfor non-carcinogens: l,2-DCB (5), cis-l,2-
DCE (6), trans-l,2-DCE (10), ethylbenzene (1750), 1,1,I-TCA (2(0), Freon 113
(12(0), selenium (10), and xylenes (1750); and for carcinogens: arsenic (SO),
benzene (O.1), 1,4-DCB (05), 1,1-DCA (5), 1,I-DCE (6), methylene chloride
(40), PCB (5), TCB (5), and vinyl chloride (O.5).
b.
u.s. MCL values for copper (1300) and zinc (5000), and toluene (2000).
The Applied Action Level of the DHS Toxic Substances Control Division for
chloroform (6).
c.
d.
The EP A Integrated Risk Information System (IRIS) oral reference dose for
acetone (3S(0).
The EPA National Ambient Water Quality Criteria for Public Health Effects
for antimony (14), isophorone (5200), nickel (154), phenol (3500), and
thallium (I).
e.
f.
The EPA Drinking Water Health Advisory for Naphthalene (5300).
'The proposed final cleanup standards for some chemicals in groundwater at the 55I site
have been modified from the ~bove standards. This modification is necessary to be health
protective due to the potential exposure to multiple chemicals through multiple exposure
pathways. The proposed final cleanup standards are as shown in Table 1 which follows:
.. - _.,.,. --- . ...
. - - ....-;. ..'
:
8
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, --... -. . .
TABLE 1
NONCARCINOGENIC CARCINOGENIC
CHEM Cw .. CHEM Cw
pg/l ,ug/l
ACETONE 400
2-BUTANONE 20 BENZENE 1
l,2-DCB 5 CHLOROFORM 6
OS-l,2-DCE 6 1,1-DCA 5
1RANS-l,2-DCE 10 1,1-DCE 1
ETHYLBENZENE 500 MEm. CHLORIDE 30
FREON-113 1200 PCE 5
4-METH.-2-PENT. 10 TCE 5
NICKEL 80 VINYL CL 0.5
PHENOL 2000
1,1,1-TCA 200
TOLUENE 1000
XYLENES 1750 ..
There are no ARAR's for the removal of VOC's from soil. Therefore, a conservative soil
remediation goal of 1 ppm for total VOC's has been set to protect the groundwater from
future pollution by leaching of VOC's from polluted soils. Soil cleanup goals for
inorganics have not been established due to the uncertainty surrounding the natural
occurrence of metals in soils in the South Bay. In addition, the RA indicated that the
cancer risk and health hazard from direct soil contact for the average case under two
future scenarios was minimal (104 or less). Therefore remedial actions and cleanup goals
for inorganics in soil will not be included in the plan or the Order. The preferred
remedial alternative for soil, SIVE, is not designed to remediate metals in soil and will
may not reduce the concentrations of inorganics in soil.
9
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An additional concern that is discussed in the FS and the Remedial Action Plan (RAP) is
the potential contamination of the air at the Solvent Service site. The appropriate
standards for this consideration are the regulations of the Bay Area Air Quality
Management District (BMQMD) Regulation 8, Rule 47 which is an ARAR for the 55I
facility. The air stripper system vapor extracQon systems at the 55I site is regulated by the
BAAQMD. The air emissions from these units do satisfy the ARAR cited above as
regulated by the BMQMD.
In addition, the Tentative Order provides for evaluation of the attainment of cleanup
standards, a five year review, and the possibility that technology and experience may
allow the discharger to exceed or to be unable to achieve the proposed cleanup standards.
A BTX&E groundwater poI1ution plume, as described above, was detected near the
southwestern site boundary during the Remedial Investigation (RI). 55I and Chevron, in
an Order adopted in January 1990, are named as responsible parties for this area. The
Order adopted in January contained requirements that the Companies cooperate in the
investigation and in remedial actions at the two sites and for the possibly commingled
plume area. Remediation of this area is not included in the proposed plan described in
this Order. Additional sampling completed at the Chevron site in April, and received by
.staff after the completion of the Tentative Order presented to the Board in June, indicates
the presence of l,l-DCA in the groundwater beneath the Chevron facility. 5taff proposes
that any further decisions regarding the possible joint remediation of the groundwater
pollution plume along the southwest boundary of the 551 property be delayed until
Chevron has completed characterization of the BTX&E groundwater plume. This may
require the Order adopted for Chevron in January to be revised. .
5taff anticipates that Chevron will contest the 551 Order on the grounds that it does not
contain joint tasks for the groundwater contamination along 55!'s southwest property
boundary. 5taff feels that 551 has defined the extent of VOC contamination in this area.
However, Chevron has not adequately defined the extent of BTX&E contamination. In
addition, it is not clear that the VOC'. detected in this area are the result of migration
from 551. Consequently, staff recommends that no further joint tasks be assigned until
Chevron has adequately defined the extent of the BTX&E contamination. Under the
Order issued to Chevron these tasks are scheduled for completion by April 1991. This
should not result in any significant delay in the completion of these tasks or the eventual
remediation of the groundwater pollution in this area.
8.0
~
A Baseline Public Health Evaluation (BPHE) for the 551 site was completed by
ICF/Cement Associates under contract to the Regional Board. The BPHE evaluated
exposure through all environmental media and the risk related to any exposure that was
considered likely to occur. This evaluation was completed for both current site conditions.'
10
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-. .... " .
.. .. .......,..,..-
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.~..
- -
and a future use scenario of residential housing occupying the site.
Under current site conditions no exposure pathways that were likely to occur were
identified. Under the future use scenario, exposure could occur through ingestion of
polluted groundwater, direct contact with soil and through inhalation of vapors resulting
from the volatilization, particularly VOC's, from groundwater and polluted soils. The risk
related to these exposures is summarized in Table IV.
The greatest risk is related to the ingestion of polluted groundwater from the and
inhalation of vapors from the volatilization of chemicals in the A aquifer, with both an
increase in the excess cancer risk above the 1()"4 - 10" acceptable range for excess cancer
risk and possible toxic effects. Risk associated with the groundwater pollution in the A
aquifer within the inferred paleochannel at the southwest portion of the site was
evaJuated separately and will be addressed separately.
Direct ingestion and inhalation exposures to the pollutants contained in the B-C zone
related to possible future use may result in an elevated risk of both cancer risk and toxic
effects. However, both increased cancer risk and potential toxic exposures are indicted
only for the maximum plausible case and not the average case. The exposure through
inhalation to vapors from the B-C zone is estimated to result in increased cancer risk for
the maximum plausible case and not for the average case. Toxic effects would not be
anticipated from inhalation vapors from the B-C zone.
Exposure through ingestion and inhalation related to the pollution of aquifer D-E is not
expected to result in either increased cancer risk beyond the acceptable 1()"4 - 1~7 range
or adverse noncarcinogenic health effects.
--
Exposure through direct contact with polluted soil was considered through two future use
scenarios 1) children playing in the soil and, 2) adult exposure through gardening. The
exposure to children through direct soil contact is within the acceptable 1()"4.. 10" range
for both average and maximum cases. The exposure for children to the noncarcinogenic
compounds is not anticipated to have toxic effects for the average case, however toxics
effects related to exposure to thallium would be predicted for the maximum plausible
case. The evaluation of the second scenario indicates that exposure through this pathway
would not be expected to result in excess cancer risk greater that the acceptable 1()"4 -10'6
range or adverse noncarcinogenic health effects.
No specia1 environmental habitats or endangered species were identified for the 55I site.
The potential for migration to any bodies of surface water is minimal. The potential and
real exposure or risk of environmental damage was judged to be nil.
These values are upperbound estimates of excess cancer cases potentially arising from
lifetime exposure to the chemicals in question. A number of assumptions have been made .-
in the derivation of these values, many of which are intentional overestimatEs of exposure
11
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. andlor toxicity. The actual incidence of cancer is likely to be lower than these estimates
and may even be zero.
9.0
SITE CLEANUP GOALS
To set cleanup goals for groundwater at the Solvent Service (551) site staff began with the
chemicals identified as chemicals of concern by the risk assessment (RA) prepared by
ICF/Clement (ICF) for the Board. The RA defined thirty-one (31) chemicals of concern in
groundwater at the Solvent Service, Inc. (5SI) site. These chemicals include nineteen (19)
volatile organics (V0Cs), five (5) semi-volatile organics (SOCS), and seven (7) inorganics
or metals. These chemicals were further classified as either carcinogenic or non-
carcinogenic (toxic) substance, with twenty (20) non-carcinogenic chemicals and eleven
(11) carcinogenic chemicals.
The primary goal of reducing pollutant concentration to background levels for all
chemicals of concern was determined to be technically infeasible due to the mixture,
concentrations of pollutants present, and experience on other sites. Therefore, staff
developed draft cleanup goals, as described below, utilizing risk-management techniques
that would be protective of human health and the environment as well as the existing
. and potential beneficial uses of the groundwater by utilizing the Hazard Index (HI) for
the non-carcinogens and excess cancer risk numbers (EeRN) for carcinogens.
The minimum goal for cleanup standards being an I-U less than 1 and an ECRN of 1()'6
with a maximum of 1~ (EP A policy/regulation). The I-U of less than 1 indicates that toxic
health effects for a single chemical or the combination of chemicals would not be
expected. Excess cancer risk- numbers (BCRNs) are evaluated for each individual
carcinogenic chemical to indicate the potential effects of carcinogens, and are usually
expressed as the number of excess cancers that may develop in a population;i. e., the 1()'6
or one-in-a-million ris~ or the 1~ (one-in-100,OOO) risk. When cancer-causing substances
are present and a threat of exposure to these substances exists, a potential risk is present
There is no "zero-risk" level associated with the threat of exposure to carcinogens. The
total ECRN for a group of chemicals is calculated by summing each individual chemical's
ECRN. A number of assumptions have been made in the derivation of these values, many
. of which are intentional overestimates of exposure and/or toxicity. The actual incidence
of cancer is likely to be lower than these estimates and may even be zero. The use of the
HI for noncarcinogens and estimation of increased population cancer risk for carcinogens
is detailed in the' EP A Risk Assessment Guidance (December 1989).
The California Deparbnent of Health ServiCes (DHS) , Office of Drinking Water has
commented on the manner in which the cancer risk was calculated for this site (see
Appendix B). The approach recommended by DH5 for the calculation of health protective
cleanup goals is the DHS carcinogenic hazard index, which is the summation of the
proposed cleanup goals divided by the appropriate guidance level, preferably the MCL,
for that chemical. This approach would result in proposed cleanup levels ~or the 55! site'
12
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at lower concentrations than those proposed by this Order. Staff feels that the approach
presented in this Order is more scientific and representative of the threat to groundwater
that the SSI site presents. The approach espoused by DHS does not address the
complicated process that goes into the establishment of MCLs, the fact that not all MCLs
are health protective, and the lack of MCLs or other standards for comparison for some
chemicals. By not describing the MCL p~ocess this approach does not make the
assumptions that have gone into the calculation of the cleanup goals available for public
sautiny. In the case of SSI establishment of cleanup standards would result in proposed
concentrations at or below the detection limit for most or all of the carcinogens.
Considering the technical difficulty and length of time estimated to achieve the proposed
cleanup standards Staff has reservations about proposing standards that would be even
more difficult to realize.
The c10sest well to the SSI site is approximately 2000 feet downgradient and draws water
from the DIE aquifer. Maximum contamination in this aquifer is currently 6,ug'l total
VOCs, well below drinking water standards. Due to the absence of contamination this
Order does not set c1eanup standards for the DIE aquifer. Groundwater monitor wells in
this aquifer are and have been inplace between this well and the SSI site. These wells do
.not currently detect any contaminants. The discharger has presented evidence that
contamination in the B?C zone and DID aquifer is the result of migration along leaky
well seals. Oeanup of the DIE aquifer has been accomplished as the result of purging
the wells prior to sampling events. The two wells that penetrated the DIE aquifer that
were suspected of leaking have been destroyed. Therefore, there is currently no evidence
of migration of contaminants through the clay at the base of BlC zone.
Oeanup in the A aquifer and BlC zone is required by this Order. The majority of the
groundwater contamination is restricted to the A aquifer. Staff feels that most
contamination in the BlC zon"e is the result of cross-contamination from the A zone. All
suspect wells have been properly destroyed and abandoned. New wells have been
installed downgradient to replace the destroyed wells and to monitor the migration of
any contaminants remaining in the BlC zone.
An explanation of the calculation of hazard indices and excess cancer risk numbers is
detailed in the attached memo, Proposed Ceanup Standards for Solvent Service, August
2,1990. The rationale for the proposed cleanup standards is also included in the attached
memo. The proposed cleanup standards are summarized in Section 7.0 of this Staff Report.
10.
DESCRIPTION OF ALTERNATIVES
The remedial alternatives encompass a range of appropriate waste management options,
as follows:
For soil remediation:
1. No Action
13
. - -.
. .....- ---.- . .
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r
2.
Containment
Capping with clay, asphaJt, concrete synthetic or a
combination
Surface controls - Diversion/collection
Excavation and Disposal
Offsite landfill .
Excavation, Treatment, and Disposal
Physical treatment - Aeration
Thermal treatment - Soil cooker
Biological treatment - Aerobic
In-Situ Treatment
Physical- Vapor recovery
Thermal - Steam injection
3.
4.
5.
For groundwater remediation: -
1.
2.
No Action
Containment
Capping plus slurry wall or hydrodynamic control
Collection, Treatment, and Disposal
Pumping - Wells, trenches
Physical treatment - Air stripping, adsorption
Chemical treatment - OzonationIUV
Biological treatment - Aerobic
In-Situ Treatment
Physical - Permeable treatment bed
3.
4.
Below is a brief description of each alternative that was considered.
No Action
SoU Remediation
This option is required for consideration and involves no further action. Current
interim remedial actions would be discontinued. Such institutional actions such
as land-use restrictions, fencing, or warning signs can also be considered under the
no action alternative. SSI presently is fenced with posted warning signs. No action
might result in eventual migration of contaminants into the drinking water
aquifers (DIE aquifer and deeper) below the SSI site.
Containment
Capping. The site would be graded and capped with a layer of less permeable
materiaJ. Capping would reduce dust, surface erosion, and minimize infiltration
and recharge by precipitation and surface runoff. Many of the options are:
... . ... "..
_. . ~ . .
14
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effeCtive, implementable, and low in cost. A large concrete bermed pad currently
exists in the center of the site.
Surface controls - Diversion/collection. Physical barriers would be placed around
the contaminated area to control and collect surface drainage and reduce surface
water infiltration and erosion. These drainage channels or berms would control
surface erosion but not stop leaching by direct rainfall or dust generation.
CUJTently, all runoff from the concrete pad is collected.
~xcava~on and Disposal
Offsite landfill. The contaminated soil could be excavated and disposed of at an
approved offsite licensed disposal facility. Bans on land disposal of untreated
wastes have been implemented based on waste characteristics. The area would be
backfilled with clean soil. This alternative eliminates site soil contamination but
creates potential for offsite liability. The contamination would must be moved to
another site.
Excavation. Treatment. and Disposal
Physical Treatment - Aeration. The contaminated soil would be excavated and
spread on the ground surface to aerate al]owing the volatile compounds to escape.
Aeration rates would be regulated to limit the organic compound emissions from
the soil. The contaminants would just be transferred from one media to another.
The excavated areas would be backfilled with the aerated soil or clean fill (with
the aerated soil going to a landfill).
Thermal Treatment - Soil cooker. The excavated soil would be treated by a soil
cooker to remove contaminants, and then, preferably be disposed of properly
onsite. The soil cooker first removes excess water from the soil and then volatilizes
organic compounds under high temperatures conditions. A purge gas, typically
air,"enhances contaminant removal. Subsequently, the removed contaminants can
be destroyed by high-temperature incineration in an after-burner or recovered by
condensation or adsorption onto activated carbon. The recovered solvents can be
disposed of or recycled.
Biological treatment. Excavated soil would be exposed to air or oxygen in order
to foster the growth of micro-organisms and subsequent breakdown of organic
compounds.
In-Situ Treatment
Physical - Vapor Recovery. Gaseous phase contaminants within the upper
unsaturated soil zone would be collected by applying subatmospheric pressure:
15
. _. -.-. ".. .
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- --- -
. ---- - -.
to a vapor recovery well. This subatmospheric pressure is maintained by a surface
pump or fan which would exhaust the gaseous phase contaminants to recovery
equipment.
Thermal - Steam injection. Steam injection would enhance the capture and
removal of volatile and semi-volatile compounds through a combination of steam
injection wells, and vapor and liquid phase extraction wells. When stearn is
injected, volatile organic compounds vaporize and are swept ahead of the steam
front where they are collected at the extraction wells. process wastes collected
through the recovery system would include liquids pumped from the recovery
well, liquids collected from the condenser, and the non-condensable gases exiting
-the vacuum vapor recovery fan. The wastes from this enhanced vapor extraction
system would be treated by carbon filtering, distillation, and bio-treatment. A pilot-
scale test of steam injection and vacuum extraction performed at S5! reduced the
total contaminant concentration in the soil from approximately 1,200,000 pglkg to
less than 22,000 pw'kg in high permeability zones. Additional contaminant
recovery is expected for longer steaming periods.
Groundwater Remediation
No Action - This option is required for consideration and involves no further
action. Current interim actions such as pumping would be discontinued.
Institutional actions such as land use restrictions, fencing, or groundwater
monitoring can also be considered under the no action alternative.
Containment
Capping with slurry wall or hydrodynamic control. The site would be capped to
reduce surface infiltration and horizontal migration would be controlled through
barriers such as extraction wells or slurry walls~ The extraction wells would be
pumped in an attempt to create a cone of depression beneath the site.
Groundwater would flow to the wells to be extracted for disposal. A slurry wall
consists of a trench filled with an impermeable material which creates a barrier to
horizontal groundwater flow.
Col1ection. Treatment. and Disposa\
Pumping wells, trenches - A plume of contaminated groundwater can be
controlled by pumping it out with wells or drainage trenches. Several wens would
be used to extract water from Aquifer A. Extraction trenches consist of ditches
excavated to a level below the water table and at least partially filled with coarse
gravel or a horizontal perforated pipe. One or more extraction wells or sumps in
the trench would remove the liquid collected by the drainage action of the trench.
Currently, there are three extraction trenches and five operating recovery wells on"
16
. . .. .--. ... -- .
- ... ',- ".''''.. ... ..
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~.
site installed as part of the interim remedial measures program.
Physical treatment - Air stripping, adsorption. Air stripping is a groundwater
treatment process in which contaminants dissolved in water become dissolved in
air. The contaminant transfer from water to air is accomplished by adding air to
the water through aeration techniques. Adsorption involves the adherence of
contaminated molecules to an adsorbent surface of activated carbon. Contaminated
water is passed through a bed of granular activated carbon and the contaminants
are adsorbed onto the carbon surface and held there. An air stripper currently
exits on site as part of the treatment facility.Carbon tanks also exist on site
and will be used to adsorb non-condensable contaminants left in the air from the
.steam injection - vapor extraction system.
Chemical treatment - OzonationlUV. Ozone is a powerful oxidizing agent capable
of destroying a wide variety of organic compounds. Ozonation consists of the
introduction of ozone and contaminated water in a contact chamber. Ultraviolet
lamps also may be operated in the chamber.
Biological treatment - An onsite biological degradation system uses bacterial
populations to convert soluble organic compounds in waste water into insoluble
organic compounds (more bacteria) which can be physically removed from the
waste water stream. Contaminated water will flow to an aeration tank where
oxygen will be supplied to produce bacterial growth. The water will then be
pumped to a bio-reactor where bacterial f1lm will accumulate and slough off. A
bio-treatment system currently exists on site.
~tu treatment
.
Physical - Permeable treatment bed. Permeable treatment beds utilize an
adsorptive process to treat contaminated groundwater in place. A trench would
be filled with a permeable treatment medium such as activated carbon to intersect
the contaminant plume in Aquifer A.
These remedial alternatives were reduced in number through comparison to the nine
criteria, 1) overall protection of human health and the environment, 2) compliance with
applicable or relevant and appropriate requirements (ARARs), 3) long term effectiveness
and permanence, 4) reduction of toxicity, mobility, or volume through treatment, 5)short
term effectiveness, 6) implementability, 7)cost, 8) lead and support agency acceptance, and
9) community acceptance.
These choices were reduced through this screening process to three soil remedial
alternatives and four groundwater remedial alternatives. Some technologies are evaluated
with multiple treatment options. This results in four soil remedial programs and six
combinations of technology and treatment for groundwater. This includes the no action:
17
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- --.. .
alternative that was carried forward for comparison.
The soil remedial alternatives that were analyzed in detail include no action, containment,
and in-situ treatment, either soil vapor extraction or thermally enhanced soil vapor
extraction (5IVE). The groundwater remedial alternatives retained for detailed analysis
include: no action, containment, extraction through wells and trenches and treatment
either by air stripping in combination with carbon adsorption or biologic treatment, and
in-situ treatment through the physical placement of a permeable treatment bed in the
saturated zone.
The removal actions for soil were rejected, though they are cost effective and expedient,
because removal would require the termination of operations at the 551 facility. However,
the estimated cost for this alternative does not consider that removal would result in the
probable permanent cessation of operations at the 55I facility. Containment would not
actively remediate the soil and the natural degradation of the contaminants is estimated
to be between 50 and 100 years. Migration of contaminants from the soil to groundwater
could continue while this process was occurring. The in-situ treatment of the soil by
enhanced biologic activity was rejected due the uncertainty of this process to work on
.chlorinated compounds or any compounds in a matrix as complex as that which occurs
in the soil at 551.
'Very few alternatives exist for the remediation of groundwater. Containment through the
placement of vertical barriers around the site does not prevent continued migration.
Therefore this alternative would still require groundwater extraction in some form to
control the migration and remove the contaminated groundwater from the subsurface.
Two in-situ technologies for groundwater treatment were considered. The first of these,
in-situ bioremediation is unproven for chlorinated compounds and the second, the
permeable treatment bed is an untested innovative technology. This leaves containment
and capture by some type of groundwater extraction as the remaining alternative.
Treatment technologies considered included ozonation-UV, air-stripping, carbon
adsorption, and bioremediation. The only one of these that was rejected was the
ozone/UV treatment. This was rejected due to the high cost. In addition, though several
pilot projects have tested this technology in the South Bay there are no operating
installations so the technology must still be considered innovative.
11.
PROP05ED PLAN
The proposed plan identifies the following group of actions for cleanup at the 551 site:
1.
Steam Injection and Vacuum Extraction (SIVE)
Bio-treatment, Carbon Filtering, and Air Stripping of Extracted
Groundwater, Surface Water, and Vapor
2.
18
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3.
Capping of the Site by Paving
4.
Groundwater Extraction
5.
Continuation of the Ground~ater Monitoring Program
SIVE is identified as the primary technology for remediation of soils polluted with VOC's.
Fluid extracted by this process will either be treated in the onsite solvent recovery system,
operated under the site RCRA permit, or treated in the groundwater treatment system (see
discussion below). If the fluid is treated by the recovery system the majority of the solvent
is removed from the vapor or water phase and recycled for offsite use. The waste from
this process is sent to the sanitary sewer as process water for waste disposal. If the fluid
is treated by the groundwater treatment system more than 98% of the VOC's will be
removed from the water. The treated water is then used in the cooling tower portion of
the solvent reclamation system. The water from the cooling tower is discharged to the
sanitary sewer system as process water and is subject to Pretreatment regulations. Vapor
recovered by the SIVE system is treated by carbon adsorption. The carbon is recharged
on site as part of the steam injection process and the liquid from the carbon recover is
t'cat:;d either in the solvent recovery system or by the groundwater treatment system,
witheventuaJ discharge to the sanitary sewer.
In conjunction with the SIVE system the site will be capped either by asphalt This will
serve both to limit exposure through fugitive dust exposure and exposure to vapors
resulting from volatilization of VOC's from groundwater and to limit infiltration of
surface water through any contaminated soil remaining inplace which will limit any
potential for continued pollution of groundwater. The initiation of this phase of the
proposed cleanup plan is dependent upon approval of the Oty of San Jose for the
necessary construction permits.
The groundwater extraction system includes three extraction trenches, and 5 extraction
wells. An additional nine large diameter wells previously installed on the site periphery
could also potentially be converted to extraction wells. However, the system has been
operating as an interim remedial action since 1987 and appears to be adequately
controlling pollutant migration and to be effectively capturing the polluted groundwater
from the site.
The treatment system for the extracted groundwater, as proposed, would include bio-
treatment, carbon adsorption, and air stripping. Each component of the treatment system
is designed to remove or convert a different group of potential chemicals of concern.
SIVE is an innovative technology and a pilot scale study has been completed at the SS!
site, however since the test was performed in an area surrounded by polluted soil
evaluation of the effectiveness of the technology was limited. Therefore excavation of .
polluted soils should be included in the RAP in case SIVE proves to be ~effective in .
19
. . . ".'..-
. -. -.'.
. '.' ""..'
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achieving soil cleanup goals, particularly in !ine-grained soil.
The groundwater extraction system, which has been put in place and operated as an
interim remedial action and for containment, is effective for the onsite cleanup of
groundwater. However, the system may have to be modified to include polluted
groundwater from the offsite areas. The plan proposes to modify some offsite monitor
wells for groundwater extraction, but only after onsite groundwater has been remediated.
The intent of this is to prevent offsite extraction from accelerating pollutant migration
from the onsite area. The plan as proposed is vague and non-specific in this area. A
specific task has been included in the Tentative Order to address methods to determine
when or if offsite extraction will begin. The monitoring program included as part of the
RAP should include specific detail regarding the wells that are inplace verify that
downgradient, offsite migration is being controlled or has not migrated beyond the
existing wells.
The groundwater extraction system proposed is not designed with the removal of
inorganics, however it will, by the removal of groundwater polluted with VOC's also
remove groundwater polluted with inorganic constituents. The groundwater treatment
is not designed for the removal of the inorganic constituents from the extracted
grcu..."1jwater prior to discharge to the sanitary sewer, however the concentration of
inorganics allowed in the system effluent is regulated under permit from the San Jose
Water Pollution Control Plant.
Due to the length of time required to achieve groundwater cleanup standards under the
proposed plan, as estimated by the discharger, Board staff would propose modification
to the plan. This modification would consist of the addition of include institutional
controls to limit the possibility of residential use of the property until cleanup standards
for soil and water are achieved.
120 SELECTED REMEDY
The selected remedy consists of the following components as described above:
1.
Steam Injection and Vacuum Extraction (SIVE)
Bio-treatment, Carbon Filtering, and Air Stripping of Extracted
Groundwater, Surface Water, and Vapor
2.
3.
Capping of the Site by Pa~g
4.
Groundwater Extraction
5.
Continuation of the Groundwater Monitoring Program
20
.. ..... ..... .. -
. . -.. .", . .0
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.. .- -" ...------.
6.
Deed Restrictions to Control Residential Development of the Property until
Oeanup Standards for Soil and Groundwater are Achieved
This system does not have the highest capital cost of alternatives that were selected for
detailed screening nor would this combination of alternatives result in the least expensive
treatment of the alternatives considered.' The estimated time to cleanup for soil is the
shortest period of any of the alternatives that went through detailed screening.
Groundwater cleanup times were not a factor for comparison of alternatives since
groundwater extraction is the only active remedial action that was considered. The
combination treatment system has the advantage that it allows for efficient treatment of
a wide variety of pollutants.
The groundwater extraction/treatment system has been installed at an estimated capitol
cost of $399,000. The annual cost of operation and maintenance is estimated to be
$884,000. The SIVE system is currently inplace on site, the estimated capitol expenditure
for this installation is $549,000. The annual operation and maintenance cost for this
alternative is estimated to be $288,000. If it is determined that it is necessary to operate the
SIVE system in vacuum mode to achieve soil cleanup standards operating and
maintenance cost will be reduced to $250,000 annually.
13.
RECOMMENDATIONS
Staff recommends the adoption of the of the six element proposed plan as ,described in
Sections 11 and 12 of this staff report and Finding 9.0 of the Revised Tentative Order. The
cleanup standards shall be 1 ppm total VOCs and SOCs for soil. The cleanup standards
for A aquifer and B/C zone groundwater shall be those detailed in section 9.0 of this staff
report and Specification 3 of the Revised Tentative Order. Staff further recommends that
the Board require a cooperative remedial effort between Chevron and 551 and
participation by 551 in the remediation of soil and groundwater in the area along the
southwest property boundary of 551, where BTX&E contamination and possible VOC
contamination is known be reviewed once the extent of e BTX&E contamination has
~rrrog~did4- ~
CONCUR
CONCUR
Mavis Kent, Section Leader
Steven I. Morse, Division Chief
South Bay Toxies Division
South Bay Toxies Division
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APPENDIX C
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REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
INTERNAL MEMO
DATE: August 6, 1990
TO: MDK, SIM, File # 2189.8076
FROM: RCG
SUBJECT: CLEANUP STANDARDS SOLVENT SERVICE, INC.
To set cleanup standards for groundwater at the Solvent Service (SSI) site staff began with
the chemicals identified as chemicals of concern by the risk assessment (RA) prepared by
ICF/Oement (ICF) for the Board. The RA defined thirty-one (31) chemicals of concern in
grotmdwater at the Solvent Service, Inc. (SSI) site. These chemicals include nineteen (19)
volatile organics (VOCs), five (5) semi-volatile organics (SOCS), and seven (7) inorganics
or metals. These chemicals were further classified as either carcinogenic or non-
carcinogenic (toxic) substance, with twenty (20) non-carcinogenic chemicals and eleven
(11) carcinogenic chemicals.
The primary goal of reducing pollutant concentration to background levels for all
chemicals of concern was determined to be technically infeasible due to the mixture,
concentrations of pollutants present, and experience on other sites. Therefore, staff
developed draft cleanup standards, as described below, utilizing risk-management
techniques that would be protective of human health and the environment as well as the
existing and potential beneficial uses of the groundwater by utilizing the Hazard Index
(HI) for the non-carcinogens and excess cancer risk numbers (ECRN) for carcinogens. The
minimum standard for cleanup being a HI less than 1 and a desired ECRN of 10'6 with
a maximum of 1()"4 (EP A policy/regulation). An HI of less than 1 indicates that toxic health
effects for a single chemical or the combination of chemicals would not be expected.
This general approach to approximating non-carcinogenic health hazard has been used
by Board staff in the past due to ease of calculation and presentation of results. In the
past the HI has been calculated as a ratio between the concentration of a chemical and
the a reference level, usually state or Federal MCLs for that chemical. This ratio for the
individual chemicals is then summed to produce an ffi for exposure to all
noncarcinogenic chemicals of concern identified for a site. This approach was utilized for
this same purpose at both the IBM and Fairchild Superfund sites in Santa Oara County.
For SSI the ffi was calculated as the ratio between the chronic daily intake (CDI) :
1
. . "
... '-'.'. ..'. .., .
-------
calculated at a given concentration for that chemical and the reference dose (RiD) for a
given chemical. The appraoch is similar to that previously used in that intake at a specific
concentration is compared to a reference intake, the RID, at which no health effects
shiould be observed. The CDI takes into account the concentration of the chemical, the
duration of exposure, average body weight, and daily intake for each chemical. The CD!
can be calculated by a standard formula given below. This ratio is then the hazard for the
individual chemical at that given concentration. The RID for each chemical is derived
from toxicological data and represents an estimate of the concentration of a chemical that
a human can be exposed to with no expected toxic results. The RID is both chemical and
exposure route specific. Compared to the approach that was utilized for the Fairchild and
IBM sites, the CDI/RfD approach may be less conservative, but is a more realistic estimate
of the hazard posed by the exposure to non-carcinogenic chemicals present at a site.
While the approach utilizing the MCL appears to be simple it obscures the complicated
process that goes into the development of MCLs.
Current toxicological theory is that there may not be a threshold for exposure to
carcinogens. This implies that any single exposure to a carcinogenic chemical, regardless
of concentration, can result in an increased incidence of cancer. In addition due to
technical and economic reasons not all MCLs are health protective and not all MCLs
pro~ide the same level of protection. Therefore, the I-U approach is not appropriate tool
for evaluating exposure to carcinogenic chemicals. The use of the HI as a ratio between
CDI and RID for noncarcinogens and estimation of increased population cancer risk for
carcinogens is detailed in the EPA Risk Assessment Guidance (December 1989).
For this site the risk and hazard estimates are based on conservative exposure estimates
as follows:
Adult body weight - 70 kg
Exposure duration - 30 years
Groundwater ingestion - 2 liters/day
Absorption - 100%
Dietary fraction - 100%
An equation was developed for the calculation of the CDI based on the following
equations:
ITI< = (C.) . (W) . (G) . (D)
where,
ITI< = chemical intake from groundwater (mwday),
c.. = chemical concentration in groundwater (mgIL),
W = daily water consumption (Uday),
G = drinking water ingestion absorption factor, and
2
- .'.
- .
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D =' dietary fraction of water ingested at home.
The total intake is then converted to a chronic daily intake (CDI) as follows:
CDI = ((1TK)-{D)-(F)JI[(BW}-{E)-(36S)] .
where,
CDI= average daily intake via groundwater (mglkglday)
ITK = chemical intake from groundwater (mglday),
D = duration of exposure (years)
F = frequency of exposure (days/year)
BW = body weight
E = extrapolation factor (years):
for noncarcinogens = exposure period = D = 30 years
for carcinogens = 70 year lifetime, and
365 = conversion factor (days/year)
These risk and hazard estimates are based on conservative exposure estimates as follows:
Average Body Weight - 70 kg = BW
Exposure duration - 30 years = D
Groundwater ingestion - 2.liters/day = W
Absorption -100% = G
Dietary fraction - 100% = D
The reference dose is estimated from toxicological studies and the values are obtained
from one of several data bases maintained by EP A. The integrated risk information
system (IRIS) maintained by EP A includes only data that has been extensively validated
by peer review. IRIS is the first choice of reference for RID or other toxicologic data and
would be considered the strongest indication that the data is valid and reliable. If an RID
for a chemical is not included in IRIS then other sources are consulted and the resultant
data is used, albeit with greater uncertainty.
The thirty year exposure is within the 90% interval for current residence times according
to current EP A guidance. The 2 liter/day consumption rate may be a high estimate of
average consumption and current EP A guidance indicates that 1.4 liters per day may be
a more appropriate assumption, however MCLs are based on the consumption of 2 liters
of water per day, consequently it is considered appropriate for this comparison. In
addition, since the cancer potency factors (q.) are calculated based on lifetime exposures
(70 yrs) the chronic dally intake (CDI) for carcinogens was normalized in the calculations
to account for this variation in exposure time (30 years vs. 70 years). Both dietary fraction
and absorption are most likely conservative since it is improbable that most residents
consume 100% of their dally water intake at home or that all chemicals would be 100% :
3
."'" ~ ....-...
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adsorb~d.
The chronic daily intake (CDI) is calculated based on the above equations and
assumptions. The CDI is then divided by the reference dose (RID), as established by
toxicological studies, to calculate the individual hazard related to a chemical. The
individual HI's are then summed to a total HI for all COC's. This approach represents a
more reali~tic estimate of the hazard posed by the exposure to non-carcinogenic chemicals
present at a site than the approach utilizing only the MCL's. In either case the HI
approach is a conservative estimate of the hazard posed by a site since summing the
exposures assumes that the toxic affect for all chemicals of concern would attack the same
system or organ.
The same equations are used for the development of excess cancer risk numbers (EeRN)
for carcinogenic chemicals. However, since cancer slope factors or potency are based on
lifetime exposures a different extrapolation factor is utilized in the equation to address the
less than lifetime exposure assumed for this circumstance. The ECRN is then calculated
as the cancer potency factor (q-), derived from toxicological or epidemiological studies,
multiplied by this CDI. The cancer potency factor is an indication of the quantity of a
chemical that can be ingested before carcinogenic results are probable. A high number
:s b:i:ative of a strong relationship between exposure to a chemical and the occurrence
of cancer.
Excess cancer risk numbers (ECRNs) are evaluated for each individual chemical to
indicate the potential effects of carcinogens, and are usually expressed as the number of
excess cancers that may develop in a population; i. e., the 10" or one-in-a-million risk, or
the 1()'$ (one-in-l00,OOO) risk. When cancer-causing substances are present and a threat of
exposure to these substances exists, a potential risk is present. There is no "zero-risk" level
associated with the threat of exposure to carcinogens. The total ECRN for a group of
chemicals is calculated by summing each individual chemical's ECRN. A number of
assumptions have been made in the derivation of these values, many of which are
intentional overestimates of exposure and/or toxicity. The actual incidence of cancer is
likely to be lower than these estimates and may even be zero. The use of the HI as a ratio
between CDI and RID for non carcinogens and estimation of increased population cancer
risk for carcinogens is detailed in the EPA Risk Assessment Guidance (December 1989).
The first trial cleanup scenario was carried out with ingestion of groundwater, the critical
pathway of concern to human health, as identified in the RA. This scenario included all
pollutants identified as chemicals of concern in the RA except 1,2,4- Trichlorobenzene, for
which no guidance data regarding acceptable levels in water was available, for a total of
thirty (30) chemicals of cencem. The potential toxic effects for all chemicals of concern are
considered and only the chemicals that are classified by the EP A as a human carcinogen.
FOr this trial scenario, the aggregate risk via this pathway was determined by setting
cJeanup standards to the ARARs identified in the RJ/FS. This resulted in a total HI of 10.18
and aggregate ECRN of 10'3 (see Table I). These risks did not meet the desired minimum ..
4
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cleanup standards and included only the groundwater ingestion pathway.
Following further review of the RA and current groundwater data, staff determined that
four SOCS and six inorganics could be eliminated from consideration as chemicals of
concern. The SOCS that were eliminated are isophorone, naphthalene, 1,4-
Dichlorobenzene, and 1,2,4- Trichlorobenzene. Isophorone was eliminated based on its
classification as a class C carcinogen. Region IX guidance indicates that class C
carcinogens, due to the uncertainty of classification as a carcinogen, may be more
appropriately treated as noncarcinogens using a modified RID approach. Review of the
toxicological data in ,the Public Health Evaluation Risk Database and the RA data also
indicated that ,the evidence for inclusion of isophorone as a carcinogen was based on five
studies, only one of which indicated possible carcinogenic affects. The RA also indentified
1,1-DCE as a chemical of concern and it is also a class C carcinogen. The toxicological
data for 1,1-DCE is more extensive and is subject to much discussion in the scientific
community. The data for 1,1-DCE is more indicative of negative evidence that 1,1-DCE
is not a carcinogen than the data for isophorone. However, it was decided to retain 1,1-
DCE as a chemical of concern as a carcinogen for setting cleanup standards due to its
frequency of occurrence onsite.
Naphthalene, 1,4-Dichlorobenzene, and 1,2,4- Trichlorobenzenewere included as chemicals
of concern for groundwater based on estimated concentration from their occurrence in
soil. Review of groundwater data that was not included in the groundwater database
used in the preparation of the RA indicated that these chemicals had been detected either
infrequently at low concentrations or never detected. Therefore these SOCS were not
considered as chemicals of concern in establishing site cleanup standards.
The inorganics that were initially eliminated from consideration were antimony, copper,
lead, selenium, and thallium. The inclusion of these metals as chemicals of concern in the
RA was determined from groundwater concentrations. estimated by modeling from
shallow soil data. Groundwater data collected in December 1989 and March 1990, after
the' completion of the RA, finds that none of these inorganic chemicals are present in
concentrations outside of ranges that might reasonably represent normal background
concentrations.
The new data on inorganics does indicate elevated levels of zinc, nickel, cadmium, and
possibly chromium in one onsite monitor well. However, since this well is highly
contaminated with SOCs and VOCS (3,490,700 Jlg/1 total) the inorganic data may be
questionable. High levels of these inorganics are not present in other wells. Therefore
these inorganics will also be removed from consideration as chemicals of concern.
Comparison of analytical results from filtered and unfiltered groundwater samples from
a subsequent round of groundwater data indicated that arsenic present in the samples
exists largely in the suspended fraction and is not in solution in the water. The samples
with the highest concentrations of aresenic (wells looA and IOlA) are highly turbid and:
5
.. .- ... -.
. '-. -.... ".. ..
-------
- .------..
removal of the sediment from the water prior to analysis reduces the concentrations of
arsenic to well below the MCL. Therefore staff recommends that arsenic also be
eliminated as a chemical of concenr for the Solvent Service Facility.
A second trial cleanup scenario was carried out for this reduced set of twenty-one (21)
chemicals of concern. Again the proposed cleanup standards for all chemicals was set at
the MCL (the more stringent of State or Federal MCL levels) or other guidance {ARARs
and TBq such as provided by IRIS, DHS action levels or water quality criteria. This
resulted in a total HI of 2.49 and aggregate ECRN of 105 (see Table I-A). These risks did
not meet the desired minimum cleanup standards and again only addressed exposure
through the groundwater ingestion pathway.
As a check an additional scenario was carried out for a set of thirty (30) chemicals of
concern to determine what cleanup stadards would be required to achieve an HI of 1.0
or less and an excess cancer risk of 10'6. This indicated that most chemicals would have
to be removed to levels at or below the detection limit (see Table D). In particular arsenic
and vinyl chloride would have to be reduced to concentrations to approximately a part
per trillion. This is based on the scenario that all chemicals identified in the RA are truly
present and are of concern.
Further review of the most recent inorganic data indicates that nickel is present above
"local" background levels and that elevated levels of zinc are present only in the single
well referenced above. Based on this data nickel has been added as a a chemical of
concern, although it was not included in the chemicals of concern utilized for the risk
assessment. Zinc has been eliminated as a chemical of concern based on its infrequent
occurence and low toxicity.
As the next step in development of cleanup standards via risk-management, the HI and
aggregate ECRN were calculated. The percentage of the risk and hazard was considered
in selecting chemicals that were accounting for the majority of the rn or aggregate ECRN.
The cleanup levels for these chemicals were then reduced to achieve the secondary
cleanup standards. These reductions were balanced against the ease of attainment of the
goal and total concentration of the chemical on the site. This process was repeated on a
trial and error basis until both the maximum HI of 1 and a minimum total ECRN (10"')
criteria were met.
These risk management techniques indicate that the major changes necessary for the non-
carcinogens were the reduction of the allowable concentration of acetone from the 3.5
mglllevel recommended by IRIS to 1 mgJL Acetone will be removed from the extracted
groundwater as a result of destruction in the bio-treatment system. The cleanup standard
for acetone is critical, since acetone is the most widespread pollutant and occurs in the
highest concentrations onsite and may account for up to 80% of the volume of
groundwater pollutants. To achieve an HI of one or less the proposed concentrations of
ethylbenzene, nickel, phenol, and toluene also had to be reduced. The proposed cleanup:
6
. '.'....' ...-.-
. .. .-.... ,.. ~~. ..... -
-------
standards for acetone was reduced from 3.5 mgll to 1.0 mgll, the proposed cleanup
standard for ethylbenzene was reduced from .68 mgll to 0.5 mgll, the proposed cleanup
standard for nickel was reduced from 0.154 mgll to 0.100 mgll, the proposed cleanup
standard for phenol was reduced from 3.5 mgll to 3.0 mgll and the proposed cleanup
standard for toluene was reduced from 2.0 mgll to 1.0 mgll to establish health protective
cleanup standards. The cleanup standards for all other chemicals under this scenario were
set at the ARARs or TBCs identified in the RIlFS. This resulted in an HI of 1.0 (see Table
ill-A), indicative that these cleanup levels would be protective health by exposure through
the ingestion of groundwater.
Even at these reduced concentrations, acetone, ethylbenzene, phenol, nickel and toluene
will still account for approximately 90% of the HI following cleanup at this site. Further
reduction of the non-carcinogenic risk posed by these cleanup standards is probably not
warranted, since reduction to background levels (Le. zero for all compounds except nickel)
of all of the compounds would not result in a significant reduction of total vs.
incremental risk, and the stringent cleanup required for acetone will also probably drive
the remaining VOCs and sees to levels below these cleanup standards.
The cleanup standards for the eight remaining carcinogens of concern have all been set
at the MCL or other water quality guidance if no MCL has been established (see Table
. ill-A). The excess incremental lifetime cancer risk, above the risk due to the exposure to
. arsenic, is estimated at 6.5 x 1~ (see Table ill-A) for a person ingesting the groundwater
after cleanup. This level of cleanup does fall within the allowable range under the NCP
and would be considered to be health protective.
Since ingestion exposure occurs under a hypothetical residential scenario exposure
through incidental residential uses (showering, cooking, laundry, etc.) must also be
considered. It is logical to assume that the if the ingestion exposure occurs that the
incidental exposures will also occur. If this is the case then the risk from each exposure
pathway must be summed. As per EPA Region IX guidance, the daily intake through the
inhalation pathway related to incidental residential use is equal to the the consumption
of two liters of water per day. Therefore the calculation of the CDI is the same for this
scenario. The CDI is then divided by the inhalation RID for volatiles, where available, to
estimate the noncarcinogenic health hazard due to exposure to chemicals through
incidental residential use. For the carcinogens the same technique was applied, with the
CDI calculated for the ingestion scenario multiplied by the inhalation cancer potency
factor (q.), to estimate the increased carcinogenic risk due to exposure to chemicals
through incidental residential use. It is then appropriate to sum both risk and hazard
from ingestion and inhalation calcuIatipns to estimate the total risk under this
hypothetical future residential scenario due to the exposure to polluted groundwater
through these two pathways. All inorganics were eliminated from the calculation of the
incidental residential use exposure since it they are unlikely to volatilize during
residential use.
7
-------
Due to the ~ununation of the ingestion and inhalation pathways the proposed cleanup
standards had to be re-calculated. To maintain the goal of an HI of one or less and an
ECRN in the desired range some cleanup standards had to be revised. The proposed
cleanup standard for acetone was further reduced from 1.0 mW! to .040 mW!, the proposed
cleanup standard for ethylbenzene was further reduced from 0.50 mW! to 0.40 mW!, the
proposed cleanup standard for nickel was fQrther reduced from 0.100 mW! to 0.080 mgll,
and the proposed cleanup standard for phenol was further reduced from 3.0 mW! to 20
mgll. In addition methylene chloride was reduced from the DHS action level of 0.040 mgll
to 0.030 mgll. This results in an HI of 1.0 for the summation of both pathways.
The only change in the proposed cleanup standards for carcinogens was the reduction
of the proposed cleanup standard for I,I-DCE to the detection limit of 0.001 mgll (see
Table ill-B). This reduction maintains the ECRN in the 10'3 range.
This approach produced minimum cleanup standards that are protective of human health
and the beneficial uses of the groundwater. The total ECRN is within the acceptable EP A
range. Three technical and policy uncertainties remain for management and public
consideration:
- Is the deletion of arsenic as a chemical of concern acceptable?,
- Was the method of elimination of some of the chemicals of concern
identified in the RA acceptable? and
- Is the minimum total ECRN, 10'3, acceptable?
The reduction of the excess cancer risk related to the remaining chemicals of concern
would require the reduction of the cleanup standards for 1,I-DCE and vinyl chloride to
below detection limits.
Board staff recommends that the cleanup standards as presented in Table m-B be utilized
in the Board Order and Record of Decision. The uncertainty surrounding the detection
of arsenic, and inorganics in general, and the comparison of filtered and unfiltered
samples is sufficient to justify the removal of most inorganics as chemicals of concern. The
reduction of the noncarcinogenic risk due to the number of chemicals involved and the
potential high levels of hazard, might be more appropriately screened by grouping
chemicals by target organ or system. This approach might result in a more realistic
appraisal of the noncarcinogenic site hazard, however it would require the expertise of
a toxicologist. .
8
.~. -
-------
SOLVENT JaVICE INC.
TA8UI
CUNCUP OOAU lEI' TO AAAII8 TO nc:.
-.-,.--.-----c -
011 ~..au fOIl"'" ~& a .-
-_."__.Oo'III'.'_'AT~
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ID. ~ ClUll'TDI~
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-
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-- I. CA IKILIto UIt .- ,- ..-
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L''- e- CA-.. ... ,- .- ......
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,- e.- CAM.. .., .- .- ....
'.'- 1- 01> IICLC .... ..- .- ..-
-,...- .... CA -. Ut "- ..- ....
-....- e.... CA-. - -- ,- .....
~ 1.8 CA-. ... ..- -- .-
trWIIIIaM.,., ,....- . -- ,.- ....
- 1'irD8 "'- ... ..-.. -- ..,..
UotII ... CA -. -- .- --- -
""" CO'\.C'"lC'l 0- CA"'. ... ,.- ...... ..-
--.......,. ""1 - -- ..- ~...
--- ...- .. ...... ..- ..,..
- ..- CA"'. ... ..- ..- ......
- .... - ... ....... ....... .-
- .... CA"" .... ...... ..... ....
"'.'-1eA 1- CA-. - ~ ..... ....
- e- CA- .... -- .- ..-
-- ..'.aD - --- ...... ......
- '.8"-' ... ..- .- .-
_a. 8.- 0&..... - ,- - .-
-- ... CAIICIL . --- ..... ....
- ... ...-. ... .-... ,.- ,-
--_. .... -
- .. -- .. - - - .-
- --
- ... ....... . .... ..- .- -
- ... CA-.'" .... ... ...,.... .- ......
- 1.8 CA_- -- ... ,- ..- .-
'.-- e8 CA-'- .... .., .._ ...,.... .-
,- .... CA..... ... .., ..- .- .....
...- ... CA IICLC ... .... ,- ...- .....
- U_ .... ... ..- .-... -
-- .- CAM.- - - -- ..- .....
- .. CA'" .... ... ..- ..- ..-
- 1- 110- .... -- .- -- ......
-.. -- OII-.- U .- ..... .-
---_. ...... -
'.
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A.""'" .... CMIQIIIDQII-
...-._----._-----
..-------._-----
C.------"-.--",,
I
.." .
..... ..
.......' ,."-
-------
SOLVENT SERVICE INC.
TABLE I-A
C1..EANUP GOALS SET TO ARAR8 TO ne.
CIETEMIINATJOH 0# EXCOS LFETIIoIE CANCER AI8It FOR CAAC:INOGEN8 NIG
O#~INDEXFOR~
CHAONICEWLYINTNtE(CCI).C.".." ED" 9/fNi" AT(YCUtGlL)
Cw . CHalICAI. COHCEHTAAT1ON. NWWBCI (MG/L)
IR. INOESTIOH RATE ~
ED . EXPOSURE DUAATJOH (Y-)
9. e..-v.. FNqU8llq' ~..,
Wi. lady WI"'" (Kg)
AT . .........., TIme (p8rIaCI - .... ........ II ........ - .".)
c.
It
fIN
AT AT
('DIll) ......,.)
'OlIO ...
ID
IF
...........
....,
.
I
-
JII
~ INDEX. CDUND
EXCE.88 LFETIME CANCER'" . COI.~"
RIO . REFERENCE D08E (YCUtCIIDAY)
-" . CANCER POTENCY FACTOR (WCMtCIIDA~'
Cw - /INPa . TW:II
MIa. CHEMICAl. Ow WOE NO COI
, ACETONE UOO .. 0., ,~,
1 BENZENE 0.1ICI07 CA UCL\A 0.0' I.OOE-OI
I I-8UTANOfE O.o:lD 0.01 L7,E.
. CHLOAOFC:INA O.DOlO CAAAL" 0.0, U,e.
I ','-oc:A 0.0010 CA UCL" 0., ,""
. '.I~ 0.001 CA UCL ... ,....
7 ,. ,-lICE o.DOIO CA UCLIe .... '.71e.
. CIS-,,I-ocE 0.001 CA UCL 0.0' '.7,e.
. TAAHS-,,I-ocE 0.0'0 CA UCL ... I.-..cM
10 ETMYUIENZENE 0.. CA UCL o., ,~
" FfIEON-"1 ,.Il1O CA AL. . IA8E4
'1 METH. CHLONDE 0.0800 CA AL." 0.. ,.~
18 ""ETH.~. 0.0'0 O.DI "".
M PCE O.DlMO CAAL." 0.0" . MEoO&
'I~ UOO WQC 0.' ,~,
11 '".,.T'CA 0.1lIO CA UCL ... L71E-08
17 TeE 0.0010 CA UCL" 0.007. ,....
11 TOLUENE 1.000 U8 UCL ... L7,E-II
1t VINVL Q, O.DOOl CA UCL\A NA ,ME-OI
10 XVlENE8 UIO CA UCL I UOE-II
1'1 ZINC LOOO 1 U8 UCL U ,~,
TOTAL. HAZARD INDEX .
CHEMICAl. Ow WOEQA88 ,8 NO CD
CAACINOCIEN
, IIENZENE 0.00' CA UCL\A .... 0.0, ......
1 CHLOAOFC:INA 0.001 CA AAL8 0.D0I1 ..... 7.-..
I ','-oc:A 0.001 CA UCL8 ..., 0., .. ,...
. '.'-lICE O.DOl CA UCLIe ... O.DOI 7....
I IIETH. CHLCRDE 0.010 CAAL.8 0.0071 ... ....
. PCE 0.001 CA AL.8 ..., 0.0' ..,...
, TeE 0.001 CA UCL" 0.0" 0.D07. ..,...
. VINVL Q, O.DOOI CA UCL\A U ..1&4
~TEEXCIE88CNCIER'" .
Ra. RaOfW. ~D08E
DIM4A. DRHKINCI WATER HEALTtt /tlNtfIQIIIN
WQC. NATIONAL ""BENT WATER QUALITY CNTBIA FOR P'UIUC HEALTtt
I U8 MCL .IECONDNW' fEDB'AL. UCL
CA AAL . DH8 APPLIED ACT10N LeI&.
WOE. WII£JCaHT 0# EVIDENCE . 8CXMCE 0# Do\TA
A.1tJiIO\Mt HUIoIAN CAACINOSEN8
I' . P'A08AIII.£ HUMAN CAACINOCIEN (IrnI8M IIv"" """",IIIIecI-"""" .... ........)
82 . P'A08AIII.£ HUMAN ~ (lMdequall IIv- """'-.IIIIecI- ........ -- ..1rM1I)
C. POUIBL.£ HUIoIAN CNQNOGEN (IrnI8M .......- .. .......111. ..1IMI1WIIe ..~
. . _.. - -..- .. -
.. -.' ,'.. .'
..
"O#TOTAL
HAZARD INDEX
,.OOE.oo ..,..
..ODE-OI 0.....
'.1IE4 0.'"
1.7'14 0.""
,....,. 0.....
,.IIE-OI 0.,..
,.8IE-DI 0.,...
'.7114 0.,..
,AIE-DI 0....
,.8CE-O, 7.8..
,.~ 0....
1.10£04 0.'"'
&.71E-OI .....
'.1IE-DI ......
,.I7E-O, ..,..
UIE-DI .....
1.I1IE-DI 0."..
,.8DE-O, 7.'"
NA O.DD'
1.l00-DI ,....
7.~' .....
"".00 ,00....
IIIIt .. 0#
AOGAEGATE IECAN
IME-07 ......
"""'-07 0.....
LI7E-OI 7.1...
...,(-01 .,..,..
8om-ll I.""
a. ,..... ......
..nE-07 0.....
'A'(-OI ,.....
,. ,...
'DD'
-------
-- -
SOLVENT SERVICE INC. TABLE D
C. SET TO ACHIEVE ECRN 10£-6 AND HI LESS THAN I
~TIOItOl'DCUIILFETIU£CNCER- FORC~ MID
~ ~INDEaFOA-~~1IENI
CHA088:~" 1If1'¥£ (CDI).c.. 0" - EDO ~-- AT~
c.. . CHEIItCAL IP£aFIC COHCENrM11DN
.. . INGESTION M~ ~
ED. DI"OCIUNO ~TION t'f-)
IF .~FNQUEJC'f~-"
." . 8CIO't WEICIHT ftI)
AT . A~ TIME,,- --....,.. II -...-. -.e)
c.. .. m . 8N AT AT
lID*' ~
-- . . - JD - ...
--
.- . CANCER POTDIC¥FACTCIIt~~'
DCE" LIFETIIIE CAMCEJlN8t. CIIIa.-
HAZAN)..oEX . CDIIND
fIID. MF~ DOIIE~'"
C. (MGILJ . CHEIIICA&. CONCIENTM11DN8 TO ACttIE\IE tllZI8 '*" 0NIj MID ,..-...
.01'
CIHDICM. 08 fID CIII .. TOTAL ..
, /lCnONE ." 0., ,"'" ,..... ,...
I NtrIIiION\' D.DOW wac D.DDCM UDI4 '''''' .....
a IIRRHIC D.DIIII01 D.OD' ''''~ ...... .....
8 IENZIHE OMDI IA D.D8 D.Dt ,,... ,...... ..,..
. 2-8UT~ "" .,. 1.1'.. "'''' ..n.
. c;:HL0A0F0MI D.- _ ...., D.Dt ,,... ,...... .....
1 ,,'~ ..- - ..., .., ,.... ,...... ...,.
. 1.I..cc:8 OMDI CAIIGL. ... ,.... ,.-- .....
. 1,8-GC8 .... _ .... .., ,,... ,...- ...,.
to '. I..(ICE ..-, .c ... I.DOt ..... ..... .....
" ~1.2-GCIE .... CA'" D.In '.7\&4 ,.,... ..,~
12 ~1.a-0c8 ..DOl CA IIGL. ... ...... ,...... ..W.
,a OOPPIJIII ..,. UlIIGL. ..., &".4 '''''' .."..
,e ITtn'\.8ENZENI ... CA IIGL. .." ,8854 ,....., ......
,. ""~"a ". CA'" . uaE-or ..,... ..n.
,.~ OJIII,' C D."' "'' ..... ,.-- .....
17 LEAD D.DOI UlIIGL. ..- ,...-- ....., ....
11 METH. CK.ONDE ..- - ...,. ... ,..... ...... .....
~. -ETK.-a.l'£Jlf. ..... ... ..... 8oJSoCN .....
81 ~~ . ... .... .. 'M! .."'"
I'I~ 8.DODI - ..., ..., ,..... ,...... ..,..'
12 P'MINOL 8.81 QUIL ... ..... ....... .....
II IIL.I*M OJIII, CA M. .... ..... ...... .....
.. ,.,.\oTCA .JIII CA IIGL. ... 1.1''''' " ..... .....
. TOE D.- - ""e ,..... ,..... .. '"'
. TtW.U8I o.DODI wac D.GDD01 """" " ,... .....
~ TOLIBIE .... . UlIICL ... '.MI. "'" ....
. VIIM. OL ...., IA ....~ - -
. M.DII8 ",1 CAIIGL. . 1.OaIWI ..... .....
.~ ... ..IIGL. ... ,..... ,.,... .....
TOTAL HoVNID - ,..... .....
waElCllII8I 01' .01'
OCIIICM. 0. ~ .. .., CIII .. TOTAL'"
1 AMENC -..-, "' . ,..... ......, ...
I IENZEJIE ..... IA .... ..., ...... ,....., , .....
I c;:HL~ ..... - ...., ..., ...... ...... ,...
e ,......0c8 ..... - .... .., ..... ,....., .....
I '.'~ ..... - ..., .., ....... ...,..., ..,...
. ,o'..(ICE ..-. .c ... .... ,..... ...... .,....
1~ ..., .c ...., ..11 ',.,..- ...,... ,..,.
. UETH. CItUIMIE ..... - '.ID1I '" ....... ..,.... ,"'.
.~ -- - ..., ..., ..... - ...,..., ,,....
.. TOE .... - ..." I.IDM ...... ....... ...,.
" VIIM. OL ...., IA ... ,..... ....... ......
MCIIEQA~ EXCD8&RTIMECMCIR'-: ...,... .....
"."~-..~008
OWHA.""'" WATER ~nt.,."",
IIIIQC. M/lT1ONA&. AM8IENT -~ QUAUTV Cfln'EJMRlRPUIUC.....".
I Ut MOL . 1E00"0"1n' ~ IIGL.
CA AM.. 0H8 ~ IICIQI L2\IIL
WOE. MIGHT 01' EVIOIICIE . ----- 01' MhIo
A.~-HUUAN~ ...
II . P'AOUaE MUM"" CMCINOCIEN ~ ""-......... ....-........ .......
lit. ~ MUMAH CMCINOCIIN ~- - -. -.-........-......,
- Co POS88LE-CMC88OCIDC~""''' -- 1 ....._----.t
-------
\-
---- --*-
SOLVENT SERVICE INC. TABLE.m-A
PROPOSED FINAL CLEANUP GOALS
D£TERMINATIOH 01' EXCE. L.JFET1ME CANCER fI8K FOR CAACINOGEH8 NlD
01' HAZAAD INDEX FOR H()N.-(:I.ACi"'tOCIENI
CHAONIC DAILY INTAK£ (CD!) . Ow''''ED°fT'If!N#"AT (UGIt~
Cw - CHEMICAL CONCENTRATtOH. NWW11ICI (U~
.. - INGESTION RATE 0JIet8/D8r)
ED. EXPOSURE DUAAT10H
-------
LVENT SERVICE INC. TABLE III-B
PROPOSED FINAL CLEANUP GOALS
..
1lE"fEAM1NA11ON ~ fWAAD INOEX FOR TOXIC HEAl," EFFECT. AT JIACf>uat:u a.£ANUP 8TNCW!D8
CHROMe IMIlV IN'f'ME (ICOIJ - Ow . .. . ED . EF, -. AT (MCMCCI/DA\1
Ow - QEUICAL CONCafTMTIOH ~
.. -1NOE8TION MTE (\.JIInI08y)
ED. DPOeU'E 0UM11ON (V...)
E'F. EXPOSUAE FfIEQUEHCV (DIrtIV..,
IW - 800\' WBOHr ftf)
AT - A~ fIIII:"'" _.........,. II --.-...)
,.
..
"
..
Cw
DIImW
.......,
..
ED
IF
-
AT AT
(alai) (o8n*IogIn)
'0180 IIIMO
.
-
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..
HAZMD INIIB . CD/AID
AID. ttP_- DOlE (llCMCCI/DA\1
" - ~ PCne8C"IFAiCfOft~CI/DA~'
EJt'CE88 LF£T8IE c:N8CEft... . COlI. "
Ow - MOf'()8EO nw. ClfNUtCMW.8
CHEIIICoIIL
t ACETONE
. IEJIZENE
I I-8UTANONE
. CH.OAOFONI
. '''~
. ',1-DCA
7 QS..I.1-OCE
. ~I,I..ocE
. I.I..ocE
10 mM.IIENZBE
11 FAEOM-III
11 MaM. CH.OIIDE
., "'ETH.-a.ftNr.
,. MCIC&.
tI PCE
'i" PttENOl
" 1.I.I.TCA
" TeE
" TOlUENE
10 \18M. CL
" JM.£NE8
Cw
COlI
INGIEIlfION "~INOE'" 1NtW.A11ON 1NtW.A11ON
Ho\lARD 110N .. AID Ho\lARD
.. ~ ~ 1NtW.A11ON .. ~
tATIOH.. 4INOE8TIOH TOTA&."
-
AID
...
..001 OAMCUA
...
.... CAMU8I
.... CA IIICL
.... CA IICU8I
0." CAA&.
0.010 CA A&.
'.001 DUe
0..00
1.1110 011 A&.
0.030 CA AUIII
..."
0.010
0.001 CA IICU8I
1.000 CA A&.
o.aoo CA IIICL
'.008 CA 8Ia.8
1.000
0.0001 CA IIICLIA
U. CA IIICL
t. ,..,.. .." ,,,.,,
I.eee.. NA .....
..1IE-OI 0.0' t.~
U'E-OI '.01 I. ,ft
U~-OI 0.00 '.1'"
U~-OI 0.00 0.''''
I.1IE-OI 0.01 I. 1ft
I.eee-Ol 0.0' ,.,...
I.." 0.00 0.'"
1. 'IE" 0." ,,,.,,
I.~" 0.00 O. ....
'.17£-01 0." ".""
I.ME-OI 0.01 0.10"
1.2IE-ol 0.11 11.....
U3E-Ot 0." 1.71..
"P,E" 0.10 .. .85"
l.1'E-oI 0." 7.7ft
I.~-Ot 0.01 I.'"
I.ME.. 0.10 U....
t.." NA NA
..OIIE.. 0.00 0.00"
0.82 '00.00"
o.t
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0.01
1.OE~1
0."
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0.1
30
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0.01
0.01
t.CIE..
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0.01
UE-ol
0.1
I
TOTA&. HoVAAD INDEX:
AS - R8 ORAL REF£RENOE D08E
DWHA - DM8ttNO WATER HEAlTH NN'IIJO/lIt't
wac - HAnoNAl NABIENT WATER QUAUT"I CRt'9IA FOR PUa.IC HEAlTH
US Met. - PRMARY FEOEIW. Met.
:r US MCL - SECONDo\R't FEOEIW. Met.
CA AM. - DHS APPlII:D ACTION lEVEl
lit. - o.--l-
WOE - WEIOKT ~ IEVIDEttCE - 80URCE ~ DATA
A - KNowN HUMAN CARCINOOEN9
., - PR08A8lE HUMAN CARCINOOEN (IrnIIed h- "'"-, 8dequ... ...we-1r0lll ..1m8Io)
8:r - PA08AIIlE HUMAN CARCINOOEN C1nedequ... hu- -.111""08, 8dequ." -.IIIln08 1r0lll ..1m8Io)
C - P08SI8lE HUMAN CARCINOOEN (IrnII1d md- of O8dnogenIly, ........ llud... 01111)
0.01
NA ..... '.U 11....
NA '.00" '.00 "'"
.... I."" '.01 1.7...
HA ..... '.01 1.""
'.00 ,.... 0.01 0.""
I.. 0.'" 0.00 ..,...
NIl 0.'" 0.02 1.""
NA 0.'" 0.01 1.~
NIl 0.00" 0.00 0.""
HA 0.'" 0." ""'"
NIl 0.00" 0.00 0.11"
HA 0.00" O.U ' Uft
0." 7.'''' 0.01 :1.0'"
HA 0.00" O.U .......
NIl 0.00" 0.01 ,.~
HA 0.00" 0.10 '.11&"
NIl 0.00" 0." 8.1,..
NA 0.00" 0.02 ,.....
0.01 ,...... 0.'1 'U:N
NIl 0.'" 0.00 0.00"
0.11 ..PI" 0." 11.....
0." '00.00" 1.0 '00.'"
0."
0.1
0.02
1.00
0."
-------
SOLVENT SERVICE INC. TABLE III-B-PART 2
PROPOSED PINAL CLEANUP GOALS
IIETENIItMTION OF DCE88 CWtCERI8C. AT PAOPOeED ClENU' 8tAH1W1D8
CHAOI8C IMIlY INfME CCOI) - 0. . " . ED . IF' 8W . AT (MGjI(GIOAY)
0. - CHEIIIOM. OONDENtMTION CMCMJ .
.. -lNOEsnoHMTE ~
ED - DP08UAE IlUMTION ('1-'
IF - DP08UAE FREatJENC"t (D8r8IYMIJ
8W -IIODY WEICIHT ftg)
AT - AVEJW)NI T81E""" -.......... II -... -II.,.)
Cw
..
ED
IF
8W
AT AT
..... ......
fDlllO 2lIIIO
C8I8nIIoII .
.....
I
.
-
JO
tNAAD INDEX - CD/ND
lID - Rtr~ DOlE (MGjI(GlDAY)
II' -CANCER POJBIOY FACYOA""G/M~t
EXCE88 LFEnIE CANCER I8C. - COl. II'
0. - PROI'08ED FINIIL ClENU' 8TAN11iMD8
WOEIClA88
CHEI8CM. 0. CMCINOOE ,,' " COI ...
t IENZENE '..t CA IIICIJA 1.11:4 t.." "_-07
I CH.0R0f0AII ..- .CA MI.J8I 8. fE-4I UE4 7.." UIE-07
. '. f-GCA '.001 CA IICUIII '.fE4 UI:-O, 8. '2£" 1.11£-01
4 '. t-«:IE ..., DUO 8.OE-O' '.0E-4I ,.... 7..-01
. IIEnt. CH.~ 0." CA AUIII 8.0E4 7..-41 ..-.... I.ME..
. PCIE 0.001 CA AUIII .. fE4 '.0E4 8. '2£" 8. '2£-01
7 TeE 0.001 CA IICUIII t.,E4 7..-41 8. '2£" 8.nE-07
. VIM. a. '.I0OI CA MCUA I.:IE.. 8. '2£-01 UfE-OI
IIOCIAEOATE EXCE88 LFEnIE CNICIR.... -
"-"OfW.Rtr~ DOlE
DMtA - DfINt... WATER HEALTH IIIN8J«t
woe - NATOW. MlIIIENJ WATER GUMJTY CInSIA FOR P\8JC HEALTH
USIIa. -I'IIIIARY FEDElW.IIa.
.; I USIIa. -IIEOONDMY FEDEJW.1Ia.
CA AM. - DH8 N'I'UED AiCT10N lPJEL
ill - D8IIcIIIaoIlMIII
WOE - WEIOHJ OF EWJENCIE - 80URCE OF MTA
A -ICNOWN HUIIAN CAACINOOEN8
.f - PA08AIlE HUIIAN CMCINOCIEN ~ --.......... ................ flam"""'"
8I..,PftOIWLE HUIIAN CMCINOOEN""""" -- .......... ........ ..w-1nIm .........
C -1'08III8lE HUIIAN CMCINOOEN (ImIIId ..w- aI 08IIIn0genIIr. .... 8tUd1l8 anlrJ
8. fOE-OI
.. OF INIJE8 NW.ATION INtWATION .. OF INtW. NW.ATIOII .. OF TOrM.
TION ECHt " HAZARD TIOII ECHt tINOE8nOII ECHt
...... '.020 "_-07 f. f'" 7. fOE-07 '.71"
..~ '.OIf I.IIE.... ".~ 8...... 7.~
.. f." '.OOE" ...... ...1£.. 8. fft
'I."" U 1.41£"" ".Ift 1.2OE.. .......
... fN ..... I.NE"" 22,71.. 1.12£.. ..~
.. fft .... f.ME-07 ...... ..i'E.. ......
UN I."" 1._-07 ...... '...-07 f.""
....... '.a f.7IE" ...... f.." "Af"
f.."" 8...E.. f.."" 8.HE.. ,......
-------
APPENDIX D
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~~
.,SOLVENT SERVICE, INC.
1040 COMMERCIAL STREET. sum 101. SAN JOSE. CA 9S112
PH: (408) 4S3-6046 FAX: (408) 4S3-604'
'..
".," ~..-.,\" -, . -.." '.
~rv..~.:... .."..
. . .. ......
".July 16, 1990
Mr. Ron Gervason
Regional Water Quality Control
San Francisco Bay Region
1800 Harrison Street
suite 700
Oakland, California 94612
Re: Tentative Order and site cleanup Requirement.
for Solvent Service co., Inc., 1021 Berryessa Road,
San Jose, Santa Clara County
Board
~
JUL ~ H ~.,.' \. I
QUt...!.t!'! Cr~2:~ ~'~. , ,-
Dear Mr. Gervason:
Solvent Service ("SSI") wishes to take this opportunity to
provide the California,Regional Water Quality Control Board, San
Francisco Bay Region (the "Board"), with comments regarding the
above-captioned order (the "Order"). These comments are intended
to supplement our previous letter to you dated June 18, 1990 and
not supersede the comments therein. The following comments are
presented in the sequence in which they arise in the Order; this
organization is not intended to be an indication of the relative
significance of the comments.
FINDINGS.
1. Findina 1. paqe 1. Sentence one should be amended to:
more correctly reflect the purpose of the SSI facility. To :
accomplish this, the phrase "treating and reclaiming industrial'
solvents and corrosive liquids," should be deleted and replaced
with "waste treatment and recycling."
Sentence two should be amended such that it more accurately
re'flects the location of the site. To accomplish this, the
second sentence should be amended to read, "The site occupies 3.2
acres and is located approximately 10 miles southeast of San
Francisco Bay and approximately 1/3 mile southwest of the
confluence of Upper penitencia Creek and Coyote Creek. The site
is near the intersection of . . . ."
. The final sentence indicates that SSI has accepted
responsibility for the release.of the pollutants into the
subsurface and the associated cleanup. This is inaccurate to the
extent it applies to the "Commingled Plume." To remedy this, the
final sentence should be deleted and replaced with:
Pursuant to Health and Safety Code Sections 25356.l(c)
& (d), the discharger is the only identified
responsible party associated with the release of non-
petroleum related contaminants to the subsurface at
1
. -0-:'_".
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this location and has accepted responsibility tor the
cleanup of the site solely as it relates to non-
petroleum related contaminants. The discharger has not
assumed responsibility for the petroleum related
contaminants that form a plume along the site's
southwestern property line' (the "Petroleum Plume"),
which have migrated onto the site from the Chevron
property located across Berryessa Road. Further, the
discharger has not assumed responsibility for the VOCs,
if any, associated with the Petroleum Plume.
.2. Pin4ing 2. Paa. 1. Sentence three is inaccurate in its
dates for the analytical results and in the concentration of the
CIS-1,2-DCE. To correct these inaccuracies, the third sentence
should be amended to read, "Some of the chemicals detected most
frequently and in the highest concentrations in the groundwater,
based on analytical results from January 1987 through July 1989
(see attached map), are acetone at 19,000,000 parts per billion
(ppb), trichloroethylene (TCE) at 150,000 ppb, 1,1,1-TCA at
100,000 ppb, and C1S-1,2-OCE at 67,000 ppb."
3. Pin4ina 2. paa. 2. To clarify the type of sampling
that was completed in December of 1989, the word "unfiltered"
should be inserted between the words "onsite" and "sampling" in
the first sentence on page 2.
. 4. Pin4ing (~ paa. 4. The remediation activities are
expected to be tra~ferred to regulation under RCRA. To clarify
that the Board will remain the lead agency after this transfer
has occurred, the phrase "and under RCRA," should be added to t~e
last sentence.
5. Pin4ing 4. paa. 2. Since the site has never been
placed on the National Priorities List ("NPL"), the beginning of
the first sentence should be changed to read, "The site has been
proposed for inclusion on the "National priorities List. . . ,"
to clarify that the .ite i. not yet on the NPL.
. 6. PinaiDa 5. paq. 2 ana 3. As discussed in our June 18,
1990 letter to you and our comment on provisions 1.j-1.q
(excluding 1.k) below, SSI should not be held responsible for the
Petroleum Plume. Therefore, this finding should be deleted. If
the Board should choose to leave in finding 5, the following ~
changes should be made:
. The final sentence on page 2 indicates that hydrocarbon
contamination has been known to exist "onsite" since 1984. This
is true for the Chevron property, not 881. To correct this the
word "onsite" should be deleted and replaced with, "at the
Chevron site..
2
.. . ,'" . -
- .. .- 0...............'" -
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, ...
The final two sentences are inaccurate in that they assu~e
that VOCs are commingled with the Petroleum Plume; this has not
been proven. Additionally, the Petroleum Plume extends beyond
the Site to the northwest, not the southwest. To make these
sentences more accurate, the language should be amended to read,
"The HCs may be commingled with low levels of VOCs in this area.
Based on current data collected by 55I and Chevron, the HC plu~e
apparently continues beyond the 55I site to the northwest."
7. Pindinq I. paa. J. The alluvial material is
consistently interspersed with layers of marine clay. Therefore,
in sentence one, the word .sometimes" should be deleted.
The second paragraph refers to "A aquifer", the fourth
paragraph refers to "Zone DIE., these are inaccurate references
to the geological layers. The appropriate reference to the three
layers are Aquifer A, Zone SIC, and Aquifer DIE. These terms
should be used consistently throughout the Order.
The last sentence of the second paragraph is inaccurate in
its description of the width of the clay layer. To correct this,
the phrase "6 to 16 foot" should be amended to read "12 to 60
feet."
. The fourth paragraph, which describes Aquifer DIE, is
~misleading in that it does not indicate that Aquifer DIE is not
used for the domestic water supply in the vicinity of the site
and that it does not indicate that this Aquifer is hydraulically
separate from the other layers. To rectify this, the third
sentence in the fourth paragraph should be deleted and replaced
with, "Aquifer DIE is believed to be very permeable and is
hydraulically separate trom the other layers. The regional
domestic water supply is historically drawn from Aquifer DIE,
however, in the immediate vicinity of the site Aquifer DIE is not
used for such purposes."
The final sentence of this finding references a channel
deposit that is adjacent to Aquifer A yet is in a paragraph that
discusses Aquifer DIE. For clarity, this sentence should be
moved to the end of the second paragraph, which discusses
Aquifer A.
8. pindina 7. Pa9. J. The information reflected in the
first two sentences is not well documented. Therefore, these two
sentences should be deleted an~ replaced with the following
language, .Underground storage tanks used for solvent storage
spill control and waste solvent storage were removed in or about
1982. Adjacent soil was also excavated, however, this is not
well documented."
3
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9. pindina 7. Paa. 4. The last sentence in the first full
paragraph on page 4 should be amended by deleting the phrase,
"which has been expanded since 1984."
In discussing the treatment storage and disposal area in the
first full paragraph on page 4" the order fails to discuss that
the TSD area has been bermed and that operational procedures have
been changed to minimize the risk of additional contamination.
To correct this, the following language should be added to the
end of the first full paragraph on page 4, "Additional interim
remedial measures have included berming the treatment and storaqe
area and changing operational procedures to minimize risk of :
additional contamination."
The third and fourth sentences in the second full paragraph
on page 4 do not accurately reflect the process of treating the
water or its subsequent us.. To rectify this, the sentences
should be amended to read, "Extracted groundwater is being
treated by a biological treatment system, air stripping, and
carbon absorption. Treated water is used in the SSI cooling
towers and is subsequently discharged into the sanitary sewer
under authorization from the sanitary district."
10. Pindina 8. Paae 4. The final sentence in the second
paragraph refers to the "initial draft RI/FS Report," this should
be a reference to th~ "final draft RI/FS Report."
11. Pindina 8. Paae 5. The third full paragraph indicates
a need for additional investigative work to es~ablish background
levels for inorganic compounds. This investigative work is most
appropriately undertaken by the Board itself or some other
government agency and should not be the responsibility of S5I. '
The following language should be added to the end of the third
paragraph, "Such background levels shall be established by the
Board or other appropriate State agency."
12. Pindin9 I. Page ,. Subparagraph a refers to
groundwater extraction from both onsite and offsite aquifers. It
should be clarified that this reference is only to Aquifer A. To
. reflect this, the phrase .onsite aquifer.. in the first sentence
should be changed to "Aquifer A," and the second sentence in the
second paragraph should be amended to read, "Therefore extraction
from Aquifer A from offsit. wells may b. required. . . ."
13. pindina I. paa. 7. ~n subparagraph
to what the phrase "(less than 1ppm)" refer..
standard is set forth in RI/FS which is to be
Order, this parenthetical should be deleted.
subparagraph f adds the requirement of a deed restri~tion .
which would prohibit development of the site for resident1al use.
until certain cleanup goals are attained. This provis~on should
c it is unclear as
Given that this
adopted with this
4
... ...
-------
be deleted because it is an inappropriate method of ensuring the
protection of public health and safety. Public health and safety
concerns regarding future".land use are already comprehensively
dealt with by the California Environmental Quality Act (IICEQA").
CEQA sets forth specified procedures which will have to be
followed to obtain approval for any different future site use,
especiallY residential development. In addition, California law
provides specific protective mechanisms, such as Proposition 65
and Health and Safety Code Section 25359.7, to ensure that
appropriate disclosures are made to future users of the premises.
In light of existing regulatory controls, the proposed deed
restriction is inappropriate in that it establishes an
administrative overlay which will .be difficult to administer
because of the very vague standards set forth. Further, it is
questionable whether the Board has the authority to require that
such a deed restriction be r.corded.
14. ~in4ina 10. Paa. 7. The use of the parenthetical
"(toxic)- is unclear in that it appears to imply all non-
carcinogenic chemicals are toxic. For clarity, this
parenthetical should be deleted.
15. Pin4ina 10. Paa. 9 an4 Fin4ina 11. Paa. 9. Both
Findings 10 and 11 refer .to Aquifer A as a potential source of
drinking water. This assumption is unfounded and should be
removed from the Order. Aquifer A has not historically been us~d
in the region as a drinking water aquifer due to its proximity to
the .surface. This makes potential contamination highly probable
and for that reason alone Aquifer A is a poor potential drinking
water supply. Further, the TDS in Aquifer A is above 1,000 ppm.
Since sources for drinking water supplies should have TDS at 500
ppm CU.S. EPA Secondary MCL) or lower, even in the absence of .
contamination, Aquifer A is not suitable as a drinking water
source.
16. 7in4ina 11. Paa. 9. The second sentence in the second
paragraph refers to the maximum amount of chemicals allowed in
the groundwater. It should be clarified that the cleanup
objective refers to the maximum amount of "organic chemicals" in
the groundwater.
Subparagraph a refers to tha appropriate cleanup standard'
for phenol as being on. (1) microgram per liter. This is the L
state Action Level for tasta and odor. It is more appropriate t~
use a health based standard such as the EPA National Ambient
Water Quality criteria for Public Health C"WQC"). As such, the
standard tor phenol should be 35,000 micrograms per liter. This
requirement should be moved to Subparagraph e on page 10 so that.
it is grouped witb the other cleanup standards based on WQC. .
17. Pin4ina 11. Paa. 10. The Secondary U.S. MCL set forth.
for toluene in Subparagraph b is not a health based standard. A'
5
_." -.. .'
. .
'. .' '.~".' ..'
-------
.
health based standard 1s more appropriate for this cleanup.
Therefore, the U.S. MCL of 2000 micrograms per liter should be
used. Subparagraph b should be amended to read, "U.S. MCL values
for copper (1,300) zinc (5,000), and toluene (2,000)."
18. pin4inq 12. ~aa. 11.. To provide a mechanism for
changing the standards, the following language should be added to
the end of the first paragraph, "The discharger may request the
Board amend the standards or amended standards when it determines
that the standards or amended standards are not reasonably
attainable."
19. Pin41na 18. ~a9. 13. For reasons discussed above in
Paragraph 15, Aquifer A is unlikely to be used for the listed
beneficial uses of groundwater. Additionally, Zone B/C does not
have sufficient water to be appropriate for such uses and like
Aquifer A has TDS over 500 ppm. Therefore, it should be
clarified, that such existing and potential uses are only
applicable to Aquifer DIE. This can be accomplished by amending
the introductory phrase to read, "The existing and potential
beneficial uses of the groundwater in Aquifer DIE underlying and
edjacent to the facility include:"
S?ECIPICATIONS.
1. SD.clfleatloD 3. Paae 14. The concentration for phenol
should be changed to 3.5 and the concentration for toluene should
be changed to 2.0. The explanation for these changes can be
found in Paragraphs 16 and 17 in the discussion above addressing
the Findings.
PROVISIONS.
1. provision 1.b. Paae 15. The completion date for
provision 1.b. should be changed from October 31, 1990 to
November 31, 1990. This will allow SSI to compile additional
information prior to suhmjtting the report.
I
2. provision 1.8. ~aae 1.. provision 1.e. refers to Tas~
.C.l.c., the reference should be to Task C.l.d. "
. 3. provision 1.f. Paae 1.. The first sentence erroneously
infers that groundwater is being pumped from pits. To correct
this the words "and pit(8) " should be deleted from the first
sentence.
,-
4. provision 1.a. Paae 17. provision 1.g. refers to Task
C.l.e., the reference should be to Task C.l.f.
5. provision 1.h. paae 17. Paragraph 2 discusses what
will occur 1f safe drinking water levels cannot be achieved. ,"
Given that it has already been determined that such lev.ls cannot
6
- 0" ..~, .. .
-------
be achieved for certain chemicals and the natural TD5 cannot meet
the safe drinking water standard, the final sentence should be
deleted. ,
6. provisioD 1.i. Paa. 17. provision 1.i. allows the
Executive Officer to require an evaluation of how final plan and
cleanup standards would be affected as a result of changes in
information. The Executive Officer should not be allowed to
require such evaluations more than once every five (5) years.
The fOllowing lanquage should be added to provision 1.i., "The
Executive Officer shall not request such an evaluation more than
one (1) time during a five year period."
7. provisioD 1.k. Paae 18. It is unclear from the
organization of the Order that Provision 1.k. refers to the
downgradient VOC contamination and not to the Petroleum Plume.
To clarify this, this Provision should be moved above provision
1.j. Additionally, the phrase, "where VOCs have been
discovered," should be added to the end of the first sentence.
SSI requests that the completion date for Provision l.x. be
changed to February 30, 1991. SSI will then have an additional
round of groundwater sampling results and as such will be able to
provide a more effective work plan for remediation of the offsite
problem.
8. provisions" 1.1-1.a (excludina provision 1.k). Paaes 18
" throuah 20. As discussed in our June 18, 1990 letter, S5I
believes that work to be done on the Petroleum Plume should be
carried out by Chevron. SSI's reasons for this position include
that S5I has done all work to date to define the extent of the
petroleum contamination on its property which has been caused by
Chevron, Chevron's lack of initiative in addressing the problem
and the fact that Chevron is primarily or solely responsible for
the contamination. As such, we believe Provisions 1.j. through
1.q., with the exception of Provision l.k., should be deleted
from this Order. Should they not be deleted from the Order, 55I
believes it would be appropriate for the Board to assign primary
responsibility to Chevron for the work and assign 55I secondary
responsibility in case Chevron fails to meet its obligations.
Additionally, as stated in our June 18 letter, regardless of
responsibility, from a technical viewpoint only provisions l.j.
and 1.1. should be required at this time because of lack of
information concerning the nature, extent and origin of the
Petroleum Plume. Given the lack of certainty concerning this
issue, 55I believes it is not appropriate, at this time, to
address the substantive aspects of the Order as it applies to the
Petroleum Plume. However", SSI reserves the right to submit such
comments at a later date should they become necessary.
: :
7
. ".-
. ... -. ".-
-------
As discussed earlier, I believe that it is best for us to
arranqe a meetinq with the Board's leqal counsel, yourself, our
technical consultants and-our leqal counsel to discuss the issue
of the Petroleum Plume and any additional issues which may have:
been raised by these comment. which you feel are appropriate to
discuss with leqal counsel. We would appreciate it if you could
arranqe such a meetinq with your counsel later this week, in
order to allow maximum time to resolve any outstandinq issues.
I look forward to hearinq from you.
Very truly yours,
SOLVENT SERVICE CO., INC.
By- ~
. Sue edantham "'
SV
cc: David Abbott
Lawrence A. Coqan, Esq.
Mary Haber, Esq.
-
8
. .. . ~ .
. ". Oa"" 0#. .. -
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Sonla Clara Valley Water District
5750 AlMADEN EXPRESSWAY
SAN JOSE. CALIFORNIA 95118
TELEPHONE (.08) 265-2600
f~IMILf (.oB) 266-0271
AN AfFIRMAJIVE ACTION EMP1.OY£R
July 20. 1990
'UL 't
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QL~'~ r '7'/ ..-
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I ""'.: .'.. ~ 0. : I .
" ,
: ,..-
. .:~
Mr. Ron Gervason
Regional Water Quality Control Board
1800 Harrison Street. Room 700
Oakland. CA 94612
Dear Mr, Gervason:
Subject:
Comments on Final Clean Up Plan. Solvent Services. Inc.. San Jose. California
This letter presents our comments on Regional Water Quality Control Board's (RWQCS's) proposed final
cltan up plan and tentative order for soils and groundwater at the Solvent Services. Inc., site in San Jose.
In general, we are in concurrence with the plan using steam injection-vacuum extraction to clean up the
surficial soils and A-aquifer; this followed by I pump-and-treat clean up of the SIC zone.
However, we do have concerns regarding proposed clean up goals for existing or potential drinking water
aquifers. Consistent with our Board of DiredOr's position on clean up goals for similar sites. we urge
you to consider seninl loals for carcinolenic contaminants usinl the Carcinolenic Hazard Index
approach. As a clean up goal. this provides a more conservative approach when multiple carcinogenic
chemicals are present. We fully'understand that further remediation requirements would be evaluated
based on feasibility and risk assessment evaluations.
The following specific comments are related to interpretation of SIC zone contamination and potential
conduits between the shallow and deep aquifers. In the assessment of the hydroleologic consultant for
Solvent Services, Inc., the contamination of the BIC zone was caused by previous improper monitoring
well installation and construction. If this were the case, clean up of this zone through pump-and-treat
should be relatively rapid. However, if contamination were caused by chemicals seeping through the
intervening'aquitard to the BIC zone, clean up may take much longer as chemicals sorbed in the aquitard
would slowly continue to be desorbed and leached into the aquifer. Therefore, it is suggested that the
discharger evaluate the full ranle of remediation efforts that mipt be required.
With regard to potential conduits, Todd Engin~. in their January, 1990, report on Final RIIFS,
identified 280 wells within one-half mile radius of the site includinl 166 active monitoring wells, 2
cathodic protection wells, 45 destroyed or abandoned monitorinl wells, 15 production wells, and 38
destroyed production wells. Also Included in this total are an estimated 14 historical production wells
identified from old maps of the area. Thouah DO contamination have been detected in any of the 15
active production welJs, we are concerned about the possible 14 historical production wells, whose.
dispositions are uncenain. and have the potential for unquantifiabJe risks. Results of sampling and testing
under AS 1803 for nearby production welJs should be reviewed on a timeiy basis to moniior any potential
adverse effects by unknown abandoned wells as potential conduits between-the shallow aquifer zone and
the deep zone. .
. .. -- '..
- .~...., '. .' .
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Mr. Ron Gervason
2
Please call Tom Iwamura or myself at (408) 921~10 should you have any questions.
Sincerely,
~~~)~~~~
~
David J. Chesterman
Division Engineer
Groundwater Protection Division
~ '" ........ '. ...
July 20, 1990
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SENT BY: .
: 1- '-80 : .'8:02
.
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SAN RAD ~
SAN FRAN BAY;' 2
Dtpart"'t'" If HNhh Semce8
.-...t. .f eo\1f8rft18
Memorcndum
T.
. steven ~i~chi., Executiv. Offic.r
Re;ional water Quality Control Board
1800 Harr1.on 8t., Sult. '00
Oakland, CA '.'12
0at8 . July 31, 1110
"'ltltCt, Tentativ. order.
sit. Clean-up
Requirement.-
Inter.il/ siemen.
, Solvent Servlce.-
Proposed Supertund
Site.-Sant&Clara Cy
'""" ,
o
otfice ot nrlnkinlJ water
2151 ~8rkeley Way, .. ...
Berkeley, CA ,.704
1-571-21'0
o.
-.
On July 2", 1990 IU". stev. Mor.. of you Boare! requested
cl:.::i!1cation. and additlonal commente tro. the D8partm.n~ of
Health service. (1)0118) . Offlc. ot Drink1n, Wate~ (OrM) on the
Cl.anup R&quiram8nt.. of superfund .It.. in Santa c1ara Coun~y.
~he.e comment. are .upplamental to tho.. previou.ly sUbmitted to
~. Board in . ."0 elated July 11, 1910. W. have recently
co~pl.t.d review for 2 cl.anup .iU.' Int.rail/liemana (XIS)
an4 801 vent Sanice. Inc. (81%) . %na..uch .. oU g8neral
guidanc. Oft cl.anup '081. fo~ cle.nup of contaminated
Vroundwatar. involving dome. tic vat.r l..ue. 1. the .&ma, v. hay.
cembined ~. two .ite. 1ft our re.pon.. ...0.. 70~ ca..-.p.clfic
comm.n~. on the di.cu..iona ot cleanup alternativ.., Carcinogen
HalareS %ndex (CHI), and zol.k calculation. tor tha %/8 and SSI
.ite., p1e... Z'efa~ to Appan4ice. A and 8, ~e.p.ctiv81r.
1)OHS-ODW - cLEANUP GOM.I
A. .~ate4 1ft our JUly 11, 19.0 ...0, for the purpo.. of ..ttinl
cleanup 90&18 for contaminated groundwatar8 d8.1vnated al
eScme.tlc watar .upply .C!)urca, the foJ,lowin, a1:'. the lJUic!ini
principle. u..11 ~ the Off1ce of Drinklng Wat8~. .
1. ~a total oancer rl.Jt. leval do.. not axc..d 10.1, or I
. .
. I. carc:lnovenia Ba.ad Ind.x do.. ftot 8xcee4 1.0, an4
~. 110 oon~aa1nant8 exc.ed KCL oZ' AL, vhe~. applicable.
'!'he pew. critaria 8hou14 H followad vh.nner it i..
t8chnclc;ically and .conomlcally tea.1b18 1ft~. remediation ot
centamin.teeS vroun4wat8Z' aquiter. foZ' ~8 protectlo1i of th.ir
beneficial u... 1nvolv1nv elom..~io con.umptioni
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SENT BY:
; 1- '-10 : '1:02 ;
SAN RAD LAI-t
SAN FRAN BAY:' 3
.
stevan.ltitch1e
Pa.g~ a
July 31, 1..0
REGIONAL BOARD (D) - PROPOSED CIJWNP tZVZI.I
w. acknowled;e the metho4 an4 procedur.. u.e4 by the Boar4 atat!
for ~erivin9 cl.anup level. fo~ superfun4 .ite.. The procedure.
are detaile4 1ft the "Guidanc. Document fo~ th. Dev.lopment ot
Heal ~-8ase4 aemecSial Clean-up Level. to~ the South BaY Kul ti-
.ite cooperative superfund 'roqram" (aWQCS, June 20, lttO). The
b&81. for ~1. fJ\11cSance document .t.mII froa the EJ'A'. National
oil aroeS Hazardou. Subatanc.. POllution contin;ency Plan, 1910,
and the Ri.k A...ssment cuidanc. For superfun4, HU=an Health Ri.k
A.s.Bement, ZPA Reiion IX R.co~.ndat10n., 118' (Interim rinal).
We .1.0 acknowl.die tha~ the.aethoe! u..4 by the Boar4 .taff va.
dev.loped primarily ~o han4le cleanup of superfund .ite.. 'l'b.
D\ethoc! eSo.. not adequat.ly addre.. .p.cific concern. on the
prot.c~ion of aftec:te4 ,roundwat.rs .. dom.atio va~.Z' aupply
(JourcJ...
w. must 8180 aeS4 that 1ft the dev.lopment of the Board'. .cuieSance
Document-, the Departman~ va. not 1nform.4 about it or .ade part
of ita p.er revlew prior to finalizat.ion.
Con.equentlY, the oleanup level. pre.cribe4 tor ~o~ th8 1/1 ane!
&SI .ite. prOP08ed in the T8ntative O~eS8r. lnvolv8 . mu~ higher
t.otal canc.~ ri8k than the Departm8nt'. recommend.4 10- level.
In addition, u.lft9 ~. CarcinOf.n Hazard IneSex .pproach, ~e.e
contaminated .It.. .tte~ r..eAia~ioft 0~er.4 ~y the Boar4, will
still have haza~ in41ca. aany ~1... higha1" t-han 1.0.
W8 are oppo..4 ~o ~e8e oleanQp level. .. they e~e axc...ively
high an4 40 no~ ade~at8ly protect the 1T0uneSwateZ". ~.n8fio1.l
u... .. dome.tic .upply 80uroaa.
cLDNUP FEASI8ILIft
On the 1..u. of oleanup t8a.ibili~y, Board .ta!f ln4icate4 durin9
the ~uly 24 meetin, that, pu~8uant to th. Board'. Resolution Ho.
la-ll, the Non-de9ra4atioD 'olloy, the al/'. ooneSuct.e! ~y both
%/1 and 88% included the .valuation of cleanup to ~non-
eS.t.8ct.abl.- or "back;roun48 leV.l.. ft. 8081'4 than .a48 the
Oet.arminatioD that thi. alternativ8 would be .conomicallY anA
technically int.a8i~1.. We aP'e. t.ba~ i~ would "e impractical to
clean up to non-det.ot.~l. level.. w. .1.0 reque.t the Board to
r.-exam1n. the f8..1b111ty of . cl.anup alternative aneS to
1"acon8id81" the ..tting of cl.anup requir81Dent.8 to a aore health
prot.ect,ive lavel frs the .tandpoint of prot8ction of dom..t.io :
water quality.
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rt~NT 8Y:
'- : 1- '-80 : 18:01 ;
SAN RAe LAB-
SAN FRAN BAY:' ,
steven Ritchi.
Pafle :I'
J'uly 31, 1"0
CALIFORNIA IAPI DRINKINCJ WATER ACT-RECOMMENDED PUBLIC H!AIJ1'H
LEVELS CRPHLa)
In acSc!ition, ve «!raw your attention to .ect10n 4023 of t.he
Calitornia Sate Drinkin; Water Act on Recommended PUblio Health
Level. (RPm..). A copy of the Act. i8 encl0..d for your
roforenc.. Th. Department. i. currentl~ 1ft the proc... ot:
promul;at1nq the RPHI.a maneSated by ou~ Drinki"9 Water Proqram.
RPHLa-.re health-ba.ec! ;oal. .et. to furt.he~ reduce contaminant.
in cSome.tic water .upplle. to b.low the MCr.- For carcinogenic
compounc!8, the RPHLa will ). .et at the 10- cancer rl.k lev.l.
'rhe.. RPHLs will be appli84 ~o all dome.tl0 wat.r .ouree..
Water 8uppli8ra .erving 10,000 service connection. or more vill
be required to .ubm1t. 8 Water Quality Improvement. Plan (WQIP) to
the Department demonatratlng th. f.asibl1lty of providln;
a441tional treatment .. w811 a. monltor1n; oontrol 1ft order to
m.et t.he RPH1.8 in both their .xi.t.in; .. w.l1 .. new water
."urce..
II.
-
In ....ne., ~. WQ%P can be vlewed a. a parall.l document a. the
Ramedial Investigation /7e.s1bility Study (RI/FS) required ot the
respon8ible party(le.) by the Board. The water 8uppliera will be
char;.c! w1th the r'.f.0n81bl11tl.. in meetin, aor. con..rvative
an4 heal~ protegt V8 wat~ quality .tandard. than those
require4 of r..pon8ible parti.. in th. cl.anup ot t.he
irounc1water. w. h.r~ advi.. the BoareS of thl. .er1ou.
potential ahortcomin; in impo.1n; 1... than acceptable or health
proteotiv. rem.c!1ation l.v.l. in the affectelS ;rounc1wat.r
.~1t.r. ua.4 tor dome.~lc .upply .ourc..
W. 'wouleS 81.0 like to polnt out that 1ft accor4anc. with the EPl'.
National contingency Plan, the RPHLs, when promulg-at.d, vill
become the ARAR.. The RPHI.8 are curr.ntl~ in developmen~. We
will ke.p t.he Board lntormelS of 811 adopted RPKL8 in i:he future.
Thank you for your con.lderat.lon on thl. Important 1..ue relatin;
water supply quality. W. ar. hopeful that w. can work ;jointly t.o
resolve this proble.. w. vil1 ba availabl. 'to further c51.cu..
thi. 1a8ua at. your request or. )'ou may have que8tlona w. can
an.wer by phone. Plea.. 40 not h..itat. to contaot .. at (415)
540-21'0.
AttDdmant.8
OCI Se. next ,.,.
~s.~
Catherlne I. t.iD9, ..8.
District Engin.er
Monteray Di.tr1Gt
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SENT BY:
; 8- '-10 ; '8:04 ;
SAN RAD LAB-
Steven Ri~ch1.
Page 4
.n~l). :;~, 19tO
co:
Santa Clara Countr Health Department
santa Clara Valley Water District
Santa Clara County Water Retailer.
CWS-Lc. Alto.
Ci tr ot CUp.~lfto
City of Cilrcw
c1tr ot Kilpita.
City of Horgan R111
Ci tr of Mountaift View
City of 'al0 Alto
C1 tr ot Ian .10..
city of Santa Clara
ei ty of Sunnyvale
Great Oaka Water co=panr
. San Jo.. Water Company
stanford univ.r..1t~
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SAN FRAN BAY:' 5
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SENT BV:
: 1- 1-80 : 11:0' :
SAN HAD LA&-
SAN FRAN BAY;' e
steven Ritchl.
pa;e 5
~u;'t :'1, 199O
APPENDIX AI IHTERSI~SIEKEN8 SUPERFUND 81'1'1
A. Cleanup l.vel.
The pr=po..4 cleanup level. prescribeeS for the I/8 -ite con~ained
in ~e Tentative Orde~ are the ARAR.C- MCL) to~ a11 ~. chemlcals
in a11 of ~e A- , B- aneS C- lone .~if.r..
A. pre.ented by Mr. Wolfen4an using the ri.k calcula~ion., the
cleanup of PCB and TCI to XCI. in the A- and B- Zone aquifsrs
would result 1n a ~o~al ri.k of 3.8 x 10-1. Thi. i. 3.8 time.
higher than the 10-1 leval recommendecS by the Departmen~ ot
Health Service.. V.1n9 the DOHS CHI approach for 2 caroinoqans
at MCL, it would have an index of 2.0, twic. that recommended by
DOHS. How.var, a. statad in our July 11 memo, the A- an4 B-
"O~.. are consieSered non-domestic supply Ion.. OUr cleanup voal.
would not b. applicabl. 1ft thi. ca.e.
In tha e- lone aquifer, Hr. Woltenden pointaeS ou~ ~a~ ~e VOc.
currently 4etected include II ppb ot TCI and 1 ppb ot 1,1-DeE.
S1nc. DCB 1. con81c!eraeS a. a non-carcinogen, only TCE 18 of
concern 1n thi. particular aquifer. Tha proposed cleanup to
cSrinkin; vater .tandard tor TCB would ~. acceptabla from.
cSomes~io .upply standpoint bacaus. only a sin9l. carcinogenic
chemical 18 involved 1n thi. ca... Also, a. discus.ed durin; the
3uly 2., 1990 meetin" the proposed cleanup to KCL for TCE at .
much higher concentration than that of DCE would at the same ~im.
brin; the DCa to very 1011 01:' l'on-det8ctable level, a.sumin9
comparable ~emovability of both TCI and DCB in the aquitar. Wa
aqree with thi8. In thi8 ca.., we suq;U..~ that it would b. more
appropriate tOl:' the Board ~o communicate the "actual. total
canoea:' rle1c axpectecS from the remecU.ation rather ~an the risk
calculated w1th the a.sumptlon that all of the cham1cal. are a~
MCL or ARAR8 level..
B.
Cleanup alternativ..
The .t.a.1blllty of ol..nup to drinking vatar .~an4ards tor
chemical. in all of the ~hre.. .ballow aquifar. A-, I- and c-
Zon.. I. ba.ael on the propo.e4 remediation plan of extraoting
con~am1nat..d. water onl,. from the A- and B- lone aczu1fan. .0
qroundwater extraction or remediation i. currently prcpo8.4 tor
the c- Ion. aquif.r. Tha qroundwatel:' mOCS.l u..d ~ ~e Board
predict. an .upwareS flow ot contaminated water tro. c- Zena
aquifer to the upper A- and a- Zone aquit.r.. TIs. modal for '.
th1. cleanup alternative 81.0 project. to . 4S-y.ar period of
remediation. Thi. appear. to !). an extr..al)' lon; and anarvY
intensive ta.t. .'
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SENT BY:
; 1- '-10 ;" '8:05 ;
Steven Ri tchl. .
'&ge .
.7\111 )1, 1"0
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SAN RAD LA8-t
SAN FRAN BAY;' ,
We que.tion the validity ot the" cleanup plan which doea not
include. 4ireot remediation plan fo~ c- Zona aquifer, sinca this
ia 'the moat vulnarable &one with reapect to domestic water
8upply. A8 diaouI.ed previously, the c- Zone aquifer 1s an
exi8tinq dom.at!c water lupply source fo~ I=all Iystem welll,
and 11 &1.0 the immediate link to the deepe~ aquifere, which ie
the primary .ouree tor moat ct large wateZ' .y.te_.
The Board should exaalna the faalib11ity of direct ax'traction
from the C aquite!'. This 00\114 be. more cOlt-effective an4
ti:e- effioient alternative toZ' the overall cl.anup prc;ram a't
%/8.
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r:~NT BY: .
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SAN RAE) LAB-
S~ FRAN BAY:' 8
Btovcn° Ritch1.
P..q8 '7
July 31, 1110
APPENDIX Ba
SOLVENT SDVICZI INC. S'OP!RFtJND 81'1'8
A.
Back;rouncl
~e 881 .It. involv.. mUltlple cbemloal. whlCh have
ccntaminatecS the A. BIC, and D/E a~lt.r., both on- ancS ott-
aite. The vreate.t extent of contamination i. tft ~e upper
A and B/C a~it.r.. The '0/. aquiter i. an exi.tin; cSom..tic
vater .upply .ouro.. Within on. .11. racSiu. trom the eit.,
there are 2 existiftg 4ome.tla vater .upply well. drawinv
fro. the D/W all'llf..
The carcinOfen1a chemical. of concern ar. (I) I Ar.enic,
tenzane, Vinyl Chlor14., 1, I-DCA, Hethylen. Chlorid., PCZ,
TCE, Cblorofor.a.
~e non-carclno;enla chemical. of aoncem ar. (1.) I
Acetone, 2-Butanon., l,2-DCB, Ci.-l,2-DCl, 1,1-DCl, Tran.-
1,2-DCI, Ethylbenlen., rreon-113, 4-Xath-2-Pent., Nickel,
Phenol, 1,1,1-TCA, Toluana, xylan..
B.
Cleanup level.
BCRI . 0.11 tor noncarclnoiaft8.
Total cancer Jiak lnolu4in; Ar.enie . t.I' x 10.t
A8 .hewn, the oleanup l.vel. propo.acS ln the Tentative Or~er
by the BoareS tor th. 88% .~. involve . .uch bigher (.,.
tim..) cancer ri.k than 10-. In addition, apply in; the
DOHS CHI approaob ra.ult. in a Halazrd In4ex of ?1.
b .tatad in our iJuly 11 .e.o, the interactlve ettect. ot
th. differant component toxicant. in the mixtur.. are not
well defined an4 un~.r.to04. w. ar. vreatly concerned about
i:ha adcU.tional health r1.k. and hazard. a..ociated v1t.b
~lxtura. of chemical.. w. aiain reque.t the Board to re-
examina t:h. fea.1bllity of additional remediation mea.ura.
and to racon.le1al" lowerin11 ~. claanup l.vel. to . .ore
health prot.ativ. l.val.
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. SENT IY:
; 1- '-10 ;.'8:08 ;
SAN HAD L~
SAN FRAN BAY" 8
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Stavan Ritchi.
pa;. ".
Julf '1, 1110
c.
Clesnup alternativ..
~e extent of the contamination and the Characterization ot
the plum. ott-aita wen not cl.ar from the ~.ntat1va
Or4er. Howaver, i~ i. claar that there will be no direct
remediation measUZ'. taken. Inatead, the remediation of
conta~ination off-site 1. propoa.d a. a "contlngancy. plan.
It 4epen4. .0181y on the on-.lta containm.n~ proce... . Thia
proce.. involve. the operation at J extraction trench.. to
"pull bacJc" anel reeovaZ'. contaminant. fZ'oa tha groundwater
off-.ite. The OZ'4aZ' , on the other hanel, .pecifically.
stat.. tha~ the 8ffectivana.. of .uch propo..d continiency
plan has not baen demcnatrated by currant data. Is thara
anethar centingane,r pllft 1n wait 1n oa.. the propoae4 one
tail.'
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. .,. 26' 8271 -.,. I,':'..L.E' I.I:aTECI
~..
Salia Oara \bBay Wt:JM ~
5750 AlMADEN EXPt£SSWAY
SAN JOSE. CALIFORNIA 9Sn8
UlEPHON£ (408) 2~2600
flt.CSlMlLE (408) 266.0271
AN AffllMATlV! ~ION (M~OI1I
AUl\llt 3, 1990
Mr. SteVe Mor..
Reatonal WIt8r Qulllt)' Conuol Board
1800 HarrlJoD Street. Room 700
OakIaoct. CA 946 J 2
DW' Mt. Mone:
Subject:
Comments on Inter,II/Siemens and Solvent Services Clelm Up Plana
In previous ~mmenta transmJtted to your sutrbf letters dated Julf 13, 1990, and Jut)' 20. 1990. for the
intenD/Siemens aDd Solvent Services lites respectively, we have suggested that the RoalonaJ Board apply
the Cu,ino,enic Hawd Jnd~ approach for lcutna dean up level.
In response to discussions with you It a moetlna on July~, 1990, and subsequent disC\WloDi with the
Department of Health Services, I ..ree that fOur methodology (or computln. cleaa up lev,t. may be
arpropriate. The District remains concerned, however, with the recommended l0ala raultJna in 1()4 rlat
level. (or carciDolenlc compound.. It II my underscandln, that tonhcomlna R~mmendod Public Health
Levels (RPHLOa) w1ll be baaed OD 11~ can"" rlst. As. result. the recommended ,oal could advltle1y
impact the future use of that portion of the .roundwaLer bulu. .
Thereforo. we Uf'Je you to require I remediation plan wblch will achieve I total cancer risk levd of 1~
ia order to assure unlDhlbl1ed use of the lfOuadwlter buln
,
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fu°l 19 '90 16: Z7
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P:kJ
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SOLVENT SERVICE, INC.
J()IO COMMERCAL SnEET. St1lTE 101, SAN JOSE. CA "112
PH: (408) ~ PAX: (408) 45)4)4'
June l' 1090
S0748-9O()IJ(X)
Mr. Ron Ocrvasnn
Rcp,na.l W~'er Q~fttit) Control BuMrd
SAn Fnancisen Ruy RcSiod
1IWO Hourison ~rrc&:t. Suite 100
OitkJaM. OIlilarn'" eJ4612
Rc: SoJvcnt Serv~ Inc. - TCD~ Order
Dr.", Mr. Ocrwson:
Thr.. lc:ucr is in reference 10 me "'Nutic;;c ar TraMminal of Site CteAD\lp
ItC'iuircmtlUS fur Solvent $cIVIc.:, Inc., 1021 8crry~&t ROc~, SAn Jgac, ColiCnrniA:
eJ4k;C1 June 4, tWO (the '"Nork.-ej. The Nudecs QlllhalUI Lite tentative or~er ("Order") 01
,he Rcaiomtl Wfn~r QualitY Cununl 808rd ("RWQCB"') and rcrcrC:lI~ ilte IUlFS #I)d
the RAP (nr rh~ Solvent $eMC:C. In~ ("SSI") luc:iJil)'. The Nodce Spec:irI~1 . pubJk
c.~tmmcm pcriod Crnm June 20 . July 20, 1990, roUuwinl ,.dopOon otlhe tc:nl»tiYe
(Jr~, 'h~ RIIFS ancJ 'hi: RAP by Ihe RWQCB At Its Dcarinl on JUlie 20 lOt 'he
rlolrpase of Initjntins the put)UC COin anent pt~ AUI~'nl otber Ihmp, ProviJlnna C.l.j.
through C.Lq. a( the Ord~r rcqu1tc tlus' 551 tab eqwd rC5ponsibilhy with Chevron
U.s.A. Int. ("ChevrOn-) tur the U1vesliCltioD aan&l tk:w1ulJ ut wut&ulUlal1" 1&\ WNat is
referred to in Ihe Order MS the -QJlIIII.;tJp:d plume arc." (m IJUs )ellet, .uch plum&.:
W'cu '" referred 10 as the: 8ChevtM PlWDe" Ac:enrdlna co PWUna 5 cnlhc Orckr, tbe:
Chevron Plume b J~'nccJ a10l1, the souchweal S.~I aire buuAdal) alld perhaps bqond
thaI: hnund:uy to rile ~.nhw~ ww iI Y.li f.4 a jl()undW8Cer plumc ut dissolvcd ar.d
separ.uc:.phCtK byeJrncarbons from OJcvrnnt. nearby CUel ~uibutinn rac:JU&1 81 1020
Berryeaa Road. AccnrdlnB U) f'JftdJna '. the hydrucartJuns in the CheYluu Plume arc
can\minslcd with Iuw 1cYc1s 0( Voc..
Generally Sbltcd, 5:51 obJcCtS CD bel. hchJ jwml, and eqUAlly rc:sponaiblc with
Chevrnn for the ('"hewon Plume. SSf cunlCnc1Ii dUal it .lwukJ OOt be classified as .
dJ.~barlcr rc:pr&ling the Cbevron PlulDC. w. ad.Cl.aat;vcly. that at most ir ahouJd be 0
held seC:OIWuiJy Ilab~ tot me ChcYrnn Plume. 551 Mhcr &lbJ&:e:18 tu ihc CAICUli.e
scnpe at che Ordcr liS il relares ro tbc Chev,run Plume. 1& II ptemArure 10 Clt.bfilll a
(uU J(hedu1e (or 1hc inveslisation and final ,~nup at the Chevron Plume. Su~""iiial
tunhet ctwacler1zatlnn of lbe exlent or the Oaa,,,," Plume appeAl" 10 be requited
prior to establish in. aiuch . ICbeduJe.
SSI and it. "yCMICOIUJlcal conau1taanL, ~.kJ KcJU1 Tndd COnluhiDa Qn;inecrl,
be. rrU&J~ En&iMe~ hcUcYC that 1& II pIflCftt'Y un\:led wbcLher the SSI ,I&c II a
sour" of tht! VOCs IhItI.rc rrescntlD the cn~run PJuwc. TOdd EngineCR nOlCS
&!Un the Chevron Plume mAY he.. completcly &J~li..c:& pJwno (rum the solven.. plume
i
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1\.1'1 18 '90 16:28 ., ... ~..
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"."',- .. ,~.ioCI..c&~~w r~ .,,-,'1-. ~..
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June 1~ 1990
'aac2
("Solvent Plume") whieh orlglmata trOD\ \he SSIllIe ~ wh1c:h is \leaSt With in \M
. RAP. "1berc in fHCt may be ;g commJnllina- U SSf .... not caused 01 contributed to
me Chevron Plume, ic is DOt 1& cJia:ba1lcr aDd should nut be required co iavcAt~lutt: or
remedi:ue such conram1nadon. The WaI,er Code ducA .1Ot pmvide that an owner 01
npcJ'810r uf property II a dlsebarl~r merely bc:CUUM: itS prnperty overlies cunt~minated
Jfoundw4ttcr.
Given Uun, at present, Chevron Js the nnl1 ,--un.:Jusivcl)' klCDtlCicd cnnrribu&or tn
use (;hevrun Plume, CbcMUn, DOt 551, shoukJ mure rull)' char.cterizc the Chevron
Plume. Accordingly, 8' thiS time. SSI shuu~ nut be clauirted ., a dlschuzer in regard
10 the Chewon Plume.
Evc:n ussumina for &he sako or araumcnt.1wt SSI .. responsible for IOme or all
of cbc VOC. Ihat Ire presem in lbe Chevron Pluue, a,tVroo should be held prinwily
UJibie and at mosc SS! should be helc.lleCOndarUy UabJc fUI the ulva&ipLlol1 and
remediation c.\f thas Chc:vroD Plume. A1I cxp1Wuc~ .nn.-e fuD)' below, the rcunna for chi»
""8Kn&ia'1y are three-told: .
(1)
UDder the drewu~~s, ample pr"cdczn e&itts to auilft ICCOndMl')'
Jiabway to SSI:
(2)
k Is unc:eruain wheLhet, ud 10 what ateDt, SSI MI ~lulibulCd 10 the
Chevron Plume; and .
(3)
ill the ,-VWH: at III InvcstJplion of Q)DtamiDatiOn ori;inatina (rom .he SSI
lite, 551 bu a1ready conduCted mueb iDvatfptlun uC the OM:YIUU Plume.
whercu ChevMn has done Bale iD chis reprd.
Pbl, SSJ 11 inrunllc:d bJ ItS 1aw1en that there is ample p'~nt lor asaipinS
secondary IiabWty to 55! under cJrcumstances such as these. A recent RWQCB W~I',
No. 89-086, wh1d\ letS lite cleanup mtuJRmleli1s tw the wte! Malnetics/Mic;ru Ster.
tedcrul Supcrfu.MI wac w Sau&a Cata, prcwfdc:. apcciaDr strOnS prcc:cdCllt far
awpmenc or primary 1i4bDJC11O CbcMIm aftd secaDdary ~billlY to $Sf. 11ac C:WUc&t
or thai OJ'eIer is IIIiJdna1y similAr to die CODtaC or the proposed Order Inwmnl SSI.
In the Intel MalnctiCIIM1em Siorale maner.lor wblch the RWOCB ..rvu u lead
18F11CJ, Inlel Maanelkl ("'lntelj C:Mducled IUbluinclaal investlp&ioa and rclllcdialiun
activities in defiD.in, and dcunina up ItS solvent plume. In the course uf ill
invatiptian. Intel disccwercd tMl the uppadient Micro StntlJC lICe appcar.d tft be a
source ut the eanramlnadOD, III well. Due .ppIIlcu'b to tlac IW»UlD&M&1 -ai-k alread)'
-~
~"'.1IU8.0I ~".~
...
-------
P.4/7
----
.1U'I 18 '90 16: 2S
-. . . _. -.. . ... '.~. .:: -" . ..,. ..., t .
,.
,.,
June 18. 1990
Pap 3
~rfotmcd by Intel, the I'8udcy of work performed by Micro SLor"e aNt by the gwner
of tbe Micro StOf.. site (KCItI), and the SUhltantt.&IIJropcss that 1ntel had made In
dealing with its contaminatiol't the RWQCB assJgnccJ P'Uua'Y rc:spoftSihiU1Y to Micro
St()raaC and KClllto conduct tbe ACXt r~ of the cJcamup, and aaUowcd 1"1-=1 and it.
Jamdlntd &0 IISSUWC secondltry respuDlibUiI)' 114'''-
f'W1her precedent IS found In dec1l1cms ot Ihe SUite Waler Resources Conrrol
Boar~ (the "Stale Snarer). which have uslped secondaJ} UabilUy In landlords where
Icnanu whu caused Ibe dJSCharae aarc avallablc _Ad capable of clcanina up the
c:onuunination. ~ e It nf e', ,i
Order No. WQ 89-12; In the ~Hn~ nf the P~lftion or 'rudcn'iji! In5uranc:c: Camp''''
~ Order No. WQ 2f7-6; h 8 Ii V 100 , Order
No. WQ K6-18. In each of tMse decisions the Stale Board considered the ability of
the tenant to ~'ean up the CMtamJnadnn, die IbWtJ or the JandJard 10 control lhe ~
property at lhe rime of disehaarae (such a. 10 haYC .ull".cient cunuol ta prevent the
discharge). .nd the JandJurd's role in Ihe dilcbarp af tbe wasu:. In &hJs case, (J)
Chevron is aavailAbJe, (2) Chevron bas me ftnancial ..biJi'YIUId ,"Mical expertise 10
cany out the remediation, (3) thus far Chewon haS complied wltb fU own RWOCB
nrder to invQtipte and rcmedi.ue che prOblem. (4) SSI did IIUI have any contrQJ over
Chevron such that it could have pmcnced the probl~m, und (~) SSI did nul hitvc . '
rolc In the tJischarge or 1he: p=ttulcUUI ptoductl. M such, rairness nDd preeeden&
dieta%e &hat me RWOCB shoUld assign' ptimMry J~ill'110 Chevron IInd ftl mas"
SC&:U~ Ji"bill1,y &0 SSI fOt the ~roll Plume.
Secand, 551'1 wDtribulJon. " amy. 10 the OICVI'OU Plume appccJ 10 be minor ill
relation tu tbe conrtJbutjun nf Chevron. 1D aha Cbc:V&UU Plume, the maximum Chemical
conccntraE1ons fU\Jnd fm total voIHtile Orpnic cumpouncss (VOC-5) (606.9 ppm in 1986)
and maximum totaJ VOW~ hydracarbans (TVH) (12.000,000 "pm In (988) in
manituring wen 3M ditfer by several urden of map'I&aJc. The VOC'I, which aaJw
include vOlatile hyili'acatbons, rcprcssenl lea duan 0,05'5 or Ibe conUamiD81liun bJ
cnncenuation. A cunory review nf ulher monJlOltfta weD COQuul1inatlnn (indudiDa ,he
TICs) aJong the soutbwest perimeter indicate a ra"p of 2416 w ,,, by conccnlt'cttjun (If
VOC compnnents with respect 10 plUtinc ",ullfIOUCnts. 1bc arca of the entire:
O1evron PJume wJcbin Ihe 100 ppb .ocaJ paoUnc Jw.c:un&;ciluaUou enneniii' (oll/O!f IJIc
Cb~YJ'Dn lite) is eSlfmaled U) be '.4 acreS. 11w Cbevruo Plume alon, &he touthwcal .
perimelCf of $SI reprcscnb IIn area ot apptnxlmaleJy 0.9 .era w 16.696 of the IOtMJ
i&1a nr l.'bevroD cnntamination. Snlvent commlnalina !rom Cb8 SSI si&c, Jrlc uisb,
. would represent IcsI thallL 0.9 acres. For compUSloD, th~ SSI Solvenl Ptwnc is '
estimMted 10 coYer lID area or 1.6 ac:n:s enclasJns'me 10 ppb IONent contO\ir inacrvat
"..,.. )I ...,..aGUMa .... .u..
--
-------
JI.1i 18 '90 16: 29 .-..
-..
-- ~.
.. - ..... - . ''''.'''' ~ . ....t.\ . .s..... . -''. ....1<
P.5/7
-..
.... .
..
>-
Jaane l' 1990
PaltS .. 0
1berd'nre, T~d EnJincefl bcUcve& lbat IOtVents luwacl aloDi the southwest perimeter
arc insiSnifJQ&Dt relative 10 the CbeYrOD PI~ and thai aulYeot concentrations wUI plAy
a minor 1,'lc in &he final c:1c.anup/remcdialloD wort. As 5W:h, Chevron should assume
primaJy responsibility for \be Investisation aDd remediation of Ihe Chc..-vron Plume.
Third. in tbe course of charaacrizlnlll1 nWD U&C and Ihe off-sitc. mi,rati"l\ of
the Solvent Plume, SSI bas done II luhslUdaJ IUI1QUAC at work in invcstipunl the
Chevron Plume. A$ finding' of the Order DOles, it Wad SSI, .am CbcYron, that fint
~tred the t:hcvrCft Plume bueadl Ihe SSlIJw. SSI J... heeD .,,",ely invc:adpdn.
Its concaminatioD prot)tem .ince about Jta. Cbcvron.. tlnl report reprdiftllbc
Chmon Plume was 1\01 submitted undl MI)' 1989, cv~n &JIuuaJ' subaurUcc peuoJcum
contarmnation was known to exist at the Qe\lron Ille II ~r11 IS 1983 (v~rious lettcrs
!tom me R WQC;a. 1916). The amss disptrfty belween the wurlL conducted to date by
SS1 and Cheyron js well shown in t.h& actaehmeni:' enlfdcd "Schedule of Wurk
Performed.. Moreovu, tbe PO'OD. 5trat.ipaph)'. and puhydtoSosY of the Chevron
PJum~ exlslina aIonS the sourhwesr perimeter of &be 551 jUe have been weD deuued by
SSI witbin the put sewral years ('t"udd EnJinccr.. Ma11988). Subsurface ~mcrWur8ai 0
and chemical charw:terwuion of tbe Charon Plume .luul &JtelOUthWQl perimctCl uf
the ~I aite havc as.o been weD denned by the ,tr()rb uC 551 .nd ill cocsultant. In
addition. valuable site specific: aeu1uH1. aeOb)'druktIY. III..,) aonchcmic:a1 informadoD
cu!Jc:ctcd from aDd tonr (he SSI.itc CAn now been IIpplicd 10 Other .djlu;cJI& lites.
OweD the Kmounl of wurk SSf has perfurmed in hwesdptinl the Chevron Plumc &0
date, an~ given rhe piucny of wort pcrfurme&J '" Chcvran. It II oDly apprnpira&C \hac
Chevron atDume primary r~ponsibDIIY fur any ackSltJorud wurk rcpnJill~ Lbc Chevron
Plume.
Also, based on ssr. priur experience- in 8ttcmpWIJ 10 oblaln inturmatJon (rom
Chevron rc:prclina Chcvron.s investlptJuD activities uDd diat~ SSI aut1cipAtes thaI ic will
be Yel)' difficult 10 pin Chevrou.s 11m,,, euupc:lllliOJl in conducdna any required join,
actMUes. As currently "rafted, rbe Orc.Icr 1N11 in 61" Impede. namer than promote,
pruarCili ha dealinl wi\h 1hc O\evron Plwno.
U the R WQCB believes that, cwsnu, ~ w1aa\ SSf baa uraed. same dcpce 0'
Uabmcy »houfd attach to ssr 81 IbJI came r.J8rdiDa the O8I:VIOU Plw"c. che: toresnin,
factors and precedent provk1e ample lCaI()D W lID"'., at &n06t, Kcondary liability to
SSI auad 10 assip priIDarJ liabill!)' 10 Cbevroa.
WhoUy apan from the issue at rapunslbnil1 tor the: Oacvron Mume, the Order,
I8S preacoUy drafted, cacompassa activlcies and dcIsdIlncs reprdlnS Ihc ChC\'ron Plwnc
P;F-"",,~~
...
-------
JlJII 18 '90 16: 321
~.
P.€V7
.
"'
June 18. JWU
PI. 5
!tom invcstiption aU the WI'Ilbrou&h f1nal. cJe:aanup. Owen Ihe c~cnt lack of
eumplete information concernin. me nature. CXICB& and Qri;in(s) w the Chevron
Plume:, most uf the pruvisions in the Or~r rClardin¥ ,be Chevron rlumc are being
impo$Cd pr~m8turcJy. From a cecbnh:al v1cwpuin\e prnviaiuDS C.1.j. .ad perhapa C.1 J.
should be the only a~ivitid spcdfl~ al tIUI lime. After these ~ities are
accnmplished and repoltl b.we been lu&bmlncd I&n..I evaluated, It would then btJ
appropriate w isSue a suMequent order related to me IICtual remediation ,If the
Chevron Plume.
.551 would like 10 ttwnk the RWQCB for dim upponuniry to present some of
SSJ's commenu to \tu: Order regarding the ChevlOIJ 'blll1e. We wnuld welcome
!urthcl discuuinl thc=se issuc:s with RWOCB Staff. all Ui'fuopria"'. P~ue note that by
submittin. this leuer, SSl does not Wliive lu ri;bc UJ 'ubm!t further ur oLhcr wmmcotJ
at a later Wuc. SSJ iIltcn\lS 10 prcwWe the: RWQCB with ~'ttunaat Q>mmcntS .
CODCCminj dae C11CV1'OD Plume IIDd o&IIcr iIIUC8.
Very vuly yours.
SalveDI Serviclt Co.. IDe.
~ AJrry-
SURD Vedftnthl1m
nnvirnnmentAl MuMacr
cc:
Lawrence A. Cnpn. Esq.
David Abbott
David Keith Todd
,~v~aMINo&.ft
.-
-------
Jl..t4 18 '90 16::30
P.7/7
--,. - rru:.U.CJ~l'l'V44U FLR mTrc &:e7
-
,.
.
SCHEDUll! OF WORK PERf OR MilD
RELATIlD TO niB CHEVRON PLUM!
T ..........
-..
... ~J ....
....
.... ----
~
~
SSI
Chevron
21 cxJst,
8 exist,
""lie propolCd
4 proposed
~n&$ to t!cterQlJne JJa~ochanne1 .eum~O'
SSI 13 driUcd' noDe ptnpn1cd . .
ChewuD 0 driUr.d DOGe rrnpnsed
Sjt~-Wf(!t' Deep ~~.
~I 8w~
CbeVron J 1JrJJk".ct
IUIIIC pruposecS (3 aloDi SW perim8ter)
ftOae propn.cd
~roun4wft't"r s.,mp1.!Da
SSI
Chevron
" SPA method 824U and S EPA ulcthod 8015
8 ducumentcd ErA m':lhud 8015 lIS of Sc:pl. 1919
4 c1acumCI1,,~(J P.P A InCtlu;Kt as140 as of Sept. 1989
10 estimated ..raplLnp early pan of 19'JO
SSI
Chewoa
12 samples (D1 and .\5)
o samples
..
... IU
.1 . ........-
I. ..
...8
1.1 .
.
SSI fWly identified the Chevron Plume In a memunwdwn pr4MousJy ,ubmitted
10 me RWQCB. M~y n, 19M, Todc.1 EnalneerS; Mcmormdum to Iho RWOCa. .
Anom(!lou.s. C(.)ncentn.linn~ qfJeMene, ~n8!. ~'ene. 8~nune (DIXS)
the w .' e' n S .
.~.8ft'~"'~I...
....
-------
APPENDIX E
-------
t
Ii
,
~---------
1'2
, : mUe
October
1188
Figure 1
"
DAVID KEITH TODD
Consulting Englneera, Inc.
Berke'e,. CaUforn18
SOLV~.NT SERVICE
LOCATION MAP
..'. . ...-........
-------
-.- - ..-,
I.
'-
~
- -,
,-:,
I
I-
I .
L-
r----"'-
I
J
I
L rCIfWD
. --1- J .....
. .e..... 81\6.
:.-.:, .a-act......
I
... .... .wI
.. - - - - -'--'.....JIII ~ - -. - -.
.. - -.--- -..-- - - ""'..« - - ---
-'-- ~
.~ ' ...
nr ..
.... J' . .,
, ,""- ..
~. ~
~ /. .
, .-
',-. .
r'~\ .
"
"
"
.. 88M
"
. "
O. ':'
. \'
"
\'
"
"
..J1 '\
LJr-
.
.
.
.
-
.
.
.
.
.
.
.
.
.
.
-
.
or
r----
,
,
,
,
,
,
,
,
.
./
---~----------------, / --
I I I I
In I .....
I ..-...10 ",lkg contamination contow 801 ....
.....--10 ppl» contamination contOW' In groundwat... I
October t-
.
I"
Of'lCr
lit
OFFICI
.
.
.
.
.
-
.
.
.
.
IIMYlIIA .GAD
.
.
. ~
DAVID KEITH TODD
Con8ulling Ingln..,.. In..
..rk.I.,. California
FIgure 17
. AREAL EXTENT OF SOL AND
GROUNDWATER CONTAMtNAT10N
-------
APPENDIX F
-------
United State~_Environmental Protection Agency Region 9
. .
Administrative Record - Table of Contents
Solvent Service. Inc.
--
YEAR - 1982
I. CORRESPONDENCE / HEETINGS
From
RWQCB
To
SSI
Desc.
Subsurface Invest
Date
12/23/82
YEAR - 1983
I. CORRESPONDENCE / HEETINGS
From To Desc. Date
SSI RWQCB Subsurface Invest 1/6/83
RWQCB SSI Subsurface Invest 1/17/83
SS! RWQCB Status Report 1/31/83
SSI RWQCB Status Report 2/14/83
RWQCB SSI Subsurface Invest 7/12/83
RWQCB SSI Request For Proposal 8/1/83
RWQCB SS! Review of Proposal 9/2/83
AEC SSI/RWQCB Subsurface Geologic Invest 9/22/83
RWQCB SS! Approval of Proposal 9/26/89
.
I I. REPORTS
-
". -
Type -,'. Date
Proposal to Perform Subsurface
Investigation and Sampling
Groundwater Contamination Study
7/25/83
....w"--
Proposal to Perform Subsurface
Investigation and Sampling
Grou~dwater Contamination Study - Phase II
8/15/83
Proposal to Perform Subsurface
Investigation and Sampling
Groundwater- Contamination-Study - Phase II
9/18/83
YEAR - 1984
I. CORRESPONDENCE / HEETINGS
From
To
De s c . -
Date
Pao,:: - 1
-------
. I .
AEC
RWQCB
AEC
nAEC
AEC
SSI/RWQCB
SSI/RWQCB
SSI/RWQCB
AEC
SSI/RWQCB
11. REPORTS
Type
Boring Logs; Letter
dated 7/12/84; Data
Sheets / Site Plan
Progress of Investigation
Study - Update
Progress of Investigation
Meeting - SSI/RWQCB
Recommendations For
Interim Extraction Trenchi
Aquifer A 12/5/84
Phase 11 Groundwater Contamination Study
Stage Ii Investigation of Horizontal Extent
on Site. Volume I - Report
Phase II Groundwater Contamination study
Stage Ii Investigation of Horizontal Extent
on Site. Volume II - Appendices
Proposal to Perform Subsurface Invest.
and Samplingi Phase IIi Croundwater
Contam.StudYi Aquifer Bi Local Groundwater
Gradient Study
Groundwater Contamination Study; San Jose
Marketing Terminali San Jose
Phase II Groundwater Contamination Study
Aquifer B: Local Groundwater Gradient Study
YEAR - 1985
From
I. CORRESPONDENCE / MEETINGS
To
AEC
"JSC
SSI
AEC
AEC
RWQCB
RWQCB
RWQCB
RWQCB
RWQCB
AEC
AEC
RWQCB
RWQC.B
Desc.
Results of Sample
Analyses
Report Review / SSI
Water Treatment Methods
Boring Logs
Phase II; GW Contam
Study; Stage 3;
Progress Report / Draft
Proposed .Phase II Work
Preliminary Site Assess;
7/18/84
8/17/84
10/19/84
11/5/84
11/8/84
Date
1/27/84
1/27/84
3/26/84
9/20/84
10/5/84
Date
1/11/85
1/29/85
2/1/85
2/20/85
4/30/85
5/15/85
-------
, '
Berryessa Ploperties 5/21/85
AEC J5C/RWQCB Permission to Install
GW Monitoring Wells and
Monitor Existing Wells 5/22/85
AEC RWQCB Boring Logs / Chemical
An~lysis 7/11/85
AEC JSC/RWQCB Permission to Continue
Work 7/25/85
AEC RWQCB Water Sample Results 8/26/85
55I RWQCB GW Mgmt. Practices 9/5/85
RWQCB RWQCB Review of 551 Work 9/13/85
CBE RWQCB General Comments 10/31/85
CBE DHS General Comments 10/31/85
RWQCB RWQCB Clarification of
9/13/85 Hemo 11/14/85
AEC RWQCB Clarification of
9/13/85 Memo 11/14/85
AEC RWQCB Site Plan / Boring Logs/
Lab Data Sheets 11/20/85
DHS RWQCB Comments From CBE 11/20/85
AEC SSI/RWQCB Notes of Meeting
11/19/85 11/25/85
AEC SSI/DHS/RWQCB Well Information Letter 12/2/85
CBE RWQCB General Comments 12/3/85
CBE DHS General Comments 12/4/85
DHS RWQCB Additional Comments-SSI 12/20/85
II. REPORTS
Type
Date
'.
Preliminary Site Assessment /
Berryessa Properties; for Jackson Shav
1/14/85
Proposal to Perform Subsurface Investigation
and Sampling; Phase 11 Groundwater
Contamination Study; Aquifers Band C:
Horizontal Extent of Contamination
Down Gradient
2/12/85
Phase II Groundvater Contamination Study
Stage 3 Progress Reporti Aquifer A:
Inter 1m Extraction Trench; . Aqui fers
Sand C:Investigation of Extent Down
Gradient
4/29/85
,..
Phase II Groundwater Contamination Study
Stage 3 Progress Reporti Aquifer A:
Interim Extraction Trench; Aquifers
Band C:Investigation of Extent Down
Gradient; Volume I - Report
5/15/85
Page - 3
-------
. .'
Phase II Groundyater Contamination Study
Stage 3 Progress Report; Volume II -
Appendices
5/15/85
Results of Performance Testing; Interim
Extraction trench: Aquifer'A; Groundyater
Contamination Study
Results of Performance Testing; Interim
Extraction Well AEC 31B: Aquifer B;
Groundwater Contamination Study
7/19/85
7/24/85
Proposal to Perform Subsurface Investigation
and Sampling; Phase II Groundyater
contaminaiiontstudY~ Aouifer At"iInvestloatlon
ot Latera Ex ent o~ COntamlna on; Aqulter
C: Groundwater gradient Investigation and
Horizontal Extent of Contamination
Down Gradient
Proposal to Perform Subsurface Investigati~n
and Sampling; Phase II Groundyater
Contamination Study; Aquifer A; Horizontal
Extent of Contamination Doyn Gradient
9/24/85
10/22/85
Proposal to Perform Phase II Groundwater
Contamination Study; Stage 5; Aquifers
A, B, C, and D
12/10/85
:II
YEAR - 1986
I. CORRESPONDENCE / MEETINGS
From To Desc. Date
RWQCB SSI Reviey of Preliminary
Groundwater Sampling Analysis 1/17/86
RWQCB CBE SSI Status 1/17/86
SSI DHS/RWQCB Comments on 12/20/85 Memo 1/20/86
AEC RWQCB Groundwater Extraction
Summary Table 1/21/86 .
AEC RWQCB Claim Against RWQCB By AEC 1/22/86 /
AEC RWQCB Soil and Water Sample
Results 1/27/86
AEC JSC Permission to Continue Work 1/29/86
AgC DHS/RWQCB Modifications to 12/10/85
Proposal 1/29/86
AEC DHS/RWQCB Notes of Meeting 1/29/86
AEC DHS/RWQCB Status of off-site
Investigation and Sampling 1/31/86
AEC DHS/RWQCB Modification of Project
Page - 4
-------
AEC. I' DH5/RWQCB
DH5 CBE
AEC RWQCB
RWQCB 551
AEC DH5/RWQCB
AEC RWQCB
DKT AEC
DKT AEC
RWQCB SOC
DKT AEC
RWQCB AEC
AEC DHS/RWQCB
AEC JSC
AEC DHS/RWQCB
DHS RWQCB
AEC RWQCB
RWQCB SSI
RWQCB CHV
AEC DHS/RWQCB
DHS AEC/RWQCB
AEC DHS/RWQCB/JSC
AEC DHS/RWQCB
CHV RWQCB
AEC DHS/RWQCB/JSC
..
RWQCB CHV
.- '.
CHV RWQCB
CSJ RWQCB
Schedule
Status of Investigation
Request For Information
Lab results
Tentative Order
Status Report - Down Gradient
Hyd~aulic Control Measures:
Aquife~s A and B
Request Fo~ Deadline
Extension
Analysis on SSI Groundwater
Ext~action Trench
Analysis on SSI G~oundwate~
Extraction Trench; Part III:
Prel1ainary Finite-Element
Analysis
Heetin9 / Public Forum / SSI
Notice of E~emption
Groundwater .Extraction Trench
- Analysis of 3/25/85 Pumping
Order' 86-16 .
Draft Report - On Site
Contamination Investi9ation
nga~t~90IuW~~~Yand Permission
To Continue Work
Confirm Results of 4/9/86
Heetin9
DHS Comments on 4/9/86 Htg.
Selection of Wells to be
Sampled During 4/86 Quarterly
Groundwater Sampling
Proposal For Additional
On-Site Remedial Action
Programs
Groundwater Contamination at
Chevron Terminal on 1020
Berryessa Road
Shallow Soils Sampling
Protocol
Response to 4/11/89 Letter
Phone Discussions - 4/18/86
and 4/24/86
Wo~k Schedule For Hydraulic
Control and On-Site Clean-Up
Response to Request For
Groundwater Investi9ation
Update of Work and Permission
To Continue Work
Second Request for
Investigation
Groundwater Discussion
Notice of Preparation of
DEIR
Page - 5
2/3/86
2/3/86
2/10/86
2/12/86
2/13/86
2/14/86
2/14/86
2/20/86
3/6/86
3/19/86
3/24/86
3/26/86
3/28/86
3/31/86
4/9/86 .
4/11/86
4/11/86
4/18/86
4/21/86
4/24/86
4/24/86
4/28/86
4/29/86
5/6/86
5/8/86
5/9/86
5/22/86
6/2/86
6/13/86
6./18/86
-------
GTI" DHS/RWQCB Con,tructlon Detal1~ 7/10/66
SSI DHS/RWQCB Amendment3 TO propo~al For
Rt:medlal Action 7/21/86
RWQCB SSI Comm~nt5 on Proposal for
Zone A Plume Control and Zone
BC Plume Control 8/15/86
DHS SSI Feasibility Study 8/27/86
SSI RWQCB Onsite Treatment Methods 9/20/86
SSI RWQCB Time Schedule Restraints 9/20/86
RWQCB RWQCB Review of GTI's Proposal 9/29"/86
5S1 RWQCB Monitoring vells Data 9/29/86
CHV RWQCB Chevron Fuel Terminal 9/29/86
5SI RWQCB List of Wells -
Quarterly Monitoring 9/30/86
5SI RWQCB Report of Extraction Trench 10/17/86
GTI RWQCB Pump Test / Zone B/C 10/30/86
DHS RWQCB Biodegradation / Feasibility
Study 11/3/86
RWQCB SSI Implementation Schedule 12/3/86
SSI RWQCB Sampling Schedule 12/5/86
SSI DHS/RWQCB Schedule I Work In Progress 12/5/86
RWCQCB RWQCB Initial Notification of
Spill/Chevron 12/11/86
GTI SSI Supplement to Degradation
Feasibility study 12/18/86
SSI DKT Authorization to Proceed 12/19/86
SSI RWQCB NPDES Application 12/22/86
II. REPORTS
Type
Date ,"
Additional Evaluation of Interim Extraction
Trench: Aquifer A
3/26/86
Proposed Measures For Hydraulic Control and
On-Site Clean-Up
3/28/86
Proposal To Perform Phase II Off-Site
Groundwater Contamination Study - Aquifer A
Results of On-Site Contamination Investigation
Groundwater Contamination Study - Volume 1
4/14/86
6/6/86
Results of On-Site Contamination Investigation
dGroundwater Contamination Study - Volume 2
Results of On-Site Contamination Investigation
Groundwater Contamination Study - Volume 3
6/6/86
6/6/86
Results of On-Site Contamination Investigation
Groundwater Contamination Study - Volume ~
6/6/86
0:1,.....:1 - r:.
-------
. 0
Results of On-Site Contamination Investigation
Groundwater Contamination Study - Volume 5
Proposal For an On-Site Remedial Action Plan
6/6/86
7/20/86
Proposal For A Zone Off Sit~ Plume Control,
B/C On site Plume Control'
7/3/86
Zone A Extraction Trench Installation and
Preliminary Performance Evaluation
7/20/86
Results of the Enhanced Natural Degradation
Feasibility Study
10/6/86
Zone A Extraction Trench Installation and
Preliminary Performance Evaluation - Revision 1
10/13/86
Zone Band C Recovery Well Installations
and Pump Test Analyses
11/19/86
YEAR - 1987
I. CORRESPONDENCE / MEETINGS
From To Desc. Date
DKT DH5/RWQCB Proposal For Supplemental
Soil Investigation 1/8/87
RWQCB RWQCB Comments - GTI Report 1/12/87
DH5 DKT Comments on Soil Invest.
ProposCil 1/14/87
General Status Meeting 1/16/87
SSI DHS/RWQCB Status Report 2/2/87
SSI RWQCS/DHS Consultant Change / Changes
To Order 2/11/87
S5I RWQCB/DHS Status Report 2/8/87
OHS 55I RAP Guidelines 2/19/87
SSI RWQCB/DHS Sampling Results 2/23/87
General Status Meeting 3/2/87
DHS SSI Guidelines / Health and
Safety Plan 3/9/87
General status Meeting 3/23/87
PM 5SI Biodegradation Feasibility
Report 4/7/87
.. Meeting Summary 4/17/87
..
DKT RWQCB Croundwater Monitoring and
.. Extraction Facilities 4/27/87
DKT RWQCB Monitoring and Extraction
Facilities; Proposed
Construction Detail 5/11/87
RWQCB CJ5 On-5it~ Remedial Action
Programs .. 5/14/87
Pa(J~ - 7
-------
1--
ff
5.s I
RWQCB
CJ5
Comments
551
CJ5
DH5 SSI
DKT DHS/RWQCB
DKT DH5/RWQCB
RWQCB SSI
S5I DHS
DKT DHS/RWQCB
DKT DH5/RWQCB
G~n~ral Groundwater Info
- Soil and Ground-
Water Report
Info on S.Cooker and
Groundwater Treatment
Systems
M~eting
Mailing List / Soil
Clean-up
Progress Report
New Monitoring Well
Locations and Chemical data
From Selected Wells
Sample and Site Safety Plan
Response to 6/23/87 Letter
Groundwater Monitoring
and Extraction Facilities
Construction Details
New Chemical Data From
Selected Wells; Sampling
Quarter 2 Completed
SSI DHS/RWQCB Updated Mailing List
RWQCB SSI Comments on QAPP
SSI DHS Updated Mailing List
SSI RWQCB Modified QAAP
DKT DHS/RWQCB Corrections to 9/87
R~port
RWQCB SSI QAPP Approval
Meeting
General Status Meeting
DHS RWQCB Comments on FS a nd RAP
I I. REPORTS
Type
Soi1 and Groundwater Investigation For
Solvent Service Inc. - Phase I - Volume I
Soi1.and Groundwater Investigation For
Solvent Service Inc. - Phase I - Volume II
Site Safety Plan For G~oundvater
-.and Soil Investigation and Interim Remedial
Action Plan
Quality Assurance Project Plan For Groundwater
and Soil Investigation and Interim Remedial
Action Plan
Soil and Groundwater Investigation For
Page - 8
5/18/87
5/22/87
6/4/87
6/12/87
6/23/87
6/24/87
7/1/87
7/3/87
7/8/87
7/14/87
7/14/87
7/23/87
8/20/87
8/21/87
9/14/87
10/13/87
10/28/87
11/19/87
12/3/87
12/15/87
Date
3/87
3/87
7/14/87
7-/14/ 8 7
-------
~olvent Service Inc. - Phase II - Volume I
~oil and Groundwater Investigation For
Solvent Service Inc. - Phase II - Volume II
Soil and Groundwater Investigation For
Solvent Service Inc. - Phase II - Volume III
Sampling Plan For Groundwater
and S01l Investigation and Interim Remedial
Action Plan
Feasibility Study of Remedial Action Plans
For Soil and Groundwater
YEAR - 1988
From
I. CORRESPONDENCE / MEETINGS
To
Desc.
DKT
DKT
DHS
DKT
'DKT
DKT
DKT
SSI
RWQCB
SSI
RWQCB
SSI
DKT
SSI
RWQCB
SSI
SSI
SSI
DHS
DHS/RWQCB
Proposal For
Supplemental Soil
Investigation
Groundvater Monitoring
and Extraction Facilities
Proposed Construction
Details
Soil Proposal Comments
Sampling Schedule For
Monitoring Wells at SSI
Monitoring of Zone B/C
Proposed Soil and
Groundvater Investigation
Plans
Progress Report-2/88
Treatment Syst~ms
Comments on WDR
Mailing List Generation
Order' 86-1E>
Mailing List Update
Progress Report - 3/88
Va~iance Request for
Groundvater and Soils
Treatment Systems
Comments on Tentative
Order
Comments on Order
CRP Development
Meeting
Revised Variance Request
Screening Analysis~
DHS/RWQCB
DKT
DHS/RWQCB
DHS/RWQCB
DHS
DHS/RWQCB
DHS/RWQCB
DHS
DHS/RWQCB
S5I
DHS/RWQCB
DHS/RWQCB
DHS/RWQCB
RWQCB
RWQCB
. DHS/RWQCB
DHS/RWQCB
DKT
Page - 9
9/87
9/87
9/81
\
10/1/87
10/87
Date
1/8/88
1/12/88
1/14/88
1/18/88
1/18/88
2/12/88
3/1/88
3/8/88
3/16/88
3/24/88
3/25/88
3/28/88
4/1/88
4/1/88
4/4/88
4/8/88
4/11/88
4/11/88
4/18/88
-------
55!
55!
DKT
55 I
-
OMS
DKT
R WOCB
OKT
SSI
DH5
SSI
SSI
OKT
RWQCB
DKT
OKT
SS!
OHS
OKT
SSI
SSI
SSI
DHS
OKT
EPA
RWQCB
RWQCB
RWQCB
DKT
RWQCB.
SSI
I I..,. REPORTS
Type
"
DKT
DHS/RWQCB
DHS/RWQCB
DHS/RWQCB
SSI
DHS/RWQCB
SSI
RWQCB
DHS/RWQCB
SSI
DHS/RWQCB
DHS/RWQCB
DHS/RWQCB
SSI
DHS/RWQCB
DHS/RWQCB
DHS/RWQCB
SSI
OHS/RWQCB
DHS/RWQCB
RWQCB/OHS
DHS/RWQCB
RWQCB
DHS/RWQCB
DHS
SSI
SSI
CHV
RWQCB/DHS
SSI
EPA
..
Report
Review of Fact Sheet 1
First Draft-Fuct Sheet 1
Screening Analysis
Report
Variance Request
S.Cookt=r
Permit / Variances
Progress Report-4/88
Order No. 88-61
Anomalous DTXE Conc.
Along Southwest Perimeter
of SSI Property 5/22/88
S. Cooker Proposal and
Screening Analysis of
Soil Remediation
Alternates
Comments on Fact Sheet
.1
SSI - CRP
Revised Fact Sheet I 1
Progress Report - 5/88
WorkPlan Request
Contamination Status
Progress Report
Revised Fact Sheet. 1
Fact Sheet Comments
Chevron Plume-Mtg
Progress Report
Fact Sheet I 1 - Final
Amendment / Extension
of Order
Copies of Fact Sheet
SSI Cleanup
Progress Report
Permit Waiver
QAPP Approval
Request For Amendment
Review of Work Plan
General Status Meetlng
General Status Meeting
Proposed schedule
Workplan Comments
Permit Status
Soil Investigation For Solvent Service Inc.
Volume I - Text
Paae - 10
4/20/88
4/21/80
4/22/88
4/26/88
5/2/88
5/6/86
5/15/88
5/16/88
5/27/88
6/2/88
6/10/88
6/12/88
6/15/88
7/7/88
7/11/88
7/15/88
7/19/88
8/4/88
8/5/88
8/15/88
8/18/88
9/1/88'
It 1 9/14/88
9/28/88
8/15/88
10/13/88
10/28/88
11/14/88
11/14/88
11/15/88
11/28/88
12/1/88
12/1/88
12/20/88
Date
4/88
-------
Soil Investigation For Solvent Service Inc.
Volume II - Appendices I to VI
4/88
Soil Investigation For Solvent Service Inc.
Volume III - Appendices VII
4/88
Proposal For a Pilot Study of Vacuum
Extraction and Steam Injection at SSI
4/88
Proposal For Decontamination of Soils By
Low Temperature Thermal Stripping
Completion of Screening Analysis of Soil
Remediation Alternates
5/88
Groundwater and Soils Treatment Systems
5/88
5/88
Community Relations Plan
6/88
Groundwater Investigation For Solvent Service
Inc. - Volume I - Text
6/88
Groundwater Investigation For Solvent Service
Inc. - Volume II - Appendix I to IV
6/88
Groundwater Investigation For Solvent Service
Inc. - Volume III - Appendix V to VI
6/88
Groundwater Investigation For Solvent Service
I.nc. - Volume IV - Appendix VII
Summary of Plume Stabilization and
Off-Site Contamination at SSI
6/88
12/88
YEAR - 1989
I. CORRESPONDENCE / MEETINGS
From To Desc. : ..
Date
RWQCB SSI Compliance Monitoring Report 2/8/89
SIVE/Work Plan/General
Stat.us Meeting 2/24/89
RWQCB SSI Comments on RI/FS Workplan 3/23/89
..'. RWQCB SSI Tentative Order 3/24/89
Site Characterization Status
eo - Meeting 3/24/89
DKT CAI Transmittal of Preliminary
Work Plan 3/29/89
DKT RWQCB Transmittal of Well Sampling
in Zone B/C Memo 3/29/89
RWQCB 55I BPHE Info. -3/31/89
n " n.~ - "
-------
s-s I"
55I
55I
RWQCB
DKT
RWQCB
DKT
RWQCB
DKT
RWQCB
DKT
55!
55!
RWQCB
SSI
SSI
RWQCB
RWQCB
S5I
RWQCB
SSI
SSI
RWQCB
RWQCB
SSI
SSI
SSI
DKT
DKT
DKT
RWQCB
RWQCB
SSI
RWQCB
RWQCB
SSI
....RWQCB
II. REPORTS
Type
RWQCB
RWQCB
RWQCB
55I
DH5/RWQCB
DKT
DHS/RWQCB
5SI
CAI
551
CAI
RWQCB
DHS/RWQCB
SSI
RWQCB
RWQCB
5SI
55I
RWQCB
55!
RWQCB
RWQCB
551
CHV
DKT
RWQCB
EPA/DHS/RWQCB
5SI/EPA/DHS
SSI/EPA/DHS
SSI/EPA/DHS
CHV
SSI
RWQCB
General
5SI
RWQCB
SSI
..-
Comm~nts on Order
Groundwater 5ampling
Work Plan Pages
BPHE - Data Package Req
New Wells and Destruction of
Old Wells
Dat. Requested by Clements
Baseline Health Evaluation
Heeting
Baseline Health Evaluation
Heeting
Honthly Report - May 1989
Order Number 89-051
Response to Request For Info
Request to add Chevron to
Hailing List
Info for Baseline Assess
Proposal for Administrative
Draft
Honthly Report - June
Info Request Re. Chevron
Access Agreement
Ad-Draft-Tentative Schedule
Response to 7/21 letter
Comments on Conduit 5tudy
Amendment to 7/29 letter
5ite Safety Plan letter
Chevron Agreement
Monthly Report - July/August
Interim. Remedial Actions
Compliance Monitoring Report
Compliance Monitoring Report
Revised SSI Site Safety Plan
Revised Site Safety Plan
Draft Table of Cont~nls for
SSI's Administrative Draft
RIFS Transmittal
RAP Transmittal
SSI Quarterly
Response to Technical
Report
Review of Site Safety Plan
Well Sampling
SSI Fact Sheet. 2
Meeting
Honthly - December
Comm~nts / RIFS/RAP
Groundwater Contamination in Zone B/C and
Page - 12
4/3/89
4/5/89
4/13/89
4/18/89
4/25/89
5/4/89
5/8/89
5/11/89
5/15/89
5/16/89
6/5/89
6/16/89
7/11/89
7/18/89
7/20/89
7/21/89.
7/25/89
7/28/89
7/29/89
8/8/89
8/9/89
8/18/89
8/24/89
9/19/89
9/20/89
9/20/89
9/21/89
9/21/89
10/2/89
10/17/89
10/31/89
10/89
11/1/89
11/3/89
11/9/89
12/89
12/14 89
12/15/89
12/28/89
Date
-------
A~ui'fer D/E
2/89
Work Plan
4/89
Environmental Characterization Reporting
Requirements For Solv~nt S~rvice Inc.
5/89
5/89
Well Logs and Soil Borings - Book 1
Well Logs and Soil Borings - Book 2
5/89
Proposal For Interim S01l Remediation Action
By Steam Injection and Vacuum Extraction
5/89
Pumping Test Data and Aquifer Characteristics
For Aquifer a, and Zone B/C; Methodology,
Analysis, and Results
Conduit Study For SSI
6/89
6/89
Quarterly Report For SSI - Volume I
7/89
7/89
Quarterly Report For SSI - Volume II
Ground~ater Characterization for SSI - Volume I. .9/89
Groundwater Characterization for SSI-Volume II.
9/89
Ground~ater Characterization for SSI-Volume III
9/89
9/89
Final Baseline Public Health Evaluation
Site Safety Plan for Soil and Ground~ater
Investigation
10/89
10/89
Remedial Investigation / Feasibility Study
Remedial Action Plan
Revised Conduit Study
10/89
12/89
YEAR - 1990
I. CORRESPONDENCE / MEETINGS,
...From To Desc. Date
DKT .R-WQCB Analyses Results 1/10/90
SSI RWQCB February Monthly 2/14/90
RWQCB/EPA SSI Meeting 2/15/90
SSI RWQCB Updated Draft AR . 2/21/90
Page - 13
-------
. "
II. REPORTS
Type
Date
Quarterly Report for SSI
1/90
1/90
Final RI/FS For SSI
Remedial Action Plan / SSI
1/90
AEC - Applied Earth Consultants
CAI - Clements Associates Inc.
CBE - Citizens For Better Environment
CJS - City of San Jose
CHV - Chevron Inc.
DHS - Department of Health Services
DKT - David Keith Todd Consultants
JSC - Jackson Shaw Company
GTI - Groundwater Technology Inc.
PM - Perry Mccarty
sac - State of California
RWQCB - Regional Water Quality Control Board
Page - 14
-------
ADMINISTRATIVE RECORD TABLE OF CONTENTS - UPDATE
Solvent Service, Inc.
YEAR - 1990 (January - September)
I. CORRESPONDENCE / MEETINGS
From
To
EPA
RWQCB
EPA RWQCB
SSI RWQCB
SSI RWQCB
SSI RWQCB
EPA RWQCB
SSI RWQCB
SSI RWQCB
SSI RWQCB
RWQCB Tentative Order
DHS RWQCB
SSI RWQCB
SCVWD RWQCB
DHS RWQCB
SCVWD RWQCB
RWQCB Internal Memo
DescriDtion
'Transmittal of Risk
Assessment Review
for Solvent Service
Comments on RI/FS Report
Monthly Report - February
Monthly Report - March
Monthly Report - April
Transmittal of EPA Air
Division Comments on
RI/FS Report
Monthly Report - May
Monthly Report - June
Comments on Tentative
Order for SSI
Site Cleanup Requirements
for SSI
Comments on Tentative
Order
Additional Comments on
Tentative Order for SSI
Comments on Tentative
Order for SSI
Comments on Tentative
Order for SSI
Additional Comments on
Tentative Order for SSI
Revised Cleanup Standards
for SSI
1
Date
1/26/90
2/12/90
2/14/90
3/14/90
4/13/90
5/14/90
5/15/90
6/15/90
6/18/90
6/20/90
7/11/90
7/16/90
7/20/90
7/31/90
8/3/90
8/6/90
-------
RWQCB Order No. 90-120 site Cleanup Requirements 8/15/90
for SSI
EPA.Internal .Memo EPA Air Division Comments 9/12/90
on ROD
EPA Internal Memo EPA Water Division 9/20/90
Comments on ROD
I I. REPORTS
~
Date
Quarterly Report for SSI
4/90
4/16/90
Inorganic Quality of Groundwater, additional
analyses for the Solvent Service site,
San Jose, Ca.
Final RAP for SSI 5/90
Fact Sheet No.3 (Proposed Plan) 6/90
Final RI/FS Report 6/90
Quarterly Report for SSI 6/90
RWQCB Staff Report for SSI (Draft) 6/6/90
RWQCB Staff Report for SSI (Final) 8/6/90
Responsiveness Summary 8/15/90
DHS -
EPA -
RWQCB
SCVWD
SSI -
California Department of Health Services
Environmental Protection Agency
- Regional Water Quality Control Board
- Santa Clara Valley Water District
Solvent Service, Inc.
2
-------
ADMINISTRATIVE RECORD
Solvent Service, Inc.
GUIDANCE DOCUMENTS
The following is a list of U.S. EPA Guidance Documents consulted
during development and selection of the Response Action for the
Solvent service, Inc. Superfund site in San Jose, California.
These documents are included in the ComDendium of CERCLA ReSDonse
Selection Guidance Documents (Volumes 1 - 35), which is available
for public review at the Superfund Records Center, EPA Region 9,
San Francisco.
-------
Page No.
09127/90
-INDU-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Doc
No
Title
Vol
Date
Authors
Status
Pages
Tier Attachments
..........--.
---. ----------.
OSIIER/EPA N~r .
-------.--------
.. RIIFS - GENERAL
2002 3 GUIDANCE FOR CONDUCTING REMEDIAL 10/01/88 - OS\IER/OERR FINAL 390 OSIIER 19355.3-01
INVESTIGATIONS AND FEASIBILITY
STUDIES UNDER CERCLA
2012 . 5 SUPERFUND STATE-LEAD REMEDIAL 12/01/86 - OERR FINAL 120 1 OSIIER 19355.2-1
PROJECT MANAGEMENT HANDBOOK
.. RI/FS' RI DATA QUALITY/SITE & WASTE ASSESSMENT
2100 5 A COMPENDIUM OF SUP~RFUND fiELD 12/01/87 - OERR fiNAL 550 OSWER 19355.0-14
OPERATIONS METHOOS
2101 5 6 DATA QUALITY OBJECTIVES fOR 03/01/87 . COM FEDERAL PROGRAMS FINAL 150 1 OSWER 19355.0-71
REMEDIAL RESPONSE ACTIVITIES: CORP.
DEVELOPMENT PROCESS
2102 6 DATA QUALITY OBJECTIVES FOR 03/01/87 . COM FEDERAL PROGRAMS fiNAL 120 OSWER 19355.071
REMEDIAL RESPONSE ACTIVITIES: CORP.
EXAMPLE SceNARIO: RI/fS
ACTIVITIES AT A SITE
"/CONTAMINATED SOILS AND
GROONDWATER
2112 8 GUIDELINES AND SPECIFICATIONS fOR 06/01/87 - ORO/QUALITY ASSURANCE fiNAL 31 2 1) MEMO: GUIDANCE ON
PkEPARING QUALITY ASSURANCE MANAGEMENT STAfF PREPARING GAPPs DATED
PROGRAM DOCUMENTATION 6/10/87
-------
Page No.
09/27/90
2
-INDEX-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Doc
No
Title
Vol
Authors
D8te
Ststus
Pages
Tier Att8chment.
....................
...... ...-....e.--......
OSWER/EPA N~r .
.......-..-..----..-..-.
2113 8 LABORATORY DATA VALIDATION 07101/88 - EPA DATA REVIEU WORK DRAFT 20 2
FUNCTIONAL GUIDELINES fOR GROUP - BLEYLER, R.VIAR
EVALUATING INORGANICS ANALYSES AND CO./SAMPLE MCMT.
OFF ICE
2114' 8 LABORATORY DATA VALIDATION 02/01/88 . BLEYLER, R./VIAR AND DRAFT 45 2
FUNCTIONAL GUIDELINES fOR OC./SAMPLE MCMT. OFFICE
EVALUATING ORGANIC ANALYSES - EPA DATA REVIEU
ORICGROOP
2115 8 PlACTICAL GUIDE fOR. GIKJUNlHMTER 09/01/85 - BARCELONIA, M.J., ET. FINAL 175 EPA/600/2-85/104
SAMPLI NG AL./ILLINOIS ST. WATER
SURVEY
2116 8 PlACTICAL WIDE FOR GIKUIJ-WATER 01/01/85 - BARCELONA, M. J., ET.
SAMPLING AL./ILLINOIS ST. WATER
SURVEY
** RI/fS - LAND DISPOSAL FACILITY TECHNOlOGY
2204 1:f LAND DISPOSAL RESTRICTIONS 08/11/81 - lONGEST, H.l./OERR FINAL 23 2 1) SUMMARY Of MAJOR LOR
PROVISIONS AIID CALIFORNIA
LIST PROHIBITIONS 2)
OTHER ATTACHS CITED ARE
AVAILABLE IN FED. REG.
-------
Page No.
09/27190
3
Doc
No
Vot
TIUe
-INDEX-
COMPENDIUM Of CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
D.te
Authors
P.ges
Tier Att.chments
OSWER/EPA N~r .
St.tus
.-..-----
--.. ------.....-
-------------.-.
** RI/fS. OTHER TECHNOLOGIES
2300 16 A COMPENDIUM Of TECHNOLOGIES USED 09/01/87 . ORD/CERI fINAL 49 2 EPA/625/8-87/014
IN THE TREATMENT Of HAZARDOUS
VASTES
** ARARS
3001 25 CERCLA COMPLIANCE AND OTHER 10/02/05 . PORTER, J.V./OSWER fiNAL 19 1) POTENTIALLY APPLICABLE OSWER 19234.0-2
ENVIRONMENTAL STATUTES OR RELEVANT AND
APPROPRIATE REQUIREMENTS
3002 25 CERCLA COMPLIANCE VITH OTHER LAWS 08/08/88 - OfRR DRAft 245 2 OSWER 19234.1-01
MANUAL
** VATER QUALITY
4003 26 QUALITY CRITERIA fOR WATER 1986 05/01/87 ' OffiCE Of WATER fiNAL 325 2 EPA/440/5-86-001
REGULATIONS AND STANDARDS
:** RISK ASSESSMENT
5001 27 CHEMICAL, PHYSICAL & BIOLOGICAL 09/21/85 - CLEMENT ASSOCIATES, fiNAL 32.0 2 OSWER 19850.3
PROPERTIES Of COMPOUNDS PRESENT INC.
~T HAZAROOUS WASTE SITES
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Page No. 4
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COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Doc
No Vol T It Ie Date Authora Status Pages Tfer Attachment. OSWER/EPA Number
.....--. --.. ----------- ----------..-.---
5002 27 FINAL GUIDANCE FOR THE 05/14/87 - PORTER, J.W./OSWER/OERR FINAL 22 2 1) SAME TITLE, DATED OSWER 19285.4-02
COORDINATION OF ATSDR HEALTH 4/22/87
ASSESSMENT ACTIVITIES WITH THE
SUPERFUND REMEDIAL PROCESS
5003 27 GUIDELINES FOR CARCINOGEN RISK 09124/86 - EPA FINAL 13 2
ASSESSMENT (FEDERAL REGISTER,
SEPTEMBER 24, 1986, P.33992)
5004 27 GUIDELINES FOR EXPOSURE 09124/86 - EPA FINAL 14 2
ASSESSMENT (FEDERAL REGISTER,
SEPTEMBER 24, 1986, P. 34042)
5005 27 GUIDELINES fOR HEALTH ASSESSMENT 09124/86 - EPA FINAL 14 2
OF SUSPECT DEVELOPMENTAL
TOXICANTS (FEDERAL REGISTER,
SEPTEMBER 24, 1986. P. 34028)
5006 27 GUIDELINES fOR MUTAGENECITY RISK 09/24/86 - EPA FIliAL 8 2
ASSESSMENT (FEDERAL REGISTER,
SEPTEMBER 24, P. 34006)
5007 27 GUIDELINES FOR THE HEALTH RISK 09124186 - EPA FINAL 13 2
ASSESSMENT OF CHEMICAL MIXTURES
(fEDERAL REGISTER, SEPTEMBER 24,
1986, P.34014)
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Palle No. 5
09/27/90
-INDEX-
COMPENDIUM Of CERClA RESPONSE SELECTION GUIDANCE DOCUMENTS
Doc
No Vol TIUe Date Authors Status P8ges Tier Att8chments OSWER/EPA Number .
.-..-...... .... ......-----.- -------.-.-----.
5008 28+ HEALTH EfFECTS ASSESSMENT 09/01/84 - ORD/CHEA/ECAO fINAL 1750 2 EPA/540/1-86/001-058
DOCUMENTS (58 CHEMICAL PROfilES)
VOL. 28: ACETONE, ARSENIC,
ASBESTOS, BARIUM, BENZO(A)PYRENE,
CADMIUM, ETC.
5009 31 INTEGRATED RISK INfORMATION I I - CHEA FINAL 2
SYSTEM (IRIS) [A COMPUTER-BASED
HEALTH RISK INfORMATION SYSTEM
AVAILABLE THROUGH
E-MAIL--BROCHURE ON ACCESS IS
I NCLU>EDJ
5011 31 PUBLIC HEALTH RISK EVALUATION 09/16/88 - GERRITOXICS INTEGRATION FINAL 2
DATABASE (PHRED) ~SER'S MANUAL BRANCH
AND TWO DISKETTES CONTAINING THE
DBASE I I I PLUS SYSTEM ARE
I NCLU>EDJ
5013 31 SUPERFUND EXPOSURE ASSESSMENT 04/01/88 - GERR FINAL 160 OMR 19285.5-1
. MANUAL
5014 31 SUPERFUND PUBLIC HEALTH 10/01/86 - GERR FINAL 500 OMR 19285.4-1
EVALUATION MANUAL
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09/27/90
6
-INDEX-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Doc
No
Vol
Title
Dete
Authors
Stetue
Peges
Tier Attech~ts
OSWER/EPA Nl.IItIer .
eo-
........-
.--. -----------
-..-..----....-----...
** COMMUNITY RELATIONS
7000 32 COMMUNITY RELATIONS IN SUPERFUND:
A HANDBOOK (INTERIM VERSION)
06/01/88
- OERR
FINAL
188
2
1) CHAP. 6 OF THE COM.
REL. HANDBOOK 11/03/88
osweR 19230.0-038
** SELECTION OF REMEDY/DECISION DOCUMENTS
9000 32 INTERIM GUIDANCE ON SUPERFUND 12/24/86 - PORTER, J.W./OSWER FINAL 10 2 OSWER 19355.0-19
SELECTION OF REMEDY
** NEW ADDITIONS
9002 33 INTERIM FINAL GUIDANCE ON 06/01/89 INTERIM OSWER 19355.3-02
PREPARING SUPERFUND DECISION FINAL
DOCUMENTS
9005 33 GROUND WATER ISSUE: PERFORMANCE 1 1 -KEELEY, J.F. EPA/540/4-89/005
EVALUATIONS OF PUMP-AND-TREAT
REMEDIATIONS
9009 33 NATIONAL OIL & HAZARDOUS 07/01/85 92
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7
-INDU-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Doc
No
Vol
TIUe
Date
Authors
Status
Pages
Tier Attachments
OSWER/EPA Number.
....--.-
..-. ----.---...
------------.---
9011 RISK ASSESSMENT GUIDANCE FCIt 12/01/89 INTERIM EPA/540/1-89/002
SUPERFUND - VOLUME 1, HUMAN FINAL
HEALTH EVALUATION MANUAL (PART A)
9012 2 RISK ASSESSMENT GUIDANCE FCIt 03/01/89 INTERIM EPA/540/1-89/001A
SUPERFUND - VOLUME 2, FINAL
ENVIRONMENTAL EVALUATION MANUAL
9013 INTERIM GUIDANCE ON 03/01/89 INTERIM 85 OSweR 9833.3A
ADMINISTRATIVE RECCltDS FCIt
SELECTION OF CERCLA.RESPONSE
ACTIONS
9014 INTERIM GUIDANCE ON COMPLIANCE 07/09/87 INTERIM 9 OSWER 9324.0-05
WITH APPLICABLE CIt RELEVANT AND
APPROPRIATE REQUIREMENTS
9015 CERCLA COMPLIANCE WITH OTHER LAWS 08/01/89 INTERIM OSWER 9234.1-02
MANUAL: PART If - CLEAN AIR ACT FINAL
AND OTHER ENVIRONMENTAL STATUTES
, AND STATE REQUIREMENTS
9017 REGION 9 ENVIRONMENTAL PROTECTION 06/01/89 28
AGENCY DRINKING WATER STANDARDS
AND HEALTH ADVISCltY TABLE
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Page No. 8
09/21/90
- I NOE)( -
COMPENDIUM OF CERClA RESPONSE SELECTION GUIDANCE DOCUMENTS
Doc:
No Vol Title Date Authors StatIM Pages Tier Attachments OSWER/EPA Number
......-.-.. ...... .-.-------- ....-.........-------
9018 CONSIDERATIONS IN GRcumWATER 10/18/89 8 OSWER 9355.4-03
REMEDIATION AT SUPERfUND SITE
9019 SUPERfUND LOR GUIDE '7: 12/01/89 2 OSWER 9347.3-08fS
DETERMINING WHEN LAND DISPOSAL
RESTRICTIONS (LDRs) ARE -RELEVANT
AND APPROPRIATE- TO CERCLA
RESPONSE ACTIONS
9020 RISK ASSESSMENT GUIDANCE fOR 12115/89 INTERIM
SUPERfUND HUMAN HEALTH RISK FINAL
ASSESSMENT: U.S. EPA REGION IX
RECOMMENDATIONS
9021 A GUIDE TO DEVELOPING SUPfRFUND 05/00/90 FACT 4 OSWER 9335.3-02FS-1
RECORDS Of DECISION SHEET
9022 GUIDANa ON REMEDIAL 06/01/85 FINAL OSWER 9355.0-068
INVESTIGATIONS UNDER CERCLA
9023 GUIDANCE ON FEASIBILITY STUDIES 06/01/85 FINAL OSWER 9355.0-05C
UNDER CERCLA
9024 CONTROL OF AIR EMISSIONS FROM 89/06/15 FINAL OSWER 9355.0-28
SUPERfUND AIR STRIPPERS AT
SUPERfUND GRWIIDWATEI SITES
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09/27/90
- INDEX-
COHPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Doc
No Vol TltU Date Authors Status Pages Tier Attachment* OSUER/EPA Nunber
9025 GROUND WATER POLICY - REGION 9 OS/00/89
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