United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-91/062
September 1991
&EPA Superfund
Record of Decision:
Valley Wood Preserving, CA
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REPORT DOCUMENTATION 1" REPORTNO. I ~ 3. R8dp1enre Acc888Ion No.
. PAGE EPA/ROD/R09-91/062
4. 1118... 8&MI8 5. AIpIrt D8I8
SUPERFUND RECORD OF DECISION 09/27/91
Valley Wood Preserving, CA a.
First Remedial Action - Final
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U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
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18. Ab8nct (LImIt: 200 wonIa)
The 14.4-acre Valley Wood Preserving (VWP) site is a former wood preserving facility
in Turlock, Stanilaus County, California. Land use in the area is predominantly
agricultural, and one residence is located onsite. There are subsurface irrigation
drains at the site, which eventually discharge to the San Joaquin River about 12
miles west of the site. From 1973 to 1979, VWP used a solution of chroma ted-copper
arsenate (CCA) to preserve lumber on site. Wood preserving chemicals were mixed and
stored onsite in three above-ground storage tanks. After treatment, the wood was
allowed to drip dry on paved and unpaved areas. Chemical spills, leaking tanks,
improper onsite disposal practices, and chemical drippings from the treated lumber
are known sources of contamination. In 1979, State investigations identified metals
including arsenic and chromium in an on site storage pond, holding tanks, onsite and
offsite soil, and the onsite underlying shallow aquifer. In 1989, EPA investigations
identified low levels of chromium contamination in several domestic wells, and
required VWP to install an interim ground water extraction and electrochemical
treatment system to help contain the migration of contamination. EPA also required
VWP to design a plan for the development of an alternative water supply for any
(See Attached Page)
17. ~ An8Iy8Ia .. De8atpIora
Record of Decision - Valley Wood Preserving, CA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: metals (arsenic, chromium)
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EPA/ROD/R09-91/062
Valley Wood Preserving, CA
First Remedial Action - Final
Abstract (Continued)
affected residences. VWP also installed three deep ground water
domestic water supplies. This Record of Decision (ROD) provides
contaminated soil and ground water. The primary contaminants of
soil and ground water are metals including arsenic and chromium.
wells to serve as
a final remedy for
concern affecting the
The selected remedial action for this site includes excavating approximately 15,000 cubic
yards of contaminated surface and subsurface soil; treating the soil using cement-based
fixation; backfilling excavated areas with treated soil that meets State criteria,
maintaining stabilized soil mass onsite to prevent future exposure; placing treated soil
that exceeds State criteria in lined cells onsitei collecting, handling, and disposing of
leachate; pumping and treatment of contaminated ground water using electrochemical
treatment to reduce hexavalent chromium to its trivalent form, followed by treating the
residual using alumina adsorption to remove any residual arsenic; disposing of ground
water onsite by infiltration and evaporation at one or more percolation ponds, or by
underground injection through subsurface injection wells; disposing of sludge generated
during the treatment process offsite; conducting soil, ground water, surface water, and
air monitoring; and implementing institutional controls possibly including deed
restrictions. The estimated present worth cost for this remedial action is $3,850,000,
which includes an annual O&M cost of $224,000.
PERFORMANCE STANDARDS OR GOALS: Soil excavation clean-up standards are based on an
excess cancer risk level of 10-6 for surface soil and levels protective of ground water
from contaminated leachate for subsurface soil. Ground water clean-up standards are
based on State levels and potential health risks. Chemical-specific soil goals include
arsenic 2 mg/kg (risk-based) and hexavalent chromium 4 mg/kg (risk-based) for surface
soil; and arsenic 5 ug/kg and hexavalent chromium 5 ug/kg for subsurface soil. State
criteria require a liner below soil containing arsenic and chromium concentrations
greater than 500 mg/kg and below soil exhibiting leachable arsenic and chromium at
5 ug/l. Ground water clean-up goals include arsenic 16 ug/l (health-based) and chromium
50 ug/l (State).
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~.
VALLEY WOOD PRESERVING SUPERFUND SITE
TURLOCK, CALIFORNIA
RECORD OF DECISION
United States Environmental Protection Agency
San Francisco, California
September 1991
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3.0
4.0
5.0
6.0
7.0
8.0
9.0
CONTENTS
Page
DEClARATION
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 . . . . . . . . . . . v
1.0
SITE LOCA110N AND DESCRIP110N ......................... 1.1
2.0
SITE HISTORY AND ENFORCEMENT AcrMTIES ............... 2-1
21 INIT1AL INVESTIGATIONS. .. ~ .. .. .. . . . . . .. . . . . . ..". . .. 2.1
22 REMOVAL ACI10NS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.3
23 REMEDIAL INVESTIGA TIONIFEASIBILITY STUDY . . . . . . .. 2.3
HIGHUGHTS OF COMMUNI1Y INVOLVEMENT. . . . . . . . . . . . . . .. 3.1
SCOPE AND ROLE OF RESPONSE ACI'IONS ................... 4-1
4.1 SOIL CONTAMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3
4.2 GROUNDWATER CONTAMINATION.......... '0'" .. . ... 4-3
4.3 PRINCIPAL THREAT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . 4-3
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . .. 5.i
5.1 GROUNDWATER. . . . . . . . . . . . .0. . . . . . . . . . . . . . . . . . . . . . . 5-1
5.2 SOIL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3
5.3 CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6
SUMMARY OF SITE RISKS. . . . . . . . . . . .. . . . . . .. . . . . . . . . . . . . .. 6-1
6.1 HEALTH RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
6.2 ENVIRONMENTAL RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-4
6.3 CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7
DESCRIPTION OF ALTERNATIVES. . . . . . ... . . . . . . . . . . . . . . . . . .. '.1
7.1 SOIL REMEDIAL ALTERNATIVES. . ... . . '0' . . . . . . . . . . . . . 7-1
7.2 GROUNDWATER REMEDIAL ALTERNATIVES. . . . . . . . . . . 7-4
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . 8-1 "
8.1 ALTERNATIVE COMPARISON FOR SOILS. . . . . . . . . . . . . . . 8-1
8.2 ALTERNATIVE COMPARISON FOR GROUNDWATER. . . . . 8-1
8.3 REMEDY SELECfION RATIONALE. . . . . . . . . . . . . . . . ~ . . . . 8-1
8.3.1 SOIL........................ o. . . . . . . . . . . . . . .. 8.14
8.3.2 GROUNDWATER........................ o. . . . .. 8-15
SELEcrED REMEDIES. . . . . . . . . . . . . . . . . . . . . . ". . . . . . . . . . . . . . . 9-1
9.1 REMEDY FOR CONTAMINATED SOILS................... 9-1
9.2 REMEDY FOR CONTAMINATED GROUNDWATER......... 9-3
9.3 CONCLUSION......................................... 9-6
SF03JS94\RP~1.5J
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6-2
6-3
7-1
8-1
8-2
8-3
8-4
CONTENTS (continued)
Page
10.0
STATUTORY DETERMINATIONS. . 0 0 0 0 0 . 0 . 0 0 0 0 0 0000000000000 10-1
10.1 CONTAMINATED SOILS. . . . . . . . . . .. .. . . . .. .. . . . . . ... 10-2
10.2 CONTAMINATED GROUNDWATER. . . . . . . . . . . . . . . . . .. 10-2
lloO DOCuMENTATION OF SIGNIFICANT CHANGES
. . . . . . . . . . . . . .. 11-1
APPENDICES
Appendix A RESPONSE SUMMARY
Appendix B. ADMINISTRATIVE RECORD INDEX
TABLES
4-1
Contaminant Concentrations and Cleanup Standards. . . . . . . . . . . . . .. 4-1
4-2
Regulatory Standards and Guidelines for VWP.Site Chemicals. . . . . . .. 4-2
6-1
Summary of Results of the Health Risks by Exposure Pathways
Current Land Use-Potential Risks at the VWP Site and Vicinity. . . . .. 6-3
Summary of Results of the Health Risks for Multiple Pathways
Future Land Use-Potential Risks at the VWP Site and Vicinity
(On-Site Residents) ........................................ 6.5
Summary of Results of the Health Risks for Multiple Pathways
. Future Land Use-Potential Risks at the VWP Site and Vicinity
(Off-Site Rsidents) . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . .. 6-6
Ust of Alternatives Considered in VWP Site Feasibility Study. . . . . . . .. 7-1
Summary of ARARs and TBCs ............................:.. 8-2
Comparative Analysis of Soil Alternatives. . . . . . . . . . . . . . . . . . . . . . .. 8-6
Comparative Analysis of Groundwater Alternatives. . . . . . . . . . . . . . . .. 8-9
Remedy Selection Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8-12
SF031594\RP\OOl.51
111
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CONTENTS (continued)
nGURES.
Page
2-1
5-1
5-2
5-3
1-1
Site Location Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1.2
Site Plan [[[ 2-2
Chromium (VI) and Arsenic Isoconcentrations in Groundwater. . . . . . .. 5.2
Approximate Areal Extent of Arsenic and Chromium (VI) in
Surface Soil (0-4 Feet) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : . . . .. 5-4
Approximate Areal Extent of Arsenic and Chromium (VI) in .
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DECLARATION
.
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DECLARATION
SITE NAME AND LOCATION
Valley WoOd Preserving Site
Turlock, California
STATEMENT OF BASIS AND PURPOSE
This decision document presents the remedial actions selected for the V aJIey Wood
Preserving Site in TurJock, California, chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act (SARA), and to the extent
practicable, the National Oil and Hazardous Substances PoJIution Contingency Plan
(NCP). This decision is based on the administrative record for this site.
The State of California concurs with the selected remedies.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response actions selected in this Record of Decision (ROD), may
present an imminent and substantial endangerment to pubJic health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDIES
The remedial actions have been selected to address contaminated soils and
groundwater in a complete site cleanup strategy. These remedies address the
documented principal pubJic health and environmental threats from the site
contamination. The major components of the selected remedies include the following:
.
Extraction of the contaminated groundwater foHowed by electrochemical
treatment, activated alumina adsorption, and disposal. The end use of
the treated groundwater wiJI combine one or both of the. following
methods: reinjection to groundwater and/or discharge to percolation
ponds.
.
Excavation of contaminated soils and chemical fIXation followed by on-
site disposal in treatment ceHs for treated soils designated as hazardous
waste.
SF031394\RP'\OO2.51
v
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STA11JTORY DETERMlNA110NS
The selected remedies are protective of human health and the environment, address aU
.principal threats from the site, comply with the federal and state requirements legally
applicable or relevant and appropriate to the remedial action, and are cost effective.
The remedies use permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable and satisfy the statutory preference for
remedies that use treatment to reduce toxicity, mobility, or volume as their principal
element. The groundwater remedy involves treatment estimated to take at least 5
years to reach remedial objectives. The soil remedy involves treatment estimated to
take about 9 months to reach remedial objectives. Because Utese remedies may result
in hazardous substances being left onsite above health-based levels, a review wilJ be
conducted within 5 years of commencement of remedial actions, and thereafter as
ne-c~ssary, to ensure that the remedies for groundwater and soils continue to adequately
protect human health and the environment.
& .
u.J LoA-
Daniel. McGovern ..(y
RegionaJ Administrator
Q.').7.Q/
Date
SF031594\RP\OO2.S1
VI
.
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Section 1.0
SITE LOCATION AND DESCRIPTION
..
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Section 1.0
SITE LOCATION AND DESCRIPTION
The Valley Wood Preserving (VWP) Superfund site, an inactive wood preserving
facility, is located at 2237 South Golden State Boulevard in an unincorporated area of
Stanislaus County, California, about 1.5 miles southeast of the City of Turlock's
corporate boundary (Figure 1-1). The Merced County line is about one-half mile
southeast of the site. The site is located within Section 2S of Township 5 South, Range
10 East, ,relative to the Mount Diablo base and meridian.
Prominent man-made landmarks in the vicinity of the site include the Southern Pacific
Railroad that parallels South Golden State Boulevard to the east; the rest area on State
Highway 99, about one-half mile to the south; Turlock Irrigation District (I1D) Lateral
No.5 surface drain, about one-half mile to the south; and Johnson School, about one
mile to the south in Merced County. The Turlock Airpark is located about one-and-
one-quaner miles to the west.
The site, occupying an area of approximately 14.4 acres, is essentially level with parts of
the site graded to control surface water runoff. The former wood treatirig and storage
area is paved with asphalt. The remainder of the site is unpaved. The entire
perimeter of the site is secured with a 6-foot-high chainlink fence.
The site is bounded by the southbound lanes of South Golden State Boulevard to the
east, a vineyard to the north, a poultry farm to the south, and fallow agricultural/
residential lots to the west. Land use in the vicinity of the site is mostly agricultural.
Most of the agricultural plots near the site are relatively large and at least partially in
residential use.
A single-family residence is located in the northeast corner of the site. Associated
structures include a garagelworkshop and a storage shed. Water for domestic use is
obtained from a well, designated VWP-2, located immediately northwest of the
residence. Also, several corrugated metal buildings formerly occupied by an equipment
rental company are located near the southeast corner of the site. They include tWo
service/storage-type buildings and a covered work structure. Most of the wood
preserving facilities and equipment have been dismantled and removed; however, an
equipment shed, tWo large aboveground tanks, a pole shed, and an office structure
remain. A 6OO,OOO-gal1on tank constructed after closure of the wood treating facility is
on-site as part of the interim groundwater cleanup program. '
Subsurface features at the site include subsurface TID irrigation drains and subsurface
piping. Four underground storage tanks were removed in 1990. The subsurface TID
, irrigation pipeline drain transects the eastern portion of the site parallel to South
Golden State Boulevard. The invert of the pipe is 4.5 to 5.0 feet below grade. The
TID eventually discharges to the San Joaquin River about 12 miles west of the site.
SF031S94\RN103.5 1
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SITE LOCATION MAP
VAlLEY WOOO PRES!RVJ«J. INC.
tURlOCK. CAlFORNlA
-------
Three waterproducing wells, vwP-1, VWP-2, and VWP-3, are the other subsurface
features at the site. According to site plans, only VWP-3 (inactive) of the three weUs
. appears to have had a significant water distnoution subsurface piping system on-site.
The mean annual precipitation in the site area is 11.7 inches, 80 percent of which falls
as rain between November and March. Average monthly air temperature varies from
4S.?'F in December and January to 76.goF in July. Mean annual wind speed is
approximately 7 miles per hour. The prevailing wind direction is north-northwest to
Donhwest, except in December, January, and February when it is to the southeast.
Most of the direct precipitation and runoff from paved areas percolates rapidly into the
ground. There is little, if any, overland flow and DO significant streams or creeks exist
in the vicinity of the site. There is an extensive network of subsurface drains and
irrigation pipes originating from TID Lateral No.5 surface drain located to the south.
In the vicinity of the site, 8 to 14 feet of vadose zone overlie an unconfined aquifer that.
extends to a depth of approximately 140 feet. The unconfined aquifer is separated
from the confined aquifer by a low permeability clay layer (aquitard) called the "E-
clay," which is present between 140 and 185 feet below grade. The water table is
typically 4 to 8 feet below grade, but is several feet deeper at this time due to drought
conditions. The groundwater flows fo the southwest and has an average hydrauJic
gradient of approximately 0.002 under nonpumping conditions. The average
transmissMty of the unconfined aquifer is 1,500 square feet per day. The hydraulic
gradient between the unconfined and confined aquifers is vertically downward.
The "E-clay" is characterized by its dark greenish-gray to blue-gray color, which is
probably due to the reduced state of the ferrous iron contained in the clay minerals.
The most diagnostic feature of the "E-clay" is the presence of diatoms, which tend to be
concentrated near the stratigraphic middle of the unit. The older alluvium overlies the
"E-clay" and consists of intercalated beds of gravel, sand, silt, and clay with some
"hardpan." Coloration of the older alJuvium is variable and has been reponed as
brown, reddish-brown, gray, brownish-gray, white, blue, and black. It is generally
distinguished from the underlying continenta1 deposits by its coarser-grained texture.
The older alJuvium reponedly becomes less permeable with depth.
The unconfined aquifer zone has been extensively developed as a groundwater
resource. There are 105 current or former water-producing wells within the study area,
in addition to the 56 monitoring welJs instalJed during investigations at the VWP site.
Ninety-one of these wells (81 active and 10 inactive) are for domestic water supply, six
are "drainage" wells, six are "industrial-use" wells, and two are without any known use.
The extraction of small quantities of groundwater from the domestic weBs in the study
area does not have a significant effect on the regional groundwater flow regime.
However, relatively large volumes of water are extracted from the unconfined aquifer
on a continuous basis by TID to control groundwater levels.
SF031594\RP'OO3.51
1-3
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Section 2.0
SITE HISTORY AND
ENFORCEMENT ACTIVITIES
.
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Section 2.0
SITE mSTORY AND ENFORCEMENT ACTIVITIES
Wood preserving operations at VWP were conducted from 1973 through "1979 and
resulted in on-site and off-site soil and groundwater contamination. The contaminants
of concern at VWP include hexavalent chromium and arsenic in the soils, from surface
to approximately 12 feet in depth, and hexavalent chromium and arsenic in the ground-
water. The groundwater contaminant plume extends approximately 2,000 feet off-site
to the southwest and poses a substantial threat to neighboring domestic wells.
VWP preserved lumber using an aqueous solution containing 1 to 2 percent chromated-
copper-arsenate (CCA). The wood preserving chemicals were stored and mixed on-site
in three above-ground storage tanks. Lumber in loads of up to 20,000 pounds was
placed onto a rail-mounted treatment train and pushed into one of four pressure
treatment cylinders. After treatment, the train would exit the cylinder and the wood
would ~ unloaded and allowed to drip dry on paved and unpaved areas. Chemical
spills, leaking tanks, on-site disposal practices, and chemical drippings from treated
lumber are the known sources of contamination associated with the VWP site. (Site
featUres are shown on Figure 2-1.) "
Harold and Joyce Logsdon were the owners of the VWP site from the beginning of
operations at the site until 1980 when Valley Wood Preserving, Inc. acquired full
ownership of VWP. Harold and Joyce Logsdon at all times have owned between 25
and 50 percent of the stock of Valley Wood Preserving (VWP), Inc. However, they are
not the sole stockholders of the corporation; five other individuals have been identified
as stockholders by the California Attorney General's Office.
2.1
INITIAL INVESTIGATIONS
In 1979, the California Central Valley Regional Water Quality Control Board
(CVRWQCB) identified toxic "wood treating chemicals (chromium, arsenic, copper)
within an on-site storage pond, within holding tanks, and in on-site and off-site soils. In
addition, groundwater contaminated with these same chemicals was detected within the
shallow, unconfmed aquifer at the site. In November 1979, the CVRWQCB issued a
cleanup and abatement order to VWP, Inc. In 1980, the CVRWQCB obtained a
preliminary injunction ordering VWP, Inc. to undertake groundwater pump- and-treat
actions at _the site. VWP, Inc. began soil and groundwater sampling in early 1980, but
ceased remedial efforts in 1983 due to alleged financial difficulties.
In March 1987, the California Department of Health Services (DHS), now known as
the California Department of Toxic Substances Control (DTSC), issued a remedial
action order (RAO) to VWP, Inc. requiring it to conduct a remedial investigation and
feasibility study (RIIFS) and to develop a remedial action plan (RAP). In response to
the RAO, VWP, l~c. contraCted with Geosystem Consultants, Inc. to conduct an RIIFS
SF031S94\RNI04.51 .
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-------
at the site. In January 1989, VWP, Inc. submitted to DHS the initial draft RI report
that has been revised several times to reflect additional site characterization. VWP was
proposed for inclusion on the National Priorities List (NPL) in June 1988 and added to
the NPL in March 1989. The United States Environmental Protection Agency (EPA)
became the lead agency in September 1989.
2.2
REMOVAL AcrIONS
While the RI was being revised, EP A became concerned about the threats to water
quality in the neighboring residential wells. In August 1989, EPA advised VWP, Inc. to
conduct monthly domestic well sampling. In addition, EP A began preparing a removal
consent order to require VWP, Inc. to implement an interim pump-and-treat operation
to contain the off-site migration of the groundwater plume. From September through
November 1989, EP A conducted site and neighborhood visits with residents in the area.
In October 1989, several domestic wells showed detectable concentrations of hexavalent
chromium. In November 1989, EP A's Environmental Services Branch sampled seven
domestic wells, and the data revealed that several of the wells contained elevated
concentrations of hexavalent chromium; these levels were, however, below the
California Maximum Contaminant Level (MCL) for chromium.
The removal consent order was signed on December 8, 1989. The order calls for
VWP, Inc. to conduct two aquifer tests to determine the aquifer's hydrologic
characteristics and to aid in the design and implementation of an extraction system for
the interim pumping. FolJowing completion of the aquifer tests, VWP, Inc. is required
to implement an interim pump-and-treat system. In addition, the removal consent
order calls for VWP, Inc. to design a plan for the development of an alternative water
supply for affect~d residents. An alternate water supply must be made available to
affected residents if any contaminant in existing supply welJs reaches 60 percent of its
MCL To date, VWP, Inc. has generally complied with the removal consent order.
The extraction and electrochemical treatment system has been operating since June
1990.
In January 1990, VWP, Inc. began to instalJ three deep groundwater wells to serve as
domestic water supplies. These wells have been completed and determined to be clean
and residential water is now supplied by these wells. VWP, Inc. will eventually seal the
old, shallow domestic wells; they are currently used as monitoring wells.
2.3
REMEDIAL INVESTIGA TIONIFEASIBILI1Y STUDY
On May 4, 1990, Harold Logsdon signed a second EP A administrative consent order on
behalf of Respondent VWP, Inc. The administrative consent order requires VWP, Inc.
to conduct an RIfFS. The effective date of this order, which supersedes the 1987 DHS
RAO, is May 1, 1990. As part of the RIIFS, EPA completed a baseline risk assessment
in February 1991 to estimate potential health and environmental risks that could result
if no action were taken at the site. The risk assessment indicated that exposure tl)
groundwater contaminated by chemicals from VWP could result in significant heJlth
SF031594\RPW04.51
2-3
.
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risks. No significant ecological risks were identified. The risk assessment is described
in more detail in Section 6.0.
In June 1991, the RIIFS was completed with the following conclusions:
.
The contaminants of concern in both soil and groundwater are hexavalent
chromium and arsenic.
.
The groundwater plume continues to migrate toward domestic wells.
Additional investigation of the vertical extent of the groundwater plume
is required immediately to ensure successful design and implementation
of the extraction well field.
.
.
Remedial technologies capable of cleaning up the VWP site in
accordance with EP A and state standards are available.
SF031S94\RNJ04.51
2-4
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Section 3.0
HIGHLIGHTS OF COMMUNITY
INVOLVEMENT
..
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Section 3.0
mGID.JGHTS OF COMMUNI1Y INVOLVEMENT
Community interest in the VWP site was high during the late 19705 when owners of
propeny adjacent to the site became concerned about odors, potentially contaminated
domestic wells, and general exposures to site chemicals. Interest has subsided some-
what since the onset of remedial activities, which continue to be frequently covered by
loca1 newspapers.
EP A has encouraged public panicipation during the RI/FS process and has met the
requirements for public panicipation under CERCLA Section 113(K)(2)(B)(i-v). Pub-
lic panicipation has occurred through the fonowing activities:
November 1988 .
Release of the community relations plan (CRP) under the dirc:c-
tion of DHS (now DTSC)
January 1989
DHS fact sheet regarding site investigations
October 1989
EP A community interviews, fact sheet regarding EPA involve-
ment at VWP
December 1989
EP A progress letter
April 1990
June 1990
EP A fact sheet on the removal pump-and-treat system
EP A fact sheet on groundwater cleanup activities
January 1991
EP A fact sheet on remedial investigation activities
June 1991
Public notice and release of draft remedial investigation/ feasibil-
ity study and proposed plan for public comment
June 1991
EP A letter reminding community of proposed plan public meeting
June 1991
A formal public meeting in accordance with CERCLA Section
U7(a)(2) was held on June 25 to discuss the RIfFS and the pro-
posed plan. Approximately 25 community members attendc:d and
no public opposition to the plan was voiced. Two written com-
ments were submitted at the meeting; the state and PRPs were
the onty other commentors during the public comment period.
The administrative record file has been established at EPA's Region 9 office in S<.In
Francisco and at the City of Turlock library. Responses to official public comment are
presented in the Response Summary attached as Appendix A to this ROD.
SFO~lSCU\RP\OO~.51
3-]
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Section 4.0
SCOPE AND ROLE OF RESPONSE ACTIONS
.
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Section 4.0
SCOPE AND ROLE OF RESPONSE ACTIONS
The selected response actions address contamination in soil and groundwater caused by
operations at the VWP site. The response actions will be performed to meet the final
site treatment standards listed in Table 4-1. These levels are based on Applicable or
Relevant and Appropriate Requirements (ARARs) and health protection criteria.
Table 4-2 presents regulatory standards and guidelines for arsenic and hexavalent
(chromi~m VI) chromium.
I
I
I .
Table 4-1
Contaminant Concentrations and Cleanup Standards
Background Maximum Site Site Cleanup
Contaminant Levels Levels Standards
SURFACE SOIlS (ppm) (ppm) (ppm)
Hexavalent Chromium <1 30 48
Arsenic <3 140 'r
SUBSURFACE SOILS (ppm) (ppm) Leachate (ppb)
Hexavalent Chromium <1 68 5 (DLM)b
Arsenic <3 232 5 (DLM)b
Treated Water
Discharge
GROUNDWATER (ppb) (ppb) Limits (ppb)
Hexavalent Chromium <10 28,000 50
(State MCL)
Arsenic <14 2,350 16
(HIC = 1)
.Standard represents a 1 x 1O~ excess risk concentration.
bDLM: Designated Level Methodology adopted by the Central Valley Regional
Water Quality Control Board (CVRWQCB) for protection of groundwater
CJiI~ 1: An HI ~ 1 means that no adverse health effect would be present due to
exposure to these concentrations.
Arsenic, copper, hexavalent chromium, and trivalent chromium are contaminants
frequently detected in elevated concentrations at the site. EP A's Risk Assessment
determined that health risks from trivalent chromium and copper at the site are not
significant; therefore, arsenic and hexavalent chromium are the primary contaminants
of concern. In significant concentrations, arsenic in all media and hexavalent chromium
SF031S94\RP\OOO.51
4-1
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Table 4-%
Regulatory Standards and Guidelines for VWP Site Chemicals
Site Chemicals
Parameter Arsenic Chromium
Maximum Contaminant Level (MCL) (ppb)8 SO 100
(Total Chromium)
Maximum Contaminant Level GoaI.(MCLG) (Ppb) SO 100
(Total Chromium)
California Maximum Contaminant Level (MCL) (Ppb) SO SO
(Total Chromium)
One-Day Acute Health Advisory 10 Kg. Child (ppb)b - 1.000
(TotaI01romium)
Longer Term Health Advisory 10 Kg. Child (ppb)b - 200
(Total Chromium) .
Ufetime Health Advisory 70 Kg. Adult (ppb)b - 100
(Total Chromium)
Total Threshold Limit Concentration (TILe) (ppmt SOO 500
(Chromium VI)
Soluble Threshold Limit Concentration (STLC) (ppmt 5 5
(Total Chromium)
Soluble Designated Level Methodology (DLM) 5 5
Concentration (ppb)d (Chromium VI)
. MCLs. MCLGs. and Health Advisories. and SMCLs were extracted from .Region 9
Environmental Protection Agency Drinking Water Standards and Health Advisory Table" by the
U.S. EPA Region 9 ( Drinking Water and Groundwater Protection Branch. January 1. 1991.)
b Standards were extracted from IRIS (Integrated Risk Information System) files for individual
chemicals (U.S. EPA, 1990).
C Values were obtained from California Administrative Code. Title 22.
d Based on the Designated Level Methodology utilized by CVRWQCB in the June 1989 updated
Staff Repon "The Designated Level Methodology for Waste Classification and Cleanup Level
Determination".
SF031594\RP\Oll.51
4-2
.
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in inhaled particulates are known human carcinogens. They are present at the VWP
site at concentrations exceeding health standards. The" selected remedies presented
" herein address the documented potential threats from the site. Treatment of the
contaminated soil and groundwater will significantly reduce the potential for future
exposure to contaminated soil and groundwater.
4.1
SOIL CONTAMINATION
The surface soil (0 to 4 feet in depth) cleanup standards for the site are based on
potential health risks from inhalation and direct contact, corresponding to 1 x 10.0
excess cancer risk. They are 4 ppm for hexavalent chromi\im and 2 ppm for arsenic.
The surface soils above these concentrations will be removed and treated, thus reducing
excess cancer risk to the 1 x 10.0 level
The subsurface soil (deeper than 4 feet) cleanup standards for the site are based on
protection of groundwater from contaminated leach~te from these soils. The cleanup
standards are 5 ppb for chromium and 5 ppb for arsenic as measured in the leachate
from subsurface soils. These levels are based on the Designated Level Methodology
for characterizing wastes in soils adopted by the CVRWQCB in June 1989. Subsurface
soils (below 4 feet to the top of the water table) with leachate exceeding these levels
will "be removed and treated. .
4.2
GROUNDWATER CONTAMINATION
The cleanup standard for hexavalent chromium in groundwater for the site is 50 ppb,
which corresponds to the California MCL for total chromium in drinking water. The
corresponding EPA MCL for total chromium is 100 ppb. The 50 ppb cleanup standard
for chromium will reduce the corresponding Hazard Index to less than one.
The cleanup standard for arsenic in groundwater for the site is 16 ppb, which is based
on potential health risk. Since there are two contaminants, arsenic and hexavalent"
chromium, that affect the same location in the human body, the arsenic cleanup
standard is set at 16 ppb so that the sum of the Hazard" Index for all the contaminants
does not exceed one.
4.3
PRINCIPAL THREAT
Contaminated groundwater at the site represents the primary risk at the site, and the
remedy will seek to return groundwater to its beneficial uses within a reasonable period
of time. Soil contamination at the site represents a continuing source of groundwater
contamination and represents the principal threat at the site. This principal threat will
be addressed by the remedy.
SF031.594\RP'OOO.5 1
4-3
.
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Section 5.0
SUMMARY OF SITE CHARACTERISTICS
.
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Section 5.0
SUMl\fARY OF SITE CHARACTERISTICS
The contaminants present at and adjacent to the VWP site appear to be related
eXclusively to the chromate-copper-arsenate solution used in the wood preserving
process and include trivalent chromium, hexavalent chromium, copper, and arsenic.
Hexavalent chromium and arsenic are known human carcinogens and are considered to
be primary contaminants of concern and principal health threats. Trivalent chromium
and copper are less toxic than the primary site contaminants, arc identified as
contaminants of less conce~ and are considered low-level threats for which no action
is required.
5.1 GROUNDWATER
The predominant metal detected in the unconfined aquifer is hexavalent chromium.
Hexavalent chromium is present in groundwater from. the western site boundary to
approximately 2,000 feet downgradient to the southwest (Figure 5-1). The
concentrations of total chromium and hexavalent chromium in the wells sampled are
generally equal, indicating there is very little trivalent chromium in the groundwater.
Under nonpumping conditions the hexavalent chromium plume appears to be migrating
at a rate of approximately 0.21 feet per day; however, the center of the plume has not
migrated significantly since 1986. The movement of this plume has decreased since the
interim pumping and treating system began operating in June 1990.
Currently, the 50-ppb hexavalent chromium isoconcentration has migrated to within
about 200 feet of several domestic wells along Golf Road. As of April 1991, hexavalent
chromium had not significantly affected any of these water-producing wells, which
supply the residences along Golf Road. However, shallow domestic wells, Segars-3,
Segars-5, and Dixon-1, have been replaced by deeper water supply wells as a
precaution against future contamination and public exposure.
The concentrations of hexavalent chromium in on-site wells have decreased with time.
Currently, the highest concentrations (up to 28,000 ppb) of hexavalent chromium have
been detected in Wells GW-5, GW-15B, and GW-26. All of these wells are off-site to
the southwest of the former mixing tank area. Hexavalent chromium concentrations in
groundwater do not vary significantly with depth in the unconfined aquifer down to 60
feet, although the highest concentrations in some well clusters are at the deepest
intervals (50 to .60 ft).
Trivalent chromium arid copper are not present at concentrations of concern in
groundwater, based on assessment of site risks, as explained in Section 6.0.
Arsenic has been detected in on-site groundwater along the western site boundary
(Figure 5-1) up to a maximum concentration of 2,350 ppb. There is no significant
SF031S94\RP\008.5 1
5-1
.
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FIGURE 5.1
CHROMIUM (VI) AND ARSENIC
lSOCONCENTRATIONS IN GROUNDWATER
JANUARY 1991
Vaney wood Preserving, Inc.
Turtock, CaHfomia
-------
off-site migration of arsenic from the site, as the arsenic plume extends only about
200 feet west of the VWP property. The arsenic concentrations in groundwater in
areas beyond the arsenic plume shown on Figure 5-1 are, in general, less than 20 ppb
(near background levels). Also, arsenic concentrations in samples collected from on-
site and off-site domestic wells are within the background arsenic concentration range.
Investigations have not been performed in the study area to characterize the
groundwater in the unconfined aquifer below 60 feet and in the strata below it. Since
the hydraulic gradient between the two aquifers (unconfined and confined) is vertically
dOWI1Wa(d, there is concern over the potential for the vertical migration of hexavalent
chromium from the unconfined aquifer to the underlying zones. Additional
investigations are underway to assess the water quality of the deeper areas of the
unconfined aquifer and of the E-clay layer. The groundwater extraction and treatment
system will be expanded to address the lower water-bearing zones if contamination is
detected above cleanup levels.
S.2 SOIL
The principal contaminants detected in the surface soil (0 to 4 feet) are hexavalent
chromium and arsenic. The approximate areal extent of the surface soil affected by
these contaminants is shown on Figure 5-2. Hexavalent chromium is distributed far less
widely than total chromium and is generally present at substantially lower
concentrations. Thus, most of the chromium detected in soil is in the trivalent form.
The maximum hexavalent chromium contamination detected in the surface soil is 30
ppm at a depth of 0.5 feet in Boring B-7, located near the eastern edge of the northern
paved depression. Background concentrations of hexavalent chromium are less than
1 ppm. The on-site shallow soils significantly affected by hexavalent chromium are
limited to the area west of the tanks and to the paved depression areas. Soils in off-
site areas have not been significantly contaminated with hexavalent chromium.
Arsenic concentrations above the background levels of 0.5 - 3 ppm were detected in
surface soil (0 to 4 feet) samples primarily in on-site areas, with the exception of
Borings P-1 through P-7 located around the perimeter of the paved wood treatment
and storage area and B-55 located just north of the site boundary. The areal
distnbution of arsenic in surface soil samples is shown on Figure 5-2. As shown on this
figure, surface soils contaminated with arsenic are localized primarily around the former
mixing tanks and northeast of the site. The maximum arsenic concentration detected in
surface soils is 140 ppm at a depth of 0.7 feet in Boring P-2, located in the northern
pan of the on-site area at the edge of the paved wood-treatment and storage area.
The distribution of hexavalent chromium in subsurface soils (4 feet to water table) was
very similar to that in surface soils (Figure 5-3). Sampling results indicate little vertical
variation in hexavalent chromium concentrations in soil. The maximum detected
concentration of hexavalent chromium in subsurface soil was 68 ppm at a depth of 6.5
feet in Boring S-8, located west of the former mixing tanks.
SF031594\RP\008..51
5-3
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.... ~. .!. ~ APPROXIMATE AREAL EXTENT OF
ARSENIC AND CHROMIUM (VI)
IN SURFACE SOIL (0-4 FEET)
DECEMBER 1989
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LEGEND
6) EXISTING MONITORINO W£LL
" ACTIVE WATER PROOUCINO WELL
o INACTIVE WATER PRODUCING WELL
-. - PROPERTY LINE
~ AREAS OF ARSENIC CONTAMINATION
~ (ABOVE BACKGROUND CONCENTRATION
OF 3.01
. EXTRACTION WELL
. INJECTION W£Ll
Valley Wood Pruervlng, Inc.
1\Jr/oclt. California
-------
.
lEGEND
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. ACTM! WATER PRODUCING WEll
. INACT1VE WATER PRODUCINO WEll
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'TIJrlock. C8111ornl8
-------
Elevated arsenic concentrations in subsurface soils occur only in the vicinity of the
wood preserving areas near the western on-site boundary, as shown on Figure 5-3. The
. maximum arsenic concentration detected was 232 ppm at a depth of 6.5 feet in Boring
8.19 located in this area.
Copper was detected above background concentrations of 7 ppm in subsurface soils in
the same area reponed for hexavalent chromium and in soils around the perimeter of
the paved area on-site. The maximum copper concentration detected was 845 ppm at
a depth of 6.5 feet in Boring 8.19, located between the former locations of the two
southern retons.
5.3 CONCLUSION
Chromium and arsenic concentrations exceeding federal and state drinking water
standards occur in the contaminated area of the unconfined aquifer down to at least 60
feet below the surface and extend to approximately 2,000 feet downgradient of the
VWP boundary. The groundwater cleanup standard for chromium corresponds to the
California MCL of 50 ppb. The cleanup standard of 16 ppb for arsenic corresponds to
a Hazard Index of 1. These are concentrations at which no adverse health effects are
exPected to occur through any exposure pathway. EP A expectS that approximately
360,000 gaJJons of contaminated groundwater wiJJ require treatment each day for at
least 5 years.
The most seriously contaminated soils are under the paved area on the VWP property.
The area with the highest levels of soil contamination consists of nearly one-eighth acre,
located on the west side of the 6OO,OOO-gaJJon tank currently being used in the interim
groundwater cleanup program. Another area under the nonheast corner of the
pavement is also significantly contaminated with hexavalent chromium and arsenic.
EPA's remedy for soil cleanup will involve excavation and treatment of approximately
15,000 cubic yards of soil contaminated with arsenic and hexavalent chromium. The
remedy wi)) reduce these soil contaminant concentrations to those corresponding to
potential excess health risk of "1 x 10.0. .
The principal site-related chemicals, the media affected, background concentration
levels, and maximum concentration levels detected are presented in Table 4-1. Data
used by EPA to develop the feasibility study, to select remedial alternatives, and to
develop conclusions and cleanup standards presented in this Record of Decision
(RQD) were validated by EP A and considered of acceptable quality for the purposes
of the RI/FS.
SF03J S94\RP'OOS.5 1
5-6
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Section 6.0
SUMMARY .OF SITE RISKS
.
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Section 6.0
SUMMARY OF SITE RISKS
EP A prepared an endangerment assessment to document the potential riskS associated
with the actual or threatened releases of hazardous substances from the VWP site.
This section summarizes the information found in the following two documents:
(1)
u.s. Environmental Protection Agency, February 4, 1991. Risk Assessment,
V~ey Wood Preserving Site, Turlock, California. EP A W A C09030 (prepared
by PRC Environmental Management, Inc.).
(2)
u.s. Environmental Protection Agency, November 21, 1990. Preliminary
Ecological Risk Assessment, Valley Wood Preserving Site, Turlock, California.
EPA WA C09030 (prepared by Versar, Inc.).,
6.1 REALm RISKS
VWP used a $elution of chromate-copper-arsenate (CCA) in day-to-day operations.
These were also the compounds detected most frequently and at the greatest
concentrations in on-site and/or off-site soils and groundwater. Of these, hexavalent
chromium in groundwater was the only contaminant linked to the site that was
identified as a contaminant of concern under current land' use conditions.
Contaminants of concern under future land use conditions include hexavalent
chromium and arsenic. Copper was not chosen as a chemical of concern primarily
because of its low mobility and low human toxicity. Arsenic and hexavalent chromium
were selected because of their relatively high human toxicity, the significant
concentrations detected, and detection frequency in soil and groundwater.
Hexavalent chromium was identified in the toxicity assessment as a probable human
carcinogen only via inhalation, whereas arsenic is considered carcinogenic by aU routes
of exposure. Arsenic and hexavalent chromium are 'capable of causing acute and
chronic noncarcinogenic health effects in humans at sufficient exposure levels.
The VWP site is bordered by residences and agricultural lands, and from land use
development patterns, it was assumed in the risk assessment that both actual and
potential uses for the site are residential. It was also assumed that under current
conditions it is unlikely that exposure to heavily contaminated surface soils on-site will
occur, since most contaminated soil is overlain by asphaltic pavement. However, future
residential andlor industrial development will likely occur, which may, require soil
excavation to a depth of 10 feet; therefore, exposure to contaminated soils may occur.
Potential pathways of contaminant migration from the site to the surrounding area
include air (windblown dust) and groundwater.
SF03159C\RP\009.51
6-1
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A number of exposure scenarios identifying exposures associated with current potential
and future potenrial land use conditions were developed. Under current potential land
use conditions, the exposures with the highest probability of occurring are residential
"exposures associated with (1) ingesrion of groundwater, (2) dermal contact with
groundwater, (3) ingestion of on-site soils, (4) dermal contact with on-site soils, and (5)
inhalation of suspended particulates on- and off-site.
To assess carcinogenic risks, the following slope factors (mg/kg-day) were used:
Arsenic (inhalation):
Arsenic (oral):
Chromium VI (inhalation): "
1.5 X 101
1.8 X 101
4.1 X 101
(Source: IRIS)
(Source: IRIS)
(Source: IRIS)
To assess noncarcinogenic effects, the following reference dose values (RID; mglkg-day)
were used:
Arsenic (oral; dermal):
Chromium VI:
Chromium VI (oral):
Chromium VI (dermal):
1.0 X 1002
5 X 10-3
2 X 10-2
1 x 10-4
(Source:
(Source:
(Source:
(Source:
HEAST) "
IRIS)
IRIS)
IRIS)
Assumptions used for soil exposure assessment included an exposure frequency of 365
days per year, ingestion rate of 100 mg per day (adult) and 200 mg per day (child), an
exposure duration (noncarcinogenic effects) of 30 ye"ars (adult) and 6 years (child), and
a lifetime exposure (for carcinogenic effects) of 70 years. Assumptions used to assess
groundwater exposure included ingestion of 2 liters of water per day (adult) and 1 liter
of water per day (child) for the same exposure duration and frequency used for soil
exposure assessment.
Based on the risk assessment, it was concluded that under actual current land use
conditions, adverse health effects are unlikely. However, as levels of hexavalent
chromium have increased over time in the shallow wells downgradient from the site and
are expected to increase for an unknown time in the absence of remedial action,
ingestion of well water downgradient from the site is expected to pose a significant
hazard in the near future. Based on this scenario, Table 6-1 presents potential health
risks under" baseline (current land use, no remedial alternative) conditions. Using
simulated data, based on solute transpon analytical modeling, generated for" the Dixon-
1 well, Hazard Indices (HI) of 4 and 8 were estimated for children and adults,
respectively. These values exceed the benchmark value of 1 and therefore warrant
public health concern. It should be noted that under current land use conditions,
arsenic will not move to domestic wells.
Potential risks to residents under future land use conditions were estimated both for an
average exposure scenario and a reasonable maximum exposure (RME) scenario.
Under a RME scenario, a resident is assumed to build a home on-site above a soil hot
spot and to draw water from the arsenic-contaminated wells. For the off-site resident,
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C7'
~
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Table 6-1
Summary or R~ult~ of the IInlth RI!ib bJ F.xp08ure P8t"""11
Curnnt tand U!ie..PotenUal RI!lk..~ .t the VWP Site Ind V.dnlt,
Re!ildenUal AYera~ F.xp08ure Rasonable M.xlmum Exp08ure
Population F..xp08ure '.t""", Chemlnl Clllftr R.!ik lIaZ8rd Quotient Cancer Risk IIlurd Quotient
Adult . Ingestion of Ground- chromium (VI) NC 7.2 I uP NC 7.2 x uP
water from Dllon Well
Dermal Contact with chromium (VI) NC 3.3 I 10,1 NC 5.5 It 10,1
Contaminants In
Groundwater at Dixon
Well
TOTAL RISKS ACROSS PATIIWAYS NC 8 x 100 NC 8 x 100
Child Ingc.
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was assumed that a home is built south (downwind) of the soil hot spot and is exposed
to both contaminated water and dust released from the site. .
Table 6.2 presents a summation of risks across pathways for on-site residents under
future land use conditions. The cancer risk associated with this exposure point,
combining exposures via ingestion, dermal contact, and inhalation, is a 1 in 100 excess
risk in adults and 8 6 in 1,000 excess risk for children, based on an RME estimate. The
most significant potential cancer risks for on-site residents under this condition result
from exposure to high arsenic concentrations in the groundwater. Ingestion of and
dermal contact with groundwater at the arsenic-contaminated wells result in an average
excess cancer risk of 9 in 10,000 and an RME cancer risk of 1 in 100 for adults. For
children, ingestion of groundwater results in an average excess cancer risk of 1 in 1,000
and an RME cancer risk of 5 in 1,000. Hazard Indices for average and RME estimates
of noncarcinogenic toxicity also far exceed the benchmark of 1 (30 and 40 for total
RME risk across pathways for adults and children, respectively).
Table 6.3 presents a summation of risks across pathways for off-site residents under
future land use conditions. According to these estimates, carcinogenic health effects
exceed the benchmark values (1 x 10~) for the RME scenarios but not the average
scenarios. Hazard Indices, as estimates of noncarcinogenic toxicity, exceed the
benchmark value of 1 for both RME and average scenarios (50 and 2 for tota] RME
risk across pathways for adults and chiJdren, respectively). The pathway of greatest
concern for noncarcinogenic hazard is ingestion of groundwater, whereas the pathway
of greatest concern for carcinogenic risks is inhalation of respirable paniculates.
Hexavalent chromium is designated a Class A carcinogen via inhalation. Its
contribution to the cancer risk via the inhalation pathway is somewhat less than the risk
associated with arsenic. For adults and children, the combined cancer risk for an
average exposure is less than the. one in a miJJion target risk level. However, the
combined'excess cancer risk for a reasonable maximum exposure is three in one mj)]ion
for children and eight in one miJIion for adults.
6.2 ENVIRONMENTAL RISKS
A preliminary ecological risk assessment was performed to determine (1) if any
wetlands exist on or near the VWP site, and (2) if a complete ecological risk assess-
ment is required.
This study concluded that aquatic communities are unlikely to be affected by
contaminants originating from the VWP site. It was determined that there are no
wetlands or watercourses either on or in the immediate vicinity of the site.
Contaminated groundwater underlying the site and adjacent areas does not discharge to
a nearby surface watercourse. Also, there are no known aquatic endangered or
threatened species affected by contaminants originating from the site. The California
Depanment of Fish and Game's natural diversity data base did not indicate the
occurrence of known endangered or threatened aquatic species in the site vicinity.
SF031S94\RP\009.51
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Cl'
tit
.
T8ble 6-2
Summ8.., or Re!lult!l of the 1Ie<h RI!lu for Multiple P8thwlll
.'uture l..and U~e--Potentlal RI~ks at the VWP Site Bnd Vldnlt,
ON-SITE RF,SIDENTS
MenRt F.xpollun ReallOd8b1e Mulmam F.xpo!lun
Popul8tlon Exposure Pathwa, Canc:er RI!lk 11818rd Index Canc:er Risk H8zard Index
Adult Uvlng I. Groundwater Inge5tlon 9 ~ 10,4 1 ~ 10+1 II 10-Z 3 ~ 10+t
onsite at the 2. Dermal Contact with Groundwater 9 Ie 10.7 4 I 10.t 2 I 1()"5 II 100
Hot Spot During Household Use 2 It 10'~ 1 It 10,2 3 I 10-4
3. Ingeslion of On-site Soli 3 x IO-t
4. Dermal Contact with On-site Soli 3 II 10,7 2 I 10,2 2 x 10'" . 6 X 10-1
5. Inhalation of Dusls 3 II: 10,7 NA I It t()"5 NA
TOTAl. RISKS ACROSS PATHWAYS 9 II 10,4 t II 10+1 . 1 x 10-Z 3 I 10+1
Child Uving I. Groundwater Ingestion t Jt 10,3 t x 10+1 S I 10,3 4 It 10+ I
on-site at the 2. Dermal Contact with Groundwater I ~ 10-6 2 II 10,1 7 It 10-6 6 I lO,t
Hot Spot During Household Use 9 ~ 10.5 6 It lO't 5 It 10-4 3 It toO
3. Ingestion of On-site Soil
4. Dermal Contact wilh On-site Soli 7 ~ 10-6 S II lO'z 9 I 10-5 8 Ie lO,t
S. Inhalation of Dusts 9 II 10,7 NA 8 It 10-6 NA
TOTAl. RISKS ACROSS PATIIWAYS I It 10,3 I x 10+1 6 I 10,3 4 Ie 10+1
Note:
NA = Not Available
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~
0\
Table 6-J
Summary or R~ult!l or the lIealth RI!lk.~ ror Multiple Pathw8l1
. .'uture I..and U~e..Potenll.1 RI~ks at the VWP Site and Vldnlty
OFF.SITE RF,SIDENTS
Reasonable Maximum
AYft'8~ F.xpMure F.xpMure
Population F.xp05ure Pathway Canter RI!lk lIal8n1lndex Cancer Risk 11818n1lndex
Adult (Living I. Groundwater Ing~tlon Not Above Background 1 . 10+1 .. S X lO+t
20n meters 2. Dermal Contact with Groundwater .. 6 x lO't .. 4 x 100
offslle) During Household Use J . 10,7 3 . 10-6
3. Inhalation 0' Fugitlvc Dusts NA NA
TOTAL RISKS ACROSS IWrllWAYS ~ . 10,1 1 . 10+1 3 . 10-6 S. 10+1
Child (Living I. Groundwater Ingcstion .- 8 . 100 .. 2 . 100
20Cl meters 2. Dermal Contact with Groundwater .. 3 . lO,t
oITsile) During Household Use 9 J( 10" 8 X 10-6
J. Inhalation 0' Fugitive Dusts NA NA
TOTAl. RISKS ACROSS PATIIWAYS 9 J( 10,7 8 x 100 8 . 10-6 2 x 100
Note:
NA = Not Avallahle
.
SFCHISQ4\RP\OI6.SI
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The study concluded that there are no environmenta1Jy sensitive areas affected by site
contaminants. Also, it is unlikely that mammals or birds, including known endangered
or threatened species, would be affected by site contaminants. The California
. Department of Fish and Game's natural diversity data base did not indicate the
occurrence of known endangered or threatened floral or faunal species in the site
vicinity.
Based on the results of the preliminary ecological risk assessment, a detailed ecological
risk assessment was not performed.
6.3 CONCLUSION
Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response actions selected in the ROD,. may present an imminent
and substantia] endangerment to public health. The current potential risk level
(noncarcinogenic) from off-site groundwater ingestion penains to a noncarcinogenic
risk (HI) of 4 and 8 for children and adults, respectively. Future potential cancer risks
for on-site residents are estimated to be as high as 1 x 10-2 for adults and 6 x 10-3 for
chiJdren and the HI is estimated to be as high as 30 for adults and 40 for chiJdren.
Future potential cancer risk for off-site residents is estimated to be as high as 3 x 10-6
for adults and 8 x 10-6 for children. The HI is estimated to be as high as 50 for adults
and 2 for children. EPA's acceptable excess cancer risk range is 1 x 10'" to 1 x 10-6,
whiJe that for noncarcinogenic risk penains to the HI not exceeding 1.
Aquatic life is unlikely to be affected by site contaminants. No environmenta1Jy
sensitive areas, or mammals or birds are expected to be adversely affected by the
contaminants.
SF031S94~~~1
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Section 7.0
DESCRIPTION OF ALTERNATIVES
.
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Section 7.0
DESCRIPTION OF ALTERNATIVES
The following discussion presents a brief description of soil and groundwater remedial
alternatives that have survived the preliminaI}' screening and have been carried through
a detailed analysis in the VWP site Feasibility Study (FS) report. Table 7-1 lists the
alternatives subject to detailed evaluation in the FS. The soil and groundwater cleanup
standards have been descnbed in Section 4.0 of this document.
Table 7-1
Ust of Alternatives Considered in VWP Site Feasibility Study
. Soil .. .'::: . u
1. No Action
2 Capping
3. In-Situ Flushing, Excavation, Fixation, and On-Site Disposal
4. Excavation, Fixation, and On-Site Disposal
Groundwater
A No Action
B. In-Situ Chemical Treatment and Hydraulic Control
Cl. Groundwater Extraction, Electrochemical Treatment, and Activated Alumina
Adsorption
C2. Groundwater Extraction, Chemical ReductionlPrecipitation, and Activated
Alumina Adsorption
...
..
..
.. ..' ..
. .., ,./,..,..,.....
,. ...:.... .
The present worth costs for the remedial alternatives are based on capital and O&M
costs, 5 percent discount rate, and the period .of performance defined for each alterna-
tive. . All costs are in January 1991 dollars. To avoid duplication of costs, annual O&M
costs pertaining to 30 years of groundwater monitoring, are not included in the costs for
soil remedial alternatives, as they are included in the groundwater remedial alternatives
costs.
7.1 SOIL REMEDIAL ALTERNATIVES
Alternative I-No Action
Under this alternative, no remedial activity would occur. At least 15,000 cubic yards of
contaminated soils would be left in place and contaminated groundwater would con-
tinue to move off-site. Access to the site would continue to be restricted by the existing
6-foot-high perimeter fence. Warning signs would be posted at lOO-foot intervals along
the fence and at the entrance gate, which would be securely locked. Continued
SF031S94\RP'DI0.51
7-1
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groundwater monitoring would be required. No risk reduction would result. The
alternative would not comply with ARARs or water quality standards. The cost of this'
alternative, primarily for groundwater monitoring, is discussed under Section 7.2
(Groundwater RemediaJ Alternatives), Alternative A - No Action,. to avoid duplication
of costs.
Alternative %-Capping
This alternative involves capping soils containing above-background concentrations of
hexavalent chromium and/or arsenic. The design objective of the cap would be to
minimize the infiltration of water through the metal-contaminated soil and prevent
exposure of this soil to the atmosphere and to potential receptors. The cap would also
be designed to promote runoff and drainage away from the impacted areas. To the
extent possible, the existing asphaJt- and concrete-paved areas would be repaired and
sealed. The unpaved areas underlain by elevated concentrations of hexavalent chrom-
ium and arsenic would be graded and paved using an appropriate low permeability
paving material. Long-term maintenance would be required to preserve the integrity of
the paving. It is estimated that an area of ap/>foximateJy 17,000 square feet (ft2) would
require paving and approximately 41,000 ft would require repair and sealing. The
currently unpaved area affected by above-background concentrations of metals is
located, for the most part, east of the nonhern depression. As at least 15,000 cubic
yards of contaminated soil would be left in place untreated, long-term cap maintenance,
institutional controls, and site (groundwater) monitoring would be required for this
alternative to remain protective. This alternative wi)) not meet the groundwater
ARARs. Capping is not a fully permanent alternative and it would not reduce toxicity,
mobility, or volume through treatment. The capital, annual operation and maintenance
(O&M), and present wonh costs for this alternative are $78,000, $138,000, and
$216,000, respectively, based on 30 years.
Alternative 3-In-Situ Flushing, Excavation, Fixation, and On-site Disposal
Alternative 3 combines the in-situ flushing of -soils containing elevated concentrations of
hexavalent chromium with the excavation and chemical fixation of arsenic-comaining
soil. The in-situ soil flushing would be performed in conjunction with groundwater
extraction and treatment. The existing asphalt and concrete pavement would be re-
moved in the reton/wood preserving area and in the vicinity of the nonhern paved
depression. Flushing basins would be constructed in each of these two areas. Water
would be ponded in the flushing basins to infiltrate through the soil. An . effective
groundwater extraction system would be instaUed downgradient of the flushing basins to
capture the elutriate. The extracted groundwater would be treated to meet ground-
water cleanup standards before reapplication to the flushing basins. Subsequent to
achieving the target cleanup goal for hexavalent chromium-contaminated soils, the
flushing basins would continue in operation solely as a means of discharging treated
groundwater.
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Because of arsenic's low leachability, soil flushing is not expected to have a significant
mitigating effect on arsenic-contaminated soil. However, the most soluble fractions of
arsenic compounds would leach during the initial stages of soil flushing and the concen-
tration of arsenic would decrease thereafter. Cleanup of arsenic-contaminated soil
would be performed by excavation and on-site, aboveground chemical fixation. The
treated soil could be used as backfill at the site. (Chemical fixation is discussed as a
separate remedial alternative under Alternative 4 below.)
The in-situ flushing would involve approximately 8,000 cubic yards of soils containing
elevated concentrations of hexavalent chromium. The excavation, fixation, and on-site
disposal would involve approximately 9,000 cubic yards of primarily surface soils con-
taminated with arsenic. The time to achieve cleanup would be approximately 5 years.
Treatability studies using site soils would be performed before remedial design. This
alternative, if implemente~ would meet ARARs and reduce the potential excess cancer
risk to 1 x 10~ level. Institutional controls would be put in place to ensure that future
land use practices are compatible with the fixed-soil mass. The risk posed by the site
would be reassessed at 5-year intervals after cleanup to confirm that this remedy con-
tinues to protect public health and the environment. The capital, annual O&M, and
present worth costs are $1,232,000, $21,000, and $1,323,000; respectiVely, based on 5
years of operation to achieve cleanup. Annual O&M costs pertaining to groundwater
monitoring are not included in this alternative, as they are already included in the costs
for groundwater remedial alternatives.
Alternative 4-Excavation, Fixation, and On-site Disposal
This alternative involves the excavation and chemical fIXation of surface soil (0 to
4 feet) containing hexavalent chromium, and arsenic exceeding the 1 x 10~ excess
cancer risk. In addition, subsurface soils (from 4 feet below surface to groundwater)
above levels considered to be protective of groundwater would be excavated and chem-
ically fIXed. The total volume of such soil is estimated at approximately 15,000 cubic.
yards. The time to achieve cleanup from the beginning of the remedial action would
be approximately 9 months. .
Excavation would be performed using conventional earthmoving equipment. The exca-
vated soil would be blended with commercially available chemical stabilizing agents
(such as Portland Cement) in mixing equipment similar to a concrete batching plant.
The fixed-soil matrix would be used to backfI11 the excavation. The purpose of the
treatment is to stabilize the contaminants and prevent mobilization. The stabilized soil
mass would eliminate fugitive dust emissions, prevent surface water erosion of contami-
nated soil, and reduce leachability of contaminants. Treatability studies using site soils
will be performed during remedial design. Measures such as covers of clean soil and
vegetation or a clay cap would be taken to protect the surface of the fixed-soil mass
from physical decomposition. Institutional controls would be put in place to ensure
that future land-use practices are compatible with the fixed-soil mass. This alternative,
if implemented, would meet ARARs and reduce the potential excess cancer risk to 1 x
10~ level. The risk posed by the site would be reassessed at 5-year intervals to confirm
SF031 S94\RP'DI 0..51
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that this remedy continues to protect public health and the environment. The capital,
O&M, and present worth costs for this alternative are $1,853,000, $0, and $1,853,000,
respectively, based on less than one year of operation to achieve cleanup. Annual
O&M costs primarily for groundwater monitoring are included in the groundwater
remedial alternatives costs. -
7:1. GROUNDWATER REMEDIAL ALTERNATIVES
Alternative A-No Action
This remedial alternative features a-no-action response to groundwater containing hexa-
valent chromium and arsenic. Under this alternative, the existing interim groundwater
cleanup program would be terminated, resulting in uncontrolled migration of the hexa-
valent chromium and arsenic in the aquifer. The migrating chemicals, particularly hexa-
valent chromium, could ultimately reach the active domestic water supply wells located
hydraulically downgradient of the site. The risks associated with exposure to the chemi-
cals in groundwater would remain unchanged, although decreases in the concentrations
of hexavalent chromium and arsenic would be expected at some future time due to
natural attenuation and dispersion. Groundwater monitoring would be required during
implementation of the no-action response. This alternative would not comply with
ARARs. The capital, O&M, and present worth costs for this alternative are $39,000,
$77,000, and $1,223,000, respectively, primarily based on 30 years of groundwater moni-
toring.
Alternative B--In-Situ Treatment and Hydraulic Control
This alternative would involve the in-situ treatment of hexavalent chromium and
arsenic-contaminated groundwater using ferrous ions generated by an on-site, above-
ground ferrous ion generator. The ferrous ions would be introduced to the aquifer, in
solution, via injection wells, infiltration galleries, and/or infiltration ponds. Injection
wells would be used in off-site areas, and infiltration ponds would be used on-site. The
existing extraction welJs, as weU as additional extraction wells near the down gradient
edge of the plume, would enhance the migration of ferrous ions through the aquifer
while hydraulically containing the plume.
Contaminated groundwater would be extracted from the aquifer via an expanded ex-
traction system consisting of approximately six extraction wells at a rate of about 250
gallons per minute (GPM). The contaminated groundwater would be transferred back
to the site for electrochemical treatment using the existing ferrous ion generator. De-
pending on the arsenic content of the treatment system influent, it may be necessary to
polish the effluent using activated alumina adsorption. The treated water would be
transferred to the 6OO,OOO-ga11on holding tank where precipitation and settling would
occur. The treatment process would generate sludge containing elevated metal concen-
- trations and requiring special handling and disposal at an off-site waste disposal facility
in accordance with state and federal regulations. Treated water would be drawn from
the holding tank and pumped to a mixing tank where ferrous ions from a second
SF031594\RP\Ol0.51
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ferrous ion generator would be added. The ferrous ion-containing solution would be
pumped from the mixing tank and delivered to the on-site infiltration ponds and the
off-site injection wells. Dissolved hexavalent chromium and arsenic would be im-
. mobilized in situ and adsorbed onto the soil matrix. Groundwater treated in situ would
be extracted downstream for additional, above-ground treatment using ferrous ions,
then recycled through the system.
A bench-scale test was performed at the site to determine the impact of ferrous ions on
the in-situ conversion of hexavalent chromium to trivalent chromium. The results of
this test demonstrated that in-situ groundwater treatment is feasible and should be
further evaJuated on a pilot-scale level. Bench-scale tests indicate that this aJtemative
may achieve target cleanup goals established for groundwater. A passage of at least
three pore volumes of solution, corresponding to at least three years of pump and treat,
is estimated to be required to achieve target cleanup concentrations. Pilot-scale testing
wiIJ be required to confirm or refine these conclusions and estimates.
Based on bench-scale testing, this alternative will be able to meet ARARs. However,
pilot-scale testing will address uncenainties in the ability of this alternative to comply
with the groundwater ARARs and cleanup standards Within the entire aquifer.
The capital, annual O&M, and present wonh costs for this alternative are $254,000,
$245,000 ($168,000 for remediation and $77,000 for groundwater monitoring), and
$1,895,000, respectively. This is based on 3 years of operation to achieve cleanup, and
30 years of O&M including groundwater monitoring.
Alternative Ct..Groundwater Extraction, Electrochemical Treatment, and Activated
Alumina Adsorption
This alternative involves the extraction of hexavalent chromium-and-arsenic-containing
groundwater, followed by above-ground electrochemical treatment (similar to that cur-
rently being used in the interim cleanup program) to remove dissolved hexavalent
chromium, fol1owed by activated alumina adsorption to remove residual dissolved
arsenic. The groundwater extraction system would consist of the existing interim pump-
and-treat system supplemented by additional extraction wells near the leading edge of
the plume. A minimum of six extraction wel1s pumping at a combined rate of about
250 gpm would be needed. It is expected that the removal of at least 5 pore volumes
would be required to achieve the target cleanup levels for groundwater (SO ppb for
hexavalent chromium and 16 ppb for arsenic), corresponding to a cleanup time of at
Jeast 5 years. The time estimate for aquifer cleanup is based on the assumption that
desorption of hexavalent chromium is uniform throughout the target zone. This
assumption wil1 be verified by evaluating the water quality data during fulJ-scale clean-
up operations.
Extracted groundwater would be transferred to the 6OO,OOO-gal1on holding tank.
Ferrous ions from the ferrous ion generator would be injected continuously into the
water transfer piping where mixing would occur. The reduction of hexavalent
SF031594\Rf>\D1 0.5 1
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chromium to its trivalent form would occur in the piping and in the holding tank. The
reduced chromium would precipitate out in the holding tank. The eleCtrochemical pro-
. cess should be capable of reducing arsenic concentrations. If required, treated effluent
would be transferred to the alumina-adsorption column for secondary treatment to
remove residual arsenic. Once treated, the effluent would be discharged to one or
more percolation ponds for infiltration and evaporation. Subsurface injection wens
could be used as a complementary option for discontinuous or intermittent discharge.
The treatment process would generate sludge containing elevated metal concentrations
and requiring special handling and disposal at an off-site waste disposal facility in ac-
cordance with state and federal regulations.
This alternative will meet aU ARARs for the action. Institutional controls to prevent
access to the contaminated aquifer would be necessary while the action is being imple-
mented. The area of attainment of cleanup standards is the entire aquifer.
The capital, annual O&M, and present worth costs for this alternative are 5177,000, .
5224,000 (5147,000 for remediation and 577,000 for groundwater monitoring), and
$1,997,000, respectively, based on 5 years of operation to achieve cleanup and 30 years
of O&M including groundwater monitoring. .
Alternative C2-Groundwater Extraction, Chemical Reduction/Precipitation,
and Activated Alumina Adsorption
This alternative would involve an of the process steps included in Alternative Cl except
that electrochemical treatment would be replaced with chemical reduction/precipitation.
During the chemical reduction/precipitation process, a reducing agent would be added
to the extracted groundwater to transform hexavalent chromium into its nontoxic triva-
lent form. The reduction process would take place under highly acidic conditions. The
effluent from the reducing process would be transferred to the 6OO,OOO-ga))on holding
tank and given sufficient time for precipitation of trivalent chromium. The effluent
would be transferred to the alumina-adsorption column to remove residual arsenic. All
other aspects, including cleanup goals, time frame for completion, and effluent and
residuals management, would remain the same as those under Alternative Cl.
This alternative will meet al1 ARARs for the action. . Institutional controls to prevent
access to the contaminated aquifer would be necessary while the action is »eing imple-
mented. The area of attainment of cJeanup standards is the entire aquifer.
The capital, annual O&M, and present worth costs for this alternative are .5369,000,
$396,000 (5319,000 for remediation and 577,000 for groundwater monitoring), and
$2,934,000, respectively. This is based on 5 years of operation to achieve cleanup and
30 years of O&M including groundwater monitoring.
SF031~94\RP'DI0.51
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~
...
Section 8.0
SUMMARY OF COMPARATIVE ANALYSIS
OF ALTERNATI\'r:S
.
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Section 8.0
SUMMARY OF COMPARATIVE ANALYSIS OF
. ALTERNATIVES
An evaJuation and comparison of the alternatives are presented in this section. The
comparison is based on the nine key criteria required under the National Contingency
Plan and CERClA Section 121 for use in evaJuation of remedial alternatives by EP A.
The nine criteria are as follows:
.
Overall protection of human health and the environment
.
Compliance with ARARs (see Table 8-1 for ARARs and TBCs eval-
uated)
..
Long-term effectiveness and permanence
.
Reduction of toxicity, mobility, or volume through treatment
.
Shon-term effectiveness
.
Implementability
.
Cost
.
State acceptance
.
Community acceptance
.8.1 ALTERNATIVE COMPARISON FOR SOILS
Table 8-2 presents a comparison of remedial alternatives for soils treatment.
8.1 ALTERNATIVE COMPARISON FOR GROUNDWATER
Table 8-3 presents a comparison of remedial alternatives for groundwater treatment.
Note that, except for cost, the evaluations of Alternatives C1 and C2 are identical.
8.3 REMEDY SELECI10N RATIONALE
A comparison of alternatives by the nine selection criteria and rationale for site-remedy
selection are discussed in this section. The criteria used in selecting each remedy are
summarized in Table 8-4.
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Table 8-1
SWDIIW'J or ARARs and TBCs
ntle DesaiptJOD Comment
SAFE DRINKING WATER ACT
National Primary Drinking Maximum Contaminant Levels ARARs (applicable);
Water StaDdards (Mas) establisb maximum per- Chromium 100 ppb .
missible levels of oontaminants in Arsenic SO ppb
40 CFR Pan 141.11(b) drinking water from a public water
system.
Underground Injection Con- Provides for protection of under- ARARs (relevant and
uol Regulations ground sources of drinking water. appropriate); A permit is not
required for onsite CERCLA
40 CFR Pan 144 to 147 response actions, but substan-
tive requirements apply to the
disposal of treated groundwater
by injection wells.
CLEAN WATER ACT
Water Quality Criteria Ambient Water Quality Criteria TBCs; This is applicable only to
(A WQC) for surface water based one disposal alternative: dis-
U.S. EP A. -Quality Criteria on toxicity to aquatic organisms charge to Turlock Irrigation
for Water, 1986- (May 1986) and public health. District Channel.
plus updates (various dates)
National Pollutant Discharge Establishes permit requirements ARARs (applicable); This is
Elimination System (NPDES) for discharge of pollutants from applicable only to one disposal
any point source into waters of the alternative: discharge to
40 CFR Pan 122 United States. Turlock Irrigation District
Channel.
CALIFORNIA SAFE DRINKING WATER ACT
Maximum Contaminant MCLs are acceptable concentration ARARs (applicable); The state
Levels (MCLs) limits from a -free flowing cold MCL for arsenic is 50 ppb.
water outlet of the ultimate user,-
22 CCR, Div. 4. Chapter 15, The state MCL of 50 ppb of
See. 64401 eI seq. chromium was used to identify
groundwater cleanup standard
at the VWP site.
Continued
SF031 S94\RP\OlZ.5 1
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Table 1-1
SullUD8l')' or AltARs and TBCs
TItle Description Comment
PORTER. COLOGNE WATER. QUALITY ACf
Water Code, Div. 7, See:. Governs discharges of waste to AR.ARs (relevant and
13000 et seq. land, where water quality could be appropriate); ContaiDs sitiDg.
adverselyimpaaed. containment, monitoring. and .
23 CCR. Division 3. Oapter closure standards. The
15 Desigaated Level Methodology
of the CeDual VaDey RWQCB
Disc:barges of Waste 10 LaDd was used to set subsurface soil
cleailup standards for this site.
(Chromium - S ppb. and
arsenic.. S ppb. both measured
iD leachate)
Water Quality Control PlaDs Promulgated water quality AR.ARs (relevant and
Water Code., Div. 7. See. standards. based on beneficial uses appropriate); Water Quality
13000 et seq. for surface water and groundwater. Objectives are used to set limits
and on water quality objectives.. for NPDES discharges and for
narrative and numerical. wbich. discharges to land. Applies to
protect specific beneficial uses. all disposal alternatives for
groundwater treated at the site.
SOLID WASTE DISPOSAL ACf (RCRA)
Identification and Usting of Defines those solid wastes which ARARs (applicable); Applies
Hazardous Waste are subject to regulation as hazard~ to sludge from treatment
ous wastes. process of the selected remedy.
40 CFR Pan 261
Releases from Solid Waste Establishes maximum contaminant ARAR (relevant and
Management Units concentrations that can be released appropriate); The maximum
from hazardous waste units. contaminant concentrations that
40 CFR. Part 264. Subpart F can be released from hazardous
waste units are identical to the
MCLs. Applies to the selected
remedy for treatment of
contaminated soil at the site.
Standards Applicable to Gen. Establishes standards for genera. ARAR (applicable); Applies to
erators of Hazardous Waste tors of hazardous waste. the hazardous wastes (sludge)
generated by the groundwater
40 CFR Pan 262' treatment process.
Standards Applicable to Establishes standards that apply to ARAR (applicable); Applies to
Transponers of Hazardous persons transponing hazardous the off-site transport of sludge
Waste waste within the U.S. if the trans. generated by the groundwater
portation requires a manifesL t~tment process.
40 CFR Pan 263
Continued
SF031594\RNl2..51
8-3
.
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....
Table 8-1
SUIDJD8fy or AltARs and TBCs
Title Descrtptlon Comment
Standards for Owners and Establishes minimum national ARAR (relevant and appropri.
Operators of Hazardous standards which define the accept- ate); Applies to the selected
Waste Treatment., Storage. able management of haurdous remedy for onsite ueatment and
and Disposal Facilities waste for owners and operators of disposal of hazardous waste.
facilities which Ue&t., store, or
40 CFR Pan 264 dispose of hazardous waste.
Standards applicable to IaDd Disposal of aJntaminated soil or ~ (applicable); Applies to
disposal of hazardous waste. debris from CERa.A response onsite and ofl'-site disposal of
action or RCRA aJrrcctive actions hazardous waste generated duro
40 CFR Pan 268 is subject to land disposal prohibit. ing the remedial actions; sped!.
ing and/or ueatment standards. ic:ally the groundwater
treatment process sludges and
tbe treated soils.
HAZARDOUS MATERIALS TRANSPORTATION ACT
49 U.5.c. See. 1801-1813 Regulates transportation of haz- ARAR (applicable); Applies to
ardous materials. off.site transpon of sludge gen.
erated by groundwater treat-
ment process.
CALIFORNIA HAZARDOUS WASTE CONTROL LAWS
Health &. Safety Code. Div. Regulations governing harardous ARARs (applicable); Applies to
20, Chapter 6.5. See. 25100 et waste control; management and management of hazardous
seq. 22 CCR. Div. 4, Chapter aJntrol of hazardous waste facil. wastes from the groundwater
30, Drv. 66001 tl seq. ities; transportation; laboratories; treatment process and the on-
classification of cxtremely harard. site treatment of contaminated
oUSt hazardous. and nonharardous soil.
waste. Generator requiremeD(s;
hauler registration; harardous
waste facility pennits; enforcement
and inspections.
STANDARDS FOR SOLID Sets the minimum requirements ARARs (applicable); Applies to
WASTE HANDLING AND and performance standards for the placement of treated soil
DISPOSAL solid waste handling and disposal on-site.
activities.
14 CCR. Div. 7. Chapter 3,
See. 17020 et seq.
CRITERIA FOR IDENTIFICATION OF HAZARDOUS AND EXTREMELY HAZARDOUS
W ASTES-1HRESHOLD LIMIT CONCENTRATIONS
22 CR. Div. 4. Chapter 30. Promulgated criteria to determine ARARs (applicable); Used to
An. 11, See 6693 et seq. if a material is harardous waste. define wastes that are generated
Includes Soluble Threshold Limit as hazardous. Hexavalent
Concentration (STLCs) and Total Chromium.TJLC.. SOO ppm.
Threshold Umit Concentrations S11£ = 5 ppm; Arsenic. TILC
(TJ1.Cs). = 500 ppm. STLC = 5 ppm;
Copper-TJLC 2.500 ppm.
STLC = 25 ppm.
Continued
SF031594\RP\Ol2.51
8-4
.
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,"-
Table 8-1
SUIlUD8I")' or ARARs and TBCs
Title I Description I Comment
CLEAN AIR ACT
42 U.s.c. See. 7401-7642 Regulates air quality, incinerator ARAR (relevant and appro-
emissions. c:rcavation. priate); The substantive re-
quirements will be met for Air
Pollution Control District rules
for excavation in the selected
remedy for soU treatmenL
CALIFORNIA a..E.AN AIR ACT
Health &, Safety Code. Div. Regulates. both nonvebicular and ARARs (relevant and
26 See. 39000 et seq. vehicular sources of air oontami- appropriate); The Stanislaus
nants in California. Defines rcla- County APCD will set
tionship of the California Air allowable discharge limits for
Resources Board (CARB) and discharges associated with the
local or regional air pollution selected remedies, particularly
oontrol districts (APCD). Estab- emissions of particulate mauer
lishes ambient air quality stan. during soil excavation.
danls. Establishes permit prace-
dures.
FEDERAL OCCUPATIONAL SAFETY AND HEALTH ACT
29 U.S.c. See. 651-678 Regulates worker health and ARARs (applicable);
safety. Requirements of the Act apply
to all remedial alternatives.
CALIFORNIA OCCUPATIONAL HEALTH AND SAFETY ACT
Labor Code. Div. S. See. 6300 Regulations to assure safe and ARARs (applicable); Worker
~r seq. healthy working conditions by safety at the site is regulated by
authorizing the enforcement of Cal-OSHA and federal OSHA
standards and procedures. for all remedial alternatives.
SF031594\R.1'\012.51
8-5
.
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qo
0\
.
t
.
.
Table 8-1
Comparative Analy!!ls or Soil Alternatives
Alternative I Alternative 2 Alternative 3 Alternative 4
I. Overall Protection of Human Health and the Environment
No action would not address Capping would reduce direct Site ronditlons may limit the fixation of rontamlnated solis
remedial action objectives. rontact and surface water runoff feasibility of this alternative as would be protective through
Continued releases of rontaml. risk. Some reduction In ground. In.sltu nushlng may not be fully reduction of mobility. Direct
nants would occur In water mobility would be effective. Overall protection of rontact and Inhalation risk would
exceedence of health and achieved, but the aCllon would human health and environment be reduced, and groundwater
environmental standards. It not be totally protective of 15 uncertain as the action may would be protected.
would not be protective of groundwater. not be totally protective of
public health or the groundwater.
environment.
2. Compliance with ARARs
The No Action Alternative A cap rould be ronstructed to This alternative will romply with This alternative will rom ply with
would not rom ply with federal address ARAR standards. A cap all ARARs unless site ronditlons ARARs.
or slate health and rould meet surface water protec. limit the feasibility of in.sltu
environmental protection Slan- tion ARARs. A cap would not nushlng to achieve groundwater
dards. allow cOmpliance wllh ground. cleanup standards.
water ARARs (MCLs).
3. Long-Term Effectiveness and Permanence
No action would offer no long. Contaminated soils would be left Iii-Situ nushing may not be fully This alternative will be effective
term effectiveness. Site risks onsite. effective for groundwater protec. because fixated soils will either
would remain indefinitely. tion. Treatability studies are meet leaching criteria or be
Less long-term effectiveness required to demonstrate placed In lined cells.
because this alternative does not effectiveness. Long-term Institutional rontrols must be
destroy/remove rontamlnants. effectiveness Is uncertain. maintained.
Continued
SFO:\1594\RP\OI8.51-1
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qo
-.J
.
Table ""1
Comperatl.e An81J!'1" or Soli Altematlva
Altematlye I AltemaUye 1 AllernaUwe J Altematlft ..
4. Reduction of Toxicity, Mobility, or Volume through Treatment
Would not reduce toxicity, mo- Capping would reducc surrace Would direclly reduce the wi. FiDtlon would eliminate leach.
bility. or volume of metals water runoff potential and air ume of hexavalent chromium In ability and mobility of hexavalent
contaminated soli. Alternative dispersion. Some reducllon In soli. Toxlcily of hexavalenl chromium and arsenic In soil.
docs not Include trealment groundwaler mobility pmslble. chromium reduced by transfor. No reduction In 10lfcllY, bUI
No reduclion In toxlclly or vol. mallon to trivalent form. Leach. exposure polenllal would be
ume would be achieved. ability, mobility. and exposure reduced. Volume of soli would
Allernallve does nOI Include potential for arsenic may be Increase due to addition of fixing
trealment reduced. Volume of soli would agenlS.
Increase due 10 addilion of fixing
agents.
S. Shorr.Term Effectiveness
NOI applicable. The Capping would pose leasl risk to Could be performed to be Excavallon and fixation could be
allernallve does not Involve an workers and communily during prolecllve of workers and performed 10 be protective of
aclion. Implemenlalion. Minimal community. Grealer potenllal workers and community. Grealer
amounls or conlaminants would for worker and rommunlty potential for worker and
be handled. exposure due to Increased rommunlly exposure due to
malcrlal handling. Increased material handling.
6. Implemenlabilily
Nol applicable. The Readily implementable. Equip- Moslly implemenlable. Soil Implementable. SOU excavallon
alternalive does not Inwlve an ment and services readily avail. nushlng not expecled to encoun. and fixation available through
action. able. ler any Insurmounlable physical several rompanles.
or lechnlcal difficulties, though
vertical plume capture Is
uncertain. Soil excavation and
flXBllon. available Ihrough several
rompanles.
Continued
srOJIS94\RP\o''',St .2
-------
qo
'00
T.ble 8-2
Comparative An.l)'1ds of Soli Altern.tlves
Altern.llft 1 Alternallve 2 Alternallve J Altern.tlft 4
7. Cmt.
Capital: Primarily Capital: S78JXXJ Capital: SI.232,OOO Capital: 51 .8S3.000
Annual O&M: groundwater Annual O&M: 5138.000 Annual O&M: 521.000 Annual O&M: SO
Pr~ent Worth: monitoring Present Worth: S216.000 Present Worth: $1,323.000 Present Worth: $1.853.000
costs.
presented In
Table 8-3.
Alternative A.
8. State Acceptance
Not acceptable Not acceptable as nnal action. Not acceptahle untIl effective. Acceptable.
The state prefers treatment. ness of In situ nushlng Is proven.
9. Community Acceptance
Not acceptahle. Not acceptable. Not acceptahle until effective. Acceptable.
ness of In situ nWihlng Is proven.
. All costs are presented In January 1991 dollars. Discount rate of 5 percent was used In present worth calculations. Period of performance
(number of years of operation) used in present worth calculations 15 stated separately for each alternative In Section 7.0. AnnualO&M
costs for 30 years of groundwater monitoring are Included .In the groundwater remedial alternatives costs.
.
SFOJI594\RP\018.51-J
-------
00
I
\0
.
Table 1-3
Compa...UYe Analysl! of Groundwater AlternatlYeS
AlternatlYe A Alternath'e R Altematlft Ct and C2
I. Overall Protection of Human Health and Environment
Not protective of public health or the envl- Prolectlon of puhlic heallh and the environ- Protective of public health and the envlron-
ronment. No action would allow rontlnued ment Is uncertain as effectiveness of In situ ment. Extraction would contain the plume.
migration of ronlamlnants downgradlent. chemical treatment Is uncertain at this time. Potential m:ess risk associated with arsenic
Groundwater concentrations exceeding This aCllon may not be tOlally protective of and hexavalent chromium-c:ontalnlng
health slandards would exist Indefinllely. public health as Insufficlenl data exist to groundwater reduced to aa:eptable 1~1s
demonstrate the effectiveness of this technol- through either type of treatment.
og)'. Treatahility studies are required.
2. Compliance with ARARs
Would not romply with ARARs. Pilot-scale testing needed to demonstrate the This alternative will comply with ARARs.
ahllity of this alternative to achieve full
rompliance wllh ARARs for groundwater.
J. Long-Term Effectiveness and Permanence
Would not be effective In Ihe long term. Long-Ierm effectivenc.~ Is uncertain as this Potential excess risk reduced over period of
Potential excess risk as.~laled wilh Inges- technology Is slillin experimental phases time (minimum of S years) 10 acceplable
tion and dermal rontaet wllh hexavalent and Insufficlenl dala exist 10 demonstrate Its 1~1s. ' Effective and permanent In the long
chromium and arsenic rontalning ground- effecllveness. term. Extraction and treatment of ground-
water would remain. water would pr~nt the migration of dis-
solved consilluents 10 polentlal offslte
, receptors and Indirectly oonlaln hexavalent
. chromium 'and arsenic leached from soli.
4. Reducllon of Toxicity, Mobility, or Volume through Treatmenl
No reducllon In ell her loxlclty of mobility of Hexavalenl chromium and arsenic concentra- Hexavalent chromium and arsenic concen-
oontamlnants. Volume of hexavalent chro- lions In groundwater would decrease. Toxic- trallons In groundwater would decrease.
mlum and/or arsenic oontainlng ground- Ily and volume or water would decrease Toxicity and volume of water would
water would Increase due to dispersion. oorrespondlngly. Mobility limited by decrease oorrespondlngly. Mobility limited
Allernatlve does not Indude trealment. hydraulic conlrol. by hydraulic oontrol.
Conllnued
SfOJIS94\RP\020,SI.1
-------
qo
.....
o
.
Table 8-J
Comparative Analr.'lls or Groundwater AlternaUvn
Alte~8t1ve A Alternative R AlternaUve ct and C2
S. Short-Term Errcctlvene5.'i
Not applicable. No action Is taken. The extraction and treatment pr0ce5S could The extraction and treatment process oould
be oonstructcd and operated to be protective be constructed and operated to be pro tee-
of human health and the environment. Hy- tive of human health and the environment.
draullc containment could prevent exposure
to oommunity during implementation. Over-
all errectlveness of In situ chemical treatment
Is unknown.
6. Implementabllity
Not applicable. No remedy implemented. Implementation technically and admlnistra. Implementation technically and administra-
tively feasihle. Pilot test will be required to tIvely feasible. Proposed remedial teehnolo-
demonstrate applicability to site-specific gles are proven and readily available. Solid
conditions and effectiveness of remedy. wastes containing chromium and arsenic
Solid wastes containing chromium and arsen- must be handled In accordance with state
ie must be handled in aa:ordance with state and federal regulations.
and federal regulations.
7. Cost-
Capital: S~9,OOO Capital: $254,000 Alternative <::1
Annual O&M: $77,000 Annual O&M: S24S.0nO Capital: $177,000
Present Worth: $ 1,22-'.(0) Present Worth: S I,R95.000 Annual O&M: $224,000
Present Worth: Sl,m,OOO
Alternative C2
Capital: $369,000
Annual O&M: 5396,000
Present Worth: $2,934,000
Continued
SFOJtS94\Rr\020.SI.2
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qo
....
....
.
Table 8.3
Comparallve Analysis 0' Grounchrater Alternatlmt
Alternallve A Alternallve 8 Alternative Ct and C2
8. State Acceptance
Not acceptable. Not acceptable until effectiveness of techno- Alternatives CI and C2 are acceptable.
logy I~ proven for thi~ site.
9. Community Acceptance
Not acceptable. Not acceptable until effectiveness of techno- Alternatl\oa CI and C2 are acceptable.
logy Is proven for this site.
. All CO!iIS are presented in January 1991 dollars. DI~unt rate of 5 percent was u.~ In present wonh calculations. Period of performance
(number of years of operation and maintenance Including groundwatcr monitoring) used In present wonh calculallons Is stated separately
fur each alternative In Section 7.0.
SfOJIS94\RP\020.SI.)
-------
Table 8-4
REMEDY SELECI10N SUMMARY
Alternative Selection Assessment
SoU . . . . ..
.' " ..
Alternative 1: No Action Not protective
Does not comply with ARARs
No TMV reduction; no treatment
Not acceptable to state or community
Alternative 2: Capping Not protective of groundwater
Does not comply with groundwater ARAR.s
No long-term. effectiveness
Some reduction in mobility; no reduction in. toxicity and volume; no
treatment
Least cost
Not acceptable to state or community
Alternative 3: In-Situ May not be totally protective of groundwater
Rushing. Excavation. May not achieve full compliance with groundwater ARARs
Fixation. and On-Site Long-term effectiveness uncertain
Disposal Reduction in toxicity and mobility; increase in volume
Lower cost than Excavation. Fixation. and On-site Disposal
Not acceptable to state or community unless its effectiveness is proven
Alternative 4: Protective
Excavation. Fixation. and Complies with ARARs
On-Site Disposal Provides long-term effectiveness with institutional controls
Reduces mobility; increase in soil volume
Highest cost
Acceptable to state and community
Groundwater
Alternative A:. No Action Not protective
Does not comply with ARARs
No TMV reduction; no treatment
Not effective
Not acceptable to state or community
Alternative B: In-Situ May not be fully protective (pilot testing needed to prove full
Chemical Treatment and protectiveness)
Hydraulic Control May not fully comply with groundwater ARARs (pilot testing needed
to eliminate uncertainty)
Long-term effectiveness uncertain
Reduction in TMV
Pilot test required before full-scale implementation
Least cost among treatment alternatives
Not acceptable to state or community unless site-specific technology
effectiveness is proven
Continued
SF031S93\RP\OO7A.Sl
8-12
.
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Table 8-4
REMEDY SELEC110N SUMMARY
Altemathe Selection Assessment
Alternative Cl: Protective
Groundwater Extraction. Complies with ARARs
EJearoc:bemic:al Effective and permanent in long term
Treatment, and Activated Significant TMV reduction
Alumina Adsorption Medium c:ost
Acceptable to state and the community
Alternative C2: Protective
Groundwater Extraction. Complies with ARARs
Chemical ReduaioD/ EffeaiYe and permanent in long term
Precipitation. and Significant TMV reduction
Activated Alumina Highest cost
Adsorption Acceptable to state and community .
SF031593\RP\OO7A.51
8-13
.
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8.3.1 SOIL
Alternatives Assessed
1.
No Action (No Action)
2.
Capping (Capping)
3.
In-Situ Flushing, Excavation, Fixation, and On-Site DisposaJ (Flushing)
4.
Excavation, Fixation, and On-Site Disposal (Fixation) .
Criteria Assessment
Overall Protection of Human Health and the Environment. No Action would not be
protective of human health or the environment; continued releases of site contaminants
into the environment would occur. Capping would prevent direct' contact and
inhalation and reduce surface water runoff risk; but it would only be partially protective
of groundwater and would leave groundwater and soil contamination on-site. . Flushing
may not be totally protective of groundwater, as site conditions may limit the feasibility
of this alternative. Fixation would be protective of human health and the environment.
Compliance with ARARs. No Action would not comply with federal and state ARARs.
Capping of soils would not address groundwater protection ARARs. Flushing may not
achieve full compliance with groundwater ARARs. Fixation would achieve full
compliance with the ARARs.
Long-Term Effectiveness and Pennanence. No Action would not offer any long-term
effectiveness. Capping could remain effective for preventing surface exposure as long
as the cap were maintained. Capping would not provide long-term protection of
groundwater. Long-term effectiveness for Flushing is uncertain, as it may not be fully
effective for groundwater protection. Long-term effectiveness for Fixation would be
dependent on the long-term maintenance and monitoring of the fixed-soil mass and
liner system used to control leachate. If implemented properly and institutional
controls are. maintained, Fixation is expected to provide long-term effectiveness.
Reduction or Toxicity, Mobility, or Volume (TMV) through Treatment. No Action
would not achieve a TMV reduction. Capping would reduce surface mobility but very
little groundwater mobility. Flushing would reduce toxicity and mobility but would
increase volume of treated soil. Fixation would reduce mobility through treatment and
containment No reduction in toxicity would occur and volume of soil would increase
due to the addition of fixing agents.
Short-term Effectiveness. All alternatives could be implemented to be protective of .
workers and the community during remedial action. Capping would pose the least risk
during implementation, as minimal amounts of contaminants would be handled.
SF031 S94\RP'OO7 oS 1
8-14
.
-------
Implementability. AU alternatives are implementable, and equipment and services are
readily available.
Cost. No Action would cost $1.223 miJJion, primarily for groundwater monitoring;
Capping would cost $216,000; Flushing would cost $1.323 million; and Fixation would
cost $1.853 million (present worth costs).
State Acceptance. No Action and Capping would not be acceptable to the state.
Aushing would not be acceptable until its effectiveness is proven for the site. Fixation
would be the most acceptable alternative.
Community Acceptance. No Action and Capping would not be acceptable to the
community. Aushing would not be acceptable until its effectiveness is proven for the
site. Fixation would be the most acceptable alternative.
Remedy Selection Rationale
EP A has selected Excavation, Fixation, and On-Site Disposal as the remedy for soils.
This alternative best protects human health and the environment and is the only
alternative that complies with all ARARs. Even through it is more costly than
Aushing, Fixation is more effective and is more acceptable to the state and the
community because soil flushing is completely unproven at this site and site conditions
may limit its feasibility.
8.3.2 GROUNDWATER
Alternatives Assessed
A
No Action (No Action)
B.
In-Situ Chemical Treatment, and Hydraulic Control (In-Situ Treatment)
C1.
Groundwater Extraction, Electrochemical Treatment, and Activated Alumina
Adsorption (Electrochemical Treatment)
C2.
Groundwater Extraction, Chemical Reduction/Precipitation, and Activated
Alumina Adsorption (Chemical Reduction)
Criteria Assessment
Overall Protection of Buman Health and the Environment. No Action would not be
protective of human health or the environment. In-Situ Treatment may not be totally
protective of human health, as insufficient data exist to demonstrate the effectiveness of
this technology. Both Electrochemical Treatment and Chemical Reduction would be
protective of human health and the environment and would contain the plume.
SF031594\RN)()7.s 1
8-15
.
-------
Compliance with ARARs. No Action would not comply with ARARs. . In-Situ
Treatment may not fully comply with groundwater ARARs. Both Electrochemical
Treatment and Chemical Reduction could be implemented to comply with ARARs.
Long-Tenn Effectiveness and Perfonnance. No Action would not be effective in the
long term. Long-term effectiveness for In-Situ Treatment is uncertain, as this
technology is still in experimental phases. Both Electrochemical Treatment and
Chemical Reduction would provide long-term effectiveness and performance through
extraction, remova~ destruction of contaminants. and long-term containment of
residuals.
Reduction of Toxicity, Mobility, or Volume through Treatment. No Action would not
result in a reduction in TMV through treatment. Reduction in TMV would occur by
any of the other three alternatives: In-Situ Treatment, Electrochemical Treatment, or
Chemical Reduction.
Short-Term Effectiveness. AU action alternatives could be implemented to be
protective of workers and the community during implementation.
Implementability. All action alternatives are implementable. However, for In-Situ
Treatment, a pilot test to demonstrate applicability to site-specific conditions and
effectiveness of remedy will be required before full-scale implementation.
Cost. No Action would cost $1.223 million, primarily for groundwater monitoring. In-
Situ Treatment would be the least expensive of all treatment alternatives
($1.895 million). Electrochemical Treatment would cost $1.997 million. Chemical
Reduction would be the most costly alternative, $2.934 million (all costs reported as
present worth).
State Acceptance. No Action would not be acceptable to the state. In-Situ Treatment
would not be acceptable until effectiveness of technology is proven for this site. Both
Electrochemical Treatment and Chemical Reduction would be acceptable to the state.
Community Acceptance. No Action would not be acceptable to the community. In-
Situ Treatment would not be acceptable until effectiveness of technology is proven for
this site. Both Electrochemical Treatment and Chemical Reduction would be
acceptable to the community.
Remedy Selection Rationale
EP A has selected Electrochemical Treatment as the remedy for groundwater because
it is more protective and effective than No Action or In-Situ Treatment and as
protective and effective as Chemical Reduction. However, Electrochemical Treatment
is less costly than Chemical Reduction.
SF031S94\RP\OO7.51
8-16
".
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Section 9.0
SELECTED REMEDIES
.
-------
,--
Section 9.0
SELECTED REMEDIES
The foIlewing text presents the selected remedies for contaminated soil and
groundwater. Both remedies will be performed to address either 1 x 1~ or greater
cancer risk level, greater than a Hazard Index of 1 for noncarcinogenic risks or
background (nondetCCt) levels where achievable.
9.1 REMEDY FOR CONTAMINATED SOILS
, Remedy Description
For contaminated soils, EPA plans to excavate the soil, fix 'it with a cement-based -
compound, and maintain the mixture on-site to prevent future exposure or movement.
For this remedy to be implemented, surface soil (0 to 4 feet) containing hexavalent
chromium and arsenic at 4 ppm and 2 ppm, respectively, must be excavated and fixed.
Subsurface soil (4 feet to groundwater) with leachate concentrations above 5 ppb for
chromium and arsenic, respecrively, would also be excavated and fixed. Fixed soil
exceeding CCR Title 221TLCISTLC and Title 23, Chapter 15 criteria would be placed
in lined cells. Fixed soil meeting 1TLCISTLC and Title 23 criteria would be placed
back onto the site.
Excavation wiIl be performed using conventional earthmoving equipment. The
excavated soil wiIl be blended with commercially available chemical stabilizing agents
(such as Portland Cement) in mixing equipment similar to a concrete batching plant.
The agents and the mix ratio will be based on treatability studies performed using site
soils. The fixed-soil matrix will be used to backfill the excavation. A liner- below the
fixed soil would be required for soils containing arsenic greater than 500 ppm,
chromium greater than 500 ppm, and copper greater than 2,500 ppm (California Title
22 TILe criteria). A liner would also be required if leachable arsenic and chromium
exceed 5 ppm and copper 25 ppm (California Title 22 STLC criteria). Collection,
handling, and disposal of leachate and long-term monitoring are required to comply
with State and Federal regulations. Deed restrictions are required for all areas where
treated waste has been deposited.
It is estimated that approximately 15,000 cubic yards of contaminated soil will be fIXed
with this remedy. Remedial objectives are estimated to be achieved in approximately 9
months, if remedial actions are done continuously. Capital and present-worth costs
have been estimated at $1,853,000 (January 1991 doIlars; see pages 7-1 and 7-4).
Annual operation and maintenance costs, primarily for groundwater monitoring for the
entire on-site and off-site areas not directly related with fixation, are included in the
remedy for contaminated groundwater (Section 9.2).
SF031594\RP\Ol3.51
9-1
..
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Remedy Selection Rationale
The selected remedy satisfies the two threshold criteria (overall protection of human
health and the environment and.compliance with ARARs), provides the best balance of
the five balancing criteria (long-term effectiveness and permanence; reduction in
toxicity, mobility, or volume through treatment;. shon-term effectiveness;
implementability; and cost). This alternative uses permanent solutions and an
alternative technology or resource recovery to the maximum extent practicable. This
alternative, compared with the other remedial alternatives, provides the most overall
protectiQD, most fully complies wth ARARs, and has the best long-term effectiveness.
It also permanently reduces the mobility of the contaminant. Even though this
alternative is associated with the highest cost, it is cost-effective, as it provides the
highest level of effectiveness for a reasonable cost. The selected remedr also has the
strongest state and community acceptance.
The objectives of the remedy for contaminated soils are to prevent surface-water runoff
of contaminated surface soils, to prevent air emissio~ of contaminated dusts, and to
prevent contaminants from leaching into the groundwater, which is a drinking water
aquifer at this site. Based on information obtained during the remedial investigation
and on a careful analysis of all remedial alternatives, EP A and the State of California
believe that the selected remedy will achieve these goals through proper
implementation and monitoring of the action. The selected soil remedy will be coupled
with groundwater extraction and treatment. The removal and treatment of
contaminated soils may significantly reduce the time required for extraction and
treatment of groundwater contaminated with inorganic compounds. The point of
compliance will be all site soils from the surface to the water table that contain
contamination above the cleanup standards.
Periodic groundwater, surface water runoff, and air quality monitoring and sampling of
leachate will be required to determine the effectiveness of this remedy and to verify
achievement of cleanup levels. Long-term operation and maintenance (O&M)
activities for the treated soil mass, institutional and engineering controls, and their cost
estimates will also be required for a period of 30 years. Such requirements and a
specific monitoring program will be defined more precisely during the Remedial
Design/Remedial Action (RD/RA) phase.
Overall protection of human health and the environment was the most important
criterion in selecting the soil remedy. The selected remedy was the only alternative
which satisfied this threshold criterion.
ARARs
The selected remedy will comply with ARARs. Health-based ARARs pertaining to soi I
contaminated with inorganic compounds are not available for the site. The soil
contamination will therefore be reduced to the health-based standards discussed in
SF031S94\RP\013.51
9-2
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Section 4.0 that eliminate threats to public health and the environment through surface
water, groundwater, and air.
Surface soil (0 to 4 feet) will be excavated to 1 x 10~ excess cancer risk level (4 ppm
for hexavalent chromium and 2 ppm for arsenic). Subsurface soil (from 4 feet below
surface to groundwater) will be excavated to levels that will meet California Regional
Water Quality Control Board Designated Level Methodology leachability limits (5 ppb
for chromium and arsenic). The soils will be treated to reduce leachability to levels
that remain protective of the groundwater resource.
Treated soils will be placed as necessary in treatment cells designed to meet Federal
and State land disposal requirements. The treatment technology used will reduce
leachability of contaminants to below the RCRA land disposal requirements. Once
treated, the soil will no longer be a hazardous waste as long as leachability of the fixed
soil meets the treatment standards. .
9.2 REMEDY FOR CONTAMINATED GROUNDWATER
Remedy Description
For contaminated groundwater, EP A has selected the remedy involving extraction,
electrochemical treatment, activated alumina adsorption, and discharge. Groundwater
will be treated to achieve EP A cleanup standards before reuse or discharge from the
site. EP A plans to use an electrochemical treatment process, similar to that currently
used at the site for groundwater treatment to remove dissolved hexavalent chromium
followed by activated alumina adsorption to remove residual dissolved arsenic.
Extracted groundwater would be transferred to a holding tank. Ferrous ions from the
ferrous ion generator would be injected continuously into the water transfer piping
where mixing would occur. The reduction of hexavalent chromium to its trivalent form
would occur in the piping and in the holding tank. The reduced chromium would
precipitate out in the holding tank. The effluent from the electrochemical treatment
process would then be transferred to an alumina-adsorption column for secondary
treatment to remove residual arsenic.
Groundwater treated to health-based standards will be disposed of through one or both
of the following means: (1) infiltration and evaporation at one or more percolation
ponds, and (2) underground injection through subsurface injection weUs. The
treatment process will generate sludge containing elevated. metal concentrations that
will be disposed of at an off-site waste disposal facility in accordance with state and
federal regulations. Disposal details will be defined further during the RD phase, and
EP A will work closely with all appropriate state and local agencies on this issue before
disposal is carried out during RA.
This groundwater alternative will reduce contaminants to the cleanup standards listed in
Table 4-1. Chromium in groundwater will be cleaned up to 50 ppb, which is the
SF031594\RP\013.51
9-3
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California MCL, and arsenic in groundwater will be cleaned up to 16 ppb,
corresponding to a Hazard Index of less than 1. Both of these concentration levels
correspond to those that will reduce the Hazard Index to less than 1. Point of
compliance for the remedy will be the entire aquifer below the site and downgradient,
as defined by the arsenic and chromium plumes. Continued definition of the plume
extent and compliance with the groundwater standards will be demonstrated through a
network of monitoring wells. The remedy will treat all contaminants to their treatment
standards. .
Groundwater extraction and treatment is estimated to be at a rate of approximately
250 gallons per minute, corresponding to about 360,000 gallons per day. It is uncertain
how long it will take to achieve the remedial objectives; howeVer, is estimated to take
at least 5 years. Capital costs have been approximated at $177,000. Annual operation
and maintenance costs are estimated at $224,000 ($147,000 for remediation and $77,000
for groundwater monitoring). The present worth of this remedy is estimated at
$1,997,000, based on a discount rate of 5 percent and period of operation of 5 years
and groundwater monitoring for 30 years. All costs reponed are in January 1991
dollars.
At the time of development of this ROD, the existing groundwater treatment plant
does not have the activated alumina-adsorption column, has not run in a continuous
mode, has not been tested at design capacity, and the effectiveness of the facility in
removal of metals has not been fully demonstrated. EP A will allow one year from
initiation of Remedial Design to modify the facility and treatment scheme to achieve
the standards presented in Table 4-1. Facility performance requirements will be
specified in the Scope of Work.
Remedy Selection Rationale
The selected remedy provides the best balance of the two threshold criteria and the
five balancing criteria. This alternative uses permanent solutions and alternative
technologies to the maximum extent practicable. The in-situ chemical treatment
alternative is not considered to be fully protective and complying with groundwater
ARARs because of the uncertainty associated with its long-term effectiveness. The
remaining two groundwater extraction and treatment alternatives are very similar in all
evaluation criteria, except for cost. The selected remedy is more cost-effective than the
alternative involving chemical reduction. The selected alternative provides the best
long-term and short-term effectiveness; permanently and significantly reduces the
toxicity, mobility, and volume of hazardous substances through treatment; and can be
. implemented at the site at substantially lower cost than the treatment alternative
involving chemical reduction/precipitation. The selected remedy employs treatment as
a principal element that significantly and permanently reduces toxicity, mobility, or
volume of the hazardous substances. It is protective of public health and the
environment, complies with federal and state ARARs, and is cost-effective.
SF031S94\RNJ13.5 1
9-4
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The objective of this remedial alternative is to restore groundwater to its beneficial use,
as a drinking water source for this site and vicinity. Based on information obtained
during the remedial investigation and on a careful analysis of all remedial alternatives,
EP A and the State of California believe that the standards required by the selected
remedy will achieve this objective. The selected remedy will require contaminated soil
removaJ and treatment to achieve this objective in a timely manner. The selected
remedy is expected to take at least 5 years to accomplish. The system will be adjusted
as warranted by the performance data collected during its operation.
Periodi~ groundwater monitoring will be required to determine the effectiveness of the
remedy and to verify achievement of the cleanup standards. Long-term O&M
activities, institutional and engineering controls, and their costs will be required. Such
requirements and a specific monitoring program will be defined precisely as the Scope
of Work is developed.
ARARs
This alternative will comply with federal and state applicable or relevant and
appropriate requirements.
The groundwater remediation and treatment standards selected for the groundwater
remedy are presented in Table 4-1. These standards were selected by the process
descnbed below. In accordance with Section 300.430(e) of the NCP, federal MCLGs,
where promulgated, were initially selected as the treatment standards. In the event
that the MCLG has been set at a level of zero, then the federal MCLs, where
promulgated, or .the 1 x 10~ risk or Hazard Index of 1 was selected. In the event that
a more stringent MCI.. has been promulgated by the State of California, then the state
MCL was selected as the treatment standard. The selected remedy will achieve the
treatment standard in the entire aquifer below the site and vicinity and in the effluent
discharged from the treatment unit.
For hexavalent chromium, the treatment standard of 50 ppb represents the California
MCL It also represents the level at which the Hazard Index is reduced to less than 1.
For arsenic, the treatment standard of 16 ppb represents the level at which the Hazard
Index is reduced to less than 1. This level was selected instead of the MCL as it
(16 ppb) is more protective. These contaminants were detected in groundwater at
levels exceeding their treatment standards.
The treatment technology used in the selected remedy will treat contaminated
groundwater to nonhazardous waste levels, and the groundwater will no longer be
subject to regulation under Subtitle C of RCRA.
SF031S94\RNll3.51
9-5
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9.3 CONCLUSION
Both remedies identified in this ROD will reduce the residual risk for each contaminant
in soil and groundwater at the site to less than Ix IO~ risk or a Hazard Index less than
1. The remedies, mentioned in the preceding sections, may need to be modified as a
result of the remedial design and construction process. The changes may reflect
alterations made during the remedial design phase and will be performed so that
standards stated in Table 4-1 WIll be met and the remedies will remain protective ,and
effective.
SF031S94\RP\013-S1
9-6
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Section 10.0
STATUTORY DETERMINATIONS
..
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Section 10.0
STATUTORY DETERMINATIONS
The selected remedies satisfy the two threshold. criteria and provide the best balance of
the five balancing criteria.
The selected remedies are protective of human health and the environment as required
by Section 121 of CERCLA. Existing or potential risks from exposure to soils and
groundwater will be eliminated, reduced, and coIitrolled by treating contamination,
stabilizing contamination, and containing contaminants. Remedial objectives will re-
duce excess cancer risks to 10. when possible (if background levels of chemicals do not
exceed this risk level), which is within the 10'" to 10. risk range. Risks from noncarcin-
ogens will be reduced to Hazard Indices of less than one. AU contaminants of concern '
will be addressed by the proposed remedies. During the implementation of the reme- '
dies, engineering controls such as dust control measures will be employed to ensure
against unacceptable short-term risks or cross-media impacts.
The remedies selected will comply with ARARs. The remedies selected will meet Safe
Drinking Water Act MCLs and the California D1SC Applied Action Levels for drink-
ing water for contaminants of concern.
The remedies for contaminated soil will comply with Federal and State Land Disposal
Restrictions. Concentrations of contaminants within leachate generated from the waste
will be handled in compliance with with 40 CFR 268 and CCR Title 23, Division 3,
Chapter 15. The treatment technology used will reduce leachability of contaminants to
below the- RCRA land disposal requirements. Once treated, the soil will no longer be
a hazardous waste as long as leachability of the fIXed soil meets the treatment stan-
dards.
The remedy for groundwater will comply with the state's well installation regulations,
water treatment facility siting and operation 'regulations, and worker protection regula-
tions.
The discharge of treated effluent will comply with ARARs and TCBs, as described
more fully in Section 9.0.
During implementation of the remedies, the substantive requirements of the Stanislaus
County Air Pollution Contro] District will be met. .
The aforementioned protectiveness and compliance with environmental requirements
will be achieved cost effectively. The alternatives chosen are the cost-effective,
approaches available to achieve the necessary degree of protectiveness.
SF031S94\RNl17.51
10-1
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The selected remedies use permanent solutions and alternative technologies to the
maximum extent possible and satisfy the statutory preference for remedies that employ
as a principal element treatment that reduces toxicity, mobility, or volume.
The cleanup standards defined in this ROD are subject to reevaluation with respect to
effectiveness in protecting human health and the environment at the 5-year review
period.
10.1 CONTAMINATED SOILS
The proposed remedy, Excavation, Fixation and On-Site Disposal, will be protective
through containment of the metals in the fixed-soil mass. This alternative will involve
treatment to reduce mobility. Toxicity and volume will not be reduced. Short-term
effectiveness will be maintained through strict environmental controls. The alternative
is implementable using standard equipment and mat~rials.
The No Action alternative would not be protective because contaminants would con-
tinue to be released into groundwater, surface water runoff, and in airborne dust.
The Capping alternative would be only partially protective of groundwater. Mobility
into groundwater would remain a concern.
The In-Situ Flushing alternative may be only partially protective of groundwater, as site
conditions may limit the feasibility of this alternative.
10.2 CONTAMINATED GROUNDWATER
The groundwater remedy, Extraction followed by Electrochemical Treatment and Acti-
vated Alumina Adsorption, will be a permanent solution because the contaminants will
be destroyed or removed from the groundwater. The groundwater remedy is expected,
to take at least 5 years to achieve treatment standards. Significant reduction in TMV
will occur. The alternative is implementable using re'adily available equipment and
materials. '
The No Action alternative would not be protective because contaminants would con-
tinue to remain in the groundwater.
The In-Situ Chemical Treatment alternative may be only partially protective of human ..
health and the environment, as insufficient data exist to demonstrate the effectiveness
of this technology.
The Chemical Reduction/Precipitation alternative offers the same TMV and risk reduc-
tion benefits and effectiveness as the selected groundwater remedy. However, it is
more expensive than the selected remedy, and therefore not as cost-effective.
SF031S94\RP'DJ7.5J
10-2
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Sectiori 11.0
DOCUMENTATION OF
SIGNIFICANT CHANGES
.
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I.
I
Section 11.0
DOCUMENTATION OF SIGNIFICANT CHANGES
Subsurface soil cleanup standards for hexavalent chromium and arsenic at the site have
been revised since the issuance of the Proposed Plan. The revised cleanup standards
for each of these two chemicals are 5 ppb in leachate for subsurface soils (4 feet to
groundwater). These standards are based on recommendations by the California Cen-
tral Valley Regional Water Quality Control Board (CRWQCB). According to their
recommendations, their June 1989 updated staff report "The Designated Level Method-
ology for Waste Qassification and Qeanup Level Determination" was used to calculate
the Soluble Designated Levels, thus determining soil cleanup levels on the leachable
concentrations, assuming an attenuation factor of 1, due to the presence of hexavalent
chromium and arsenic in the groundwater and the limited attenuation of the existing
on-site contaminated soils. Thus the revised cleanup standards of 5 ppb of hexavalent
chromium and arsenic in leachate for subsurface soils are Soluble Designated Level
Methodology concentrations, and are based on CR WQCB guidance on whether a waste
poses a threat to beneficial uses of the groundwater. .
SF031594\RN)19.51
11-1
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Appendix A
RESPONSE SUMMARY
.
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RESPONSES~Y
The PropOsed Plan for the Valley Wood Preserving (VWP) site was issued to the
public on June 17, 1991. This Proposed Plan descnbed EPA's preferred remedial
alternatives for contaminated soils and groundwater at .the site. During the public
comment period, which extended from June 17 through July 17, 1991, EP A briefed
concerned citizens and state and local officials on the Proposed Plan at a public
meeting (June 25, 1991).
SUMMARY OF COMMENTS RECEIVED
During the public comment period, EP A received comments from tWo individuals
within the local community, from the Central Valley Regional Water Quality
Control Board, the California Department of Toxic Substances Contro~ and from
the potentially responsible parties. Comments pe~ining to elements of the
Proposed Plan and EPA's responses to the comments are summarized below.
A.
COMMENTS FROM COMMUNl1Y MEMBERS
Commentor: Resident of Community No.1
Date: June 25, 1991
1.
Comment:
The commentors raised questions about backfill and fence replacement during off-
site excavations.
1.
Response:
All soH excavated from off-site areas will be replaced with clean soH and if
excavation requires fence removal, the fence will be replaced by Valley Wood
Preserving.
2.
Comment:
The commentors state that additional extraction wells on their property should be
placed so as to protect their livestock. .
1
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2
Response:
EP A agrees. EP A will direct VWP, Inc. to conduct all remedial design/remedial
action activities associated with the site in a manner that minimizes inconveniences
to neighboring residences and is protective of private property, including livestock.
3.
Comment:
The commentors state that they prefer reinjection and percolation ponds, rather
that irrigation, as disposal options for treated groundwater.
3.
Response:
Onsite reinjection and/or percolation ponds are the only disposal options for treated
groundwater selected in the Proposed Plan. Turlock Irrigation District has
. expressed several concerns regarding potential discharge of the treated groundwater
from VWP into its system; therefore, EP A would further explore this optjon only if
reinjection/percolation were ineffective.
Commentor: Resident of Community No.2
Date: June 25, 1991
1.
Comment:
The commentor expressed concern about movement of contaminants from VWP in
the air and ~oundwater, and potential adverse health effects.
1.
Response:
According to data gathered during the Remedial Investigation/Feasibility Study
(RIIFS), the prevailing wind direction at the VWP .site during most of the year is to
the north-northwest; from December through February, the prevailing wind
direction is to the southeast. The commentor's given address, south of VWP, is
upwind most of the year and the soils which could pose health threats through
blowing dust have been paved since 1976. The groundwater plume is moving to the
southwest and appears to be approximately 1,000 feet cross-gradient from the
commentor's well; analyses of samples from this well have never detected VWP site
contaminants. Therefore, based upon data obtained to date, no adverse health
effects are expected to have occurred at this residence from VWP site contaminants
through the air or groundwater pathways. The Proposed Plan recommends a site
remedy that will prevent potential adverse health effects through these exposure
pathways in the future. .
2
.
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B.
COMMENTS FROM STATE AGENCIES
Commentor: Antonia KJ. Vorster, Central Valley Regional Water Quality
Control Board (CVRWQCB)
Date: August 9, 1991 -
1.
Comment:
The commentor states that Title 23 of the California Code of Regulations (CCR),
Chapter 15, is an Applicable or Relevant and Appropriate Requirement (ARAR)-
for alternatives that leave contaminated soils onsite.
1.
Response:
EP A concurs. CCR Title 23, Chapter 15 will be added to the FS and included in
the Record of Decision (ROD). .
2.
Comment:
The CVRWQCB considers the Safe Drinking Water & Toxic Enforcement Act
(proposition 65) to be a site ARAR.
2.
Response:
EP A has performed a thorough evaluation of Proposition 65 or the Safe Drinking
Water and Toxic Enforcement Act of 1986 (the Act) and the regulations
implementing it (CCR Title 22 Section 12000 et. seq.), and has determined that the
Act is not an ARAR for this site for the following reasons. CCR Title 22, Section
12701, paragraph (a) clearly allows EPA to use discharge standards other than
those presented in the regulation. This paragraph states, "Nothing in this article
shall preclude a person from using evidence, standards, risk assessment
methodologies, principles, assumptions or levels not descnbed in this article to
establish that a level of exposure to a listed chemical poses no significant risk."
EP A has performed a risk assessment meeting the requirements of CCR Title 22,
Section 12721, and has determined that EP A's standards pose "No Significant Risk"
as intended under this regulation.
EP A's identification of an alternative standard is also supported by Proposition 65
Title 22 regulations. Section 12703, paragraph (b) states,
For chemicals assessed in accordance with this section, the risk level which
represents no significant risk shall be one which is calculated to result in one
excess case of cancer in an exposed population of 100,000, assuming lifetime
3
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exposure at the level in question, except where sound considerations of
public health support an alternative level. as for example. where a clean-up
and resultin~ discharge ordered and supervised by an appropriate
eovernmental agen~ or court of competent jurisdiction (emphasis added).
As the lead agency for the VWP site, EP A clearly can select health-based standards
using other standards and considerations that are protective of human health and
the environment.
EP A has discussed Proposition 65 issues with California Health and Welfare Agency
personnel (the Health and Welfare Agency is the administering Agency for
Proposition 65) and has been informed that Proposition 65 was not intended. to
establish clean-up levels or discharge limitations for hazardous waste site remedial
actions. They cited CCR Title 22, Article 4 (Discharge), Section 12401 (Discharge
of Water Containing a Listed Chemical at Time of Receipt) in making this
statement. Section 12401 (b) states:
Whenever a person otherwise responsible for the discharge or release,
receives water containing a listed chemical from a source other than a source
listed in subdivision (a), [subdivision (a) specifies a drinking water supply in
compliance with aU primary drinking water standards, which is not the case.
for this site], the person does not "discharge" or "release" within the meaning
of the Act to the extent that the person can .show that the listed chemical
was contained in the water received, and "discharge or release" shall apply
only to that amount of the listed chemical derived from sources other than
water, provided that:
The water is returned to the same source of water supply, or
(1)
(2)
The water meets aU primary drinking water standards for the
listed chemical or, where there is no primary drinking water
standard, the water shall not contain a significant amount of
the chemical.
Therefore, treated water that is reinjected or directed to the percolation ponds,
which both meets the standards presented in 12401 (b )(2) and will ultimately be
returned to the same source of water supply as stated in 12401 (b)(l) does not
constitute a discharge or release under Proposition 65.
In summary, it is EP A's goal to return the site aquifer to its greatest beneficial use
and to reduce the residual risk at the site to health protective levels. All discharges
from the site will be performed to standards identified in the Record of Decision
that are protective of human health and the environment and will pose no
significant risk. Because EP A goals and standards are consistent with Proposition
65, Proposition 65 is not an ARAR for this site.
4
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Finally, the communication requirements of Proposition 65 duplicate or are not
more stringent than Federal standards and are not an ARAR for this site.
3.
Comment:
The commentor has provided a list of ARARs considered by the CVR WQCB to be
" pertinent to the VWP site.
3.
Response:
EP A has included in the ROD the appropriate requirements from this list for "the
VWP site, and has directed VWP, Inc. to amend the FS in the same way. It should
be noted that state standards or criteria that are less sttingent than federal
standards or criteria for the same contaminant are not considered ARARs. State
Action Levels are "To Be Considered" (TBCs) criteria, if needed to protect public
health; they are not enforceable standards and therefore, are not ARAR$.
4.
Comment:
Potential ARARs and TBCs for hexavalent chromium and arsenic in the" FS should
be revised to include the Designated Waste Methodology (and others "already
discussed above).
4.
Response:
EP A agrees that the Designated Waste Methodology should be included in the FS
and the ROD as a TBC in developing soil cleanup levels.
s.
.
Comment:
The commentor recommends that the target zone for cleanup of soil contaminated
with hexavalent chromium should be to the top of the groundwater table, rather
than to 7 feet below surface, as stated in the FS.
s.
Response:
EP A agrees. The ROD defines subsurface soils to be those from 4 feet to the top
of the groundwater table, with leachate containing hexavalent chromium or arsenic
above 5 parts per billion (ppb).
6.
Comment:
The commentor disagrees with the soil cleanup levels defined in the FS. She
recommends using the Soluble Designated Levels calculation to determine
subsurface soil cleanup standards.
5
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6.
Response:
EP A agrees. The FS will be amended to include this calculation, which is
incorporated within the Designated Waste Methodology, and EP A has used it in
setting the ROD standards for subsurface soils: 5 ppb of hexavalent chromium and
arsenic in the leachate from these soils.
7.
Comment:
The commentor discusses inacceptability of soil remedial Alternatives 1 and 2, and
potential acceptability of Alternatives 3 and 4.
7.
Response:
EP A concurs. Comment noted.
8.
Comment:
. -
The commentor notes that Alternative B for groundwater is unacceptable to the
CVRWQCB due to high Total Dissolved Solids in the groundwater.
8.
Response:
Comment noted.
9.
Comment:
The commentor states that the CVRWQCB advocates reuse/reclamation for treated
groundwater, rather than discharge to a publicly owned treatment works (POTW).
9.
Response:
The proposed Plan does not include discharge to a POTW as a disposal option.
10.
Comment:
The CVRWQCB would like discharge to the Turlock Irrigation District (TID)
network to be retained as a disposal option for treated groundwater.
10.
Response:
Please see response #3 to Resident of Community No.1.
6
.
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Commentor: Anthony J. Landis, California Department of Toxic Substances
Control (DTSC)
Date: July 19, 1991
1.
Comment:
The commentor states that Proposition 6S is an ARAR for the VWP site.
1.
Response:
EPA disagrees. Please see response #2 to A Vorster.
2
Comment:
The commentor states that National Environmental Policy Act is an ARAR for this
site.
2.
Response:
The National Contingency Plan (NCP) presents the criteria that EP A uses in
identification of ARARs. The NCP (40 CFR Section 3oo.4oo(g)(4» states, "Only
those state standards that are promulgated, are iderttified by the state in a timely
manner, and are more stringent .than federal requirements may be applicable or
relevant and appropriate. For purposes of identification and notification of
promulgated state standards, the term 'promulgated' means that the standards are
of general applicability and are legally enforceable." The NCP further states that
EP A may select an alternative that does not meet a state identified ARAR if "the
state has not consistently applied, or demonstrated the intention to .conslstently
apply, the promulgated requirements in similar circumstances at other remedial
actions within the state" (40 CFR Section 3oo.430(f)(c».
EPA has determined that the requirements. of the National Environmental Policy
Act (NEPA) are no more stringent than requirements for environmental review
under the Comprehensive Environmental Response, Compensation and liability
Act (CERClA), as amended by the Superfund Amendments and Reauthorization
Act (SARA). Pursuant to the provisions of CERClA, the NCP and other federal
requirements, EP A's prescribed procedures for evaluation of environmental impacts,
selecting a remedial action with feasible mitigation measures, and providing for
public review, are designed to ensure that the proposed action provides for the
short-term and long-term protection of the environment and public health and
hence perform the same function as, and are substantially parallel to, the State's
requirements under the California Environmental Quality Act (CEQA) (and under
NEPA).
7
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Since EP A has found that CERCLA, the NCP, and other federal requirements are
no less stringent than the requirements of NEP A, EP A has determined that NEP A
is not an ARAR for this site.
EP A will cc;>ntinue to cooperate with DTSC and other State and federal agencies
during the design phase of the remedial action to clarify further environmental
review and mitigation requirements and ensure that they are fulfilled.
3.
Comment:
The commentor states that CCR Title 14, sec. 750 et seq.,. and Fish and Game
Regulation on Pollution, sec. 5650 et seq., are applicable to the VWP site if
percolation ponds are used for disposal of treated groundwater.
3.
Response:
EPA agrees. These ARARs will be included in the FS and the ROD.
4.
Comment:
General comments on the ARARs Table 7 in the FS are provided.
4.
Response:
EP A has incorporated these suggestions in the FS and ROD where appropriate.
5.
Comment:
The commentor disagrees with the subsurface soil cleanup standards defined in the
Proposed Plan.
5.
Response:
EP A concurs and has revised these standards. Please see response #6 to A.
V orster.
6.
Comment:
The commentor notes that wastes and/or sludges of unknown composition remain
onsite, as well ~ chromium sludge in the 20,000 gallon tank. .
6.
Response:
Comment noted. These sludges and/or wastes will be analyzed and either disposed
of at a regulated facility off-site or, if possible, included in the soil remedy on-site.
8
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7.
Comment:
The commentor notes that the neighboring duck fann may be adversely affected by
contaminated subsurface soils coming into contact with the groundwater. table,
should a percolation pond be built. He recommends monitoring the duck fann
wells and maintaining a standard of 11 ppb for hexavaJent chromium (EP A's
National Ambient Water Quality Criteria) in these wells, to protect the ducks.
7.
Response:
EP A has consulted with the California Department of Fish and Game and other
wildlife experts regarding this issue and has not yet located any relevant literature
or guidance pertaining to adverse health effects to waterfowl from ingestion of
hexavalent chromium. We will continue to pursue this information. Until otherwise
informed, EPA will maintain the 50 ppb State Maximum Contaminant Level (MCL)
standard for hexavalent chromium in groundwater.
c.
COMMENTS FROM THE POTENTIALLY RESPONSIBLE PARTIES
Commentor: Gene Pietila, Valley Wood Preserving, Inc.
Date: July 16, 1991
1.
Comment:
The commentor questioned the calculations used to estimate cost of soil and
groundwater alternatives.
1.
Response:
The cost of soil and groundwater alternatives listed in Tables 24 and 2S of the
RIIFS report was based on several sources of information. Capital and operation
and maintenance costs were obtained from:
(1)
(2)
Telephone contacts and correspondence with several vendors dealing
with equipment and treatment process units;
U.S. EPA Handbook: Remedial Action at Waste Disposal Sites;
EP A/62S/6-8S/006, October 1985;
U.S. EP A Costs of Remedial Action (CORA) Model, April 1990; and
Prior experience by the consulting engineer (Geosystem) preparing
the RIIFS report.
(3)
(4)
, ,
, .
Present worth costs were based on capital costs, annual operation and maintenance
costs, a 5 percent discount rate, and the number of years of remediation for each
specific remedial alternative. All costs are reported in January 1991 dollars. It
should be noted that all costs reported in the RIIFS report are order of magnitude
9
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costs, accurate within the + 50 and -30 percent range. More accurate costs of the
selected remedy would become available during remedial design. For more details,
the commentor should contact his (VWP's) consultant (Geosystem) who prepared
these cost estimates.
2.
Comment:
The commentor references a report on ambient arsenic levels in air, prepared by
the staff of the Air Resources Board and elated March 1990, from which he
concludes that the "ability to clean up Valley Wood Preserving to below the 1()'6 risk
is impossible. n
Response:
EP A is not proposing to clean up the VWP site to below the 1(}4 risk level in any
media. The cleanup standards penain to soil and groundwater at the site and
~~~ .
2.
3.
Comment:
Oeanup levels cannot be achieved in the soil at VWP by excavation and fixation.
3.
Response:
The intent of the excavation and fixation remedy for soils is to remove the potential
for direct contact with contaminated soils and to prevent contamination from
leaching into groundwater. Excavation and fixation accomplishes these goals by
removing the contaminated soils and binding them so that hazardous substances can
no longer migrate to the groundwater resource. The cleanup standards define the
extent of soils for excavation. EP A recognizes that contaminants above these
standards will remain in the fixed mass, but they will be immobilized in that mass,
and contained in treatment units if leachability tests indicate contaminant leaching
potential. .
4.
Comment:
The commentor notes that the arsenic cleanup standard for soils, 2 ppm, is very
stringent when compared to ambient arsenic levels in soils statewide.
4.
Response:
This is a site-specific cleanup standard. Background arsenic levels in VWP soils
ranged from 0.49 - 3.2 ppm. Given the high toxicity of arsenic in an media and the
site background concentrations, the 2 ppm cleanup standard is appropriate.
10
.
-------
s.
Comment:
The commentor provided a copy of a risk assessment conducted in New Jersey on
chromium contaminated soil, which contradicts EPA's Risk Assessment on VWP.
s.
Response:
The risk assessment procedures used by the Industrial Health Foundation in
conducting the New Jersey site risk assessment were inconsistent with EPA risk
assessment procedures. In addition, risk assessments are site-specific in their
conclusions. .
.
11
-------
Appendix B .
ADMINISTRATIVE RECORD INDEX
..
-------
.
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION IX
VALLEY WOOD PRESERVING, INC.
. SUPERFUND SITE
Turlock, California
ADMINISTRATIVE RECORD INDEX
Docwnents:
ARI - ARI08 .
Supplement No. I: ARI09 - ARB7
Supplement No.2: ARB8 - AR139
-------
VALLEY WOOD PRESERVING, INC. SUPERFUND SITE
Tt1RLOCIt, CALIFORNIA
ADMINISTRATIVE RECORD FILS XHDE%
This Index describes documents contained in the Administra-
tive Record File for Valley Wood Preserving, Inc. Superfund Site
in Turlock, california. The documents are in ascending
chronological order, undated documents filing at the beginning of
the chronological listing. Each document has been assigned a
'unique number for purpose of identification. They follow in se-
quential order and are consistant with the arrangement in the
microfilm of the Administrative Record itself.
The documents contained in the Administrative Record File
have been considered by the U.S. Environmental Protection Agency
in identifying the appropriate response action for the Valley
wood Preserving, Inc. Superfund Site.
/
..
-------
J'AC'1' 8BET
Administrative .ecords in Local .eDositories
The "administrative record" is the collection of documents
which forms the basis for the selection of a response action at a
Superfund site. Under section 113(k) of the Comprehensive En- .
. vironmental Response, Compensation, and Liability Act (CERCLA) as
amended by the Superfund Amendments and Reauthorization Act
(SARA), EPA is required to establish an administrative record for
every Superfund response action and to make a copy of the ad-
ministrative record available at or near the site.
The administrative record file must be reasonably available
for public review during normal business hours. The record file
should be treated as a non-circulating reference document. This
will allow the public greater access to the volumes and also min- ..
imize the risk of loss or damage. Individuals may copy any docu-
ments contained in the record file, according to the procedures
at the local repository. If duplicate or replacement copies are
needed of the microfilm or hard copy documents, contact:
Superfund Records Center
u.s. EPA (H-6-1)
75 Hawthorne Street
San Francisco, CA 94105
Tel. No. (415) 744-2165
Documents may be added to the record file as the site work
progresses. Periodically, EPA may send supplemental microfilm,
documents and/or indexes to the local repository. These supple-
ments shou~d be placed with the initial record file.
The administrative record file will be maintained at the lo-
cal repository until further notice. Questions regarding the
maintenance of the record file should be directed to the Super-
fund Records Center.
The Agency welcomes comments at any time on documents con-
tained in the administrative record file. Please send any such
comments to:
Diane Grosser
Remedial Project Manager
U.S. EPA (H-7-2)
75 Hawthorne Street
San Francisco, CA 94105
The Agency may hold formal public comment periods at certain
stages of response process. The public is urged to use these
formal review periods to submit their comments.
-------
AO
ARARs
attch
attchs
CADOHS
cont
CRWQCB-CV
docs
encl
EPA
EPA-9
fr
FS
Geosystem
ltr
11
photo
RI
RI/FS
rpt
TES
TL
VWP
w/
WA
w/o
A4miDi8t~ive aecord Pile %Ddex
AcroDym~/Ab~r.viatioD8
- Administrative Order
- Applicable or Relevant and Appropriate Requirements
- Attachment
-Attachments
- california Department of Health Services
- Contract
- California Regional Water Quality control Board -
Central Valley
- Documents
- Enclosure(s)
- Environmental Protection Agency
- Environmental Protection Agency - Region IX
- From
Feasibility Study
- Geosystem Consultants, Inc
- Letter
- Number
- Photoqraph(s)
- Remedial Investigation
- Remedial-Investiqation/Feasibility Study
- Report
- Technical Enforcement Support
- Transmittal Letter
- Valley Wood preservinq Inc
- With
- Work Assiqnment
- Without
.
-------
Pap 1
09/16191
VALLEY UDaD PltESElV.IG, IIC.
fur-hIck, C811fomfa
IoDMIIISTUTIVE HealD IIDEX
All, DATE IUrIlCll ADDRESSEE IUIJECT
"/'f188/dd
--.------- .......- ---..-----.-..---.-.--.-. ------------.-...-....-.- --.-.--.----.-........-...-.--.-.-....-
All 1 00100/00 lobert Iomatefn hYin C8rreh8n Ltr: Concenw 8bout 8b8orptlon of lIuvy
EIwi...-nt.1 ProtectCon II"NC~t.1 ProtectCon _t.ls by verCOI8 el'Clll8 & _ter teble
AIenCY - legion , At8nCY, """f~on DC fluctuatfon, "'0 encl alte lIIatory,
U1datld
Al2 00100/00 Anne Sergeant lobert Iomatel" 8880: levl... 801 I & 'rcuDlater dlita for
Envl rorlP.ent.1 Protect Ion EnvC~tal Protectfon alte - on potential root uptake of
Agency . Office of Agency - legion , -t.ls, V/blbl 100raphy (~ted)
I..earc:ll & DewIClplent
Al3 57/00/00 10IN'y Arkley SoH aurvey of eastem Stanlsla", a...a,
unlvof C811fomf. C81 ffomla (Soli survey Serl.. 1957 120)
Al4 87/03/18 ..... Allen Marold LOIsdon, Joyce Ltr: Issue rllllldl.l eetion order (t./encl
CA Dept of Health LOIador! - CADONS dockat tHSA 86/87.023), wlo
SeNle.. Valley WOOd Pr..eNfne, . _II recefpt "-475-808.747
Inc
AIlS 17/05/00 C8rolyn d'AI_IdIi MRS pack.,e w/list of referenc.. .ttchs
Envfrorwnental Protection (Reference docs - Incomplete)
Agency - Region'
All 6 88/06/20 ..erry CI ffford M.rold LOIsdon Ltr: Proposal to add VWP t~ National
Envl rorwnenta I Protect I on Valley WOOd PmeNlne, Prlorftl.. List (NPL) wlo encl
Agency - Region , Inc
AR 7 88/10/15 Mohsen fiiehr.n Albert Cronin, Jr., Ltr: PrOlress rpt - 9/88 w/attchs
GeosYS:1III Consultants, attorney
Inc City of Stockton
AlII 88/11/08 Mohsen Mehran Albert Cronin, Jr.. Ltr: Update RI/fS of site ..,.ttchs
li808yat- Consul tanta, .ttorney
Inc Cfty of Stockton
AR' 88/11122 freefe Ifilington Albert Cronin, Jr., Ltr: Respanae to Geosyst8ll'S 11/8/88 I tr
CA Dept of Meal th attorney to addr..s.., ur,lng VWP to comply
SeNlc.. Cfty of Stockton "'revlsld tl- Ichedula, e~lata Rl/fS
& addftlonal actions
All 10 88/12/15 Mohsen Mehran Albert Cronin, Jr., Ltr: PrOlress rpt - 11/88 - allo address
Geosyat- Consultants, attorney lasues ralsld In CADONS Itr of 11/22/88
Inc City of Stockton
M 11 89/01110 Mot\len Mehran Albert Cronin, Jr., Ltr: lespanae to CADOHS 12/27/88 request
GeoIystUII Consultants, .ttorney re disposal of 101 I cuttlnes &
Inc City of Stockton groundwater In temporary Itora;e
-------
Plge 2
09/16191
VALLET woaD PRESERVING, INC.
Turloct, tel ifomil
AD'UNIITUTIVE IECXJtD INDEX
AI. DATE AUTIICII ADDIESS£E "JEeT
W/8/dd
...----... ....--.. --------.----.-.-......-. .-.-.-.-....-......-..... .....-.-------.-................-.-....
AI 12 89/02101 .1- T ;oswld Albert Cronin, Jr., Ltr: Inpons. to Ge08yst8" 1/10/89 1 tr
CA Dept of Hulth attorney ,.. diaposll of lOi I cutti,.., &
Sem en ct ty of Stocltton .~t.r
AI 13 89/fD107 Pet. Coli i.r Treci.lilll,..ton """: '..ponse to ~t to evaluate
CA Dept of Hell th CA Dept of H.Ilth portions of drIft II prepered by
SeNicn leNI c.. Geosystem
AI 14 89/t13/10 JlY Lucu Trecl. 1lllt,..ton MeaD: c:aanenta on geology & hydrogeology
CA Dept of ~'Ilth CA Dept of Ke8lth . uctlons of II drIft rpt of 1/89
SeNicn Services authored by Geosystllll
AI 15 89/03/14 Trect.lllltngton Albert Cronin, Jr., Ltr: Commentl on drIft r.-edill
CA Dept of Hellth attorney tnvestigltion (RI) rpt prepared by
SeNt en City of Stockton Geosystem
AI 16 89/01./06 Metlsen :lehren Albert Cronin, Jr., Ltr: ..Ipenae to refUlatory avencies'
Geosystl~ Consul tenta, attorney eommentl on 1/20/89 drIft RI rpt w/8ttch
Inc City of Stockton
AR 17 89/05/15 Vll Siebel .Irold Logldon, Joyce Ltr: Commentl on Geolyltem'l '16/89 ltr,
CA Dept of Health Logsdon ../notice of proposed detenninetlon of
SeNice. Valley Wood Pmerving, noncompllince w/remedial action order'
Inc HSA 86/87-023
AI 18 89/05/31 Philip Mill.r, Mohlen Albert Cronin, Jr., Ltr: anticipated ,ctleci.lle for c~letion
Metlren attorney of RI/'5 8ctivltles w/attchs . t8ble 1 &
Geosystem consul tents, City of Stockton recent correspondence
Inc
AI 19 89/05/31 Philtp Miller, Mohlen Albert Cronin, Jr., Ltr: Anticipated ,checi.ll. for c~let;on
Met! ren IttOrney of II/'S letivltln w/attch
Geosystelll Consul tents, City of Stockton
Inc
AI 20 89/07/20 lobert Iomlt.in ~I Men88h Ltr: Mendli,.. of trelted "Iter on lite,
Envirorlllentli Protection CA Dept of H.llth "/Ittch drIft Itr to lussel DeLuca of
AQency . legt on 9 SeNien Turlock -Irrigation Di'trlct for program
t..,l.-ntltion
AI %1 89/07/21. lobert Iomltetn ~I Mens8tI Ltr: Support all cannents &
Envi rorlllentll Protect t on CA Dept of H.al th rec0nmend8tlons presented by CADOKS on
Agency' legion 9 SeNlen 3/1"89, request the risk Isses~t to
be r...rttten
AlU 89109/12 EIIIII8nUe I Menslh Dom Dlebert Memo: Comment. on additional remedi.1
CA Dept of M.alth CA DtIS)t 01 tlell tn investigations (II) worltplln lubm\tt~
.
-------
hie 3
09/16/91
VALLET \IXI) PRESERVING, INC.
'""lock, tal I foml I
ADMINISTRATIVE IECXItD JIIDEX
MtI DATE AUTHOR ADDIESSEE SUBJECT
Y'//..,dd
---.------ ____a-a. -.-------------.....-.-.- ...-.------.-.--...------ ..------------.--.-..-.-.-.-.-.-.-.-..-
lervfces 1e,."lces by G808yat-
MD 89109/18 lobert Iomateln .II. ""on lOt: I811plll'l8 & .."Itorll'll of dClmestlc
Envlron.ent8l Protection Itenlll818 Cculty . ...UI 8lOl'l8 Golf 108d w/3 copies
A88"CY - legion , Dep8rt88nt of
Envl~t8l I..ourc..
All 24 89/09/19 Dam Dlart Albert Cronin, Jr., Ltr: Commentl on additional remediel
CA Dept of "81th .ttorney Irweatll8tlons (II) worltpt8n
Se,.,,1 c.. City of Stockton
All 25 89109121 Jeff loaermtOOlll D8Vld Stuart Memo: I~st 11q)1I1'I8 of dClmestlc ...lla
Envl ronaenul Protection Envl rcnDent81 Protect I on In the vicinity of 'lite Mlo encl
Agency . legion , Agency . 1"lon 9
All 26 89/10/03 Phil Ip Miller Albert Cronin, Jr., Ltr: Monthly 11q)1I1'I8 & 8Nllysis
Geoayat- Conaul tentl, .ttorney (monltorll'l8) of groundWeter w/lttchs
Inc City of Stockton
All 27 89/10/19 Phi l Ip MI ller Albert Cronin, Jr., Ltr: Monthly .~I 11'18 & en.tlysis
Geosya,t- Conaul tents, .ttorney (monitoring) of groundWlter w/ettchs
Inc City of Stockton
AR28 89/11/00 St8W8rt "..on Envl rorlllent81 Protect I on VWP 11/89 groundw8ter 1~ling plen
Envir~ul Protection Agency. leg I on 9 (w/Table 1.0 . dr8ft) & 11/16/89 field
Agency . 1"lon 9 lUIII8ry rpt prepared 2/90, w/transmittal
8lIIIO to "ery Mesters, 2/28/90
All 29 89/11120 lobert ~mateln Albert Cronin, Jr., Ltr: lequest sludge renovel before
Envl ron:wnt81 Protection .ttorney ator8ge tank inspection on ahe
Agency . legion , City of Stockton
All 30 89/12/00 CieoIyat. Conaul tenta, V81 ley Wood Pme,."ing, Work plan. additional r.medill
Inc Inc inveatigltlona w/appendic.. A.C
All " 89/12/05 MoIIaen Mehren Albert Cronin, .Ir., Ltr: progr..s rpt w/8ttchs ,
Geoayat- Conaul tents, .ttorney
Inc City of Stockton
AR32 89/12/11 .Ieff Zellkaon M8rold Logsdon Admlnlatr8tlve consent order 190-01 In
Envlr~t81 Protection V8lley Wood Pr...,."II'II, .tter of VWP
Agency . legion 9 lnc
AIID 89/12/27 lobert lornsteln Eamanuel Mensah Ltr: Comments on revised additional RI
Enviroraenul Protection CA Dept of Mell th workplan (12/89) albDltted by Geosystem
Agency . legion 9 Se,.,,1 Cel
.
-------
Pete 4
09/16/91
VALLEY WIXID PR£SElVUIG, IMC.
Tur~ock, Ca~ Ifoml.
ADtIIMISTIATJVE HCCRD IIII)EX
All, DATE AUTHOR ADDRESSEE UJECT
yyl_dd
.-........ -------- ----....-.------------... ----.-.----------.-.--.-. .-.-.----------.-.-.---....-........-..
All 34 90/01/23 lobert lomlteln Inter-egency CCI8IIItt.. ....,: Ipt on other ahe actlvhles &
Envl ~t.~ Protect Ion ....,.. NqYI8t CCIID8fttl by 2/7190 on dreft
At8ftCY - I..Ion 9 Interl. Ir0undw8ter r8I8dlatlon MOrkp~en
of Geo8yst-
All 35 90/02/08 lobert lornsteln A~bert Cronin, Jr., Ltr: Approve Geosyat8'1 Interlll
Envlromental Protection .ttorr.y Iroundw.ter remedl.tlon dr.ft MOrkpl.n
Agency - I..Ion 9 City of Stockton of 1/12190 M/cammentl
All 36 90/02/21 Robert Bornstein Albert Cronin, Jr., Ltr: Motlfy VWP of atlpulated penalties
Envlroment.l Protection .norr.y If It f.UI to begin ~ test on
AeencY - legion 9 City of Stockton Z/2419O
All 37 90/03/05 Robert lornsteln Albert Cronin, ettorr.y Ltr: Re det.y In Itudge removal & extend
Envl rOl"ll8rlu I Protect I on CI ty of Stockton date of r~I red ~ testa to 3/19190
Agency - levlon 9 pul'8'*'t to EPA AD 190-01
All 38 90/03107 Robert lornsteln Mohlen Metlren Ltr: lequest for .It pump teat dati &
Envl r'CII-..nul Protect I on Geosyat- Consul tents, Inform thet revlonal hydrotogllt Herb
AeencY - lev I on 9 Inc Levine Milt help Interpreting
hydrotoglcel cheracterlltlcs
All 39 90/03115 Mohlen Mehrln Devld Doyle Ltr: Progress rpt - 12/89 to 2190 .
GeoIyat- Consul tentl, "IaCle, MecMlchaet & M/.ttcha
Inc Upton
All 40 90/03115 Mohlen Metlren Robert lornstein Ltr: Response to r~t of 3/7190 for
Geosyaun Consut tentl, Envir~tel Protection pumping test dat., elk for EPA
Inc AeencY - lev I on 9 references I/or c~er progrems for
hydrotoglc _tyall
All 41 90/03/19 lobert Iornsteln MoIIaen Mehren Ltr: Geo8yat8 fel tl to Inform
EnvlrOl"ll8rlut Protection GeoIyat- Consul tents, regutetory .genel.. of 1V15/89
AeencY - levlon 9 Inc IrcuOl8t.r ...t In; dete
All 42 90/03/19 lobert lornsteln MoIIlen Mehren Ltr: Effectiveness of on-lite
Envirorllllntal Protection Geosyat- Consut tents, etectroch.lcet tre8t8lftt celt, & other
Apncy - legion 9 Inc lisues dlacusled et Inter.gency -.etlng
of 3/15190
All 43 90/03/30 MoIIlen Mehren lobert lornsteln Ltr: I..ponse to EPA ttr of 3/19/90,
GeoIyat- Consuttentl, Envlr~tet Protection MftI8rlzes reesons for det.y In
Inc AeencY - lev I on 9 reporting doa8stlc ..tt 1~lIng
AR " 90/05/01 Robert Bornstein Mohsen Mehrln Ltr: Request for additlonat detlils &
Envlr~t.l Protection Geosyatem Consul tents , flow dl.grams of proposed
Agency - le810n 9 Inc extraction/Injection lyat. (1,/12/90
.
-------
'''' 5
09/16191
VALL£Y WODD PttESDVIIG, IIIC.
Tur'oct, California
ADIUIIISTRATIVE UCXIID IIIDEX
M. DATE aura MOUSSEE SUBJECT
Y'//..,dJJ
...------- ..------- __-.e-.-._------.-.--.... .-.---------------.-..... ----....---..---......-----------------
progresa rpt)
M45 90105/10 .l8ff lelltaon "rold Lopdan A&8lnlatretlw conMnt order In .tter
ErNI~al Protection Valley Wood 'reservl,., of WP, .USEPA docItet 890-02,
AeencY . 1..lon 9 Inc ..,..",1 nal I a
M46 90105118 lobert r4rnsteln Intra.atenCY Cal8ltt.. ~: I~t Geosyat- to ~ly design
ErNl rcn.""ul Protect I on Melli)era apeclflcatlons for pulp & treatment
Agency - _eglon 9 .yat8 (AO 90-01) & EPA plan to conduct
Infor81l P'bllc ..tlng
M 47 90/05/19 Mohlen Mehren David Doyle Ltr: 'rogresl rpt . 4/90, ../attchl &
GeoIyat- CONultentl, r; liable, MacM I chael & .",Inalla In table 1
Inc Upton
MIo8 90/05/24 Phil Ip Miller Robert Iornsteln Ltr: Design for Interl. groundwater
GeoIyat8 CONultentl, Erwlroreental Protection ,...slatlon, ",.ttchl
Inc Agency - _eglon 9
M49 90/05/31 Mohlen Mehren David Doyle Ltr: Regional wll Inventory, In
GeoIyst- Consul tents, Khable, MacMIch.el & response to lection V-B-4 of USEPA
Inc Upton edmlnlltratlw consent order 190-02,
,,'attcha & .",Inalla
AI 50 90/05/31 Kemettl Landau Robert Bornstein Ltr: Questions & COlllllentl On 5/21,'90
CA Regional Water Gull fty ErNlrornental Protection design & operation of Interim
Control loard . Centrll Agency. Region 9 Iroundwater remediation Iystem,
Valley ",.rllnalla
AI 51 90106/01 Robert '~teln MoIIlen Mehren Ltr: Interagency commltt.. requests
£mill'Orl8fttal Protection GeoI)'It8 Consul tentl, 8Ctlona re Interl. pulp & treatment
Agency . let lon' Inc ayat- pursuant to EPA AO 90-01 & 90-02
after 615190 Met I,.
AI 52 90106/20 Mahlen Metlren David Doyle Ltr: 'rogr811 rpt . 5190, ..,attchl
GeoIyat. CONul tentl, Klel., MacMlch..l &
Inc Upton
AI" 90/06/22 Mohaen Mehren David Doyl. Ltr: Work plan - ILDurface
GeoIyat- CONul tenta, Itlel., MacMlct\ael & character I lat I on In fONer W'dergrCUld
Inc Upton tank area of Ifte, ..,aUchs
MSIt 90/06/28 lobert Fcurt Robert Elladge Ltr: Coamentl on Geosyatem'l 6/20/90
Stenillaus Cculty . Valley Wood Pr..ervlng, progress rpt re 8roundwater Ia\I toring
Depart8nt of Inc
ErNl rom8'lt8l aescurc..
. .
-------
P888 6
09/16/91
VALLET WDDD PlESERVIIIG, IIiC.
Turtock, Catifornia
ADIUIiISTUTIVE RECORD IIIDEX
All,
DATE
.,.".,dd
AUTIICIt
AIIORESSEE
UJECT
......----
-.-.----
-----..........-...-..... .................-----...
-.--.-----...........-.-.-......---...-
II. 5S
90/06128
lobert 'ourt
It...lat- Ccu'tty -
Dep8rt8lnt of
Emi rcn.entat 1880UF'C88
VaUey Wood Preservi,.,
Inc
Ltr: Caaaenta on 6/20190 worlcplan of
&808y8t-
AR56 90/07/19 MohMn tlehr... David Doyle Ltr: ProsIre.. rpt . 6190, wanchs
Geosystf''' Consultantl, t:lele, IIKI'lchael &
Inc Upton
AR 57 90/07130 MofIlen Met! ran David Doyle Ltr: IfYlleeI work plan a~urface
GeoIyst81 Consultantl, t:imle, "'ctllchael & characterization in fOnDer underground
Inc Upton tank area of lite, w/attc~.
AR 58 90/08/1' Robert Fourt lobert El ledge Ltr: ~rove GeoIyst8l'I 7130190
Stanillaus Ccurty - VaUey Wood Preserving. worttplen for insullatlon of a
Depertllllnt of Inc grCUldwater lIonitorlng wU, w/outllned
Erwlr~tal lesources 8)dlficat ions
All 59 90/08/20 MofIlen Met! r... David Doyle Ltr: PrOllres. rpt . 7/90. w/anchs
GeoIyst81 Consul tantl, t:ldlle, ICadClchael &
Inc Upton
AR60 90/08/23 t:emeth Landau lobert Bornstein Ltr: Comments on 7190 draft feas ibill ty
CA Regional Water Clu8l1ty Erwir~ul Protection Itudy
. Control 'oard - Central Agency' legion 9
Valley
AR 61 9Oi09/18 Mohlen I4wtI r... David Doyle Ltr: lelponse to 9/13/90 Inquiry of
GeoIyst- Consul tantl, t:lele. M8c:Mlchael & Robert Bornstein. E'A-9, re testing,
Inc Upton operation & ..Intenence of Interim
groundwater remediation aystem on lite
All 62 90/09/19 MofIlen Metlr... David Doyle Ltr: PrOllrell rpt . 8190, w/attch.
GeoIyst- Consult...ta. t:lele, M8c:Mlchael &
Inc Upton
AR63 9O/09/2' '''ry ....tera David Doyle Ltr: Commenta on draft feasibility study
Erwlr~tal Protection t:iele, M8c:Michael & (FS) workplan of lite, w/end
Agency . legion 9 Upton
AR" 90/10/01 t:emeth Landau ...ry lluterl Ltr: Comments on Geosystem'l lecond
CA Regional water Qualtty Erwlr~ul Protection draft 8/90 remedial Investigation rpt
Control Board' Central Agency - Region 9
Valley
AR 65 90/10/08 Mohsen"'" ran Moward Su Ion Ltr: Response to request re lite, w/encl
GeoIyst~~ Consultants. Verlar. Inc (additional II workplen 12/89 & second
.
-------
p... 7
09/16'"
VALLEY WOtD PlESElVIIG, IIiC.
Turiock, C8i Ifomil
AD.nIlISTIATiVE IECXItD INDEX
AI' DATE AUTHOR ADDIESSEE SUBJECT
yy/8/dd
-----..-. --..---- .-.-.-.--------.-----.-.- --.-.-.----------.--....- .-.-.--...---------.-.----.-.--.-....--
Inc drift II rpt 8/90)
AI 66 90/'0"0 lobert l0rn8teln Devld Doyie Ltr: PrOwlalON " operltlon &
Envlran""t8i pratectlon II8Iie, M8cMldt..i & _lnt8n8ftC8 of Interl. .ro&niweter
A88ncY . ...Ion ' Upton trut8lnt 8)'8t-
AI 67 90/'0"5 Devld Hogshe8d Devld Doyle Ltr: '190 extrectlon Injection operltlon
Geo8ystem Consui tents, I I ele, IledU dt.. i & dati (8/31.10/1/90), M/lttch
Inc Upton
AR68 90/10/22 lIohaen llehren Dlvld Doyie Ltr: Progress rpt . '190, M/lttchs
GeoIyat- Consui tents, Ileie, M8cMldtHI &
Inc Upton
AR69 90/10124 MotIs.. lletlren Gene loyer TL: Dltl V8ildatlon plckl,es fr
Geo8yst- Consui tents, PiIMI"" Reselrch Corp C8llfomll Wlter Leba (M) & Mld-
lne Envlr~tll M8Mgelllnt, Pecfflc Envlrar8entli Labontary, lne
lne (MPEL)
AR70 90/10/26 Robert Iomateln, Miry Dlvld Doyle Ltr: RecpJUt for "Iter que I Ity dati,
....ters Ilele, l18cMichHI & trelt8ent celi stltUS, Inflltrltion pond
Envl ron.1enul Pratect I on Upton design & itr of credit fr alte
Agency ., Region'
AR71 90/10/29 IIohsen IIetIren Dlvld Doyle Ltr: liveekly rpt - ,roundv8ter
Geo8yst- Consultants, KI8Iie, M8cMlchHi & extraction Injection operltlon date
Inc Upton (10/1-15/90) provided by WP ../Inch
AR72 90/11/01 IIohHn llehran Dlvld Doyle Ltr: Tank effluent "Iter quellty dati
Geo8yat- Consul tenta, Killble, II8cMlchlel & (6/26-9/21,/90), "/Ittchs
Inc Upton
AR73 90/11109 IIohs.. llehran Dlvld Doyle Ltr: Groundwlter extrlctlon/treltment
Geo8yst- Consul tenta, 118Ile, M8cMldtHI & operltlon dati, bl....kly rpt (10/16-
Inc Upton 31/90), M/lttchs
AR 74 90/11'" IIohs.. llehr.. Devld Doyie Ltr: Progress rpt - 10190, "/Ittchs
Geo8yat- Consui tents, KI8Iie, II8cMldteei &
Inc Upton
AR75 90/11121 MotIHn 'ellr.. D8vl.d Doyie Ltr: Response to EPA itr of 10/26/90 re
Geo8ystNl Consui tent., 118Ile, II8cMldtael & trelted .roundwater Inflltrltlon pond,
Inc Upton M/lttchs & -relnel li
AR 76 90/11121 Ve....r, Inc Plemlng Reselrch Corp Prelf.lnery ecologlcei risk Isussment,
Envi rar8entll Mlnegement, "/Ippendices A-C & 39 photo, ../0
lne locltlon -p on plge 3, WA' C09030, EPA
.
-------
p... 8
09/16191
VALLET WOCI) PR£SRVIIIG, IIiC.
Turloclt, C8ltfomla
ADIUIiISTUTIVE UCORD IIIDEX
AI. DATE AUT'" ADOlfSS£E SUBJECT
'/'f/8A/dd
---------- .....---- ----...-----.------------ -------.-.-.------.....-- ---------.-..........-------.-.-.......
contI 68-W-0009
AI 71 90/11128 ~8Y C8~.r, IIahMn hvld Doyle ur: Addltlonel .-urlace
""'ren (1.le, 1I8dt1ch8e1 & characterization atudy in tOnier
G808yst- Conaut t~, Upton wwiertr«nf ator... tri8 of aUe,
Jnc "'audla.
AI 78 90/12/05 lobert .ornateln, M8ry Nohaen llehren Ltr: Response to propos8d plen of
8I88tera GeoIyst- Consultents, 11/21/90 re developlllnt & Iq:llenentltlon
Envir~tel Protection Inc of Infiltration pond
Agency - 1..lon 9
AI 79 90'12/06 Matlaen llehren David Doyle ur: Present resul ta of capture ~one
Geosyst- Consul tents, 1Cll8lIe, M8c:MldI..1 & ....lys.. for treated IrcuOlater'
Inc Upton infiltration In fo...r pondlng aree,
"'.pI
AI 80 90'12/10 Matlsen Met\ren David Doyle Ltr: GroundWeter ..traction/InJection
Geoayst.. Conaultents, 1C1I8I1., Mac:MldlHI & operation & ~ter quality deta, bi~kly
Inc Upton rpt (11'16.30/90>, liI/auch.
AI 81 90/1211' Moh~en t.etlren Davi d Doyle Ltr: Groundwater extraction/injection
Geoaysten Consul tents, 1CII8I18, Mac:MichHI & operation & liIat.r quality deta, bi~kly
Inc Upton rpt (12'1-15/90>, liI/attch.
AI 82 90'12'19 Matlsen IIeh ran David Doyle Ur: Progress rpt - 11190, liI/euch.
Geosyst.. Consultants, 1C1I8I1., Mac:Mlcha.1 &
Inc Upton
.83 90'12121 PI...,I"I a....rch Corp Envlr~tal Protection Valldetlon rpt on aelect deta, YES 12 at
Envlrcn8fltal Menaltllent, Agency - '..ion 9 hazardous ...ste .ft.., zone IV, r81lions
Inc 8-10, EPA contI 68.W9-0009, WA' 012-
C0903007
AI 84 91/01'15 Matlsen Metlran David Doyle Ur: Groundwater extraction/Injection
Geosystlll Consul tents, 1C1..le, M8c:MldlHI & operation & ~ter quality deta, bl~kly
Inc Upton rpt (12/16-31190>, "'auchs .
AI 85 91101"7 Matlsen Metlren David Doyle Ur: PrOlr... rpt . 12190, liI/auch.
Geosyst- Consu\ tent., (I.\e, M8c:MlchH\ &
Inc Upton
.86 91/01122 MatI.en tlatlran David Doyle Ltr: Groundwater extraction/Injection
Geo8ys.. Consul tanta, (1..1., M8c:Mldlael & operation & water quality deta, bi~kly
Inc Upton rpt (1'1.15'91>, "'attchs
Alfl7 '1101/24 MoIIsen llehr., David Doyle Ur: WOrk plan for abandorlnent of vet I
.
-------
Pete ,
09/'6'"
VALLET woaD PlESERVIIiG. IIIC-
T""toct. Cel ffornla
AD.UIIISTlATIVE RECORD IIIDEX
AI' DATE AUT- ADDRESSEE -JECT
W/8/dd
.-.---.... ------.- ...--..------.....--..... --.-.....---.......--.... .------...................-.-.-....-.-.
Geo8y8t~ Con8ul tenta. rlele. I88dCldl8el & WP-3
Inc Upton
AI 88 91/OZ/OO Geo8yst- Con8ut t..ta. Valley Wood P.....rvll'll. 'nalbfl Ity atudy IIOrtpl... MlTL to
Inc Inc Dwld Doyle fr Noh.., NeIIr... 2122191
AI 89 "102101 Mary Maste,.. Nohsen "ellr.. 8IeIII: ......t for respons. to 1130/"
Envlromental Protection Geosyst- Consultants. . COIIa8nts (enci) on proposed clpture zone
Agency - legion ' Inc design by hydrolOSlIst David Burden to
Herbert Levine (By Fax>
AI 90 "102/04 Plamlng Research Corp Envlromental Protection list assessment flnel rpt. TES 12 It
Envlronmentll Maneg~.t. A8eftCY - Dfflc. of Wiste hazerdous ah... zone IV. regions 8-10,
Inc PrOSlr... Enforcement contI 68-W9-0009. WM C09030
AI " "102/08 8Iohsen 8let\ran Dlvld Doyle Ur: Groundiliter utrectlon/lnjectlon
Geosyst- Consul tents. Itilltlle, MaeMldlMI & operltlon & Wlter ~lfty diu, biweekly
Inc Upton rpt (1/16-31"'>, v/attchs
AI 92 "/02/1' "Iry Ma;;te,.. Dlvld Doyle Ur: lequest canments fr EPA, CRWCCB-CV
Envl rorr.""tll Protect I on ltitICle. M8cMlchl.\ & (1/17/"> & eADONS (1117190> be IncluOed
Agency . legion ' Upton Into IIIFS rpt. v/encl
AI 93 "1021'3 Mary Maste,.. Nohlen "ellren 8IeIao: Request for inclusion of
Envlromentll Protection Geosyst- Consul tents. StenllllUl COUnty wll 8b8ndorment
Agency - legion ' Inc requirement Into IIOrkplen, v/.ttch (Jim
Simpson's 2/4/" \tr & diagram) By fax
AI" "102/" 8Iohlen 8let\ran Dwld Doyle Ltr: PrOSlr..s rpt - 1191. v/lttchs
Geo8yst.. Consult..ts. IClllble. M8cMichMl &
Inc Upton
AI 95 91103/1" Marla Meerl,. Mary Malters Ur: CaDents on WJI-] well 8b8ndorment
CA legl_l Water Quality Envlromental Protection IIOrkplen
Control Ioard - Central A8encY - leg lon'
Valley
AI 96 "103/1' Noh.., 8I8tIran Dwld Doyle Ur: Wort plan - additlONlI on-Ilu &
Geo8ystfll Consul t..ts. Itillble. MaeMlch..\ & off-alte charecterlzatlon, w/lttchs
Inc Upton
AI '7 "103/1' 8Iohsen Ihhran David Doyle Ur: Groundllater extrectlon/lnject i on
Geo8yst.. Consultants. lCitlCle. lIaeMlchHI & operltlon & Wlter ~lIty dltI, biWftkly
Inc Upton rpt (2/16-28191>, V/attchs
ARtS "/03/22 lIohlen Mehren Dlvld Doy\e Ltr: Groundiliter extrlctlon/injection
Geosystem Consul tents. ltitICle, MaeNlchlel & operltion & wlter ~llty dati, b'~kly
-------
Plge 10
09/16191
i.
VALLIY woao PUSERVI8IG, IIIC.
furlock, Cal ffomla
ADMI.ISTIATlVE If CORD IIIDEX
AI, DATE AUTHOII ADDIESS£E ""ECY
yy/WlJ/dd
-......--- -.-.--.- ------------...----.-.--- -.-.----.-.-.-.----....-. ....-.---------.-----------...-.--....-
Inc Upton rFt CS/1-15/91), Miattch8
AI 99 "/03/22 lIohaen IWIran David Doyl. Ltr: prog..... rpt - 2191, Milttchl
Geo8yst- Consul tante, IellDl., II8dIlchMl &
Inc Upton
0100 "/03/26 Dam Dlebert Mery Me.ters Ltr: Concem r. ...11 decCIIIIlliloning,
CA Dept of Hellth Erwl rorIIentll Protect I on 11/3/13191 canments (IUch) fr Rlchlrd
Servl cn AtencY - legion 9 8Ic"riln to E.......l ....... on _11
8b8ndonaent workplan of 1/24/91
AI 101 . 91/04115 "ohlen Mahran DIYld Doyle Ltr: Ifwetly rpt - gnuOllter
Geoa)'llte Consul tentl, leilltlle, M8cMlcheel & r8ICIlatlon syst.. operltlon dati (3/16'
Inc Upton 31191) provided by WP "/lttch (By fax)
o 102 "/04/'7 Mary Masters Dlvld Doyle Call1leftts on 3191 drift rpt FS, "/l tr
Erwlromentll Protection 1e11D1., M8cMlchl.1 & trWIUIluing ~ject rpt, acheO.ile
Allency - legion 9 Upton ...tin; on 4/22 to discuss CCllllllents &
Info", flnel IIIFS rpt due by 5120191
AI 103 91/04117 Plenning Research Corp Erwlrorllental Protection Spring 1991 IIrcx.ndwater & treatment WIlt
Erwl romental tl8ne1l~t, Agency - Office of Waste field aampllng plan, TES 12 It hlzlrdOus
Inc PrOllr8ft8 Enforcement .ste sites, zone IV, regions 8-10,
cont' 68-1119-0009, WAf C09030
AI 1010 91/04/18 Mery Ma.t.rs DIYld Doyle Ltr: Concur "/callllefttl by CADOHS &
Erwl romentll Protection ICllItIle, MacMlch..1 & .CRWQa-cv on 1/24/91 ...11 WP-3
Agency - 1811 I on 9 Upton 8b8ndon1ent workplln, request s~ission
of revised 8b8ndoment workplln by
5/13191
Al10S 91/04/19 Mery Me. cera Dlvld Doyle Ltr: Disapprove of 3/19191 Iddltionel
£rwl rcnentll Protectl on IellDl., MecMlchl.l & on-alte & off-alte chlracterizltlon
Agency - legion 9 Upton workplan, outl me work thlt should be
Included In revised workplan
Al106 91105/06 Mery Mestl,. IIohsen ..... ran Ltr: Outline cCllllmenta ""Ich ahould be
Erwl roraental Protection Geo8yst- Consultentl, Iddresaed In flnel 'S. for P'blic corrment
Agency . legion 9 Inc due on 5120191., "'IUch (e.~le of
ARAIIs tell)
0 107 91/05/13 "ohlen Mehren Dlvid Doyle Ltr: liMe8ltly rpt - groundwlter
GeoIyst- Consultants, IClatll., MacMlchlel & remediation aystem operation dltl <'/16-
Inc Upton 30/91) provided by WP w/luch
AR10S 91105/14 Erwi rClrlllentll Protect Ion List of guidance document.
Allency
.
-------
Page 11
09/16191
AI'
..----.-.-
DATE
Y'f/-.Jdd
.-.-....
.0. of lecords: 108
\8rlfrwl1.rpt
VALLET WDCD PRESERVING, INC.
Turloclt, Cal ffomfe
ADM 1111 STIA TI VE IECCItD IIIDEX
NJTIICIt
ADDRESSEE
_JECT
---.---...-.-.-------.... ...---.....-.--.......-.. .....--.-...........-.......-..........
.
-------
~y WOOD PRESERVXNG, %NC. SUPERFUND S%TE
~rlock, California
&dmini.~ra~ive Record Pile %n4ez
8upplement HUmber 1
This Administrative Record File Index, Supplement Number 1, lists
the documents contained in the Administrative Record File for the
Valley Wood Preserving, Inc. Superfund Site, Turlock, California,
since the compilation of the original on May 20, 1991. The Index
presents the documents in ascending chronological order, reflect-
ing the organization of the documents in the f~le itself.
Each document has been assigned a unique number for purposes of
identification. These are indicated as "ARxx". Numbering of the
documents in Supplement No.1 begins where the original Ad-
ministrative Record File Index left off: thus the first document
is numbered "AR109".
Please note that the original Adminstrative Record File consists
of documents '1 - 108 arranged chronologically from 1957 to
5/14/91. Supplement No.1 consists of documents jAR109 - AR117
arranged chronologically from 4/19/91 to 6/10/91. Because of the
overlap in dates, it is necessary to use both indices to locate
documents for a particular date.
The documents contained in the Administrative Record File are
used by the U.S. Environmental Protection Agency in identifying
remedial activites appropriate for use at the Valley Wood
Preserving, Inc., Turlock, California.
.
-------
P8ge 1
09/\6191
AI 110
AI 111
AI 112
AI 113
"'"
AI 115
AI 116
AI ,,7
VALID woaD PlESEIVIIIG, IIC.
Turloct, California
ADMIIISTRATlV£ IECCItD IIDEX
SUppI-.nt 10. ,
DATE
yyl.dd
AUTHOR
ADDIESSEE
M'
.--------
Al109 91104,\9 WIaen IWIren D8V.d Doyle
GeoIyat- COnIuI tenta, It hlble, IIIcM I cll881 &
Inc Upton
91104129 .Mn Mhren David Doyle
GeoIyatf18 eonaul tenta, rlele, IIIcMlch881 &
Inc Upton
91105/20 Nohaen Mehran David Doyle
Geoayst- Canaul tanta, ICIICle, MacMldlael &
Inc Upton
91105/24 Nohaen Mehran David Doyle
Geoayst8D Consul tanta, Khlcle; MacMldlHI &
Inc Upton
91'O6~ Envlrornental Protection
Agency - Region ,
"'06/00 Geoayst- Consultanta, Valley Wood Preserving,
Jnc Inc.
"/06/00 Geosyst~ Consultanta, Valley Wood Preserving,
Inc Inc
"106/01 Mohsen """ran David Doyle
Geosystem Consultants, Klele, lIIcMidlHI &
Inc Upton
.-------
._._e_____.-.---------.-. ------...-.--.-.-..-....-
91106/10 Nohaen Mehran
GIOSyst- Consultanta,
Jnc
David Doyle
rhlble, MacMldlHl &
Upton
10. of Records:
'arflnal1.rpt
,
""EeT
____e.__--_-.--.-----.-------.-.-.-...-
L~r: prog....a rpt . 3191, ",.udla
Ltr: I~t.r extraction trut8lnt
reinjection ayst_, operation & ...ter
qu8llty data, biweekly rpt (4/1-15/"),
"'andls
Ltr: progr..s rpt - 4191, .,/lttchs
Ltr: GrOlftiwlter extraction treltalent
Injection aystem, operation & MIter
quality dati, blNeekly rpt (5/1-15/91),
"'andla
'act M"t: EPA announces proposed plan
for long-term cleanup on alte
lemedial Investigation/feasibility atudy
(11"5), v1 - te.t - final draft rpt
Remedial Investigation/feasibility study
(11/'$), v2 - appendices
Ltr: GroundMater ..traction treltment
Injection aystem, operation & v'ter
qu8llty data, biweekly rpt (5/16-3'191),
"'andls
Ltr: Progr..a rpt - 5191, .,/luchs
.
-------
Page 1
09/24/91
.-...--.--
All 118
All 119
AR 120
AR 121
AR 122
AR 123
AR 124
AR 125
VALLEY WOOD PRESERVING, INC.
Turlock, C8ltfomia
ADMINISTRATIVE RECORD INDEX
SUppI~t No.2
AR'
AUTHOR
ADDRESSEE
SUBJECT
-.-.--------------.-.---------.-.--...-
GO/GO/GO lesldents
City of Turlock
Mary Masters Ltr: !>\bl ic CCllllllent on Proposed Plan of
Envil"Clf'8l!ntal Protection alte (N8I\IeS & addresses of Individuals
Aeency . legion 9 redacted.' Privacy Act)
GO/GO/GO Resident
City of Turlock
Mary Masters Ltr: !>\bllc COlllllent on Proposed Plan of
Envirorlllental Protection aite (N_S & addresses of individuals
Agency - Re;ion 9 redacted - Privacy Act)
Ltr: Review 11/28/90 rpt by Geosystem
Consultants, request ~ to submit
voritplan (due within 45 days) for onsite
treatment of contaminated loi Is
. .
Ltr: Groundwater extraction treatment
injection Iystem, operational & water
quality data, biweekly rpt (6/1-15/91),
w/auchs
Minutes of community meeting re Valley
Wood Preserving Superfund Site proposed
plan for long-term clean-up (Copy)
Ltr: Progress rpt - 6/91. w/attchs
Ltr: Request revisions of RI/FS draft in
Itr format as addendum by 7/17/91.
w/attch memo (EPA corrections to 6/91
RI/FS rpt fr M Masters & G McCabe)
Ltr: Groundwater extraction treatment
injection system, operational & water
quality data, biweekly rpt (6/16-30/91),
w/auchs
AR126 91/07/16 Gene Pietila Mary Masters Ltr: Public COlllllent on Proposed Plan for
Valley Wood Prnerving, Enviromental Protection alte, wl-anch
Inc Agency' Re;ion 9
AR127 91/07/16 Donn Diebert Mary Masters Ltr: ~line COlllllentS on EPA Proposed
CA Dept of M.al th Envi romenta I Protect I on Plan of 6/91, w/encl (7/16 memo of
Services Agency' Re; i on 9 conmentl on proposed plan fr Toxic
Substances Control Program, CADOHS)
AR 128 91/07/18 Li.. Manuaialt Data validation rpt MYF826 Memo .2
ICF Technology, lnc w/attch & TL to Mary Masters/EPA-9 ir
DATE
'tY /IIQ/dd
------.-
-------------------------
-------------------------
91/06/13 Robert Fourt Robert Elledge
Stanillaus County - Dept Valley Wood Prelerving,
of Enviromental Inc
Relources
91/06/20 Mohsen Mehran David Doyle
GeoIystem Consultants, Kimble, MacHichael &
Inc Upton
91/06/25 Ronald Peters
Peters Shorthand
Reporting Corp
91/07/01 Mohsen Mehran David Doyle
Geosystem Consultants, Kimble, MacHichael &
Inc Upton
91/07/08 Mary Masters . David Doyle
Environmental Protection Kimble, MacMichael &
Agency' Re; I on 9 Upton
91/07/09 Nohaen Mehran
GeoIyatem Consul tents,
Inc
David Doyle
Kimble, MacM I chel &
Upton
.
-------
Pete 2
09/17/91
......-.-.
AR129
AR'
DATE
YY/ealdd
IUfHOR
-.---...
.--------..--.-.-.-.--...
"/07/" fIohHn Meh.....
Geos)'St- Consul tents.
Inc
AR 130 "/07/'9 Anthony Lendl.
CA Dept of Ileal th
Servl~es
AR 131 "/07/22 Usa lIanuslak
ICF Technology. Inc
AR 132
AR133
AR1~
AR 135
AR136
AR 137
AR138
"/08/09
VALLEY WOOD PRESERVING. INC.
Turlodt. tellfomla
ADMINISTRATIVE RECORD INDEX
",",l~t 110. 2
ADDRESSEE
------.-----.-....-.-....
Davfd Doyle
Chicle. l18dCi~..l &
Upton
M8ry Mesters
EnvirGm*\tal Protection
Agency - legion ,
SUBJECT
---------------..--.-.-.--------.-..---
VI~torfa Teylor/ICF TedInology Inc
Ltr: G~ter utractfon t,..atlllent
tnjectlon .)'St-. operational & Meter
quality data. biweekly rpt (7/1.15/91).
../att~s
Ltr: Revi... ~CllllDenta on draft
F.aslbllfty Study (FS) dated 3/25/",
../encl (711' Ileal) on ARAR. fr Toxi~
~tancH Control progr8ll, CADOHS)
Data val idation rpt MYF80S to MY~825.
MYF827. MYF828 Memo 13. ../att~h & TL to
M8ry M8sters/EPA-' fr Vi~toria
Taylor/ICF Technology Inc
Antonia Vorster Mary Masters
CA Regional Water Qual fty EnvlrGm*\tal Protection
Control Board - Central Agency - Region ,
Valley
"/08/15 Mohsen ~ehran
GeoI)'Str.m Consultants,
Inc
"/08/20 Mohsen Mehran
Geos)'St811 Consul tants.
Inc
"/09/05 fIoh.en Mehran
GeoI)'St- Consul tents.
Inc
"/09/13 MeIfIsen Mehran
Geos)'St811 Consultenta.
Inc
"/09/13 Mohsen Mehren
GeoI)'SteID Consul tent..
Inc
"/09/16 Udai Sh~
David Doyle
Kimble, Ma~l~hael &
Upton
David Doyle
Kimble, MacMI~hael &
Upton
David Doyle
Khcle. M8cMi~h..l &
Upton
David Doyle
Kimble, MecMi~h..1 &
Upton
David Doyle
Kimble, M8cMi~hael &
Upton
Daniel Shafer
Ltr: Comments on Remedial
Investigation/Feasibility Study (RI/FS)
& addenduD, ../encl (5/17 IIeIIIO on ARARs,
817 IIeIDO "'~ommenta on sol I ~leal'AJP
levels)
Ltr: Groundwater extra~tiOn treatment
injection .)'Stem. operational & ..ater
quality data. biweekly rpt (7/'6.31/"),
../att~s
Ltr: Progress rpt - 7/". "/att~hs
Ltr: GroundWater extraction treatment
tnjection s)'SteID, operational & Meter
quality data. biweekly rpt (8/1-15/91),
"'att~s
Ltr: GrOundwater extraction treatment
Injection .)'SteID, operational & ..ater
quality data. biweekly rpt (8/16-3'/"),
"/att~s
Ltr: Progress rpt - 8/", ..attchs
Ltr: VWP remedial alternative ~ost
.
-------
pqe 3
09/17191
AI'
.-........
AI 139
DATE
yy/ra/dd
...---.-
'" AlJTIICR
VALLEY WOOD PRESERVING, INC.
Tur-Iock, tellfoml.
ADMINISTRATIVE REcaRD INDEX
SUppl.-ent No.2
ADDRESSEE
-..ECT
...............----.-.--- .....--------.-..-....-.- -----.-.---..--.-.-.---.-..-......---.-
CDC HfH
91/09/ 27 Erw'~t.l Protection
Agency . legion 9
No. of Records: 22
'.rfinal1.rpt
Plamlre 1....rdI Corp ..tf_t.. for lecord of Decl.fon (1(1)
Envfronaent.l M8n8g88ent.
Inc
Record of Dec'.'on (R(I)
.
-------
SFUWO KtCORDS CTR
1317.00060
PACE NO.
05/1'191
SELECTED GUIDANCE DOCUMENTS FOR VALLEY WOOD PRESERVING, INC.
AR010S.
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
110
. Vol
TItle
Oete
Authors
Status
Pages
Her Attachments
OSVER/EPA IIumber
........
.... ...........
................
..
0000 INOEX TO CCHPENOltM OF CERCLA 05/01/119 -DUPE .PRC.ENVIRONMENTAL FINAL 8 I) DATA El£NENT
RESPONSE SELECTION GUIDANCE MANACEMENT, INC. DEFINITIONS 2)
OOC\JtENTS ORGANIZATIONAL
ABBREVIATIONS ANO
ACRONYMS IDENTIFIED IN
INDEK
.. PRE.REMEDIAL
0001 1 EXPANDED SIT£ INSPECTION 10/01/117 .DERR FINAL 7' 2 OMR 19345.1-02
TRANSITIONAL GUIDANCE FOR FY-88
0002 PRELIMIIIARY ASSESSMEIIT GUIDANCE 01/01/88 - OERR/HSCD FINAL 83 Z OMR 19345.0-01
FISCAL YEAR 1988
.. REMOVAL ACTION
1001 1 COSTS OF REMEDIAL RESPONSE 01/01/111 - RISHEL, H.L. ET.AL./SCS FINAL 164
ACTIONS AT UNCONTROlLED HAZARDOUS ENGINEERS
WASTE SITES - AlBRECTH, O.W./MERL
1002 EMERCEIICY RESPONSE PROCEDURES FOR 01/01/83 - MELVOLD, R.V./ROCKVELL FINAL 23 EPA-600/O-/I4-023
CONTROL OF HAZARDOUS SUBSTANCE INTERNATIONAL
RelEASES . MCCARTHY, L.T./MERL
.
-------
PAGE NO. 2 SELECTED GUIDANCE DOCUM£NTS FOR VALLEY UOOD PRESERVING, INC.
05/'4/9'
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
No Vol TItle Dete Authors Status Pages Tier Attec'-nt. OSWER/EPA Number
.
.......... .... ........... ................
'00] ENVIRONMtNTAL REVIEW REQUIREMENTS ~/1]/87 - OERR/ERD FINAL 6 2 OSWER 19318.0,05
FOR REMOVAL ACTIONS
'005 INFORMATION ON DRINKING "ATER ~/19/88 ' F I EtDS, JR., FlNAL '7 2 1) MEMO: RELEASES FROM
ACTION LEVELS T .OSYER/ERD LAWFULLY APPLIED
PESTICIDES 2) MEMO DRIP
CONTAMINATION 3) GUIDANCE
FOR ETHYLENE DIBROMIDE IN
DRINKING H20
'006 SUPERFUND REMOVAL PROCEDURES, 02101/88 - OSWER/OERR FINAL 365 OSWER 19360.0-038
REVISION 13
'007 TME ROlE 0' EXPEOITED RESPONSE 0It12' /87 - lONGEST, M.l./DERR FINAL 3 2 OSWER 19360.0-038
ACTIONS UNDER SARA
4002 26 INTERIM FINAL GUIDANCE ON REMOVAL 10/06/87 - OSYER/DERR FINAL 9 2 OSWER 19360. '-01
ACTION LEVELS AT CONTAMINATED
DRINKING "ATER SITES (SECONDARY
REFERENCEJ
.. RI/FS . GENERAL
2001 3 EPA GUIDE FOR MINIMIZING THE 06/0'/85 - ENVIRONMENTAL RESEARCH FINAL 250 2 EPA/600/8-85/008
ADVERSE ENVIRONMENTAL EFFECTS OF LABORATORY
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05/11,/91
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INOEK ...
Doc
No Vol TItle Olte Authors Stltus Peges Tier Attlchments OSWER/EPA Number
........ ...... ............. ................
CLEANUP OF UNCONTROlLED
HAZARDOUS-VASTE SITES
2002 3 GUIDANCE FoR CONDUCTING REMEDIAL 10/01/88 . OSVER/OERR FI NAL 390 OS\O 19355.3,01
INVESTIGATIONS AND FEASIBILITY
STUDIES UNDER CERCLA
2005 " POlICT ON FLOOD PLAINS AND 08/01/85 - HEOEMAN, JR., V.N./OERR FINAL 9 Z OSVER I9Z8O.0-0Z
VETLAND ASSESSMENTS FOR CERCLA . LUCERO, C./OWPE
ACT! ONS
Z008 4 RI/FS IMPROVEMENTS 07/Z3/87 - LONGEST, H.L./OERR FINAL 11 Z 1) RI/FS IMPROVEMENTS OSVER 19355.0-20
2009 " RI/FS IMPROVEHEIITS FOllO'I-\'" 041Z5/88 - lONGEST, M.L./OERR FI NAl 16 2 1) RI/'S IMPIOVEMEIITS OSVER 19355.3-05
FOLLOII-\'" Z) REMEOIAL
INFORMATION TRANSFER
ACTIVITIES
2010 " SUPERFUND FEDERAL-LEAD REMEDIAL 1Z/01/86 . OERR DRAFT 179 OSVER 19355. t-1
PROJECT MANAGEMENT HANDBOOK
2011 5 SUPERFUND REMEDIAL DESIGN AND . 06/01/86 . DERR FINAL 100 OSVER 19355.0-4A
REMEDIAL ACTION GUIDANCE
.
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PACt! 110. ~ St!LECTED GOIDANCt! DOCUMENTS FOR VAllEY WOOD PRESERVING, INC.
05/1'/91
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
No Yo\ "t\. Date
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PAGE NO. 5 SELECTED GUIDANCE DOCUMENTS FOR VALLEY WOOD PRESERVING, INC.
05/11./91
CCMPENDIUH OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEK ...
Doc
No Vol TItle Dlte Authors Stetus Peges Iler Attechmentl OSWER/EPA NlJIi)er
......... .... ........... ................
PROCEDURES MANUAL I4-SITE ENTRY
2107 7 FIELD STANDARD OPERATING 04/01/85 - DERR/HRSD FI NAL 19 2 OSWER 19285.2-04
PROCEDURES MANUAL '6-WOIIIC ZONES
2108 7 FIELD STANDARD OPERATING 01/01/85 - OERR/HSCD FI NAL 24 2 OSWER 19285.2-03
PROCEDURES MANUAL .a-AIR
SURVE IllANCE
2109 7 FIELD STANDARD OPERATING 04/01/85 - OERR/HRSD FI NAL 26 2 I) SAMPLE SITE SAFETY OSWER 19285.Z-05
PROCEDURES MANUAL I9-SITE SAFETY PLAN AND OSHA SAFETY PLAN
PLAN Z) EMERGENCY OPERATION
CODES REAL TIME MONITOR
3) RESPONSE SAFETY
CHECK-OFF SHEET
2112 8 GUIDELINES AND SPECIFICATIONS FOR 06/01/87 - ORDIQUAllTY ASSURANCE FINAL 31 2 I) MEMO: GUIDANCE ON
PREPARING ~LI'Y ASSURANCE MANAGEMENT STAff PREPARING GAPP. OA'£O
PROGRAM DOC\MNTATlOII . 6/10/87
2113 8 LABORATORY DATA VALIDATION 07/01/88 - EPA DATA REVltV WORK DRAFT 20 2
FUNCTIONAL GUIDELINES 'OIl GROUP - BLETLER, R.VIAI
EVALUATING INORGANICS ANALYSES AND CO./SAMPLE HCMT.
OffiCE
- HSED
.
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PAGE NO. 6 SELECTED GUIDANCE DOCUMENTS FOR VALLEY WOOD PRESERVING, INC.
05/11,/91
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
No Vol Title Date Authors Status Pages Tier Attachment. OSVER/EPA Number
........ .... ........... ................
2115 8 PRACTICAL GUIDE FOR GROUND-VATER 09/01/85 - BARCELONIA, M.J., ET. FINAL 175 EPA/600/2-85/104
SAMPLING AL./ILLINOIS ST. VATER
SURVEY
- SCALF, M.R./ORD/ERL
2111 8 SOIL SAMPLING QUALITY ASSURANCE 05/01/84 - BARTH D.S. & MASON, B. FINAL
USER'S GUIDE J./U. OF NEVADA, LAS
VEGAS
2118 9+ TEST METHODS FOR EVALUATING SOliD 11/01/86 - OSVER FINAL 3000
VASTE, LABORATORY MANUAL
PHYSICAL/CHEMICAL METHODS, THIRD
EDITION (VOlUMES 1A, 1B, 1C, AND
,"
211' 11 USER'S GUIDE TO THE CONTRACT 12/01/88 - OERR/CLP SAMPLE FINAL
LABORATORY PROGRAM MANAGEMENT OFFICE
.. RI/FS - LAND DISPOSAL FACILITY TECHNOLOGY
2200 12 CoveRS FOR UNCONTROLLED HAZARDOUS 09/01/85 - MCANENY, C.C., ET. FINAL 475 2 EPA/540/Z-85/00Z
VASTE SITES AL./U.S. COE/VES
- HOUTHHOOFD, J.M./NVERL
2201 13 DESIGN, CONSTRUCTION, AND 11/01/08 - COLDHAN, J.L., ET. AL. FINAL 500 Z EPA/530/SV-86/007F
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PAGE NO. 7 SELECTED GUIDANCE DOCUMENTS fOR VALLEY WOOD PRESERVING, INC.
05/14/91
COMPENDIUM Of CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... I NOEl< ...
Ooc
No Vol TlUe Olte Author. Stltus Peges Tfer Attlchment. OSUER/EPA lumber
........ .
.... ........... ................
EVALUATION Of CLAY LINERS fOR INUS
VASTE MANAGEMENT fACILITIES . RCUlIER, M.H./RREL
2204 1J LAND DISPOSAL RESTRICTIONS 08/11/87 ' LONGEST, H.L./OERR fiNAL . 23 2 1) SUMMARY OF MAJOR lDR
. LUCERO, G./OWPE PROVISIONS AND CALIFORNIA
LIST PROHI81TIONS Z)
OTHER AT TACHS CITED ARE
AVAILABLE II fED. REG.
2210 15 SUPPLEMEITARY GUIDANCE ON 08/07/86 ' WEDDLE, B.R./PERMITS FINAL 60 2 1) ANALT.II AND OS\IER 19480.00-1]
DETERMINING LINER/LEACHATE AND STATE PROGRAMS OIY flNGERPRIITIIG Of
COlLECTION SYSTEM COMPATIBILITY UNEXPOSED & EXPOSED
POlYMERIC MEMBRANE LINERS
MATRECON, INC. 2) SEC.
3019: EXPOSURE INFO. AND
HEALTH ASSESSMENTS
2211 15 TECHNICAL GUIDANCE DOCUMENT: 10/01/86 - HERRMANN, FINAL 118 2 OSUER 19472.003
CONSTRUCTION QUALity ASSURANCE J.G./NVERL/LAND POLLUTION
FOR HAZARDOUS WASTE LAND DISPOSAL CONTROL DIY
FACILITIES . OS\IER
3DDO 25 APPLICABILITY OF THE HSUA MINIMUM 04/01/85 . SKINNER, J ./OSV FINAL 3 2 OSUER 19480.01(85)
TECHNICAL REOUIREMENTS RESPECTING
LINERS AND LEACHATE COLLECTION
.
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'AGE 110. 8 SELECTED GUIDANCE DOCUMENTS FOR VAllEY UOOO 'RESERVING, INC.
05/14/91
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
110 Vol Title Date Authora Status Pages Tier Attachmenta OSWER/EPA IIumber
.
........ .... ........... ................
SYSTEMS (SECONDARY REFERENCEJ
.. RI/FS . OTHER TECHNOlOGIES
2300 16 A CCMfIEIIOIUM OF TECHNOlOGIES USED 09/01/87 - ORO/CUI FINAL 49 2 EPA/625/8-87/014
III THE TREATMENT OF HAZARDOUS
"ASTES
2308 18 HANDBOOK FOR 06/01/86 . CULLINANE JR., M.J. FINAL 125 EPA/540/2-86.001
STABiliZATION/SOliDIFICATION OF ET.Al. /U.S. COE/VES
HAZARDOUS "ASTE - HOUTHHOOFD,
J.M./ORD/HIlERL
2309 19 HANDBOOK REMEDIAL ACTION AT WASTE 10/01/85 - ORD/HWERl FI NAl 560 EPA/6Z5/6-85/006
DISPOSAL SITES (REVISED) - OSVER/OERR
2]11 20 MOBll£ TREATMEIIT TECHNOlOGIES FOR 09/01/86 - CAMP, DRESSER, AND FINAL 130 E'A/540/2-86-oo]F
SUPERFUND WASTES MCKEE INC.
- GALER, L-D./HRSD
2315 21 REVIEW OF III-PLACE TREATMEIIT 11/01/84 - SIMS, R.C., ET.AL./JRB FINAL 350 £PA-540/2-84-oo]B
TECHNIQUES FOR CONTAMINATED ASSOCIATES
SURFACE SOILS-VOl. Z: BACKGROUND - BARKLEY, II./MERl
INFORMATION FOR III.SITU TREATMENT
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PACE 110. 9 SELECtED GUIDANCE DOCUMENtS FOR VALLEY WOOD PRESERVING, INC.
051 "'91
COMPENDIUM OF CERCLA RESPONSE SELECtiON GUIDANCE DOCUMENTS
... INDEX ...
Doc
No Vol Tltte Dlte Authors . Stltus Plges Tier Attlchment. OSWER/EPA Number
............. ...". ........... ................
2316 21 REVIEW 0' III-PLACE TREATMENT 09/19/84 - OS\IER/OERR FINAL 165 EPA/540/2-84-oo3A
TECHNlauES FOR COIITAHINATEO - ORO/HERL
SURFACE SOILS-VOL 1: TECHNICAL
EVALUATlOII
2317 22 SlUIU" TREIICH COIISTRUCTION FOR 02101/84 - OERR FINAL 220 £PA/540/2-84-oo1
POlLUTION MIGRATION COIITROl . OROIHERL
2318 22 SYSTEMS TO ACCELERATE IN SITU 09/01/86 - AMDURER, M., FINAL 285 £PA/540/2-86/OO2
StABILIZATIOII OF WASTE DEPOSITS ET.AL./ENVIROSPHERE CO.
- ORUBE, W./HVERL
2319 22 TECHNOLOGY SCREEIIING GUIDE FOR 09/01/88 - OS\lER/OERR FI NAL 130 EPA/540/2-88/004
TREATMENt OF C£RCLA SOilS AND
SLUDGES
2320 22 TREAtMENt TECHNOlOGY IRIEFS: 07101/86 - MRL FINAL 35 2 EPA/6OO/8-86/017
ALTERNATIVES TO HAZARDOUS WASTE
LANDFILLS
.. RI/F$ . GROUND-WAtER MONitORING & PROT£CtION
21,03 21, GROUND-WATER PROTECTION STRATEGY 08/01/84 - OFFICE OF GROUND-YATER FI NAL 65 2 £PA/440/6-84-oo2
PROTECTION
.
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PAGE NO. '0 SELECTED GUIDANCE DOCUMENTS FOR VALLEY UOOO PRESERVING, INC.
05/"/9'
COMPENDIUM OF CERClA RESPONSE SELECTION GUIDANCE DOCUMENTS
... I NOEX ...
Doc
No Yol title Dete Authors Stetus Pages Tier Atteeh8ent. OSWER/EP~ Number
........ .... .-......... ...-.-..........
2404 24 GUIDELINES FOR GltOONlHIATER '2/0'/86 - OFFICE OF GROUND-WATER DRAFT 600 2
CLASSIFICATION UNDER THE EPA PROTECTION .
2407 25 RCRA GROUND WATER MONITORING 09/0'/86 - EPA FINAL 270 2 OSWER 19950.'
TECHNICAL ENFORCEMENT GUIDANCE
DOCUMENT nEGO)
.. AIIARS
3001 25 CERClA COMPLIANCE AND OTHER '0/02,1g.5 - PORTER, J.W./OSWER FINAL '9 ,) POTENTIALLY APPLICABLE OSWER 19234.0-2
ENVIRONMENTAL STATUTES OR RelEVANT AND
APPROPRIATE REQUIREMENTS
3002 25 CERClA COMPLIANCE WIT" OTHER LAWS 08/08/88 - OERR DRAFT 245 2 OSWER 19234.' -0'
MANUAL
3003 25 EPA'S IMPLEMENTATION OF THE OS/2'/87 - THOMAS, L.M./EPA FINAL 4 2
SUPERFUIIO AMENOMENTS AND
REAUTHORIZATION ACT OF '986
3005 25 INTERIM RCRA/CERCLA GUIDANCE ON 03/27/86 - PORTER, J.W./OSVER FINAL 8 2 ') COMB I N I NG HAlAROM OSWER 19347.0-'
NON-OONTIGUOS SITES AND ON-SITE WASTE SITES FOR REM-
MANAGEMENT OF WASTE AND TREATMENT ACTION
RESIDUE
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PACE NO. t1 SELECTED GUIDANCE DOCUMENTS fOR VALLEY UOOD PRESERVINC, INC.
05/14/91
COMPENDIUM OF CERClA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
110 Vol Tttle Date Authors Status Pages Tier Attach8enta OSVER/EPA I~r
........ .... ........... ................
2407 25 RCRA CROUND'WATER MONITORING 09/01/86 . EPA FINAL 270 2 OSVER 19950.1
TECHlllCAl ENFORCEMENT GUIDANCE
DOCUHENT(TECD) [SECONDARY
REFER£NCE]
9001 32 RCRA/CERCU DECISIOIS MADE 01 06/24/85 . KILPATRICK, FINAL 3 2
REMEDY SELECT 101 [SECONDARY N./COMPLIANCE BRANCH,
REFERENCE] OIIPE
.. WATER QUAll'Y
400t 26 GUIDANCE DOCUMENT FOR PROVIDIIIG 02/01/88 ' OERR FINAL 64 2 OSVER 19355.3,03
ALTERNATE VATER SUPPLIES
'002 26 IIITERIM FIliAL GUIDANCE 01 REMOVAL 10/06/87 . OS\IER/OERR FINAL 9 2 OSVER 19360.1,01
ACT 101 LEV£LS AT CONTAMINATED
DRIIKIIG VATER SITES
.. RISK ASSESSMEIT
5000 27 ATSO. "EAlT" ASSESSMENTS 01 NPL 06/16/86 . DEPT. OF HEALTH AND DRAFT 14 2
SITES HUMAN SERVICES/ATSDR
500t 27 CHEMICAL, PHYSICAL & 810LOGICAl 09/27/85 . CLEMENT ASSOCIATES, FINAL 320 2 OSVER 19850.3
PROPERTIES OF COMPOUNDS PRESENT INC.
.
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PAGE 110. '2 SELECTED GUIDANCE DOCUMENTS FOR VALLET YOOD PRESERVING, INC.
05/''/91
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
No Vol TIUe D.te Authors S te tUs Pages Tier Attachments OSWER/EPA'Number
..-..... .... ............ ................
AT HAZARDOUS VASTE SITES
5003 27 GUIDEliNES FOIt CARCINOGEN RISK 09/24/86 - EPA FINAL 13 2
ASSESSMENt (FEDERAL REGISTER,
SEPTEMBER 24, '986, P.33992)
5004 27 GUIDELINES fOR EXPOSURE 09/24/86 - EPA FINAL 14 2
ASSESSMENt (FEDERAL REGISTER,
SEPTEMBER 24, '986, P. 34042)
5005 27 GUIDELINES fOlt HEALTH ASSESSMENT 09/24/86 - EPA FINAL 14 2
OF SUSPECT DEVELOPMENTAL
TOXICANtS (fEDERAL REGISTER,
SEPTEMBER 24, 1986. P. 34028)
5006 27 GUIDEliNES FOIt MAGENECITY RISK 09/24/86 - EPA fiNAL 8 2'
ASSESSMENT (FEDERAL REGISTER.
SEPTEMBER 24, P. 34006)
5001 21 GUIDELINES JOlt THE HEALTH RISK 09/24/86 - EPA fll'Al 13 2
ASSESSMENt Of CHEMICAL MIXTURES
(FEDERAL REGISTER, SEPTEMBER 24,
'986, P.34014)
'5008 28+ NEAlTH EfFECTS ASSESSMENT 09/01/84 - ORD/CHEA/ECAO fiNAL 1750 2 EPA/540/1-86/001-OS8
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'AGE 10. U SELECTED GUIDANCE DOCUMENTS FOR VALLEY WOOD PRESERVING. INC.
05/14/91
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUHENTS
... INDEX ...
Doc
10 Vol TlUe Dlte Author. Status Peges TIer Atteehmentl OS\IEII/EPA llumer
........ .... ........... ................
DOCUMENTS (58 CHEMICAL PROFILES) - OSWER/CERR
VOl. 28: ACETONE, ARSENIC,
ASBESToS, BARIUM, BENZO(A)PYRENE.
CADMIUM, ETC.
5009 31 INTEGRATED RISK INFORMATION / / - CHU FINAL 2
SYSTEM (IIIIS) fA COMPUTER-BASED
HEALTH RISK INFORMATION SYSTEM
AVAILABLE THROUGH
E-MAll--BROCHURE ON ACCESS IS
I NClU)EDJ
5011 31 PUllIC MEALTII RISIC EVALUATION 09/16/88 - DERR/TOXICS INTEGRATION FINAL 2
DATABASE (PMIIED) ~EII'S MANUAL BRANCH
AND TWO DISKETTES CONTAINING THE
DBASE I II PLUS SYSTEM AilE
I HClU)ED]
5013 31 SUP£IIFUND. EXPOSURE ASSESSMENT 04/01/88 - OERII FINAL 160 OS\IEII 19285.5-1
MANUAL
501' 31 SUPEIIFUND PUBLIC HEALTH 10/01/86 - CERR FINAL 500 OSWEll 19285.4-1
EVALUATION MANUAL - OSWER
5015 31 TOXICOlOGY HANDBOOK 08/01/85 - lIFE SYSTEMS, INC. DRAFT 126 2 OS\IER 19850.2
.
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PACt: NO. 14 SELECTED GUIDANCE DOCUMENTS FOR VALLt:Y WODD PRESERVING, INC.
05/14/91
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
U. INDEX U.
Doc
No Vol TItle Dete Authors Status Pag~s TI~r AttllChtllenU OSWER/EPA IlUltler
-....... .... ........... ................
- TYBURSKI, T.E./ME
8000 32 ENDANGERMENT ASSESSMENT GUIDANCt: 11122/85 - PORTt:R, J.V./OSYER FINAL " 2 OSWER 19850.0-1
(SECONDARY REfERENCE]
** COST ANALYSIS
6000 32 REMEDIAL ACTION COSTING 10/01/87 - JRB ASSOCIATES/CH2M FINAL S6
PROCEDURES MANUAL Hill
- ORO/MERL
- OSYER/OERR
6001 32 REMOVAL COST MANAGE"EIIT MANUAL 04/01/88 - OSYER/OERR FINAL 170 OSWERf9360.0-028
*. COMMUNITY RELATIONS
7000 32 COMMUNITY RELATIONS IN SUPERFUND: 06/01/88 - OERR FINAL 188 2 1) CHAP. 6 OF THE COM. OSVER 19230.0-03B
A HANDBOOK (INTERI" VERSION) REL. HANDBOOK 11/03/88
U ENFORCEMENT
8001 32 INTERIM GUIDANCE ON POTENTIAllY 05/16/88 . PORTER, J.V.IOSYER FINAL 37 2 OSWER f9835.1A
RESPONSIBLE PARTY PARTICIPATION
IN REMEDIAL IIIVESTIGATIONS AND
FEASIBiliTY STUDIES
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"AGe MO. 15 SELECTED GUIDANCE DOCUMENTS 'OR V~llE' VOOD "RESERVING, INC.
05/11./91
COMPENDIUM OF CfRClA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
110 Vo\ Htle Oate ~uthof'l Status Pages Her Attachmenta ~R/EPA NUitler
........ .... ........... ................
.. NEV ADDiTIONS
9002 33 INTERIM 'INAl GUIDANCE ON 06/01/89 INTERIM ~R 19355.3,02
PREPARING SUPERFUND OECISION FINAL
DOCUMENTS
9003 33 SUPERFUND GRCUID VATER I SSUE I 10/01/88 -PUlS, R.V. EPA/540/4-B9/001
GROUND VATER SAMPLING FOR METALS -BARCElONA, M.J.
ANAlYSES
9005 33 GROONO "ATER ISM: PERFORMANCE / / -KEElEY, J.F. EPA/540/4-B9/00s
EVALUATIONS OF PUMP'ANO-TRE~T
REMED I A TI ONS
9009 33 .ATION~l OIL & HAZARDOUS 01/01/85 92
SUBSTANCES POlLUtiON ICONTlilGENCY
GUID~NCE, PART 300, 40 CFR CH. 1
(1/1/85 EDITION), pp. 664 - 155
9010 33 SUPERFUND AMENDMENTS & 10/11/86 99'" CONGRESS OF U.S. 130
REAUTHORIZATION AtT OF '986
(SARA)
9011 RISK ASSESSMENT GUIDANCE FOR '2/01/89 IIITERIM EPAI540/1-B9/002
SUPERFUND' VOlUME 1, HUMAN FI NAl
HEALTH EVALUATION MANUAL (PART A)
.
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PAGE NO. 16 SELECTED GUIDANCE DOCUMENTS fOR VALLEY WOOD PRESERVING, INC.
05/1'/91
COMPENDIUM Of CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
... INDEX ...
Doc
NO Vol TltI. Date Author. Statue Plg.1 TIer Attachment. OSWE./EPA Number
........ .
.... ............ ................
9012 2 RISK ASSESSMENT GUIDANCE fOR 03/01/89 INTERIM EPA/540/1.89/001A
SUPERfUND. VOltI'E 2, FINAL
ENVIRONMENTAL EVALUATION MANUAL
9015 CERCLA COMPLIANCE VITH OTHER LAUS 08/01/89 INTERIM OS\IER 9234.1.02
MANUALr PART II . CLEAN AIR ACT FINAL
AND OTHER ENVIRONMENTAL STATUTES
AND STATE REQUIREMENTS
9019 SUPERfUND LOR GUIDE 17: 12/01/89 2 OSVER 9347.3.08fS
DETERMINING UHEN LAND DISPOSAL
RESTRICTIONS (LDRI) ARE "RELEVANT
AND APPROPRIATE" TO CERCLA
RESPONSE ACTIONS
9020 RISK ASSES_IT GUIDAIICt fOR 12/15/89 INTERIM
SUPERfUND NOMAII HEALTH RISK fI NAL
ASSES_NTr U.S. EPA REGION IX
RECClKNDATIONS
9021 A GUIDE TO DEVELOPING SUPERfUIID 05/00/90 fACT 4 OSVER 9335.3.02'S.1
RECORDS Of DECISION SHEET
9022 GUIDANCE ON REMEDIAL 06/01/85 fiNAL OSWER 9355.0.068
INVESTIGATIONS UNDER CERCLA
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PAGE 110.
05/14/91
Doc
110
9023
9038
901,2
.
17
Vo\
tltte
GUIDANCE 01 FEASIBILITY STUDIES
UNDER CERClA
NATIONAL OIL AND MAlARDeuS
SUBSTANCES POLLUTION
CONTINGENCIES PLANI FINAL RUlE,
PART II, 40 CFR PART ]00 (]/8/9O
EDITION) pp. 8666.8865
REGION 9 ENVIRONMENTAL PROTECTION
AGENCY DRINKING VATER STANDARDS
AND HEALTH ADVISORY TABLE
SELECTED GUIDANCE OOCUHENTS FOR VALLEY WOOD PRESERVING, INC.
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE OOCUMENTS
... I NOEll ...
Oate
........
06/01/85
0]/08/90
01/91
Authors
Stltus
FINAL
BRUCE MACLER
Plgel
200
27
Tier Attachmenta
OSVER/EPA '~r
.... ...........
.
............-...
OSVER 9355.0'OSC
EPA-OW-OO"
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