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

-------
                                         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.

-------
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

-------
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.

-------
           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

-------
                        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

-------
              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.

-------
 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
-------
                         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.

-------
              \
•  FRESNO
           CITY
                    mile
RDD63320.RI
                            FIGURE 1

                     SITE LOCATION MAP
                   REMEDIAL INVESTIGATION REPORT
                        PURITY OIL SALES SITE
                         FRESNO, CALIFORNIA

-------
   COMI
COTTON COMPRESSOR
       FIGURE 2

 VICINITY LAND USES

REMEDIAL INVESTIGATION REPORT
   PURITY OIL SALES SITE
    FRESNO. CALIFORNIA
               QUALITY
          POOR
             ORIGINAL



-------
                       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

-------
 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

-------
 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

-------
 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

-------
         
                                                        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

-------
 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

-------
                           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

-------
 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

-------
                                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

-------
                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 
-------
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

-------
 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

-------
 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

-------
                     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

-------
                                                               FEDERAL ARARS
                           CKatlon
                                                                       Requirement Description
                                                                              RA
      I. RCRA Location Standards
        (22 OCR 66264.18)
U
uZ
8
a.

-------
                                                                FEDERAL ARABS
                            Citation
                                                                      Requirement Description
                                                                               RA
           1.  (Continued)
o
Z
O
ui
Q.
W

O
           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

-------
                                                         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

-------
•:'T-- .:•'••.'•••'•%••&''*• '- "'•-•• •-'• ' .. •" - •"•:'• • STATE ARARS • ' •'..•'••'•<•'• 	
'"'•• ' " ' ';.':'"f;':^-citallon'^^^; :" • -''•'•' :: '












LL
O
Ul
Q.
W
j

UJ
x
o














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
o
C
S
a.
(0
z
o
5
o
3
                                             New waste management units shall have a 61-meter (200-
-------
                                                        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
a
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

-------
                                                                 STATE ARARS
                        Citation
                         Requirement Description
RA
        B.  Discharges of Waste to Land, Construction
            and Operation Requirements for Waste
            Management Units (23 CCR 2510-2601)
o
01
a.
(A

O
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

-------
                                                           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

-------
                                                    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.

-------