United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-92/086
September 1992
&EPA Superfund
Record of Decision
Purity Oil Sales, CA
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request o<
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document AH supplemental material is, however, contained in the administrative record
for this site.
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R09-92/086
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Purity Oil Sales, CA
Second Remedial Action - Final
S. Report Date
09/30/92
7. Authors)
8. Performing Organization RepL No.
8. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. ContracUC) or Grant(G) No.
(C)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.w.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
15. Supplementary Notes
PB93-964508
16. Abstract (UmH: 200 words)
The 6.8-acre Purity Oil Sales site is a former waste oil re-refining facility in the
township of Malaga, Fresno County, California. Land use in the area is mixed
agricultural, industrial, and residential, with the North Central Canal flowing along
the southern border of the site. The town of Malaga surrounds the site at distances of
about 1/2 mile or more. From 1934 to 1975, waste oil was re-refined onsite using a
number of treatment processes, including clarification, chemical addition, dehydration,
distillation, and filtration. During its history, the facility has changed ownership
several times, and the property is now in the custody of the state. Oil and
by-products from the re-refining process were stored in sumps and tanks and disposed of
onsite in unlined pits. In 1973, at the request of the county, Purity Oil backfilled
the waste pits with soil but did not remove any of the waste. Recent investigations
have revealed that the most highly contaminated soil is in the former waste pit areas
and extends from the surface to the ground water, and that the eastern 2.5 acres of the
property demonstrates surface soil contamination to a 2-foot depth. In 1986 and 1987,
two removal actions were initiated by the state and EPA, which involved removal of
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Purity Oil Sales, CA
Second Remedial Action - Final
Contaminated Media: soil, sediment, debris
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), other organics (PAHs,
pesticides), metals (arsenic, chromium, lead)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
50
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-35)
Department of Commerce
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EPA/ROD/R09-92/086
Purity Oil Sales, CA
Second Remedial Action - Final
Abstract (Continued)
1,800 cubic yards of hazardous materials and 30,000 gallons of waste oil and water from
an above-ground tank to be disposed of offsite. A 1989 ROD addressed remediation of the
ground water and tanks, as OU1, and provided for the removal of seven above-ground tanks
and their contents and allowed private well users downgradient of the site to be
connected to city or county water systems. This ROD addresses a final remedy for OU2,
the contaminated soil at the site. The primary contaminants of concern affecting the
soil, sediment, and debris are VOCs, including benzene, PCE, TCE, toluene, and xylenes;
other organics, including PAHs and pesticides; and metals, including arsenic, chromium,
and lead.
The selected remedial action for this site includes constructing a slurry wall around the
perimeter of the site to minimize migration of contaminants; excavating approximately
500 cubic yards of contaminated canal sediment and spreading them over the site; filling
the excavated areas with 8,600 cubic yards of imported soil; applying foam to control
emissions during excavation and slurry wall construction; transporting and disposing of
rubble uncovered during the excavation process offsite, possibly at a RCRA facility;
enclosing the entire length of the North Central Canal in a reinforced concrete pipe;
treating 72,000 cubic yards of deep soil onsite using a soil vapor extraction (SVE) to
remove VOCs; treating air emissions from the SVE process using carbon adsorption, prior
to discharge to the air; disposing of spent activated carbon offsite at a permitted RCRA
facility; covering the site with a RCRA multi-layer cap, with a retaining wall to support
the cap; monitoring ground water; conducting environmental monitoring to ensure the
integrity of the cap; and implementing institutional controls, including deed
restrictions. The estimated present worth cost for this remedial action is $36,254,000,
which includes an annual O&M cost of $741,000 for 9.4 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil clean-up goals were not provided; however, vadose zone monitoring
will be performed to ensure that the SVE system is reducing the VOC mass so that it no
longer threatens to contaminate ground water at levels above SDWA MCLs.
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RECORD OF DECISION
For The
PURITY OIL SALES, INC.
Superfund Site,
Soils Operable Unit
Prepared by
The U.S. Environmental Protection Agency
Region IX
San Francisco, California
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TABLE OF CONTENTS
PURITY OIL SALES RECORD OF DECISION
Soils Operable Unit
Section Page
Declaration i
Decision Summary 1
I. Site Name, Location and Description 1
II. Site History and Enforcement Activities 1
III. Highlights of Community Participation 6
IV. Scope and Role of the Operable Unit 6
V. Summary of Site Characteristics 7
VI. Summary of Site Risks 9
VII. Description of Alternatives 15
VIII. Nine Evaluation Criteria 21
IX. Summary Analysis of Alternatives Against 23
the Nine Criteria
X. The Selected Remedy 25
XI. Statutory Determinations 31
XII. Documentation of Significant Changes 33
Appendix A Applicable or Relevant and Appropriate Requirements
Appendix B Responsiveness Summary to Public Comments
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Purity Oil Sales Site
Malaga, California
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Purity Oil Sales site, which was 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 Contingency Plan (NCP). This decision is based on the
Administrative Record for this site.
The State of California concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This operable unit is the second action of two operable units for
the site. The first operable unit involved remediation of the
groundwater. This second operable unit addresses contaminated soil
which is the source of the groundwater contamination. This action
addresses the principal threats at the site through a combination
of treatment and containment and is considered the final action to
be taken by EPA at the site.
The major components of the selected remedy include:
. Treatment through Soil Vapor Extraction of soils from 14
feet below the surface to the water table;
. Capping the site in accordance with the Resource
Conservation and Recovery Act Subtitle C requirements;
. Installing a slurry wall around the perimeter of the site;
. Conducting environmental monitoring to ensure the effective-
ness of the remedial action.
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STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
_ _
Daniel W. l*Q
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DECISION SUMMARY
I. Site Name, Location and Description
The 6.8 acre Purity Oil Sales site is located approximately one-
half mile south of the Fresno city limits, in the township of
Malaga, California (Figure 1) . The site is in a zone defined as
heavy industrial under the Fresno County General Plan. The site is
located in a mixed-use area and is surrounded by agricultural and
industrial land on the west, a scrap iron yard on the north, a
residential trailer park and market on the northeast, a propane
distributor on the east, a small farm on the southeast, and a used
auto parts business on the south. The North Central Canal flows
along the southern boundary of the site (Figure 2).
About one-half mile to the west and southwest of the site are
fields of oats, alfalfa, cotton, fruit trees, and grapes. The town
of Malaga, which has a medium density residential area, surrounds
the site at distances of about one-half mile and more.
The site is located in a non-attainment area for the following air
quality standards: ozone, carbon monoxide (CO) and PM-10.
The Purity site and the surrounding areas do not provide habitat
for or sustain any rare or endangered species of plant or animal.
There are no signs of any significant wildlife or vegetation on the
site itself, other than scrub grasses.
All structures on the site have been removed and the site has been
partially regraded.
XI. Site History and Enforcement Activities
Waste oil was re-refined at the site from approximately 1934 to
1975. Waste oil was collected from businesses such as service
stations, car dealers, truck stops, electrical transformer yards,
military facilities, and municipalities. The used oil was re-
refined using a number of treatment processes including
clarification, chemical addition, dehydration, distillation, and
filtration. The oil and by-products from the re-refining process
were collected and stored in sumps and storage tanks and were
disposed of on-site in unlined sludge pits. A composite diagram of
the approximate locations of the buildings, storage areas, and
waste disposal areas from 1942 to 1973 is shown in Figure 3.
In 1973, Purity Oil Sales began complying with a Fresno County
Superior Court Order to empty and backfill the waste pits. By early
1975, the waste pits had been completely filled with soil and
demolition debris. However, no evidence is available to indicate
that petroleum wastes stored in the pits were emptied during this
period.
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\
FRESNO
CITY
mile
RDD63320.RI
FIGURE 1
SITE LOCATION MAP
REMEDIAL INVESTIGATION REPORT
PURITY OIL SALES SITE
FRESNO, CALIFORNIA
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COMI
COTTON COMPRESSOR
FIGURE 2
VICINITY LAND USES
REMEDIAL INVESTIGATION REPORT
PURITY OIL SALES SITE
FRESNO. CALIFORNIA
QUALITY
POOR
ORIGINAL
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HorlionUl Tanks
HorlionUI Tank
Impoundmant
Doubla - Day Warahbuia
May 18. 1842
Approximate Soil* 1:5200
Saturated Soil-* Lwaate Plla
Sump
Doubla - Bay WarahouM
b. January 31. 1060
Approximate Seal* 1:8300
REFERENCE: BACKGROUND REPORT, DOHS 1885
Doubla - Day
WarahouM
C. 1057 to 1867
Praaant In 1W7 and 19(1 Photographi
(8885888 Pra*ant In 1IS7 Photograph Only
Approximate Seal* 1:0000
Doubla - Day WarahouM
1970 to 1973
Approximate Scale 1:6000
FiounE 3
SITE LAYOUT 1942 - 1973
REMEDIAL INVESTIGATION REPORT
PURITY OIL SALES SITE
FRESNO. CALIFORNIA
mo.Hi
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During its history, the re-refining facility changed ownership
several times. The original owners were William Dickey and Ray
Turner, who operated the facility from 1934 to 1948. In 1948,
William Siegfried and Robert Hall purchased the site as Paraco Oil,
Inc. The site and facilities were sold to Michael Marcus of Purity
Oil Sales, Inc., in 1965. In 1975, Michael Marcus filed for
bankruptcy, and the site was held by the State of California for
non-payment of taxes. The site was sold to an individual in 1979,
who was granted a recision of the sale in 1982. The site was
returned to the custody of the State of California where it remains
today. Title of the property was returned to Purity Oil Sales, Inc.
in 1984.
In February 1982, the EPA Emergency Response Team, the California
Department of Toxic Substances Control (DTSC) and the California
Regional Water Quality Control Board carried out a joint site
investigation that included soil and groundwater sampling and air
emissions monitoring. The site was placed on the National
Priorities List in December 1982.
The Department of Toxic Substances Control was designated lead
agency for the site and published a Remedial Investigation Report
on May 12, 1986. During the state's remedial investigation, EPA's
Emergency Response Team removed about 1,800 cubic yards of
hazardous material from the site.
In January 1986, EPA assumed the lead for the site and expanded the
remedial investigation work performed by the state to include
additional soil and groundwater studies.
During September 1987, EPA's Emergency Response Team removed
approximately 33,000 gallons of oil and water from one of seven
above ground tanks to eliminate the potential for an oil spill.
EPA issued a Remedial Investigation Report in October 1988. A
Feasibility Study and a Proposed Plan for Soil and Groundwater were
issued in April 1989. The Regional Administrator signed a Record of
Decision (ROD) for the Groundwater and Tanks Operable Unit on
September 26, 1989.
EPA conducted two remedial actions in accordance with the ROD. In
October 1991, seven large above-ground steel tanks and their
contents were removed from the site. In March 1992, private well
users downgradient of the site were connected to either the Malaga
County Water District or the City of Fresno water system.
In May 1992, EPA issued a Soil Solidification Feasibility and Cost
Evaluation Report and a Revised Soil Vapor Extraction and Cap
Feasibility Study. A Revised Proposed Plan for Soil was issued in
June 1992.
General Notice letters for the groundwater operable unit were
issued to 108 Potentially Responsible Parties (PRPs) on April 19,
1990. EPA issued Special Notice letters for the groundwater
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operable unit to 87 PRPs on April 1, 1991. After EPA and the PRPs
failed to negotiate a settlement, EPA issued a Unilateral
Administrative Order on September 30, 1991 to the California
Department of Transportation, Chevron Corporation, Cummins West,
Foster Poultry Farms, Morrison-Knudsen Engineers, Pacific Gas &
Electric Company, Phillips Petroleum, Southern Pacific
Transportation Company, and Unocal. The Administrative Order
required the Respondents to design and construct a groundwater
extraction, treatment, and disposal system. EPA issued General
Notice letters for the soils operable unit on June 5, 1992 to the
existing 87 PRPs and to 59 additional PRPs.
III. Highlights of community Participation
The Remedial Investigation (RI) Report, the Feasibility Study (FS)
Report, the Soil Solidification Feasibility and Cost Evaluation
Report, the Revised Soil Vapor Extraction and Cap Feasibility
Study, and the Revised Proposed Plan for Soil were released to the
public in June 1992. These documents were made available to the
public in both the Administrative Record and the information
repository maintained at the Superfund Records Center in Region 9
and at the Fresno Central Library. The notice of the availability
of these two documents was published in the Fresno Bee on June 8,
1992 and in the Spanish language newspaper Vida En El Valle on June
17, 1992. A public comment period was held from June 8, 1992
through July 10, 1992. A request for an extension to the public
comment period was made by the California Department of Toxic
Substances Control and the San Joaquin Valley Unified Air Pollution
Control District. As a result, the public comment period was
extended to August 10, 1992.
A public meeting was held on June 22, 1992. At this meeting,
representatives from EPA answered questions about problems at the
site and the remedial alternatives under consideration. A response
to the comments received during this period is included in the
Responsiveness Summary.
This decision document presents the selected remedial action for
the Purity Oil Sales site in Malaga, California, chosen in
accordance with CERCLA, as amended by SARA, and, to the extent
practicable, the National Contingency Plan. The decision for this
site is based on the Administrative Record.
IV. Scope and Role of Operable Unit
As with many Superfund sites, the problems at the Purity Oil Sales
site are complex. As a result, EPA organized the work into two
operable units (OUs) . These are:
. OU One: Contamination of the groundwater
. OU Two: Contamination in the soils.
EPA has already selected a groundwater treatment remedy for OU One
in a ROD signed September 26, 1989. The OU One action is in the
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remedial design stage and is being performed by PRPs under an
Administrative Order. This ROD is for OU Two and addresses
contaminated soil.
V. Summary of Site Characteristics
Soil contamination extends from the surface to the groundwater
table, with the most highly contaminated layers occurring between
0-14 feet, in the location of the former waste pits. A cross
section of site soils is shown in Figure 4.
Contaminated surface soils extend vertically to a depth of two feet
and are defined as the eastern 2.5 acres of the site where the
office and warehouses were located. Waste pits were not located in
this area. These surface soils are contaminated with organic
compounds, pesticides, oil and grease, and a variety of metals.
The levels of organic compounds in the surface soils are generally
below the California Total Threshold Limit Concentration (TTLC)
values for definition as a state hazardous waste. The pesticide
concentration for 4,4-DDT exceeds the California TTLC value in one
location. Four locations had PCB concentrations up to 11 parts per
million (ppm), which is well below the TTLC value of 50 ppm. For
inorganics, all metals except lead were detected at concentrations
below the TTLC. The TTLC value for lead is 1,000 ppm. Lead
concentrations range from 18,000 ppm to 27,000 ppm in surface soil.
The pH of on-site surface soil samples vary from 0.9 to 8.1.
The surface soils have not been determined to be RCRA listed waste
or RCRA characteristic waste based on the EP Toxicity test. TCLP
has replaced EP Toxicity as the test method used by EPA to
determine the leachability of toxic constituents. Toxicity is one
characteristic that defines a waste as a Resource Conservation and
Recovery Act (RCRA) hazardous waste. A Toxicity Characteristic
Leaching Procedure (TCLP) test was not conducted for surface soils.
The waste pit area contains numerous organic compounds, including
benzene, toluene, polyaromatic hydocarbons (PAHs), methylene
chloride, phthalates, acetone, and numerous solvents. Below the
waste pits, the organic compound concentrations decrease rapidly.
Concentration levels range from < 10 to 50,000 ppm. Toluene was
detected in most waste pit locations onsite, in concentrations
ranging from 0.004 to 4,200 ppm. Toluene was also detected in off-
site background borings. This off-site contamination is present
north, south, and west of the site.
Samples from the waste pit area indicate elevated lead values and
low pH values less than or equal to 2. The maximum concentration of
lead in the buried waste is 19,600 ppm. The mean concentration of
lead in the buried waste is 695 ppm. The state TTLC (1,000 ppm) and
Soluble Threshold Limit Concentration (STLC) standard (5 ppm) for
lead are exceeded. The state TTLC standard for organic lead (13
ppm) is also exceeded. The waste in layers B and C is RCRA
characteristic based on exceedence of the federal TCLP standard of
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a
o
o>
Q)
u.
c
o
?
«
UJ
WEST
300
290
280
270
o 260
250
240
Waste Pit Area
* Former Plant «-
Site Area
EAST
Aveage Qroundwater Elevation 248.0
LEGEND
A Soil, construction rubble, waste sludge
B Tar/sludge with soil
C Visually contaminated silty sand (native soil)
D Slightly contaminated silty sand
E Uncontaminated to slightly contaminated silty sand Figure 4
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5.0 ppm for lead. Figures 5-4 through 5-23 in the RI present the
chemical investigation results from soil borings.
Lead concentrations in samples taken from locations along the
slopes of the North Central Canal above the water surface ranged
from 1,200 ppm to 13,000 ppm and exceed the state TTLC standard for
lead of 1,000 ppm.
VI. Summary of site Risks
The baseline risk assessment provides the basis for taking action
and indicates the exposure pathways that need to be addressed by
the remedial action. It serves as the baseline indicating what
risks could exist if no action were taken at the site. This section
of the ROD provides the results of the baseline risk assessment
conducted for this site.
The particular chemicals of concern identified in the risk
assessment are listed in Table 1. The toxicity profiles of the
chemicals of concern are included in the Public Health Evaluation
(CH2M Hill, 1989).
Acute toxic effects of lead, the primary soil contaminant, include
encephalopathy, abdominal pain, hemolysis, liver damage, renal
tubular necrosis, seizures, coma and respiratory arrest. Chronic
exposure can affect the hematopoietic system, the nervous system,
and the cardiovascular system. Lead inhibits several key enzymes
involved in heme biosyntheses. One characteristic effect of
chronic lead intoxication is anemia, by reduced hemoglobin
production and shortened erythrocyte survival. In humans, lead
exposure has resulted in nervous system injury including reduced
hand-eye coordination, reaction time, visual motor performance, and
nerve conduction velocity. Children appear especially sensitive to
lead-induced nervous system injury. Lead can also affect the
immune system and produce gingival lead lines. Epidemiological
studies have indicated that chronic lead exposure may be associated
with increased blood pressure in humans. Exposure to lead is
associated with sterility, abortion, neonatal mortality, and
morbidity. Organolead compounds are neurotoxic.
The exposure pathways of concern that were evaluated for potential
health risks are 1) direct contact with contaminated site soils by
trespassers and future on-site workers or residents, 2) inhalation
of site dusts by current near-site residents or workers, and future
on-site residents or workers, and 3) direct contact with
contaminated canal sediments by trespassers, farm workers, and
irrigation district workers.
The risks for the site were calculated for both on-site residential
and occupational exposure. However, since the site is located in an
area that is zoned industrial, it is unlikely that there will be
future residential uses on-site. Residential exposure was assumed
to occur 24 hours a day, 365 days a year for a 70-year period.
Occupational exposure was assumed to occur five days per week for
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Table 1
CONTAMINANTS OF CONCERN AT THE
PURITY OIL SITE
Acetone
Aldrin
Antimony
Arsenic
Barium
Benzene
Benzoic acid
Beryllium
Beta-BHC
Bis(2-ethylhexyl)phthalate
2-Butanone
Cadmium
Carbon disulfide
Carbon tetrachloride
Chlorobenz ene
Chloroform
Chromium
Cyanide
4,4-DDD
4,4-DDE
4,4-DDT
Di-n-butyl phthalate
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethane
Dieldrin
Diethyl phthalate
Endosulfan
Ethylbenzene
Gamma-BHC (Lindane)
Heptachlor
Heptachlor epoxide
Lead
Methylene chloride
N-nitrosodiphenylamine
Mercury
4-Methyl-2-pentanone
2-Methyl phenol
4-Methyl phenol
Napthalene
N-nitrosodiphenylamine
PAHsf*
PCBs
Phenol
Selenium
Silver
Styrene
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Vanadium
Vinyl chloride
Xylenes
Zinc
a,
PAHs which are considered carcinogenic are assessed as a
group (Benzo[a] anthracene, Benzo[Jc] fluoranthene and
Chrysene).
PCBs are assessed as a group (Arochlor 1248, Aroclor 1254,
Aroclor 1260).
CVR146/046
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a 40 year period.
These calculations result in numbers called risk levels, which
express the risk in terms of the chance of cancer occurring. A
risk level of 1 in 1,000,000 means that one person out of one
million people so exposed could develop cancer as a result of the
exposure. This risk level is expressed in scientific notation as
lxlO-6.
For a Super fund project, EPA's goal is to reduce risk for a site to
within or above the range of 1 cancer in 10,000 (1x10-4) to 1 in
1,000,000 (1x10-6) persons.
For non-carcinogens (chemicals that do not cause cancer but may
cause other adverse health effects), the risk level is calculated
in terms of the Hazard Index (HI). The Hazard Index is a numerical
indicator of the transition between acceptable and unacceptable
exposure to multiple chemicals. If the HI exceeds 1.0, unacceptable
non-carcinogenic health effects may result (e.g., kidney or liver
disfunction). When the HI is less than 1.0, insignificant adverse
health effects are expected.
Surface Soil and Buried Waste
The data summary for chemicals of concern in surface soil is shown
in Table 2. The data summary for chemicals of concern in deep on-
site soils is shown in Table 3.
Carcinogenic risk associated with both the surface soil and the
buried waste was determined to be within, or below, the acceptable
risk range. Risks for surface soil ingestion ranged from 3x10-6,
(most probable occupational) to 7x10-5 (worst case adult
residential). Risk associated with deep soil ingestion was
calculated to be 6x10-7, most probable occupational exposure.
Hazard Indexes calculated for potential surface soil exposure
through ingestion range from 2.8 (worst case adult residential;
worst case occupational) to 39.4 (worst case 10-kg child
residential exposure). The Hazard Index of soil below 1 foot was
less than 1.0.
Canal Sediment
Contaminant concentrations in canal sediments are summarized in
Table 4. Lead accounts for over 98 percent of the hazard indexes
for adult (HI = 3.95), 35-kg child (HI = 15.8) and 10-kg child (HI
= 55.3) worst case exposure scenarios. The potential carcinogenic
risks estimated for exposure to canal sediments through ingestion
range from 6x10-8 (most probable adult occupational) to 2x10-6
(worst case adult trespass).
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
11
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Table 2
DATA SUMMARY FOR CHEMICALS OF CONCERN IN SURFACE SOILS
Observed
Concentrations
Chemical of Concern
Aldrin
Antimony
Arsenic
Barium 1
Beryllium
Beta BHC
Bis(2-ethylhexyl)phthalate
Cadmium
Chromium
4,4-ODD
4,4-DDE
4,4-DDT
Dieldrin
Diethyl phthalate
Endosulfan
Heptachlor
Heptachlor epoxide
Lead 14
Mercury
PCS
Phenol
Silver
Zinc 1
Maximum
(ugAg)
100
8,400
22,000
,120,000
1,500
85
7,800
17,000
43 ,000
150
1,525
590
350
150
540
170
1,400
,300,000
900
-^12,400
50,000
2,400
,410,000
Mean
(ugAg)
78
3,300
8,500
295,500
600
81.5
3,800
17,000
89.4
195
177
139
215
102
187
2,669,000
190
4,045
22,000
800
344,900
Standard
Deviation
20
1,000
5,700
306,000
200
4.9
3.3
9,800
51.9
413
277
183
423
212
357
4,709,000
210
4,883
28,000
300
417,000
Number of
Detections/
Number of
Samples
03/27
01/27
26/27
27/27
03/27
2/27
01/27
27/27
27/27
05/27
04/27
04/27
03/27
01/27
04/27
01/27
08/27
27/27
16/27
05/27
01/27
01/27
27/27
CVR146/052
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Table 3
DATA SUMMARY FOR CHEMICALS OF CONCERN IN
DEEP ONSITE SOILS
Observed
Concentrations
Chemical of Concern
Acetone
Barium
2-butanone
Bis (2-ethylhexyl}phthalate
Cadi urn
Carbon disulfide
Chlorobenzene
Chloroform
1 , 1-Dichloroethane
1 , 2-Dichloroethane
Ethylbenzene
Lead
Methylene chloride
4-Methyl -2-Pentanone
2-Methyl phenol
4-Methyl phenol
Naphthalene
PAHs
PCBs .£.
Phenol
Selenium
Tetrachloroethene
Trichloroethene
1,1, 1-Trichloroe thane
Toulene
Xylene
Zinc
Maximum
(ug/kg)
7,200
2,250,000
8,700
12,000
2,100
770
2,900
310
1,100
960
19,000
11,700,000
620
9,100
1,100
56,000
91,000
102,000
1,975
99,000
1,200
3,200
10
4,100
20,000
120,000
616,000
Mean
(ug/kg)
1,270
202,200
720
3,345
600
247
245
38
133
36.6
882
695,000
284
626
657
4,612
6,682
9,049
544
4,811
600
310
6.8
201
1,459
6,485
71,000
Standard
Deviation
3,571
449,000
2,380
5,301
300
357
731
74
285
147.9
2,672
2,220,000
218
1,465
401
9,049
13,040
12,342
837
14,211
600
736
2.4
771
3,656
19,275
103,000
Number of
Detections/
Number of
Samples
09/74
68/68
17/70
12/67
09/68
03/23
17/77
22/74
02/17
2/77
25/77
67/68
06/74
20/56
03/31
09/52
23/77
5/76
3/23
13/63
03/68
24/100
29/77
05/74
64/77
30/62
68/68
-------
Table 4
DATA SUMMARY FOR CHEMICALS OF CONCERN IN CANAL SEDIMENTS
Observed
Concentrations
Chemical of Concern
Barium 1
Beryllium
Bis (2-ethylhexyl)phthalate
Cyanide
4, 4 -ODD
4,4-DDE
Dieldrin
Endosulfan
Gamma BHC (Lindane)
Heptachlor
Heptachlor epoxide
Lead 13
Mercury
Naphthalene
Zinc 1
Maximum
(ug/kg)
,770,000
1,300
100,000
4,400
280
19
130
230
84
77
1,400
,200,000
200
54,000
,260,000
Mean
(ug/kg)
645,000
600
38,300
1,320
80
104
149
47
48
210
3,815,000
70
29,500
262,000
Standard
Deviation
625,000
200
34,490
1,100
133
56
272
32
33
425
5,017,000
50
23,699
430,000
Number of
Detections/
Number of
Samples
10/10
01/10
02/10
10/10
04/10
01/10
01/09
01/10
01/09
01/09
04/10
10/10
01/10
02/10
10/10
CVR146/051
-------
to public health, welfare, or the environment.
VII. Description of Alternatives
A detailed evaluation of the alternatives for treatment of soil is
presented in the April 12, 1989 Feasibility Study, the May 1992
Soil Solidification Feasibility and Cost Evaluation and the May
1992 Revised Soil Vapor Extraction and Cap Feasibility Study.
Alternatives selected for discussion in the June 1992 Revised
Proposed Plan for Soil are listed below.
Actual levels of soil contaminants vary with depth throughout the
site. It should be noted that the 0-14 feet and 14-40 feet soil
layers discussed are approximate levels only. Actual cleanup will
depend on the depth of contamination at specific locations.
Alternative 1: No Action
The No Action Alternative serves as a "baseline" for developing the
risk assessment, and its evaluation is required by law. It assumes
that no action would occur at the site, allowing unrestricted
access to contaminated soils.
Alternative 2: RCRA Equivalent Cap
Manor Components of the Remedial Alternative. The major features of
this alternative include covering the site with a multi-layer RCRA
equivalent cap, and enclosing the North Central Canal in a
reinforced concrete pipe.
Containment Components: The 6.8 acre site would be capped and
closed as a RCRA Subtitle C landfill in accordance with the
requirements specified in 22 CCR 66264.310 for landfill closure,
which require a cap to have a permeability less than or equal to
the permeability of the natural underlying soil.
The cap would be designed and constructed to promote drainage,
minimize erosion of the cover, and provide long-term minimization
of migration of liquids through the underlying soils. Consistent
with the requirements of 22 CCR 66264.117, long-term operation and
maintenance (O&M) would be conducted to monitor groundwater and to
insure the integrity of the cap.
The cap proposed for the site (Figure 5) would consist of a 1 foot
foundation layer, 2 feet of bentonite/clay mix, a high density
polyethylene liner, 1 1/2 feet of sand followed by 2 feet of top
soil, and a gas/drainage collection system. The total height of the
cap would be 7 feet. A retaining wall to provide slope stability
would be constructed around the cap. The top of the wall would be
5 feet above grade. The wall is anticipated to be 2 feet thick.
15
-------
Vegetation
Topsoil
Water Drainage
Granular Sand
Geotextile
HOPE Liner
Bentonite/Clay Mix
Geotextile
Gas Collection
Foundation Soil Layer
o
o
r^ & <=>
C=> O n
0 ^ ^ o
O O <=> _ c
_Corrtaminatea/Sbir - /
Figure $: RCRA Equivalent Cap
-------
Alternative 3: Boil Vapor Extraction (SVE) and RCRA Equivalent Cap
with Slurry Walls
Man or Components of the Remedial Alternative. The major features of
this alternative include treating soils from 14 feet to the water
table with Soil Vapor Extraction (SVE), constructing a slurry wall,
covering the site with a multi-layer RCRA equivalent cap,
constructing a retaining wall to support the cap, and enclosing the
North Central Canal in a reinforced concrete pipe.
Treatment Components: Soil Vapor Extraction (Figure 6) is a process
in which organic contaminants are volatilized from the soil, using
a series of on-site air injection wells and extraction wells. The
extracted Volatile Organic Compounds (VOCs) are then treated by
carbon adsorption prior to discharge to the air. Carbon adsorption
is a treatment system where the volatilized contaminants are forced
through tanks containing activated carbon, a specially treated
material that attracts the contaminants. The contaminants cling to
the carbon, and the air leaving the system would meet air quality
standards.
Soil from 0-14 feet is contaminated with oil and grease which would
greatly inhibit the effectiveness of SVE wells. Therefore, SVE
wells will treat soil from 14 feet to the water table. A
significant amount of the VOCs in soil deeper than 14 feet
(approximately 24,387 pounds) would be removed by the action of the
SVE system. Approximately 25% or 17,950 pounds of VOCs in soil
from 0-14 feet are expected to be drawn into the lower layers of
soil and be treated by the SVE system. The SVE wells would be
drilled through the RCRA cap and screened in Layers C,D, and E. The
SVE system would operate in place underneath the cap.
Containment Components: Soil from 0-14 feet would be covered by a
RCRA equivalent cap and surrounded by a slurry wall. See
Alternative 2 for a discussion of a RCRA equivalent cap. A slurry
wall acts as an underground barrier, surrounding the contaminated
soil. The slurry wall, constructed of clay and soil, would be 25
feet deep which is 10 feet below the deepest level of Layer B, the
most highly contaminated layer of soil.
Alternative 4; Excavation and On-site Incineration of Soil at 0-14
feet. SVE and Capping
Manor Components of the Remedial Alternative. The major features of
this alternative include excavation and treatment of soils at 0-14
feet with on-site incineration, stabilization of the incineration
ash, treatment of soils from 14-40 feet with SVE, and covering the
site with a soil and clay cap.
Treatment Components: Approximately 64,000 cubic yards of
contaminated soil and canal sediment would be excavated and treated
through rotary kiln incineration. The incineration process would
destroy 99.99% of the principal organic hazardous constituents
(POHCs) in soil from 0-14 feet. The results of a rotary kiln
17
-------
So/7 Gas
from Other Blowers
Treated Air
to Atmosphere
r i
^
i \
.«
1 !
\
Vacuum
Blower
Activated
Carbon
Adsorber
System
I n ject Ion/ Ext ra ct I on
Wells
Contaminated
Soil Layers
Figure 6 Soil Vapor Extraction System
-------
incineration treatability study demonstrated that ash from the
incinerator would fail the TCLP standard for lead. Therefore, ash
would be solidified to immobilize lead in compliance with the Land
Disposal Restrictions (LDR) treatment standard for lead of 5.0
milligrams/liter (mg/1).
Soil from 14-40 feet would be treated through SVE. See Alternative
3 for a discussion of SVE.
Containment Components: The site would be covered with a soil and
clay cap. The soil and clay cap would consist of a 2 foot silty
sand foundation layer, 2 to 3 feet of gravel and bentonite/clay
mix, a 1 to 2 foot drainage sand layer followed by a 2 foot layer
of top soil. The cap would be 8 feet high and would contain a
drainage collection system.
Alternative 5: Excavation and Solidification of Soil at 0-10 Feet.
SVE and Capping
Manor Components of the Remedial Alternative; The major features of
this alternative include excavation and treatment of soils at 0-10
feet with on-site solidification, treatment of soil from 14-40 feet
with SVE and covering the site with a soil and clay cap.
Treatment Components: Approximately 38,000 cubic yards of material
from Layer A and canal sediment would be excavated. Rubble larger
than 3 feet in size would be removed from the excavated material
and later returned to the excavation and backfilled with solidified
material. The excavated material would be fed directly to a thermal
unit to remove VOCs. The exhaust gas from the thermal unit would be
treated in a venturi scrubber and a carbon adsorption system to
remove particulates, sulfur dioxide, and VOCs. The material
discharged from the thermal unit would be further screened to
remove debris larger than 4 to 6 inches. This debris would also be
backfilled with solidified material. The soil from the thermal unit
would be transferred to a rotary mixer/blender (pugmill). Solid
additives would be metered from storage bins or silos and fed to
the pugmill. Similarly, measured flows of a liquid reagent would
be fed into the pugmill. After mixing in the pugmill for a
predetermined period, the processed soil would be discharged and
placed back in the excavation.
Soils from 14-40 feet would be treated using SVE. See Alternative
3 from a discussion of SVE.
Containment Components: A soil and clay cap would be constructed
over the stabilized material. See Alternative 4 for a discussion
of the cap. The increase in site elevation due to solidification
alone would be 2 feet. The total increase in site elevation due to
solidification and installation of the cap would be 9 1/2 feet.
19
-------
Alternative 6; Excavation and Solidification of soil at 0-14 feet.
8VE and Capping
Mai or Components of the Remedial Alternative. The major features of
this alternative include excavation and treatment of soils at 0-14
feet with on-site solidification, treatment of soil at 14-40 feet
with SVE and covering the site with a soil and clay cap.
Treatment Components: The treatment components for this alternative
are similar to alternative 5. Approximately 64,000 cubic yards of
material from Layers A and B and canal sediment would be excavated
and treated in the thermal unit and then solidified.
Containment Components: A soil and clay cap would be constructed
over the stabilized material. See Alternative 4 for a discussion of
the cap. The increase in site elevation due to solidification alone
would be 3 1/2 feet. The total increase in site elevation due to
solidification and installation of the cap would be 11 feet.
Alternative 7; Excavation and Solidification of Soil Exceeding 500
ppm Lead. SVE and Capping
Major Components of the Remedial Alternative. The major features of
this alternative include excavation and solidification of soils
containing lead in excess of 500 ppm, treating the remaining soil
with SVE, and covering the site with a soil and clay cap.
Treatment Components: The treatment components of this alternative
are identical to Alternative 5. Approximately 69,680 cubic yards of
soil containing lead in excess of 500 ppm and canal sediment would
be excavated and treated in the thermal unit and then solidified.
Containment Components: A soil and clay cap would be constructed
over the stabilized material. See Alternative 4 for a discussion of
the cap. The increase in site elevation due to solidification
alone would be 3/4 feet. The total increase in site elevation due
to solidification and installation of the cap would be 11 1/4 feet.
Alternative 8; Excavation and Off-Site Treatment and Disposal of
Soil at 0-14 Feet, SVE and Capping
Manor Components of the Remedial Alternative. The major features of
this alternative include excavation of soil from 0-14 feet and
treatment and disposal at an off-site landfill, treatment of soil
from 14-40 feet with SVE, and covering the site with a soil and
clay cap.
Treatment Components: Approximately 64,000 cubic yards of
contaminated soil and canal sediment would be excavated and
transported off-site for treatment and disposal at a permitted
hazardous waste disposal facility.
Soil from 14-40 feet would be treated using SVE. See Alternative 3
for a discussion of SVE.
20
-------
Containment Components: The site would be covered with a soil and
clay cap. See Alternative 5 for a discussion of the cap.
Table 5 provides cost estimates and cleanup times for each of the
alternatives.
VIII. Nine Evaluation Criteria
EPA uses nine criteria, or standards, to evaluate alternatives for
cleaning up a National Priorities List site. The nine criteria are
summarized below:
1. Overall Protection of Human Health and the Environment
Addresses whether or not a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Addresses whether or not a remedy will meet all federal and
state environmental laws and regulations, or provide grounds
for waiving a particular ARAR.
3. Long-term Effectiveness and Permanence
Refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time,
once cleanup goals have been met.
4. Reduction of Toxicity, Mobility and Volume (TMV) through
Treatment
Refers to the ability of a remedy to reduce the toxicity,
mobility, and volume of the hazardous components present at
the site.
5. Cost - 30-year present worth
Evaluates the estimated capital, operation and maintenance
costs of each alternative.
6. Short-Term Effectiveness
Addresses the period of time needed to complete the remedy,
and any adverse impact on human health and the environment
that may be posed during the construction and implementation
period, until the cleanup standards are achieved.
7. Implementability
Refers to the technical and administrative feasibility of
21
-------
TABLE 5
Alternative Project Cost
*2 RCRA Equivalent Cap $24.686,000
*3 SVE & RCRA $36.254.000
Equivalent Cap
*4 Incineration.
0-1 4 feet,
SVE & Cap $74.756.000
*5 Solidification
0-10 feet
SVE, Cap $41,918,000
#6 Solidification
0-1 4 feet.
SVE, Cap $53,073,000
#7 Solidification
500 ppm lead
SVE. Cap $55,861,000
#8 Off-site
Treatment &
Disposal, 0-14
feet, SVE, Cap $63.659,000
Annual
Capital Cost Operation and Estimated Cleanup
Maintenance Cost Time in Years
$8,016,000 $736,000 2
$17,023.000 $741.000 9.4
$57,780.000 $60.000 7.5
$31.992,000 $60,000 9.6
$40.752,000 $60,000 7.6
$42.942,000 $60.000 7.8
$49,066,000 $60.000 6.5
-------
a remedy, including the availability of materials and services
needed to carry out a particular option.
8. State Acceptance
Indicates whether, based on its review of the information, the
state concurs with, opposes, or has no comment on the
preferred alternative.
9. Community Acceptance
Indicates whether community concerns are addressed by the
remedy, and whether or not the community has a preference for
a remedy.
In order for an alternative to be eligible for selection, it must
meet the first two criteria described above, called threshold
criteria.
IX. Summary Analysis of Alternatives Against tbe Nine Criteria
An evaluation of the eight alternatives in relation to the nine
decision making criteria is summarized below.
1. Overall Protection of Human Health and the Environment
All of the alternatives, with the exception of the "no action"
alternative, meet this criterion by minimizing or eliminating the
risks from direct contact with soils and by minimizing or
eliminating the source of groundwater contamination.
2. Compliance with ARARs
All of the alternatives, with the exception of the "no action"
alternative, meet this criterion. ARARs are not applied to the "no
action" alternative since no activity is taking place.
Since the "no action" alternative is not protective of human health
and the environment it will not be discussed further in the
criteria analysis.
3. Long-term Effectiveness and Permanence
The alternatives involving treatment or removal of the upper layers
of soil as well as treatment of the lower layers of soil, provide
the highest degree of long-term effectiveness.
The selected alternative, Alternative #3, would leave waste in
place in the upper layers. However, the waste will be isolated by
the cap and slurry walls, thus eliminating direct contact with the
waste material and minimizing leaching to groundwater. The selected
alternative will undergo a review every 5 years to insure
protection of human health and the environment as required by EPA
when waste is left in place.
23
-------
4. Reduction of Toxicity, Mobility and Volume through Treatment
All alternatives with the exception of Alternative #2, RCRA cap,
would remove approximately 24,387 pounds of VOCs from soil below 14
feet through the action of the SVE system.
Alternative #3 assumes that 25% or 17,950 pounds of VOCs in the
upper layers would move into the lower layers and be treated. The
mobility of contaminants in all soil layers would be reduced by the
cap and slurry walls.
The solidification alternatives, #5-#7, would reduce the toxicity,
mobility and volume of both volatile organic and inorganic
contaminants by heating the excavated waste to remove VOCs and then
stabilizing the soil to encapsulate the inorganics, including lead.
Approximately 99.99% of the VOCs in the upper layers of soil would
be destroyed through incineration, alternative #4. The incineration
ash would be stabilized, thereby encapsulating the lead.
5. Cost
See Table 5. The total project cost is the present value of capital
costs plus operation and maintenance costs.
6. Short-term Effectiveness
Alternative #2 would have the least short-term impacts on site
workers and nearby residents and workers because there would be no
excavation of the waste. All of the alternatives that have
excavation components (Alternatives #3-7) would have short-term
impacts on the community and workers due to air emissions generated
during excavation. Air emissions would be controlled.
See Table 5 for estimated clean-up times.
7. Implementability
All of the alternatives employ treatment technologies that have
been proven effective in the field. Additionally, treatability
studies performed on site waste showed that incineration and
stabilization were effective in treating the contaminated soil.
8. State Acceptance
The State Department of Toxic Substances Control supports the
preferred alternative, Alternative #3.
9. Community Acceptance
No community members attended the June 22, 1992 public hearing on
the Revised Proposed Plan for Soil or submitted written comments
during the comment period. Potentially Responsible Parties
submitted written comments which questioned the need for the SVE
24
-------
system.
Table 6 provides a comparative analysis of the eight alternatives
in relation to the nine criteria.
X. The Selected Remedy
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives using the nine criteria, and
the lack of adverse public comments, both EPA and the State have
determined that Alternative #3 (Soil Vapor Extraction and RCRA
Equivalent Cap with Slurry Walls) is the most appropriate remedy
for the Purity Oil Sales Site.
The first step in implementing this alternative, will be to
construct a slurry wall along the site boundaries to minimize the
migration of contaminants. The wall will be constructed by
excavating a trench approximately 25 feet deep and 2 to 4 feet wide
around the perimeter of the site. The trench will be filled with a
slurry of soil mixed with bentonite clay. Rubble uncovered during
excavation of the trench will depending on the level of
contamination be transported off-site to an appropriate RCRA
facility or disposed on-site. Foam will be applied as necessary to
control emissions during construction of the slurry wall.
Following construction of the slurry wall, the site will be graded
and all contaminated canal sediments will be excavated and spread
over the site. It is estimated that approximately 500 cubic yards
of sediment will require excavation. The western 2/3 of the site is
3 to 5 feet above the surrounding land due to the rubble used to
fill the former waste pits. Approximately 8,600 cubic yards of
imported soil will be used as fill material for the eastern 1/3 of
the site. Foam will be applied during excavation and spreading of
the canal sediment to control emissions. The entire length of the
canal along the southern boundary of the site will then be enclosed
in a reinforced concrete pipe.
The 6.8 acre site will then be covered with a cap capable of
satisfying the requirements under RCRA Subtitle C for closure of a
hazardous waste landfill. The cap should consist of a 1 foot
foundation layer containing a gas collection system, 2 feet of
bentonite/clay mix, a high density polyethylene (HOPE) liner, 1 1/2
feet of sand containing a drainage collection system, followed by
2 feet of top soil.
The gas collection system will deliver gases to a treatment system.
The system will include a scrubber to remove sulfur dioxide (SO2)
and a carbon adsorber to remove VOCs.
For SO2 removal, the treatment system will be designed for one
scrubber to achieve a 95 percent SO2 removal efficiency. Scrubber
blowdown, generated at an estimated rate of 16 gallons per day,
will be shipped off-site for disposal.
25
-------
TABLE 6
NINE CRITERIA LEVEL OF CONFIDENCE ANALYSIS
.' S
wm
*»WR». '
w&»\
raor\ ^
C681?
..»».....; *
»fHW> ~
8* ^
..<* :..:?:.:
**$$ a: "
LOW
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
&&£+ $*-
HIGH
HIGH
LOW
HIGH
$25
HIGH
LOW
LOW
LOW
JUH*«'3:
HIGH
HIGH
MEDIUM
HIGH
$36
HIGH
MEDIUM
HIGH
HIGH
IUMIV4'
HIGH
MEDIUM
HIGH
LOW
$75
MEDIUM
HIGH
LOW
LOW
**«; *
HIGH
MEDIUM
LOW
MEDIUM
$42
MEDIUM
LOW
LOW
MEDIUM
MX* * '
HIGH
MEDIUM
HIGH
MEDIUM
$53
MEDIUM
HIGH
LOW
MEDIUM
kifetP
HIGH
MEDIUM
HIGH
MEDIUM
$56
MEDIUM
HIGH
LOW
MEDIUM
£&?*>$>
HIGH
HIGH
HIGH
MEDIUM
$64
HIGH
HIGH
MEDIUM
HIGH
PPHE - PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
ARARs- COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
INCLUDING APPLICATION OF WAIVERS
LTE&P- LONG TERN EFFECTIVENESS AND PERMANENCE
STE - SHORT TERM EFFECTIVENESS
COST - TOTAL 30-YEAR PRESENT WORTH COST IN 1995 DOLLARS- IN MILLIONS
IMP. - IMPLEMENTABILITY
RTMVT- REDUCTION IN TOXICITY MOBILITY VOLUME THROUGH TREATMENT
SA - STATE ACCEPTANCE
CA - COMMUNITY ACCEPTANCE
-------
ALT. 1- NO ACTION
ALT. 2- RCRA EQUIVALENT CAP
ALT. 3- RCRA EQUIVALENT CAP, SLURRY WALLS, RETAINING WALLS, SVE
ALT. 4- EXCAVATION, ON-SITE INCINERATION (0-14 FEET), SVE, CLAY CAP
ALT. 5- EXCAVATION, ON-SITE SOLIDIFICATION (29,000 CUBIC YARDS), SVE, CLAY CAP
ALT. 6- EXCAVATION, ON-SITE SOLIDIFICATION (55,000 CUBIC YARDS), SVE, CLAY CAP
ALT. 7- EXCAVATION, ON-SITE SOLIDIFICATION (69,680 CUBIC YARDS), SVE, CLAY CAP
ALT. 8- EXCAVATION, OFF-SITE SOLIDIFICATION (55,000 CUBIC YARDS), SVE, CLAY CAP
HIGH- HIGH LEVEL OF CONFIDENCE THAT CRITERION WILL BE ACHIEVED
MEDIUM- MODERATE LEVEL OF CONFIDENCE THAT CRITERION WILL BE ACHIEVED
LOW- LOW LEVEL OF CONFIDENCE THAT CRITERION WILL BE ACHIEVED
N/A- NOT APPLICABLE
-------
For VOC removal, saturated gases from the scrubber will be heated
by a natural gas fired duct burner to raise the gas temperature by
approximately 20 degrees F to avoid condensation. One adsorber
will be designed to achieve a 95 percent VOC removal efficiency.
Another similar unit will be installed as a stand-by unit. It is
assumed that 1 pound of activated carbon would adsorb 0.15 pounds
of VOCs. The spent activated carbon will be disposed of off-site
at a permitted RCRA facility.
A retaining wall will be constructed around the cap to provide
slope stability. The wall will be designed to withstand the lateral
movement from a maximum credible earthquake. It is anticipated that
the top of the wall will be 5 feet above grade. The wall is
anticipated to be approximately 2 feet thick and the foundation is
anticipated to be approximately 3 feet deep.
Finally, SVE wells will be installed through the cap and screened
in Layers C, D, And E. The radius of influence of the SVE system
will cover the entire length and width of the site with the
possible exception of the 2.5 acre "front yard" area and the .5
acre area south of the North Central Canal. Additional sampling
and analysis will be performed in these areas during design to
determine the nature and extent of contamination. If it is
determined by EPA that the level of contamination in these areas
poses a risk to human health and the environment, the design of the
SVE system will insure that the radius of influence extends to
these areas.
Based on a radius of influence of 30 feet, an air flow rate of 40
cfm and a VOC extraction rate of 0.5 Ibs per day per well, EPA
estimates that 58 wells will be required to cover the site.
All SVE wells will be screened as appropriate to provide coverage
from 14 feet down to the water table. The wells will be designed to
be used interchangeably as extraction or air injection wells.
A significant amount of the VOCs in soil deeper than 14 feet
(approximately 24,387 pounds) will be removed by the action of the
SVE system. Approximately 25% of 17,950 pounds of VOCs in soil from
0-14 feet are expected to be drawn into the lower layers of soil
and be treated by the action of the SVE system. Tables 7 and 8 show
the type and average concentration of the major VOCs in Layers A
through E.
It is anticipated that four carbon adsorption systems, three active
and one backup, will be needed to adsorb VOCs extracted from the
soil. The amount of VOCs released to the atmosphere after treatment
in the carbon adsorber will meet state and federal air quality
standards.
Based upon the assumption that 25% of the VOCs in the upper layers
will move downward, an operation period of approximately 80 months
is anticipated for the SVE system. This assumes a system
availability of 80 per cent due to maintenance. The actual
operation time will be determined during design based on additional
28
-------
..'..-' . . ' TABLE .7 ':'-'. .. '\-. " : '," '.
VOC CONCENTRATION IN SOIL LAYERS A & B
Contaminated Soil Layer
Layer A, average concentration of VOCs in soil
(Samples at depths of 1 1/2 feet-5 feet)
Total Soil in Layer A = 29,000 yd3
Total VOCs Present in Layer A
Layer B, average concentration of VOCs in soil
(Samples at depths of 5 feet - 12 feet)
Total Soil in Layer B = 26,000 yd3
.rt**-\'.
Total VOCs Present in Layer B
Type and Average Concentration
of the Major Volatile Compounds0'
1 8,722 jig/kg
Benzene
Ethylbenzene
Chlorobenzene
Toluene
Trichloroethylene
Tetrachloroethylene
Xylene
2-Butanone
1,456
1 ,009,226 ng/kg
Benzene
Ethylbenzene
Chlorobenzene
Toluene
Trichloroethylene
Tetrachloroethylene
Xylene
4-Methyl-2 Pentanone
70,345
(19ppm)
1 .8%
6.6%
5.1%
28.8%
10.9%
6.5%
31 .6%
8.4%
Ib
(1 ,009 ppm)
1.8%
15.1%
2.0%
29.1%
8.9%
6.3%
26.1%
2.5%
Ib
The major compounds In Layer A are 97% of the total volatile organics in Layer A and the major compounds
in Layer B are 88% of the total volatile organics present in Layer B.
-------
TABLE 8
VOC CONCENTRATION IN SOIL LAYERS C, D, & E
Contaminated Soil Layer
"' -" '\ **',* ' ' ,'.-:« '-
': f -: *
Layer C, average concentration of VOCs in soil
(Samples at depths of 12 feet-20 feet)
Layer D & E, average concentration of VOCs in soil
(Samples at depths of 20 feet - 39 feet)
Type and Average Concentration
, of the Major Volatile
, "Compounds"'
134,134 iig/kg (134 ppm)
Benzene 1 .6%
Ethylbenzene 1 2.3%
Chlorobenzene 7.0%
Toluene 26.2%
Trichloroethylene 6.8%
Xylene 22.0%
2-Butanone 23.9%
42,512 |ig/kg (43 ppm)
Toluene 7.6%
Trichloroethylene 35.9%
Methylene Chloride 26.2%
4-Methyl-2 Pentanone 4.7%
2-Butanone 6.0% .
(1)
The major compounds in Layer C are 94% of the total volatile organics In Layer C and the major compounds
In Layers D and E are 80% of the total volatile organics present In Layers D and E
TOT
,- ;e5<~;"
.;S5Xl,' Layer}, /
Layer C
Layers D and E
AL VOCs IN LAYERS C,D AND
Amount of
Contaminated [Soil
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testing.
Once the cap and SVE system are constructed, monitoring wells will
be installed in accordance with RCRA in the vadose zone and
groundwater to determine if hazardous constituents are migrating
from the site.
In order to protect the cap, deed restrictions will be imposed on
the site to prohibit future excavation. The site may be suitable
for light industrial uses once cleanup levels have been achieved.
Applicable or Relevant and Appropriate Requirements fARARs)
ARARs are federal and state standards, requirements or levels of
control that Superfund remedies must meet. The ARARs identified for
the selected alternative are listed in Appendix 1.
Cleanup Levels
The purpose of this response action is to control risks posed by
direct contact with soils and canal sediments and to minimize the
migration of contaminants to groundwater.
The purpose of the SVE system will be to reduce VOC mass in the
vadose zone from 14 feet to the water table to a level that no
longer threatens to contaminate groundwater at levels above MCLs.
The threat to groundwater will be evaluated through vadose zone
monitoring and vadose zone contaminant transport modeling. The
Vadose Zone Transport Model (VLEACH) or a similar analytical tool
determined acceptable by EPA, will be used to determine contaminant
transport through the vadose zone. Vadose zone monitoring and
modeling data will be used by EPA to determine the need for
additional SVE or monitoring wells and to determine when to stop
operating the SVE system. Modeling information will be supplemented
by soil boring data taken between selected SVE wells and above and
below the screened intervals for each layer.
A request to evaluate the need to continue operation of the SVE
system will not be considered by EPA until the SVE system has
operated for a minimum of one year. This will allow the SVE system
to draw down and treat the most mobile VOCs in Layers A and B.
The groundwater monitoring system installed in compliance with RCRA
Subtitle C requirements and the SVE system will be maintained in
perpetuity. If it is determined that MCLs are being exceeded after
the SVE system has ceased operating, the SVE system and/or the
groundwater extraction wells will be re-activated under the
direction of EPA.
XI. Statutory Determinations
Under CERCLA section 121, EPA must select remedies that are
protective of human health and the environment, comply with
applicable or relevant and appropriate requirements (unless a
31
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statutory waiver is justified), are cost-effective, and utilize
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
In addition, CERCLA includes a preference for remedies that employ
treatment that permanently and significantly reduce the volume,
toxicity, or mobility of hazardous wastes as their principal
element. The following sections discuss how the selected remedy
meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through treatment of VOCs in soil deeper than 14 feet, thereby
eliminating them as a source of groundwater contamination. Also,
approximately 25% of the VOCs in the upper 14 feet of soil will be
drawn down to the lower layers by the action of the SVE system and
be treated.
The RCRA equivalent cap minimizes the risks from direct contact
with soils. The cap and slurry wall significantly reduce the
potential for rainwater to leach contaminants from the soil into
the groundwater.
There are no short-term threats associated with the selected remedy
that cannot be readily controlled. In addition, no adverse cross-
media impacts are expected from the remedy.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy will comply with all ARARs. The ARARs are
presented in Appendix 1.
Cost-Effectiveness
EPA believes this remedy will eliminate the risks to human health
at an estimated cost of $36,254,000, therefore the selected remedy
provides an overall effectiveness proportionate to its costs, such
that it represents a reasonable value for the money that will be
spent.
The selected remedy assures a high degree of certainty that the
remedy will be effective in the long-term because of the
significant reduction of the toxicity and mobility of the wastes
achieved through SVE and cap with slurry walls respectively.
Utilization of Permanent Solutions and Alternative Treatment
Technologies (or Resource Recovery Technologies) to the Maximum
Extent Practicable
EPA and the State of California have determined that the selected
remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective
manner for the soils operable unit at the Purity Oil Sales site. Of
those alternatives that are protective of human health and the
32
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environment and comply with ARARs, EPA and the State have
determined that this selected remedy provides the best balance in
terms of long-term effectiveness and permanence, reduction in
toxicity, mobility, or volume achieved through treatment, short-
term effectiveness, implementability, cost, while also considering
the statutory preference for treatment as a principal element and
considering state and community acceptance.
The selected remedy significantly reduces VOC levels, one of the
principal threats posed by the soil. This remedy will cost less
than treatment of all soil layers or off-site disposal. The
selection of a remedy which treats the contaminated soil is
consistent with program expectations that indicate that highly
toxic and mobile wastes are a priority for treatment and is often
necessary to ensure the long-term effectiveness of a remedy.
Lead, the other principal threat at the site, will not be treated.
However, the cap and slurry wall will prevent direct contact with
contaminated soil, thereby eliminating the exposure pathway for
lead.
Preference for Treatment as a Principal Element
By treating the contaminated soils by SVE, the selected remedy
addresses one of the principal threats posed by the site through
the use of this treatment technology. By utilizing treatment as a
significant portion of the remedy, the statutory preference for
remedies that employ treatment as a principal element is satisfied.
XII. Documentation of Significant Changes
The Proposed Plan for the Purity Oil Sales site was released for
public comment in June 1992. The Proposed Plan identified
Alternative #3, treatment of soil from 14-40 feet with Soil Vapor
Extraction, RCRA equivalent cap, slurry wall and enclosing the
North Central Canal, as the preferred alternative for soil
remediation. EPA reviewed all written and verbal comments submitted
during the public comment period. Upon review of these comments, it
was determined that areas beyond the planned RCRA cap which are
contaminated due to past site activities will be investigated
further during design.
Contamination exists in surface and deep soil off-site. If further
sampling and analysis during design indicates that these areas pose
a threat to human health and the environment they will be
remediated consistent with the design of the selected alternative.
It is anticipated that off-site surface soil contamination will be
excavated and brought on-site to be covered by the cap and that
off-site deep soil contamination will either be excavated and
brought on-site or remediated in place using SVE.
33
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APPENDIX A
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
-------
FEDERAL ARARS
Citation
..-
/: '''
\. Resource Conservation and Recovery Act (RCRA) as
amended by Hazardous and Solid Waste
Amendments (HSWA) (42 USC 6901 et seq.)
Hazardous Waste Control Act (HWCA) (Health and
Safety Code Section 25100-25395)
A. Characteristics of Hazardous Waste (CCR 66261.1-
66261.126)
Requirement Description
RCRA is the federal law providing requirements for hazardous waste
management including criteria for the identification of hazardous waste
and specific standards for the design, operation, and closure of
hazardous waste treatment, storage, or disposal units and facilities. EPA
has authorized California to administer the RCRA program. State
regulations will be cited for the authorized portions of the program.
RCRA requirements are generally applicable to CERCLA actions when
the following conditions are met:
(1) the waste meets the RCRA criteria for a listed hazardous waste or a
characteristic hazardous waste, and
(2) the waste is treated, stored or disposed (as defined in 40 CFR
260.10) after the effective date of the RCRA requirement.
RCRA identifies a solid waste as a hazardous waste if it exhibits the
characteristic properties of ignrtability, reactivity, toxicity, or for liquid or
aqueous wastes, corrostvity. The RCRA toxicity characteristic is based
upon the teachability of designated constituents as measured by the
Toxicity Characteristic Leaching Procedure (TCLP). Specific chemicals
identified at Purity Oil which are currently included in the toxicity criteria
are:
TCLP Maximum
Chemical EPA HW No. Concentration (mg/f)
Arsenic 0004 5.0
Barium D005 100.0
Benzene D018 0.5
Cadmium D006 1.0
Chlorobenzene D012 100.0
Chloroform D022 6.0
Chromium D007 ; 5.0
Heptachlor D031 0.008
Lead D008 5.0
Mercury D009 0.2
Methyl Ethyl Ketone 0035 200.0
Selenium 0010 1.0
Silver 0011 5.0
Tetrachloroethylene 0039 0.7
Trichloroethylene 0040 0.5
A
X
RA
A = Applicable
RA = Relevant and Appropriate
A-1
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FEDERAL ARARS
CKatlon
Requirement Description
RA
I. RCRA Location Standards
(22 OCR 66264.18)
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FEDERAL ARABS
Citation
Requirement Description
RA
1. (Continued)
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2. Land Treatment Unsaturated Zone Monitoring
(22 OCR 66264.90)
3. Closure and Post-Closure (22 CCR 66264.110-
66264.120)
4. Landfill Closure and Post-Closure Care (22 CCR
66264.310)
migrated beyond the outer containment layer prior to the end of post-
closure care. The regulations are applicable to 'regulated units' which
are surface impoundments, waste piles, landfills, and land treatment units
that received hazardous wastes after July 26,1982.
The RCRA-equivalent closure would not meet the definition of regulated
unit However, the closure includes leaving untreated waste in the
ground. Therefore, groundwater monitoring requirements are relevant
and appropriate for assuring effective protection.
Because all wastes are not removed from the disposal area, vadose zone
(unsaturated zone) monitoring requirements that require monitoring of soil
and soil-pore liquids as feasible to determine whether hazardous
constituents are migrating, are relevant This requirement should be
considered appropriate only to the extent that the remedial design can
feasibly incorporate vadose zone monitoring.
RCRA closure of a 'regulated unit* requires minimization of the need for
further maintenance or control; minimization or elimination of postclosure
escape of hazardous waste, hazardous constituents, leachate,
contaminated runoff, or hazardous waste decomposition products; and
disposal or decontamination of equipment, structures, and soils.
Because this alternative leaves hazardous constituents in place, closure
and post-closure requirements are relevant and appropriate. The landfill
at the Purity Oil site should be closed pursuant to these regulations.
Closure of a landfill requires a final cover designed and constructed to:
prevent the downward entry of water into the landfill for a period of at
least 100 years; function with minimum maintenance; promote drainage
and minimize erosion of the cover, accommodate settling and subsidence
so that the cover's integrity is maintained; and have a permeability less
than or equal to the permeability of natural subsoils present. After final
closure, all post-closure requirements contained in 22 CCR 66264.117
through 66264.120, including maintenance and monitoring, must be
complied with throughout the post-closure care period. In addition, a
control system designed to collect gases emitted from the buried waste
and convey these gases to a treatment device is required unless it is
demonstrated that significant amounts of toxic or flammable gasses will
not be emitted from the buried waste.
A - Applicable
RA - Relevant and Appropriate
A-3
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FEDERAL ARARS
Citation
Requirement Description
RA
5. Land Disposal Restrictions for Hazardous Debris
(22 OCR 66268, General)
(57 PR 160, Hazardous Debris Rule)
Land disposal restrictions are applicable to RCRA wastes that are
excavated and placed either offsite or onsite. Debris is defined as
materials that are primarily non-geologic in origin such as man-made
synthetic manufactured materials, or construction and demolition
materials. On August 18,1992, EPA promulgated treatment standards to
be attained prior to land disposal of debris which is a restricted RCRA
waste.
II. Clean Water Act (CWA) (33 USC 1251-1376; 40 CFR
100-199)
A. National Pollutant Discharge Elimination System
(NPDES) (40 CFR 122-125)
Both onsite and offsite discharges from CERCLA sites to surface waters
are required to meet the substantive CWA NPDES requirements,
including discharge limitations, monitoring requirements, and best
management practices. Only offsite CERCLA discharges to surface
waters must be NPDES-permitted. Stormwater runoff that is channeled to
a receiving water body is included under this requirement.
III. Clean Air Act (CAA) (42 USC 7401 et seq.)
National Emission Standards for Hazardous Air
Pollutants (NESHAPs)
A. Fugitive Emissions Sources (40 CFR 61.240)
Standards are given in the regulation for equipment that either contains
or contacts a liquid or gas that is at least 10% by weight volatile
hazardous air pollutants (VHAP), defined as regulated substances
including benzene and vinyl chloride. Regulated equipment includes
pumps, compressor pressure relief devices, sampling connection
systems, open-ended valves or lines, valves, flanges and other
connectors, product accumulator vessels and control devices or systems.
Although the treatment units at Purity Oil are not expected to process
VHAP at concentrations in excess of 10% by weight, these standards are
still considered relevant and appropriate because their intent is to
regulate and minimize VHAP emissions.
A - Applicable
RA = Relevant and Appropriate
-------
FEDERAL ARARS
Citation
Requirement Description
RA
B. Benzene Waste Operation Standards (40 CFR
61.344)
Owners or operators of chemical manufacturing plants, coke by-product
recovery plants, petroleum refineries, or RCRA-permitted hazardous waste
facilities that treat, store, or dispose of hazardous waste (TSDFs) from
these three types of facilities must comply with benzene emission
standards if they manage a total quantity of benzene in excess of 10
megagrams per year (11 tons/year). These standards include general
treatment and operation requirements and specific requirements for
surface impoundment (defined as waste management units containing
liquids wastes or wastes with free liquids), tanks, containers, and oil-water
separators. The surface impoundment operation standard requires that
the unit be equipped with a cover that does not release detectable
benzene emissions as indicated by an instrument reading less than 500
ppmv above background. Again, the treatment units at Purity Oil are not
expected to manage in excess of 10 megagrams per year of benzene,
but these standards are still relevant and appropriate.
A = Applicable
RA = Relevant and Appropriate
A-5
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:'T-- .:'.''%&''* '- "'- -' ' .. " - ":' STATE ARARS ' '..''<'
'"' ' " ' ';.':'"f;':^-citallon'^^^; :" -'''' :: '
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1. Hazardous Waste Control Act (HWCA) (Health
and Safety Code Section 25100-25395)
A. Criteria for Identifying Hazardous Waste (22
CCR 66261.1-66261.126)
Requirement Description
HWCA provides the state law for the management of hazardous waste including
the state criteria for the identification of hazardous waste and standards for the
design, operation, and closure of hazardous waste treatment, storage, and
disposal facilities. While this program closely parallels the federal RCRA program
it contains some components with requirements In excess or more stringent than
RCRA.
Hazardous waste may be identified according to any of the following criteria
according to specified test procedures.
Toxictty Criteria: Toxicity of hazardous waste is established by LD^ or LC^,
criteria.
Persistent and Bioaccumulative Toxic Substances: Total Threshold Limit
Concentrations (TTLCs) and Soluble Threshold Limit Concentrations (STLCs) have
been established to identify hazardous waste. Chemicals detected at Purity Oil
that have STLC or TTLC values are the following:
Chemical STLC(mg/l) TTLC(mci/kg)
Arsenic 5 500
Barium 100 10,000
(excludes Ba SO^)
Cadmium 1.0 100
Chromium (total) 560 2,500
Copper 25 2,500
Lead 5 1,000
Mercury 0.2 20
Nickel 20 2,000
Silver 5 500
Trichloroethylene 209 2040
Vanadium 24 2,400
Zinc 250 5,000
Corrosivity Criteria: If, when a waste is mixed with an equivalent weight of water, a
liquid is produced which corrodes steel according to EPA SW-846 Test Method
1110 SW-846, it is a hazardous waste.
List of Special Wastes: These include baghouse and scrubber wastes such as
from APCD's and drilling muds from oil and gas wells.
A
X
RA
A * Applicable
RA - Relevant and Appropriate
-------
STATE ARARS
Citation
Requirement Description
RA
Porter-Cologne Water Quality Act (WC 13000-
13806) (23 CCR 2510-2533)
Class I Waste Management Units
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New waste management units shall have a 61-meter (200-
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STATE ARARS
Citation
Requirement Description
RA
C. Closure and Post-Closure for Interim Status
and Permitted Facilities (22 CCR
66264.110-66264.120)
A hazardous waste management unit facility shall be closed in a manner that
minimizes the need for further maintenance and controls, minimizes, or eliminates
postclosure escape of hazardous waste, leachate, contaminated rainfall, or waste
decomposition products to the ground or surface waters, or the atmosphere.
Closure shall be completed within 90 days after receiving the final volume of
hazardous waste. When closure is completed, all facility equipment and
structures shall be properly disposed of, or decontaminated by removing all
hazardous waste and residues. Post-closure care, including environmental
monitoring, shall continue as long as the waste presents a potential threat to the
environment.
Closure and post-closure care requirements are relevant and appropriate because
it proposes to leave either untreated or treated waste at the site within engineered
containment systems. It is relevant and appropriate for the monitoring and
containments used for the untreated waste and the wastes treated in situ.
8
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O.
Porter-Cologne Water Quality Act (WC 13000-
13806; 23 CCR 1050-2836).
A. Water Quality Monitoring for Classified
Waste Management Units (23 CCR 2550)
The Porter Cologne Water Quality Act provides broad statutory authority to protect
water quality by regulating waste disposal and requiring hazardous waste
cleanup. Regulations for monitoring and corrective action are applicable to
persons responsible for discharges at waste management units which are closed,
abandoned, or inactive on the effective date of the regulations,' meaning that the
SWRQC and the RWQCB have jurisdiction over waste disposal sites abandoned
prior to the enactment of requirements (§ 2510.(g)). Porter-Cologne delegates
standard-setting authority to the RWQCBs. The Central Valley RWQCB has not
promulgated specific treatment performance standards.
Monitoring is required to detect leaks from waste management units and a
corrective action program is required if leaks are detected. A waste management
unit is broadly defined as an area of land where hazardous, designated, or
nonhazardous waste is discharged. Owners and operators of new or existing
landfills and surface impoundments shall monitor groundwater, surface water and
the unsaturated zone as feasible.
This requirement is applicable and generally complements the federal RCRA and
state HWCA monitoring requirements.
A > Applicable
RA = Relevant and Appropriate
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STATE ARARS
Citation
Requirement Description
RA
B. Discharges of Waste to Land, Construction
and Operation Requirements for Waste
Management Units (23 CCR 2510-2601)
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Waste management unit standards include design, construction, operation, and
closure requirements for surface impoundments. Although alternative designs
may be allowed if they are equally protective of water quality, specific
requirements for Class I, or hazardous waste management units include the
following:-
- New and existing waste management unit landfills must be operated to
ensure that wastes will be a minimum of five feet above the highest
anticipated elevation of groundwater.
- Cutoff walls are required where there is a potential for lateral movement of
fluid; the walls must be constructed a minimum of 5 feet into natural
geologic material with a permeability of 10'7 cm/s or less.
- Clay liners shall be at least 2 feet thick, of 90% relative compaction and
maximum permeability of 1 x 10"6 cm/sec.
- New and existing units must be closed with a cover consisting of 2 feet of
foundation material, 1 foot of compacted top soil (permeability equal to the
bottom liner), and the final coyer must be graded to prevent ponding or
erosion.
- Post-closure care Including monitoring, leachate collection, and cover
maintenance must continue for as long as wastes present a threat to water
quality.
These standards are applicable under the assumption that hazardous wastes
would be left in place at the closed unit.
San Joaquin Valley Unified Air Pollution Control
District Rules and Regulations
Rule 220.1 - New and Modified Stationary
Source Review
The San Joaquin Valley Unified Air Pollution Control District has authority to
implement the federal and state air quality management programs In Fresno
through the State Implementation Plan. However, Fresno County Air Pollution
Control District (FAPCD) 'Rules and Regulations' remain in effect in Fresno County
until the corresponding San Joaquin Valley Unified Air Pollution Control District
Rules and Regulations are promulgated in the State Code of Regulations. The
District is completing "Rules and Regulations' and has issued the following that
may serve as ARARs for Purity Oil.
All new stationary sources which emit affected pollutants (pollutants Including
VOCs, NOX, SOX, PM10, lead, and reduced sulfur compounds, are subject to the
following requirements:
A - Applicable
RA - Relevant and Appropriate
A-9
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STATE ARARS
ClUrtlon
Requirement Description
RA
A. (Continued)
- Use of Best Available Control Technology (BACT) for emissions,
- Emission offsets for nonattainment pollutants, and
- Air quality modeling to show that NAAQ8 or CAAQS are not violated or an
existing violation is not made worse.
These requirements apply to proposed remedial activities Including In situ vapor
extraction and air pollution control device emissions.
IV. Fresno County Air Pollution Control District
(FAPCD) Rules and Regulations
A. Rule 401 Visible Emissions
B. Rule 404 - Paniculate Matter
Concentrations
C. Rule 405 - Paniculate Matter Emission
Rates
D. Rule 406 - Sulfur Compounds
E. Rule*408 - Fuel Burning Equipment
Air contaminants shall not be emitted for a period longer than three minutes if they
are darker than Number 1 on the Ringlemann Chart.
Emissions may not contain more than 0.23 grams/m3 of paniculate matter at
standard conditions.
Emission shall not exceed the values given by the following equations.
E » 3.59 P0-88
E = 17.31 P016
P * 30 tons/hour
P > 30 tons/hour
Where: E = emissions in pounds per hour
P = process weight In tons per hour
Sulfur compounds (measured as S02) shall not exceed 0.2 percent by volume of
any discharge to atmosphere.
Equipment that bums fuel for the primary purpose of producing heat must not
exceed the following emission limits:
- Sulfur Compounds: 200 pounds per hour (Calculated as SO2)
- Nitrogen oxides: 140 pounds per hour (Calculated as NO2)
- Combustion Contaminants: 10 pounds per hour.
Theses limit would apply to any air pollution control devices or process that use
combustive processes.
X
X
X
A - Applicable
RA => Relevant and Appropriate
-10
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OTHER REQUIREMENTS
Document
Requirement Description
These guidelines provide the standard for compliance with
previously cited RCRA requirements.
I. RCRA Technical Guidance Document 'Final Covers on
Hazardous Waste Landfills and Surface Impoundments.'
II. RCRA Groundwater Monitoring: Technical Enforcement
Guidance Document.'
These guidelines specify a multilayer cover consisting of the following layers from
top to bottom:
Vegetation/Soil: 60 cm (2 ft.)
Filter (Nominal Thickness)
Drainage: 30 cm (1 ft.)
Low Permeability Flexible Membrane LJner: 20 mil (minimum)
{; Low Permeability Soil: 60 cm (2 ft.)
Optional layers and layer modifications Include the addition of a gravel top surface
for erosion control and the removal of the drainage layer in arid climates, the
addition of biotic barriers to prevent damage by animals, and the addition of a gas
vent layer to control gas emissions.
This comprehensive guidance document provides procedures to be followed for
groundwater monitoring at RCRA TSD facilities.
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