United States        Office of
          Environmental Protection   Emergency and
          Agency          Remedial Response
EPA/ROD/R09-93/092
June 1993
v°/EPA    Superfund
          Record of Decision:
          San Fernando Valley Area 2
          (Operable Unit 2), CA

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50272-101	

  REPORT DOCUMENTATION
          PAGE
1. REPORT NO.
EPA/ROD/RO9-93/0 92
                                                                     3. Recipient's Accession No.
4.  THIe and Subtitle
   SUPERFUND RECORD  OF DECISION
   San Fernando Valley Area 2  (Operable Unit 2),  CA
   Third Remedial Action
                                                                     5.  Report Date
                                                                              06/18/93
                                                                     6.
7.   Author(s)
                                                                    8.   Performing Organization Rapt. No.
 9.  Performing Organization Name and Address
                                                                    10 Pro|ect Taskwork Unit No.
                                                                     1 1 .  Contraet(C) or Grant(G) No.
                                                                     (0)
12. Sponsoring Organization Name and Address
   U.S.  Environmental  Protection Agency
   401 M Street, S.W.
   Washington, D.C.  20460
                                                                     13.  Type of Rsport & Period Covered

                                                                        800/800
                                                                     14.
 15.  Supplsmsntary Notes
                       PB94-964527
16.  Abstract (LlmH: 200 words)

  The San  Fernando Valley Area 2  (Operable Unit 2)  site is part  of  the Crystal  Springs
  NPL Site,  which is  one of four  San  Fernando Valley Superfund sites in Los Angeles
  County,  California.   Land use in the  area is mixed industrial,  commercial, and
  residential.   The 122,800-acre  Glendale Study Area is located  within the San  Fernando
  Basin, is  adjacent  to the Los Angeles River, and  consists of the  North Plume  and the
  South  Plume,  which  are two main portions of the aquifer in the San Fernando Basin where
  high concentrations  of contaminants have been identified. An estimated 800,000
  residents  use the ground water  of the San Fernando Basin as a  significant source of
  their  drinking water supply.  In 1980,  after finding organic chemical contamination in
  the ground water of  the San Gabriel Valley, the State ordered  all major water purveyors
  in the San Fernando  Valley using ground water to  conduct tests for the presence of
  certain  industrial  chemicals.   Initial and subsequent testing  revealed the presence of
  VOCs in  the San Fernando Valley ground water.  As a result, several municipal supply
  wells  were taken out of service in  Los Angeles, Burbank, and Glendale.  By 1986,  four
  sites  within  the San Fernando Valley  had been added to the NPL; the North Hollywood,
  Crystal  Springs, Verdugo,  and Pollock sites, also referred to  as  San Fernando Valley

  (See Attached Page)
17. Document Analysis     a. Descriptors
   Record of Decision - San Fernando Valley  Area 2  (Operable Unit 2),  CA
   Third Remedial  Action
   Contaminated Medium: gw
   Key  Contaminants:  VOCs (benzene, PCE, TCE),  other organics (PAHs),  inorganics
                       (nitrates)

   b.  Identifiers/Open-Ended Terms
   e.  COSATI Field/Group
                                                     19.  Security Class (This Rsport)
                                                               None  	
                                                     20.  Security Class (This Page)
                                                               None .	
                                                                              21. No. of Pages
                                                                                      64
                                                                              22.  Pries
(SeeANSI-Z39.18)
                                   Seo Instructions on Reverse
                                                                             OPTIONAL FORM 272 (4-77)
                                                                             (Formerly NTIS-35)
                                                                             Department of Commerce

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EPA/ROD/R09-93/092
San Fernando Valley Area 2  (Operable Unit 2), CA
Third Remedial Action

Abstract  (Continued)

Areas 1, 2, 3, and 4, respectively. EPA has preliminarily identified twenty-two facilities
that are located in the vicinity of the Glendale Study Area  (North Plume) and that are
potentially responsible for the ground water contamination.  1987 and 1989 RODs addressed
interim remedies for contaminated ground water at the North Hollywood site and the Burbank
site, respectively.  This ROD addresses an interim remedy for the Glendale North Study
Area, which includes the VOC contamination of the North Plume and adjacent areas where
contamination is known or believed to have migrated, as OU2.  Another 1993 ROD addresses
the Glendale South Study Area, as OU3.  Future RODs will address additional OUs and a
final remedy for the San Fernando Valley Areas 1, 2, 3, and 4.  The primary contaminants
of concern affecting the ground water are VOCs, including benzene, PCE, and TCE; other
organics, including PAHs; and inorganics, including nitrates.

The selected interim remedial action for this site includes installing new extraction
wells to most effectively inhibit the migration of the contaminant plume and maximize the
extraction of the most contaminated ground water; extracting approximately 3,000 gpm of
the contaminated ground water; filtering the extracted ground water to remove suspended
solids, if necessary, followed by onsite treatment to remove VOCs using single-stage or
dual-stage air stripping or liquid phase granular activated carbon (GAC); using
vapor-phase GAC adsorption for emissions control, if air stripping is used; blending the
VOC-treated water offsite with water that does not contain nitrate in excess of the
nitrate MCL to reduce nitrate levels, followed by delivering the water to the Glendale
public drinking water supply system or another municipal system; abandoning or
rehabilitating existing production wells in the area, if required; providing for a
contingency remedy with no blending for nitrate reduction and reinjection into the aquifer
for the treated ground water, if the City of Glendale or another municipality does not
accept any or all of the treated water; and establishing ground water monitoring wells to
evaluate the effectiveness of the interim remedy.  In order to decrease cost, treatment
and delivery of treated water for the Glendale North and Glendale South OUs will be
combined. Ground water monitoring wells also will be established to evaluate the
effectiveness of the interim remedy.  The estimated present worth cost for this interim
remedial action is $36,400,000, which includes an annual O&M cost of $3,240,000 for 12
years.  If the treatment plants for the Glendale North and South Plumes are combined as
planned, the estimated present worth cost for both would be $47,532,000.

PERFORMANCE STANDARDS OR GOALS:

Chemical-specific cleanup goals for the treatment plant effluent from the Glendale North
OU are based on the more stringent of Federal and State MCLs for VOCs, and include benzene
1 ug/1; bis(2-ethylhexyl)phthalate 4 ug/1; carbon tetrachloride 0.5 ug/1; 1,1-DCA 5 ug/1;
1,2-DCA 0.5 ug/1; 1,1-DCE 6 ug/1; 1,2-DCE 6 ug/1; 1,1,2,2-PCE 1 ug/1; PCE 5 ug/1; and TCE
5 ug/1.

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         GLENDALE NORTH OPERABLE UNIT


             RECORD OF DECISION



          PART I:     DECLARATION


          PART II:    DECISION SUMMARY


          PART III:  RESPONSIVENESS SUMMARY
  SAN FERNANDO VALLEY AREA 2 SUPERFUKD SITE

       LOS ANGELES  COUNTY,  CALIFORNIA
United States Environmental Protection Agency
     Region 9  -  San Francisco,  California

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                        TABLE OF CONTENTS
                                                  Page No.
Part I.   Declaration                                  1
Part II.  Decision Summary                             4
     1.0  Site Location and Description                4
    • 2.0  Site History                                 5
     3.0  Enforcement Activities                       8
     4.0  Highlights of Community Participation        9
     5.0  Scope and Role of the Operable Unit          10
     6.0  Summary of Glendale North OU Site
          Characteristics                              11
     7.0  Summary of Site Risks                        13
     8.0  Description of Alternatives                  18
     9.0  Summary of Comparative Analysis
          of Alternatives                              24
     10.0 Applicable or Relevant and Appropriate
          Requirements                                 30
     11.0 The Selected Remedy                          39
     12.0 Statutory Determinations                     43
     13.0 Documentation of Significant Changes         44
Part III. Responsiveness Summary                       45
     Executive Summary                                 45
     Part I - Responses to Comments from the Local
              Community (including the City
              of Glendale)
     Part II - Responses to Legal and Technical
               Comments (including those of the State
               of California)
Appendix A - San Fernando Valley Information Respositories

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                        RECORD OF DECISION

           GLENDALE NORTH OPERABLE UNIT INTERIM REMEDY

                       PART I.  DECLARATION
SITE NAME AND LOCATION

San Fernando Valley Area 2
Glendale North Operable Unit
Los Angeles County, California

STATEMENT OF BASIS AND PURPOSE

     This decision document presents the selected remedial action
for the Glendale North Operable  Unit,  San Fernando Valley Area 2
Superfund site,  chosen in accordance with, CERCLA as amended by SARA
and, to  the extent  practicable,  the National  Contingency Plan.
This decision  is  based  on  the Administrative  Record  for  this
operable unit.

     In  a letter  to EPA  dated  March 29,  1993,  the  State  of
California agreed with the selected remedy for the Glendale North
OU.

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

     EPA has selected an  interim  remedy  for the  North  plume of
groundwater contamination in the Glendale Study Area.  This interim
remedy is referred to as the Glendale North Operable Unit  (OU).  An
OU is a discrete action that comprises an incremental step toward
comprehensively addressing  Superfund site problems. The remedy-and
all of the  alternatives  presented in the  feasibility  study were
developed to meet the  following specific cleanup objectives for the
Glendale North OU:

     o    To  inhibit vertical  and  horizontal   migration  of
          groundwater contamination  in  the North Plume  of the
          Glendale Study Area; and

     o    To begin to remove contaminant mass from the upper zone
          of the aquifer in the North Plume of the Glendale Study
          Area.

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     The  remedy  involves groundwater extraction and treatment for
 the shallow aquifer system in the Glendale area of the San Fernando
 Valley.-^  Under  this remedy,  -contaminated groundwater would be
 extracted at a rate of 3,000 gallons per minute (gpm) for 12 years
 from new  wells to be installed in  the  Glendale Study  Area.   The
 extracted contaminated groundwater will be filtered to remove any
 suspended solids,  if necessary, and then treated by air stripping
 (single  or dual-stage)  and/or liquid  phase  granular activated
 carbon  (GAC) to  remove  volatile organic compounds  (VOCs).   After
 treatment, the water shall meet drinking water standards (maximum
 contaminant levels or MCLs)  for VOCs.  If air stripping treatment
 is selected, air emissions will be treated using vapor phase GAC to
 ensure  that all  air emissions meet  applicable or relevant and
 appropriate requirements.   The exact number,  location and other
 design  specifics  of  these   new  extraction  wells  and  air
 stripping/liquid  phase  GAC  units  will  be determined  during the
 remedial  design  phase of  the project.   After treatment to remove
 VOCs, to  meet  the nitrate MCL, the water  will be  blended with an
 alternative water of  a quality  such  that  the resulting  water
 treated,  blended water will meet all drinking water MCLs.  All or
 part of the extracted treated  water will  then be  conveyed to the
 City of Glendale or another San Fernando Valley water purveyor for
 distribution through its public water supply system.

     As a result  of comments by  the  City  of  Glendale on the
 Glendale  North OU  Proposed Plan (July 1992) and Glendale South OU
 Proposed  Plan  (September  1992)  which indicated that the City had
 sufficient water credits to accept the treated water from both the
 Glendale  North and Glendale South OUs,  and  in order  to decrease
 overall costs associated with the  OUs, EPA has  determined that the
 treatment plants for the Glendale North and Glendale South OUs will
 be combined. The total 5,000 gpm of treated water will  be conveyed
 to the City  of  Glendale for distribution to its public water supply
 system.   The exact configuration  of the combined  treatment plant
will be determined during the remedial design phase  of the project.
 The Glendale South OU Record  of Decision will also reflect this
 decision  to combine the treatment plants.

     However,  if the City of Glendale does not agree to accept the
 treated water from both OUs or  if EPA determines that combining the
treatment   plants  will  significantly  delay  or  hinder  the
 implementation of the Glendale  North OU, the treatment  plants will
not be  combined.   Furthermore, if the  City  of Glendale does not
 accept  any  or all of  the treated  water  (possibly due  to water
 supply  needs),  any  remaining  portion  of the  water  will  be 1)
 offered to  another  San  Fernando  Valley water purveyor  or 2)
 reinjected into the aquifer.

     The  total  duration of the Glendale  North OU  interim remedy
will be 12 years.  EPA will determine the need for and scope of any
 further actions  every five  years  throughout  this  interim remedy
 period and again at the conclusion of this period.

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     The  remedial  action for the Glendale  North  OU represents a
discrete   element   in  the   overall   long-term  remediation  of
groundwater in the eastern portion of the San Fernando Valley.  The
objectives  of this  interim  action; inhibition of  migration and
restoration of groundwater quality to meet drinking water standards
for VOCs to the extent practicable,  would not be inconsistent with
nor preclude  implementation of any  final, overall remedial action
or  actions selected  by  EPA  in  the future for the San Fernando
Valley Areas  l, 2, 3  and  4.

     EPA is the lead agency for this project and the Department of
Toxic Substances Control  of the  state of California Environmental
Protection Agency Department of Toxic  Substances Control  (DTSC) is
the support agency.

DECLARATION

     This  interim  action is  protective of human health and the
environment, complies with Federal and State applicable or relevant
and appropriate requirements  directly associated with this action
and is cost effective.   This action utilizes permanent solutions
and alternative treatment (or resource recovery)  technologies to
the maximum  extent practicable, given  the limited  scope  of the
action.  Because this action  does not constitute the final remedy
for the site,  the  statutory  preference for remedies that employ
treatment that reduces toxicity,  mobility, or volume as a principal
element will be addressed at the time of the final response action.
Subsequent  actions are  planned to fully address  the  principal
threats at these sites.

     Because  this  remedy will  result  in  hazardous  substances
remaining on-site  above  health-based  levels,  EPA shall conduct a
review, pursuant to CERCLA Section  121,  42 U.S.C. Section 9621, at
least once every five years after commencement of remedial action
to ensure that the  remedy continues  to provide adequate protection
of human health and the environment. •
   ^—•f-Q'KA—
  mjz. Wise
              C . co
Johajz. Wise       •             •        Date
Acting Regional Administrator

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         '^          PART II.  DECISION SUMMARY

     This  Decision Summary provides an overview  of the Glendale
North  OU  interim remedy,  including  the  nature  and  extent  of
contamination  to  be addressed,  a description  of  the remedial
alternatives,   the   comparative   analysis    of    the   remedial
alternatives,  a  description  of  the selected  remedy and  the
rationale for remedy selection

1.0  SITE LOCATION AND DESCRIPTION

     The Glendale Study Area is  located within  the San Fernando
Basin.   The following  sections  present a  basin description,
regulatory history, and a summary of the Remedial Investigation and
Feasibility Study (RI/FS) activities within the San Fernando Valley
and the Glendale  Study Area.

1.1  Description  of the  San Fernando Basin

     The San Fernando Basin is located within the Upper Los Angeles
River Area (ULARA), which consists of the entire watershed of the
Los Angeles River and  its  various tributaries.  The San Fernando
Basin covers approximately  122,800 acres and comprises 91.2 percent
of the  ULARA alluvial  fill.   It  is bounded on the  north  and
northwest by the  Santa  Susana Mountains,  on  the  northeast by the
San Gabriel Mountains, on  the west by the Simi Hills,  and on the
south by the Santa Monica Mountains.

     The San Fernando  Basin is a  significant source of drinking
water, with  an  estimated total volume of  3  million acre-feet of
groundwater  stored  in  aquifers within the alluvial fill  of  the
basin.  The groundwater of  the San Fernando Basin has been used as
a source of drinking water for more than 800,000 residents within
the cities of Los Angeles, Burbank,  Glendale, and San Fernando.
Groundwater  extractions  within  the San Fernando  Basin typically
provide 15  percent of Los Angeles'  annual average water  supply and
historically have accounted for between 50 and 100 percent of the
water needs of the other cities.

1.2  Description  and Background of the Glendale Study Area

     The Glendale Study Area is  in the vicinity  of the Crystal
Springs National  Priorities List  (NPL) Site,  one of the four San
Fernando Valley Superfund  NPL sites, and  is  adjacent  to the Los
Angeles River (Figure  1).   The Glendale  Study Area includes two
portions of the aquifer where high concentrations  of contaminants
have been identified: the North Plume and the South Plume (Figure
2).   Although  contamination has been  detected  throughout  the
Glendale Study Area in  an apparently contiguous plume, differences
exist between the North Plume and South Plume,  including the types
of   contaminants   detected   and   the  concentrations   of   the

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         ^AN^FERNANDO VALL EY SUPERFUND SITE
                                                San Gabriel Mountains
                                                 iWVERDUGO
                                                       NPL
                                                  X«i.'-!?«i^. SITE
                                  Verdugo Mountains ^i^v
  NORTH
HOLLYWOOD
 NPL SITE -*
                                                 Glendale
                                                Study Area

                                                   CRYSTAL
                                                   SPRINGS
                                                   NPL SITE
Santa Monica
 Mountains
                                         POLLOCK
                                         NPL SITE
                                           GLENDALE
  GROUNDWATER
  BASIN BOUNDARY

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                                                                  NORTH OU

                       HEADWORKS
                       SPREADING
                       GROUNDS
TCE CONCENTRATION IN GROUNDWATER
POTENTIALLY EXCEEDING 5000 ug/l

TCE CONCENTRATION IN GROUNDWATER
POTENTIALLY RANGING FROM 500 ug/l TO 5000 ug/l

TCE CONCENTRATION IN GROUNDWATER
POTENTIALLY RANGING FROM 100 ug/l TO 500 ug/l
TCE CONCENTRATION IN GROUNDWATER
POTENTIALLY RANGING FROM 50 ug/l TO 100 ug/l
TCE CONCENTRATION IN GROUNDWATER
POTENTIALLY RANGING FROM 5 ug/l (MCL) TO 50 ug/l
       FIGURE 2:    AREAS OF CURRENTLY
                 KNOWN TCE CONTAMINATION
               IN THE GLENDALE STUDY AREA
           QLENDALE STUDV  AREA REMEDIAL INVESTIGATION
  0      2000
  I

SCALE IN FEET

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 contaminants.  The Glendale North and South Plumes are separated by
 an  area of lower-level groundwater contamination.   The Glendale
 North OU includes the North Plume of VOC contamination and adjacent
 areas where contamination is known or  believed to have migrated.

     In 1990, an analysis  was performed to evaluate the need for an
 OU  within  the Crystal Springs NPL site  (CH2M Hill,  1990).  This
 analysis   included   a  qualitative comparison  based  on  known
 groundwater contamination, potential downgradient impacts and water
 supply.  This analysis concluded  that there was a need for an OU
 within   the   Crystal  Springs  NPL   site  because:     1)  high
 concentrations of TCE and PCE were present in groundwater, 2) the
 critical loss of groundwater production in the Glendale area and 3)
 the potential for contaminating groundwater downgradient from the
 Crystal  Springs  NPL site.    Additional  data  collection  was
 recommended  to more  adequately  characterize the horizontal and
 vertical distribution of contamination in the aquifer, and  also to
 improve the definition of the hydrogeology of the area.

     EPA      conducted  a   remedial   investigation   (RI)  that
 characterized  the  nature  and  extent  of  contamination   in  the
 Glendale-Study Area.  Upon completion of the Remedial Investigation
 Report  for the Glendale Study  Area (January 1992), a feasibility
 study (FS)  was undertaken  for the Glendale North OU which evaluated
 a range of cleanup alternatives for  addressing the contaminated
 groundwater.    The FS  report entitled Feasibility Study  for the
 Glendale Study  Area  North  Plume  Operable Unit  was  completed in
 April 1992.

 2.0  SITE HISTORY

     In 1980, after finding  organic chemical contamination in the
 groundwater of the San Gabriel Valley,  the California Department of
 Health Services  (DHS) requested that all major water purveyors in
 the San  Fernando Valley using groundwater  conduct  tests  for the
 presence of  certain industrial chemicals  in  the water  they were
 serving.  The results of  initial  tests and of subsequent testing
 revealed  the  presence  of  volatile   organic  compound  (VOC)
 contamination  in the  groundwater  of  the  San Fernando Valley.
 These findings resulted in  a number of municipal  supply wells for
 the cities of Los Angeles, Burbank, and Glendale being taken out of
 service.   The primary contaminants of concern were  and  are the
 solvents  trichloroethylene  (TCE)  and  perchloroethylene  (PCE),
widely  used  in  a variety of industries  including metal plating,
machinery degreasing  and dry cleaning.

     In  1984,  EPA  proposed four  sites  within the  San Fernando
Valley for inclusion on the NPL and in 1986 the sites were added to
 the list  (Figure 3).   Each  site boundary  encompasses an area in
which   production    wells   produced   groundwater   containing
 concentrations of TCE and  PCE above State and Federal  standards in
 1984.  The four NPL sites  in the San Fernando Valley are the North

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 contaminants.  The Glendale North and South Plumes are separated by
 an area of  lower-level  groundwater contamination.  The  Glendale
 North OU includes the North Plume of VOC contamination and adjacent
 areas where  contamination is known  or believed to have migrated.

      In 1990, an analysis was performed to evaluate the need for an
 OU within the Crystal Springs NPL  site  (CH2M Hill, 1990).  This
 analysis   included  a  qualitative  comparison  based  on  known
 groundwater  contamination, potential downgradient impacts and water
 supply.   This  analysis concluded that there was a need for an  OU
 within  the  Crystal  Springs   NPL  site   because:     1)  high
 concentrations of  TCE and PCE were  present  in  groundwater,  2) the
 critical loss of groundwater production in the Glendale area and 3)
 the potential for  contaminating  groundwater  downgradient  from the
 Crystal  Springs   NPL site.     Additional   data   collection  was
 recommended  to more  adequately  characterize  the  horizontal and
 vertical distribution of contamination in the aquifer,  and also  to
 improve the  definition of the hydrogeology of  the  area.

      EPA     conducted  a   remedial  investigation   (RI)   that
 characterized  the  nature  and   extent  of  contamination  in  the
 Glendale' Study Area.   Upon completion of the Remedial Investigation
 Report  for the Glendale  Study Area (January 1992), a  feasibility
 study (FS) was  undertaken for the Glendale North OU which evaluated
 a  range of cleanup alternatives for addressing the contaminated
 groundwater.   The FS  report entitled Feasibility  Study  for the
 Glendale  Study  Area North Plume Operable Unit was  completed  in
 April 1992.

 2.0   SITE HISTORY

      In 1980, after finding organic chemical contamination in the
 groundwater of the San Gabriel Valley, the California Department  of
 Health Services (DHS) requested  that all major water purveyors  in
 the San Fernando  Valley using groundwater  conduct tests for the
 presence of  certain  industrial chemicals in the  water they were
 serving.  The results of initial tests and of subsequent testing
 revealed  the  presence   of  volatile   organic  compound  (VOC)
 contamination  in  the  groundwater of the  San Fernando  Valley.
 These findings resulted  in a number of municipal supply wells for
 the cities of Los Angeles,  Burbank,  and Glendale being taken  out  of
 service.   The  primary contaminants of concern were  and  are the
 solvents  trichloroethylene  (TCE)  and perchloroethylene  (PCE),
widely used  in a  variety  of industries  including metal plating,
machinery degreasing and dry cleaning.

     In 1984,  EPA proposed four sites  within the  San Fernando
Valley for inclusion on the NPL and  in 1986 the sites were  added  to
the list  (Figure  3).   Each site boundary  encompasses an area  in
which   production    wells   produced   groundwater   containing
concentrations of TCE and PCE above  State and Federal standards  in
 1984.   The four NPL sites in the  San Fernando Valley are the North

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           SAN  FERNANDO
           VALLEY
  NORTH
HOLLYWOOD
 NPL SITE
  SANTA UONI
          MOUNTAIN
             SAN FERNANDO VALLEY STUDY AREA.
               INCLUDING THE FOUR NATIONAL
                PRIORITIES LIST (NPL) SITES
                              CLENDAIE STUDY AREA
                                 FIGURE  3
                             SITE LOCATION MAP

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 Hollywood,  Crystal  Springs,  Verdugo,  and  Pollock  sites,  also
 referred to  as  San  Fernando Valley  Areas  l,  2,  3,   and  4,
 respectively.   EPA is managing the four sites as one large site.
 The San Fernando  Valley Study Area  includes the  four  sites as
 listed on the NPL and adjacent  areas where contamination has or may
 have  migrated.    A basinwide  groundwater  RI report  for  the San
 Fernando Valley  Study  Area  was  completed  in December 1992.
 Groundwater  wells  installed  by  EPA as  part  of  the basinwide
 groundwater RI  are routinely  sampled to  continue to monitor the
 nature  and extent  of the  groundwater  contamination  in  the San
 Fernando Valley.

     EPA has previously  signed Record of Decision (ROD) documents
 for two  OUs in the  San Fernando Valley: the  North Hollywood OU
 (1987) and the Burbank OU  (1989).  The North Hollywood OU  interim
 remedy is currently operating and the Burbank OU is in the remedial
 design phase.  In the Glendale Study Area, EPA has  identified two
 OUs:  the Glendale North Plume  OU and the Glendale South Plume OU.
 In  addition, EPA has recently  initiated an RI/FS for  an OU in the
 Pollock  area  of  the San  Fernando Valley.     All  of these OUs
 represent interim cleanups currently in  progress throughout the
 eastern  portion of the San Fernando Valley.  All remedial  actions
 established by EPA thus  far in the Record of Decision for  each OU
 have been  interim measures.   EPA has  not yet  selected  a final
 remedy for the entire San Fernando Valley.

     TCE and PCE have been detected in the majority  of the  City of
 Glendale's wells  at  levels  that are above the  Federal   Maximum
 Contaminant Level  (MCL), which is 5 parts  per  billion (ppb) for
 each of these VOCs.  The State  of  California MCL is  also 5  ppb for
 both TCE and PCE.   Other VOC contaminants have been  detected above
 State and/or Federal MCLs in the Glendale area.  As a result of the
 groundwater contamination, the majority of the City of Glendale's
wells  have been   taken out   of  service.    The most  prevalent
 contaminants are TCE and PCE.   In  1992, the highest concentrations
of TCE and PCE detected in EPA monitoring wells in the  San Fernando
Valley were  7100  ppb and  160 ppb,  respectively.   Groundwater
samples  from wells  installed at  industrial facilities in  the San
Fernando Valley near potential  sources of contamination have shown
concentrations greater than 30,000 ppb for TCE and over 15,000 ppb
for PCE.   The maximum  of 30,000 ppb for  TCE was  detected  in a
facility well located in the north plume  portion of the Glendale
Study Area.

     Nitrate,   an   inorganic  contaminant,  has  been  detected
consistently at levels in excess  of the MCL  (45 mg/1 as nitrate or
10 mg/1  nitrate as nitrogen)   in the groundwater of the Glendale
Study Area.   The nitrate contamination is likely to be the result
of past  agricultural practices and/or septic systems in the San
Fernando Valley.

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      It* should be noted that the City of Glendale closely monitors
 the quality of  drinking water delivered to residents.  The water
 the City serves  to its residents must meet all Federal and State
 drinking water requirements.   Currently, nearly all of the water
 delivered  by the  City  of  Glendale  is  purchased  from  the
 Metropolitan Water District (MWD)  of Southern California. The City
 uses a limited amount of groundwater from a small percentage of its
 nine production wells in the San Fernando Valley. .If the levels of
 VOCs and  other  contaminants  detected  in  the  groundwater  of
 production wells are equal to or less than 10 times MCLs, the State
 of  California Department of  Health  Services,  Office of Drinking
 Water permits the City  to  extract the water,  blend it with MWD
 water  to  meet  all   drinking water  standards, and convey  the
 extracted, blended water to its public distribution  system.

     As  described  briefly  in Section 1 above, the Glendale Study
 Area includes two portions of the aquifer .where high concentrations
 of contaminants have been identified: the north plume and the south
 plume.  A remedial  investigation (RI) that characterized  the nature
 and  extent  of   contamination in  the  Glendale Study  Area  was
 completed in  (January 1992).  The Glendale Study Area RI included
 a  characterization of  the nature  and extent  of  contamination,
 baseline risk assessments,  and other RI data for both the north and
 south plumes.  However, separate FS reports evaluating a range of
 cleanup alternatives for the contaminated groundwater were prepared
 for  each  plume.   The Glendale North OU  FS  report  and subsequent
 Proposed  Plan  were  finalized  in  April  1992 and July 1992,
 respectively.  The Glendale South OU FS report was completed in
 August 1992 and the Proposed Plan  was completed in September 1992.

     EPA's preferred  alternatives as  described in  the Proposed
 Plans were:   extraction of   3000  gallons  per minute  (gpm)  of
 contaminated  groundwater for Glendale  North  and  2000 gpm  for
 Glendale South, treatment of VOCs  by  air  stripping or liquid phase
 GAC, and conveyance of the treated water to a water purveyor, where
 it would be blended with water of  a quality such that the treated,
 blended  water would meet all drinking water standards, for eventual
 distribution through a public water system.  As a contingency, if
 all or part of the treated water was  not  accepted by  the purveyors
 (possibly  due to  water supply  needs),  the  treated water  from
Glendale North would be reinjected and for Glendale South would be
recharged at the Headworks Spreading Grounds  (see Figure 1-2).

     In   response to  comments by the  City  of Glendale  on  the
Glendale North and South OU Proposed Plans and in order to decrease
overall  costs associated with the  OUs, EPA has determined that the
treatment plants  for the Glendale North and Glendale  South OUs will
be  combined  and  the  total 5,000  gpm of  treated  water will  be
conveyed to the  City  of Glendale for distribution  to its public
water supply  system.    The exact  configuration of  the combined
treatment plant will be determined during the remedial design phase

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 of the--^>roject.   The Glendale South OU  Record of Decision also
 reflects this decision to combine the treatment plants.

      However,  if the  City of Glendale does not agree to accept the
 treated  water from both OUs or if EPA determines that combining the
 treatment  plants  will   significantly  delay   or  hinder  the
 implementation of the Glendale North OU, the treatment plants will
 not  be  combined  and  only  the  extracted treated  water from the
 Glendale North OU will be conveyed to the  City  of Glendale for
 distribution  to its  public water  supply  system.  As a further
 contingency,  if the City of Glendale does not accept any or all of
 the  treated  water (possibly  due  to  water  supply  needs),  any
 remaining portion of water will  be 1)  offered   to  another San
 Fernando Valley water purveyor or 2) reinjected/recharged into the
 aquifer.

 3.0   ENFORCEMENT ACTIVITIES

      In September 1989, EPA signed a cooperative agreement with the
 State Water Resources  Control Board  (SWRCB) providing funds for the
 Regional Water Quality Control Board, Los Angeles Region (RWQCB) to
 expand its capability  to conduct source reduction,  identification,
 and  enforcement activities at  individual facilities  in the San
 Fernando Valley. Activities include conducting surveys and inspec-
 tions, and overseeing  investigations and remedial  activities.  The
 cooperative agreement has been renewed annually  since 1989.   If
 RWQCB investigations  confirm soil or groundwater contamination at
 a specific facility, then  that facility is referred to  EPA. EPA is
 using the RWQCB's facility specific information in  conjunction with
 RI  data,  groundwater  and  vadose  zone  modeling  results  and
 information  gathered   from other   sources  including  California
 Environmental  Protection  Agency (CAL-EPA)  investigations,  South
 Coast Air Quality Management District (SCAQMD)  investigations and
 responses  to  information   request  letters,  to  build  enforcement
 cases.

     EPA  is  and  will be using   its  investigatory  resources,
 enforcement resources and authority under  CERCLA in  conjunction
with the work  of the Los Angeles Region (Region 4)  of the RWQCB to:

     o    Identify individuals  and  companies who  are responsible
          for the historic and current contamination.

     o    Compel  responsible  parties  to  design,  construct  and
          operate treatment facilities and reimburse EPA for prior
          and any future expenditures at the site.

       EPA  issued  preliminary  notices  of potential   liability
 (General Notice) for the Glendale North  OU to 35 parties on August
 27, 1992  and  to two additional parties on  August 31,  1992.   The
 list of  General Notice parties  was  updated in February  1993 when
 one owner was deleted and three others added.   These parties have

                                8

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 been  preliminarily  identified  as  owners  and  operators  of 22
 facilities located in the vicinity of the north plume portion of
 groundwater contamination in the  Glendale  Study  Area of the San
 Fernando Valley.   EPA anticipates  that additional parties will be
 notified of potential liability. Special notice pursuant to  CERCLA
 §122 has not yet  been issued for the Glendale  North  OU.

 4.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

      EPA's preferred alternative, as well as six other alternatives
.were described in EPA's Proposed  Plan for  the Glendale North OU
 (July 1992).  The Proposed Plan was in the form of a fact sheet and
 was distributed to 'all parties on EPA's mailing list for the San
 Fernando Valley  Superfund sites.    The  original 30  day  public
 comment  period was   extended an  additional  30  days  after EPA
 received requests for extensions from members  of the public.  The
 public comment period closed on September 8, 1992.   EPA received
 over 150 comments.  These comments and EPA's responses to these
 comments are summarized in Part III  (the Responsiveness Summary) of
 this ROD.

      A public meeting was held in the City of Glendale on July 23,
 1992,  to  discuss  EPA's  preferred  alternative   and the  other
 alternatives.   At this meeting EPA  gave  a  brief  presentation
 regarding  the  Proposed Plan,  answered questions,  and accepted
 comments from members  of the  public.

      At  the public meeting and in a subsequent  letter,  the City of
 Glendale emphasized  that  it  would like to  receive greater than
 3,000 gpm  of extracted,  treated  groundwater.    The  City also
 indicated  that it had stored  water credits  and  water   rights
 sufficient  to accept greater  than  5,000 gpm of extracted, treated
 groundwater  from  the  San  Fernando Valley.    As a  result  of the
 City's oral and written comments on the Glendale North OU, EPA has
 determined  that the  treatment plants  for the  Glendale North and
 South OUs will be  combined  and the total 5,000 gpm  of treated water
 will  be  conveyed  to the City  of  Glendale.

      Notice of the public  meeting  as well as the availability of
 the  Proposed Plan was published in the Los  Angeles Daily News on
 July 8, 1992.   In  addition, several newspaper articles were written
 about  the remedial investigation,   the feasibility study and the
 Proposed Plan for the  Glendale North OU including: Los Angeles
 Times - June 19, 1992; Los Angeles  Daily News - June 19,  1992; Los
 Angeles  Times  - July  23,  1992;  Los Angeles  Daily News - July 24,
 1992  and the  Glendale News Press -  July 24, 1992.   A map  of the
 Glendale North OU  was  provided in the Proposed Plan and the various
 newspaper articles described the area that would be impacted  by the
 Glendale North OU.

      Prior  to  mailing  out   the Proposed  Plan  fact  sheet and
 conducting  the public meeting  for the Glendale North OU, EPA

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 conducted  an outreach program specifically aimed at the Glendale
 community.   EPA  placed inserts describing  the proposed interim
 cleanup  of  groundwater in  the Glendale  area in  utility bills
 delivered  to over 127,000  community members.  The insert not only
 explained  the  project but offered an  opportunity to be added to
 EPA's mailing  list for  the San  Fernando Valley  project by filling
 out and returning an attached coupon.   As  a result of this utility
 bill insert  project,  EPA was able to double its mailing list for
 the San  Fernando  Valley project and to educate community members
 likely to  be impacted by the Glendale North OU  project.

     In general,  the purpose of EPA's community relations program
 for the San Fernando Valley project is  to  inform community members
 and  other  interested  parties  about  the  Federal process  for
 addressing contamination at  hazardous  waste  sites,  as well as to
 encourage  two  way communication between  the  concerned public and
 EPA and/or other  local  agencies.

     From March 1987 through December 1991, EPA and  LADWP attended
 quarterly  meetings of the Community Work  Group (CWG)  to discuss
 technical  issues  and  management  strategies  involving the  San
 Fernando Valley Superfund project including the interim groundwater
 cleanup for the Glendale area.  The CWG  consisted of  interested San
 Fernando Valley  community  residents,  elected  officials,  agency
 representatives,  and environmental and business leaders.  The CWG
 provided input  to EPA  on the various components of  the Superfund
 project, including the interim groundwater cleanup of the Glendale
 area.

     The community relations  plan for the  San Fernando  Valley
 Superfund sites was most recently updated and  issued  in April 1990.
 The plan will  be  revised again  in  1993  to  address  community
 relations during the remedial design phase of  the Glendale North OU
 interim  action and other changes  in the   community  relations
 program.

 5.0  SCOPE AND ROLE OF THE OPERABLE UNIT

     The  interim  remedial  action for   the  Glendale  North  OU
 represents a discrete element in the overall long-term remediation
 of groundwater in  the eastern portion of the San Fernando Valley.
While the  final  overall  plan  for the  remediation of the  San
 Fernando Valley Sites has not yet been determined,  the objectives
 of the Glendale North OU are:

     o    To   inhibit   vertical  and  horizontal   migration  of
          groundwater  contamination in  the   North  Plume  of  the
          Glendale Study Area

     o    To begin to remove contaminant mass from the upper zone
          of the  aquifer in the North Plume of the Glendale Study
          Area.

                                10

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      EPA does not expect these objectives to be inconsistent with,
 nor preclude, any final action for San Fernando Valley Areas 1, 2,
 3, and 4.

      The Glendale North OU interim remedy  is  intended to address
 the immediate and significant groundwater contamination problem in
 and beyond a portion of San Fernando Valley Area 2 (also known as
 the Crystal Springs NPL site)  and includes  a large section of the
 City of Glendale.   A more complete investigation of  the overall
 groundwater problem in the San Fernando Valley is being conducted
 through the basinwide remedial investigation and feasibility study
 process.

      The basinwide  groundwater RI  Report  for  the San  Fernando
 Valley Study  Area was completed in  December 1992.   Groundwater
. wells installed by EPA as part of the basinwide  RI  are routinely
 sampled to  continue  to monitor  the nature  and extent of  the
 groundwater contamination in the San Fernando Valley.

      EPA  is  currently   using   the  results  of   the  remedial
 investigation in  basinwide feasibility  studies  to address  VOC
 contamination in  both  the  groundwater and  vadose  zone of  the
 eastern portion of the San Fernando  Valley.

      As part of the basinwide  groundwater FS,  EPA is revising and
 recalibrating the basinwide groundwater  flow model to incorporate
 the most recent data.   The  updated  version of the model will be
 complete  in  early  1993.  EPA will then review and evaluate various
 groundwater  remediation options  for  the  basin including:  regional
 pump and treat, well-head treatment, use of innovative technologies
 and no-action alternatives.

      During  1993,  EPA will also  initiate work on  a vadose zone FS
 to examine ways  to protect the groundwater  from contaminants that
 could reach the groundwater in the future.   This FS will review and
 evaluate  options for cleanup of  VOC contamination in  the vadose
 zone of the  San  Fernando Valley.

      EPA will  continue to gather and analyze information important
 to the  project.  EPA has been working with the San Fernando Valley
 water purveyors  and the  Upper Los  Angeles  River  Area  (ULARA)
 Watermaster to summarize past and future groundwater management in
 the San Fernando Valley, including an overall water balance for the
 San Fernando Valley.  EPA's interim actions  to remove contaminants
 and inhibit  migration from the most contaminated areas  in  North
 Hollywood, Burbank, Glendale North, Glendale South and Pollock OUs
 will  also provide  information useful  for the  basinwide FS.

 6.0  SUMMARY  OF  GLENDALE NORTH OU SITE CHARACTERISTICS

      Results  of  LADWP's  groundwater monitoring programs conducted
 from  1981 through  1987  revealed that  TCE and  PCE  had contaminated

                                11

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 approximately  50 percent of the water supply wells in the eastern
 portion""" of  the  San  Fernando  Valley   groundwater   basin  at
 concentrations  exceeding   State  and  Federal   drinking  water
 standards.

     The results of recent (1989-1992) EPA  sampling of groundwater
 monitoring  wells installed  by EPA  throughout  the  San Fernando
 Valley indicate that TCE and PCE continue to be the principal con-
 taminants of concern. TCE and PCE are industrial solvents commonly
 used in the metal degreasing and dry-cleaning industries. Both are
 known  animal  carcinogens  and probable human  carcinogens.   The
 Federal MCL for both TCE and PCE is 5 ug/1 (ppb).  The State MCLs
 for TCE and PCE are also 5 ug/1  (ppb).

     There are ten EPA monitoring wells located in the north plume
 portion of the Glendale Study Area.   In these ten wells, nine VOCs
 have been detected  above  Federal and/or  State  MCLs:   benzene;
 carbon tetrachloride; 1,1-dichloroethane (1,1-DCA); 1,2-DCA; 1,1-
 dichloroethene (1,1-DCE); total 1,2-DCE; 1,1,2,2-tetrachloroethane;
 PCE; and  TCE  (See Tables  6-1 and 6-2).   As reported  in  the RI
 Report for the Glendale Study Area,  TCE was  detected in eight of
 ten  EPA  monitoring  wells  in  the  north plume  at  a  maximum
 concentration of 12,000 ppb.   PCE was detected in seven of the ten
wells at  a maximum of  120  ppb.   Groundwater samples  from wells
 installed  at  industry  facilities in  the  Glendale north  plume
portion  of  the  Glendale  Study Area, near potential  sources of
contamination, have shown concentrations greater  than 30,000 ppb
 for TCE and greater than 500 ppb for PCE  (See Figures 6-1 and 6-2).

     Nitrate has been detected consistently at levels in excess of
the MCL in the  groundwater of the Glendale Study Area.  The highest
 level detected in groundwater from a shallow monitoring well in the
Glendale Study Area is 16 mg/1 as nitrogen (See Figure 6-3).  The
Federal MCL  is  10  mg/1 for  nitrate as nitrogen.   The  nitrate
contamination  is likely the result of past agricultural practices
and/or septic  systems in the San Fernando Valley.  Nitrate is not
a CERCLA hazardous substance.   However, the interim OU remedies in
the San Fernando Valley involve the distribution of treated water
to  public  water supply  systems  and therefore,   EPA has  been
compelled  to  address  the  nitrate  contamination  in  developing
remedial alternatives.

     Some metals have  been detected  at levels above the Federal
and/or State MCLs in groundwater monitoring  wells located in the
Glendale  Study Area.   These  metals include: arsenic,  cadmium,
chromium,  lead and mercury.   MCL exceedances occurred in early
 (1989)  sampling  rounds when  field filtering of samples  was not
performed.   Subsequent  sampling and  current sampling protocol
require field  filtering.  As  a result,  only chromium and mercury
have been found to exceed their MCLs since the initial sampling and
only in  a small number of wells.  An analysis of  these  data to
examine the likelihood that the metals are waterborne contaminants

                                12

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                                                            TABLE   6-1
                    MAXIMUM VALUES OF VOLATILE AND SEMIVOLATILE ORGANIC COMPOUNDS DETECTED IN
                                 GROUNDWATER FROM THE CRYSTAL SPRINGS CLUSTER WELLS
                                                WITHIN THE NORTH PLUME OU
Constituent
Volatile Organics (/ig/l)
Acetone
Benzene
2-Butanone (MEK)
Carbon Tetrachloride
Chlorofonn
1 , 1 -Dichloroethane
1 ,2-Dichloroethane
1 , 1 -Dichloroethene
1 ,2-Dichloroethene (total)
Ethylbenzene
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
TetrachJoroethene (PCE)
Toluene
1,1,1 -Trichloroethane (TCA)
Trichloroethene (TCE)
Xylene (total)
Semivolatile Organics (j»g/l)
Bis(2-ethylhexyl)phthalate
Di-n-octylphthalate
MCL'
(Mg/0

— c
1.0
»-»c
0.5
100"
5.0
0.5
6.0
6.0r
680
-..*
1.0
5.0
1,000
200
5.0
1,750

4
_^_e

Shallow Cluster
Number of
Maximum Wells With
Concentration Detects
(Mg/l) out of 9

6'
0.8
22
42
23
39
2
100
17
ND
0.5"
8.0
120
0.4"
26
3,100
ND

ND
ND

4
1
1 •
4
4
3
1
3
3
0
2
2
8
1
3
9
0

_.
—
Wells"
Number of
Wells Which
Exceed MCL

—
0
—
4
0
2
1
2
1
0
0
2
6
0
0
8
0

...
—
t
Maximum
Concentration
(Mg/D

22
ND
ND
1.0
2.0
ND
ND
ND
ND
0.2
5.0*
2.0
130
3"
ND
220
1

140
11'
Lower Cluster
i
Wells"
Number of
Wells With Number of
Detects Wells Which
out of 12 Exceed MCL

5
0
...
2
1
0
0
0
...
1
7
1
9
3
0
8
2

1
1

...
0
...
2
0
0
0
0
...
0
0
1
6
0
0
6
0

...
—
Note:  Samples collected May 1990 and October 1990
ND = Not Detected
'    Promulgated federal or state MCL, whichever is more stringent.
b    Shallow cluster wells include CS-COl-105, CS-CO2-62, CS-CO2-180, CS-CO3-100, CS-VPB-04, CS-VPB-05, CS-VPB-06, CS-CO5-160 and CS-C06-I85.
    Lower cluster wells include all remaining cluster wells.
'    No state or federal MCL promulgated.                                                                      ,,                          ,
'    MCLisforthesumoftrihalomethanes.                                                      Source:   Remedial Investigation for  the
'    Detected in laboratory blanks; may be considered a lab contaminant.                                          Glendale Study Area  (January 1992)
'    For sum of cis- and trans-isomers, use the MCL for cis-; this isomer is more prevalent and its MCL is lower.

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                                                                TABLE   6-2

                          MAXIMUM VALUES OF VOLATILE AND SEMIVOLATILE ORGANIC COMPOUNDS DETECTED IN
                                 GROUNDWATER  FROM THE CRYSTAL SPRINGS VERTICAL PROFILE BORINGS
                                                       WITHIN THE NORTH PLUME OU
                                                   Initial Sampling - September 1989b
                                        Resampling - September 1990''

Maximum
MCL* Concentration
Constituent G»g") ' G«g/0
Number of
VPBs With
Detects
out of 10
Number of
VPBs which are
at or Exceed
MCL

Maximum
Concentration
G'g/0
Number of
VPBs With
Detects
out of 1 1
Number of
VPBs Which
are at or Exceed
MCL
Volatile Organics 0 Not Detected
  •   Promulgated federal or state MCL, whichever is more stringent.
  k   Initially sampled wells include CS-VPB-01, CS-VPB-02, and CS-VPB-04 through CS-VPB-11; Rcsampled wells include CS-VPB-01 through CS-VPB-11.
  •   No state or federal MCL promulgated.
  '   MCL is for the sum of trihalomethanes.
  •   Delected in laboratory blanks; considered a lab contaminant.
  '   For sum of cis- and trans-isomers, use the MCL for cis-; this isomer is more prevalent and its MCL is lower.

           Source:   Remedial  Investigation  for  the  Glendale  Study Area  (January  1992)

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                                                                                                    .V' »• .'V
                                                                                                   x . sS Vy
                                                                                                     V" <  .' j-
                                                                                                      * s ^  • *
                                                                                       NORTH PLUME OU
                            MONITORING WELL
                            CLUSTER WELL
                            VPB  WELL
PHILIPS
COMPONENTS
     SITE
TCE CONCENTRATION IN  GROUNDWATER POTENTIALLY-0
EXCEEDING 5000 ug/l
TCC CONCENTRATION IN  GROUNDWATER POTENTIALLY
RANGING  FROM  500  ug/l TO 5000 ug/l
TCE CONCENTRATION IN  GROUNOWATER POTENTIALLY
RANGING  FROM  100  ug/l TO 500 ug/l

TCE CONCENTRATION IN  GROUNDWATER POTENTIALLY
RANGING  FROM  50 ug/l TO 100 ug/l
TCE CONCENTRATION IN  GROUNDWATCR POTENTIALLY
RANGING  FROM  5 ug/l (MCL) TO  50 n»|/l
                          FIGURE  6-1
          ESTIMATED EXTENT OF  TCE CONTAMINATION
          IN THE UPPER ZONE AT THE WATER  TABLE
                       SEPT.-OCT. 1990
NORTH PLUME OPERABLE UNIT
     FEASIBILITY  STUDY

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                                                                                   NORTH PLUME OU
V/V/
                                                                                              A.C. LAYNE  SITE
                                                                                              	PMC-MW-04
                                                                                                 COLORADO BLVD


                                                                                                   -VPB-02
                                             PHILIPS
                                             COMPONENTS
                                                  SITE
CLUSTER WELL
VPB WELl
                          PCE CONCENTRATION IN GROUNDWATER POTENTIALLY
                          RANGING FROM 100 ug/l TO 500 ug/l
                          PCE CONCENTRATION IN GROUNDWATER POTENTIALLY
                          RANGING FROM SO ug/l TO  100 ug/l
                          PCE CONCENTRATION IN GROUNDWATER POTENTIALLY
                          RANGING FROM 5 ug/l (MCL) TO  50 ug/l
                                                   FIGURE 6-2
                                   ESTIMATED EXTENT OF PCE CONTAMINATION
                                    IN THE UPPER ZONE AT THE WATER TABLE
                                                 SEPT.-OCT.  1990
                                                                     PO-VPB-OI
                                                                          A
NORTH PLUME OPERABLE UNIT
    FEASIBILITY STUDY

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                                                                                 NORTH  PLUME OU
                                                                                      CLENOAKS BLVO
                                                                                                 •
                                                                                            A
                                                                                           -VPB-tl
                                                                      PHILIPS
                                                                      COMPONENTS
                                               NITRATE CONCENTRATIONS
                                               GREATER  THAN 10 mg/l-N
   tono  o  1000 2000

         rtti
                 FIGURE  6-3                     £
ESTIMATED EXTENT OF NITRATE CONTAMINATION   <
               IN UPPER  ZONE                   \
               SEPT.-OCT. 1990
NORW PLUME OPERABLE UNIT
    FEASIBILITY STUDY

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 rather than sampling artifacts (i.e.,  residual particulates from
 well   construction  and  development)   was  conducted  by  EPA's
 contractor  and  presented  in  a  technical memorandum entitled:
 Review of Metals Data from Monitoring Wells located in the Glendale
 Study  Area. North Operable Unit (June 16,  1992) .  This memorandum,
 available for review in the Administrative Record for the Glendale
 North  OU, concluded that the metals exceedances were most likely
 the  result  of  sampling  artifacts.   EPA  continues  to  analyze
 groundwater samples  collected  under   the quarterly  monitoring
 program for priority pollutant metals.

     Thirty-one  wells in the Glendale Study Area were sampled for
 naturally-occurring radionuclides  as   part of  EPA's  quarterly
 monitoring  program.   The samples were  taken during the period of
 July 31 to August 7, 1992.  The results  of this third quarter 1992
 groundwater sampling  for radionuclides.  indicate  that all  EPA
 groundwater monitoring  wells in  the Glendale  Study Area  are in
 compliance with current MCLs for  radionuclides  (gross alpha, gross
 beta,  gross radium, radium-226, strontium-89, strontium-90, gross
 uranium, tritium, and radon).  In addition, the samples were also
 in compliance  with  all  proposed  radionuclide MCLs, except radon.
 The proposed MCL for Radon is 300 pCi/1.  Most of the groundwater
 samples from the 31 monitoring  wells exceeded the proposed MCL for
 radon.  If  necessary, this  factor will  be taken into account for
 remedial design.  Radionuclides in the groundwater  of the Glendale
 Study  Area  and  their  potential  impacts  on the  design  of  the
 Glendale North OU are discussed  in  greater detail in:   Technical
 Memorandum San Fernando  Valley Superfund Site, Radionuclides in the
 Glendale Study Area, dated  March 2, 1993.   This  memorandum is
 available for  review  in EPA's  Administrative Record Supplement 1
 for the Glendale North OU.

     In addition, during  the RI  for the Glendale Study Area,  EPA
 confirmed through modeling that  the groundwater  in the area is a
 source of recharge for the Los Angeles River.

 7.0  SUMMARY OF SITE RISKS

     Data regarding contaminants  in  the  north plume of groundwater
contamination in the Glendale Study Area obtained by EPA during the
remedial investigation was  used to  estimate  the  health risks
associated with exposure to the groundwater. This estimate, called
a risk assessment,  was then used to identify  which contaminants
pose risks to human health.  The data used for the Glendale North
OU risk  assessment  is  presented in  the  Remedial  Investigation
Report for  the Glendale Study Area (January 1992)  and in other
documents include in  the  Glendale North OU Administrative Record
file.

     Baseline risk assessments  are conducted at Superfund sites to
fulfill one of the requirements of the National Oil  and Hazardous
Substances Pollution Contingency  Plan (NCP). The NCP (40 CFR Part

                               13

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 300)  requires development of a baseline risk assessment at sites
 listed  on the National Priorities List  (NPL)  under CERCLA.   The
 CERCLA process for baseline risk assessments is intended to address
 both  human health and the environment.  However,  due to the highly
 urbanized setting of the  Glendale  Study Area,  the focus  of the
 baseline  risk assessment  for the Glendale North  OU  was focused on
 human health  issues, rather than environmental issues.

      The  objective of the baseline risk assessment for the Glendale
 North OU  was  to  evaluate  the human health and environmental risks
 posed by the contaminated groundwater  beneath the  north plume
 portion  of  the  Glendale  Study Area if  it  were to be used  as a
 source  of drinking water  without  treatment.   The  baseline risk
 assessment  incorporated the water  quality  information generated
 during  the  basinwide  groundwater  RI   field  investigation  and
 sampling  program to  estimate current and future human health and
 environmental  risks.  The groundwater data  used for the Glendale
 North OU  risk assessment included  sampling  results from the 1990
 Crystal  Springs  initial  cluster  well  sampling,  and the  1991
 resampling of the Crystal Springs Vertical Profile Borings/shallow
 monitoring wells (VPBs).  In cases where more than one  sample event
 was recorded for a single well, the most recent data were used.  If
 a compound was not detected in a particular well,  half the value of
 the lowest detection limit was used from the most recent sampling
 event.  The current public health risk calculations were based on
 estimates  of   concentrations  at points of  exposure  from  these
 sampling  efforts.

      The risk assessment for the Glendale North OU was  conducted in
 accordance with  EPA  guidance  including:   Guidance for Conducting
 Remedial Investigation and Feasibility Studies under CERCLA (USEPA,
 1988),  Risk  Assessment  Guidance  for Superfund.  Vol. I  Health
 Evaluation Manual (Part A)  and Vol.  2JEcological Assessment (USEPA,
 1989),  The  Exposure  Factors  Handbook   (USEPA,  1989), and  Risk
Assessment Guidance  for Superfund Human Health Risk  Assessment.
USEPA Region IX Recommendations (USEPA, 1989).

     A risk assessment  involves the  qualitative or quantitative
characterization of potential health effects of specific chemicals
on  individuals  or populations.    The  risk assessment  process
comprises four basic steps:   1) hazard identification,  2) dose-
response  assessment,   3)   exposure  assessment,   and  4)   risk
characterization.  The purpose of each element is as follows:

      •    Hazard identification characterizes the potential threat
          to human health and the environment posed by the detected
          constituents.

      •    Dose   response  assessment  critically   examines  the
          toxicological  data  used  to determine  the relationship
          between the experimentally administered animal dose and


                                14

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           the  predicted response  (e.g.,  cancer incidence)  in a
           receptor.

      •     Exposure assessment estimates the magnitude, frequency,
           and duration  of human exposures to chemicals.

      •     Risk  characterization estimates  the  incidence of  or
           potential for an adverse health or environmental effect
           under the conditions of exposure defined in the exposure
           assessment.

Human Health Risk Assessment

     Risk assessments estimate the possibility that one additional
occurrence of cancer  will  result from exposure to contamination.
A risk of 1 in 1,000,000 (one million) means  that one person in one
million exposed could develop cancer as a result of the exposure.
EPA  considers  risks  greater  than  one   in  ten  thousand  (10~4)
"unacceptable."

     In  preparing  risk assessments,  EPA uses  very  conservative
assumptions that weigh  in favor of protecting public health.  For
example, EPA  may assume that  individuals consume two  liters  of
drinking water  per  day from wells situated within  a contaminant
plume, over a 70-year lifetime or  that a person is  exposed to a
chemical,  24 hours a  day,  365  days a year,  for a 30-year period,
even though typical exposure to the chemical would be far less.

     The baseline  risk assessment for the  Glendale North  OU  is
presented in Section 7.0 of the Remedial  Investigation Report for
the  Glendale  Study Area   (January  1992)i   The risk  assessment
estimated  the  potential  risks  to  public  health under  current
situations and potential future  situations.  The risk assessment
examined the potential health effects if  individuals were exposed
to contaminated groundwater from the upper and lower zones of the
aquifer for the Glendale north plume groundwater contamination in
the Glendale Study Area.

     Chemicals of potential concern for the Glendale North OU used
in the  risk assessment calculations included:  TCE;  PCE;  carbon
tetrachloride; 1,1-DCA; 1,2-DCA; total 1,1-DCE; 1,2-DCE; nitrate
and  others including  some metals.    A list  of all  potential
compounds  of concern  for  both the upper  and lower  aquifer zones
included in the quantitative risk assessment for the Glendale North
OU are presented in Table  7-1.   Due  to the  potential for adverse
health effects  to infants  from consumption of water  with high
nitrate  levels,  a quantitative  evaluation  of   this  compound for
chronic non-carcinogenic risks was calculated.   The maximum value
and an average value were used for exposure point concentrations in
the calculations.
                                15

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                           TABLE 7-1

  COMPOUNDS OF POTENTIAL CONCERN INCLUDED IN THE QUANTITATIVE
        RISK ASSESSMENT FOR THE GLENDALE NORTH  PLUME OU
  Constituent
 Upper
  Zone
(Yes/No)
 Lower
  Zone
(Yes/No)
VOCS

Benzene
Carbon Tetrachloride
1,l-Dichloroethane
1,2-Dichloroethane
Tetrachloroethene
Trichloroethene
1,1-Dichloroethene
1,1,2,2-Tetrachloroethene
2-Butanone  (MEK)
1,2-Dichloroethene  (total)

BNAs

Bis(2-ethylhexyl)phthalate

Inorganics

Arsenic
Nickel
Lead
Mercury
Zinc
Nitrate
   y
   Y
   Y
   Y
   Y
   Y
   Y
   Y
   Y
   Y
   N
   Y
   Y
   N
   Y
   Y
   Y
   N
   Y
   N
   N
   Y
   Y
   N
   Y
   N
   N
   N
   N
   Y
   Y
   Y
   Y

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      As indicated  by the  table,  fewer  compounds  of potential
 concern were identified in samples from wells installed in the deep
 aquifer.    Therefore, a  separate  characterization  of risk  was
 performed  for  the upper and lower groundwater zones.

      An exposure assessment was  conducted  to  identify potential
 transport pathways  (e.g.,  groundwater, surface water, air); routes
 of  exposures   (e.g.,  ingestion, inhalation,  dermal contact);  and
 potential  on-site  and  off-site  receptor populations.   Exposure
 assessment  involves  the  consideration  of  particular transport
 pathways and routes of exposure  to  potential receptors which may
 include current users of the site as well as adjacent populations
 that  may be exposed to chemicals that have been transported off
 site.   Receptors may  also include aquatic and terrestrial biota.

     A  critical  step in  assessing  the  potential  risk to public
 health  is  to  identify the pathways through which exposure could
 occur.   The major  transport  pathway considered  in  the Glendale
 North  OU  baseline  risk  assessment  was  the use  of  contaminated
 groundwater.  The point of potential contact with the contaminated
 groundwater is through water use from the upper or lower zone.

     EPA evaluated four potential methods of exposure  to water from
 the upper  and lower  zones of the  aquifer: (1)  exposure during
 residential use,  (2)  worker  exposure during  operations  at  the
 Glendale Grayson Steam Plant (3)  exposure from discharge into the
 Los Angeles River,  or  (4)  exposure in various  other commercial
 uses.   Other commercial users  of groundwater in the Glendale Study
Area include Walt Disney; Sears, Roebuck & Co.; and the Los Angeles
 City Zoo.   The residential use of the contaminated groundwater as
well as exposure from Glendale  Grayson Steam Plant operations were
 carried into the quantitative risk assessment.

     EPA included three potential exposure routes in the Glendale
North  OU  risk assessment:  (1) drinking  the groundwater  during
residential use,  (2)  inhaling the chemicals in groundwater vapors
during showering, and (3)  inhaling groundwater vapors during steam
plant operations. Dermal contact was also considered  but was found
by EPA not to pose a  significant risk.

     In accordance  with  current scientific opinion  concerning
carcinogens, it is assumed that any  dose,  no matter how small, has
some associated response.   This is called  a  nonthreshold effect.
In the risk assessment for the Glendale North OU, the non-threshold
effect was  applied to  all probable carcinogens.  EPA has classified
carcinogens with regard to the epidemiologic and toxicologic data
available.   The assessment of noncarcinogenic effects is complex.
There is a  broad interaction of time  scales (acute, subchronic, and
chronic) with  varying kinds of effects.   In addition, there are
various levels of "severity" of effect.   The Hazard Index is used
to determine the potential for adverse health  effects resulting
from exposure to non-carcinogenic chemicals.

                               16

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      The Hazard  Quotient is  defined as  the  ratio  of a  single
 exposure level over a specified time period to a reference dose for
 that substance derived from a similar exposure period.  A reference
 dose (RfD)  is EPA's preferred toxicity value for evaluating  non-
 carcinogenic effects  resulting from exposures at Superfund sites.
 The Hazard  Index is the sum of more  than  one Hazard  Quotient for
 multiple substances or  multiple  pathways.  The Hazard Index is
 calculated separately for chronic, sub-chronic and shorter-duration
 exposures.  A Hazard Index greater than 1.0 indicates the potential
 for adverse health effects.   However,  it  should be noted  that a
 Hazard  Index value of 1.0 or greater does not mean that an  adverse
 health  effect is certain.   It is  a benchmark value  indicating a
 greater probability for  a possible  adverse effect.

      The results of  the baseline  risk  characterization for  the
 upper and lower  zones of the aquifer are summarized  in Tables 7-2
 and 7-3.  A  detailed  discussion  of  the data  presented in these
 tables  is  included in Section 7.0  of the Remedial  Investigation
 Report  for the Glendale  Study  Area  (January  1992).

      The risk associated with  ingestion of  groundwater from  the
 upper zone  found that TCE,  l,l-DCE and arsenic were the primary
 contributors  to  the  carcinogenic  risk in the ingestion  scenario.
 PCE  and  carbon  tetrachloride   were   secondary  contributors.
 Concentration  levels  of  TCE and  Ijl-DCE  were  several orders of
 magnitude  above  their   respective  MCLs,  but  concentrations of
 arsenic were detected below its MCL.  For shower inhalation  risks,
 TCE and l,i-DCE were major contributors  to  risk  for groundwater in
 the upper and lower zones.

     The uncertainties associated with the Glendale North OU risk
 assessment are discussed in  detail  in Section 7.6 (page 7-24) of
 the  Remedial Investigation  Report  for  the  Glendale  Study Area
 (January 1992).

     In  summary,  the  results of the  human health  portion  of the
 Glendale North OU risk assessment indicated that  contaminant levels
 in the upper zone of the  aquifer of the Glendale Study Area would
 pose an unacceptable (2 x 10"3) risk to  human health  if this water
were  to  be  delivered directly to  local residents,  without being
 treated.  This means that an estimated  1 in  500 persons would be
more likely to develop cancer  during  their lifetimes.

 Environmental Risk Assessment

     An  ecological  risk  assessment  was also  performed for   the
Glendale North  OU to address the potential ecological risks to
 flora  and  fauna  in  the  area.     This   assessment  provided a
 qualitative  evaluation  of  potential current  and  future risks
 represented by the present site conditions,  assuming no remedial
 action is taken in the Glendale Study Area.


                                17

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                           TABLE 7-3

            SUMMARY OF RISK CHARACTERIZATION FOR THE
                       LOWER ZONE AQUIFER
                FOR THE GLEMDALE NORTH FLUKE OU
Exposure
Scenario
Adult
Ingestion
Shower -
Inhalation
Steam Plant
Inhalation
Arithmetic
Mean1
2E-05
3E-01
IE-OS
2E-01
— — —
RKE2 Maximum3
5E-05 1E-04
7E-01 2E+00
2E-05 6E-^05
4E-01 1E+00
	 1E-07
	 2E-03
Type of
Risk
Cancer Risk
Hazard Index
Cancer Risk
Hazard Index
Cancer Risk
Hazard Index
     1 Average Value

     2 Reasonable Maximum Exposure.  The highest  exposure that
is reasonably expected to occur at a site (95% upper confidence
limit of observed concentrations).

     3  The  exposure  scenario  using  the   highest  observed
concentration  in any  monitoring well  in  the  north plume  of
groundwater contamination of the Glendale Study Area.

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                            TABLE 7-2

             SUMMARY OF RISK CHARACTERIZATION FOR THE
                        UPPER ZONE AQUIFER
                 FOR THE GLENDALE NORTH PLUME OU
 Exposure
 Scenario
Arithmetic
   Mean1
 RMEa
Maximum3
 Type of
  Risk
Adult
Ingestion
   8E-04

   4E+00
2E-03

8E+00
  5E-03

  2E+01
Cancer Risk

Hazard Index
Shower
Inhalation
   1E-03

   4E+00
2E-03

8E+00• •
 8E-03

 2E+01
Cancer Risk

Hazard Index
Steam Plant
Inhalation
  2E-05

  4E-02
           5E-05

           7E-02
            Cancer Risk

            Hazard Index
      1 Average Value

      2 Reasonable Maximum Exposure. The highest exposure that is
 reasonably expected  to occur at  a  site  (95% upper confidence
 limit of observed concentrations).

      3  The  exposure  scenario  using   the  highest  observed
 concentration  in any  monitoring  well  in  the  north  plume of
 groundwater  contamination in  the Glendale Study  Area.    EPA
 considers this scenario to be unreasonably high.

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      The Glendale Study Area is-zoned for commercial and industrial
 establishments.   The surrounding area  is  a mixture of  residential
 and commercial zoning.  Although an extensive ecological survey was
 not performed for the area, the presence of a significant wildlife
 population was not indicated.  In addition, the developed condition
 of  the  site excludes  the  potential  for   significant natural
 vegetative cover.

      The release pathway  of  primary  concern at this  site is
 contaminated groundwater.  There is no information, at  present, to
 indicate that  this  groundwater  reaches the surface or  that
 significant  concentrations are discharged  to a surface water  source
 (i.e.,  canal, river,  etc.).  Discharges to the Los Angeles River
 are likely to occur but are not expected to be significant enough,
 in volume or frequency, to  impact aquatic biota.

      Given the  present developed condition  of the  site and the
 major exposure pathway consideration of contaminated groundwater,
 there was no expectation  for  significant  impact  to  potential
 environmental receptors. Urbanization has already  replaced habitat
 potential; therefore, no significant number of receptors appeared
 to be present.    There  appeared to be  no apparent mechanism for
 exposure to environmental receptors  from contaminated groundwater.
 Also,  there  was no indication that  future  site plans  would
 reinstate  habitat   and   thereby  recreate   a   potential  for
 environmental receptors in the future.

 8.0   DESCRIPTION  OF ALTERNATIVES

      Based on the results of the RI,  EPA identified several cleanup
 alternatives  for  addressing  groundwater contamination in  the
 Glendale North Plume.  The  alternatives were developed  to meet the
 following specific cleanup objectives for the Glendale North  OU:

      o    To  inhibit   vertical  and   horizontal  migration  of
          groundwater  contamination in  the   North Plume of  the
          Glendale Study Area; and

      o    to begin to remove contaminant mass from the upper  zone
          of the  aquifer in the North Plume of the Glendale Study
          Area.

     All of the alternatives, with the exception of the  "no action"
alternative  (Alternative  l), involve  groundwater extraction and
treatment for the shallow  aquifer system  in  the Glendale area of
the San Fernando Valley.  The upper zone or shallow-most portion of
the aquifer is where the majority of the VOC contamination has  been
identified.  Detailed descriptions of the  various  alternatives are
presented in the Feasibility  Study  for the  Glendale  Study  Area
North Plume Operable Unit (April 1992).
                                18

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      Initially,  all  of the  alternatives  were  screened  for: 1)
 effectiveness at protecting public health  and  the  environment, 2)
 technical feasibility (implementability), and 3)  cost.  As a result
 of this initial  screening, seven alternatives were  evaluated using
 nine specific criteria: l)  Overall Protection  of Human Health and
 the Environment,  2)  Compliance with Applicable or Relevant and
 Appropriate Requirements (ARARs),  3) Long-term  Effectiveness and
 Permanence,  4)  Reduction of Toxicity, Mobility  or Volume  through
 Treatment,  5) Short-term Effectiveness,  6)  Impleroentability, 7)
 Cost,  8)  State Acceptance,  and 9)  Community Acceptance.   Each of
 EPA's  nine evaluation criteria  is  summarized below.

 Overall Protection of Human Health  and  the  Environment;   This
 criterion assesses whether each  alternative provides for both short
 term and  long  term overall  protection  of human  health  and the
 environment   from   unacceptable risks  posed  by  the  hazardous
 substances, pollutants, or contaminants present in the North Plume.
 The  assessment   draws  upon  the  evaluation  of  short-term
 effectiveness, long-term effectiveness, implementability, reduction
 of   toxicity,  mobility and/or volume  through treatment,  and
 compliance with  ARARs.

 Compliance with ARARs;  This criterion is used to  determine  whether
 the  alternative  meets  all   of   the   chemical-,  action-  and
 location-specific  ARARs identified  in Section  10 of  this  ROD.
 Since the remedial action established by the Glendale  North OU ROD
 is an interim action, chemical-specific requirements to be attained
 in  the  aquifer  at the end of the  final remedy are not ARARs for
 this  action.    Action-specific ARARs  address  the  groundwater
 response  actions that  may be  taken as part of  this interim action
 for  the Glendale North  OU.   All  of the  alternatives,  except no
 action,  include  groundwater extraction  followed by treatment and
 disposal or use as potable supply.   Therefore,  specific levels for
 treatment  of the  contaminated water prior   to disposal  or to
 delivery to the drinking water purveyor are chemical-specific and
 action-specific ARARs  for the Glendale North OU.

 Long-Term Effectiveness  and Permanence;   Long-term effectiveness
 refers to the period after the remedial action is complete.   Each
 alternative  is  assessed for  its  long-term  effectiveness  and
 permanence in reducing the risk to human health  and  the environment
 at  the  end of the  12-year  period.   The  long-term effectiveness
 evaluation focuses  on how  much total contaminant mass has  been
removed and contaminant concentrations remaining  in the aquifer at
the end of the 12-year period.

Reduction of Toxicitv. Mobility, and/or Volume through Treatment;
This criterion  addresses how well the  remediation technologies
permanently and significantly reduce the toxicity, mobility and/or
 volume of the hazardous substances.  The evaluation based  on  this
 criterion focuses on the quantity of hazardous  materials destroyed
 or  treated,   the   degree  to  which  the  remedial  action  is

                                19

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 irreversible, the type and quantity of residuals that are remaining
 after the remedial action is complete, and whether the alternative
 satisfies  the statutory preference for treatment  as  a principal
 element of the remedy.

 Short-Term Effectiveness;  Each alternative is evaluated based on
 its  effectiveness  in protecting  human health and the environment
 during the construction and implementation period.  The short-term
 effectiveness evaluation for each alternative focuses on how well
 the alternative removes contaminant mass, inhibits the movement of
 the contaminant plume, and how well the treatment system meets the
 cleanup levels in the extracted and treated groundwater during the
 12-year  period.    Short-term  effectiveness  also   addresses  the
 effectiveness of  the alternative in reducing  potential  risks to
 people living in the vicinity  of the  Glendale North Plume and to
 workers' health  and  safety  during construction of the  proposed
 facilities and implementation of the interim remedy.

 Implement ability;  The implementability criterion includes both the
 technical  and  administrative  feasibility  of  implementing  an
 alternative.  The  technical  feasibility refers to  the ability to
 construct,  reliably operate and maintain,  and meet cleanup levels
 for  process  options.   Administrative feasibility  refers  to  the
 ability to obtain  approvals  from other  offices and agencies,  the
 availability  and  capacity  of treatment,  storage, and  disposal
 services, and the availability of specific equipment and technical
 specialists.

 Cost;   The NCP  requires that the following  types of  costs  be
 evaluated:  1) Capital costs, including both  direct and  indirect
 costs,  2) Annual operation and maintenance costs and 3) Net present
value  of  capital  and  operations and  maintenance (O&M)  costs.
 Capital and O&M costs presented in the Glendale North OU FS report
have an accuracy  of +50 percent to -30  percent,  as specified by the
Guidance for  Conducting Remedial  Investigations and  Feasibility
 Studies Under CERCLA  (USEPA,  1988).    Capital  costs include  a
 contingency  of  20  percent  of  total  field  cost (TFC)  and  a
contractor's overhead and profit  (OH&P) at 30 percent of the sum of
TFC and contingency.   Evaluating present worth  costs assumes an
 interest rate of 10 percent and operating period of  12 years.  The
O&M cost evaluation assumes an operating load factor of 90 percent.

 State Acceptance;   This criterion considers the concerns of the
 State (technical and administrative) regarding the alternatives.

Public  Acceptance;   This  criterion  assesses the  components  of
 alternatives that interested persons in the community support, have
 reservations about or  oppose.

     EPA's  preferred  alternative, as  well  as  the other  six
 alternatives were described in EPA's Proposed Plan for  the Glendale
 North OU (July 1992).

                               20

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      ffie Glendale North  OU is an interim  action  and is not  the
 final  remedy for  cleanup  of contaminated  groundwater  in  the
 Glendale area.  With the exception of the  no action  alternative,
 all of  the  alternatives  involve the extraction of 3,000 gpm of
 groundwater  for a period of 12 years.  The total duration of  the
 remedy is 15 years, but  during  the  first three years the remedy
 will be  in  the remedial  design  and construction  phases and no
 extraction or treatment of groundwater will  be taking place.  A
 computer model called a solute transport model was developed  and
 used to determine  that  the extraction rate  of 3,000 gpm  over a 12
 year period would result in the most effective inhibition of  plume
 migration and effective  contamination  removal  for this interim
 action.   With the exception of Alternative 1 - No Action, all of
 the alternatives would involve the construction  and operation of a
 VOC treatment system.

      With the exception of Alternative l - No  Action, the  seven
 alternatives  analyzed and  compared during the FS and  presented in
 the Glendale  North OU FS  report include three major  elements: 1)
 extraction of contaminated groundwater at the rate  of  3000 gpm, 2)
 treatment of  the VOCs, and  3)  one of  four options for final  use -
 distribution  to a public water supply system,  reinjection into the
 aquifer,  spreading at an existing spreading grounds,  or discharge
 to  the  Los Angeles River  (See Table  8-1).  The major elements of
 each  of  seven alternatives  are listed below.

     Alternative l            NO Action

     Alternatives 2           Extract/Treat VOCs(air  stripping or
                              liquid  phase  GAC)/Public   Water
                              Supply

     Alternative 3            Extract/Treat VOCs(perozone)/Public
                              Water Supply and/or Reinject

     Alternative 4            Extract/Treat VOCs/River

     Alternative 5            Extract/Treat VOCs plus  ion exchange
                              for nitrate/Reinject

     Alternative 6            Extract/Treat VOCs/Spreading Grounds

     Alternative 7            Extract/Treat VOCs/Reinject


     The  highlights of  the  seven  alternatives are summarized
briefly below.  More detailed descriptions of the alternatives are
presented in  the  Feasibility  Study  for the Glendale Study Area
North Plume Operable Unit  (April 1992).
                                21

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Table 8-1:     Summary of Alternatives—Glendale North OU
Components
Groundwater Extraction
Treatment
Final Use
CRITERIA
Effectiveness and
Permanence
HeajKon ol Toxsiy. MoSnty.
Volume, ana Treatment
Compliance »•:-. ARARs
Overall Protection of human
Heaitn ar.d Environment
(Human Hea'th)
[Environment)
ImplementaDility
(Tecnncal)
ESTIMATED COSTS
Total Capital Cost
Annual O&M
Total Present Wonh
Alternative 1
• None
• None
• Monitor groundwater quality

• Not effective in the short or long-term
• No reduction of toxicity, mobility, or
volume
• Will not meet ARARs
• Assuming no institutional controls,
increased lifetime cancer risk of
ingesting contaminated groundwater
is estimated to be 1 in 500
• Not protective of environment
• Monitoring wells easy to construct
Spread of groundwater plume could
make future remediation difficult

$230.000
$110,000
$791,000
Alternative 2
• Extract 3000 gpm groundwater feom
12 wells
• Treat VOCs with dual-stag* air
•tripping and vapor-phase GAC
• Meet nitrate MCL toy blending
• Convey treated, blended water to "i:----
. City of Glendale'* PublteDiBtraxrton;
: System • :• • • •-••*;-••" - •,'.•'•
EVALUATION
• Inhfeit vertical and lateral migration;
of contaminant plume , ;
• No contaminated groundwater
discharged to Los Angeles River
• Remove contaminant maas from
aquifer . :
• Treated groundwater would meet
drinking water standards
• Estimated to reduce TCE concentra-
tions in the aquifer from 600 ppbto
less than 100 ppb attar 12 years
• Removes 82% o( the rnfttial mass of
TCE in the aquifer
• Wit meet ARARs
• Protective of human health
• Environmental degradation will be •
reduced because migration of .
groundwater contain^ TCE
concenbalions inhibftetf and TC£
masa removed
• Can be implemented
V
~
si9.eoo.ooo
$3^40.000 >-,-,'
$36,400,000
Alternative 3
• Same as Alternative 2
• Treat VOCs with perozone oxidation,
airstripping, and vapor-phase GAC
• Same as Alternative 2
• Same as Alternative 2

• Same as Alternative 2
• Same as Alternative 2
• Same as Alternative 2
• Same as Alternative 2
• Same as Alternative 2
* Same as Alternative 2
• Same as Alternative 2
• Same as Alternative 2
• Same as Alternative 2
• Same as Alternative 2, except
perozone oxidation treatment proven
at pilot scale only

S17.BOO.000
$2,610.000
S31.200.000
        EPA's Preferred alternatives.
        Alternative *S presented here in this Proposed Plan was formerly Alternative *8 in the Feasibility Study for the Glendale Sfjfly Area- North Plume
        O;e-aB!e 'J-ii'. (Asr.; 199?'.
        Aite;r.a;ive *7 p'esented here in this Proposed Plan was formerly Alternative *10 in the Feasibility Study for the Glendale Study Area: North Plume
        Ose'aS'e LJ-X iAs'i! 1992).

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Table 8-1 (cont):   Summary of Alternatives—Glendale North OU
Alternative 4
• Same as Alternative 2
• Same as Alternative 2
• Discharge treaiea water to Los
Angeles River
Alternative 5*
• Same as Alternative 2
• Same as Alternative 2. plus treat-
ment of nitrate with ion exchange
• Inject 3,000 gpm treated water into
12 wells
Alternative 6
• Sam» as Alternative 2
• Sam* as Alternative 2
• Discharge treated water to
Headworks Spreading Ground
EVALUATION
• Same as Alternative 2
• Same as Alternative 2
• Same as Alternative 2
• Treated g-ojicwate- wa-M meet
Brining wa:e- staissrss for VOCs
and $j<1ace waie- fl.scnarge
standards for nitrates
• Sa me as Attema :we 2
• Same as Alternative 2
• Same as Auemat've 2
• Same as Alternative 2
• Same as Aternative 2
• Same as Afle.-natwe 2

$17,700.000
S3.0SO.OOO
$33.300.000
• Same as Alternative 2
• Groundwater discharge to Los
Angeles River may be greater than
Alternative 2 (but TCE concentra-
tions lower)
• Same as Alternative 2
• Same as Alternative 2
• Estimated to reduce TCE concentra-
tions from 600 ppb to less than 100
ppb after 12 years
• Removes 69% of initial mass of TCE
in the plume
• Same as Alternative 2
• Same as Alternative 2
• Same as Alternative 6, except
greater mass of TCE removed
• Same as Alternative 2; issues
associated with waste brine disposal
(from ion exchange) and with
injection (e.g., potential for clogging)
will have to be addressed

S37.000.000
$4.760.000
$61.400,000
• Same as Alternative 2
• Same as Alternative 2
• Sam* as Alternative 2
• Treated groundwater would meet
drinking water standards for VOCs
and groundwater recharge standards
for nitrates
• Sam* as Alternative 2
• Removes 66% of the initial mass of
TCE in the plume
• Sam* as Alternative 2
• Same as Alternative 2
• Same as Alternative 2, except
greater mass of TCE removed
• Same as Alternative 2; on*
administrative issue may be the
availability of the Headworks
Spreading Grounds (or recharge

$19.600.000
S3.300.000
$36,500.000
Alternative?**
•'•> Same as Alternative 2
• Seme as Alternator* 2
• Same as Alternative 5

• Sam*asAH*mattv*2 .
• • Same as Alternative 5
• Same as Alternative 5
• Same a* Alternative 5
• Sam* as Alternative 5
• Sam* a* Altemativ* 5
• Sent* a* Alternative 2
• Sam* «s Alternative 2
• Same •* Alternatives •..• .
>
• Same as Alternative 2, saeept issues
associated wRn Injection (e.g..
dogging), which win have to be pilot-
tested prior to fuB-*cale Implementa-
tion -,

S21.800.000
$3.300,000
$38.700.000

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 Alternative  1;   No  Action

      The No Action alternative serves as a "baseline" against which
 other alternatives  are compared.  This alternative is evaluated to
 determine  the risks that would  be posed to public health and the
 environment  if  no  action  were taken  to treat  or contain  the
 contamination.    The no  action alternative  would involve  only
 groundwater  monitoring; no additional cleanup activities would be
 conducted.

 Alternative  2;   EPA's Preferred Alternative
 Extract/TreatrAir  Stripping  or Liquid  Phase  GAC1/Public  Water
 System

      Alternative 2  involves  the  extraction  of  3,000  gpm  of
 contaminated groundwater for 12 years.   The extraction wells would
 be  located  to  inhibit  most effectively the  migration of  the
 contaminant  plume.  Various locations  and scenarios for extraction
 wells and rates of extraction  are proposed in the feasibility study
 report.for the  Glendale  North OU.   However,  all design decisions
 for  this  interim remedy will be made  during  the  remedial design
 phase.  At that time, one of the locations proposed for extraction
 wells and scenarios for rates  of extraction at  individual wells may
 be selected  or  new  ones may be selected.

      The  extracted groundwater will  be  filtered  to  remove  any
 suspended  solids,  if necessary, and then treated for  VOCs using
 dual-stage  or  single-stage  air  stripping with vapor-phase  GAC
 adsorption for emissions control or liquid phase GAC.  Whether air-
 stripping  (dual versus  single)  or liquid  phase GAC will be used
'Will  be determined during  remedial   design  as will  the  exact
 location for the treatment plant (note that four  possible locations
 were  proposed  in the Glendale North OU  FS report).   The treated
 water will be blended with water which does not  contain nitrate in
 excess  of  the nitrate MCL  to reduce  nitrate levels to  meet the
 nitrate MCL.  The treated water  shall meet all ARARs identified in
 Section 10 of this ROD and will be conveyed to  the City of Glendale
 and/or another San Fernando Valley water purveyor for blending and
 distribution through the  public  supply  system.   The  treated,
 blended water will  have to  meet  all  applicable drinking water
 requirements for drinking water in existence at the time that the
 water is served prior to distribution through the public drinking
 water supply system.

      In  response to comments  by the  City  of Glendale  on  the
 Glendale North and South OU Proposed Plans and in order to decrease
 overall costs associated with the OUs,  EPA has determined that the
 treatment plants for the Glendale North and Glendale South OUs will
 be  combined and the total 5,000 gpm  of treated water  will be
 conveyed to  the City of Glendale  for  distribution  to its public
 water supply system.  The exact location of the  combined treatment
 plant will be determined during the remedial  design phase of the

                                22

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 project.    The Glendale  South' OU  Record of  Decision  will also
 reflect this decision to combine  the treatment plants.

      However,  if  the  City of Glendale does not agree to  accept the
 treated water  from both OUs (possibly due  to water supply needs) or
 if  EPA determines   that  combining  the  treatment  plants will
 significantly delay or hinder the  implementation of  the Glendale
 North OU, the treatment plants will  not be combined.   Furthermore,
 if the city of Glendale does  not  accept any  or all  of the treated
 water,  any remaining portion of water will be 1) offered  to another
 San Fernando  Valley  water  purveyor or  2)  reinjected into the
 aquifer, per Alternative 7  (see description  below).

      Existing  production  wells  that may  provide  pathways for
 vertical   migration  of  contamination   will   be  abandoned  or
.rehabilitated,  if required.   Final  determinations regarding which
 production  wells  will be abandoned and/tor rehabilitated will be
 made during  remedial design.  Groundwater monitoring wells will be
 installed  to evaluate the effectiveness  of  the remedial action.
 More specifically,  groundwater monitoring shall  be  conducted no
 less frequently  than  quarterly  to:  1)  evaluate  influent and
 effluent water quality, 2) determine and evaluate  the capture zone
 of the extraction  wells,  3)  evaluate  the  vertical and lateral
 (including downgradient) migration of contaminants, 4) evaluate the
 effectiveness  of  the  reinjection well system,  if necessary  and 5)
 monitor any  other factors associated with the effectiveness  of the
 interim remedy determined to be necessary during remedial design.

 Alternative  3;  Extract/Treat(Perozone Oxidations/Public Water
 System

     Alternative  3  also requires the extraction  of 3,000. gpm of
 contaminated groundwater  for  12 years,  and the same  final use of
 the treated water and the same groundwater monitoring requirements
 as Alternative 2.  Alternative 3 only differs from Alternative 2 in
 that  the  extracted groundwater would be treated  for VOCs  using
 perozone oxidation, followed by air  stripping with vapor-phase GAC
 adsorption for emissions control.  Air stripping would be required
 to  remove  any carbon tetrachloride in  the extracted groundwater
 because the  perozone  oxidation process alone does not effectively
 treat this VOC.

 Alternative  4:  Extract/Treat/River

     Alternative  4  also involves the extraction  of 3,000  gpm of
 contaminated groundwater for  12  years,  and  the  same  treatment
 methodology  and the same groundwater monitoring  requirements as
 Alternative  2.  However,  rather than providing the treated water to
 a public water purveyor, the treated  water would be  discharged to
 the  Los Angeles River.
                                23

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 Alternative 51:   Extract/Treat-plus Ion Exchange/Reinject

      Alternative 5 also involves the  extraction  of  3,000 gpm of
 contaminated groundwater for  12  years,  and  the  same monitoring
 requirements as  Alternative  2.     Alternative  5  differs from
 Alternative 2 in that the extracted groundwater would be treated
 for VOCs  using  dual-stage  air  stripping with  vapory-phase GAC
 adsorption for  emissions  control  and then would be treated using
 ion exchange to reduce the nitrate levels in the water to meet the
 nitrate MCL.  The treated water would  then be reinjected.

 Alternative 6:   Extract/Treat/Spreading Grounds

     Alternative  6 also involves the  extraction  of  3,000 gpro of
 contaminated groundwater for 12 years,  the same treatment approach
 as  described  in Alternative 2 and  the same ground water monitoring
 requirements  as Alternative 2.   However, ..unlike Alternative 2, the
 treated water would be recharged  to the  aquifer at the  Headworks
 Spreading  Grounds.

 Alternative 72;   Extract/Treat/Reinject

     Alternative  7 also involves  the  extraction  of  3,000 gpm of
 contaminated  groundwater for 12 years, the same treatment system,
 the same   groundwater  monitoring requirements  and  provides for
 abandonment or rehabilitation of production wells as required for
 Alternative  2.   However,  the treated  water  would be reinjected.
 The reinjection shall occur where nitrate levels in the aquifer are
 equal to  or greater than the  nitrate  levels in the  water  to be
 reinjected.

 9.0  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

     A comparative analysis  of the  alternatives against the nine
 evaluation criteria is presented in this section.

No Action versus the Nine Criteria.   Clearly, Alternative 1 would
not be effective  in the short- and  long-term in protecting human
health and the environment as it does not provide for removing any
contaminants  from  the upper zone of the  aquifer,  for inhibiting
further downgradient and vertical contaminant plume migration, or
for reducing the  toxicity,  mobility  and  volume  of  contaminants
through treatment.  Implementing the no-action alternative would be
     1 Note:  Alternative #5 presented here in this ROD was
formerly Alternative #8 in the Feasibility Study for the Glendale
Study Area: North Plume Operable Unit (April 1992).

     2 Note:  Alternative #7 presented here in this ROD was
formerly Alternative #10 in the Feasibility Study for the
Glendale Study Area; North Plume Operable Unit (April 1992).

                                24

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       —-^
 simple  and  inexpensive  since  it  involves  only  groundwater
 monitoring.   As indicated  by the baseline risk assessment for the
 Glendale North OU presented in  the RI Report for the Glendale Study
 Area (January 1992), Alternative 1 could pose both carcinogenic and
 non-carcinogenic risk  if a person were exposed to the groundwater
 from the upper  zone of the aquifer.   Loss of  a valuable water
 resource from continued degradation  of the aquifer and discharge of
 valuable water  to the  river is a major concern.

 overall  Protection of Human Health and  the Environment, Short Term
 Effectiveness and Long Term Effectiveness.  Alternatives  2 through
 7  are effective in the  short-term  and  long-term in reducing the
 risk to  human health and the environment by removing contaminants
 from the  upper  zone  of  the aquifer,  by  inhibiting further
 downgradient  and vertical contaminant plume  migration,  and  by
 reducing the toxicity, mobility, and volume of contaminants in the
 aquifer.  Alternatives 2 through 4 have the same  effectiveness in
 inhibiting downward  and  downgradient migration of  the contaminant
 plumes,  in  removing contaminant mass from the Upper Zone of the
 aquifer, and in reducing the discharge of contaminated groundwater
 to the Los Angeles River.  During the first 12 years of operation,
 Alternatives  2 through 4 are estimated to remove  approximately 82
 percent of the total estimated  initial TCE mass,  and may reduce the
 maximum  TCE  concentration remaining in the upper zone  of  the
 aquifer by as much as 88 percent.

     Alternative  6  is  effective  in  inhibiting downward  and
 downgradient  migration  of the contaminant  plumes, in  removing
 contaminant  mass from  the upper  zone of  the  aquifer,  and  in
 reducing  the discharge  of contaminated groundwater to  the  Los
Angeles  River.   Because Alternatives 6 involves  recharge at the
Headworks Spreading Grounds which  would  push  a  portion  of  the
 contaminant  plume   located upgradient  of  the  extraction  sites
towards the extraction wells, this alternative may remove slightly
more  mass (86 percent  of  the  estimated  initial  TCE mass)  than
Alternatives 2 through 4 (82 percent of the estimated initial TCE
mass).  Alternative  6  also reduces  the maximum TCE concentration
remaining in the Upper  Zone  of  the  aquifer  by  as much as  88
percent.

     Alternatives 5  and 7 have the  same  effectiveness in inhibiting
downward and downgradient migration of the contaminant plumes and
 in removing contaminant  mass from the  Upper  Zone of the aquifer.
The  extraction  well configuration proposed in the FS  report for
Alternative 5 is different from those proposed for Alternatives 2
through 6, in that three  extraction sites are  used instead of four,
to accommodate injection downgradient of extraction.  Reinjecting
the treated groundwater may increase the discharge of contaminated
groundwater to the river near the injection wells  in excess of the
discharge estimated  in the no-action alternative.  However,  the
 injection  of  3,000  gpm  of  treated  water  would  dilute  the
contamination in the  groundwater   and  decrease  the contaminant

                                25

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 concentration  levels  in the groundwater  discharged to  the Los
 Angeles River.  Other injection sites could be investigated during
 the remedial design phase.  The model estimates that approximately
 89 percent of the initial estimated mass of TCE in the groundwater
 would be removed during  the  first  12 years of operation.

     Alternatives  5 and  7  reduce the  maximum TCE concentration
 remaining  in the  Upper  Zone  of  the  aquifer  by  as much  as  86
 percent.   Although  slightly more contaminant  mass  (89  percent
 versus  82  and 86  percent  for Extraction  Scenarios  4  and  8,
 respectively)  is  removed in this  scenario due to  the effects of
 aquifer recharge,  the TCE concentration remaining in the Upper Zone
 is slightly  higher.   The higher TCE  concentration is due to the
 downgradient reinjection of the treated groundwater, which may tend
 to restrict  the remaining contaminant mass to  a slightly smaller
 area.

 Reduction of Toxicity, Mobility and Volume  through Treatment.  The
 VOC treatment technologies used in Alternatives 2,  4, 5, 6, and 7
 (dual-stage  air stripping with  vapor-phase GAC  adsorption and/or
 liquid phase GAC adsorption) and used in Alternative 3 (perozone
 oxidation   followed   by  air  stripping   with   vapor-phase  GAC
 adsorption) are technically feasible and effective in meeting ARARs
 for VOCs in  the extracted and  treated groundwater.   Treatment of
 the extracted contaminated groundwater via dual-stage air stripping
 with vapor-phase GAC adsorption and/or liquid phase GAC adsorption
 would  reduce   substantially  the  toxicity   and   mobility  of
 contaminants in the aqueous phase.  The  adsorption of contaminants
 onto  the  GAC  would  reduce the  volume  of  contaminated  media.
 However,  a substantially larger quantity of contaminated GAC media
would  be  generated with the  dual-stage air  stripping  system
 compared to perozone oxidation  (which is a destructive technology)
 followed by  air stripping with  vapor-phase GAC  adsorption.   This
 contaminated GAC would require disposal or regeneration.

     Treatment  of  the  extracted  contaminated  groundwater  via
perozone oxidation followed by air stripping with vapor-phase GAC
 adsorption would destroy greater than 90 percent of the VOCs, and
generate a smaller quantity of contaminated GAC media compared to
 dual-stage air stripping.  VOC treatment using perozone oxidation
has  only   been  tested   and   applied   in   pilot-scale/limited
 applications,  and limited  O&M  data are  available; however,  a
demonstration-scale  (2,000-gpm)  facility has begun  operation in
North Hollywood for treating TCE- and PCE-contaminated groundwater.
This prototype  facility should provide useful information regarding
the long-term performance and O&M  costs.

     As a result  of comments received  during the  public comment
 period, EPA further evaluated the use of perozone  oxidation for the
 Glendale North OU.  Additional research on perozone  use and revised
 cost estimates based on a bench scale  treatability  study can be
 found in  the following  technical  memorandum:    Applicability of

                                26

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Perozone  Treatment. Process for the Glendale  North Operable Unit
Groundwater Remediation  (March 12, 1993) included in Supplement 1
of the Administrative Record for the Glendale North OU available at
all  five information  repositories for  the San  Fernando Valley
Superfund  sites.   Carbon  tetrachloride,   which  is  one of  the
contaminants found in the groundwater  of the Glendale North plume,
is not as readily  treated using  the perozone process  and must be
treated using air-stripping or liquid  phase GAC to ensure that the
treated water will meet all drinking water  standards for VOCs.  In
addition, incomplete  oxidation can lead to the  formation of by-
products such as formaldehyde which would also need to addressed.
The bench scale treatability study found  that the total present
worth  cost  estimated in  the FS  report  is underestimated  and
$500,000  or  more  could  be added  to  the  estimated  $31,200,000.
These  factors  coupled with  the  uncertainties  associated  with
design,~capital and operational costs  and reliability, and finally
the fact  that a municipality  will be receiving this  water,  all
combine to make Alternative 3 less preferable than Alternatives 2
and 4 through 7 which propose using air stripping or liquid phase
GAC for VOC treatment.

Compliance with ARARs.  As discussed in the ARARs section  (Section
10) of this ROD, since this remedial action is an interim action,
there are no chemical-specific ARARs for aquifer cleanup for any of
the alternatives.   For  Alternatives  2-7,  the  chemical-specific
ARARs for the treated  water from the  VOC treatment plant at this
site are  Federal MCLs  and more  stringent State MCLs for  VOCs.
Alternatives 2,  4,  5,  6 and 7 are expected  to meet these ARARs for
the treated water.  There is some  uncertainty regarding the ability
of Alternative 3 to meet these  ARARs because perozone has not been
used to treat such high  concentrations  of  VOCs  at such high flow
rates.  Therefore,  there could be problems unless the air stripping
unit  proposed  to  follow the  perozone  system   is  a  redundant
treatment system which would add substantially to the cost.

     For the Alternatives that  involve distribution of the treated
water to  a  public  water supply  system (Alternatives 2  and 3),
secondary drinking water standards are ARARs and will be met prior
to blending of  the water for  nitrate.   For water that  will be
served at the  tap,  all applicable requirements will have to be met
after blending,  including the nitrate  MCL.   For Alternatives 6 and
7, the nitrate levels  in the treated groundwater will meet ARARs by
ensuring that recharge of the treated groundwater  (Alternative 6)
and reinjection of the treated  water  (Alternatives  5 and 7) occurs
where  levels  of these substances in the  receiving  aquifer are
similar to those in the treated water to be discharged, recharged
or reinjected.   EPA  has  confirmed  that  nitrate levels  in the
groundwater beneath the Headworks Spreading Grounds are similar to
the nitrate levels observed in  the vicinity of proposed extraction
well sites.   In Alternative  4,  the  treated water will meet MCLs
for VOCs prior to discharge to  the Los Angeles River (which is on-
site) .

                               27

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      For a more detailed discussion of ARARs please review Section
 10 of this ROD .

 Implementability.   Technically and administratively. Alternatives
 2,  3,  4 and  6 could be implemented.   The technologies considered
 for groundwater monitoring, extraction, and  conveyance are proven
 and have  been  applied  extensively.    For  Alternative 6,  the
 availability  of  the Headworks Spreading Grounds for discharge of
 extracted and treated groundwater would  need to  be addressed.
 Technically,  Alternatives 5 and  7 could probably be implemented,
 but using ion exchange for nitrate treatment (Alternative 5) and
 reinjection   for  treated  groundwater  disposal  may  pose  some
 technical and administrative  feasibility  issues.   In particular,
 disposing of  the waste brine generated from backwashing the ion
 exchange system may restrict the  technical  and administrative
 feasibility of using ion  exchange for nitrate treatment.  Several
 technical  feasibility  issues  may arise  when  injecting treated
 groundwater.   At the location of the proposed reinjection sites,
 the  groundwater is approximately  30 feet below the ground surface;
 thus,  only  a limited  hydraulic  head could  be  applied  to induce
 injection.   Groundwater-injection pilot studies  may  be required
 prior  to full-scale application.    In addition, other possible
 locations  for reinjection well  placement  can  be  proposed  and
 reviewed during the  design phase.

     EPA has determined that the  treatment plants for the Glendale
 North and Glendale  South OUs will be combined.  The total 5,000 gpm
 of  treated  water will  be conveyed to  the City of Glendale for
 distribution  to its  public  water  supply  system.    The  exact
 configuration of the combined treatment plant will  be determined
 during  the remedial design phase of  the  project.    The City of
 Glendale has  indicated that it has  sufficient  water  credits and
 capacity in their existing water system to accept this amount of
 extracted treated water.  Therefore, combining the treatment plants
 for  the  Glendale North and South OUs would be implementable.

 State and Public Acceptance.  Based on comments received during the
public comment period,  the State and the public generally expressed
 support  for Alternatives 2 through 7.  In a  letter dated June 16,
 1992,  the State   (DTSC)  expressed  its concurrence  with  EPA's
preferred  alternative  presented  in  the  Proposed  Plan  for  the
Glendale  North OU  which  is  now EPA's. selected  remedy  for the
Glendale  North OU.    In  a letter dated March  29,  1993,  after
reviewing the Draft ROD for the Glendale North OU,  DTSC stated that
 it agreed with EPA's selected remedy for the Glendale North OU.
EPA received several comments from other State agencies, the City
of Glendale and members of the Glendale community specifically in
 support  of Alternatives 2  and 7.   In a letter dated September 8,
 1992, the Los Angeles Region of the Regional  Water Quality Control
Board offered support for  EPA's preferred alternative presented in
                                28

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 the Proposed Plan for the Glendale North OU but requested to go "on
 record" as favoring the direct use of the treated water as opposed
 to reinjecting it.

     One  member of  the  public  commented  that he did not  like
 Alternative  2  and asked  that  EPA not include distribution  to a
 public water supply as a final use of the treated water.. The State
 Water Resources  Control Board, City  of  Glendale,  and many other
 commenters did not  support Alternative 4,  involving discharge to
 the Los  Angeles River.   A few commenters including  the  City of
 Glendale  had  a preference for  Alternative  3,   which  proposes
 perozone  for VOC treatment.  Comments received during the public
 comment period along with EPA responses are presented in Part III
 of  this ROD, the Responsiveness Summary.

     A public meeting was held in the City of Glendale on July 23,
 1992,  to  discuss  EPA's  preferred  alternative   and  the  other
 alternatives.   At  this  meeting  EPA  gave  a  brief presentation
 regarding  the  Proposed  Plan,  answered  questions, and accepted
 comments from members of  the public.

     At the public meeting and in a subsequent  letter, the City of
 Glendale  emphasized  that it would like to receive greater  than
 3,000 gpm of  extracted,  treated  groundwater.    The City  also
 indicated  that  it  had  stored water credits and water  rights
 sufficient to accept greater than 5,000 gpm of extracted,  treated
 groundwater from the San Fernando Valley.   As  a  result  of the
 City's oral and written comments  on the Glendale North OU, EPA has
 determined that  the  treatment plants  for the  Glendale North and
 South OUs  shall  be combined and  the total 5,000  gpm of  treated
 water will be conveyed to the City of Glendale.

 Cost.   The estimated total present worth of Alternatives 2, 3, 4,
 6, and 7 ranges from $28,200,000 to $38,700,000. The total present
worth costs for Alternative 2  fall within the middle of this range
 at  $36,400,000.  The total  present worth for Alternative 5 which
 includes  nitrate treatment using  ion exchange is $61,400,000.
Using ion exchange for nitrate treatment  adds significantly to the
 cost of the alternatives.

     EPA has determined that the treatment plants for the Glendale
North and Glendale South OUs will be combined.  The  total 5,000 gpm
 of  treated  water will  be conveyed to the  City of Glendale for
distribution  to  its  public  water  supply  system.   The  exact
 configuration of the combined  treatment plant will be determined
 during the remedial design phase  of the project.  The costs of the
two separate OU projects  is. estimated to  be  $36,400,000 for
 Glendale  North  and $25,020,000  for Glendale  South.   Therefore,
 these two separate OU projects total $61,420,000.   Recent EPA cost
 estimates  (included in  Supplement  1 to the  Glendale North OU
Administrative Record) indicate that  combining the Glendale North
 and South OUs could result  in a cost  savings of $13,888,000.

                               29

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     Although  the  cost  estimate for  Alternative 2  is  slightly
higher  than some of the other  alternatives,  the estimated costs
presented here and  in the FS do not  take  into  account the value of
utilizing the groundwater resource as opposed to disposing of the
water in the Los Angeles River  (Alternative 4) or reinjecting the
water back  into the aquifer  (Alternative 7).

10.0 APPLICABLE OR  RELEVANT AND APPROPRIATE REQUIREMENTS

     This section discusses Applicable or Relevant and Appropriate
requirements  (ARARs)  for the  Glendale North OU.   Under Section
121 (d) (1) of the Comprehensive Environmental Response, Compensation
and Liability Act of  1980  as amended by the Superfund Amendments
and Reauthorization Act of 1986  (collectively, CERCLA). 42 U.S.C.
§  9621(d)  remedial actions  must attain a level or  standard of
control~ of  hazardous  substances which  complies  with ARARs of
Federal environmental laws and more stringent state environmental
and facility siting laws.   Only state requirements that are more
stringent  than Federal  ARARs,  and  are  legally  enforceable  and
consistently enforced statewide may be ARARs.

     Pursuant to Section 121(d) of CERCLA,  the on-site portion of
a remedial  action selected  for a Superfund site must comply with
all ARARs.   Any portion of a remedial action which takes place off-
site must comply with all  laws legally applicable at the time of
the off-site activity occurs,  both administrative and substantive.

     An  ARAR  may  be  either  "applicable",  or  "relevant  and
appropriate", but not both.   According  to the  National  Oil  and
Hazardous Substances Pollution Contingency  Plan  (NCP)  (40 CFR Part
300) ,  "applicable"  and "relevant and appropriate" are defined as
follows:

      •    Applicable  requirements are  those cleanup  standards,
          standards of control,  or other  substantive environmental
          protection  requirements,   criteria,    or  limitations
          promulgated  under  Federal  or state   environmental or
          facility  siting   laws that  specifically  address  a
          hazardous substance,  pollutant,   contaminant,  remedial
          action, location,  or other circumstance found at a CERCLA
          site.  Only those state standards that  are identified by
          a state in a timely manner and that are more stringent
          than   Federal    requirements    may   be   applicable.
          "Applicability" implies that the remedial action or the
          circumstances  at  the   site   satisfy  all   of   the
          jurisdictional prerequisites of a requirement.

      •    Relevant  and appropriate requirements are those cleanup
          standards,  standard of control,  and  other substantive
          environmental  protection  requirements,  criteria,  or
          limitations promulgated under  Federal environmental or
          state environmental or facility siting laws that, while

                                30

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           not "applicable" to  a  hazardous substance, pollutant,
           contaminant,   remedial  action,   location,   or  other
           circumstance  at  a  CERCLA site,  address  problems or
           situations sufficiently similar  to those encountered at
           the CERCLA site that their use is  well  suited to the
           particular site.   Only  those  state  standards that are
           identified in a timely manner and that are more stringent
           than  Federal   requirements   may   be   relevant  and
           appropriate.


 Chemical-Specific  ARARs.   Chemical-specific ARARs are health- or
 risk-based concentration limits, numerical values, or methodologies
 for various environmental media (i.e., groundwater, surface water,
 air,  and  soil)  that are established for a specific chemical that
 may  be present in  a  specific  media at the site,  or  that may be
 discharged to the site during remedial activities.  These ARARs set
 limits on  concentrations   of  specific  hazardous  substances,
 pollutants, and contaminants in the environment.   Examples of this
 type  of ARAR are ambient water quality criteria and drinking water
 standards.

 Location-Specific   ARARs.    Location-specific  requirements  set
 restrictions  on  certain  types   of  activities  based  on  site
 characteristics.   Federal and  state  location-specific  ARARs are
 restrictions placed on  the  concentration of a contaminant or the
 activities to be conducted because  they are in a specific location.
 Examples of special locations possibly requiring ARARs may  include
 flood  plains, wetlands, historic places, and sensitive ecosystems
 or habitats.

 Action-Specific   ARARs.     Action-specific   requirements   are
 technology- or activity-based requirements which are triggered by
 the type of remedial activities under consideration.  Examples are
 Resource,   Conservation  and Recovery  Act  (RCRA)  regulations for
 vaste  treatment, storage or disposal.

     Neither CERCLA nor the National  Oil and Hazardous Substances
 Pollution  Contingency Plan  (NCP)   (400 C.F.R.  Part 300) provides
 across-the-board standards  for determining whether  a particular
 remedy will result in an adequate cleanup at  a  particular site.
 Rather, the  process recognizes that  each site will  have unique
 characteristics  that must  be  evaluated  and  compared to those
 requirements that apply  under the given circumstances.   Therefore,
ARARs  are  identified on  a  site-specific  basis  from information
 about specific chemicals at the site, specific features of  the site
 location,  and actions that are being  considered as remedies.

     The following section outlines the Applicable or Relevant and
Appropriate Requirements  (ARARs) that apply to this site.
                                31

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 10.1 Chemical-Specific ARARs

     10.1.1  Federal Drinking Water Standards

 Section  1412 of  the  Safe Drinking Water  Act  (SDWA^.  42 U.S.C.
 S300g-l.  "National Water Regulations"; National Primary Drinking
 Water Regulations. 40 CFR Part 141.

     EPA has established Maximum Contaminant Levels  (MCLs)  (40 CFR
 Part 141)  under  the  Safe Drinking Water  Act  (SDWA)  to protect
 public health from contaminants that may be found in drinking water
 sources.  These  requirements are applicable at the  tap for water
 provided directly to 25 or more people or which will be supplied to
 15 or more  service connections.   The MCLs  are applicable to any
 water that would be  served  as drinking  water.   Under NCP Section
 300.430ff) (5), remedial actions must generally attain MCLs and non-
 zero Maximum Contaminant Level Goals (MCLGs) for remedial actions
 where the groundwater is  currently or  potentially  a  source of
 drinking water.

     The Glendale North groundwater is a  source of drinking water.
 However, since the Glendale North OU remedial action  is an interim
 action,  chemical-specific cleanup requirements for the aquifer such
 as attaining MCLs  and non-zero MCLGs, which would be ARARs for a
 final remedy, are not ARARs for this interim action.  (See 55 Fed.
 Reg.  8755.)    Nevertheless,  EPA  has  determined  that   for  the
 treatment plant  effluent from the Glendale North OU, the Federal
 Maximum Contaminant Levels (MCLs) for VOCs and any more stringent
 State of California MCLs  for VOCs are relevant and appropriate and
must be attained regardless of the end use or discharge method for
 the treated water.

     For the treated and blended water which will be put into the
 public water supply, all applicable requirements for drinking water
 in existence at the time that the water is served will have to be
met because EPA considers the blending facility and the serving of
 the water to the public  (at the tap) to be off-site.  Complying
with all applicable requirements  for drinking water at the tap will
 also require attainment of the MCL for nitrate  prior  to serving the
water to the public.  Since these are not ARARs, these requirements
 are not  "frozen" as of  the date of the ROD.   Rather,  they can
 change over time as new laws and regulations applicable to drinking
water change.  See 55 Fed.  Reg.  8758  (March 8,  1990).  Figure 10-1
provides a diagram of the treatment chain and blending process for
 the treated water prior to distribution  of  the treated and blended
water to the public water supply for Alternatives 2  and  3.
                                32

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                         ON-SITE
                         Treatment
                            Plant
            I I  I I I I I I  I
              Extraction
                Wells
                                   OFF-SITE
                                                 1. Point o! Delivery
                                                  to Water Purveyor*
                                    Blending
                                    Facilities
I  ITT
Infection Wells
        Must meet all ARARs

        Must meet all legal requirements
        Including MCL tor nitrate
                                                           2. Point ol Public
                                                            Water System
                                                            Introduction"
                              FIGURE 10-1: ON-SITE ARARS AND OFF-SITE LEGAL
                                          REQUIREMENTS FOR THE GLENDALE NORTH OU
                                          INTERIM REMEDY
SFO69208.06.01

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 10.1.2 '""State  Drinking Water standards

 California  Safe  Drinking  Water Act.  Health  and Safety  Code.
 Division  5. Part  1.  Chapter 7. 54010 et sea.. California Domestic
 Water  Quality  Monitoring regulations. CCR Title  22.  Division 4,
 Chapter 15. S64401 et sea.

     California has  also established drinking water standards for
 sources  of  public  drinking  water,  under  the  California  Safe
 Drinking  Water Act  of  1976,  Health  and  Safety Code  Sections
 4010.l(b) and  4026(c).   The State  of  California  has  promulgated
 MCLs  for  primary VOCs.     Several  of the  State MCLs  are  more
 stringent than Federal MCLs.   In these cases,  EPA has determined
 that  the  more stringent State  MCLs for VOCs  are relevant  and
 appropriate  for  the treatment plant effluent  from the  Glendale
 North  OU  interim remedy.    The   VOCs  for which  there  are  more
 stringent State standards include:  benzene; carbon tetrachloride;
 1,2-Dichloroethane  (1,2-DCA);  1,1-Dichloroethene  (1,1-DCE);  cis-
 1,2-DCE; trans-l,2-DCE; and Xylene.   There are also some chemicals
 where  State  MCLs  exist but there are  no Federal MCLs.   EPA has
 determined that these state MCLs  are relevant and appropriate for
 the  treated  water prior  to discharge or delivery to the  water
 purveyor.   The VOCs  for which there are  no  Federal MCLs but for
 which   state   MCLs  exist   include:       1,1-DCA;   1,1,2,2-
 tetrachloroethane; and 1,1,2-Trichloroethane.

     In  a letter to  EPA  dated June  2,  1992,  the  California
 Environmental  Protection  Agency, Department of Toxic Substances
 Control  (DTSC)  stated  that   EPA  should include  a  discussion
 regarding "future State MCLGs and the cumulative hazard index and
how they will  affect the use of treated groundwater as a drinking
water source."   Water served as drinking water is required to meet
MCLs at the  tap,  not MCLGs.  Therefore,  EPA would generally not
expect a  future  change in  an  MCLG  to affect the  use  of treated
groundwater as a  drinking  water source.   The  cumulative hazard
 index is also not  an  ARAR.   However, EPA does retain the authority
to require changes in the  remedy if necessary to  protect  human
health  and  the  environment,  including  changes  to  previously
selected ARARS. See 40 C.F.R. Sections 300.430(f)(1)(ii)(B)(1) and
300.430(f)(5)(iii)(C).  If EPA  receives new information indicating
the remedy is not  protective of public health and the environment,
EPA would  review the  remedy  and make  any changes necessary to
ensure protectiveness.

     EPA has  also  determined that the monitoring  requirements found
 in CCR Title 22 Sections 64421-64445.2 are relevant and appropriate
 for  any  treated  water  which will  be delivered  to the  City of
Glendale's  Public  Water  distribution  system.    However,   the
 selection of  these sections  as ARARs involves only the requirements
that specific  monitoring be performed.   It  would  not  include any
 administrative requirements (such as reporting  requirements)  and
would also not include meeting  substantive  standards  set within

                               33

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these sections since no such standards have been identified by the
State as being more stringent than Federal requirements.  For the
off-site portion of this remedy, including the treated water after
blending,  all  applicable requirements would have to be satisfied
including  the  monitoring requirements  in CCR  Title  22 Sections
64421-64445.2.

     Accordingly,   the   chemical-specific   standards   for   the
groundwater  extracted and  treated under  the Glendale  North OU
interim remedy are the  current Federal or State  MCLs  for VOCs,
whichever  is more stringent.

10.2   Location-Specific ARARs

     No special characteristics exist  in the Glendale Study Area to
warrant  location-specific  requirements.    Therefore,  EPA  has
determined  that there are  no  location-specific  ARARs for  the
Glendale"North OU.

10.3   Action—Specific ARARs

10.3.1  Clean Air Act. 42 U.S.C. S7401 et sea.

Rules and  Regulations of the South Coast  Air Quality Management
District

     Glendale North OU treatment of VOCs  by air stripping, whereby
the  volatiles  are  emitted  to  the atmosphere,  triggers action-
specific ARARs with respect to air quality.

     The Clean  Air  Act regulates air emissions to protect human
health and the  environment,  and is the  enabling statute for air
quality programs and  standards.   The  substantive requirements of
programs provided under the Clean Air Act are implemented primarily
through Air  Pollution Control  Districts.    The South  Coast  Air
Quality Management District  (SCAQMD) is the district regulating air
quality in the San Fernando Valley.

     The SCAQMD. has  adopted  rules that  limit  air emissions of
identified toxics and contaminants.   The  SCAQMD Regulation XIV,
comprising Rules 1401,  on new  source review  of carcinogenic air
contaminants is applicable for the Glendale North OU.  SCAQMD Rule
1401 also requires  that best available control technology (T-BACT)
be  employed  for  new  stationary operating   equipment,  so  the
cumulative carcinogenic impact from air toxics does not exceed the
maximum individual cancer risk limit of ten in one million (1 x 10~
5) .   EPA has determined that this T-BACT rule is applicable for the
Glendale North OU because compounds such as TCE and PCE are present
in groundwater, and release of  these  compounds to the atmosphere
may pose health risks exceeding SCAQMD requirements.
                                34

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     The substantive portions of SCAQMD Regulation XIII, comprising
Rules  1331  through  1313,  on new source review are also ARARs for
the Glendale North OU.

     The SCAQMD also has rules to limit the visible emissions from
a point source  (Rule 401),  which prohibits discharge of material
that  is  odorous or  causes  injury,  nuisance or  annoyance  to the
public (Rule 402), and limits down-wind particulate concentrations
(Rule 403) .  EPA has  determined that these rules are also ARARs for
the Glendale North OU interim remedy.

10.3.2    Water Quality Standards for Reinjection and Discharges of
          Treated Water to Surface Waters or Land

Federal Standards

     The Safe Drinking  Water Act provides Federal authority over
injection wells.  The Federal Underground Injection Control Plan is
codified in Part 144  of 40 C.F.R and prohibits  injection wells such
as those  that would be  located at the Site  from (1)  causing a
violation of primary MCLs  in the receiving waters and (2) adversely
affecting  the  health of  persons.  40 C.F.R. §144.12.   Section
144.13 of the Federal Underground Injection Control Plan provides
that  contaminated ground water  that  has  been  treated may  be
reinjected  into the  formation  from  which it is withdrawn if such
injection is conducted pursuant to a CERCLA cleanup and is approved
by EPA.  40 C.F.R.  §144.13.   These regulations are applicable to
any Glendale North  OU treated water that  is  reinjected into the
Glendale North groundwater.

     The Resource  Conservation and Recovery Act (RCRA) Section 3020
is also an action-specific ARAR.  This section  of  RCRA provides
that the ban on the  disposal of hazardous waste into a formation
which contains an underground source of drinking water (set forth
in  Section 3020(a))   shall  not  apply  to   the  injection  of
contaminated groundwater into the aquifer if: (i)  such injection is
part of  a  response  action  under CERCLA;  (ii)  such  contaminated
groundwater   is  treated   to   substantially   reduce   hazardous
constituents  prior  to  such injection;  and  (iii) such response
action will, upon  completion, be sufficient to  protect human health
and the environment.  RCRA Section 3020(b).

State Standards

     For any  reinjection to  the basin,  including  spreading,  or
discharges  to surface water that occur  on-site, the reinjected or
discharged  water  must  meet all  action-specific ARARs  for such
reinjection or  discharge.  The ARAR  applicable  to the recharged
(Alternative 6) or reinjected  (Alternative 5 or 7) water is:
                                35

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      • ~   The Los Angeles Regional Water Quality Control Board's
           Water Quality  Control  Plan, which  incorporates State
           Water Resources  Control Board  Resolution  Mo.  68-16,
           "Statement  of Policy with Respect  to Maintaining High
           Quality of  Waters  in California.11  Resolution No. 68-16
           requires maintenance of  existing State  water quality
           unless  it is demonstrated that a change will benefit the
           people   of  California,   will  not unreasonably  affect
           present or  potential uses, and will not result in water
           quality less   than  that  prescribed   by   other  State
           policies.

     EPA  anticipates  that there may be short-term discharges of
treated water to the Los Angeles River during the initial operation
of the VOC treatment plant and on  certain other limited occasions.
The ARAR for any treated water that is  discharged, on  a short term
basis, to the Los Angeles  River is the National Pollutant Discharge
Elimination  System (NPDES)  Program  which is implemented  by the
LARWQCB.  In establishing  effluent limitations for such discharges,
the LARWQCB  considers the Water Quality Control Plan  for the Los
Angeles  River  Basin  (the  "Basin  Plan"),  which   incorporates
Resolution 68-16,  and the best available technology  economically
achievable (BAT).  See. Cal. Water Code § 13263.

     Since  the  RWQCB  did  not  identify  specific   substantive
discharge requirements or technology standards for such temporary
discharges, EPA has reviewed the Basin  Plan  and considered BAT and
has made  certain  determinations for  the short-term discharges to
the Los Angeles River.   In  order to comply with this ARAR, any
treated groundwater that will be discharged, on a  short-term basis,
to the Los Angeles River  on-site  must  be treated to meet Federal
MCLs or State MCLs for VOCs, whichever is more stringent.

     The treated water will also contain nitrate.  The Basin Plan
states that the level  of nitrate shall  not exceed 45 mg/1 in water
designated for use as domestic or municipal supply.  According to
the Basin Plan,  the  Los Angeles  River is  not designated for
municipal or domestic water supply.   Therefore, the 45 mg/1 is not
an ARAR for the short-term discharges associated  with  the Glendale
North OU.

     EPA has also considered what  BAT could  be for such short-term
discharges.   For on-site  discharges,  meeting  the  nitrate MCL
through treatment by ion exchange would result in  complex technical
issues, such as disposal of waste brine, and would be  very costly
given the  temporary nature of such discharges. Therefore,  EPA has
not identified  ion exchange as the NPDES  treatment standard for
such short-term discharges.

     EPA also considered the Mineral  Quality Objective for the Los
Angeles River  of 36  mg/1  (8 rog/1 nitrate-N) established  in the
Basin  Plan.    Because the  anticipated average  concentration  of

                               36

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       —-a                      »
 nitrate  in the short-term discharge is likely to be close to the
 MCL,  and any discharge would be short-term, there should not be any
 significant long-term effects on the  mineral  quality of the Los
 Angeles  river associated with short-term discharges of VOC-treated
 water from the  Glendale North  OU.

      It  should also  be  noted that  extractions of  3,000  gpm of
 groundwater per the  Glendale  North OU will result  in decreased
 amounts  of  contaminated groundwater recharging to the Los Angeles
 River, thereby  further protecting its  beneficial uses.

      Again, with respect to VOCs, any on-site discharge  to the Los
 Angeles  River  must  meet Federal MCLs or  State MCLs  for VOCs,
 whichever  is more  stringent.  Since short-term discharges to the
 Los Angeles River would occur on-site,  the procedural requirements
 for Federal National Pollution Discharge Elimination System  (NPDES)
 as implemented in RWQCB Waste Discharge Requirements  (WDRs) issued
 under Section  13263  of  the California  Water  Code would  not be
 ARARs.

 10.3.3 'Secondary Drinking Water Quality Standards

      The State  of California's Secondary Drinking Water Standards
 (SOWS) are ARARs for the  Glendale North OU if the final use option
 involves serving  treated groundwater  as drinking water.  22 CCR
 §64471.  The California SOWS  are selected as  ARARs because they are
promulgated state standards and are relevant and appropriate to the
 action of supplying the treated water to a public water supplier.
Although California  SOWS  are not applicable to non-public water
 system suppliers,  the California  SOWS are relevant and appropriate
 since the  treated  water  under this action would be  put into the
 City's drinking water system action.   Since the Federal SOWS are
not enforceable limits and are intended as guidelines, they are not
ARARs for this action. Furthermore,  since the  State SOWS are more
stringent than the Federal SDWS,  EPA has not selected the Federal
SDV?S as requirements  for this action.  In summary, if the treated
water is  to be served  as drinking water, the  treated water prior at
the point of delivery must meet  the  California SOWS.  See Figure
10-1.  If  the treated water is  reinjected or discharged  to the
river, the water will not be required to meet  State SDWS.

10.3.4 Resource Conservation and Recovery Act (RCRA)  and Hazardous
Solid Waste Amendment (HSWA1 Standards. 42 U.S.C. SS6901-6987.

     RCRA,  passed by Congress in  1976 and amended by the Hazardous
and Solid  Waste Amendments of 1984,  contains  several provisions
that are  ARARs for the Glendale North OU.  The  State of California
has been  authorized to enforce its own  hazardous waste regulations
 (California Hazardous Waste  Control Act) in lieu  of the Federal
RCRA Program administered by  the EPA.   Therefore, State regulations
 in the California  Code  of Regulations  (CCR),  Title  22, Division
4.5, Environmental Health Standards for the management of Hazardous

                               37

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 Wastes  (hereinafter  the  State HWCL Regulations), are now cited as
 ARARs instead  of  the Federal RCRA Regulations.

     Since  the source of the contaminants  in the groundwater is
 unclear,  the contaminated groundwater is not  a  listed RCRA waste.
 However,  the contaminants are sufficiently similar to RCRA wastes
 that  EPA has  determined  that  portions  of  the  State's  HWCL
 Regulations  are  relevant  and  appropriate.    Specifically,  the
 substantive requirements of the following general hazardous waste
 facility  standards  are  relevant  and   appropriate  to  the  VOC
 treatment plant for Alternatives 2 through 7:   Section 66264.14
 (security requirements),  Section 66264.15 (location standards) and
 Section 66264.25  (precipitation standards).

     In  addition,  the  air stripper  would  qualify  as  a  RCRA
 miscellaneous  unit  if  the contaminated  water  constitutes  RCRA
 hazardous  waste.    EPA has  determined  that  the  substantive
 requirements  for  miscellaneous  units  set  forth  in  Sections
 66264.601 - .603 and related substantive closure requirements set
 forth in 66264.111 - .115 are relevant and appropriate for the air
 stripper.  The miscellaneous unit  and related  closure requirements
 are relevant and appropriate because the water is similar to RCRA
 hazardous  waste,  the  air stripper  appears  to  qualify  as  a
 miscellaneous  unit,   and the air stripper  should be  designed,
 operated, maintained  and closed in  a manner that will ensure the
 protection of human health  or the environment.

     The land disposal restrictions (LDR), 22 CCR Section 66268 are
 relevant and appropriate  to discharges of contaminated groundwater
 to land.  The remedial alternatives presented do not include land
 disposal of untreated groundwater.  Because of the uncertainty in
 the levels of contamination  and volumes of water to be derived from
 the development,  purging  and/or  aquifer  testing of  monitoring
 and/or extraction wells at the Glendale North OU,  these waters must
 be treated to meet Federal  and  State MCLs for VOCs,  whichever is
more stringent, prior to discharge to land.

     The  container  storage  requirements  in  22  CCR  Sections
 66264.170 -.178 are  relevant  and appropriate for  the  storage of
 contaminated groundwater over 90 days.

     On-site storage or disposal  of  the  spent carbon from the
treatment system  could  trigger the  State HWCL requirements for
 storage  and  disposal  if  the  spent  carbon  contains  sufficient
quantities of hazardous constituents that cause the spent carbon to
be classified as  a characteristic hazardous waste.   If the spent
 carbon  is determined to be a  hazardous waste under HWCA,  the
requirements for handling such waste set forth in Sections 66262
 and 66268 are applicable.

     Certain other portions of the State's HWCL's regulations are
 considered to be relevant but not  appropriate  to the VOC treatment

                                38

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plant. ""EPA has determined that  the  substantive requirements of
Section   66264.15   (general   inspection  requirements).  Section
66264.15   (personnel  training)  and  Sections  66264.30-66264.56
(Preparedness  and  Prevention and Contingency Plan  and Emergency
Procedures) are relevant but not appropriate requirements for this
treatment  system.   EPA  has  made this  determination  because the
treatment  plant will  be  required  to have health and safety plans
and  operation  and  maintenance  plans  under  CERCLA  that  are
substantively equivalent to the requirements of Sections 66264.15,
66264.30-66264.56.

10.4  Summary of ARARs for the GlendaleJNorth OU Interim Remedy

     EPA has determined a number of  chemical-, and action-specific
ARARs  for the  Glendale North  OU  interim  remedy.    All  of the
alternatives  that  involve groundwater  extraction  and treatment
could achieve  the  chemical-specific treatment  standards  for the
groundwater at the point of delivery (See Figure 10-1).  However,
Alternative 3 which uses perozone is a  less certain technology than
air  stripping  or  liquid-phase  GAC adsorption  for  such  a large
volume of  water and therefore  is  somewhat less  likely to achieve
the chemical-specific ARARs.

11.0  THE  SELECTED REMEDY

     Based upon consideration of  the  requirements of CERCLA, the
detailed analysis of the alternatives,  and public comments, EPA has
determined that Alternative 2:  Extraction,  Treatment of VOCs by
air stripping  (either single- or dual-stage)  or liquid phase GAC,
Blending to meet the  nitrate standard and Conveyance to a public
water distribution system, in combination with Alternative 7  (as a
contingency): Extraction, Treatment of  VOCs,  and Reinjection, is
the most appropriate interim remedy for the Glendale North OU.

     Alternative  2  includes  the  extraction   of   3,000  gpm  of
contaminated groundwater for 12 years.  The extraction wells will
be  new and  will  be  located  to  inhibit most effectively the
migration of the contaminant plume while maximizing  the extraction
of  the most  contaminated groundwater.    The  most contaminated
groundwater  is located in the upper or shallowest  zone  of the
aquifer.  Various locations and scenarios for extraction wells and
rates of extraction are proposed in the  FS report for the Glendale
North OU;  however,  all design decisions  for this  interim remedy
will be made during the remedial design phase. During the remedial
design phase one of the locations proposed for extraction wells and
scenarios  for rates  of  extraction per  individual well  may be
selected or new ones may be selected.

     The  extracted groundwater will  be  filtered   to  remove any
suspended  solids,  if  necessary, and then treated for VOCs using
dual-stage or single-stage  air  stripping  with vapor-phase GAC
adsorption for emissions  control  or liquid  phase GAC may also be

                                39

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 used.   Whether air-stripping  (dual versus single) or  liquid phase
 GAC will  be used will be determined during remedial  design as will
 the exact location for the treatment plant (note that four possible
 locations were proposed in the  FS  report).   If air-stripping is
 used for VOC  treatment,  the  air stream will  be treated using a
 vapor-phase GAC adsorption system to ensure that air emissions meet
 Federal air quality  standards  as regulated by  the South  Coast Air
 Quality Management District and  described in the ARARs section of
 this ROD.

     After  the extracted  groundwater is  treated  for  VOCs,  the
 treated water  exiting the  treatment plant shall  meet  all MCLs and
 secondary drinking water standards with the exception of nitrate.
 The VOC-treated water  will then be blended with water which does
 not contain nitrate in excess of the nitrate MCL to  reduce nitrate
 levels  to meet the nitrate MCL.   The treated and blended water to
 be  delivered to a public drinking water supply shall  meet  all legal
 requirements.   The water  will then be  conveyed to  the City of
 Glendale  and/or another municipality for distribution through the
 public  water supply system.

     As a result  of comments by the  City of Glendale  on  the
 Glendale  North OU Proposed Plan  (July 1992) and  Glendale  South OU
 Proposed  Plan  (September  1992) which  indicated that the City had
 sufficient water credits to accept the treated water  from both of
 these OUs, and in order to decrease overall costs associated with
 the OUs,  EPA  has  determined  that the  treatment plants for  the
 Glendale North and Glendale South OUs will be combined.   The total
 5,000 gpjn of treated water  will be conveyed to the City of Glendale
 for distribution to  its public  water  supply  system.   The exact
 configuration  of the combined  treatment  plant  will be determined
 during  the  remedial  design phase of  the project.   The Glendale
 South OU  Record of Decision will also reflect  this  decision to
 combine the treatment plants.

     However,  if the  City of Glendale does not  agree to accept the
 treated water  from both OUs (possibly due to water supply  needs) or
 if  EPA  determines  that  combining  the  treatment  plants  will
 significantly  delay or hinder  the implementation of the Glendale
North OU, the treatment plants will not be combined.

     EPA  has  selected  Alternative 7,  reinjection of the treated
water,   as a contingency if the  City  of Glendale or another  San
 Fernando Valley water purveyor does not  accept any  or all of the
treated water.  As a result,  any remaining portion of water not
 accepted by the City of Glendale will be:  first, offered to another
 San Fernando Valley water  purveyor or second, reinjected  into the
 aquifer, per Alternative 7.

     With the  exception  of blending to meet the nitrate MCL and
 final use of   the  treated water, Alternative  7 is identical to
Alternative 2  above.

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      After the  extracted  grouhdwater is  treated for  VOCs,  the
 treated water  exiting the treatment plant shall meet all MCLs for
 VOCs  but will not need to meet secondary drinking water standards.
 with  the exception of nitrate.  The VOOtreated water will then be
 reinjected into  the  aquifer.    To  comply  with  ARARs,  nitrate
 concentrations  in the water to  be  reinjected  will  have  to be
 similar to or  lower  than the  levels of nitrate in the area of the
 aquifer where the reinjection will occur.

      Reinjection wells will be new wells and will be located such
 that  the  effectiveness of   inhibition  of  further  downgradient
 groundwater contamination migration  and  contaminant mass removal
 from  the aquifer are optimized,  to the maximum extent practicable.
 Locations  and injection rates for injection wells are proposed in
 the  FS  report  for  the  Glendale  North  OU,  however,  all  design
 decisions  for this interim remedy  will be made during the remedial
 design  phase.    During  the  remedial  .design  phase  one of  the
 locations  proposed  for reinjection wells may be  selected  or new
 ones  may be selected.

      Existing  production wells  that  may provide pathways  for
 vertical   migration   of  contamination  will  be   abandoned  or
 rehabilitated,  if required.   While the Glendale North OU FS report
 proposed several production  wells be abandoned or rehabilitated,
 these are  only proposals.   Again, final  determinations regarding
 which production wells will be abandoned and/or rehabilitated, if
 any, will  be made during remedial design.

     Alternative   7   production   well    abandonment   and/or
 rehabilitation and monitoring well requirements  are identical to
 those discussed above  for Alternative 2.

     Groundwater monitoring wells  shall  be installed  to evaluate
 the effectiveness of the Alternative  7 interim remedial action for
 the Glendale North OU.  More  specifically, groundwater monitoring
 will be conducted no  less frequently than  quarterly to: 1) evaluate
 influent and effluent water  quality,  2) determine and evaluate the
 capture zone of the extraction wells, 3) evaluate the vertical and
 lateral  (including downgradient) migration of contaminants,  4) to
 evaluate the effectiveness of the reinjection well system and its
 impact on the remedy  and 5) to monitor any other factors associated
with  the  effectiveness  of  the  Alternative  7  interim  remedy
 determined to  be  necessary  during  remedial design.    Once  the
 Glendale North  OU remedial action has been operating for six years,
monitoring frequency may  be decreased to  less than  quarterly if
 conditions warrant.

     The VOC  treatment plant of  the Glendale North  OU interim
 remedy  (whether it be Alternative 2, Alternative 7 or a combination
 thereof) shall be designed  and  operated  so  as  to prevent  the
 unknowing  entry, and minimize the possible effect of unauthorized
 entry,  of  persons or  livestock into the  active portion of  the

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 facility.  One means of preventing unauthorized entry would be to
 erect a perimeter fence around the VOC treatment plant.  This fence
 should be  in place prior to initiation of the remedial action and
 should remain in place throughout the duration of the remedy.  The
 VOC treatment plant  shall  also  be designed and operated so as to
 prevent releases of contaminated groundwater from the plant.

     The selected  remedy  for the Glendale North OU meets all of
 EPA's nine evaluation  criteria.  The selected remedy  is equally
 effective as the other  alternatives in the short-term and  long term
 reduction of risk to human health and the environment by removing
 contaminants from  the upper zone of the  aquifer,  by  inhibiting
 further  downgradient and  vertical  migration  of the  contaminant
 plume,  and by  reducing the  toxicity,  mobility,  and volume of
 contaminants in the aquifer.

     The selected remedy is estimated to remove approximately 82%
 (Alternative 2)  to  89%  (Alternative 7)  of the total  estimated
 initial TCE mass after 12 years of extraction, and may reduce the
 maximum  TCE concentration  remaining in  the  upper zone  of  the
 aquifer- by 88% or more.  Thus,  at the end of the 12 year interim
 remedy,  the maximum TCE concentration remaining in the upper zone
 of the  aquifer would  be  approximately 250  ug/1.   The  selected
 remedy is estimated to significantly inhibit downgradient migration
 of contaminated groundwater as well as vertical migration from the
 upper to the lower zone of the aquifer. Vertical migration will be
 further curtailed  with the rehabilitation  and/or  abandonment of
 inactive production  wells  screened  in  both the upper  and lower
 zones.   Furthermore,  the  modeling conducted  as  part  of  the FS
 indicated that the 3000 gpm extraction rate of  the selected remedy
would be  effective in  inhibiting the discharge of contaminated
 groundwater to the Los Angeles River by reducing groundwater levels
to below river bottom elevations.

     The VOC treatment technologies selected (dual- or single-stage
 air stripping  with  vapor   phase  GAC or   liquid  phase  GAC)  are
technically feasible and proven effective at meeting ARARs for VOCs
 in the treated groundwater.

     Alternative 2,  in combination with alternative 7,  could be
 implemented,  both  technically   and administratively.     Other
alternatives which dispose  of  the water by  spreading  at  the
Headworks  Spreading Grounds  may  not be implementable because
Headworks is widely used and may not be available.

     In  a   letter  dated  March  29,  1993,  the State  expressed
agreement with EPA's selected remedy.  EPA  received  several public
comments during the sixty day public comment,  the majority of which
expressed  support  for Alternative  2,  primarily  because  this
alternative  provides  the   treated  water to   a  drinking  water
purveyor.  EPA's preferred alternative.  These comments, along with


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 EPA's "Responses  are  presented  in  Part III  of  this ROD,  the
 Responsiveness Summary.

      The  selected remedy  is  protective  of human  health  and the
 environment, meets ARARs,  and unlike some other alternatives such
 as Alternative 4  which includes discharge of the treated water to
 the Los Angeles River, provides beneficial uses  (distribution to a
 public water supply and/or reinjection) for the treated water.  The
 selected  remedy  is   cost-effective.    The  estimated  cost  of
 Alternative 2 has a total present worth of $36,400,000,  which is in
 the middle of  the range for all seven alternatives and this cost
 would be  significantly reduced by combining the treatment plants
 for the OUs  (based on  a  total cost savings of up to $13.8 million
 for  both  OUs) .   The  estimated  total cost  of Alternative  7  is
 $38,700,000, which is  higher than Alternative 2 but significantly
 less  than Alternative  5,  the most expensive alternative proposed.
 As discussed  in  Section 10  (ARARs),  Alternative 5  exceeds the
 chemical-specific ARARs because it involves treatment of nitrate by
 ion exchange.

 12.0  STATUTORY DETERMINATIONS

      As required under Section 121 of CERCLA, the selected interim
 remedial action is protective of human health and the environment,
 complies  with  Federal  and State  requirements  that  are  legally
 applicable or  relevant  and  appropriate  to the  interim remedial
 action, and  is  cost  effective.   The  selected remedy  utilizes
 permanent solutions and  alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference
 for remedies that employ treatment to  reduce toxicity, mobility,
 and volume as a principal element.

      The selected interim remedial action  is protective of human
health and the environment in that it removes  a significant VOC
 contaminant mass  from the upper zones of the aquifer and inhibits
 further  downgradient  and  vertical  migration  of  contaminated
groundwater.

      The VOC  treatment  technologies selected (dual-  or single-stage
air  stripping  with  vapor phase  GAC  or liquid  phase GAC)  are
technically feasible and proven effective at meeting ARARs for VOCs
in the treated groundwater and the air.

     The selected remedy permanently and  significantly reduces the
toxicity,  mobility,  and  volume  of hazardous  substances  in the
aquifer as well as the extracted groundwater.

     Because  this remedy will  result  in  hazardous  substances
remaining on-site above  health-based levels,  EPA shall conduct a
review, pursuant to CERCLA Section 121, 42 U.S.C. Section 9621, at
 least once every  five years after commencement of remedial action


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 to ensure that the remedy continues to provide adequate protection
 of human health  and  the  environment.

 13.0   DOCUMENTATION  OF SIGNIFICANT  CHANGES

      The only significant change to the Glendale North OU interim
 remedy proposed  in the Proposed Plan  fact  sheet  dated July 1992
 involves the volume of  water to  be  conveyed to  the  City  of
 Glendale.

      As  a result of oral  comments at the Glendlae North OU Proposed
 Plan  public meeting  as  well  as written comments by  the  City of
 Glendale on the  Glendale North OU  Proposed Plan  (July 1992) and
 Glendale South OU Proposed  Plan (September 1992)  which indicated
 that  the City had sufficient  water credits to accept the treated
 water from  both the  Glendale North  and Glendale South OUs, and in
 order to decrease overall costs associated with the OUs,  EPA has
 determined  that  the  treatment plants  for. the Glendale North and
 Glendale South  OUs  will be  combined.   The  total  5,000  gpm of
 treated  water will  be  conveyed  to   the  City  of  Glendale for
 distribution  to  its public  water supply  system.    The  exact
 configuration of  the combined treatment plant will  be determined
 during  the  remedial  design phase  of  the project.   The Glendale
 South OU Record  of  Decision  will  also reflect this  decision to
 combine  the treatment plants.

      However, if the  City of Glendale  does not agree to accept the
 treated water from both OUs  (possibly due to water supply needs) or
 if  EPA  determines  that combining  the  treatment  plants  will
 significantly delay  or hinder the  implementation  of the Glendale
 North OU, the treatment  plants  will not be combined and only the
 extracted treated water from the Glendale North OU will be conveyed
 to the City  of Glendale for distribution to  its public water supply
 system.  As  a further contingency, if the City of Glendale does not
 accept any  or all  of the treated water,  any remaining portion of
water  will  be 1)  offered  to  another San   Fernando Valley water
purveyor or 2)  reinjected/recharged into the aquifer.

     The impact of this change is that an additional 2,000 gpm of
treated water would  be provided to  the City.   In its comments to
EPA on both the  Glendale North and South OU Proposed Plans, the
City  indicated that  it  would be able to   accept the additional
treated  water.     The  cost  of  construction and  operation  and
maintenance of the combined  treatment  plant  is expected to be less
than  the cost  of  construction  and operation and maintenance of
 individual  treatment plants.   Recent  EPA cost estimates indicate
that  as  much as  $13,888,000 would  be  saved on  the  total  present
worth cost  by combining the two treatment plants.
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                PART III.  RESPONSIVENESS SUMMARY

  For Public Comments received during the Public Comment Period
       for the Glendale North Operable Unit Interim Remedy
            at the San Fernando Valley Superfund Site
                  Los Angeles  County/ California


EXECUTIVE SUMMARY

     This Responsiveness Summary addresses comments received from
the public, state agencies, and  local  agencies  on EPA's proposed
interim cleanup plan for the Glendale North OU.  Comments from the
California Environmental  Protection Agency,  Department  of Toxic
Substances Control (DTSC) on the RI report for the Glendale Study
Area, the Glendale North FS Report, and the draft Proposed Plan for
the Glendale North  OU  were received by EPA prior to issuing the
Proposed Plan  and initiating  the public comment  period.   DTSC's
'comments  and  EPA's responses are  available  for review  in the
Administrative  Record   for  the  Glendale  North  OU  and are not
included in this responsiveness summary.

     EPA held a sixty day public comment  period  on the RI and FS
reports, Proposed Plan and other Glendale North OU Administrative
Record documents  between  July 6, 1992 and September  8,  1992.   A
public  meeting   was   held   in   Glendale  on  July   23,   1992.
Approximately 30 representatives  of  the community, state and local
agencies,  and  EPA  attended  the  meeting.    EPA  staff  made  a
presentation on the Glendale North OU alternatives, including EPA's
preferred alternative,  and answered questions.  A transcript of the
meeting  is  included in the  Supplement 1 to the Administrative
Record for the Glendale North OU.

     EPA received comments orally from  three members of the public
during the July 23,  1992 public meeting.  The first commenter was
a representative  of the City of Glendale.   The  City's comments
included a request  for additional  water  (up  to  12,000  gpm) and
their  overall  support  of  EPA's preferred alternative for the
Glendale North OU.  EPA responded to this comment by stating that
the Glendale  North  OU  remedy involves extractions  of  3,000 gpm
only.  However, EPA has since determined  that the Glendale North
and South OUs  will  be combined  and the extracted,  treated water
will be conveyed to the  City of Glendale.  If this  is accomplished,
an  additional  2,000  gpm of  extracted,  treated  water  would be
provided to the City,  for a total of 5,000 gpm.

     The  second commenter  expressed  an  interest  in  seeing EPA
consider selecting Alternative 3  for the Glendale  North OU  interim
remedy.  Similar comments were also made by the City of Glendale.
Alternative  3  involves  treating  VOC  contamination  using  an
innovative  technology  called perozone  (hydrogen peroxide and

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 ozone)-i»  EPA explained that this VOC treatment  is not proven at
 high flow rates (> 3,000 gpm), may  be  substantially more costly
 than  estimated  and is  not effective  at treating  some  of the
 Glendale North OU contaminants (e.g.  carbon tetrachloride).   Since
 the  final use of the  treated water is distribution  to a public
 water  supply  system,   EPA  determined  that  selecting  a proven
 technology   (e.g.,  air  stripping   or   liquid  phase  GAC)  was
 preferable.

     The third commenter expressed concern about using groundwater
 from the lower zone of  the aquifer for blending to meet the nitrate
 MCL.  The State also expressed this same concern to  EPA in writing.
 EPA explained that  it  shares these concerns because this water is
 also likely to  be  contaminated and extracting  it  would likely
 result in vertical migration of both VOC  and nitrate contamination.
 In   addition,    such   extractions   might  interfere   with  the
 effectiveness of the Glendale North OU remedy.

     EPA  also  received nine  letters  containing  comments  from
 interested community members,  the  City of  Glendale, the  California
 Department of Health Services Office of Drinking Water  (ODW), and
 the Los Angeles Region of  the California Regional Water Quality
 Control Board (RWQCB).   A tenth letter was received one day  after
 the close of the public comment period.   The comments included in
 the tenth letter were  similar  to  those  of earlier commenters and
 thus EPA was able to address them.  These letters are included in
 Supplement l of the Glendale North OU Administrative Record.

     One member  of  the public  was concerned that extracting 3000
 gpro of  groundwater over a 12-year period  would result in  subsidence
 and sink  hole  formation.   EPA responded that subsidence is not
 likely  to  occur as a  result  of  Glendale North OU extractions.
 Other commenters  asked that EPA  use the treated  water only for
 reclaimed water purposes and not for drinking water. EPA explained
 that the  treated water will  be  of a  much higher  quality than
 reclaimed water and  will meet all drinking water standards prior to
 final use.

     The City of Glendale's  written  comments were similar to  those
presented orally at the public meeting.

     The RWQCB  expressed  support  for EPA's preferred alternative
 and favors direct use of the treated water to reinjecting it.  EPA
 also prefers direct use of the  treated water but will reinject any
remaining portion if a  water purveyor cannot accept it.  ODW stated
that it considers the  perozone treatment process an experimental
 one and  that it  should not be  used for the Glendale North OU
 interim remedy.   EPA agreed with this  comment.   ODW also stated
 that the City of Glendale must obtain a water supply permit.  EPA
 responded that the City will receive the treated water at the  point
 of delivery and thereafter the water will  need to meet all offsite


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 legal requirements,  including permits for offsite actions, before
 it  is cbnveyed to  the public water distribution system.

     EPA also received numerous comments from ITT General Controls,
 Inc. on several issues relating to the RI  and FS documents and the
 Proposed Plan for  the Glendale  North OU interim remedy.   Most of
 these comments  criticized EPA  for not justifying  its decisions
 including its preferred alternative selection, suggested that EPA
 did not provide the proper supporting documentation and stated that
 the  interim remedy  for Glendale  North  OU did  not demonstrate
 consistency with  a permanent remedy for  the San  Fernando Valley
 sites.   EPA responded that  the  Glendale  North OU  is an interim
 action  and  not  a permanent remedy,  that  the RI/FS  and remedy
 selection were conducted in accordance with the NCP,  applicable EPA
 guidance, that  an entire  Administrative  Record  with supporting
 documentation is available for review at  the San Fernando Valley
 information repositories, and finally that  the Glendale  North OU
 interim  remedy  would  not  be   inconsistent with  nor  preclude
 implementation of  any final remedy  for the San  Fernando Valley
 sites.

     The Responsiveness Summary is divided into two  parts.  Part I
 focuses on EPA's  responses  to the concerns and major issues raised
 by members of the  local community including the City of Glendale.
Part II includes detailed responses to the comments received that
were more legal  or  technical in nature.    Comments submitted by
State agencies are included in Part II.
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