PB94-964512
EPA/ROD/R09-94/114
July 1994
EPA Superfund
Record of Decision:
Waste Disposal, Inc. Site,
Santa Fe Springs, CA,
12/27/1993
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WASTE DISPOSAL, INC.
SOIL AND SUBSURFACE GAS OPERABLE UNIT
RECORD OF DECISION
Waste Disposal, Inc. Superfund Site
Santa Fe Springs, California
United States Environmental Protection Agency
Region 9 - San Francisco, California
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TABLE OF CONTENTS
Record of Decision for Waste Disposal, Inc. Superfund Site
Santa Fe Springs, California
Part I Declaration
1.0 Site Name and Location. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-1
2.0 Statement and Basis of Purpose. . . . . . . . . . . . . . . . . . . . . .. 1-1
3.0 Assessment of Site. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
4.0 Description of the Selected Remedy. . . . . . . . . . . . . . . . . . . .. 1-1
5.0 Statutory Determinations. . . . . . . . . . . . . . . . . . . . . . . . . . .. 1-2
Part II Decision Summary
1.0 Site Name, Location, and Description. . . . . . . . . . . . . . . . . . . . . 2-1
2.0 Site History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
3.0 Enforcement Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
4.0 Highlights of Community Participation. . . . . . . . . . . . . . . . . . . . 2-4
5.0 Scope and Role of Operable Unit. . . . . . . . . . . . . . . . . . . . . . . . 2-5
6.0 Summary of Site Characteristics. . . . . . . . . . . . . . . . . . . . . . . . 2-5
7.0 Summary of Site Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6
8.0 Description of Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7
8.1 Alternative 1: No Action. . . . . . . . . . . . . . . . . . . . . . . . . 2-7
8.2 Alternative 2: Fencing, Revegetation, and Institutional
Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7
8.3 Alternative 3: Containment.. . . . . . . . . . . . . . . . . . . . . . 2-9
8.3.1 Option A: Multi-Layered Soil Cover. . . . . . . . . . . 2-10
8.3.2 Option B: Asphalt Cap without Excavation. . . . . 2-10
8.3.3 Option C: RCRA-equivalent Asphalt Cap with
Limited Excavation. . . . . . . . . . . . . . . . . . . . . . 2-10
8.3.4 Option D: Multi-Layered Hazardous Waste Final
Cover. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12
8.4 Alternative 4: Excavation and Off-site Disposal. . . . . . . . 2-12
9.0 Summary of Comparative Analysis of Alternatives. . . . . . . . . . . . 2-13
10.0 The Selected Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17
10.1 Clean-up Standards. . . . . . . . . . . . . . . . . . . . . . . . . . 2-19
10.2 Limited Excavation and Consolidation. . . . . . . . . . . . . . 2-20
10.3 Passive Venting System. . . . . . . . . . . . . . . . . . . . . . . 2-21
10.4 RCRA-equivalent Impermeable Cap. . . . . . . . . . . . . . . . 2-21
10.5 Gas Monitoring, and Active Gas Extraction and Treatment 2-21
10.6 Institutional Controls. . . . . . . . . . . . . . . . . . . . . . . . . . 2-22
10.7 Annual Inspection. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23
10.8 Cost. . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . 2-23
10.9 Design Options. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23
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Table 01 Contents
(continued)
11.0 Statutory Determinations. . . . . . . . . . . . . '. . . . . . . . . . . . . . 2-24
11 .1 Protection of Human Health and the Environment. . . . . . 2-25
11.2 Compliance with Applicable or Relevant and Appropriate
Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-25
11.3 Cost Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . 2-26
11.4 Use 01 Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable. . . . . . 2-26
11.5 Preference for Treatment as a Principal Element. . . . . . . 2-27
12.0 Documentation of Significant Changes. . . . . . . . . . . . . . . . . . 2-27
Part 811 Responsiveness Summary
1.0 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
2.0 Summary of Responses to Major Issues and Concerns. . . . . . . . . 3-2
2.1 Health Concerns and Site Risks. . . . . . . . . . . . . . . . . . . . 3-2
2.2 Aesthetics and Future Land Use. . . . . . . . . . . . . . . . . . . 3-3
2.3 Effectiveness of Remedy. . . . . . . . . . . . . . . . . . . . . . . . . 3-4
3.0 Detailed Response to Comments. . . . . . . . . . . . . . . . . . . . . . . . 3-4
3.1 Comments from Ernest Brown & Company. . . . . . . . . . . . . 3-4
3.2 Department of Toxic Substances Control, Comments to the
Feasibility Study Report for Soils and Subsurface Gas. . . . 3-7
3.3 Water Replenishment District of Southern California. . . . . . 3-9
3.4 Department of Toxic Substances Control Comments to
WDI Proposed Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11
3.5 Bear, Kotob, Ruby & Gross, on behalf of Dr. Adeline
Bennett. . " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 2
3.6 State 01 California Department of Health Services. . . . . . . 3-13
3.7 City of Santa Fe Springs. . . . . . . . . . . . . . . . . . . . . . . . 3-1 5
3.8 Albert L. Sharp, Mayor Pro Tern, City of Santa Fe Springs. 3-19
3.9 Phil Campbell. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20
4.0 Public Meeting Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20
Attachment A
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PART I DECLARATION FOR THE RECORD OF DECISION
1.0 Site Name and LocatJon
Waste Disposal, Incorporated (CERCLIS ID #CAD980884357)
Los Nietos Road at Greenleaf Avenue.
Santa Fe Springs, California
2.0 Statement of Be8ia and Purpose
This decision document presents the selected remedial action for the Waste
Disposal, Inc. site in Santa Fe Springs, California, which was chosen in accordance
with CERCLA, as amended by SARA, and, to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan. This decision is based
on the Administrative Record for this site.
The State of California agrees with the selected remedy.
3.0 Assessment of the Site
....
Actual or threatened releases of hazardous subst:inC3S from the site, if not
addressed by implementing the response action seler-ted !n this ~ecord of Decision,
may present an imminent and substantial endangerment to public health, welfare,
or the environment.
4.0 Description of the Remedy
This operable unit is the first of two planned operable units for the site. An
operable unit is a discrete portion of a response action under CERCLA. The first
operable unit addresses contaminated soil and subsurface gases. This action
addresses the principal threat at the site, which is exposure to contaminated soil,
through containment and institutional contr::>ls.
The major components of the selected remedy incltiJe:
. Consolidation of contaminated soil beneath a rT'Iultiiayered, RCRA-
equivalent cap
. Capping approximately 17 acres of the 43-acre site with above mentioned
cap (approximately 75% asphalt, 25% vegetation top cover);
. Extraction and treatment by flaring of subsurface gases, if necessary;
. Institutional controls that restrict future use of properties with residual
contamination that pose an exposure risk; and
. Groundwater monitoring.
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. 5.0 Statutory Determinations
\
\
The selected remedy is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. This remedy uses
permanent solutions and alternative treatment (or resource recovery) technologies
to the maximum extent practicable for this site. However, because treatment 01
the principal threat of the site was not found to be practicable, this remedy does
not satisfy the statutory preference for treatment as a principal element. Because
this remedy will result in hazardous substances remaining on-site above health-
based levels, a review will be conducted. within five years after commencement of
the remedial 8ction to ensure that the remedy continues to provide adequate
protection 01 human health and the environment.
....
This ROD will be followed by another operable unit ROD which will address'
groundwater and the final remediation of the Site. .
. "~
....
~fY/.Lfr
Deputy Regional Administrator
United States Environmental Protection Agency
Region IX
Iz-*f3
Date
1-2
,
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PART II DECISION SUMMARY
1.0 Site Name, Location, and Description
The Waste Disposal, Inc. (WDn Superfund site is located in the city of Santa Fe
Springs, Los Angeles County, California, on a 43-acre parcel of land. The facility is
bordered on the northwest by Santa Fe Springs Road, on the northeast by Fedco
Food Distribution Center (Fedco) and St. Paul High School, on the southwest by
Lost Nietos Road, and on the southeast by Greenleaf Avenue (see Figure 1).
Residences are located across from the facility on Greenleaf Avenue. The
remaining areas on and across Los Nietos Road and Santa Fe Springs Road are
occupied by industrial complexes.
2.0 Site History
'.
The WDI site contains a 42 million gallon capacity concrete reservoir originally
constructed for crude petroleum storage. The reservoir was decommissioned in the
late 1920s for product storage, and was subsequently used for disposing of a
variety of industrial wastes. Aerial investigations, records searches and previous
site sampling indicate the surrounding grounds also were used as unlined sumps for
disposal. Disposal activities continued unregulated until 1949, and thereafter under
permit from Los Angeles County, until closure in 1964. Documentation on disposal
was sporadic, but investigations have shown that drilling muds, sludges, tank
bottoms, various industrial wastes, and construction debris and other solid wastes
were disposed at WDI.
WDI stopped accepting wastes in 1964, bringing in fill and covering the site,
including the reservoir. Across most of the site, between 5-1 5 feet of clean fill,
cover the contaminated soil. However, several areas have contaminated surface
soil (within the first five feet). Since 1966, when grading was completed, the site
has been divided into multiple lots, and various businesses have developed on the
site (see Figure 2). The area over the reservoir, however, is vacant, except for one
small portion covered with an asphalt parking lot used for recreational vehicle
storage.
3.0 Enforcement Activities
The site was placed on the National Priorities List (NPL) in July of 1987. After the
site was listed, EPA sent General Notice Letters to 28 Potentially Responsible
Parties (PRPs). The list included current and former property owners, generators,
and transporters identified during the PRP Search. At that time, no party came
forward with a good faith offer to conduct the Remedial Investigation (RI), so EPA
began the RI. In 1988, EPA undertook a removal action, erecting a fence around
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Figure 1 Site Location Map
SCALE
~1.:;-J2 mi,..J
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lit
OC U)
n
PAPPB ftRSTT
ANN STREET
FEDCO
FOOD
DISTRIBUTION
CENTER
via
ST-PAUL
HIGH SCHOOL
SCHOOL
ATHLETIC
FIELDS
SCHOOL
PARKING
REIS STREET
ui
RESIDENCES
BARTON STFtRET
RESIDENCES
LOS NIETO$ AOAD
Figure 2 Facility Plan
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one corner of the site to improve site security and prevent accidental exposure to
surface contamination.
EPA completed the RI in November 1990, and initiated a Feasibility Study (FS).
The State of California expressed reservations about the groundwater data, and
suggested that EPA conduct further sampling. In January 1992, EPA began three
Quarters of groundwater monitoring, culminating in the January 1993 Groundwater
Sampling Report. However, the data did not conclusively identify a source for
groundwater contamination on site, and EPA decided to divide the site into two
operable units so that more information could be collected for groundwater without
delaying the decision for the remaining contaminated media. In August 1993, EPA
completed the FS for contaminated soils and subsurface gases.
4.0 Highlights of Community Participation
EPA released the Proposed Plan for Contaminated Soil and Subsurface Gases to the
public on August 12, 1993, at the same time making the Administrative Record
available in the information repository maintained at the Santa Fe Springs City
Library. EPA also mailed the Proposed Plan to interested individuals on the mailing
list.
A public comment period was held from August 12, 1993 through October 31 ,
1993. This comment period included two extensions, one requested by the City of
Santa Fe Springs and the second requested by a PRP. During the public comment
period, EPA conducted a public meeting, held September 1, 1993 in Santa Fe
Springs. At this meeting, representatives from EPA presented the Proposed Plan,
answered questions about the site and the remedial alternatives under
consideration, and accepted comments from the public. The notice of availability
of the RI reports, FS, Proposed Plan, and the rest 01 the administrative record, the
start 01 the comment period and the scheduled Public Meeting was published in
both the Los Angeles Times (Southeast Section Edition) and the Whittier Daily
News on August 12, 1993. EPA also published two additional notices in these
papers announcing the extensions to the public comment period on September 23,
1993 and October 22, 1993.
In addition to the official Proposed Plan public meeting mentioned above, EPA
presented its Proposed Plan to the Santa Fe Springs City Council on August 26,
1993 and the City Planning and Development Office on September 9, 1993. EPA
also conducted an informative meeting for the parents of St. Paul High School,
which is located adjacent to the site, on September 9, 1993.
During its meetings with the community, EPA heard from some members of the
community that they felt overwhelmed by the Superfund process, and that without
more time to think and study the information provided, they would not be able to
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adequately understand the issues and provide their comments. EPA commined to
more community involvement during the design process, so the community would
have several more opportunities to provide input and make their feelings known.
This open design process will require more public meetings than generally required
during the design phase, but will ultimately lead to a remedy design that
incorporates more input from both the public and the involved regulatory agencies
that should be more acceptable to all concerned parties.
More of the community's concerns can be found in the transcript of the public
meeting. EPA's responses can be found in the Responsiveness Summary, Part III
of this ROD.
5.0 Scope and Role of Operable Unit
As with many Superfund sites, the contamination at the WDI site cover several
environmental media, and each must be addressed in order to reduce the risks
posed by the site. The work at WDI has been divided into two operable units
(OUs). These are: .
. OU One - Contaminated Soils and Subsurface Gas
. OU Two - Contamination in the Groundwater
The first OU is the subject of this ROD. More data will be collected before a
decision will be made concerning contaminated groundwater found beneath the
site.
6.0 Summary of Site Characteristics
Because the RI conducted by EPA is the most recent and extensive investigation to
date, the site characteristics are based primarily on its findings. The Final Remedial
Investigation Report of November 1989 (Ebasco), as well as the media-specific
reports (available in the Administrative Record), should be referred to for a detailed
description and analysis of contaminants found at the site.
The contamination present on-site at WDI exists in the soil and groundwater
matrices, and in the form of subsurface gases. Present in on-site soils are large
amounts of oil well drilling muds and sludges and waste products, metals, low
concentrations of volatile organic compounds and semivolatile organic compounds,
low concentrations of pesticides and PCBs, and lead. Methane is the most
prevalent subsurface gas, with the highest concentrations in the reservoir area.
Volatile organic compounds also were detected in the subsurface gas.
Groundwater samples contained several metals in concentrations above MCLs, as
well as volatile organic compounds. Because this ROD only covers soils and
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subsurface gases, this document does not discuss groundwater characteristics in
further detail.
The remedial investigation generated a large quantity of data, which can be found
in the Final RI Report. Samples were taken at St. Paul High School to establish
background levels. Background levels for the area established in the US Geologic
Survey (USGS) Professional Paper 1270, Element Concentrations in Soils and Other
Surficial Materials of the Conterminous United States, have also been taken into
account. The primary contaminants in soils at WDI are the drilling muds and oil-
field wastes appearing as black oily material or tar-like sludge. The constituents of
these wastes (in levels greater than those detected in the background) include:
. Metals - arsenic, beryllium, thallium, and lead
. Volatile Organic Compounds - toluene, methylene chloride, acetone,
ethyl benzene, 2-butanone, and xylene
. Semivolatile Organic Compounds - benzo(a)pyrene, 2-chlorophenol,
naphthalene, 2-methylnaphthalene, 4-nitrophenol, phenanthrene,
chrysene, 1,4-dichlorobenzene, benzo(a)anthracene, anthracene,
pyrene, phenanthrene, pentachlorophenol, and fluorene
. Pesticides - DDD, DDE, DDT, alpha- and gamma-chlordane, and dieldrin in
surface soils
. PCBs in the surface soils
In the twenty six soil vapor monitoring wells, sampling revealed ten gases present
in the subsurface. These gases were methane, benzene, 1, 1 ,1-trichloroethane,
1,2-dibromoethane, 1,2-dicloroethane, carbon tetrachloride, chloroform,
tetrachloroethane, trichloroethene, and vinyl chloride.
There are also barrels containing investigation derived wastes (mainly soils from the
installation of wells). and barrels containing various debris and wastes from
previous industrial activities. All of these will be addressed through this ROD.
7.0 Summary of Site Risks
The information on site risks is taken from the Final Endangerment Assessment of
November 1989, with additional information provided in the Feasibility Study of
August, 1993. These documents should be consulted if greater detail is needed.
Under current site conditions, possible exposure pathways consist of direct contact
with contaminated surface soils and inhalation of airborne particulates and volatiles
by students and nearby residents. The average risks, both cancer and non-cancer,
are based on the average contaminant concentration for the site and a typical
exposure scenario. The maximum risks are based on the highest concentrations
observed at the site for each contaminant combined into one "composite sample"
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that represents the source of contamination and the maximum plausible exposure
scenario (even if the chance for exposure to the highest level of contamination is
very small). The future risk scenario assumes an exposure to residents with homes
built on the site, and no protective measures taken. This provides the maximum
exposure scenario for which protective actions can be taken.
For the WDI site, the highest risks are posed by arsenic, thallium, benzene,
pesticides, PCBs, and vinyl chloride. These risks for current exposure scenarios are
almost within what EPA considers acceptable without any remedia,l action, but can
pose an elevated threat to future users of the site. Arsenic presents the highest
threat at the site, but is 8150 found in background soils in the Santa Fe Springs
area. The background levels, recognized by the US Geologic Survey as averaging
6.5 mg/kg and found in the background samples at 2.3 mg/kg, are within the EPA
acceptable risk range for residential exposure. Some on-site samples, however,
detected arsenic at significantly higher levels than background.
8.0 Description of Alternatives
The alternatives summarized here were presented in the Proposed Plan. A detailed
evaluation of all the alternatives is presented in the Feasibility Study (FS) Report for
Soils and Subsurface Gas dated August 2, 1993. (The FS, Proposed Plan, and the
rest of the Administrative Record can be found at the Santa Fe Springs City Library
on Telegraph Road.) Several alternatives were screened out prior to the nine-
criteria analysis used to evaluate the alternatives presented in the Proposed Plan,
including complete excavation and off-site disposal 01 contaminated soils, and on-
and off-site incineration.
8.1 Alternative 1: No Action
The No Action alternative, required by the National Oil and Hazardous Substances.
Pollution Contingency Plan (NCP) (40 CFR 300.430(e)(6», provides, among other
things, an analysis 01 the risk posed by the facility if no remedial action is
conducted. Therefore, it is used as a baseline alternative against which other
alternatives are measured. With this alternative, there would be no reduction 01
toxicity, volume or mobility of the contaminants. The only actions that would take'
place would be.re-seeding of any areas where vegetation was disturbed by on-site
activities during the investigation, periodic monitoring required by CERCLA
(because wastes will be left on-site), and five year reviews to evaluate site
conditions over time.
8.2 Alternative 2: Fencing, Revegetation, and Institutional Controls
Site access would be restricted under this alternative. The site would be fenced
to prevent direct contact with the contamination exposed at the site. The
2-7
-------
perimeter fence along Greenleaf Avenue and St. Paul's High School would be
augmented to a minimum height of seven feet and topped with barbed wire and
razor ribbon to prevent access by trespassers. The rest of the perimeter fence
would be inspected and repaired where necessary. Figure 3 shows the proposed
fencing diagram for this alternative. Areas disturbed during the remedial
investigation would be revegetated.
o
X
STEBOUNDRY
FENCE
RESTPOED AREA
Figure 3 Fencing Diagram
2-8
-------
Institutional controls would be implemented to restrict land use. The purpose of
these controls would be .to prevent exposure to contaminated media, and would
include placing a notice on the deed, preventing the use 01 the groundwater
beneath the site, preventing development on parcels within the site boundary that
could cause exposure to contamination, and restrictions on the use of the fenced
parcels. While the property owners would have some discretion to propose future
uses, the institutional controls will ensure that any future use is protective of
human health.
Because wastes would remain on-site, annual monitoring along with a series of
five-year reviews to evaluate changes in site conditions would be required for this
alternative. Annual monitoring would include soil, subsurface gas, and
groundwater media. The barrels of waste material currently on the property would
be properly disposed off-site.
8.3 Alternative 3: Containment
There are four options to this alternative, all of which entail some type of cap over
the contaminated areas. Excavation is included for some 01 the options of this
alternative. Excavated materials would be consolidated under the cap. Option A is
a multi-layer soil cap, Option B is an asphalt cap, Option C is a RCRA-eQuivalent
asphalt cap, and Option D is an impermeable hazardous waste RCRA cap. The
goal of this alternative is to prevent exposure to contamination, so land use
decisions would take exposure scenarios into consideration.
land use restrictions would be implemented to prevent activities that might breach
or damage the cap. Restrictions also would be implemented to prevent the use of
the groundwater in the shallow aquifer underneath the site, and to restrict use of
properties with residual contamination so that potential contact with contamination
beneath the properties is prevented.
The containment options might also require a landfill gas venting and treatment
system, since the gases would no longer be able to slowly permeate the existing
soil cap and release to the atmosphere. With a cap in place, the landfill gases
generated might migrate laterally from under the cap and infiltrate surrounding
buildings. More testing and sampling would be done to determine the volume and
extent of gas generation, but a venting remedy is likely to be necessary. To
prevent migration of landfill gases, a combination of passive and active venting
would be installed. Passive venting consists of perforated plastic tubing which
provides gases a means of transport to the surface for treatment. The active
portion of the system consists of a blower which would pull gases to the surface
through the vapor wells installed in the reservoir. The treatment would be simple
flaring of the gases, with any condensation generated from this process being
contained and disposed off-site.
2-9
-------
Because the wastes would remain on-site for all options under this alternative,
5-year reviews would be required. The annual monitoring strategy for all the
options of this alternative would include cap stability evaluations, in addition to
monitoring groundwater and subsurface gas contaminant levels over time.
8.3.1 Ootion A: Multi-Lavered Soil Cover
This option involves the installation of a multi-layered soil cap over all accessible
waste handling areas and the reservoir. The lower layer would be a compact clay
layer having a low permeability. The upper layer would be topsoil and vegetation.
Option A provides erosion and moisture control and controls off-site migration of
contaminated dust. The cap would cover approximately 860,000 square feet
(approximation based on aerial photographs). This area corresponds to Areas 3, 4, .
6, 7, and most of Area 2. (See Figure 4 for the cap area.) The barrels of soil from
the remedial investigation (soils from the well drilling) would be consolidated under
the cap. The remaining barrels of waste materials would be disposed off-site. The
entire site, with the exception of the businesses presently operating, would be
fenced and posted.
8.3.2 Ootion B: Asohalt Cao without Excavation
This option would place a six-inch asphalt cap (four inches of gravel overlain by
two inches of asphalt) over any exposed soil areas of the site. This would provide
an additional physical barrier between the contaminated soils and the surface
population. Like Option A, no excavation of contaminated material would be done
on the site. The only earth moving work would be consolidating the barreled
investigation derived wastes (lDW) under the cap, and perhaps some addition of
soil to even up site grade for installation of the asphalt cap. The asphalt would
cover approximately 860,000 ft2, the same area as Option A.
8.3.3 Ootion C: RCRA-eauivalent Asohalt Cao with Limited Excavationn
The cap material for this option itself is similar to Option B, but this option would
cover a smaller area of the site because the limited excavation would consolidate
the contaminated material under a smaller space. The intent of the excavation is to
remove the contaminated soils found in the sumps and other areas to the
background (or a 1 0~6 excess cancer risk) level for the contaminants of concern,
and consolidate them under the cap so that some parcels on the property can be
free from some of the institutional controls. An additional Flexible Membrane Liner
(FML) would also be added underneath the asphalt cap to reduce the possibility of
rainwater infiltration. With the membrane liner and gas remedy system, this cap
would meet the substantive requirement of the more extensive RCRA cap described
as Option 4. The estimated area covered by this option is 750,000 ft2. Figure 5
presents the area to be capped and the areas to be excavated.
2-10 .
-------
,
Figure 4 Area to be Capped for Alternatives 3A and 38
, .
CJ..,,:,,:;./~
~
x'
.>s.m,;
Figure 5 Areas to be Excavated and Capped for Alternatives 3C and 3D
2-11
~ capped
~excavated
-------
8.3.4 Oction D: Multi-Lavered Hazardous Waste Final Cover
For Alternative 3, Option D, it multi-layered cap meeting the requirements for
surface impoundment/landfill closure, as defined in 40 CFR 264.221 and 264.228,
would be installed. The cap would cover approximately 750,000 square feet, the
same area as that of Option C, shown in Figure 5. Limited excavation would be
done to consolidate contamination not currently contained and proteCted by asphalt
or structures. This alternative would provide erosion and moisture control and
prohibit upward vertical migration of contaminants (liquid, solid, gas/vapor) through
a series of low permeability layers and synthetic liners. Figure 6 shows a
schematic of a full .RCRA cap structure.
CObbIeS/IOO{ ~ . ---~:,..~. -
top layer . ~ ~-- -- 60 em
. biotic barrier -. ~ -.- . . - geosynthetlc filter
(cobbles) 30 em
drainage layer '.:., :;:. :..':' .:. . . ','.. - geosynthetlc mter
.... ...... ..... . .. 30 em
low-permeabDlty.{ .....:., "".'...' B - 4iIi8- 2o-mD FMl
FML/soU layer - - 60 em .
gas vent layer 30 em geosynthetlc filter
wast.
o coo 0 0
00 I\) C:>0~
o~ooo 1\)0
c ~ I\) 0
Q 0 ~ 0 0 000 0
Figure 6 Cross-section Schematic of a Full-RCRA Cap
8.4 Alternative 4: Excavation and Off-site Disposal
This alternative would excavate contaminated material and dispose of it at an off-
site facility permitted to accept such wastes, In the FS, two options to this
alternative were presented: (A) excavation of only the areas described in the
Alternative 3 options, with subsequent fencing and institutional controls of the
reservoir area, and (8) complete excavation of all contaminated soils at the site,
2-12
-------
including the reservoir and Area 2,. The option for complete excavation was
discarded due to the very high cost, increased short term risks, and the small
increase in long term effectiveness versus the other alternatives.
The alternative presented in the Proposed Plan was Option A, limited excavation
(as explained for Alternatives 3C and 3D), off-site disposal, fencing of the
remainder of the property, and institutional controls.
9.0 Summary of Comparative Analysis of Alternatives
The NCP sets forth nine criteria to be used for a detailed, comparative analysis of
alternatives that have been retained after the screening portion of the Feasibility
Study. The nine criteria are as follows:
. Compliance with ARARs
. Overall protection of human health and the environment
. Long-term effectiveness and permanence
. Reduction of toxicity, mobility, or volume through treatment
. Short-term effectiveness
. Implementability
. Cost
. State acceptance
. Community acceptance
A detailed analysis was presented in the Feasibility Study, while a summary was in
the Proposed Plan, not including an evaluation of State and Community
acceptance. The comment period on the Proposed Plan provided this information,
which is included in Table 1. For a more detailed evaluation of the alternatives and
the nine criteria, please refer to Chapter 5 of the Feasibility Study of August 2,
1993.
2-13
-------
...."
Criteria
Overall
Protectiveness
Aid
No Action
No, however
risk levels are
within, or only
slightly above,
levels EPA
considers
acceptable
.". ,,'.. ,. ." ".".""".. '~'. >':':"'.':"::<:":"'/' i...::,(.c- ,...:. ,~
T8bltt.,:,~.. Comp'rIS9H~t~:~......,"".Ya~>"
.. ,- . .... ..'
. . ,",'" '.",' ...,. ..... .
Alf2 . ,.:A!f3A "\, Alt 3if" .."
. Fenclno. Multl~ayer Solil\ipt18ItC~p ".
Revegetation, . . . Cap" . without
. 8nd EXC8V8tl~~/
Instltutlon81 .. . . "
Controls
No, however
risk levels are
within, or only
slightly above,
levels EPA
considers
acceptable
"".
Moderate,
depending on
maintenance of
the cap.
Moderate,
depending on
maintenance of
the cap.
ARAR Compliance No, does not No, does not No, since No, since
meet landfill meet landfill permeability permeability
closure closure may not meet may not meet
requirements requirements landfill closure landfill closure
requirements requirements
long-term No, since No, since Yes, so long as Yes, so long as
Effectiveness wastes will be wastes will be cap Integrity Is cap integrity Is
left on-site, left on-site, maintained to maintained to
with no with no prevent prevent
effective effective exposure to exposure to
control to control to contamination contamination
prevent prevent contact
contact with with
contamination contamination
Implementabillty
Yes
Yes
Yes
Yes
Yes
Yes
Yes, integrity
of cap more
easily
maintained
than 3A, 38 to
prevent
exposure to
contamination
Yes
. ...
........ .
. ..
;.:.:.;.:.:.;.
....
... .
.......
','.'.','.'.'.".'
Yes
Yes
Yes, Integrity
of cap is more
assured
because of
multiple layers,
therefore
preventing
exposure to
contamination
Yes
. ,"., ".' ..,' ..,.".'.'
.;:;'.;.;
"
Moderate,
since surface
contamination
removed and
current risk
levels are
within, or only
slightly above,
levels EPA
considers
acceptable
No
No, since
wastes will be
left on-site,
with no
effective
control to
prevent
contact with
contamination
Moderate.
Transporting
soil may be
difficult.
-------
. .
. ,"
."
Criteria
.. ..
Short-term
Effectiveness
Reduction of
Toxicity, Mobility or
Volume through'
Treatment
Cost
~
...
Alt 1
No Action
.,
Yes
No
$427,000
Table 1, Comparison. o~ Alterniithies,: . . " .',',.. .. .".:;~
, .. . .. ,. .. ';:;,;",":' Aii' :3~~::,:;";;;;:;':"::';::,:";;':.'Ait"4~':;:i}"::;:
:t),q=~@'; , F~I RCRA Ca~ . lhlilted
. ,'. A8Phel~ Clip ,.~:!.i,::'.i,,:;,:.::~.~,:E,...,.:~:....;;...;:.,.:.'.'::,:l:v,.;:.:,:~.;:.m;:.;,;:.:.:;,..::,i;kJri,"....;!..,-.;,:,:,:...I,!.i:;:..:. !.1,...;:.,M...:,:,::;d::,',~:'.P,v:',:.e.:~;;.:,',~....:'...!",'...:.:,
"-".,..:,,..;.~..E':,;:.i~.".~~.t.'.~,o~.'.~..;.:.:;.":;.:;.';.. ...".:'f:".,::,." "':;:':':"':"':;'::;'" ,.:::::::;.,..:.,:::,::":".:,:;:",:.:,:.,:,,:,;',.,,,.:'.,:,','':.''
,",",",',',',",,','.',-,",.','.',',",'.',',','...'.'.,',',',',',",',",' -"",-"",",""" """ ".....-...
..
Alt2
.. Fencln~, .
Reveget.tlo,'h
end
histltutlonel
. .Controls ',;.
...
Yes
No
$457,000
" Alt 3A;.,;..
Multl-Ieyer Son
. Cep '.
....
......
Yes
Though there
would be no
treatment of
contaminated
soils, there
would be some
reduction of
mobility due to
decrease in
rainwater
infiltration.
Flaring system
would reduce
volume and
mobility of
subsurface
gases through
treatment.
$2,095,500
, ..
::AIt'3it
.. AjphiM Cip"
, 'without '.
Excavetloij
.,1;"::(';"
,'.
Yes
Though there
would be no
treatment of
contaminated
soils, there
would be some
reduction of
mobility due to
decrease in
rainwater
infiltration.
Flaring system
would reduce
volume and
mobility of
subsurface
gases through
treatment.
$3,259,500
Slight Increase
In short-term
risk due to
excavation.
Precautions
would be
taken to
mitigate risks.
Though there
would be no
treatment of
contaminated
soils, there
would be some
reduction of
mobility due to
decrease in
rainwater
infiltration.
Flaring system
would reduce
volume and
mobility of
subsurface
gases through
treatment.
$5,514,700
Slight increase
In short-term
risk due to
excavation.
Precautions
would be taken
to mitigate
risks.
Though there
would be no
treatment of
contaminated
soils, there
would be some
reduction of
mobility due to
decrease in
rainwater
infiltration.
Flaring system
would reduce
volume and
mobility of
subsurface
gases through
treatment.
$12,824,700
Slight Increase
in short-term
risk due to
excavation.
Precautions
would be
taken to
mitigate risks.
No treatment
to reduce
TMV, but
would reduce
on-site volume
by excavation
and off-site
disposal.
$12,937,700
-------
........ ."..:....,:
...::. .'.">. c~j.t.tlil.
i,.' <.
. .....::....
State Acceptance
Community
Acceptance
Alt 1
No Action
..
The State
indicated that
it would not
support a
decision of No
Action.
The
community has
expressed no
interest In a
no-action
remedy
selection.
.. Table 1Comp~fij~~~!AI~ir~'t'v~~,
Alt2
. Fencing,.
Revegetation,
and
Institutional
Controls
The State has
indicated that it
would not
support a
decision where
no physical
measures were
taken to reduce
risks.
The community
has expressed
its interest in
having the
contamination
removed, and
would not
support only
administrative
approaches.
Alt3A
Multl-tayer Soli.
.Cap . .
_,n, 'n-
The State has
expressed its
support for
permanent
containment
remedy, but
would require
more than only
a soil cap.
The community
generally
supported this
option, since it
would be
aesthetically
pleasing. Had
reservations
with all
containment
options
concerning
protectiveness,
since
contamination
remains.
....... n'
n .................
..... ......
.".........,. ..O'.
. . . . . .. ... ." ...
:..,::.......'.~gm:.........".,..,
.iquwalrit~(,
..'. Asphalt Cei)(
:.:w~ lImlt~?\
:~....:.:...:)::.::::::i:... :,.):...~~9~~'9rl..\:..
. ...
.." "'.', ",. ,",'
. ..... ..
..Alf3if .......
. A.phiilt~~~......
.."wlthout. .
Excavatloff
...
. ...
.. ..
The State has
express Its
support for a
permanent
containment
remedy, and
an asphalt
cover would
meet most of
their
requirements.
The
community
was somewhat
supportive of
this option, but
had concerns
with final
appearance
and overall
protectiveness
and long term
safety of any
containment
option.
..
H"'"
.......
.........
'.':':'.':'
. . . . . . . . . . . .
.. ..
..'.",",".'.","."',"
. , ..
. . -......
'.',",' ",''''''',',
. . . .. ...........
. .' ,
.,- ......""..
...... .....
....
. ',",.,'..',..',"',',',
... ""''''''''''- ..
....""....,,,,, ..', ,
, ". , . , , , ., ' , , , , , ,
"..,'........"""", ..
.',',.','.', ,',','.',','.',',',,',"',',',,',',',',',' ,',','
.','.",',",",','.',',"',"",',",".','.',",','
"",","",', ,',',',',',' ,',
'....".."......, .. ..
,",',",',',,',"', ',''','"',',','",,',,. " " """"",
."'..'ii.AI(~P:,:::;::,;::: .H ....
~~ j.:.:.;.!..~.:.:.:.:...-.....E.:.;...~]\
......' ,..' ....,..........",...,.., " , ,
.....,.,. '",.,,',',",',,'",,',,'.'.,',.''.',',','''. .,." ,.,,','"',,',",'.",,' "',','"
;';':-;';';';',':-";;';;';':';';';';';';';';';';';',';';';';';';';';';';';','. ..;,;;,;;,;.;,;.;,:,;:;,;,:,:,;;-::;:,;,;,:,;;,;,;;,:,:;;';':':',.,',
,',',',',',"',',',',',',','''.''',',',',','.','..,',','.',',',',','.','",'.',' ""'",,,',',',',',',',',',""""""",',',".',',',,'",',',','''.'.'
The State has
expressed Its
support for
this option.
The
community
was somewhat
supportive of
this option,
but had
concerns with
final
appearance,
protectiveness,
effectiveness,
and long term
safety of any
containment
option.
The State has
expressed Its
support for this
option.
The community
was somewhat
supportive of
this option, but
had concerns
with
protectiveness,
effectiveness,
and long term
safety of any
containment
option, as well
as the finished
height of this
option.
The State has
expressed Its
support for a
permanent
containment
option, and
since this
alternative
would leave a
great deal of
contaminated
material In
place, would
not be
supported.
The
community
was not
supportive of
this option.
They would
like all the
contaminated
soli removed,
not just a
portion, with
the remainder
of the site
fenced.
-------
10.0 The Selected Remedy
Based upon consideration of the requirements of CERCLA, the detailed analysis of
the alternatives using the nine criteria, and public comments, EPA has determined
that a hybrid 01 Alternatives 3A and 3C is the most appropriate alternative for the
WDI Superfund Site. The goal of the remedy is to provide a permanent barrier to
the contaminated soil, prevent rainwater from infiltrating the contaminated soils
and carrying the contamination into the groundwater, prevent gases from migrating
off the property, and maximize the beneficial end use of the site to the extent
practicable.
The selected remedy is protective, meets ARARs, and is effective for the long-term
and is permanent. While it does not meet the statutory preference for treatment of
the principle threat, landfill gases may be treated if necessary. The selected
remedy is constructable with readily available materials and common construction
techniques, so is considered implementable", Short-term risks will be slightly
elevated during construction, but measures will be taken to minimize the impacts.
Since the cap will be impermeable, groundwater will be protected, thus further
reducing the risks posed by the site.
This remedy is considered cost effective, and has been accepted by the State of
California. During the design process, the community will have the opportunity to
participate in determining the ultimate configuration of the remedy, so that
community acceptance, as much as possible, will be achieved.
Concerns of both the citizens and the City Council of the City of Santa Fe Springs,
were that EPA's Proposed Plan (Alternative 3C was the preferred alternative) would
result in an unattractive mound of black asphalt that would be useless to all
concerned, as well as an eyesore to the residents of Santa Fe Springs and the
students of St. Paul High School. As a result, the decision for the final
configuration of the cap will be made during the design phase of the project with
input and involvement from the community. This involvement provides for public
meetings describing the design as it develops through the design process, and
input into the decision-making processes in determining the configuration and final
design of the cap, The cap will be required to meet an impermeable standard of
10.7 cm/sec. Materials that will be used to achieve this performance standard will
be evaluated during the design phase,
With the selected remedy, the site will be ca"pped with an impermeable, RCRA-
equivalent cap, with the surface configuration to be determined during design. For
cost estimating purposes, EPA estimates that a liner will cover the capped area,
with approximately 75 % of the cap surface asphalt, and the remainder of the cap
area a soil and vegetation cover, This configuration of the remedy will be
protective and provide for a more attractive solution to the site problems.
2-17
-------
The following are the key components of the selected remedy:
. Excavating designated areas to clean-up standards (see Table 2)
. Consolidating excavated materials within Area 2
. Placing perforated piping for the passive gas extraction system throughout
area to be capped (Figure 5)
. Constructing RCRA-eQuivalent, impermeable cap over the reservoir and
designated areas (see Figure 7 for estimated final configuration).
. Monitoring gases that emanate from the site, and installation of an
extraction and treatment system if constituents and volume of gases
. require it .
. Implementing institutional controls so that future use of the site is
compatible with the remedial goals and the' integrity of the cap is
maintained, parcels that have residual contamination are restricted
from activities that could lead to exposure to contaminated soils, and
shallow groundwater use is prohibited
~
o
a:
en
o
z
it
IL
en
~ Vegetation
,
~ Asphalt
f
i
10
.' . .,~. .:~.
)(
! ~::,:J
LOS NlE10S ROAD
Figure 7 Approximate Configuration of Selected Remedy Cap
2-18
-------
10.1 Clean-up Standards
The purpose of the excavation of the selected remedy is to remove the sump
material from the undeveloped areas and consolidate the contaminated material.
Since no ARARs were identified for clean-up standards for soils, the standards for
the excavation are based upon either background, or health based levels
(preliminary remediation goals, or PRGs, were used, and are explained in the
Feasibility Study) for the contaminants without detectable background levels. The
clean-up standards have been established so that the contaminated soils and sump
materials are removed, while soils at or near background levels are left in place.
Table 2 presents the contaminants of concern, the health based PRG (based on
residential exposure), the background level, if any, and the clean-up standard.
'.
~~lf:~~~~::~~~~~~~~;Ir~~'~~:;;dS
I......' ...
CLEAN-UP
PRG BACKGROUND STANDARDS
CHEMICAL (mg/kg) (mg/kg) (mg/kg)
Arsenic 0.97 2.31 10.0
(6.5 USGS)
Beryllium 0.41 0.278 0.41
Chromium 44 12.10 44
Cadmium 39 0.363 39
lead 500 7.00 500
Thallium 5.5 12.00 12.0
Benzene 2.7 --- 2.7
Dieldrin 0.11 --- 0.11
DDT,DDE, DDE 5 --- 5
cP AHs 0.23 --- 0.23
PCBs 0.22 --- 0.22
2-19
-------
The clean-up standard for arsenic higher than background was selected. This
decision was based on several factors. First, background levels in soils pose an
excess cancer risk to residents ranging from approximately 2.5 x 10-6, based on
samples from St. Paul High Schhol, to almost 7 x 10-8, based on USGS background
levels for the general area. Secondly, the areas to be excavated are currently
zoned for light industrial use, and any proposed development would be limited to
industrial use only. The PRG for industrial soil exposure is 3.3 mg/kg, so the clean-
up standard of 10.0 mg/kg, which is three times the PRG, would yield a risk 01
approximately 3 x 10-8 for industrial use. This approximates the current risk posed
to residents in the area from the natural, background soils. Lastly, the institutional
controls that will be placed on the properties will ensure that none of the properties
are used for residential purposes.
10.2 Limited Excavation and Consolidation
The areas to be excavated are identified in Figure 5. These areas were chosen
because of the levels of contamination found at and beneath the surface, the
accessibility of the selected areas since they are vacant, and remediation will
maximize economic redevelopment opportunities. No businesses or buildings
would be disrupted by this excavation. Other areas of the site where
contamination was discovered are covered either with buildings, pavement, or
both. These structures' prevent direct contact with any existing contamination
beneath the soil, and therefore meet the main goal of this remedy, which is to
prevent direct contact with the contaminated soils.
The excavated material will be moved to the Area 2 portion 01 the site, where the
cap will be placed. The existing clean surface fill will be pushed back so that the
excavated material can be covered over by clean fill prior to the placing of the first
layer 01 the cap. The final grade 01 the site will be made such that drainage and
run-off is uniform and directed to the storm drains, and that there will be no
collection of standing water on the cap. The excavated portions will be refilled
with clean fill, compacted, and graded.
Dust suppression will be employed during the excavation, so that the potential for
contaminant migration during excavation is greatly reduced. Suppression
techniques include water or polymer spraying on the surface, wind breaks, and
other methods for reducing the amount 01 migrating dust. Air monitoring will also
be required during the excavation to ensure that any subsurface gases encountered
during the excavation are dealt with properly, and that the activities at the site are
not adversely impacting local air quality.
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10.3 Passive Venting System
Since methane, the major component of subsurface gases detected at the site, is
lighter than air, it tends to move upward through the soil until it arrives at the
surface, where it is released into the atmosphere. If buildings occupy the space
above the area where methane is generated, the gas could collect and pose a fire
or explosion hazard. The gas could also migrate laterally if there is not an outlet in
the vertical direction. For this reason, perforated piping will be placed on the
surface of the site, prior to the placement of the cap. The piping will direct the
rising gases to the surface atmQsphere, where they can be vented or treated if
necessary. If an active gas extraction system is necessary (the volume of
subsurface gases is high, or its components require extraction), the passive system
will be piped to the active extraction system and all the gas will be treated in one
flaring system (if volume is sufficient to burn). If the risks posed by the gases
cannot be mitigated by flaring, an alternate treatment such as carbon adsorption
will be evaluated and implemented. Section 10.5 discusses the active gas
extraction and treatment component of the remedy.
10.4 RCRA-equivalent Impermeable Cap
The actual cap will be constructed as a multi-layer, impermeable cap that meets the
substantive requirements of RCRA. Its components will be determined during the
design phase, but its final configuration will have a permeability of 10.7 em/see,
which will provide protection of groundwater as well as maintain the performance
of the cap over the long-term. For cost analysis purposes, it was assumed that
the preferred alternative in the Proposed Plan, Alternative 3C, would comprise the
major portion of the cap, with approximately 563,000 ft2 of the site capped with a
flexible membrane, gravel, and asphalt. The remaining 190,000 ft2 will be covered
with a multi-layered vegetation cap.
10.5 Gas Monitoring, and Active Gas Extraction and Treatment
Prior to any excavation or construction, the vapor wells will be sampled to estimate
the volume of gases beneath the site and determine the proper gas treatment
components. A flux chamber may be used to estimate the volume and make-up of
gases permeating the existing soil cover of the site, since the cap will prevent the
permeation of gases to the atmosphere that is presumably occurring. Once these
data are collected, an analysis will be performed to determine if an active gas
extraction system is necessary. If the volume of gases rising to the surface
warrant treatment, an active system must be put in place so that the gases may be
treated by flaring. If there are chlorinated components to the extracted gases, a
wet scrubber may be necessary for the flare.
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The active system would utilize existing vapor wells as eXtraction wells. The gases
would be pulled from the wells by a blower, and directed to a flare, where they will
be destroyed. If the volume of methane is not high enough to allow burning, then
another treatment, such as carbon adsorption, will be used.
10.6 Institutional Controls
Institutional controls are legal restrictions placed on a property to restrict types of
use. In general, institutional controls are either (1) government controls imposed
by state or local governments; or (2) proprietary controls, such as deed restrictions,
whereby a party holding an interest in a parcel of property restricts the use of that
property. The purpose of institutional controls is to prevent use of the site that
could facilitate contact with contaminated soils. The restriction on use of the
property will depend on the level of contamination that exists on the parcel, and
the risks posed by that contamination. The institutional controls may vary from a
simple notice on the deed stating that contamination exists on the property (if the
contamination is deep and low-level), to restrictions on digging or excavation that
could expose the contaminated soil. Restrictions will also be made for the use of
groundwater beneath the site.
There will also be restrictions on the compatible uses of the capped areas of the
site. Since the purpose of these restrictions is to maintain the integrity of the cap,
only those uses that will not adversely affect the cap will be allowed. Some of the
compatible uses include recreation (e.g., tennis and basketball courts, miniature
golf), and light storage. Uses that are not compatible include heavy equipment
storage, enclosed buildings, and any structure that would need to break the
integrity of the asphalt in order to be built. While EP A recognizes that there may
be isolated cases where the cap may be breached and suitably repaired, EPA will
discourage all but the most substantive justifications for tampering with the remedy
and the integrity of the cap.
Restrictions placed on the properties with residual contamination will be determined
during negotiations with each property owner. In general, if there is contamination
beneath a property that can pose a health risk, there will be a restriction placed on
the property. At the very least, the restriction in the deed will state that
contaminated material exists beneath the site. The deed restriction will be utilized
when contamination is at least 15 feet deep, and the likelihood for direct contact,
even with construction activities, is minimal.
For contamination that lies within the first 15 feet, a determination will be made as
to whether the contamination poses a health threat. For arsenic, for example,
levels less than 10.0 mg/kg will not require any additional restriction other than a
notice. For arsenic levels greater than 10.0 mg/kg, restrictions will require that
suitable mitigation measures be implemented to protect workers and surrounding
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residents from the risks posed by the contamination and the potential exposure.
These measures would include sampling prior to any work being performed, worker
protection and dust suppression during any construction, and remediation if
necessary. A similar determination will be made for other contaminants found on
the properties The final development of the institutional controls will be made
during negotiations in the design phase.
Vegetation planted on the soil and clay cap must be low-maintenance and drought
tolerant. Also, the root systems of the selected plants will be fairly shallow, so
that the roots do not penetrate the clay layer. The plants will also be chosen to
maximize erosion protection along the slopes. At a minimum, the vegetation
should be sustainable for the climate of Santa Fe Springs without irrigation (after
initial planting) and require little maintenance. Once the vegetation begins growing,
only minimal work will be required for upkeep and maintenance.
10.7 Annuallnspection
All components of the remedy will be inspected and evaluated not less than
annually. Special circumstances (such as earthquakes or heavy rains) may require
additional inspections. Monitoring will be conducted as required by ARARs, and
include groundwater sampling, vapor well sampling, and flare performance and
emissions (if there is a flare). The site will also be inspected to ensure that the cap
integrity is maintained, and that institutional controls are in effect. Operation and
maintenance will be conducted to ensure that the remedy maintains its
effectiveness.
10.8 Cost
A detailed cost description of each of the components of the remedy is included in
the FS. The estimated cost for the selected remedy is shown in Table 3 as a
present worth value, and includes annual monitoring for 30 years and appropriate
5-year reviews.
10.9 Design Options
During the Public Comment period, several suggestions were made to enhance the
selected remedy. These included a block retaining wall between the site and the
St. Paul High School athletic fields, and a gas trench near the border of the site to
prevent gas migration onto those fields. These suggestions will be taken into
account during the design, since they may be somewhat mutually exclusive given
current site conditions (especially the trees along the border). The trench may also
be incompatible with the gas extraction system.
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..':...'..:.,:.....,.,,:,,:.:. . . . ..:;.",:. "
.. .
: Table 3':selected. Rem8dy:Costs:
.. .',' ",..". ..
Present Worth
Component Cost
Monitoring $252,000
. Subsurface gas samples - $3600/yr
. Groundwater samples - $4235/yr
. Annual reporting - $5000/yr
. Five Year Reviews - $10,000 each
Excavation of Contaminated soil
. 78,000 yd3 @ $10/yd3 $780,000
Replacement Fill
. 52,000 yd3 @ $0.10/yd3 $5,200
Flexible Membrane Liner
. 750,000 ft2 @ $2.40/ft2 $1,800,000
Clay layer (1 foot thick, 10.7 permeability)
. 7000 yd3 @ $13/yd3 $91,000
Top Soil (1 foot thick)
. 7000 yd3 @ $14.50/yd3 $101,500
Vegetation (hydroseeding)
. 21,000 yd2 @ $1.25/yd2 $26,250
Asphalt Paving
. 562,500 ft2 @ $3.00/ft2 $1,687,500
Gas Collection and Treatment System. $427,500
Total $5,170,950
11.0 Statutory Determinations
EPA must select remedies that are protective of human health and the
environment, comply with applicable or relevant and appropriate requirements
(unless a .statutory waiver is justified), are cost-effective, and utilize permanent
solutions and alternative treatment technologies or resource recovery technologies
to the maximum extent practicable. In addition, CERCLA includes a preference for
remedies that employ treatment that permanently and significantly reduce the
toxicity, mobility, or volume of hazardous wastes as their principal element. The
following sections discuss how the selected remedy meets these statutory
requirements.
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11.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment through the
reduction of direct contact with contaminated soil by constructing a multi-layered
cap. The cap will also reduce the potential for rainwater to leach contaminants
from the soil into the groundwater. The gas venting component of the remedy will
reduce the potential for migration of subsurface gases laterally from the site, and
will treat the gases, if necessary, to reduce the impact to local air quality.
Institutional controls will be implemented so that permanent restrictions will be in
place to notify future land owners of the extent and risks of residual contamination.
The restrictions placed on the parcels will prevent inadvertent contact with
contaminated soil for the parcels where no excavation or capping will take place.
For the capped area, the institutional controls will maintain the integrity of the cap
so that contaminated material is effectively contained.
There are some short-term risks associated with this remedy while excavation and
consolidation of the contaminated soils are performed. However, dust suppression
measures will be taken to minimize this risk.
11.2 Compliance with Applicable or Relevant and Appropriate Requirements
The specific regulations that are applicable or relevant and appropriate for the WDI
site are listed below. All of these regulations are action-specific ARARs. For a
description of the regulations, see Table 2-3 of the Feasibility Study. This list
constitutes EPA's determination of the ARARS for the activities outlined as the
selected remedy. The ARARs identified for WDI for the selected remedy are:
Hazardous Waste Control Act (HWCA) (State equivalent of RCRA) that are
Relevant and Appropriate:
. Monitoring for Interim Status Facilities, 22 CCR ~ 66265.97 (a) - (d)
. Landfill Closure and Post-closure Care, 22 CCR ~ 66265.310 (a), (c)
. Seismic Design Standards, 22 CCR ~ 66265.25 (b)
California Integrated Waste Management Board Regulations that are Relevant
and Appropriate: .
. Gas Monitoring and Control During Closure and Post-closure, 14
CCR Chapter 3, ~ 17783-17783.1 5
. Post Closure Land Use, 14 CCR ~ 17796
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South Coast Air Quality Management District (SCAQMD) Regulations that
are Applicable:
. Regulation IV
- Rule 401 - Visible Emissions
- Rule 402 - Nuisance
- Rule 403 - Fugitive Dust
- Rule 404 - Particulate Matter (Concentration)
- Rule 405 - Solid Particulate Matter
": Rule 407 - Liquid and Gaseous Air Contaminants
- Rule 408 - Circumvention
- Rule 409 - Combustion
- Rule 473 - Disposal of Solid and Liquid Wastes
. Regulation XI
- Rule 1150.2 - Control of gaseous emissions from inactive
landfills
South Coast Air Quality Management District (SCAQMD) Regulations that
are Relevant and Appropriate:
. Regulation IX - Standards of Performance of New Stationary Sources
. Regulation X - National Emission Standards for Hazardous Air
Pollutants
. Regulation XI -
- Rule 1108.1 - Emulsified Asphalt
- Rule 11 50 - Excavation of Landfill Site
In addition, the guidance document, EPA/530-SW-89-047, July 1989, "Final
Covers on Hazardous Waste Landfills and Surface Impoundments" will be used in
implementing the selected remedy.
11.3 Cost Effectiveness
EPA believes this remedy will significantly reduce the risks at this site by
eliminating the pathway for direct contact with contaminated soil. This remedy will
also reduce the potential for rainwater leaching contaminants from the soil into the
groundwater by the construction and maintenance of the impermeable cap. This
will be done at an estimated cost of approximately $5,170,000, which EPA
considers reasonable for the risk reduction that will be achieved.
11.4 Use of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected remedy utilizes permanent solutions and alternative treatment
technologies (or resource recovery) to the maximum extent practicable. However,
the treatment of the principal threats of the site was evaluated in the FS and
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screened out because it was not found to be practicable. The remedy consists of
proven technologies, common construction materials and practices, and
incorporates EPA guidance for closing permitted landfills to provide a protective,
permanent solution to the site problems.
11.5 Preference for Treatment as a Principal Element
It was determined that treatment of the principal threats of the site was not
practicable for this site. The main contaminant posing site risks, arsenic, is not
readily treatable in the soil. However, treatment is a contingency of the subsurface
gas component of the remedy. EPA believes that the selected remedy, though not
implementing treatment as part of its principal element, is protective for the long-
term and currently implementable.
12.0 Documentation of Significant Changes
The Proposed Plan for the Waste Disposal, Inc. Superfund Site was released for
public comment in August 1993. An Asphalt Cap with Flexible Membrane liner
was the main component of the remedy, with limited excavation and consolidation
of some contaminated soils under the proposed cap. EPA has reviewed all written
and verbal comments submitted during the public comment period, and has made
its decision with only minor changes to the remedy.
Instead of a full asphalt cover over the capped area of the site, the cap with
consist of a multi-layered, RCRA-equivalent cap with a performance standard
permeability of 10-7 cm/sec. The components and final configuration of the cap
will be determined during the design phase, with additional community involvement
in making those final determinations. The decision was made to allow for greater
public participation during the design phase in response to public comments and
City concerns for the aesthetics of the finished remedy. This has a small effect on
cost, and impacts long-term effectiveness slightly, since some of the cap surface
may be vegetation which might be easier to breach than asphalt. However, since
the cap will be essentially impermeable, the selected remedy will still be protective
of human health and the environment.
Additional design options were added as a result of comments received during the
comment period. A block retaining wall between the site and St. Paul High School
will be considered in order to provide more security for the site, as well as block
the view of the site from the school. A gravel trench for gas migration prevention
will also be considered. However, current site conditions must be carefully
evaluated and adequate involvement from the High School, because in order to
implement both design options, the trees currently growing between the site and
the High School may have to be removed.
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PART 118 RESPONSIVENESS SUMMARY
1.0 Introduction
This Responsiveness Summary provides EPA's response to comments received on
the Proposed Plan for Contaminated Soil and Subsurface Gas at WDI. The
Proposed Plan was made available for public review and comment on August 1 2,
1993. During a public meeting on September 1, 1993 EPA presented the
alternatives for addressing the soil and subsurface gas contamination, described
EPA's preferred alternative, answered questions, and received public comments on
the Proposed Plan. EPA also made a presentation to the Santa Fe Springs City
Council on August 26, 1993, and to the parents of St. Paul High School students
on September 9, 1993.
The public comment period ended on October 31, 1993. In addition to the
comments received during the public meeting, EPA received the following comment
letters:
. Ernest Brown & Company, Public Comment on Preferred Alternative
Waste DisDosal. Inc. SUDerfund Site, September 9, 1993
. Department of Toxic Substances Control, Waste Disposal, Inc. Feasibility
Study Report for Soils and Subsurface Gas, September 9, 1993
. Water Replenishment District of Southern California, Proposed Plan for
Contaminated Soil and Subsurface Gas for Waste Disposal, Inc., Santa
Fe Springs, California, September 10, 1993
. Department of Toxic Substances Control, Comments to Waste Disposal,
Inc. Proposed Plan, September 10, 1993
. Bear, Kotob, Ruby & Gross, Waste Disposal Inc. in Santa Fe Springs-
Superfund Site, on behalf of Dr. Adeline Bennett, September 15,
1993
. Department of Health Services comments of the Proposed Plan, September
21, 1993
. City of Santa Fe Springs, City of Santa Fe Springs' Comments on EPA
Proposed Remediation Plan for Waste Disposal, Inc. Superfund Site,
October 8, 1993
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. Albert L~ Sharp, City of Santa Fe Springs Mayor Pro Tern, Proposed Soils
Remedy for the Waste Disposal, Inc. Superfund Site - Santa Fe
Springs, California, October 8, 1993
. Phil Campbell, letter of support for EPA's preferred alternative, October 29,
1993
Copies of these letters, as well as additional correspondence that relates to the
comment letters EPA received during the comment period, are attached to this
document as Attachment A.
The remainder of this responsiveness summary is divided into three sections.
Section 2 is a summary of major issues and concerns raised by the comments and
EPA's response to these concerns. Section 3 includes each written comment
received and EPA's detailed response to each comment. Section 4 includes the
comments received during the Public Meeting and EPA's response to them.
2.0 Summary of Responses to Major Issues and Concerns
There were several issues and comments that were brought to EPA's attention
during the public comment period. Some of these were raised formally during the
Public Meeting, but many were also expressed during the meeting with the parents
of St. Paul High School, as well as EPA's presentation to the Santa Fe Springs City
Council. As a result, EPA has committed to increased community involvement
during the design process, and will solicit more comments from the community as
the project progresses. The following are concerns related to the decision for the
remedy.
2. 1 Health Concerns and Site Risks
One of the main concerns is that of a potential health threat, both to the citizens of
Santa Fe Springs and the students of St. Paul High School. As explained in the
Feasibility Study and during the Public Meeting, EPA considers the site a potential
health threat, based on assumptions made for future use of the site. The site does
not currently pose a risk to nearby residents, students, or workers, since there is
no activity that would expose persons to the contamination. However, if the site is
opened up for development, one of the first things that would happen would be
digging for foundations of buildings, in which case contaminated soil would
become exposed to the atmosphere, greatly increasing the chances for human
exposure. There also exists some surface contamination that trespassers could
become exposed to, if they chose to cross the currently fenced site.
In order to protect the health of the community, the pathway through which the
population can be exposed must be eliminated. EPA has chosen to place a
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physical barrier between the community and the contaminated soils, which pose
the highest risk at the WDI site. In order to keep the physical barrier protective,
EPA will also implement restrictions on use of the physical barrier, or cap, so that it
protects people from exposure to the contaminated soils beneath. These
restrictions will be placed on any property within the site boundary where
contamination exists above a health concern.
Conversely, some members of the community feel that since the site poses no
current threat, nothing should be done at the site. EPA, however, feels that it is
necessary to aCt prior to any exposure occurring. The no-action approach fails to
take into account the potential threat of contaminants travelling to the
groundwater. Since rainwater can leach contaminants out of the soil and into the
groundwater, rainwater must be prevented from entering the soil. This is the other
main goal for the cap. Leaving the site in its current condition would provide no
protection.
2.2 Aesthetics and Future Land Use
Much of the interest and concern for this site concerns ultimate use of the site, and
what it will look like to passers-by, students, and nearby residents. EPA has
taken these concerns into account by committing to a design process that will
allow for greater public involvement.
In the Proposed Plan, EPA's preferred alternative called for a multi-layered cap with
an asphalt top layer over the reservoir area. However, this would not have been
simply a mounded hill of black asphalt; the cap would have been designed to allow
for uniform drainage, and would have changed the current topography very little.
In this Record of Decision, EPA has modified the alternative somewhat by requiring
a multi-layered, impermeable cap, with the final configuration determined during the
design phase. Again, this will allow for greater public involvement during the
design of the remedy.
The future use of the site has not yet been decided. It is hoped that EPA, the City
of Santa Fe Springs, and the property owners can come to a mutually agreeable
decision regarding future use of the capped property. Community input will also be
solicited during the discussions of final use. EPA insists that any activity protect
the integrity of the cap, and that the activity be included in the design of the final
remedy. Once the cap is in place, it should not be breached. EPA recognizes that
there may be cases where the cap may be breached and suitably repaired,
however, EPA will discourage all but the most substantive justifications for
tampering with the remedy. Any foundations or poles that need to be installed for
planned future activities should be installed at the time of cap construction, so that
the cap retains its protectiveness.
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2.3 Effectiveness of Remedy
The other major concern of the community was the effectiveness of the remedy, or
how to ensure that the remedy is protective, especially for the students of St. Paul
High School. EPA is confident that the remedy will be protective, since the remedy
design will follow EPA guidance established and proven by previous efforts with
landfill sites. Also, with future monitoring and evaluations, EPA will ensure that
the chosen remedy remains protective and effective. If the analysis of the data
shows that the remedy is not performing according to expectations, and that
contaminant levels are increasing or spreading, the remedy decision will be re-
evaluated.. .
3.0 Detailed Response to Comments
3..1 Comments from Ernest Brown & Company
A. RCRA-Equivalent Cap
1. DeDth of Liner: While the EPA has expressed a desire to facilitate the
reuse of the property where the proposed cap is to be placed, the present
cap configuration .prevents viable economic use of that property. Provisions
should be made to place the impermeable liner and the consolidated .
excavated soil at a greater depth with relation to the asphalt surface. Since
the consolidated excavated (i.e., contaminated) materials lie directly under
asphalt and thin membrane, there is virtually no ability to place the type of
minimal subsurface foundations necessary for likely use. For instance, any
RV parking or other storage uses would require a series of fence posts and
lamp posts which require shallow subsurface foundations.
Response: Since the purpose of the institutional controls for the cap area is to
maintain the integrity of the cap, even if the liner and contaminated soils
were below placed at a greater depth with relation to the asphalt surface,
there would still not be any allowable activity that would breach the cap.
Since the cap is multi-layered, each component must be considered part of
the whole and integral to the protection offered. One component cannot be
breached and still have cap integrity maintained. As discussed in the
institutional controls section of the ROD, future use plans need to be
addressed during design, so that any needed foundations or post holes can
be incorporated into the design and constructed during the implementation of
the remedy.
2. ComDosition of liner: In-depth consideration should be given to
substituting a one foot clay liner in lieu of the proposed flexible membrane
liner now being proposed. Such a clay liner may be more durable and may
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serve as an equal or superior barrier to infiltration of rainwater. The cost of
a clay may also be more economical to construct. If a synthetic membrane
is truly deemed the best alternative, testing and/or statistical results should
be included in the ROD showing durability and longevity data on the
proposed synthetic liner. .
Response: EPA has considered the comment, and has decided on a performance-
based standard for this remedy, rather than calling out specific materials in
this Record of Decision. The Proposed Plan called for a RCRA-equivalent,
impermeable, multi-layered cap (membrane liner, gravel and asphalt). This
ROD requires a permeability of 10.' em/see for the final cap configuration,
with a combination of surface configurations based upon community input.
That said, the replacement of a membrane liner with a clay layer is not likely,
based upon the poor performance of clay layers in dry climates like Santa Fe
Springs. Cracking caused by drying of the clay (desiccation) can be
irreversible, opening a pathway to the contamination and nullifying the
protection of the cap. During design, the final low-permeability layer/top
layer configuration will be determined, with additional public input into the
decision.
B. Contaminated Soils:
1. Characterization: If the Preferred Alternative is implemented, there
should be a more complete characterization of the contaminated soils to be
excavated from the former waste handling areas (e.g. areas 3, 4, 6, 7, and
Toxo Spray Dust area). Upon review of the Final Remedial Investigation
Report (1989), there appears to be an insufficient number of borings placed
in these areas (only two borings in some areas) and insufficient laboratory
analyses performed. 'In particular, there appears to be too little data (e.g.,
only 3-4 analyses in some areas) regarding the lateral and vertical extent of
volatile organics, semi-volatile organics, pesticides, PCBs, and metals.
Response: The determination of the extent of excavation will be made based on
on-site sampling to ensure that the excavation meets the clean-up standard
established in this ROD. EPA feels that based on the RI data, as well as
previous studies that outlined the extent of the sumps, the contamination in
the designated areas will be removed to the levels established in this
document.
2. Movement Across ProDertv Boundaries: The Preferred Alternative
contemplates moving contaminated soils onto the center property partly
owned by the Pitts Grandchildren's Trust prior to capping. In the absence of
express authorization from the Trust, this action, regardless of how logical in
the macro sense or how well-intended, constitutes a trespass. The Trust
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would like confirmation by the EPA that it must obtain the permission of the
Trust, or take the property and pay just compensation under the 5th
Amendment, prior to implementing the Preferred Alternative.
Response: EPA does not concur with the Trust's assertions. As a preliminary
matter, EPA notes that the issue only arises with respect to soils that are
being moved onto the Trust's property from property not owned by the
Trust. Some of the contaminated soil that is being consolidated will be
moved from areas that are already partially owned by the Trust.
Furthermore, for several reasons, EPA does not believe that the movement of
the contaminated soils from the areas not owned by the Trust would
constitute a trespass or a taking.
First, EPA has broad regulatory authority under Section 104(a) of the
Comprehensive Environmental Response, Compensation, and liability Act
(CERCLA), 42 U.S.C. S9604(a), to perform such remedial action as it
believes is necessary to protect human health and the environment as long
as the remedial action is consistent with the National Contingency Plan. The
selected remedial action at the wel Site is a proper exercise of EPA's
regulatory power to abate a public nuisance and is not a trespass or a taking.
Second, EPA notes that the center property partly owned by the Trust
already contains contaminated soils and, in fact, is the most contaminated
portion of the entire Superfund Site. Unless a Superfund remedial action is
performed, the land owned by the Trust cannot be used for any purpose and
has no real market value. Thus the remedial action would not cause any
diminution in the value of the property or any injury or damage to the Trust.
Finally, EPA observes that the Trust, as the current owner of contaminated
property at the Site, is a potentially responsible party (PRP) pursuant to
Section 107(a)(1) of CERCLA, 42 U.S.C. S9607(a)(1), and is thereby jointly
and severally liable for the costs of the response action. Accordingly, if the
contaminated soils from the perimeter areas were transported to a disposal
facility off-site, rather than being consolidated in the center property, the
total cost of the response action would be significantly higher and the Trust.
as a PRP, would be liable for that higher total cost.
Whether a particular action constitutes a trespass or a taking is, of course,
ultimately a judicial determination. If this issue were to be litigated, EPA
reserves all of its rights to present the above legal arguments and any other
legal arguments that might be pertinent. However, since the Trust is a
potentially responsible party. EPA will be attempting to have further
discussions with the Trust in an effort to negotiate a settlement resolving the
Trust's liability under CERCLA Section 122, 42 U.S.C. S9622.
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c. Vegetation/Greenbelt Option
As part owners of the area which is proposed to be capped under the
Preferred Alternative, the Pitts Grandchildren's Trust strenuously objects to
any vegetation or greenbelt option which would make business ventures on
the central property impossible. The EPA should continue its prior
commitment to work hard in order to implement a remedy which allows for
the maximum economic use of the property. A vegetation/greenbelt option
would constitute a Taking under the 5th Amendment for which just
compensation (i.e., lost profits on a yearly basis indefinitely) must be paid.
Response: The community, the property owners, and the City have expressed
various concerns about the future use of the property. Some of the
concerns emphasize future economic use, others emphasize safety, and still
others focus on aesthetics. In the selected remedy EPA has attempted to
address and balance those various competing concerns. Some of the
specifics regarding the future uses of the Site will be determined during the
design phase after further consultation with the interested parties.
The selected remedy contemplates some landscaped vegetation as a
component of the cap. For many of the same reasons set forth in the
response to the preceding comment, EPA does not believe that the
landscaping would constitute a taking. As part of the remedia,1 action, the
landscaping would be a proper exercise of EPA's regulatory authority.
Furthermore, since the Trust's property cannot presently be used for any
business purpose. the selection of a remedy that included a greenbelt would
not cause any diminution in the value of the property.
3.2 Department of Toxic Substances Control, Comments to the Feasibility Study
Report for Soils and Subsurface Gas
1.
The Department has in the earlier comments to the draft Feasibility Study
(FS) stated that the acronyms STLCs and TILCs were not correctly used
and could mislead the reader. They are still found in certain places in the
final FS to imply that if they are below STLCs and/or TTLCs, they are not
hazardous. As stated in the Health & Safety Code Section 66699, STLCs/
TTLCs are used to determine if any waste is hazardous waste or not
(Underlined for emphasis. See the definition for waste.)
Response: EPA recognizes that the use of STLCslTTLCs is inappropriate for the
discussion of the extent of contamination. However, previous studies
referred to in the FS utilized this analysis. and it would be inappropriate for
EPA to alter the discussion of these previous studies. EPA also recognizes,
however, that in lieu of background levels or health-based risk standards, the
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comparison of a material to its concentration that determines a hazardous
waste is better than simply stating the results of the sampling. Without
some kind of reference or context, the values may be meaningless to many
of the readers.
2.
The Department is concerned with any contaminated soils left in place,
regardless of the alternative selected for the final remedy. The State has
regulations on land use and definitely require some form of deed restrictions
placed on the main reservoir and any other areas that have contaminated
soils if they do not meet the requirements for an unrestricted land use.
Unrestricted land use means that the land must meet risk criteria for
residential land use. .
Response: The selected remedy requires an evaluation of the contamination found
on each parcel, with appropriate restrictions placed on parcels can pose a
health risk. Please refer to Section 10.6 of the ROD for a more detailed
description of the institutional controls. The final determination of
restrictions for each property will be made during negotiations in design.
3.
In relation to concerns presented by the community with regards to seismic
activities, the following regulations should be considered as ARARs and be
taken into consideration during the design phase:
a. CCR Title 23, Section 2547 which states that structures which control
surface drainage, erosion or gas should be designed to withstand the
Maximum Credible Earthquake (MCE) without damage.
b. CCR Title 22, Section 67108 which states that cover system and
containment control features should be designed to withstand the MCE
without the level of public health and environmental protection afforded by
the original design being decreased.
c. CCR Tile (22) 67418 which states that the cover be designed to
accommodate the forces of earthquakes.
Response: EPA made a final ARARs determination in a letter to the State dated
December 7, 1993. The regulations identified in parts (b) and (c) above
have been repealed and are now incorporated into Title 22 CCR !66264.25
(b), which has been included as an ARAR. The regulation identified in part
(a) is duplicative of the regulations in (b) and (c), 80 EPA does not consider it
to be an ARAR.
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0.
4.
The Department would like to make a few minor comments on the
discussion on the risk assessment so they will reflect the current thinking on
this subject:
a. In the 3rd paragraph of Section 1.12, the risk were based on the average
(geometric mean) of the contaminant concentration. DTSC generally uses
the 95 % Upper Confidence Level for this value.
b. In Table 1-9, the age and the average weight given fits a "Student"
better than an .Off-site Adult Residents..
c. The Dermal Absorption Factors used were lower than currently
acceptable values. For example, the dermal absorption factors for the
Carcinogen PAHs and PCBs were stated as 0.02 and 0.07, respectively.
The values used in the DTSC Preliminary Guidance Manual (7/29/93) were
0.20 and 0.14, respectively.
d. In Table 1-13, the PRG for lead was indicated as 500 mg/kg. Presently
acceptable levels are 130 ppm.
Response: EPA thanks the State for their comments to the Feasibility Study. In
response to part (d), EPA refers to the Region IX PRGs for Fourth Quarter
1993 (November 1, 1993), which still identifies the PRG for lead, based on
the Uptake Biokinetic Model, as 500 mg/kg for a residential soil exposure.
5.
Section 1.6, 1st paragraph. Typo. The Groundwater Elevation Map is
shown in Figure 1-4 and not in Figure 1-5 as stated in the text.
Response: The comment is correct; the figure was misidentified in the text.
3.3 Water Replenishment District of Southern California
1.
The August 1993 EPA proposed plan announcement indicates that the
majority of the non-disposal reservoir contaminated soils occur within 5 to
15 feet below ground surface. However, the "Preliminary Risk Assessment"
prepared by the EPA contractor, Ebasco (December 1989) indicated that
"The majority of subsoil contamination was detected at depths ranging from
10 to 20 feet" (~basco, 1989, p2-35). In addition, a review of soil sample
analytical summary tables presented in the "Final Remedial Investigation
Report" (Ebasco, November 1989) indicates that certain metals, volatile
organic compounds, semivolatile organic compounds, pesticides, and. .
polychlorinated biphenyls occur at potentially elevated concentrations to
maximum depths of 50,60,60,35, and 35 feet, respectively. We are
therefore concerned that the depth of soils excavation may not be adequate
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to prevent further leaching of contaminants into the ground water,
particularly, if these areas remain undeveloped and are exposed to rainfall or
landscape irrigation infiltration. The installation and periodic maintenance of
an asphalt cap on the excavated area may limit, albeit not eliminate, this
potential problem.
Response: The comment is correct that contamination exists deeper than 5-15 feet
deep. EPA was trying to convey that there was little chance for exposure to
surface contamination, and that most of the contamination was located !U
!u.I15-15 feet deep below the ground surface. Unfortunately, that was not
how the Proposed Plan read.
2.
We are concerned that certain contaminants in the existing former disposal
reservoir may continue to migrate downward to the groundwater owing to
the potentially high liquids content of some of the sludges that were
deposited in the reservoir. The installation and periodic monitoring of a soil
moisture Iysimeter network adjacent to and beneath the disposal reservoir
(the latter via angled borings) may alleviate this concern.
Response: EPA appreciates the commenter's concern regarding potential leaching
of contaminants into the groundwater from the disposal reservoir. EPA has
been monitoring the groundwater beneath the site, and will continue to
monitor the groundwater until a groundwater remedy is selected. Since the
site has been inactive for almost 30 years, EPA feels that once the
infiltration of surface water is eliminated, the likelihood that any contaminant
leaching will occur is small.
3.
We are concerned that the ground water quality monitoring to be
implemented as part of the proposed soil remedy is not to be considered as
the final ground water remedy. To this end we intent to take an active role
in reviewing and commenting upon data generated from the proposed ground
water monitoring program and to work with EPA to develop groundwater
protection strategies that will ensure groundwater quality in a cost-effective
manner. .
Response: Since EPA has not been able to determine that the WCI site is the
source of contaminated shallow groundwater, EPA postponed the decision
on a groundwater remedy until more data could be collected. The
requirement for sampling as part of this remedy is to ensure that the selected
remedy is not adversely impacting groundwater quality; it will also provide
information for future groundwater actions. Also, since wastes will be left in
place, sampling is a closure requirement, and is necessary for conducting
five year reviews.
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3.4 Department of Toxic Substances Control Comments to WDI Proposed Plan
1.
Regardless of the alternative selected as the final remedy, it is expected that
some contaminated soils will be left in place at the reservoir area and some
surrounding areas at the site. Up to the present, no deed restrictions have
been imposed on any parcel. However, the Department would require a
voluntary deed restriction be recorded to limit the use of these areas.
Health and Safety Code Section 2522.1 authorizes a landowner to agree
voluntarily to a deed restriction on the property. However, if a landowner
refuses to agree to a deed restriction, EPA or the State should require the
landowner to clean up the contaminated areas and restore them to
residential land use.
Response: Institutional controls are part of EPA's selected remedy. During the
design of the remedy, EPA hopes to negotiate appropriate restrictions for
each parcel of the site. If we cannot reach an agreement on voluntary
restrictions for each parcel, the State has the authority under 125220 et seq.
of the Health and Safety Code to make a determination that a particular
property should be designated as "hazardous waste property" or "border
zone property", with subsequent restrictions imposed on those properties.
2.
The Department has determined that the design of the RCRA equivalent cap
for Alternative 3C as illustrated in Figure 3 of the Proposed Plan is
inadequate. Potential problems that have been identified and/or
improvements that can be made are presented below:
a. The location of the consolidated excavated soils in the cap is too
shallow and does not allow any buffer zone or safety factor in the
event of accidental or intentional penetration; and/or cracking/breaking
of the asphalt cap and flexible membrane liner. As you know, some
of the proposed excavated soils are contaminated and exposure could
result in health risks.
b. To minimize the exposure to the consolidated soils, it is suggested
that the consolidated soil be buried as close as possible to the waste
material by first removing some of the current 5-10 feet soil covering.
c. Laying the asphalt directly over the flexible membrane liner is not
advisable for the following reasons:
(1 )
There is a possibility for the flexible membrane liner to
tear should the asphalt crack or break which could occur
during a major earthquake or as a result of subsidence.
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(2)
The flexible membrane liner may be damaged during
installation by the heavy equipment rolling over the
surface and from sharp stones lying next to the
membrane liner. Generally, a layer of fine soil or sand is
placed on the top and bottom of the membrane liner for
protection. The soil layer also serves as a drainage layer
and gas vent layer.
Response: EPA has included your recommendations in the description of the
selected remedy. EPA will require that the excavated soil be placed under
clean fill already located on the site. The clean surface fill will be scraped
back in order to provide room for the excavated material. However, it is not
advisable to expose the contaminated soil any more than necessary, so the
excavated contaminated soil will be placed at least two feet below the
ground surface, but will probably still remain above the unexcavated
contaminated soil.
In response to the construction of the cap, EPA has decided to call out only
a performance standard for the impermeable cap, so that issues like those
brought up by the State will be addressed during the design of the cap. EPA
recognizes that these issues are best addressed at that time.
3.
DTSC does not object to a different type of cap other than that proposed in
Alternative 3C, provided the remedial response objectives are maintained,
i.e. . ...to protect against and minimize the release of hazardous pollutants,
or contaminants so that they do not migrate and cause substantial danger to
present and future public health and welfare or the environment. n
Response: EPA agrees that any remedy must be protective, and EPA's selected
remedy will meet the remedial response objectives and be protective.
3.5 Bear, Kotob, Ruby & Gross, on behalf of Dr. Adeline Bennett
Dr. Bennett .would like to see a higher degree of environmentally friendly
landscaping techniques employed in conjunction with the asphalt cap. n She
is also concerned about the degree of pollutants that may become airborne
in any excavation of the perimeter properties. . . . At this time, Dr. Bennett
objects to the transportation of such contaminates into a centralized
collection area, as proposed. Dr. Adeline Bennett does not wish to waive
any rights at this time, but stands ready to cooperate and entertain any
proposal the EPA may propose.
Response: EPA intends for any landscaping that is done on the site to be
environmentally sound, which will include low water consumption. We
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share Dr. Bennett's concern that airborne contaminants may be released
during the excavation, and will take precautions to minimize any release and
the impact of the excavation to local air quality.
Dr. Bennett has stated that she objects to the consolidation of the
contaminated soils in the central property. The comment does not offer a
specific basis for that objection. To the extent that the objection is based on
a theory that the consolidation would constitute a taking under the Fifth
Amendment, EPA reiterates and incorporates by reference the response it
provided above to the comment made by the Pitts Grandchildren's Trust on
this issue (See Section 3.1 B). While EPA recognizes that the current
property owners may object to the consolidation of contaminated properties
onto the central portion of the site, that option 18 considered the most cost
effective. and will remove contaminated soil from other parcels they own. as
well as from other parties. in order to make the excavated parcels potentially
useful for future development. An alternative that would leave all
contaminated soils in place with a cap over the property would significantly
impair the future usefulness of the various properties.
3.6 State o( California Department o( Health Services
1.
Ensure that the cap. whether it is the proposed RCRA-equivalent cap or a
clay/green cap, adequately covers the waste so that casual physical
disturbance of the cap can not occur.
Response: EPA will ensure that the cap is protective and adequately prevents
physical contact with the underlying contamination.
2.
Ensure that the cap, whether it is the proposed RCRA-equivalent cap or a
clay/green cap, adequately covers the waste so that water may not
penetrate into the waste material.
Response: EPA will require that the cap meet an impermeable definition of
10.7 centimeters/second. -
3.
Ensure that the integrity of the cap can adequately withstand the strong
seismic activity that has occurred in southern California and is predicted for
the future.
Response: EPA has added seismic ARARs called out in the California Hazardous
Waste Control Act. Title 22 CCR. 166264.25 (b). Seismic Design Standards.
4.
Adequately maintain the fence in order to prevent public access to site.
especially during future site disturbances when waste material is exposed.
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Consider building a taller sound barrier-type fence along the side of the site
adjacent to the school.
Response: During site activities, the site will be secured. In addition, a
supplemental wall will be considered during design 01 the remedy, at which
time the EPA can discuss the options with the City of Santa Fe Springs, the
community, and St. Paul High School.
5.
Conduct real-time air monitoring and air sampling before and during site
disturbances, especially during the proposed soil excavations. Monitor and
sample the air that is within the human breathing zone as well as on
rooftops. Monitor for volatile organic compounds and particulate-associated
compounds. Take samples during the site activities separate from samples
taken during the time when no site activities are occurring. Include in the
remedial design workplan a worker health and safety plan and a residential
contingency plan that require certain health protective steps be taken based
on the levels detected in the air monitoring and air sampling.
Response: EPA will conduct air sampling during site activities as suggested.
6.
Ensure that the remedial action will involve collection and treatment of
subsurface gases. The microbial production of gases other than methane
may pose a long-term health concern to the employees working in the on-
site buildings. Even if there is not enough methane to light a flare, another
method of treatment may need to be considered.
Response: Consideration of treatment other than flaring is included in this
decision, if a treatment option is required.
7.
Address in the remedial design the following concern: although the waste
material has not yet migrated laterally through the soil column, the addition
of a cap may provide an additional force that would encourage lateral
migration. If not taken into the account, the waste may surprisingly appear
in the school's athletic fields or ooze through holes or cracks in the
foundations of the on-site buildings.
Response: EPA will take these concerns into account during the design of the
remedy to ensure that the remedy does not encourage migration of
contaminated soil from under the capped area. . .
8.
Require adequate institutional controls to ensure that there will be no
penetration of the cap for development purposes. Deed restrictions that
prevent digging or excavation of subsurface soils rather than a simple notice
on the deed should be included as a part of the institutional controls.
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Response: EPA will negotiate institutional controls with property owners that will
be protective for any anticipated actions. Please refer to Section 10.8 of the
ROD for a full description of the anticipated restrictions.
9.
Require adequate institutional controls that prevent current owners or future
owners for those commercial parcels with underlying waste material from
carrying out activities which entails penetrating the subsurface soil and
disturbing the waste material.
Response: EPA will negotiate institutional controls with property owners that will.
be protective for any anticipated actions. Please refer to Section 10.8 of the
ROD for a full description of the anticipated restrictions.
10.
Inspect the cap and surrounding area on a regular basis to ensure that the
cap is intact, there is no spread of the waste material, and the institutional
controls are working.
Response: EPA's selected remedy requires annual sampling and inspections.
11.
Circulate the remedial design plan (including the worker health and safety
plan and the residential contingency plan) to CDHS for public health review.
Response: EPA looks forward to working with CDHS in the future, and will provide
material for their review, and endeavor to include them in any future
community discussions.
3.7 City of Santa Fe Springs
1.
The City's preferred alternative is to have the site completely free of
contaminated soil. Implementation could be accomplished by excavating the
soil and hauling it off-site for proper disposal or remediation. This solution
would then allow unrestricted development of the site, and would totally
alleviate any potential problems of human exposure to the contaminated soil.
Response: As explained during the Public Meeting, this alternative was evaluated
by EPA and determined to be very costly for a subsequent small reduction in
the long-term risks posed by the site, while increasing the short-term risks.
Since the volume of contaminated materials is very large, the risks posed by
them fairly low (almost within what EPA considers safe for residential use),
and the estimated cost $120 million, complete removal is not considered a
feasible option.
2.
If the above excavate/haul alternative is deemed cost-prohibitive, then in-situ
bio-remediation of the organic and hydrocarbon constituents of the waste
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:---
should be accomplished, and the remaining metal constituents be
immobilized through chemical fixation. This solution would significantly
reduce potential human exposure, and the site would have less prohibitive
restrictions on development.
Response: As explained during the Public Meeting. the main risk posed by this site
is due to the presence of arsenic, a natUrally occurring metal in California
soils. Arsenic poses a cancer risk, and can be toxic or have non-cancer
health effects at high levels. For soil micro-organisms, arsenic can be toxic,
and will kill them when they come into contact with the contaminant. For
this reason, bio-remediation is impractical for this site.
As for chemically fixing the arsenic and other metals found in the soils at the
site, this process involves mixing the contaminated soil with materials to
basically" cement" the metals so that they cannot leach out. The mixture
that is used to "fix" the soil must be carefully determined. so treatability
studies must be done to formulate the chemical mix. The fixation process
cannot be done while any bio-remediation is taking place, so the treatment
would have to wait until the bio-remediation is complete. The soils would be
treated on-site, but would probably require excavation (unless the treatment
process could be performed in-sitU) and replacement once treatment was
completed. Since the volume of contaminated soils is estimated at 750.000
yds3, and at a minimum, the cost of treating the soils is estimated at
$100/yd3 (from EPA technical staff estimates), the cost of this remedy
would be approximately $75 million. This process would prevent the metals
from leaching into the groundwater, but would still require restrictions on
future use. This same result can be achieved by EPA's selected remedy at a
much lower cost.
3.
With regard to the peripheral contaminated properties, the City-preferred
alternative is to bio-remediate the contaminated soils or excavate these soils
and haul off-site for remediation. This action would alleviate the need of
transferring the contaminated soil to the reservoir grounds, and consequently
would allow the site to maintain its present topographical appearance.
Response: See above comment for a discussion of bio-remediation. As for hauling
excavated soils off-site, this option was evaluated, but was discarded
because it raises the cost of the remedy significantiy without providing
appreciable, additional risk reduction. Since the area proposed for
consolidation is already contaminated and includes the reservoir. the
consolidation would not greatiy increase the risk posed by the reservoir area.
During consolidation and site grading, EPA will endeavor to maintain the
site's current topographical profile, since the site is not smooth and flat at
present.
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4.
In some places the depth of clean uncontaminated cover soil is reported to
be at least 15 feet. Upon completion of remediation the site should be
regraded to lower the overall height of the mound as much as possible.
Response: The current site mound height is mainly due to the presence of the old
concrete reservoir. and the clean fill covering it. It would not be desirable to
remove this soil cover. which would expose the disposed material in the
reservoir. in order to flatten the site topography. However. every
opportunity will be taken to fill in holes, and minimize the slopes on the site.
But since the concrete reservoir is above the level of the street. the site will
retain a higher profile than the surrounding properties.
5.
Prior to the issuance of the Record of Decision the City requests that EPA
establish the topographical profile of the site before and after completion of
remediation. Knowing the final physical appearance of the site will assist the
City in commenting on the plan as regards future development opportunities
00 the site.
Response: Current site profiles are available in the Final Groundwater
Characterization Report of May 1989. Figures 2-7 through 2-9. A
topographic map of the site can also be found. in Figure 3-2. Expected
topographic profiles for the remedy can be included in the design work.
6.
Prior to the issuance of the Record of Decision the City requests that EPA
reveal the nature of the deed restrictions at the site upon completion of
remediation and to which properties the restrictions will be applied.
Knowing this will assist the City in commenting on the restrictions and
perhaps recommending alternatives.
Response: As explained in Section 10.6 of this ROD, deed restrictions will be
negotiated with site property owners. Specifics of the restrictions will be
made at that time. but in general, will follow the outline in Section 10.8.
7.
After the site is remediated we recommend that the current fencing along
the northern boundary of the site (particularly along the St. Paul's High
School property) be replaced with a concrete block retaining wall of
sufficient height to restrict the view of the site from anywhere on the
school's property, and of sufficient height to discourage students or others
from climbing the wall. Furthermore, the school should be generally
consulted in this matter so as to express its concerns regarding the wall's
appearance and any landscaping that may be done.
Response: We have included the design option of a block wall or fence as part of
the selected remedy. The exact configuration of any fence will be
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determined during the design phase of this project, and will include public
discussion of the issue. It may not be necessary to construct a fence,
depending on the final configuration of the cap, if current trees remain aher
construction of the remedy. .
8.
EPA should place a gravel trench adjacent to St. Paul High School to act as a
barrier to migration of methane gas. This is a precaution which has been
required elsewhere in the City adjacent to landfills.
Response: This suggestion has been included as a design option of the remedy
decision. The exact configuration and function of the trench, if any, will be
determined during design.
9.
In those areas where the asphalt cap is not applied and where development
cannot take place (e.g., along the slope of the mound), the City requires
some sort of low maintenance landscaping to reduce the possibility of
unsightly weed growth.
Response: Areas that will be capped with vegetation will be landscaped to be low-
maintenance. However, slopes may be paved with asphalt if that is the
desired configuration of the cap. It is possible to pave on grades up to 50%.
10.
EPA should better define and prepare a plan showing where and how surface
water run-off from ~he site will be collected and disposed.
Response: The final design for the surface of the site will include uniform run-off.
Surface water run-off will be directed to the storm sewers. Since the run-off
will not be in contact with contaminated material, it will not be necessary to
collect and dispose of it.
11.
When weed abatement is permitted by EPA at the site prior to remediation,
the City should be advised in advance of the work, and dust suppression
should be used during the work.
Response: This has in the past been the usual operating procedure. However,
EPA was not notified prior to the last weed abatement work that was
performed at the request of the Fire Department of the City of Santa Fe
Springs. The Los Angeles County Weed Abatement Program Project
Manager was out of town when the request was received, so the work was
begun without EPA notification. There should probably be only one more
weed abatement prior to the implementation of the selected remedy.
However, for any future weed abatement activities, better communication
within the City's departments as well as with EPA will prevent further
misunderstandings. As for dust suppression being used during any weed
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abatement, though not necessary, may be possible. and will be discussed
with the LA County Project Manager before the next abatement is begun.
12.
There are numerous unmarked and unsealed barrels containing unknown
substances on the site. The presence of these unmanaged barrels pose a
potential fire and safety hazard, as well as a public nuisance. EPA should
address the management of these barrels immediately, and not wait until
remediation is under way.
Response: These containers were addressed in a letter to the City of Santa Fe
Springs dated November 4, 1993. The containers were evaluated by EPA
during the removal action taken in March 1988. The containers were
determined to contain non-hazardous waste material that did not qualify for
action under EPA removal authority. These containers will be addressed by
EPA's selected remedy.
3.8 Albert L. Sharp, Mayor Pro Tem, City of Santa Fe Springs
". . ~ Environmentally Safe Products Corporation (ESP) has contacted my office and
made me aware of the option of using biodegradable products to promote
degradation of contaminates. ESP also believes that they have environmentally
safe products which could be used to fixate, in place, the non-biodegradable
contaminates and to seal the surface of the site. . . . In assessing the alternatives
and before selecting the final WCI clean up strategy, EPA should give further
consideration to the new technologies which may be available in the marketplace.
ESP represents the type of approach which may provide EPA, The City of Santa Fe
Springs, and a surrounding property owners with a more cost effective and minimal
risk alternative. "
Response: Please see the response to the City of Santa Fe Springs comment on
bio-remediation and chemical fixation. EPA contacted Environmentally Safe
Products Corporation to investigate their proposal for remediating this site.
The materials we received are included in this Responsiveness Summary.
EPA feels that the proposal received by ESP was inadequate, and could not
use it to determine the effectiveness of the proposed processes. EPA did
not receive any information concerning past successes with the ESP
processes, nor any participation by a regulatory agency, EPA or state. In
addition, the materials EPA did receive (mainly the Material Safety Data
Sheet for the soil sealer) show that the material is 100% water soluble,
which would not be desired to keep water from infiltrating the soil. Since
the proposal required the use of unproven technologies, its selection would
require extensive treatability studies and evaluation, during which no other
remedy would be implemented. EPA feels that its selected remedy is the
most cost effective, protective measure currendy available.
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3.9 Phil Campbell
If. . . I am very supportive of your Number 3C proposal. I would hope that this
proposal will be decided upon and initiated within a short time! . . . I would
appreciate it if you could give me a time frame as to when we could expect to have
the contamination removed and what those specific plans are'"
Response: EPA hopes that work on the design will begin in early 1994. Once the
design is underway, EPA will conduct additional public meetings to discuss
the schedule and progress of the project.
4.0 Public Meeting Comments
During the Public Meeting of September 1, 1993, a court reporter was present to
provide a transcript of the meeting. EPA received several questions and comments
on the Proposed Plan and general site conditions. Many 01 these comments have
already been addressed in Section 2.0 of this Responsiveness Summary, Major
Issues and Concerns. EPA feels that the following comments received during the
Public Meeting (page numbers are those 01 the transcript) warrant a specific
response.
4.1 Page 24, line 3, Mr. Sharp
If . . . why would not the fence be moved back to the green area (capped area on
overhead) so all the white area, which had been excavated and the impurities
removed from the soil, be able to be open for development?"
Response: The area that will be capped, and the area to be excavated, are both
private properties. EPA's selected remedy requires that the cap be put in
place to prevent direct exposure to the contamination and prevent rainwater
infiltration. The restrictions on the property require that site activity be
compatible with the cap design and that cap integrity be maintained. If the
owners of the properties feel that this can be met with a fence, a fence can
be placed around the entire cap. However, If the property owners wish all
their property fenced, that is also their option. While the excavated
properties will be free from development restrictions imposed by EPA, it does
not necessarily follow that the properties will actually be developed.
4.2 Page 41, Father Gallagher, Principal, St. Paul High School
". . . it does strike me as a little bit strange that we already have a city government
empowered to make decisions for the people within the City, but that the EPA
would come in and become more restrictive than you feel that the City of Santa Fe
Springs would be with our already elected officials, and you would put something--
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you would force the city to comply beyond just the normal level of concern that
the people who live right here in the City would already have about what is going
on in the City. . . The second thing is .- it has to do with the whole idea about the
word contamination is that, you know, there's a lot of parents here who have
children who go to St. Paul, and when people think contamination, I think that a lot
of times they're thinking about nuclear contamination, the threat of what is
airborne, what is soil-born, and I was led to understand in our conversations that
actually that whatever contamination there is really a metallic contamination from a
very minor kind of a normal industry output like oil, sludge that was a part of what
was going on here, and actually that will not ooze from one piece of property to
the next piece of property without any kind of a major catastrophe. II
Response: EPA's authority to respond to actual or potential environmental health
risks was granted by the United States Congress under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) of
1980, also known as Superfund. This law was amended in 1986 by the
Superfund Amendments and Reauthorization Act (SARA). These laws give
EPA authorities not granted to local governments to address environmental
issues.
Concerning the word" contamination ", it is an accurate term for the
substances found at the WDI site. Though the materials are not nuclear in
origin or pose a radiological hazard, the site is not without risk. While some
of the contamination comes from a "normal industry" like the oil industry,
this does not reduce the hazard to human health. Some of the contaminants
found at the site are potential or known human carcinogens, while others
have non-cancer health effects. We do not want to minimize the potential
dangers of the substances found at the site, nor do we wish to unduly alarm
people. Although current risks are small, eliminating exposure to these
hazardous substances (the "contamination") will funher reduce the risks
posed by the site.
lastly, EPA believes that the selected remedy will adequately contain the
contamination, and that migration of the contaminated materials will not be a
problem. We will monitor the site annually and evaluate the effectiveness of
the chosen remedy to ensure that the selected remedy is performing to EPA
expectations.
4.3 Page 48, line 22, Father Gallagher
". . ./ think there would be some liability on the part of the government for. . .
putting in something where we would be concerned about -- I would always be
concerned about well, what's happening over there which we have no control
over? I would have control over who was on our property, but I wouldn't have
3-21
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control over who is standing on the piece of property above us looking down at the
students who are unprotected. 50, you know, it's simply a question or a
comment, but I do think that there'd (be) some governmental liability if something
were to occur. "
Response: EPA, under CERCLA, has the responsibility to protect human health and
the environmental from potential and actual releases of hazardous
substances. With the implementation and proper operation and maintenance
of the remedy, this responsibility will be met. Since the site is located on
privately owned property, any activities occurring on the site that St. Paul
High School jeopardizes the safety of their studentS are the responsibility of
the property owners. If the integrity of the remedy is compromised, the
situation would warrant EPA attention. However, EPA does not assume any
liability for actions taken by private parties on private property.
4.4 Page 50, line 6, Mr. Sharp
"Why wasn't bioremediation put in there as one of the alternatives? It's a method
we've used successfully of cleaning up some of the oil properties in the City the
City wanted to redevelop during the redevelopment agency. I don't see that listed
as any type of alternative, yet it's probably the most successful method currently
used throughout the world."
Response: Please refer to the previous discussions on the lack of bio-remediation
options for arsenic contamination in Section 3-7, page 3-16. It was
screened during the Feasibility Study and discarded due to the inability to
reduce the main risk at the site.
4.5 Page 54, line 5, Mr. Cabral
"I've worked on the one (methane flare) in Rose Hills, and that makes a lot of
noise. "
Response: The amount of noise will be considered when the design of any flare is
undertaken. However, with the limited amount of methane that is
anticipated, any noise generated at the site should be minimal.
4.5 Page 62, line 4, Ms. Aguilar
"My comment is that. . .we have children playing out there every day hard,
breathing hard, breathing that gas you're going to put up in the air hard right next
to it. I'm talking a few feet from there. Why can't they just clean it? Clean it."
3-22
-------
Response: As stated in the Public Meeting, no gases were detected at the surface
of the site other than typical ambient (local) air. We are concerned that any
site contaminants not impact the students, however, and will investigate
treating gases that are generated at the site, if necessary. However, if the
amount and types of gases that are generated are below acceptable risk
standards, the gases will be emitted into the atmosphere. Any emissions
will have to meet both health standards and California air quality regulations.
As previously explained, the cost of removing the contaminated materials is
too high for the limited amount of risk reduction ultimately achieved. Also,
complete excavation of the site would increase the short-term risks to the
surrounding residents and students, even while meeting all emissions
standards. The additional emissions just from the trucks would be
significant. At present, there aren't any known technologies that can "clean
up" the site.
4.6 Page 66, Father Gallagher
"I would like to say that we are very appreciative of the work of the EPA. . .If in
conjunction with the City of Santa Fe Springs, who we believe are responsible
individuals elected by the members of the City, that something should be decided
to be done on that property, that we would prefer that nothing would be above the
level of the property in terms of business where we would have to be concerned
about the safety of the students at some future date based on a decision of
somebody other than us about who is going to own that property or use that
property or we would want something, for example, a wall or the government to
provide some kind of protection so that we would not have to be concerned about
the safety of our students, so if we had a comment to make I would think that it
would be that we would prefer that it not be asphalt, that it would remain exactly
the way it is, and if there is absolutely no problem right now and if I could build a
house there that I could live on for 70 years with no problem, well, then I would
just as soon see that things be left as they are right at this moment."
Response: EPA has taken your comment into account regarding public discussion
of future uses of the site, as well as having a design option for a wall or
enhanced barrier between the site and St. Paul High School. As for the
safety of the students being jeopardized by any activities on the site in the
future, EPA cannot at present envision any such activity that would be
allowed and also protect the integrity of the cap. Also, the final
configuration of the cap will be decided during the design phase, and the
public will be able to comment and contribute their opinions to the final
appearance of the site.
3-23
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4.7 Page 67, line 6, Mr. Sharp
"Along with Father Gallagher, I as a City Councilman in this City have no desire to
see anything happen on that site as far as a storage yard or anything. I think every
member of the EPA in this room knows how I feel about putting asphalt down. I
don't want to see a black or a green mountain. As far as I'm concerned, if there's
nothing wrong with the soil, why don't we just plant wild flowers over it, make it
as aesthetically pleasing to the community as we possible can and let that sleeping
dog lie if there's no -- all we're doing is just covering it so someone can come in
and set some tractors and trucks and travel trailers and whatever else on it. No,
I'm not in favor of that."
Response: As previously discussed. the final use of the property will be decided
upon by EPA, the City of Santa Fe Springs, and the property owners, along
with contributions by the general public. The possibility of a "green" cap
has been evaluated. and the limitations of this type of cap. mainly the ease
with which it can be pierced, was also presented at the Public Meeting. The
final configuration for the surface of the cap will be decided upon during
design. with community involvement throughout the process. and can
include some "green" cover."
4.8 Page 68, line 20, Ms. Calderone
". . . my comment and concern basically goes back to seismic activity. I have
children that go to St. Paul. If we have a major catastrophe - it could be today.
tomorrow, ten years from now -- my kids have to go out there on that field. Is
there any warning signs. bells or something to say that. you know. there is toxic
waste going out in the air, methane gas? Are they going to be exposed and
harmed by this if they're out there in the field? I mean what is the limits to where
they would be exposed?"
Response: EPA has included seismic requirements into the selected remedy. In the
unlikely event that there is a major exposure of the contaminated materials
at the site, the risks would still prove fairly small. since the highest risk from
the site was long-term. direct exposure to the contamination for residents on
the site. Since there are no residents living on the site, the risks are less for
the students attending St. Paul High School next door.
4.9 Page 70, line 12, Mr. Calderone
"You're talking about putting the daisies and everything. 15 there any way that you
can put a nicer looking fence instead of barbed wire or a higher fence?"
3-24
-------
Response: Once the remedy construction is completed, there will be no
requirement for fencing the site, unless it is determined that a fence is
needed to protect the cap. Otherwise, any fencing would be at the
discretion of the property owners. EPA has included a block retaining wall
as a design option for the remedy that may be placed between the site and
St. Paul High School.
4.10 Page 72, line 4, Mr. Moreno
"And there have been reports of odors. I don't know how many people have
gotten sick. There's been - there have been those reports. II
Response: EPA has had only anecdotal evidence of any odors emitted from the
site in recent history (since the site was closed and covered with soil). We
have also not received any notice that anyone has been made ill from the
site. Since no emissions were detected at the site, we can only conclude
that the site is not currently the cause of illness or source of odors. The
reports referred to reports of a "gas cloud" observed after an earthquake.
However, this observation was disputed by the principal of St. Paul High
School as having originated at another site, upwind of WCI and the high
school.
4.11 Page 74, line 1, Mr. Lazaretto
"Some work beforehand should be done to make representation of how -- how the.
site will look given the fact that more earth is going to be placed on top so that
there's some good idea so people can make, I think, an informed decision of how
it's going to look ultimately,"
Response: A representation of the final appearance of the site will be made during
the design phase of this project. Various options should be presented at that
time for public evaluation and comment.
4.12 Page 77, line 11, Father Gallagher-
"I think that some people have indicated here this evening that they're confused. If
you will not take away everything that is on the property right now, why would
you ever accept that we would want you to dig in some of the area that you
consider contaminated and put that contaminated soil on top of five feet of soils
that is not contaminated and then guarantee us that that is going to be protected
by whatever you do with it when you're using the argument that it would be safer
for us to not -- not to touch -- not to move it from that area at all1 So that's why I
think that there has to be a clarification about the word contamination because I
have been led to believe that we're using the word contamination, and there is
3-25
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probably a possibility of contamination on that piece of property that might not be
any different than the back yard of somebody in Santa Fe Springs in some areas of
contamination. "
Response: EPA's selected remedy proposes moving some of the contaminated
material that is more readily accessible and consolidating the contamination
into a smaller area. This excavation and consolidation will be performed
under carefully controlled operations to limit contact with the contaminated
soils, so the workers will be exposed to minimal risks. Dust suppression will
be used to protect non-workers as well. In order to provide more protection,
the surface soil in the consolidation area will be partially removed in order to
provide a thicker protective barrier betWeen contaminated soils and the
surface.
Although some of the contaminants found at WDI are also found in the
background soils in the Santa Fe Springs area, they are found at the site at
greater levels than is considered healthy. They are also found at levels
higher than background, so in that respect are not like backyard soils. There
are also contaminants that are not found in the background, and are present
as a result of previous industrial activity at the site. The excavation will be
performed to remove the contaminated soils of the sumps to the protective
levels established in the Section 10.1 of the ROD.
4.13 Page 81, line 13, Brother Dennis
"My concern is that's a fairly ugly looking thing, and I obviously would be more -
the green field is obviously more pleasing to look at. "
Response: Thank you for your comment. We will consider aesthetics during the
design phase of this project.
4.14 Page 86, line 7, Father Gallagher
"One comment, and it would be a very brief one, is that I'd like to reiterate that the
position of the school is that we'd be very reluctant to have any business up above
the level of the school yard where we would have to be concerned about the
safety of the students and always be wondering well, who was going to be looking
down on them since -- since the field is used for a lot of different activities, so this
is a different safety, so I would hope that the EPA would also allow for that if
they're going to be making some kind of improvements in the area."
Response: As previously stated, final uses for the site will be determined during
the design phase of this project; we will try to address concerns similar to
those stated in the comment at that time.
3-26
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r---m
ATTACHMENT A
-------
WRITTEN COMMENTS
-------
STATE .OF CAUFORNIA - CAUFORNIA ENVIRONMENTAL PROTECTION AGENCY
PETE WILSON. Governor
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
1011 N. GRANDVlEW AVENUE
GLENDAlE. CA 91201
(818) 551-2800
@
september 9, 1993
Mr. Rusty Harris-Bishop
u. s. Environmental Protection k;Jerr:Y
Region 9 - SUperfun:i, H-7-2
75 Hawt:home Street
San Francisco, CA 94105
Dear Mr. Harris-Bishop:
WASTE DISREAL, DIC. FEASIBIIJ:'lY S'lUDY ~ FCR OOIIS AND ~.tH.IKYACE GAS
'!he Department of Toxic SUbstances COntrol (Department) has ccmpleted
the review of the subject report dated August 2, 1993 an:i have the follCltliIg
general arxl specific ~.
1.
'!he Department has in the earlier OJl,u,_ld:s to the draft Feasibility
Study (FS) Report stated that the acronyms STICs arxl T1'I.Cs were not
correctly used arxl could mislead the reader. '!hey are still fourd in
certain places in the final FS to imply that if they are below STICs
amjor Tl'ICs, they are not hazardous. As stated in the Health & Safety
COde Section 66699, STICsj'lTICs are used to ~ if any waste is
hazardous waste or not (Un::ierlined for emphasis. See the definition for
waste) .
2.
'!he Department is concemed with ~ ccntam:inated soils left in place,
regardless of the alternative selected for the final remedy. '!he State
has regulations on larxl use arxl definitely require sane fom of deed
restrictions placed on the main reservoir arxl ~ other areas that have
contaminated soils if they do not meet the requirements for an
unrestricted lan::l use. Unr€:::>LLicted larxl use means that the larxl must
meet the risk criteria for residential larxl use.
3.
In relation to concerns presented by the cammmity with re;rcmis to
seismic activities, the follCltliIg regulations should be considered as
ARARs am be taken into consideration durin:;J the design phase:
a. CCR Title 23, section 2547 which states that structures which cunlLul
surface drainage, erasion or gas should be designed to withstani the
Maximum Credible Earthquake (MCE) without damage.
b. CCR Title 22, Section 67108 Which states that caver systan arxl
contairunent control features features should be designed to withstand
the MCE without the level of public health am eJWllOllne1ttal protection
afforded by the original design bein;J dec:reased.
c. CCR Title 67418 which states that the CCNer be designed to
a~IIII.oJate the forces of earthquakes.
-------
Mr. Rusty Harris-Bishop
september 9, 1993
Page 2
4.
'Ihe DeparbDent Wcu1d like to make a few minor OCub::llts on the it; ~1~c:ion
on the risk aC!~'-'~ so they will reflect the current 1:hin1d.rxJ on this
subject:
a. In the 3rd para<;rali1 of section 1.12, the risk were based on the
average (gecmetric mean) of the cxmtaminant oonoentration. DISC
generally uses the 95% ~ Confi.der¥Je Level for this value.
b. In Table 1-9, the age am the average weight given fits a "Student"
better than an "Off-site 1Idu1t Residents".
c. 'n1e ~t"l'Ml AbsoJ:ption Factors used were lower than c:m::rently
aooept:able values. For exauple, the demal absoJ:ption factors for
Carcinogen PAHs am PCBs were stated as 0.02 am 0.07, :respectively. '!he
values used in the Dl'SC PIeliminazy Guidance Manual (7/29/93) were 0.20
and 0.14 , :respectively.
d. In Table 1-13, the FRG for lead waS indicated as 500 1Ig/kg.
Presently acceptable levels are 130 ~.
5.
Section 1.6, 1st paragrat:b. Typo. '!be Grc:JurXiwater Elevation Map is
shawn in Figure 1-4 and net in Figure 1-5 as stated in the text.
If you have any questions, please call me at (818) 551-2880.
Sincerely,
aG~.~ y
Amancio Sycip .
Site Mitigation Branch
cc: Hamid Saebfar .
Department of Toxic SUbstances COntrol
1011 N. Gran:iview AverD.le
GlenJale, CA 91201
Dr. I..al lENy
Department of Toxic SUbstances COntrol
1011 N. Grandview AverD.le
GlenJale, CA 91201
-------
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CONSJ1WCT1ON
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San Diego
San Fr8DCisa)
september 9, 1993
Feder.al Express
Mr. Rusty Harris Bishop
U.S. EPA, Region IX
75 Hawthorne street
San Francisco, CA 94105
Re:
Public Comment on Preferred Alternative
Waste Disposal. Inc. Superfund site
Our File No.: 1353-01
Dear Mr. Harris Bishop:
On behalf of the Pitts Grandchildren's Trust, we make the
following public comments with respect to the Waste Disposal, Inc.
(WDI) Superfund site:
A.
RCRA-Eauivalent Cap
1.
Depth of Liner: While the EPA has expressed a desire to
facilitate the reuse of the property where the proposed cap
is to be placed, the present cap configuration prevents
viable economic use of that property. Provision should be
made to place the impermeable liner and the consolidated
excavated soil at a greater depth with relation to the
asphalt surface. Since the consolidated excavated (i.e.,
contaminated) materials lie directly under asphalt and thin
membrane, there is virtually no ability to place the type of
minimal subsurface foundations necessary for likely use.
For instance, any RV parking or other storage uses would
require a series of fence posts and lamp posts which require
shallow subsurface foundations.
2.
Composi tion of Liner: In-depth consideration should be
given to substituting a one foot clay liner in lieu of the
proposed flexible membrane liner now being proposed. Such
a clay liner may be more durable and may serves as an equal
or superior barrier to infiltration of rainwater. The cost
of a clay may also be more economical to construct. If a
synthetic membrane is truly deemed the best alternative,
testing and/or statistical results should be including in
8001 Irvine Center Drive
Suite 900
Irvine, California 92718-1911
Facsimile (714) 7Z7-G656
Telepbone (714) 727..0559
-------
Mr. Rusty
US EPA
september
Page 2
B.
Harris Bishop
9, 1993
the ROD showing durability and
proposed synthetic liner.
longevity
on
the
data
Contaminated Soils
1.
Characterization: If the Preferred Alternative is
implemented, there should be a more complete
characterization of the contaminated soils to be excavated
from the former waste handling areas (e.g. areas 3, 4, 6, 7,
and Toxo Spray Dust area). Upon review of the Final
Remedial Investigation Report (1989), there appears to be an
insufficient number of borings placed in these areas (only
two borings in some areas) and insufficient laboratory
analyses performed. In particular, there appears to be too
little data (e.g., only 3-4 analyses in some areas)
regarding the lateral and vertical extent of volatile
organics, semi -volatile organics, pesticides, PCBs, and
metals.
2.
Movement Across Propertv Boundaries: The Preferred
Alternative contemplates moving contaminated soils onto the
center property partly owned by the pitts Grandchildren's
Trust prior to capping. In the absence of express
authorization from the Trust, this action, regardless of how
logical in the macro sense or how well-intended, constitutes
a trespass. The Trust would like confirmation by the EPA
that it must obtain the permission of the Trust, or take the
property and pay just compensation under the 5th Amendment,
prior to implementing the Preferred Alternative.
C.
Veqetation/Greenbelt Option
As part owners of the area which is proposed to be capped under
the Preferred Alternative, the pitts Grandchildren's Trust
strenuously objects to any vegetation or greenbelt option which
would make business ventures on the central property impossible.
The EPA should continue its prior commitment to work hard in
order to implement a remedy which allows for the maximum economic
use of the property. A vegetationjgreenbel t option would
consti tute a Taking under the 5th Amendment for which just
compensation (i.e., lost profits on a yearly basis indefinitely)
must be paid.
-------
Mr. Rusty
US EPA
September
Page 3
Harris Bishop
9, 1993
We appreciate your time and energy in addressing these important
points and look forward to the written responses.
Esq., R. E . A .
JVV:dlh
cc:
pitts Grandchildren's Trust
Lewis C. Maldonado, Esq. (EPA)
135701 \Corresp\Bisbip.C!H
-------
DIRECTORS
DAN GlASGOW. PRESIDENT
KENNETH M. ORDUNA. VICE PRESIDEHT
ROBERT GOLDSWORTHY. SECRETARY
ClARENCE WONG. TREASuRER
ALBERT ROBlES. DIRECTOR
WATER REPLENISHMENT DISTRICT
OF SOUTHERN CAUFORNIA
JOHN W. NORMAN. GeNERAL. ~R
September 10, 1993
Mr. Rusty Harris-Bishop
United States Environmental Protection Agency
75 Hawthorne Street
San Francisco, CA 94105
Subject:
Proposed Plan for Contaminated Soil and Subsurface Gas
for Waste Disposal, Inc., Santa Fe Springs, California
Dear Mr. Harris-Bishop:
The Water Replenishment District of Southern California (WRD) appreciates the
opportunity to submit comments for your consideration in reponse to the proposed
soil remedy to be performed by the United States Environmental Protection Agency
(EPA) at the Waste Disposal, Inc., site. .
WRD is a special district established under the California Water Code. WRD
manages the groundwater in the Central and West Coast Groundwater Basins of
Los Angles County, which provide a portion of the water supply to approximately
3.5 million people in a service area that covers 420 square miles in southern Los
Angeles County. The Waste Disposal, Inc., site is located wihin the Central Basin.
As you can appreciate, sources of contaminantion that threaten groundwater
supplies are of major concern to WRD.
It is our understanding that the proposed soil and soil gas remedy includes the
excavation of variously contaminated soils in the vicinity of the former 42 million
gallon disposal reservoir, placing and compacting these soils on top of the former
reservoir and capping the combined wastes with a flexible plastic membrane liner
and an asphalt surface seal. The implied intent of double liner construction over the
waste pile would be to minimize infiltration of rainwater and potential leaching of
contaminants into the ground water and to protect the public from direct or
airborne exposure to surface contaminants. A gas collection/venting system with
possible treatment is also proposed to reduce organic gas emissions associated
with the decomposition of some of the waste constituents.
12621 E. 166t/1 Street Cerritos, California 90701
Phone (310) 921-5521 Fax (310) 921-6101
-------
Mr. Rusty Harris-Bishop
September 10, 1993
Page 2
We further understand that ground water monitoring would be required under the
proposed soils remedial plan to evaluate the effectiveness of this remedy relative to
the potential migration of certain waste pile contaminants to the ground water.
The WRD is generally in concurrence with the proposed plan. However, there are
several concerns that we have regarding ground water protection:
1.
The August 1993 EPA proposed plan announcement indicates that the
majority of the non-disposal reservoir contaminated soils occur within 5 to
1 5 feet below ground surface. However the "Preliminary Risk Assessment"
prepared by the EPA contractor, Ebasco (December 1989) indicated that
"The majority of subsoil surface soil contamination was detected at depths
ranging from 10 to 20 feet. n (Ebasco, 1989, p2-35). In addition, a review of
soil sample analytical summary tables presented in the "Final Remedial
Investigation Report" (Ebasco, November 1989) indicates that certain metals,
volatile organic compounds, semivolatile organic compounds, pesticides, and
polychlorinated biphenyls occur at potentially elevated concentrations to
maximum depths of 50, 60, 60, 35, and 35 feet, respectively. We are
therefore concerned that the depth of soils excavation may not be adequate
to prevent further leaching of contaminants into the ground water,
particularly, if these areas remain undeveloped and are exposed to rainfall or
landscape irrigation infiltration. The installation and periodic maintenance of
an asphalt cap on the excavated area may limit, albeit not eliminate, this
potential problem.
2.
We are concerned that certain contaminants in the existing former disposal
reservoir may continue to migrate downward to the ground water owing to
the potentially high liquids content of some of the sludges that were
deposited in the reservoir. The installation and periodic monitoring of a soil
moisture Iysimeter network adjacent to and beneath the disposal reservoir
(the latter via angled borings) may alleviate this concern.
3.
We are concerned that the ground water quality monitoring to be
implemented as part of the proposed soil remedy is not to be considered as
the final ground water remedy. To this end we intent to take an active role
in reviewing and commenting upon data generated from the proposed ground
water monitoring program and to work with EPA to develop groundwater
protection strategies that will ensure groundwater quality in a cost-effective
manner.
-------
Mr. Rusty Harris-Bishop
September 10, 1993
Page 3
We look forward to working with you and your staff in the remediation of the
Waste Disposal, Inc., site. Should you have any questions, please contact me.
Very t Iy yours,
t~
J n Norman
Ge ral Manager
cc:
Central Basin Water Association
Southeast Water Coalition
Harold Morgan (Bookman-Edmonston Engineering)
Tom Regan (Bookman-Edmonston Engineering)
-------
STATE OF CAUFORNIA - CAUFORNIA ENVIRONMENTAl. PROTECTION AGENCY
PETE WILSON. Governor
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
1011 N. GRANDVlEW AVENUE
GLENDALE. CA 91201
(818) 551-2800
@
september 10, 1993
Mr. Rusty Harris-Bishq)
u. s. Emr1.LUUlla::Iltal Protection Aqercy
Region 9 - SUperfun:l, H-7-2
75 Hawthome Sl.&.=:rt.
san Fzancisoo, CA 94105
Dear Mr. Harris-Bishop:
CI:HtEHlS 'It) WAS'JE IJISRSAL, :INC. 1'H.JtU:iW PIAN
'!he Department of Toxic SUbst.aooes control (DeparbDent) has ocnpleted
the review of the subject plan and has the follCMiD;J formal (LJIID'-nts.
1.
Regardless of the alternative selected as the final remedy, it is
expected that sane canta:m:inated soils will be left in place at the
reservoir area and sane surrounding areas at the site. Up to the
present, no deed r=l.&..i.ctions have been i~ on any parcel. However,
the Department would require a voluntaJ:y deed restriction be :reocm:ied to
l:imit the use of these areas.
Health and Safety Cede Section 2522.1 authorizes a 1.amowner to agree
voluntarily to a deej r,==Ldction en the property. ~, if a
lan:iowner refuses to agree to a deed L~l.1..i.ct:ion, EPA or the .State
should require the landowner to clean up the contaminated areas and
restore them to residential land use.
2.
'!he Department has det:emined that the design of the RCRA equivalent cap
for Alternative 3C as illustrated in Figure 3 of the Proposed Plan is
inadequate. Potential problems that have been identified an:1jor
:improvements that can be :made are presented belCJi111:
a. '!he location of the consolidated excavated soils in the cap is too'
shallow and does not allow any buffer zone or safety factor in the event
of accidental or intentional penetration; an:1jor ~ of
the asphalt cap and flexible ~cme liner. As you kncJi,[, sane of the
proposed excavated soils are canta:m:inated and ~ cculd result in
health risks.
b. To minimize the exposure to the consolidated soils, it is suggested
that the consolidated soil be buried as close as possible to the waste .
material by first removin; scme of the c::unent 5-10 feet soil oaverin:].
-------
Mr. Rusty Harris-Bishop
September 10, 1993
Page 2
c. Layin3 the aspmlt clli'ectly aver the flexible membrane liner is net
advisable for the followin3' reasons:
(1) .
'!here is a possibility for the flex;ible ~ane liner to
tear sha11cl the ~t crack or break Wich coold cxx:ur
c:h1riD;J a major earthquake or as a ~t of subsidence.
111e flex;ible ~ane liner may be damaged d1.1rin;J
installation by the heavy ""J1ipnP11t ro1.1inJ over ~ surface
am fran shaJ:p stones lyin;J next to the membrane liner.
Generally, a layer of fine soil or sam is placed em the top
am bot:tan of the membrane liner for protection. 'lbe soil
layer also serves as a drainage layer am gas vent layer.
(2) .
3.
DISC does not object to a different type of cap other than that ~.tJCSE!d
in Alternative 3C, p:rcvided the ~i;:l' :response objectives are
maintcrined, i. e. "... to protect against am minimize the release of
hazardous pollutants, or contaminants so that they do not migrate am
cause substantial darger to PI ~Mtt am fut:me p.lblic health am welfare
or the envll::oi4ueut".
If you have any questions, please contact me at (818) 551-2880.
Sincerely,
"'...-'.
; 7'" "
,. . .l:. ,~,{~ - '"-f}---t:'
k/ ~io Sycip
site Mitigation Brand1
cc: Hami.d Saebfar
Department of Toxic SUbstances Control
1011 N. G:raniview Avenue
GleOOale, CA 91201
-------
L.AW OFFICES
BEAR. KOTOB. RUBY ~ GROSS
.,.AILING ADDRESS:
A PRO"£SS'ONAL CORPORATION
POST OFFICE BOX 747
DOWNEY. CALIFORNIA 90241-0747
1084' PAAAWOUNT BOULEVARD, SUITE 302
DOWNEY. CALIFORNIA 90241-3396
TEL.EPHONE (3'0) 923-1207 OR 923-9836
FACSIMILE (3101 823-971iJ2
September 15, 1993
Environmental Protection Agency
Harris-Bishop
75 Hawthorne Street (H-1-1)
San Francisco, California 94105
Re:
Waste Disoosal Inc. in Santa Fe Sorinas - Suoerfund Site
Dear Mr. Harris-Bishop:
I am writing this letter on behalf of Dr. Adeline Bennett,
one of the landowner's concerned with the Santa Fe springs clean-
clean-up projection. Thank you again for taking the time to
explain the details of your proposals and giving her personal
attention.
After extensive discussions with Dr. Bennett she wanted me
to send this communication on to you to advise you that she is in
agreement with your basic concept. She has a few suggestions
concerning the aesthetics. She would like to see a higher degree
of environmentally friendly landscaping techniques employed in
conjunction with the asphalt cap.
Dr. Bennett is concerned about the degree of pollutants that
may become airborne in any excavation of the perimeter properties
which we are informed contain degrees of arsenic, burillium,
chromium and other toxins. Digging up, loading, transporting and
unloading hundreds of truck loads of dirt contaminated with these
toxins would by necessity release some of them into the air. At
this time, Dr. Bennett objects to the transportation of such
contaminates into a centralized collection area, as proposed.
Dr. Adeline Bennett does not wish to waive any rights at this
time, but stands ready to cooperate and entertain any proposal
the EPA may propose.
-------
Environmental Protection Agency
September 15, 1993
Page 2
If you have any further questions concerning this matter,
please do not hesitate to call.
ve~ truly yours,
/,'-",
BEAR, KO~0B UBY & GROSS
A prOfLe~Si a~ forporation
~ ./ !
By ;
GARY .
GLA/lJh
cc: Dr. Adeline Bennett
-------
STATE OF CAUFORNIA-HEALTH AND WElfARE AGENCY
PETE WILSON. Go...-
DEPARTMENT OF HEALTH SERVICES
2151 BERKELEY WAY
BERKELEY. CA 947Q.4-1011
(510) 540-3657
September 21,
1993~
Rusty Harris-Bishop
Remedial Project Manager
u.S. Environmental Protection
75 Hawthorne Street (H-7-2)
San Francisco, CA 94105
Agency
Dear Mr. Harris-Bishop:
This letter is in response to your request for comments on the
proposed plan that addresses contaminated soils and subsurface
gases at the Waste Disposal, Inc. site in Santa Fe Springs
California. The California Department of Health Services (CDHS),
under cooperative agreement wi th the Federal Agency for Toxic
Substances and Disease Registry (ATSDR), is currently preparing a
Site Review and Update document (SRU) on this .site as a fOllow-up
to ATSDR's Preliminary Health Assessment for Waste Disposal, Inc.
released November 15, 1988. The SRU will be forwarded to you for
review and comment after it has undergone ATSDR's review process in
Atlanta.
staff from CHDS toured the perimeter of the Waste Disposal, Inc.
site on March 1, 1993 and June 23, 1993. On September 1, 1993,
Marilyn C. Underwood and Jane Riggan from CDHS, accompanied by
yoursel f and U. S . EPA Communi ty Relations Coordinator Angeles
Herrera, toured the former reservoir area. These site visits and
a review of documents related to the Waste Disposal, Inc. site
resulted in the items listed below, which we would like to bring to
your attention.
We support u.s. EPA's choice of capping in place as described in
the Feasibility Study Report of August 2, 1993, and further
discussed at the community meeting of September 1, 1993. However
we have several recommendations for the remedial design phase:
1. Ensure that the cap, whether it is the proposed
RCRA-equivalent cap or a clay/green cap, adequately covers the
waste so that casual physical disturbance of the cap can not occur.
2. Ensure that the cap, whether it is the proposed
RCRA-equivalent cap or a clay/green cap, adequately covers the
waste so that water may not penetrate into the waste material.
3. Ensure that the integrity of the cap can adequately withstand
the strong seismic activity that has occurred in southern
California and is predicted for the future.
-------
Rusty Harris-Bishop
September 21, 1993
4. Adequately maintain the fence in order to prevent public
access to site, especially during future site disturbances when
waste material is exposed. Consider building a taller sound
barrier-type fence along the side of the site adjacent to the
school.
5. Conduct real-time air monitoring and air sampling before and
during site disturbances, especially during the proposed soil
excavations. Monitor and sample the air that is within the human
breathing zone as wells as on rooftops. Monitor for volatile
organic compounds and particulate-associated compounds. Take
samples during the site activities separate from samples taken
during the time when no site activities are occurring. Include in
the remedial design workplan a worker health and safety plan and a
residential contingency plan that require certain health protective
steps be taken based on the levels detected in the air monitoring
and air sampling.
6. Ensure that the remedial action will involve collection and
treatment of subsurface gases. The microbial production of gases
other than methane may pose a long-term health concern to the
employees working in the on-site buildings. Even if there is not
enough methane to light a flare, another method of treatment may
need to be considered.
7. Address in the remedial design the following concern: although
the waste material has not yet migrated laterally through the soil
column, the addition of a cap may provide an additional force that
would encourage lateral migration. If not taken into the account,
the waste may surprisingly appear in the school's athletic fields
or ooze through holes or cracks in the foundations of the on-site
buildings.
8. Require adequate institutional controls to ensure that there
will be no penetration of the cap for development purposes. Deed
restrictions that prevent digging or excavation of subsurface soil
rather than a simple notice on the deed should be included as a
part of the institutional controls.
9. Require adequate institutional controls that prevent current
owners or future owners for those commercial parcels with
underlying waste material from carrying out activities which
entails penetrating the subsurface soil and disturbing the waste
material.
10. Inspect the cap and surrounding area on a regular basis to
ensure that the cap is intact, there is no spread of the waste
material, and the institutional controls are working.
-------
Rusty Harris-Bishop
September 21, 1993
11. Circulate the remedial design plan (including the worker
health and safety plan and the residential contingency plan) to
CDHS for public health review.
We appreciate the opportunity to provide our comments on the
proposed plan for contaminated soil and subsurface gas at Waste
Disposal, Inc. site. If further clarification is required, please
contact myself at (510) 540-3657.
Sincerely,
fl4-t~
Marilyn C. Underwood~ Ph.D.
Associate Toxicologist
Environmental Health
Investigations Branch
cc:
Ms. Gwen Eng
Regional Representative
Agency for Toxic Substances
75 Hawthorne Street, H-1-2
San Francisco, CA 94105
and Disease Registry
Ms. Gail Godfrey
Technical Project Officer
Agency for Toxic Substances and
Department of Health Assessment
1600 Clifton Road, NE, E-32
Atlanta, GA 30333
Disease Registry
and Consultation
-------
NA TIQNo-WID;
-
. .. ..- -. --
--- -.;.- -- - .
'1111'
CITY OF SANTA FE SPRINGS
AWARe WINNER
L -..-
.' -"~.c...' ..-: :-~~4:..!-~.-",""':"-.4':._"""'~':.~'-- .:.:..-...::.:, .:-.~::':'....~~~.c:~.-.r~:-":"~.- .-r:'~,,-:!:' ~~~.:::.~.=--:..-=-~~:-
11710 TELEGRAPH ROAD. 90670-3658 - P.O. BOX 2120 - (310) 868-0511 - FAX (310) B6~7112
October 8, 1993
Mr. Rusty Harris-Bishop (H-7-2)
United States Environmental Protection Agency
75 Hawthorne Street
San Francisco, CA 94105
Subject:
City of Santa Fe Springs' Comments on EP A Proposed Remediation Plan for
Waste Disposal, Inc. Superfund Site
Dear Mr. Harris-Bishop:
The purpose of this letter is to communicate the City of Santa Fe Springs' comments on the EP A
proposed remediation plan for the Waste Disposal, Inc. Superfund site. We have reviewed the
summary of the plan, and have attended the Public Meeting held by EPA on September 1. We
appreciate your presentation of the plan to the City Council on August 26.
General
Comment 1:
Comment 2:
Comment 3:
The City's preferred alternative is to have the site completely free of
contaminated soil. Implementation could be accomplished by excavating
the soil and hauling it off-Site for proper disposal or remediation. This
solution would then allow unrestricted development of the site, and would
totally alleviate any potential problems of human exposure to the
contaminated soil.
If the above excavate/haul alternative is deemed cost-prohibitive, then in-
situ bio-remediation of the organic and hydrocarbon constituents of the
waste should be accomplished, and the remaining metal constituents be
immobilized through chemical fixation. This solution would significantly
reduce potential human exposure, and the site would have less prohibitive
restrictions on development
With regard to the peripheral contaminated properties, the City-preferred
alternative is to bio-remediate the contaminated soils or excavate these
soils and haul off-site for remediation. This action would alleviate the
need of transferring the contaminated soil to the reservoir grounds, and
consequently would allow the site to maintain it present topographical
a~ce.
AI Fuentes. MayDr. Albeit L. Sharp. Mayor Pro-TmtpoIT
City CDU11t:i1
Men:r:dr:s A. Diaz . Ronald S. Kr:tnr:s . Br:ny Wilson
City M0114grr
Don Powell
-------
Mr. Rusty Harris-Bishop
United State Environmental Protection Agency
October 8, 1993
Page 2
EP A's Preferred Alternative -
RCRA EqJlivalent AS1Jhalt ~p wlLimited Excavation
Comment 4:
Comment 5:
Comment 6:
Comment 7:
Comment 8:
Comment 9:
In some places the depth of clean uncontaminated cover soil is reported
to be at least 15 feet. Upon completion of remediation the site should be
regraded to lower the overall height of the mound as much as possible.
Prior to the issuance of the Record of Decision the City requests that EP A
establish the topographical profile of the site before and after completion
of remediation. Knowing the final physical appearance of the site will
assist the City in commenting on the plan as regards future development
opportunities on the site.
Prior to the issuance of the Record of Decision the City requests that EP A
reveal the nature of the deed restrictions at the site upon completion of
remediation and to which properties the restrictions will be applied.
Knowing this will assist the City in commenting on the restrictions and
perhaps recommending alternatives.
After the site is remediated we recommend that the current fencing along
the northern boundary of the site (particularly along the St. Paul's High
School property) be replaced with a concrete block retaining wall of
sufficient height to restrict the view of the site from anywhere on the
school's property, and of sufficient height to discourage students or others
from climbing the wall. Furthermore, the school should be generally
consulted in this matter so as to express its concerns regarding the wall's
appearance and any. landscaping that may be done.
EP A should place a gravel filled trench adjacent to St. Paul High School
to act as a barrier to migration of methane gas. This is a precaution
which has been required elsewhere in the City .adjacent to landfills.
In those areas where the asphalt cap is oot applied and where development
cannot take place (e.g., along the slope of the mound), the City requires
some sort of low maintenance landscaping to reduce the possibility of
unsightly weed growth.
-------
Mr. Rusty Harris-Bishop
United State Environmental Protection Agency
October 8, 1993
Page 3
Comment 10:
EPA should better define and prepare a plan showing where and how
surface water run-off from the site will be collected and disposed.
Comment 11:
When weed abatement is permitted by EP A at the site prior to
remediation, the City should be advised in advance of the work, and dust
suppression should be used during the work.
Comment 12:
There are numerous unmarked and unsealed barrels containing
unknown substances on the site. The presence or these unmanaged
barrels pose a potential rlre and safety hazard, as well as a public
nuisance. EP A should address the m!ln'tgement of these barrels
immediately, and not wait until remediation is under way.
The City of Santa Fe Springs appreciates this opportunity to comment on the proposed
remediation plan for the Waste Disposal, Inc. Superfund site. We look forward to working.
closely with EP A to finalize this plan to the mutual benefit of all those concerned, and to the
beginning of remediation. Should you have any questions regarding our comments, please call.
Sincerely,
-.,.! ij<~.
,... ~' )
~. .
ROBERT G. 0 J
Director of Planning & Development
cc:
City Council
Don Powell, City Manager
N. Schnabel, Fire Chief
Andy Lazzaretto, Redevelopment Consultant
Andrea R. Abdullah, Environmental Coordinator
Dave Klunk, Environmental Protection Specialist, Fire Dept.
-------
0...':' ":';=:'\,,~\..'......=-:.
CITY OF SANTA FE SPRINGS
-
--- -.:- -- - .
~IIII'
!-'o".'':'::::::: V,,"I"\:':=
11710 TELEGRAPH ROAD. 90670-3658 - P.O. BOX 2120 - (310) 868-0511 - FAX (310) 868-7112
October 8, 1993
Rusty Harris-Bishop (H-7-2)
U.S. EPA, 75 Hawthorne St.
San Francisco, CA 94105
SUBJECT:
Proposed Soils Remedy for the Waste Disposal, Inc. Superfund Site -
Santa Fe Springs, California
Dear Mr. Harris-Bishop:
After reviewing the proposed plan for dealing with the contaminated soil and subsurface gas at
the Waste Disposal, Inc. (WDI) site, and attending the community meeting at the Santa Fe
Springs Ubrary on September 1, 1993, it has come to my attention that there is an alternate
remediation strategy available which the U.S. Environmental Protection Agency (EPA) should
consider. As a result of the publicity surrounding the WDI project, Environmentally Safe
Products Corporation (ESP) has contacted my office and made me aware of the option of using
biodegradable products to promote degradation of contaminates. ESP also believes that they have
environmentally safe products which could be used to fixate, in place, the non-biodegradable
contaminates and to seal the surface of the site. If the representations made by ESP are correct,
the cost to treat the WDI site, both in economic and physical terms could be significantly
reduced.
In assessing the alternatives and before selecting the final WDI clean up strategy, EP A should
give further consideration to the new technologies which may be available in the marketplace.
ESP represents the type of approach which may provide EPA, the City of Santa Fe Springs and
a surrounding property owners with a more cost effective and minimal risk alternative.
Please continue to keep me informed as you make progress on this project. I am very anxious
to learn of your reaction to my comments.
Sincerely,
.-'" I I ." - - I-
.' /; .'. i~J ~tYt4/
, ...t_-'v y. II
Alb~rt L. Sharp \ f
Mayor Pro Tern
cc:
Mayor and City Council
Donald Powell, City Manager
AI fuentes. .Ifoyor. Albert L Sharp. .1foyor Pro-Tnnporr
Ciry' Council
~lcrcedcs"'. Diaz . Ronald S. Kern.. . Be",; Wilson
Dt:r .I/anal["
Dun Puwell
-------
1~ J. ~, '::~
.L.C~...JI
Invlronm.n,.II,
..f. ProduG'..
t':arp.o..tIO"
E"
Fax
Fax
Fax
Fax
Fax
Melling & Shipping A~":
2100 Ruald to Six FlagS E.
ArUngton, TX 70011
Phone: 817-275-5533
Metro; 8172«15-1903
Fax: 817.27S.1311
To; Mr. Rusty Hanfs.Bl8hop FuNo: 4151744.1917
Company: EnVironmental Protection Agency No of pag.. 2
ineludlng this page:
From: Leo Sanders Date: October 18, 1'93
Subject: Project 'Santi Fe Sprtngs"
Per our telephone conversatton this afternoon, I am forwarding to you the one-page
Santa Fe springs information that we discussed. I will have the additional information
sent to you this week.
Please call if you have any questions.
Best regardS,
~
./
Leo SandersIDale English
~
-------
l~]/ 17/::-::'
J.C;~I
Eftvl....Ift...t.lI~
..f. ~.ecluet..
carD...'tO"
E"
PROJECT 'SANTA FE SPRINGS"
The leaching and vaporization of contaminants on the site described into the environ-
ment (Which Includes adjacent rhziospheres and water tables), can only be accom-
plished by methods which involve Mbond breaking-. .complexing- and 8bonding. of
molecular structures.
These methods insure short-tenn and long-term reduction of migration and mobility of
hazardous materials while long-term decomposition and degrading is being accom-
plished naturally by 5011 microbes.
We suggest that through a .plping- process. the 8f100"'- of the waste area be saturated
with a non-toxic siliceous formula which will bond the small particles short-term while
long-term degradalion by enhanced soil microbes is taking place.
The stages would be:
a. Injection of ESP624 (8 siliceous complexing liquid) Into the lowest strata 01 the
contaminated area. This Injection will prevent at least 96% 01 any possible
leaching of contaminsnts.
b. Inoculation of ESP2001 microbes and enzymes into the soil area at 100
gallons per acre. This Inoculation of 8 self-supporting "biomass- will naturally
-break bonds. 01 various molecules and complex atoms of toxic products 80
that they cennot leach.
c. Laying ESP624 on top of this layer of contaminated soli to separate the
biological sandwich.
d. Building of a 8so11 rhziosphere" which will cover the inoculated area, and
Inoculating this soil addition with ESF>2001.
The technology Involved in this Is the forming of natural zeolites, microbial degrada-
tion, and immobilized enzymes. Short term protection is afforded by zeolite formation.
Long term protection is afforded by microbial degradalion and bond-breaking.
10111S/93 . ESP COt'P . Z100 Rd to Six Fl8g8 E. . AttIngton,"IX 70011
P8g8 2
-------
12/06/93
B8:S3
00:
~nYironm.nl.lI~
.... Prod..ct.~
Fax
Fax
Fax
Fax
Fax
~nrDo,_rfO";
E"
Mailing 5 Shi/1I1insJ Add~u;
2100 Roaa to 5ix Flags f!.
ArOngtOn, TX 76011
Phone: 817-275-5533
Metra: 81'-265-19D3
Fax: 817-275.1311
To: Mr. R. Harris-Bishop Fax No: (415) 744.1917
Company: EPA No of pages 5
including this page:
Flom: Leo Sanders D:Jte: December 6, 1883
Subject: SURFACEAl
Mr. Harris-Bishop:
Tne following infonnatlon is for your review per your request.
Best regards,
U r--.
~\;:; .
.~
Leo Sanders
-------
12/06/93
1118:53
002
.....~.....1aIIy
.... ItrocIucts It,'
':. :; " ;: (I Ii II , I () N
December 6, 1993
Environmental Protection Agency
75 Hawthorne Street H-7-2
San Francisco, CA 94105
Attention: Mr R. Harri$-Bi5hop
Dear Sir:
Surfacesl, ESP Corporation's trade name, was originally formulated to seal concrete
and other road base materials, including the sand utilized in making concrete.
It has been approved by the Uniled Slates Department of AgriCUlture for use in certain
food establishments and by the Environmental Protection Agency for the treatment of
concrete where potable water is involved.
Additional information will be furnished on request.
very truly yours,
ES: ~~.~~~ration ~..
./ \ ~
. .- "-
,~" 'x~- . C.t~.....
Leo Sanders
Executive Vice President
~, 1 on R""t.' III $." H/lqs La,:
A.I"I(JtO". TY. 1601 t
tHI7j?7"SS:n
rAX(!:i1/)2I!.1:01
-------
12/06/93
08:53
~
-
-..,&~-
2100 ROM1 ID SI1c RI8p E..
IldingtDn. 'TN 7(J()f 1
ESP Corporation
!nvironmen&8lly SIIf8 p~ Corpor8IiGn
~.' .f7-27$-:J:S33
M8trQ: .f7-:IO~180'
Fax: .'7-ZT6-'",
. '''-"''~'''. . .. . ""''''''''''- . ':..';' .C:..' .. .:. ~ :... ".:" ..:... .
":"MATERIAL 'SAFETY1JAtA~:"$HEti.
. '." '.. '..' :',: .:';".: " '.'" ',.~ '''''''1'....,.......,.", .... "
. .n . .... .. ...
Surfaceal
Non-tDItk EnvIomme,*' s..,.",
--..,
SECTION I: MANUFACTURER I EMERGENCY CONTACT
ESP Corporation, 2100 Road to Six Flags East, Arlington, TX 76011
Emergency Phone: 817-27~6633
Infonnation Phone: 817-27S.5S33
Date Prepared: 416193
SECTION II: HAZARDOUS INGREDIENTS I IDENTITY INFORMATION
Ingredient: None
TLV:
None
SECTION III: PHYSICAL I CHEMICAL CHARACTERISTICS
Boiling Point (Degrees F) . . . . . . . . . . . . . . . . . . . . .
Vapor Pressure. . . . . . . . . . . . . . . . . . . . . . . . . . . .
Vapor Density. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Specific Gravity. . . . . . . . . . , . . . . . . . . . . . . . . . . .
Melting Point. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Evaporation Rate. . . . . . . . . . . . . . . . . . . . . . . . . .
Solubility in Water. . . . . . . . . . . . . . . . . , . . . '.' . , ,
Appearance and Odor. . . . . . . . . . . . . . . . . . . . . .
pH """""""""""""""""'"
230°F.
NJA
N/A
1.30.1.56 @ 20°C.
N/A
N/A
100%
NJA
8.1
SECTION IV: FIRE AND EXPLOSION HAZARD DATA
Flash Point. . . . . . . . . . . . . . . . . None
Flammable Umlts . . . . . . . . . . . . . NIA
L.ower Explosive Umit . . . . . . . . . . N/A
Upper Explosive Umll . . . . . . . . . . NIA
extinguishing Media """" NlA
Sped.' Fire Figtlting . . . . . . .. None
Unusual Fire & explosion. . .. None
SECTION V: REACTIVITY DATA
c~ ToAIItJId
Stability. . . . . . . . . . . . . . . . . . . . . . . . . . . Stable. . . . . . . . . . . . - .. None
Incompatibility (Mlt.t1aIS to Avoid) """" Mlnel'll acids, CXVInlC KidS, non-ferrous metals.
Huerdous Decomposition or Byproduds ". None
Hazardous Polymerization. . . . . . . . . . . . . . Will not occur . . . . . . . . .. None
-------
12/1216/93
08:53
004
MATERIAL SAFETY DATA SHEET (MaDS)
Sutf8ce8/- Page 2
SECTION VI: HEALTH HAZARD DATA
Route(s) of Entry:
'ntut18t1on ..................................., No
Ingestion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -. Yes
Skin. . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . .. Yes
Health Hazards (Acute & C"",nlc): .,.... . . . . . . . . . . .. None
Carcinogenicity Infonnlltion:
NTP ...................................... No
IARC Monographs .. .. . .. . .. .. .. . . .. . .. .. . . .. . ., No
OSHA Regul8ted . . . . . - . . . . . . . . . . . . . . . . . . . . . . . .. No
Signs & Symptoms of Exposure. . . . . . . . . . . . . - - . . . . . . . . .. N/A
M8d1c8l COnditions Generally Aggravated by Exposure ... . . . . .. None Known
Emergency & First Aid Procedures. . . . . . . . . . . . . . . . . , . . , .. In C8M of contac:t with
skin, ftush with water. In case of cont8d with eyes, wash with clean Wllter (00 NOT
USF: EYEWASH SOLUTION).
SECTION VII: PRECAUTIONS FOR SAFE HANDUNG AND USE
Steps to be taken in case meterial is released or spilled. . . . . .
Wasle Disposal Method .., -"""""""""""'"
Flush area thoroughly with WIder.
Mix with 20 parts water & dilpOl8 in
ordinary drain.
Meterial will freeze at O°F.
Materiel will adhere to aluminum and
glass
StOring & Handling Precautions. . . . . . , . , , . . , . . , . . . . . . .
Other Precautions. . . . . . . . . . . . . . . . . . . . - . . . . . . . . . . . .
SECTION VIII; CONTROL MEASURES
Respir8tory Protection. . . . . . . . . . . . . . . . . . . . . . . . . . - . .. Not required
Ventilation:
Local Exhaust. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Mechanical. . . . . - . . . . - . . . - . . . . . . . : . . . . . . . . . .
Protective Gloves. . . . . . . . . . - . - . . . . . . . . . . . . . . .
Protective Clothing. . . . . . . . . . . . . . . . . . . . . . . . . . , .
WortUHygienic Practices. . . . . . . . . . . . . . . . . . . . . . . .
Special. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,
Other. . . . . . . . , . . . . , . . . . . . . . . . . . . . . . . , . . , ,
. Eye Protection. . . . . . . . . . . - . . - . . . . . . . . . . . . . . . .
Conditions to Avoid -. . . . . . . . . . . . . . . . . . . . . . . . . .
Acceptable
Acceptable
Rubber or PlaStic
Not Required
Normal
Not Required
Not Required
Goggles
None
All _18""l11li. 1nf0nn8\10n .net .. provldad ... th.. M....... s.r.11 Da.. ,"-I... ........11 II» " ._1It lInG ...1118. 'TtI8y - .........
wIholll 8..18,"", -'"'nty or ...pot'I8IDlIIIy 0' ."" Idnd, ..p..8MCI or ImplwclOfl - pan. u.... atmuW ..... Ih8Ir -. --...,...... to
1Ie\81'm1n. 'M au18l1.-y 0' - InIorm8I1Dn or p.oduc18 ... hit p8rt1r:u18r PUfPO". NoIhIng GOftIaIn8d -..e'" .. .....~ .. ,.",,--...
lndUC8ment or recommencl.aon '" wbl8" any 18- or 10 pt80IIDe .ny Inyenllon _raG IIY .elatlng p8t8"".
-------
12/e6/93
88:54
~;:,
Eave""".n,.lIr
a.f. P'adua'...
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."
PROJECT '$ANTA FE SPRINGS"
The leaching and vaporization of contaminants on the slt8 descrtbed into tne enViron-
nent (which includes adjacent rhziospheres and water tabies), can only be accom-
plished by methods which involve -bond breaking., .compJeXing. and -bonding- of
molecular 6tructures.
These methods insure short-term and iong-term reduction 01 migration and mobility 01
hazardous materials while long-term decomposition and degrading is being accom-
plished naturally by soil microbes.
We suggest that through a .piping8 process, the .1100("' of the waste area be saturated
with a non-toxic siliceous formula which will bond the small partiCles short-term while
long-term degradation by enhanced soil microbes Is taking place.
The stages would be:
8. Injection of ESP624 (a siliceous complexing liqUid) into tria lowest strata of the
contaminated areB. This injedion will prev~nt at least 95% 01 any possible
leaching of contaminants.
b. Inoculation of E$P2001 microbes and enzymes Into tne soil area at 100
gallons per acre. This inoculation of is self-supporting "biomass. will naturally
.break bonds8 of various molecules and complex atoms of toxic proaUC\$ $0
that they cannot leaCh.
c.
Laying ESP624 on top of this layer of contaminated SOli to separate the
biOlogical sandwiCh.
d. Building of B "soli rhziosphere8 whictl will cover the inoculated area, and
inoculating this soil addition with ESP2001.
The technology involved in this is the forming of natural zeolites, microbial degrada-
tion, and immobilized enzymes. Short term protection is afforded by zeolite formation.
Long term protection is afforded by microbial degradation and bond-breaking.
1GIIW3 . E$P Corp . 2100 "d 10 81& ",,"gw C. . Nlntlon, n: ?eOn
Page 1
-------
October 29, 1993
Rusty Harris-Bishop
U.S. EPA 75 Hawthorne St.
San Francisco, CA 94105
Dear Mr. Harris~Bishop:
This letter is in regards to your request for some public
input to your several alternatives of concluding the
investigation and remedial proposals of the Waste Disposal
Inc. Superfund site.
I am very supportive of your Number 3C proposal. I would
hope that this proposal will be decided upon and initiated
within a short time!
As you know every other property within the bounds of the
Superfund has been able to operate as though there were no
restrictions on these individual properties. My particular
piece of real estate does have limited contamination, and
is under direct EPA authority as what can be done to
establish it as a viable piece of property that can be
developed.
I would appreciate it if you could give me a time frame as
to when we could expect to have the contamination removed
and what those specific plans are!
I would also like to work with you to establish the guilt
of the parties that contaminated the property. I have been
involved with the city in the possible selling of this
property for development since 1982. As you can see many
frustrating years have elapsed since the initial
undertaking of the development of this property. Anything
you can do to hasten an end to this long and bureaucratic
experience would be certainly welcomed and appreciated.
I am 65 years old, and looking forward to having this
piece of property developed before I die! Please endeavor
to help me obtain my goal!!
k-iijO~£
v
Phil Campbell
-------
~St<4~.
i A \
\~l
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, Ca. 94105-3901
November 4, 1993
Mr. Albert L. Sharp, Mayor Pro-Tempore
City of Santa Fe Springs
1171 0 Telegraph Road
Santa Fe Springs, CA 90670-3658
RE:
Waste Disposal, Inc. Superfund Site
Dear Mr. Sharp:
I would like t~ thank you for your letter of October 8, 1993 concerning the
Proposed Plan for the Waste Disposal, Inc. (WDI) Superfund Site. I appreciate the
information you provided both in the letter, and in our meeting of October 18, 1993. I
am enthusiastic to develop a closer working relationship with the City so that we can
develop a creative solution to the interesting issues posed by the WDI Superfund Site.
I have responded to the official City of Santa Fe Springs comment letter via
separate correspondence (on which you are copied), but I wanted to thank you
personally for you interest and activities concerning this site. I hope that I will be able
to meet with the City Council again and discuss some of EPA's ideas regarding future
use of the site, so that we can come to a mutually agreeable decision prior to the
Remedial Design phase of the project. .
Again. thank you for your concern and interest in this site. I look forward to
working with you and your fellow council members in the near future.
~~~
Rusty Harris-Bishop
cc:
Lewis Maldonado (RC-3-1)
Dan Opalski (H-7 -2)
Prinrtd on R«ydtd ~r
-------
~sr..~.
i A,
t~=}
'l?-4L ~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, Ca. 94105-3901
November 4, 1993
Robert G. Orpin
Director of Planning and Development
City of Santa Fe Springs
11710 Telegraph Road
Santa Fe Springs, CA 90670-3658
RE:
Comments on EPA's Proposed Plan for the Waste Disposal, Inc.
Superfund Site
Dear Mr. Orpin:
I would like to thank you for submitting the City of Santa Fe Springs comments
to EPA's Proposed Plan for the Waste Disposal, Inc. (WDI) Superfund Site, located in
your city. Most of your comments will be addressed in the Responsiveness Summary
of the Record of Decision (ROD), which should be completed by early December;
however, there were a couple of items in your comment letter that I wanted to address
prior to the issuing of the ROD. I also wanted to reiterate some of EPA's thoughts on
future land use of the site, especially since City input will greatly affect the amount of
cr~ative thinking involved in determining and allowing for compatible uses of the site.
Comment 12, which requested EPA action on numerous barrels located on the
southeast area of the site, has been addressed. These barrels were identified in 1988
by EPA as non- hazardous and not posing an imminent threat to human health or the
environment, and therefore did not qualify for a removal action under EPA's removal
action authority. I have spoken with Steve Koester of your Fire Department, as well
as George Baker of the Los Angeles County Fire Department, and understand that
there were oily petroleum products in some of the barrels, and that some appeared to
be leaking. Petroleum products are not considered hazardous under federal
regulations, but may be considered so under state regulations. The Santa Fe Springs
Fire Department has covered the barrels with plastic, and that should prevent any
further releases. The owner of the property is having the materials evaluated, and he
will presumably take care of the disposal of the barrels. If not, these barrels will be
taken care of during the Remedial Action. I have included the summary of the On-
scene Coordinator's report from EPA's initial actions at the site. If further action is
required, EPA may be able to send someone down to examine the facility and re-
evaluate the hazards.
Printftl on R«yclfti ~r
-------
Mr. Robert G. Orpin
Director of Planning and Development
November 4, 1993
Page 2
As for the weed abatement (Comment 11), the last effort was initiated at the
request of the Santa Fe Springs Fire Department. While I am usually informed prior to
the disking operations, it is not required, since EPA has determined -that the disking
does not pose a health threat to the community (mowing tends to create more dust,
since it actually pulls dirt and dust up into the blades, and then directs it away from
the mower). However, it would be desirable for the operation to suppress any excess
dust, so I will make that suggestion to the LA County Weed Abatement Project
Manager, Grace Murase. It is unfortunate that there was a complaint from a parent
from St. Paul High School; the proposal to provide dust suppression during excavation
for the remedy has been confused with dust suppression for the site in general. I
explained the situation to Santa Fe Springs Fire Marshall Stan Betcher, and he feels
comfortable with the decisions made, and will be able to provide information to any
concerned citizens should this issue come up again.
As for your other comments, most will be addressed in the Responsiveness
Summary of the ROD. Comments 4 and 10, though, will be addressed during the
Remedial Design phase. For Comments 5, I would like to refer you to the Final
Remedial Investigation Report, Volume I, Chapter 3. This chapter shows the
topographical profile of the site and several cross-sections. A final topographical
profile for the site will not be made until the design is completed.
Deed restrictions (Comment 6), as explained in the Proposed Plan, will be
placed on the area where the cap will be constructed, in. order to maintain the integrity
of the remedy. In addition, restrictions will be placed on each parcel where the risk of
contact with contaminated soil exists. These restrictions can be as simple as a
voluntary notice on the deed that.contamination exists under the property. If the
property owners are not cooperative with EPA in placing the voluntary restrictions,
the State may declare the property a hazardous waste property, which carries with it
more severe use restrictions. A City zoning ordinance could also be used to restrict
use of properties where there is underlying contamination, if desired. These decisions
will be made during the design phase as well, since the ROD will describe only the
requirements and actions that will be taken, with the specifics left for the Remedial
Design. EPA hopes to restrict property use as little as possible, but will do what is
necessary to prevent exposure to contamination existing at the site.
I would like to close by discussing some of the ideas EPA has come up with
concerning future land use at the site. While EPA's selected remedy will be
protective, we feel that we have a unique opportunity to be very creative in terms of
future land use, and that we should expand our thinking to indude other uses of the
cap. Since restrictions that will be placed on the cap will not allow piercing the cap for
-------
Mr. Robert G. Orpin
Director of Planning and Development
November 4, 1993
Page 3
building or construction, any construction ideas would need to be discussed and
included in the Remedial Design. From our meetings with the public, both at the
public meeting and with the parents from St. Paul High School, we know that
development of the site for use as a vehicle storage area is not desirable. However,
there could be other uses for the asphalt surface, including tennis courts, basketball
courts, or other recreational uses. EPA is willing to work with the City and the current
property owners to develop some future use scenarios, but this will need to be done
during design. Our ROD will most likely call for a hybrid cap, with an asphalt cap over
the reservoir, and a soil and vegetation cap over the remainder of the contaminated
area. We think that with the participation of the City, the property owners, the
community, and EPA, we can develop a plan for use that will be beneficial to all
concerned, and still maintain the integrity of the remedy and the protection required by
our remedy. Again, I want to stress that EPA is very willing to work with the City in
coming up with a viable use for the property that will be acceptable to all concerned
parties; however, we need to have a plan in place so that we can design it into the
remedy. If we cannot incorporate the future use ideas into the design, the cap
restrictions will prevent any activity from taking place in the future.
I look forward to working with you on this site, and hope that we can come up
with a creative, innovative solution to the problems posed by this Superfund site.
Sincerely,
Rusty Harris-Bishop
Remedial Project Manager
Enclosure
cc:
Mayor and City Council of Santa Fe Springs (5 copies)
Don Powell, Santa Fe Springs City Manager
N. Schnabel, Santa Fe Springs Fire Chief
James Nishida, LA County Fire Department
Dan Opalski (H-7-2)
Lewis Maldonado (RC-3-2)
-------
The Waste Disposal Incorporated Site
Santa Fe Springs, California
I.
Summary of Events
The Waste Disposal Incorporated (WDI) Site is located at the
intersection of Greenleaf Ave. and Los Nietos Road in the City of
Santa Fe Springs, California. The site is rectangular in shape
and approximately five (5) acres in size. The site is bounded to
the north by a scrap metal dealer and a heat treating operation,
to the east by Greenleaf Ave., to the south by Los Nietos Rd. and
to the west by a lumber yard and several other small businesses.
A private school is located within one block of the site.
From the 1940's through the mid 1960's the site served as a
disposal facility that accepted drilling, refinery, milling and
brewery wastes. The site was later capped with two feet of clean
soil and currently listed on the EPA's National Priority List for
remedial action.
In February 1988 Remedial Project Manager (RPM) John Kemmerer
requested that the Emergency Response Section (ERS) conduct a
preliminary assessment of the WDI site in order to determine the
following:
the nature and degree of hazard associated
with approximately 200 drums stored on site
the need to restrict access-to the property
On March 2, 1988, the EPA/TAT Response Team arrived on site
to conduct the assessment. During the course of the assessment,
it was determined that the drums in question were either empty or
contained non hazardous materials and would not qualify for a
removal action.
Upon completion of the drum assessment, site access control
options were considered.
Details of the_day's activities are discussed in the TAT
report dated March 15, 1988.
On March 3-4, 1988 the results of the
discussed with RPM John Kemmerer and Betsy
Enforcement Programs Section. As a result
was agreed that:
assessment wer~
Curnow, Chief of the
of these meetings it
no action would be taken with respect to
the drums of non-hazardous material.
-------
-2-
A security fence would be constructed around
that portion of the site known as the Campbell
property. This fence would eliminate the
threat of exposure to the public stemming from
the potential contamination of surface soils
by previous waste disposal activities.
During the period March 7-21, 1988 TAT developed specifi-
cations for the fence construction which were detailed in the TAT
report dated March 21, 1988.
On March 21, 1988 funding for the project was approved by
Jeff Ze1ikson, Director, Toxics and Waste Management Division.
Construction of the fence began on March 30, 1988 and was
completed on April 27, 1988.
All keys for the site were given to Betsy Curnow.
II.
Effectiveness fo the Remedial Action
A.
The Responsible Parties
Betsy Curnow has determined that the current property
owner was either unwilling or unable to conduct the
necessary actions.
R.
State and Local Forces
NQ assistance was provided by state or local forces.
C.
Federal Agencies and Special Forces
The Technical Assistance Team (TAT) was tasked with the
following activities:
Develop of Site Safety Plan
Assist in conducting a preliminary assessment of the
site
Develop specifications for the fence construction
Overview the fence construction
All tasks were accomplished on time and in a professional
manner.
-------
III.
IV.
-3-
-
D.
Contractor
This project was carried out by Crosby and Overton, a
contractor to Riedel Environmental Services Inc., the
Zone 4 Emergency Response Cleanup Services (ERCS)
contractor.
sub-
In general I would rate the performance of the contractor
as "good".
Problems
None
Recommendations
None
-------
Chronology of Events
22 Feb. 88
RPM John Kemmerer requests that ERS conduct a preliminary
assessment of the W.D.I. Site.
1 Mar. 88
EPA/TAT Response Team travel to Santa Fe Springs Ca.
2 Ma r. 88
EPA/TAT Team conduct preliminary assessment of W.D.I. Site.
3 Mar. aa
asc Lewis and TAT members Wolf meet with RPM Kemmerer.
Kemmerer informed that drums do not qualify for a removal
action.
4 Har. 88
Meeting between OSC Lewis, RPM Kemmerer, Betsy Curnow, Chief,
Enforcement Programs Section and Terry Brubaker, Chief
Emergency Response Section.
ase Lewis proposes that ERS/TAT develop and implement a
moderate sampling plan to assess the Campbell property.
Based on the results of the study ERS would propose one
following action plans:
Delist the property
Conduct a limited removal action and delist the
property
Fence the property pending future remedial action.
Curnow and Kemmerer reject this proposal and request that
ERS construct a fence.
Lewis and Brubaker agree to design and construct fence.
7 ~'ar. 88
TAT tasked with developing specifications for the fence
construction.
-------
-2-
15 Mar. 88
TAT submits report covering the preliminary assessment of
the W.D.I. Site.
21 Mar. 88
TAT submits report covering fence specifications.
Action Memo approved by Jeff Zelikson.
Delivery Order issued to Riedel Environmental Services Inc.
24 Mar. 88
OSC Lewis and TAT Member Len Marcus meet on-site with Larry
Boyle, Response Manager with Crosby and Overton and two
potential fence sub-contractors.
2 8 f-ia r. 88
Two fence bids submitted to Crosby and Overton.
Fence sub-contractor selection made.
30 Har. 88
Fence construction begins.
20 Apr. 88
All site fence keys turned over to Betsy Curnow.
27 Apr. 88
Fence Construction completed.
TAT submits final project report.
-------
TRANSCRIPT FROM PUBLIC MEETING
VERBAL COMMENTS
-------
SFUNO R~Cu~~~ ~i~
2047-00376
J
. . "
UNITED STATES ENVIRONMENTAL "'PROTECTION AGENCY "":'
REGION 9 WASTE DISPOSAL I INC.
AR0187
~. .:
. . .~
SUPERFUND '. SITE PROPOSE!? I'PLAN. PUBLIC MEETING . . ;:. ~'.~ ,,)'. ,"'>" " : . .;,.': :.;:;:' ~
". .. ..,.." :!
. .
ORIGI NAL:'
GOlO'IG COUll I£PORTERS
D~PUCATE D:CUI.tEHr
cof SOcII~ RefOlds .'~~::~
TAKEN AT:
11710 TELEGRAPH ROAD
SANTA FE SPRINGS, CALIFORNIA 9067~'
DATE/TIME:
WEDNESDAY, SEPTEMBER 1, 1993
7:10 P.M. - 9:00 P.M.
REPORTER:
KAREN M. KLEIN
CSR NO. 5368, RPR/CM
JOB NO.:
93-1311
GOLDING COURT REPORTERS
CERTIFIED SHORTHAND REPORTERS
17785 CENTER COURT DRIVE, SUITE 440
CERR/TOS. CAlIFORNIA 90701
(310) 924-2724. (909) 381-9228
-------
1--
.
1
2
APPEARANCES
ANGELES HERRERA
DAN OPALSKI
RUSTY BARRIS-BISHOP
LEWIS MALDONADO
AMANCIO SYCIP
~
2
3
4
FROM UNITED STATES
ENVIRONMENTAL PROTECTION
AGENCY:
5
6
FROM CALIFORNIA
ENVIRONMENTAL PROTECTION
AGENCY:
7
8
9
10
11
12
13
14
15
16
17 "
18
19
20
21
22
23
24
25
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1
2
SANTA FE SPRINGS, CALIFORNIA, WEDNESDAY, SEPTEMBER 1, 1993
7:10 P.M.
3
* * *
4
5
MAY I HAVE YOUR ATTENTION, PLEASE?
WE
MS. HERRERA:
6 WOULD LIKE TO GET STARTED.
7
MY NAME IS
GOOD EVENING, EVERYONE.
8 ANGELES HERRERA, AND I WORK WITH THE UNITED STATES
9
10
ENVIRONMENTAL PROTECTION AGENCY IN SAN FRANCISCO.
IAM
THE COMMUNITY RELATIONS COORDINATOR FOR WASTE DISPOSAL,
11 . INCORPORATED S~ERFUND SITE KNOWN AS W. D. I.
I WOULD LIKE
12
TO THANK YOU ALL FOR ATTENDING OUR MEETING THIS EVENING.
13 AS YOU CAN HEAR, ENGLISH IS NOT MY PRIMARY LANGUAGE SO
14
15
PLEASE DON'T HESITATE TO STOP ME AT ANY TIME IF I'M TALKING
TOO FAST OR IF I MISPRONOUNCE ANY WORDS.
16
(SPEAKS IN SPANISH.)
E.P.A. IS HERE TONIGHT TO PRESENT ITS PROPOSED
17 .
18
PLAN FOR CONTAMINATED SOIL AND SUBSURFACE GASES AT WASTE
19
DISPOSAL.
WE'RE ALSO HERE TO ANSWER YOUR QUESTIONS AND TO
20
21
TAKE YOUR COMMENTS.
I HOPE YOU ALL GOT A CHANCE TO PICK UP
A COpy OF OUR FACT SHEET ON THE WAY IN IF YOU DID NOT
22
RECEIVE ONE IN THE MAIL.
ALSO, I WANT TO APOLOGIZE.
WE
23
24
JUST FOUND OUT THIS MORNING THAT SOME OF THEM WERE NOT
COMPLETE .
APPARENTLY, OUR CONTRACTOR MADE A MISTAKE AND
25
SENT OUT SOME FACT SHEETS INCLUDING TWO OF THE FIRST PAGE
3
-------
1
2
AND THE MIDDLE PAGES WERE NOT INCLUDED, SO IF YOU RECEIVED
AN INCOMPLETE COPY, PLEASE FEEL FREE TO PICK UP A COMPLETE
3
4
COpy AT THE END -- ON THE TABLE AT THE END OF THE MEETING.
WE ALSO HAVE A PACKAGE WITH THE AGENDA AND THE
5
OVERHEADS.
WE'D ASK YOU TO PLEASE PICK UP A COpy OF THIS
6
BECAUSE THIS WILL BE VERY HELPFUL FOR YOU TO FOLLOW THE
7
PRESENTATION.
8
9
AND WE HAVE A SIGN-IN SHEET.
WE'RE ASKING YOU TO
SIGN THOSE SHEETS SOMETIME THIS EVENING, AND THE REASON WE
HAVE THE SIGN-IN SHEET IS BECAUSE THAT'S OUR PRIMARY SOURCE
10
11'1'0 UPDATE OUR MAILING LIST, SO IF WE DON'T HAVE YOUR NAME
12
13
IN THE MAILING LIST, IT'S EXTREMELY IMPORTANT FOR YOU TO
SIGN THE SHEET, SO WE WILL PUT YOU ON THE MAILING LIST AND
14
YOU WILL RECEIVE FURTHER INFORMATION.
15
NOW I WOULD LIKE TO INTRODUCE RUSTY
16
HARRIS-BISHOP, E.P.A.'S PROJECT MANAGER FOR
17 -:THE SITE; DAN OPALSKI, E.P.A. SECTION CHIEF FOR THE SITE;
18
LEWIS MALDONADO, E. P . A. ' S ATTORNEY, AND WE ALSO HAVE THE
STATE B.P.A. COUNTERPART, AMANCIO SYCIP, CALIFORNIA E.P.A.
19
20
21
WE HAVE A TOXICOLOGIST FOR THE CALIFORNIA DEPARTMENT OF
HEALTH SERVICES.
HER NAME IS MARILYN UNDERWOOD.
WE ALSO
22
23
HAVE THEIR COMMUNITY RELATIONS COORDINATOR, JANE RIGGAN.
AS YOU NOTICE, WE HAVE A COURT REPORTER WITH US.
24
THIS EVENING.
SHE'S HERE TONIGHT TO RECORD THE ENTIRE
25
MEETING, AND THEN SHE WILL WRITE OUT A TRANSCRIPT OF THE
4
-------
1
2
THIS TRANSCRIPT WILL BECOME A PART OF THE
MEETING.
DOCUMENT THAT WILL DOCUMENT THE DECISION THAT E.P.A. WILL
3
4
THIS DOCUMENT IS CALLED THE RECORD OF DECISION.
WE NEED YOU TO SPEAK LOUD, TO STATE YOUR NAME AND
MAKE .
5
AFFILIATION FOR THE RECORD, AND SHE WILL STOP YOU IF SHE
DOESN'T GET YOUR NAME, AND WE ASK YOU TO PLEASE SPELL IT
6
7
FOR HER.
8
9
LET ME MAKE SURE OF TELLING YOU EVERYTHING I
SHOULD BE TELLING YOU.
10
11
NOW I'M GOING TO TAKE A MINUTE TO RUN THROUGH
TONIGHT'S AGENDA.
FOLLOWING THE INTRODUCTION, WE WILL BE
12
13
HEARING FROM DAN OPALSKI, WHO WILL BE COVERING THE
SUPERFUND PROCESS IN GENERAL.
THEN RUSTY -- AND THAT'S
14
GOING TO TAKE APPROXIMATELY FIVE MINUTES, AND THE REASON
15 WE'RE PUTTING TIME TO EVERY AGENDA ITEM IS BECAUSE WE NEED
16
TO BE OUT OF HERE BY NINE 0 'CLOCK, BUT WE WANT TO MAKE SURE
17.. THAT WE ANSWER ALL YOUR QUESTIONS, BUT THE MAIN REASON OF
18
HAVING THIS MEETING IS TO TAKE YOUR COMMENTS, AND THE COURT
REPORTER IS ONLY GOING TO BE HERE UNTIL NINE O'CLOCK, SO WE
19
20
MAY HAVE TO STOP THE QUESTIONS TO GO INTO THE COMMENTS
21
BECAUSE WE WANT TO MAKE SURE WE TAKE ALL YOUR COMMENTS, AND
THEN IF IT'S NINE O'CLOCK AND WE NEED TO STAY LONGER TO
22
23
ANSWER YOUR QUESTIONS, WE WILL BE GLAD TO DO IT OUTSIDE THE
ROOM.
24
25
THEN RUSTY WILL BE TALKING ABOUT -- HE WILL BE
5
-------
1
2
PRESENTING OUR PROPOSED PLAN, AND BE WILL ALSO BE COVERING
THE DIFFERENT ALTERNATIVES THAT ARE BEING CONSIDERED FOR
3
4
THE SITE, AND THAT'S GOING TO TAKE APPROXIMATELY 15
MINUTES, SO IN TOTAL, THE WHOLE PRESENTATION WILL PROBABLY
5
6
BE LIKE 20, 25.
ANSWER SESSION.
THEN WE'RE GOING TO HAVE A QUESTION AND
DURING THIS QUESTION AND ANSWER SESSION,
7
WE ENCOURAGE YOU TO ASK ANY QUESTIONS OR ANY ADDITIONAL
CLARIFICATION YOU MAY NEED REGARDING E.P.A.'S PROPOSED PLAN
8
9
OR ANYTHING YOU BEAR TODAY OR IF YOU BAD A CHANCE TO REVIEW
10
OUR FEASIBILITY STUDY AND YOU HAVE ANY QUESTIONS REGARDING
11 OUR FEASIBILITY STUDY, YOU CAN ASK THOSE QUESTIONS DURING
12
13
THE QUESTION AND ANSWER SESSION.
THEN WE WILL -- AND
THAT'S PROBABLY GOING TO BE LIKE HALF AN HOUR.
14
THEN WE WILL HAVE THE FORMAL COMMENT PERIOD.
15
DURING THE FORMAL COMMENT PERIOD, E.P.A. WILL NOT BE
16
ANSWERING TO THOSE COMMENTS TONIGHT.
WE WILL ANSWER TO
17 . THOSE COMMENTS ON THE RESPONSIVENESS SUMMARY, WHICH IS ALSO
18
A DOCUMENT THAT BECOMES A PART OF THE RECORD OF DECISION.
19
ONCE AGAIN, WE WILL NOT ANSWER TO THOSE COMMENTS TONIGHT,
SO IF YOU HAVE A QUESTION THAT YOU WANT AN ANSWER TONIGHT,
20
21
22
YOU SHOULD ANSWER THAT -- YOU SHOULD ASK THAT QUESTION
DURING THE QUESTION AND ANSWER SESSION, BUT IF YOU HAVE A
23
COMMENT, A SUGGESTION OR A THOUGHT FOR US TO CONSIDER
DURING -- DURING THIS COMMENT PERIOD FOR THE RECORD OF
24
25
DECISION, PLEASE DO THAT DURING THE FORMAL COMMENT PERIOD.
6
-------
1
2
WITH THAT, I WOULD LIKE TO TURN IT OVER TO
DAN OPALSKI.
THANK YOU
3
4
GOOD EVENING.
I'M GOING TO TAKE JUST A
MR. OPALSKI:
5
COUPLE OF MINUTES, AS ANGELES SAID, TO TALK GENERALLY ABOUT
THE SUPERFUND PROCESS TO BRING EVERYBODY UP TO SORT OF A
6
COMMON LEVEL OF UNDERSTANDING ABOUT WHAT SUPERFUND IS ALL
7
SUPERFUND IS THE WORD COMMONLY USED TO REFER TO THE
ABOUT.
8
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND
LIABILITY ACT THAT WAS ORIGINALLY PASSED BY THE U.S.
9
10
CONGRESS BACK IN 1980.
UNDER SUPERFUND, E . P . A. HAS THE
11 . AUTHORITY AND THE RESPONSIBILITY TO RESPOND TO HAZARDOUS
12
WASTE SITES AROUND THE COUNTRY.
THESE SITES CAN FALL IN
13
THE CATEGORY OF PLACES WHERE WE NEED TO RESPOND ON AN
14
15
EMERGENCY BASIS, WHETHER THINGS LIKE SPILLS OR DANGEROUS
AND IMMEDIATE THREATS TO HUMAN HEALTH; TWO:
SITES WHERE
16
THERE NEEDS TO BE SOME LONG-TERM EVALUATION, MUCH MORE LIKE
17 . THE CURRENT SITUATION AT THE FORMER WASTE DISPOSAL SITE.
18
FOR THE SITES THAT GO THROUGH THIS LONGER TERM RESPONSE,
19 . WHAT WE TEND TO REFER TO AS A PIPELINE, THERE ARE THE STEPS
20
21
THAT ARE PROVIDED HERE ON THIS OVERHEAD, AND I'LL GO
THROUGH EACH OF THOSE REAL BRIEFLY.
22
23
FIRST STEP IS SITE DISCOVERY.
THAT'S ESSENTIALLY
THE WAY IN WHICH E.P.A. BECOMES AWARE OF THE SITE.
THAT
24
CAN HAPPEN BECAUSE A COMMUNITY MEMBER CALLS UP, IT CAN
HAPPEN BECAUSE WE BEAR FROM A LOCAL FIRE DEPARTMENT, IT
25
7
-------
1
2
COULD HAPPEN BECAUSE WE BEAR FROM A LOCAL OR COUNTY OR
STATE ENVIRONMENTAL AGENCY.
IN THE CASE OF WASTE DISPOSAL,
3
4
BOTH THE CITY AND THE STATE WERE INVOLVED IN THIS SITE AND
BROUGHT IT TO OUR ATTENTION.
ONCE A SITE BAS BEEN BROUGHT
5
6
TO OUR ATTENTION, THERE'S A PRELIMINARY AMOUNT OF DATA
COLLECTION THAT GOES ON.
THAT IS GEARED TOWARDS FINDING
7
OUT ABOUT THE BACKGROUND OF THE SITE, FINDING OUT GENERALLY
WHAT KINDS OF CHEMICALS ARE FOUND AT THE SITE AND GETTING A
8
9
FIRST SENSE FOR HOW -- HOW HIGH THE CONCENTRATION OF THOSE
10
ALL THAT IS PUT TO WORK
CONTAMINANTS MIGHT BE IN THE AREA.
11 IN THE -- WHAT IS SHOWN HERE AS THE N.P.L. RANKING OR
12
13
WHAT HAPPENS IS THERE'S A MODEL THAT IS USED TO
LISTING.
DETERMINE WHETHER OR NOT THE CONDITIONS AT THE SITE MEET
14
ENOUGH OF A THRESHOLD TO MAKE THAT SITE WORTHY OF THE
15
16
EXPENDITURE OF OR ELIGIBLE FOR THE EXPENDITURE OF FEDERAL
CLEANUP DOLLARS.
THAT HAPPENED FOR THE W.D.I. SITE BACK IN
17
18
JULY 1987 AS IT'S SHOWN HERE.
WE MOVE INTO A LONG STUDY PHASE.
WE TRY IDEALLY
19
TO BE LOOKING AT ABOUT AN 18 MONTH PERIOD DURING WHICH WE
20
21
DO A REMEDIAL INVESTIGATION, FEASIBILITY STUDY.
THAT
PROCESS OBVIOUSLY HAS TAKEN LONGER HERE AT THE W.D.I. SITE,
BUT WHAT THAT IS IS A PROCESS WHERE WE FIRST TRY TO
22
23
24
CHARACTERIZE THE NATURE AND EXTENT OF THE CONTAMINATION.
AGAIN, WE'RE TRYING TO DEFINE MORE DEFINITIVELY WHAT ARE WE
SEEING OUT THERE, WHAT ARB THE CONCENTRATIONS, WHAT ARB THE
25
8
-------
-
1
POTENTIAL PATHWAYS FOR EXPOSURE THAT TEND TO THREATEN OR
2
MIGHT THREATEN PUBLIC HEALTH OR THE ENVIRONMENT.
THAT'S IN
3
4
DURING THE FEASIBILITY
THE REMEDIAL INVESTIGATION STAGE.
STUDY THEN, WE'RE LOOKING AT OKAY, WE'VE DEFINED THE
PROBLEM, HOW CAN WE RESPOND TO IT, . WHAT KINDS OF
5
6
TECHNOLOGIES ARE APPROPRIATE FOR ADDRESSING THE KINDS OF
7
SO IN THE
CONDITIONS THAT WE'RE SEEING AT THE SITE.
8
FEASIBILITY STUDY, WE TAKE THOSE TECHNOLOGIES, WE PUT THEM
TOGETHER TO FORM REMEDIAL ALTERNATIVES, WE EVALUATE THOSE
9
10
ALTERNATIVES AGAINST ONE ANOTHER, AND WE COME UP WITH A
11 . PREFERRED OR A.PROPOSED REMEDY.
WE -- WE PUBLISH THAT
12
13
PREFERRED OR PROPOSED PLAN IN A FACT SHEET USUALLY LIKE THE
ONE THAT YOU HAVE RECENTLY RECEIVED IN THE MAIL OR YOU'VE
14
PICKED UP TONIGHT, AND THAT PUTS US INTO THE PUBLIC COMMENT
15
16
PERIOD THAT YOU SHOW HERE -- THAT IS SHOWN HERE.
DURING THE PUBLIC COMMENT PERIOD, THE COMMUNITY
17 . HAS THE OPPORTUNITY TO LOOK AT THE FULL RECORD, NOT JUST
18
19
THE PROPOSED PLAN AND THE REMEDIAL INVESTIGATION
FEASIBILITY STUDY BUT ALL THE RECORDS THAT B.P.A. BAS PUT
20
21
INTO AN ADMINISTRATIVE RECORD FILE TO FORM THE BASIS FOR
MAKING A DECISION.
A COpy OF THAT ADMINISTRATIVE RECORD
22
23
FILE IS HERE IN THIS LIBRARY.
AFTER THE PUBLIC COMMENT PBRIOD, WE ARB -- WE ARE
REQUIRED TO CONSIDBR ALL SIGNIFICANT COMMENTS, TO
24
25
INCORPORATE THEM INTO A RESPONSIVENESS SUMMARY AND TO
9
-------
1
2
DOCUMENT OUR FINAL DECISION IN THE RECORD OF DECISION.
THAT RECORD OF DECISION, AGAIN, WOULD BE HERE IN THE
3
4
LIBRARY AVAILABLE FOR EVERYONE'S REVIEW, AND THERE, AS
ANGELES SAID EARLIER TONIGHT, YOU WOULD HAVE THE
5
6
OPPORTUNITY TO LOOR AT THE RESPONSES TO THE OFFICIAL
COMMENTS YOU MAKE, EITHER TONIGHT OR IN WRITING SUBMITTED
7
8
TO OUR AGENCY.
AFTER THE RECORD OF DECISION, WE MOVE INTO A
REMEDIAL DESIGN AND REMEDIAL ACTION STEP, waICH IS -- waICH
9
10
IS, FIRST OF ALL, THE DRAWING OF THE TECHNICAL
11 . SPECIFICATIONS .FOR THE ACTUAL WORK THAT WILL BE REQUIRED
12
13
AND THEN THE ACTUAL CONSTRUCTION OR OTHER ACTIVITY. THAT IS
REQUIRED AT THE SITE TO SECURE IT TO MAKE SURE THAT THB
14
15
REMEDY IS PROTECTIVE.
OKAY?
THAT IS SUPERFUND IN A REAL
QUICK, GENERAL WAY.
ACTUALLY, WE COULD TAKE A COUPLE OF
16
QUESTIONS IF THERE'S ANYTHING THAT'S UNCLEAR AT THIS POINT
17 .. OR WE CAN MOVE RIGHT INTO RUSTY'S PRESENTATION, BUT I WANT
18
19
TO STOP FOR A SECOND IF THERE'S ANYTHING THAT IS UNCLEAR AT
THIS POINT.
OKAY?
20
RUSTY?
21
MR. BARRIS-BISHOP:
THANKS, DAN .
22
23
OKAY.
I'M RUSTY BARRIS-BISHOP, AS ANGELES SAID,
AND I'M GOING TO BE PRESENTING THE ALTERNATIVES THAT E.P.A.
24
HAS LOOKED AT, B.P.A.'S PROPOSED ALTERNATIVE AND ALSO SOME
OF THE INVESTIGATIONS AND THE CONTAMINATION '!'BAT WE FOUND
25
10
-------
:<4 ~:~ -
1
2
TO DATE AND A LITTLE BIT OF THE BACKGROUND OF THE SITE.
AND WHILE I'D LIKE TO PROBABLY WAIT FOR MOST OF
3
4
THE QUESTIONS, YOU KNOW, AT THE END, IF I SAY SOMETHING
THAT PEOPLE DON'T UNDERSTAND OR YOU'RE NOT FOLLOWING ME,
5
PLEASE STOP ME, LET ME KNOW SO I CAN CLEAR IT UP, SO WE
CAN, YOU KNOW, KEEP THE PRESENTATION MOVING SO EVERYONE CAN
6
7
UNDERSTAND.
AS DAN SAID, THE SITE WAS INITIALLY PLACED ON THE
8
9
N.P.L. IN 1987, AND WHEN WE PLACED IT ON, THIS IS THE
10
IT WAS BASICALLY THE
BOUNDARY IS THIS DASHED LINE.
11
12
PROPERTY FROM SANTA FE SPRINGS ROAD TO GREENLEAF AVENUE AND
LOS NIETOS ROAD TO THE EDGE OF THE FEDCO PROPERTY AND THE
13
ST. PAUL'S HIGH SCHOOL PARKING LOT AND ATHLETIC FIELDS.
14
THE MAIN FOCUS OF THE DISPOSAL ACTIVITIES THAT
15
WENT ON WHEN THE SITE WAS OPERATING WAS THIS, CONCRETE
16
DISPOSAL RESERVOIR, AND IT WAS ABOUT A 42 MILLION GALLON
CONTAINER ORIGINALLY USED FOR STORING CRUDE OIL FROM THE
17
18
19
WELL FIELDS AROUND HERE.
AS THE WELL FIELDS STARTED TO
PRODUCE LESS, IT WAS CONVERTED TO OR THEY STARTED USING IT
FOR DRILLING MUDS AND SLUDGES FROM THE OIL FIELD INDUSTRY.
20
21
DURING THE PROCESS OF OPERATING IT FROM ABOUT 1929 TO 1964,
22
23
THEY OPERATED -- THEY ACCEPTED A LOT OF DIFFERENT KINDS OF
WASTE, SLUDGES FROM INDUSTRIAL PROCESSES, CONSTRUCTION
24
DEBRIS, CONCRETE.
THEY ALSO DUG SOME PITS TO KIND OF
25
SOLIDIFY ANY OF THE LIQUIDS OR SLUDGES THAT WERE IN THAT
11
-------
1 'RESERVOIR AND EVENTUALLY USED A LOT OF THIS AREA IN THIS
2
3
BOUNDARY FOR DISPOSAL.
SO IT EVENTUALLY CLOSED IN THE EARLY , 60' S, AND
4
5
THEN THEY BROUGHT IN A LOT OF SOIL AND GRADED IT OVER TO
BASICALLY ITS CURRENT CONFIGURATION THAT IT'S IN TODAY.
6
E.P.A. BECAME INVOLVED IN THE SITE IN 1986, '87,
7
BUT THERE WERE SEVERAL INVESTIGATIONS PRIOR TO THAT THAT
8 . DID SOME CURSORY ENVIRONMENTAL INVESTIGATIONS AND ALSO SOME
9
10
GEOTECHNICAL LIKE STRUCTURAL STUDIES TO SEE WHAT KIND OF
BUILDINGS THE SITE COULD HOLD, THAT KIND OF THING, BUT
11 MOSTLY E.P.A. RELIED ON THE DATA THAT WAS COLLECTED DURING
12
13
THE REMEDIAL INVESTIGATION THAT WENT ON THROUGH '88 AND
, 89, AND THAT'S THE BASIS OF THE FEASIBJ;LITY STUDY THAT WAS
14
PUBLISHED IN AUGUST OF THIS YEAR.
15
WE LOOKED AT
WE STUDIED THREE DIFFERENT MEDIA.
16
GROUNDWATER CONTAMINATION, SOIL CONTAMINATION AND
17 . SUBSURFACE GAS CONTAMINATION.
NOW, SUBSURFACE GAS
18
19
CONTAMINATION IS BASICALLY THE METHANE THAT IS A PROBLEM
THROUGHOUT THIS AREA BECAUSE OF THE OIL FIELD AND THE OIL
20
THAT'S LOCATED HERE.
AS IT DEGRADES, METHANE IS GENERATED,
21
AND IT GENERALLY COMES TO THE SURFACE SLOWLY AND JUST
22
23
EVAP -- JUST GOES OUT AND DISSIPATES INTO THE AIR.
WE
WANTED TO MAKE SURE WHAT WAS GOING ON DOWN THERE, SO WE DID
24
THAT INVESTIGATION AS WELL.
THE GROUNDWATER, WE DID
25
ANOTHER INVESTIGATION.
WE DID SOME MORE SAMPLING IN 1992
12
-------
1 r AT THE REQUEST OF THE STATE BECAUSE THEY FELT LIKE WE
2
3
NEEDED TO DO SOME MORE CHARACTERIZATION, AND BASICALLY
WE -- WE DIDN'T COME TO A CONCLUSION AS TO WHETHER THE SITE
4
5
WAS CONTRIBUTING TO GROUNDWATER CONTAMINATION OR NOT
CONTRIBUTING, SO WE'RE GOING TO BE LOOKING AT GROUNDWATER
6
SEPARATELY, BUT I WANT TO STRESS RIGHT NOW THAT OUR
INVESTIGATION SHOWED THAT THE SITE IS NOT CONTRIBUTING TO
7
8
9
ANY DRINKING WATER CONTAMINATION BECAUSE THERE ARE SEVERAL
LAYERS OF GROUNDWATER BEFORE ANY DRINKING WATER SOURCE THAT
10
THE CITY OF SANTA FE SPRINGS USES, SO THERE'S NO DRINKING
WATER THREAT, AND WE WANT TO MAKE SURE THAT THAT DOESN'T
11
12
HAPPEN AT SOME .TIME IN THE FUTURE.
13
14
I'LL TALK A LITTLE BIT ABOUT SOME OF THE SITE
I WANT TO PUT THIS PICTURE UP.
THIS
CONDITIONS TO DATE.
15
SHOWS SOME OF THE DOCUMENTED DISPOSAL AREAS THAT WE FOUND
16
DURING THE INVESTIGATION, AND THESE ARE MOSTLY FROM AERIAL
17 . PHOTOGRAPHS.
WE'RE LUCKY THAT WE HAVE PHOTOGRAPHIC RECORDS
18
19
BACK TO, I THINK, 1928 OR 1937 ANYWAY THAT SHOW DIFFERENT
DISPOSAL SITES THAT WERE OCCURRING DURING THIS TIME.
SO
20
21
THIS IS -- SO WE KIND OF LOOKED AT THIS AND THOUGHT WELL,
YOU KNOW, IT LOOKS LIKE THEY USED THIS ENTIRE SITE FOR
22
23
DISPOSAL, SO WE PUT A GRID DOWN AND BASICALLY DUG 100 HOLES
DOWN TO THE GROUNDWATER AND SAMPLED THE SOIL EVERY FIVE
FEET TO DETERMINE WHAT KIND OF CONTAMINATION WAS THERE.
WE
24
25
ALSO PUT IN 26 VAPOR WELLS TO SAMPLE THE GASES THAT ARE
13
-------
1 : DOWN IN THE GROUND AND 27 GROUNDWATER WELLS TO SAMPLE THE
2
GROUNDWATER.
THE SOIL INVESTIGATION IS WHAT REALLY DROVE
3
4
ANY -- WHAT DROVE THIS INVESTIGATION FURTHER BECAUSE MOST
OF THE -- MOST CONTAMINATED MEDIA IS SOIL, AND MOST OF THE
5
6
SOIL CONTAMINATION WE FOUND IS BELOW THE SURFACE BECAUSE
7
THEY DID GRADE THIS OVER, AND THE CONTAMINATION OCCURRED
8 . OVER A LONG PERIOD OF TIME, SO MOST OF THE CONTAMINATION IS
9
10
I ALSO WANT TO STRESS THAT MOST OF THE
BELOW FIVE FEET.
CONTAMINATION IS AT FAIRLY LOW LEVELS, AND, IN FACT, MOST
11 IS WITHIN A LEVEL THAT E.P.A. COULD WALK AWAY FROM AND SAY
12
13
IT'S WITHIN OUR ACCEPTABLE RISK RANGE.
HOWEVER, THAT'S AT
CURRENT EXPOSURE, AND RIGHT NOW THERE'S NO REAL THREAT TO
HUMAN HEALTH, BUT IF THIS SITE IS SOMEHOW DEVELOPED AND
14
15
PEOPLE START DIGGING AND GET DOWN INTO WHERE THE
16
17
CONTAMINATION IS, YOU KNOW, AT 10 FEET UP TO 35 OR 40 FEET
DOWN, THEN THERE'S A POTENTIAL RISK, AND SO THAT'S WHAT WE
18
WANT TO ADDRESS IS ANY POTENTIAL RISK THAT COULD LEAD TO --
19
OR ANY POTENTIAL ACTIVITIES THAT COULD LEAD TO AN EXPOSURE
20
DOWN THE ROAD, SO THAT'S BASICALLY WHERE THE THRUST OF OUR
ACTIVITIES AND THAT'S WHERE THIS PREFERRED PLAN OR PROPOSED
21
22
23
PLAN IS TRYING TO ADDRESS THAT RISK.
I WANT TO STRESS A LITTLE BIT, LIKE I SAID, ABOUT
24
25
THE SUBSURFACE GAS AS IT SLOWLY COMES UP TO THE SURFACE,
AND WE DIDN'T DETECT ANY OF THESE GASES AT THE SURFACE WHEN
14
-------
1 "WE WERE DOING OUR, INVESTIGATION, BUT WE mow THAT IT'S DOWN
2
THERE AT 65 FEET, AND WE KNOW THAT METHANE BAS A TENDENCY
3
4
TO RISE.
WE DID DETECT IT AT THE SURFACE, BUT WE'RE GOING
TO BE DOING SOME MORE INVESTIGATIONS TO MAKE SURE THAT IT
ISN'T COMING TO THE SURFACE BECAUSE IF IT IS, WE WOULD LIKE
5
6
TO MITIGATE THAT BY PUMPING IT OUT THROUGH THE VAPOR WELLS
7
WE ALREADY HAVE IN PLACE AND THEN FLARING IT, MUCH LIKE A
8 . LANDFILL FLARE OR A FLARE THAT YOU SEE IN THE OIL WELLS
9
10
WHERE THEY BURN THE METHANE AS THAT'S COMING OUT, SO THAT'S
A COMPONENT OF OUR REMEDY, IF NECESSARY.
11 AND WE FOUND GROUNDWATER CONTAMINATION, BUT LIKE
12 I SAID, WE'RE GOING TO BE ADDRESSING THAT SEPARATELY
13 BECAUSE WE NEED TO FIND SOME MORE DATA, AND WE ARE LOOKING
14 FORWARD TO WORKING WITH THE CITY AS WELL AS THE STATE
15
REGIONAL WATER QUALITY CONTROL BOARDS AND THE STATE
DEPARTMENT OF TOXIC SUBSTANCES CONTROL TO GET A LARGER
16
17
PICTURE OF THE CONDITIONS OF GROUNDWATER, ESPECIALLY AT
SHALLOW LEVELS, WHICH IS NOT NORMALLY WHAT PEOPLE STUDY
18
19
BECAUSE PEOPLE LOOK AT THE DRINKING WATER SUPPLY, WHICH IS
20
MUCH DEEPER.
WE WANT TO -- WE NEED TO LOOK AT THE SHALLOW
21
GROUNDWATER, WHICH IS WHAT THE SITE WOULD IMPACT, SO WE'RE
22
GOING TO BE DOING SOME MORE INVESTIGATIONS INTO THAT AREA
23 ,AND LOOKING AT A BROADER PICTURE, BOPEFULLY IN
24
OCTOBER/NOVEMBER TIME FRAME, EVERYONE GETTING TOGETHER.
AT THIS POINT, I'D LIKE TO TALK A LITTLE BIT
25
15
-------
1 ." ABOUT OUR AL'l'ERNATIVES THAT WE REVIEWED THAT ARE IN THE
2
3
FEASIBILITY STUDY.
IN THE FEASIBILITY STUDY WE LOOK AT A
LOT OF DIFFERENT THINGS, DIFFERENT TECHNOLOGIES THAT WE
4
COULD USE AND DIFFERENT TREATMENT OPTIONS.
ONE OF THE
5
6
PROBLEMS AT THIS SITE IS WE HAVE A VARIETY OF CONTAMINANTS
THAT NO ONE TECHNOLOGY IS USUALLY COMPATIBLE WITH MULTI --
7
MULTIPLE CONTAMINATION UNLESS THEY'RE ALL SIMILAR, SO WE
8 ~DID LOOK AT A LOT OF TECHNOLOGIES AND THEN SCREEN THEM OUT
9
10
BECAUSE THEY WEREN'T PRACTICAL, AND THE SEVEN THAT WERE
PRESENTED IN THE FEASIBILITY STUDY OR IN THE PROPOSED PLAN
11 . ARE ALSO UP HERE ( INDICATING), AND FIRST I'D LIKE TO GO
12
13
THROUGH E. P . A. ' S PREFERRED ALTERNATIVE, BUT I WANT TO
STRESS THAT ALL OF THESE ALTERNATIVES ARE, YOU KNOW, UP FOR
14
COMMENT BASICALLY, AND NONE OF THEM ARE REALLY SET IN
15
STONE.
I MEAN IF THERE'S A COMPONENT THAT YOU FEEL REALLY
16
STRONGLY ABOUT THAT WE SHOULD EMPLOY IN OUR PREFERRED
17 . ALTERNATIVE, WE NEED TO KNOW THAT, AND THESE ARE ALL, YOU
18
KNOW -- WE CAN KIND OF CONTOUR THE REMEDY TO MAKE SURE THAT
IT'S PROTECTIVE, WHICH IS OUR FIRST GOAL, AND ALSO THAT IT
19
20
21
BAS COMMUNITY ACCEPTANCE, WHICH IS ONE OF THE CRITERIA THAT
WE NEED TO USE.
22
23
OUR FIRST GOAL THOUGH IS MAKE SURE WE PREVENT ANY
EXPOSURE AND PREVENT ANY FURTHER EXPOSURE, AND THEN THE
24
25
OTHER ALTERNATIVES -- THE CRITERIA THAT WE LOOK AT INCLUDE
COMMUNITY ACCEPTANCE, SO OUR PROPOSED AL -- OUR PREFERRED
16
-------
.- r;
1 . ALTERNATIVE IS ALTERNATIVE 3C, walCH IS LISTED IN THE FACT
2
3
SHEET AND ALSO IN THE FEASIBILITY STUDY.
I'M GOING TO
THROW UP THAT SCHEMATIC RIGHT HERE.
BASICALLY THERE'S FOUR
4
COMPONENTS TO IT.
THE FIRST ONE IS LIMITED EXCAVATION, AND
5
6
WHAT WE WANT TO DO HERE 1;S IN THESE RED AREAS, THAT'S AREAS
WHERE IT'S BASICALLY AN UNDEVELOPED PROPERTY SO THAT THE
7
CONTAMINATION THAT'S IN THE SOIL UNDER THE GROUND -- UNDER
8 .THE SURFACE IS EASIER TO GET TO, AND SO WHAT WE'D LIKE TO
9
DO IS EXCAVATE THAT SOIL AND CONSOLIDATE IT OVER HERE IN
10
THIS MIDDLE ABOVE WHERE THE RESERVOIR IS TO FREE UP THIS
11 PROPERTY (INDICATING) FOR UNRESTRICTED DEVELOPMENT.
12
THE SECOND COMPONENT IS AN INSTITUTIONAL CONTROL,
WHICH IS KIND OF A FANCY PHRASE FOR ANY NUMBER OF THINGS,
13
14
INCLUDING DEED RESTRICTION, NOTICES ON THE DEED THAT JUST
LET PEOPLE KNOW WHAT IS AT THE SITE ALL THE WAY TO SOME
15
16
KIND OF ZONING RESTRICTION OR A DESIGNATION BY THE STATE
17
THAT THIS IS A HAZARDOUS PROPERTY WITH LIMITED USE.
WE'LL
18
BE WORKING WITH THE PROPERTY OWNERS AND THE CITY AS WELL AS
19
THE STATE TO DETERMINE WHAT EXACTLY NEEDS TO BE DONE ON
20
EACH PARCEL AROUND HERE WHERE WE FOUND CONTAMINATION
21
( INDICATING) AS WELL AS THIS CENTRAL AREA THAT WE'RE GOING
TO BE PAVING, WHICH IS THE THIRD COMPONENT OF THE
22
23
24
ALTERNATIVE, TO MAKE SURE THAT WE ARE BEING PROTECTIVE BUT
ALSO NOT BEING TOO RESTRICTIVE IN ALLOWING SOME USE.
SINCE
25
WE'VB DONE A PRETTY THOROUGH INVESTIGATION ON EACH PARCEL,
17
-------
1 . WE CAN TELL WHAT IS UNDERNEATH BACH PARCEL, SO WE CAN LET
2
3
PEOPLE KNOW WHAT THE RISKS ARE.
IF THE RISKS ARE AT 25
FEET, WE CAN PRETTY MUCH ALLOW, YOU KNOW, USE OF 20 FEET OF
THE PROPERTY, AND SO MOST OF THE PROPERTY IS ALREADY
4
5
DEVELOPED AROUND HERE.
WE WILL NOT BE DOING ANY -- WE
6
7
WON'T BE IMPACTING THE CURRENT BUSINESSES THAT WE HAVE THAT
ARE ON THE SITE.
8 .'.
THE THIRD COMPONENT IS THIS GREEN HATCHED AREA,
9
10
R.C.R.A. IS THE
WHICH IS WHAT WE CALL THE R.C.R.A. CAP.
RESOURCE, CONSERVATION. AND RECOVERY ACT, WHICH IS A FEDERAL
11 . LAW THAT REGULATES HAZARDOUS WASTE SITES, HAZARDOUS WASTE
12
GENERATORS AND HAZARDOUS MATERIALS, AND SO WHILE IT DOESN'T
DIRECTLY APPLY TO THE SITE BECAUSE THIS WASN'T REALLY A
13
14
MUNICIPAL LANDFILL AND IT WASN'T A HAZARDOUS WASTE
15
16
LANDFILL, THEY ADDRESS A LOT OF THE SAME CONCERNS THAT WE
HAVE HERE, WHICH IS CONTACT WITH THE EXPOSURE -- CONTACT
17 'WITH THE CONTAMINATION, WHICH LEADS TO EXPOSURE AND
18
19
PREVENTION OF GROUNDWATER CONTAMINATION.
WHAT CAN HAPPEN
IN SOME INSTANCES IS IF YOU HAVE SOIL THAT'S CONTAMINATED,
YOU HAVE RAINWATER HIT THE GROUND, AND IT FLUSHES THROUGH,
20
21
YOU KNOW, THAT'S HOW WATER GETS INTO THE GROUND, AND IT
FLUSHES THE CONTAMINATION THROUGH AND CAN LEAD TO
22
23
GROUNDWATER CONTAMINATION.
SO WE WANT TO PREVENT THAT FROM
24
HAPPENING BY PUTTING A PHYSICAL BARRIER HERE, WHICH IS
25 ASPHALT, AND UNDERNEATH IT A THIN PLASTIC LAYER, WHICH IS,
18
-------
1 . YOU KNOW, PRETTY TOUGH TO POKE A HOLE THROUGH IT SO THAT WE
2
3
HAVE TWO LAYERS THAT WATER CAN'T GET THROUGB, AND WATER
WILL BE SHEDDED OFF TO THE SIDES HERE (INDICATING).
THAT
4
WOULD PREVENT GROUNDWATER FROM BECOMING CONTAMINATED BY
5
SOME RAINWATER FLUSBING THROUGH, AND IT WILL ALSO PROVIDE A
PHYSICAL BARRIER TO PEOPLE SO THAT THEY WON'T -- IT MAKES
6
7
IT MORE DIFFICULT TO DIG A BOLE THROUGH, YOU KNOW, SIX
8 . ..INCHES OF ASPHALT THAN IF WE WERE JUST TO LEAVE IT AS PLAIN
9
SOIL.
10
THEN THE FOURTH COMPONENT, AS I SAID BEFORE, IS A
11 . GAS TREATMENT AND FLARING SYSTEM IF THAT BECOMES
12
13
NECESSARY.
WE'VE GOT SEVERAL VAPOR WELLS THROUGHOUT THE
SITE, SO IF WE DO NEED TO EMPLOY SOME KIND OF GAS
COLLECTION AND TREATMENT SYSTEM, WE'VB GOT A LOT OF THE
14
15
APPARATUS ALREADY THERE, BUT WE'LL BE DOING MORE
INVESTIGATIONS INTO THAT AREA DURING DESIGN TO MAKE SURE
16
17
THAT'S NECESSARY, AND THEN WE'LL BE MONITORING EVERY YEAR
TO MAKE SURE THAT OUR REMEDY IS BEING PROTECTIVE AND THAT
18
19
20
GROUNDWATER IS NOT BECOMING MORE CONTAMINATED AND THAT GAS
IS NOT MIGRATING FROM UNDERNEATH THIS CAP AND COMING OUT,.
21
YOU KNOW, THE SIDES, SO WE'LL BE MONITORING EVERY YEAR AND
THEN EVALUATING OUR REMEDY AT LEAST EVERY FIVE YEARS, walCH
22
23
IS BY STATUTE WE HAVE TO LOOK AT EVERY FIVE YEARS OUR
REMEDY TO MAKE SURE IT'S PROTECTIVE BECAUSE WE ARE LEAVING
24
25
WASTES IN PLACE HERE.
19
-------
1 .
OKAY.
LET ME GO BACK THROUGH -- OH, I'LL JUST
2
3
SHOW YOU THIS REAL QUICK.
THIS IS THE R.C.R.A. CAP, walCH
IS KIND OF A SCHEMATIC OF WHAT WE HOPE THAT OUR CAP WOULD
4
5
BASICALLY WE'VE GOT THE WASTE MATERIAL DOWN
LOOK LIKE.
HERE ( INDICATING), AND WE'VE GOT FIVE FEET OF ALREADY . SOIL
6
WHAT WE WOULD DO IS THIS WOULD BE THE
COVERING.
7
CONSOLIDATED MATERIAL WE'D EXCAVATE FROM THE OTHER AREAS OF
8 . THE SITE, AND THEN WE'D HAVE THE FLEXIBLE MEMBRANE LAYER
9
OVER THE WHOLE THING AND THEN SIX INCHES OF ASPHALT OVER
10
11
THE TOP OF THAT.
OKAY.. I WANT TO TALK A LITTLE BIT ABOUT THE
12
OTHER ALTERNATIVES WE LOOKED AT, AND THEY'RE ALSO EXPLAINED
13
THE FIRST ONE, THE NO ACTION
IN THE FACT SHEET.
14
ALTERNATIVE, WE ARE REQUIRED BY LAW TO LOOK AT AS KIND OF A
BASELINE FOR IF WE JUST WALKED AWAY FROM THE SITE, WHAT
15
16
WOULD THE RISKS BE, WHAT WOULD THE COSTS BE, AND THEN WE
USE THAT AS A COMPARISON.
17
18
WE WOULD -- INCLUDED IN THAT NO ACTION
19
ALTERNATIVE IS SAMPLING.
WE WOULD HAVE TO CONTINUE TO
20
21
SAMPLE THE GROUNDWATER IN THE SOIL AND THE VAPOR BECAUSE OF
THE WASTES LEFT IN PLACE.
ALTERNATIVE TWO IS FENCING,
22
REVEGETATION AND INSTITUTIONAL CONTROLS.
THAT'S PRETTY
23
SELF-EXPLANATORY.
WE'D AUGMENT THE FENCES WE HAVE
24
25
CURRENTLY AROUND THE SITE TO MAKE IT TALLER AND LESS
ACCESSIBLE WITH BARBED WIRE OR RAZOR WIRE, REVEGETATE THE
20
-------
1 . AREAS THAT WE DUG AND PUT TBE WELLS IN TO MAKE SURE WE HAVE
2
NOT ANY BARE SPOTS THAT WE CREATED AND THEN JUST PUT THOSE
3
4
INSTITUTIONAL CONTROLS IN.
THEY WOULD BE DIFFERENT FROM
THE ALTERNATIVES DOWN HERE BECAUSE WE WOULDN'T HAVE ALLOWED
ANY USE OF THAT CENTRAL PROPERTY BECAUSE WE HADN'T DONE
5
6
ANYTHING TO IT, SO WE'D WANT TO MAKE SURE THAT IT
7
DOESN'T -- IT WON'T BE DISTURBED.
WE'D RAVE SIMILAR
8 . CONTROLS THAT WE WOULD HAVE FOR THE OTHER ALTERNATIVES
9
10
AROUND THOSE BUSINESS PROPERTIES, YOU KNOW, THESE -- THESE
PROPERTIES HERE ( INDICATING) .
WE'D BASICALLY BE FENCING
11 . THIS WHOLE AREA AROUND HERE AND THEN PREVENTING ANY FUTURE
12
13
USE.
ALTERNATIVE THREE IS BASICALLY THE CONTAINMENT
14
15
OPTIONS, AND WE DIVIDED THEM INTO FOUR DIFFERENT
CONTAINMENT OPTIONS AND DEGREES OF COMPLEXITY.
THE FIRST
16
ALTERNATIVE IS A MULTI-LAYER SOIL CAP.
IT BASICALLY WOULD
17 . BE AN AUGMENTATION OF WHAT WE ALREADY HAVE.
WE'VE GOT FIVE
18
FEET OF SOIL COVERING THE CONTAMINATION.
WE WOULD PUT AN
19
20
ADDITIONAL CLAY LAYER DOWN TO MAKE IT LESS PERMEABLE TO
WATER, AND THEN WE'D PUT DOWN TWO FEET OF TOP SOIL SO THAT
THEN PLANTS AND SHRUBS COULD GROW THERE I AND THEY WOULD
21
22
23
HAVE TO BE MAINTAINED LIKE A -- LIKE A REGULAR LAWN, AND
THAT WOULD BE OVER THE ENTIRE AREA THAT'S EXPOSED RIGHT
24
25
NOW I WHICH WOULD BE THIS WHOLE AREA (INDICATING) AND NOT --
NOT JUST THIS SQUARE BUT ALSO THESE PARCELS HERE
21
-------
1 . (INDICATING).
2
3
ALTERNATIVE 3B COVERS THAT SAME AREA" ANY AREA OF
THE SITE THAT IS UNDEVELOPED, AND IT HAS POTENTIAL FOR
4
5
EXPOSURE BECAUSE IT'S LESS -- YOU KNOW, THERE'S LESS
PHYSICAL BARRIER THERE.
MOST OF THE SITE IS COVERED WITH
6
CONCRETE OR PAVEMENT OR BUILDINGS, SO WE DON'T NEED TO ADD
ANYTHING TO THAT BECAUSE THAT'S A PRETTY EFFECTIVE BARRIER,
7
8
BUT IN THE AREAS THAT ARE UNDEVELOPED, WE'D PUT JUST A
SIMPLE ASPHALT CAP, BASICALLY KIND OF LIKE A PARKING LOT.
9
10
THE THIRD ALTERNATIVE, walCH I EXPLAINED IS
11 . E.P.A.'S PREFERRED ALTERNATIVE, IS THE ASPHALT CAP WITH AN
12
13
ADDITIONAL PLASTIC LAYER UNDERNEATH IT AS AN ADDED
PROTECTION LAYER FOR GROUNDWATER INFILTRATION AND A
14
BARRIER FOR, YOU KNOW, CONTACT AND EXPOSURE.
THE FOURTH ONE IS BASICALLY MORE LAYERS THAN 3C.
15
16
A FULL R.C.R.A. CAP AND THE GUIDELINES FOR CLOSING A
17
MUNICIPAL LANDFILL, THERE ARE JUST SOME ADDITIONAL LAYERS
OF STONES, COBBLES, THAT KIND OF THING THAT ARE ALSO
18
19
20
REQUIRED.
IT MAKES THE CAP ABOUT FIVE FEET THICK, AND
WITHOUT ANY REAL ADDITIONAL BARRIERS TO RAINWATER
21
22
INFILTRATION, WE FEEL THAT WE NEED THE REQUIREMENTS walCH
ARE TO BE PROTECTIVE OF GROUNDWATER AND PROTECTIVE OF HUMAN
23
24
HEALTH BY EXPOSURE BY THE MORE SIMPLE ASPHALT THAN THE
PLASTIC LINER.
25
MR. SHARP:
QUESTION?
ON THE PREVIOUS SLIDE YOU
22.
-------
-~
1 -SHOWED THE AREA FENCED.
IF I'M UNDERSTANDING THE
2
3
PRESENTATION, THE RED AREAS WILL BE EXCAVATED.
THAT
4
MATERIAL WILL BE MOVED INTO THE GREEN AREA, THEN THE ENTIRE
AREA WILL CONTINUE TO BE FENCED, AND THE ENTIRE AREA WILL
5
6
BE COATED WITH AN ASPHALT LAYER?
MR. BARRIS-BISHOP:
YES.
WITH OUR --
7
ALL THE ENTIRE SURFACE AREA WITHIN THE
MR. SHARP:
8
9
FENCE?
MR. HARRIS-BISHOP:
YEAH, THE AREA WITHIN HERE
10
11
( INDICATING) .
WE DON'T ACTUALLY -- WE WOULD NOT REQUIRE A
FENCE ALONG THIS BORDER.
WE'VE GOT A FENCE ALREADY ALONG
12
HERE (INDICATING).
13
MR. SHARP:
SO THE FENCE WOULD REMAIN ON THE OUTSIDE
14
PERIMETER OF THE ENTIRE PROPERTY.
INSIDE THE FENCE IT
15
WOULD BE ASPHALTED.
16
MR. BARRIS-BISHOP:
YEAH.
ACTUALLY THOUGH -- I MEAN
17
THE ISSUE OF A FENCE IS SOMETHING THAT CAN BE DEALT WITH
18
LATER.
THAT WOULD PROBABLY BE MORE OF A PROPERTY OWNER'S
19
20
DECISION BECAUSE WITH THIS CAP, WE WOULD BE PROTECTIVE, SO
WE WOULDN'T NECESSARILY NEED THE FENCE TO-BE THERE TO ADD
21
THAT EXTRA LAYER OF PROTECTION BECAUSE WE'VE ALREADY
22
EXCAVATED THE CONTAMINATED SOIL FROM HERE.
PROBABLY A
23
24
FENCE WOULD BE A GOOD IDEA JUST TO KEEP PEOPLE FROM BEING
ON THE- PROPERTY, YOU KNOW, SKATEBOARDERS OR WHATEVER, SINCE
IT MAY BE AN ATTRACTIVE SKATEBOARDING AREA IF IT'S A NICE,
25
23
-------
1
1 . SMOOTH ASPHALT SURFACE.
2
3
MR. SHARP:
QUESTION.
IF THE GREEN AREA IS THE AREA
THAT YOU'RE CONCERNED WITH, WHY WOULD NOT THE FENCE BE
MOVED BACK TO THE GREEN AREA SO ALL THE WHITE AREA, WHICH
4
5
BAD BEEN EXCAVATED AND THE IMPURITIES REMOVED FROM THE
6 . SOIL, BE ABLE TO BE OPEN FOR DEVELOPMENT?
7
PULL UP THE OTHER SLIDE BECAUSE WHAT YOU
MR. OPALSKI:
8 .NEED TO CLARIFY IS SOME OF THE ALTERNATIVES CALL FOR THAT
9
EXCAVATION AND OTHERS DO NOT.
10
11
MR. HARRIS-BISHOP:
THIS ONE (INDICATING)?
MR. SHARP:. I THINK WE'RE ONLY DEALING WITH 3C, AND
THAT'S YOUR PREFERRED, SO I THINK --
12
13
MR. HARRIS-BISHOP:
I WANTED TO EXPLAIN ALL THE
14
ALTERNATIVES THOUGH SO THAT EVERYONE KNOWS THAT ALL THOSE
15
ALTERNATIVES ARE STILL, YOU KNOW, DEBATABLE.
WE CAN
16
DISCUSS THOSE, AND THEY'RE ALL UP FOR DISCUSSION.
17
THE REPORTER:
WOULD YOU IDENTIFY YOURSELF, PLEASE?
18
MR. SHARP:
BEG YOUR PARDON?
19
20
THE REPORTER:
WOULD YOU IDENTIFY YOURSELF?
MR. SHARP:
MY NAME'S ALBERT SHARP, S-H-A-R-P.
21
MR. HARRIS-BISHOP:
SO YEAH, WE'D BE EXCAVATING THESE
22
RED AREAS SO THAT THEY COULD UNDERGO SOME FUTURE
23
24
DEVELOPMENT.
IF THE OWNER OF THE PROPERTY WANTS THAT TO BE
FENCED, I MEAN THAT WOULD BE THEIR DECISION, BUT THE
FENCING THAT WE HAVE CURRENTLY IS TO PREVENT PBOPLE FROM
25
24
-------
1 . COMING ONTO THE SITE.
WITH OUR CAP, WE WOULD BE
2
3
PROTECTIVE, SO WE WOULDN'T NEED THAT EXTRA LAYER OF
PROTECTION, WHICH IS BASICALLY A FENCE.
4
MARILYN, DO YOU HAVE A --
5
MS. UNDERWOOD:
SO JUST TO CLARIFY, YOU'RE NOT
6
PROPOSING TO PAVE THE AREA THAT WAS EXCAVATED.
7
8
NO.
BECAUSE THEN THAT WILL BE
MR. BARRIS-BISHOP:
OPEN TO FUTURE DEVELOPMENT BECAUSE WE WOULD BE REMOVING THE
9
RISK THAT WAS PROPOSED WITH DEVELOPMENT BECAUSE WITH
10
YOU'D
DEVELOPMENT THERE WOULD BE A FOUNDATION, WHATEVER.
11 . HAVE TO GET DOWN AND POTENTIALLY BE EXPOSED.
WE'D BE
12
13
REMOVING THAT RISK.
MR. SHARP:
WOULD YOU CLARIFY THAT THEN ONCE AGAIN
14
BECAUSE I ASKED A QUESTION, AND YOU SAID IT WOULD BE
15
PAVED.
SHE ASKED THE SAME QUESTION; YOU SAID IT WOULDN'T
16
BE.
INSIDE THE EXISTING FENCED AREA, ONLY THE GREEN AREA
17
NOW OUTLINED WILL BE PAVED.
18
MR. BARRIS-BISHOP:
YEs.
19
20
MR. SHARP :
ALL THE REST WILL BE DEVELOPABLE WITH
DIRT, WITH ALL THE FOUNDATIONS AND THOSE CONSEQUENCES AMD
21
EVERYTHING REMOVED.
22
MR. OPALSKI:
RUSTY, LET ME CLARIFY.
AGAIN, I WANT TO
23 .CLARIFY THERE HASN'T BEEN A DECISION MADE, SO WE HAVE TO BE
24
REAL PRECISE HOW WE'RE ASKING THAT QUESTION.
UNDER 3C,
25
E.P.A.'S PREFERRED ALTERNATIVE, WHAT YOU STATE IS TRUE.
25
-------
'-
1
2
ONLY THE AREA THAT'S IN THE GREEN HATCH WOULD BE PAVED,
OKAY?
UNDER SOME OF THE OTHER ALTERNATIVES, INCLUDING THE
3
ALTERNATIVE RUSTY DISCUSSED, IT WAS JUST THE FENCING WITH
4
INSTITUTIONAL CONTROLS.
THERE WOULDN'T BE ANY EXCAVATION
5
6
IN THOSE AREAS, AND, THEREFORE, FOR PROTECTIVENESS THE
FENCING WOULD BE EXPANDED TO INCLUDE THE AREAS THAT ARE IN
7
RED BECAUSE UNDER THAT ALTERNATIVE, THERE WOULDN'T BE THE
EXCAVATION.
8
9
10
MR. HARRIS-BISHOP:
SO NONE OF THAT LAND WOULD BE
FREED UP FOR DEVELOPMENT BECAUSE CONTAMINATION STILL EXISTS
11
12
AND THE RISK FOR EXPOSURE WOULD STILL EXIST.
MR. OPALSKI:
IS THAT CLEAR THOUGH?
I WANT TO MAKE
13
SURE.
14
MR. SHARP:
NO, IT HASN'T CHANGED ANY SINCE 1984.
15
MR. OPALSKI:
NO, I WANT TO MAKE SURE WE'RE CLEAR
16
BEFORE WE MOVE ON BECAUSE IT'S AN IMPORTANT QUESTION.
THE
17
DIFFERENCE IS THAT WE'RE ANSWERING -- I GUESS THE POINT IS
18
THE ANSWER TO THE QUESTION IS DIFFERENT DEPENDING ON WHICH
19
ONE OF THESE ALTERNATIVES YOU'RE ASKING ABOUT.
UNDER
20
21
E.P.A.'S PREFERRED ALTERNATIVE, THE EXCAVATION IN THE RED
AREA OCCURS, THE EXCAVATED MATERIAL GETS MOVED TO THE AREA
22
WHERE THE CONCRETE SUMP IS, AND A CAP IS PUT OVER THAT
23
24
AREA.
THE CAP DOES NOT EXTEND TO AREAS WHERE THE
EXCAVATION'S OCCURRED, SO THAT'S UNDER THE E.P.A.'S
PREFERRED ALTERNATIVE, THE ONE THAT'S PRESENTED AS
25
26
-------
1 "ALTERNATIVE 3C.
2
MR. SHARP:
UNDER YOUR PREFERRED, ALL THE WHITE LAND
3 AND THE LAND NOW IN RED WOULD BE FREE FOR COMMERCIAL
4
DEVELOPMENT?
5
MR. OPALSKI:
THAT'S CORRECT.
6
WITH THE TILT-UP BUILDINGS OR WHATEVER THE
MR. SHARP:
7
8
PROPERTY OWNER WISHED TO PUT IN THAT AREA.
MR. HARRIS-BISHOP:
WITH THE INSTITUTIONAL CONTROLS
9
THAT WOULD BE REQUIRED FOR THE PROPERTIES THAT STILL HAVE
10
WE'RE ONLY EXCAVATING THE
CONTAMINATION UNDERNEATH THEM.
11 "UNDEVELOPED AREAS BECAUSE WE CAN GET TO THEM WITHOUT
12
IMPACTING THE BUSINESSES.
THERE'S STILL SOME UNDERLYING
13
CONTAMINATION IN THESE PARCELS THAT ALREADY HAVE BUILDINGS
14
AND PARKING LOTS THAT WE WOULD HAVE TO DO SOME KIND OF
15
16
RESTRICTION, EITHER A DEED NOTICE JUST SAYING THAT THERE IS
CONTAMINATION UNDER THESE PROPERTIES AND WHAT THAT
17
18
CONTAMINATION IS OR A ZONING RESTRICTION SAYING WHAT CAN
AND CAN'T BE DONE TO THE PROPERTY AND PERHAPS GO AS FAR AS,
IF WE CAN'T WORK THAT OUT, RAVING THE STATE DESIGNATE IT AS
19
20 A HAZARDOUS WASTE PROPERTY, WHICH HAS ITS OWN SUBSEQUENT
21
22
RESTRICTIONS ON USE.
WE CAN'T REALLY -- B.P.A. CAN SAY
WE'D RATHER NOT HAVE ANYONE DIG UNDER ANY OF THESE
23
PROPERTIES WHERE WE HAVEN'T REMOVED THE MATERIAL, BUT WE
CAN'T PREVENT ANYONE FROM GOING OUT THERE AND DIGGING ON
24
25
THEIR OWN PROPERTY.
WHAT WE'D LIKE TO DO THOUGH IS
27
-------
1
MITIGATE ANY CHANCE. OF EXPOSURE BY LETTING PEOPLE KNOW AND
2
3
LETTING SUBSEQUENT OWNERS KNOW THAT THERE IS CONTAMINATION
THERE AND WHAT THE RISKS ARE THAT ARE POSED BY DOING THESE
4
ACTIVITIES.
THE CURRENT ACTIVITIES AT THE SITE DON'T POSE
5 ANY RISK FROM -- YOU KNOW, THEY DON'T POSE ANY EXP.oSURE TO
6
THE CONTAMINATION.
WHAT WE WANT TO PREVENT IS ANY FUTURE
7
8
EXPOSURE BY DIGGING OR SOMETHING AND LETTING PEOPLE KNOW
WHAT IS UNDER THERE, AND THAT'S WHAT THOSE INSTITUTIONAL
9
CONTROLS WOULD BE FOR ON THE SURROUNDING PROPERTIES.
WE
10
HAVE INSTITUTIONAL CONTROLS ON THIS PAVED AREA ALSO BECAUSE
11
12
WE WANT TO MAKE SURE THAT WHATEVER IS DONE ON THAT
PROPERTY, THE FIRST GOAL, WHICH IS TO BE PROTECTIVE, IS
MAINTAINED BY KEEPING THAT CAP, YOU KNOW, THE INTEGRITY OF
13
14
THAT CAP MAINTAINED BY NOT PUTTING SOMETHING ON THERE
15
16
THAT'S GOING TO CRUSH IT OR CRACK IT OR, YOU KNOW, SPLIT IT
OPEN, SO THERE -- THERE CAN BE SOME LIMITED USES FOR THE
17
18
PROPERTY, BUT WE WANT TO MAKE SURE THAT WE ARE BEING
PROTECTIVE.
19
20
MS. HERRERA:
RUSTY, WE HAVE A QUESTION.
MR. HARRIS-BISHOP:
FATHER GALLAGHER?
21
22
FATHER GALLAGHER:
MY NAME IS GALLAGHER, AND WHAT I'M
INTERESTED IS IN KNOWING:
IS THAT THE ONLY PURPOSE OF THAT
23
24
CAP IS TO PREVENT RAINWATER FROM PASSING THROUGH THE TOP
LEVEL OF SOIL AND THEN TAKING WHATEVER ELEMENTS ARE BELOW
25
THERE TO A DEEPER LEVEL WHERE THE GROUNDWATER WOULD BE
28
-------
-
1
2
AFFECTE~; IS THAT CORRECT?
THAT'S ONE OF THE PURPOSES.
MR. HARRIS-BISHOP:
THE
3
4
OTHER PURPOSE IS TO MAKE -- PROVIDE ANOTHER PHYSICAL
BARRIER TO THE CONTAMINATION AND ALSO TO ALLOW SOME LIMITED
5
6
USE OF THE PROPERTY.
FATHER GALLAGHER:
IF THERE IS ALREADY FIVE FEET OF
7
UNCONTAMINATED SOIL THERE, IS E.P.A. NOT CONVINCED THAT THE
CITY OF SANTA FE SPRINGS KEEPS GOOD ENOUGH RECORDS OF WHAT
8
9
IS GOING ON ON THEIR PROPERTIES THAT THEY WOULD NEVER USE
10
THAT PROPERTY, FOR EXAMPLE, TO BUILD A 50-STORY BUILDING OR
11
12
SOMETHING LIKE THAT?
MR. HARRIS-BISHOP:
NO.
I MEAN THAT'S -- IF WE
13
WERE -- IF WE WEREN'T GOING TO PUT THIS PAVEMENT HERE, THEN
14
WE WOULD HAVE THAT RESTRICTION IN PLACE, THAT, YOU KNOW,
15
16
WHAT COULD AND COULDN'T BE DONE ON THE PROPERTY BECAUSE WE
DON'T WANT TO HAVE ANY POTENTIAL -- AFTER WE'RE ALL GONE,
WITHIN 100 YEARS FROM NOW, WE'D HOPE THAT THOSE
17
18
RESTRICTIONS WOULD STILL BE IN PLACE.
19
20
FATHER GALLAGHER:
SO AGAIN, MY QUESTION OR MY COMMENT
WOULD BE THAT -- THAT ANY KIND OF ACTIVITY THAT'S GOING ON
21
ON THAT PROPERTY RIGHT NOW IS REALLY -- THERE'S ABSOLUTELY
NO PROBLEM ABOUT THE SAFETY OF THAT PROPERTY.
22
23
MR. HARRIS-BISHOP:
NO.
24
25
FATHER GALLAGHER:
IN OTHER WORDS, JUST THE FENCE IS
PROTECTIVE.
29
-------
1
2
MR. HARRIS-BISHOP:
YEAH .
AND WE JUST WANT TO MAKE
SURE THAT THAT CONTINUES TO BE, AND A FENCE IS A LIMITED
3
4
PROTECTION MEASUREMENT.
I MEAN, AS YOU KNOW, THAT FENCE
BAS BEEN CLIMBED OVER AND STEPPED ON, AND I THINK EVEN A
SECTION HAS BEEN, I THINK, REMOVED, SO A FENCE IS ONLY --
5
6
IS A SHORT-TERM ALTERNATIVE.
WITH AN ASPHALT CAP, WE FEEL
7
8
THAT HE HAVE A LONG-TERM PROTECTIVE MEASURE.
LIKE WE
LOOKED AT THESE OTHER ALTERNATIVBS.
YOU KNOW, THERE ARE
9
PROS AND CONS WITH ALL OF THESE ALTERNATIVES.
THIS ONE WE
10
FEEL MEETS ALL OF OUR REQUIREMENTS AND OUR GOALS, WHICH IS
TO BE PROTECTIVE AND PREVENT LONG-TERM EXPOSURE.
11
12
THE CURRENT CONFIGURATION AS IT IS NOW IS
13
MODERATELY PROTECTIVE, BUT IN THE LONG-TERM, WE CAN'T
ENSURE THAT, YOU KNOW, SOMEONE ISN'T GOING TO GO OUT THERE
14
15
AND -- AND BECOME EXPOSED INADVERTENTLY TO THAT DEPENDING
16
ON THE DEVELOPMENT SO --
17
18
FATHER GALLAGHER:
BUT IN ORDER TO BE EXPOSED TO THAT,
THEY WOULD HAVE TO DIG 25 FEET BELOW GROUND?
19
MR. HARRIS-BISHOP:
WELL, THEY'D HAVE TO DIG AT LEAST
20
21
FIVE FEET TO COME IN CONTACT WITH ANY CONTAMINATION, AND
MOST OF THE CONTAMINATION IN THIS AREA IS, IN FACT, AT 10
22
TO 15 FEET.
23
FATHER GALLAGHER:
BUT THAT WILL ALREADY BE RESTRICTED
24
BY CITY ORDINANCE.
25
MR. HARRIS-BISHOP:
CITY ORDINANCE OR A RESTRICTION ON
30
-------
1
2
THE DEED, NOTICE ON THE DEED.
YES, MA'AM.
3
EXCUSE ME.
WOULD YOU STATE YOUR NAME?
MS. HERRERA:
4
MS. CABRAL:
YOU'RE SAYING YOU'RE GOING TO PUT A CAP
5
ON THAT GREEN AREA, AND I KNOW RIGHT THERE WITH THE
BASEBALL FIELD AND ST. PAUL, IT'S NOT FLAT.
6
7
MR. HARRIS-BISHOP:
IT'S ACTUALLY -- IT KIND OF SLOPES
8
DOWN THROUGH HERE (INDICATING).
9
MS. CABRAL:
IT'S ABOUT TEN FEET HIGH.
10
11
MR. HARRIS-BISHOP:
WE CAN ACTUALLY MAKE --
MS. CABRAL:
THAT'S GOING TO BE GOING DOWN TO THE
12
13
GROUND.
MY NAME IS LOUIS CABRAL.
ON THAT SITE
MR. CABRAL:
14
15
THERE, ARE THEY GOING TO JUST PUT IT ON TOP AND NOT ON THE
SIDE?
16
MR. HARRIS-BISHOP:
NO.
IT'S GOING TO GO ALL THE WAY
17
TO THE PROPERTY LINE, walCH IS DOWN AT THE BOTTOM OF THAT
18
SLOPE, BECAUSE WE NEED TO MAKE SURE THAT WE HAVE A UNIFORM
19
DRAINAGE, SO WE WOULD HAVE A SLOPE, AN ASPHALT SLOPE, ALL
20
THE WAY DOWN HERE (INDICATING) AND THEN SOME KIND OF
DRAINAGE TO TAKE THAT WATER FROM THE RAINWATER THAT RUNS
21
22
23
OFF TO THE STORM DRAIN.
MR. CABRAL:
ALL WHAT YOU'RE DOING IS TALKING ABOUT
24
COVERING EVERYTHING UP.
25
MR. HARRIS-BISHOP:
YES, WITH SOIL.
31
-------
1
2
ACTUALLY, THE MAIN PLAN IS JUST COVERING
MR. CABRAL:
EVERYTHING UP.
3
MR. BARRIS-BISHOP:
YES.
4
5
AND LET SOMEBODY ELSE WORRY ABOUT IT DOWN
MR. CABRAL:
THE LINE WHO USES THE PROPERTY.
6
7
TO PREVENT SOMEONE FROM COMING
MR. BARRIS-BISHOP:
8
INTO CONTACT WITH IT, YEAH, THAT'S THE BEST ALTERNATIVE
THAT WE CAN HAVE TO BE PROTECTIVE AND ALSO, YOU KNOW, HAVE
9
10
SOME KIND OF LIMITED USE.
THE FOURTH ALTERNATIVE --
11
12
MR. MORENO:
RICK MORENO.
IS IT TOO EXPENSIVE TO
CLEAN IT UP?
13
MR. HARRIS-BISHOP:
YEAH .
14
MR. MORENO:
IS THAT WHY YOU CAN'T CLEAN IT UP?
15
MR. HARRIS-BISHOP:
THAT'S THE FOURTH ALTERNATIVE,
16
17
WHICH WAS -- ACTUALLY, WE LOOKED AT A COUPLE OF
ALTERNATIVES THAT WERE EXCAVATION AND OFF-SITE DISPOSAL OF
18
19
THAT SOIL.
THIS AREA WE'RE TALKING ABOUT IS ALMOST
THREE-QUARTERS OF A MILLION CUBIC YARDS OF CONTAMINATED
SOIL THAT WOULD HAVE TO BE REMOVED, AND THE ESTIMATED COST
20
21
22
ON THAT IS ABOUT 120 MILLION DOLLARS, AND THIS HAS
CURRENTLY BEEN A TAXPAYER FUNDED PROJECT, SO IT -- AND THE
23
24
MAIN THING IS THAT THE RISKS THAT ARE POSED BY THE SITE
WITH THAT MATERIAL ARE FAIRLY LOW.
IF THIS WERE SOMETHING
25
THAT WERE GOING TO BE AN IMMEDIATE HEALTB TBREAT OR A HIGH
32
-------
1
2
RISK MATERIAL THAT, YOU KNOW, CON -- WHERE PEOPLE COULD
COME CONTAMINATED WITH, WE WOULD DO THAT.
WE WOULD REMOVE
3
4
THE SOIL, BUT THE CONTAMINATION IS FAIRLY LOW LEVELS, AND
IT DOESN'T POSE A RISK UNLESS -- WE LOOKED AT RESIDENTIAL
5
6
EXPOSURE, IF SOMEONE BUILT A HOUSE ON THIS PROPERTY AND
LIVED THERE FOR 70 YEARS, WHAT KIND OF CONTAMINATION --
7
8
WHAT KIND OF RISKS WOULD BE POSED BY THIS, AND WE LOOKED AT
IT, AND WE WERE ALMOST WITHIN OUR RISK RANGE NUMBERS
9
10
WITHOUT DOING ANYTHING.
BY PROVIDING THIS CAP, WE'RE
REDUCING ANY POTENTIAL EXPOSURE AND BECOMING -- AND BEING
11 . PROTECTIVE WITHOUT HAVING TO EXCAVATE.
12
THE OTHER -- LET ME JUST SAY ONE THING.
IF WE'D
13
EXCAVATE IT, WE'D BE GENERATING A HUGE AMOUNT OF DUST.
IF
14
WE'RE GOING TO DO THIS ENTIRE AREA, THAT WOULD TAKE A LONG
TIME AND WOULD EXPOSE THE SURROUNDING AREA, THE SCHOOL AND
15
16
THE NEIGHBORHOODS TO A HIGHER RISK.
IT'S A MUCH ELEVATED
17
18
SHORT-TERM RISK THAT DOESN'T REALLY JUSTIFY THE RE -- THE
OVERALL REDUCTION IN THE RISK AND THEN THE COST, YOU KNOW,
IS AN ASTRONOMICAL COST.
19
20
21
THE QUESTION BEHIND THE FATHER FIRST.
MS. CALDERONE:
MY NAME IS DEBORAH CALDERONE, AND I'M
22
23
CONCERNED ABOUT THE SEISMIC ACTIVITY THAT WE HAVE HERE IN
CALIFORNIA, AND NOTHING HAS BEEN SAID SO FAR ABOUT THE
REQUIREMENTS, IF THAT MEETS REQUIREMENTS TO DATE, AND WITH
24
25
THE CAPPING, WILL IT MEET FURTHER REQUIREMENTS?
33
-------
1-
1
THAT'S ONE -- IN THE -- I
MR. BARRIS-BISHOP:
YEAH .
2
3
HAVE A BRIEF EXPLANATION IN THE FACT SHEET.
WE HAVE
4
REQUIREMENTS CALLED A.R.A.R. 'S, waICH ARE APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS THAT WE HAVE TO LOOK
5
ONE OF THE THINGS THAT WE LOOK AT AS A -- AS SOMETHING
AT.
6
7
TO CONSIDER IS SEISMIC CRITERIA, AND SO WE WANT TO MAKE
SURE THAT THIS CAN WITHSTAND AN EARTHQUAKE, THAT IT'S NOT
8 . GOING TO SHIFT AND CRACK.
WITH THAT ADDED PLASTIC LINER,
9
10
WE HAVE AN ADDED LEVEL OF PROTECTION BECAUSE THE PLASTIC IS
MORE FLEXIBLE TO ALLOW FOR, YOU KNOW, SUBTLE MOVEMENTS, I
11
12
MEAN -- SO WE WILL TRY AND BE PROTECTIVE OF THOSE SEISMIC
CRITERIA.
13
YES, SIR.
14
15
FATHER GALLAGHER:
I'D LIKE -- GALLAGHER -- AND I'D
LIKE A CLARIFICATION OF WHAT YOU WERE JUST SAYING THERE.
16
IF I WERE TO BUILD A HOUSE ON THAT PIECE OF PROPERTY AND
17 LIVE IN THAT HOUSE FOR 70 YEARS, YOU ARE NOT -- YOU ARE
18
SAYING THAT AS FAR AS THE E.P.A. WOULD. BE CONCERNED, THAT
THERE'D BE NO GUARANTEE THAT I WOULD BE EXPOSED TO ANY
19
20
21
CONTAMINATED -- ANYTHING THAT WOULD HARM MY HEALTH AT ALL.
MR. HARRIS-BISHOP:
THAT'S POSSIBLE.
THE RISKS ARE
22
ELEVATED BECAUSE OF THE LEVELS OF CONTAMINATION THAT WE
23
24
HAVE HERE (INDICATING).
LIKE I SAID, MOST OF THE SOIL
CONTAMINATION IS BELOW GROUND, SO IF YOU JUST -- YOU KNOW,
JUST EXISTED PURELY ON THE SURFACE, THE CONTAMINATION THAT
25
34
-------
1
2
WE HAVE AT THE SURFACE IS LIMITED TO OVER HERE
3
(INDICATING), WHICH IS WHY WE FENCED THAT PROPERTY IN 1988,
AND SOME OF THE AREAS, I BELIEVE, THAT ARE ALREADY UNDER
4
PAVEMENT WE FOUND SOME SURFACE CONTAMINATION, SO YEAH, I
5
CAN'T SAY THAT, YOU KNOW, IF YOU BUILT A HOUSE THERE, YOU
WOULD HAVE NO RISK, BUT THE RISKS ARE FAIRLY LOW, AND THAT
6
7
SINCE MOST CONTAMINATION IS DOWN DEEP, YOU WOULDN'T RUN
INTO THAT RISK UNLESS YOU DUG, BUT YOU WILL BE DIGGING IF
8
9
YOU BUILD A HOUSE.
10
DOES METHANE COME UP LIKE AT THE LA BREA
MR. MORENO:
11 TAR PITS?
YOU HAVE -- ALL THE TIME YOU HEAR OF EXPLOSIONS
12
AND GAS, AND IT'S COMING UP ALL THE TIME EVEN THOUGH YOU
HAVE PAVEMENT THERE.
13
14
WE DO -- THAT'S WHY WE
MR. BARRIS-BISHOP:
YEAH .
15
WOULD BE LOOKING INTO THAT GAS TREATMENT AND COLLECTION
16
17
SYSTEM.
WE'VE ALREADY GOT WELLS DUG THAT HAVE DETECTED
METHANE, BUT WE NEVER DETECTED ANYTHING AT THE SURFACE.
WE
18
DETECTED IT DOWN DEEP WHERE WE HAVE THE ORGANIC MATERIAL
19
THAT'S DECOMPOSING CREATING METHANE, AND THERE'S METHANE
THROUGHOUT THIS --
20
21
MR. MORENO:
IS THAT CRUDE OIL?
22
MR. HARRIS-BISHOP:
PARDON?
23
24
MR. MORENO:
IS THAT CRUDE OIL?
MR. HARRIS-BISHOP:
NO.
IT'S ORGANIC RELATED
25
MATERIAL, A LOT OF DECOMPOSED ORGANIC MATERIAL --
35
-------
1
2
IS THERE ANY BENZENE --
MR. MORENO:
MR. HARRIS-BISHOP:
WE DID DETECT BENZENE IN ONE AREAS
3
OR TWO AREAS DOWN, AGAIN, AT DEPTH AND NOTHING AT THE
4
5
WHEN WE PUT OUR AIR ~ONITORS DOWN ON THE GROUND,
SURFACE.
WE DIDN'T DETECT ANY BENZENE OR -- WE DIDN'T DETECT
6
7
ANYTHING OTHER THAN REGULAR AIR CONSTITUENTS, BUT WE WANT
TO MAKE SURE THAT WE'RE NOT GOING TO CAUSE A BIGGER PROBLEM
8
9
BY PUTTING A CAP ON THERE BECAUSE, AS YOU PROBABLY REALIZE,
IF WE ARE PREVENTING GROUNDWATER FROM GETTING CONTAMINATED
10
BY THE RAINWATER, WE'RE ALSO PREVENTING THE GASES FROM
11 . SLOWLY COMING UP, BUT WHAT WE HAVE IS THESE HOLES ALREADY
12
13
DUG SO THAT WE CAN PULL THAT GAS OUT IF REQUIRED AND THEN
BURN IT.
14
MS. HERRERA:
BEFORE WE GO TO THE NEXT QUESTION, SIR,
15
16
WOULD YOU PLEASE STATE YOUR NAME FOR THE RECORD?
MR. MORENO:
RICK MORENO, M-O-R-E-N-O.
17
MR. HARRIS-BISHOP:
OKAY.
18
FATHER GALLAGHER:
DID YOU INTEND THIS ON BEING THE
19
QUESTION AND ANSWER SESSION --
20
MR. HARRIS-BISHOP:
ACTUALLY, IF I CAN JUST GET
21
THROUGH -- I'M ALMOST FINISHED.
I'M ALMOST AT THE END
22
23
50 . . .
THE ALTERNATIVE FOUR walCH WE LOOKED AT IN THE
24
25
FEASIBILITY STUDY WAS LIMITED EXCAVATION AND JUST TAKING
THE RED AREAS ON THIS MAP AND TAKING THEM TO AN OFF-SITE
36
-------
1
2
DISPOSAL AREA, AN ACCEPTABLE HAZARDOUS WASTE DISPOSAL AREA,
AND THEN, AGAIN, FENCING THIS CENTRAL PORTION TO PREVENT
3
4
ANYONE FROM COMING INTO CONTACT WITH IT, SO THAT'S
ALTERNATIVE FOUR.
5
6
LIKE I SAID EARLIER, WE ALSO LOOKED AT INITIALLY
EXCAVATING ANY CONTAMINATED MATERIAL FROM THE SITE.
THE
7
VOLUME IS JUST HUGE.
THE INCREASE IN SHORT-TERM RISKS IS
8
9
HIGH, AND THERE'S NOT A REAL BENEFIT TO DOING THAT BECAUSE
OF THE ADDED COST AND THE REDUCTION OF RISK IS SO SMALL
10
BECAUSE WE'VE ALREADY GOT THE- CONTAMINANTS THAT WE FOUND IN
11
12
THE SOIL, LIKE ARSENIC, THALLIUM, BERYLLIUM AND OTHER
METALS ARE ALREADY CONSTITUENT HERE.
THEY'RE NATURALLY
13
THIS IS CALIFORNIA, AND WE HAVE AN ARSENIC --
OCCURRING.
14
YOU KNOW, IT'S JUST NATIVE TO HERE, SO WE HAVE, YOU KNOW, A
15
BACKGROUND LEVEL CONTAMINATION THAT EVEN IF WE ELIMINATED
16
THAT, IT WOULD JUST BE REALLY EXPENSIVE, AND WE WOULDN'T BE
17
18
REDUCING THE RISK THAT MUCH FOR THE AMOUNT OF MONEY THAT
WE'D BE SPENDING SINCE THE RISKS ARE FAIRLY LOW AT THE SITE
19
20
ALREADY.
YES, SIR.
21
MR. SHARP:
ALBERT SHARP.
QUESTION:
BACK TO FATHER
22
23
GALLAGHER'S QUESTION.
MY UNDERSTANDING IS THAT NO
PERMANENT DWELLING OR BUILDING COULD BE BUILT ON THE GREEN
24
AREA .
25
MR. BARRIS-BISHOP:
YES.
37
-------
1
2
MR. SHARP:
YOU ASKED A QUESTION, IF I BUILT A HOUSE,
WOULD I BE ABLE TO LIVE THERE AND NOT SUFFER ILL WILL, AND
3
4
MY UNDERSTANDING IS YOU CAN'T DO
THE ANSWER WAS YES.
ANYTHING IN THE GREEN AREA EXCEPT MAKE IT A PARKING LOT OR
5 A STORAGE AREA OR SOME OTHER -- MY PERSONAL FEELING --
6
UNDESIRABLE USE OF THE PROPERTY.
7
MR. BARRIS-BISHOP:
WHAT I WAS SAYING IS BASED
YEAH .
8
ON THE CURRENT RISKS AT THE SITE, IF YOU WERE TO BUILD A
9
10
BOUSE, NOT THAT YOU CAN --
MR. SHARP:
YOU WOULDN'T BE ABLE TO GET A
11 . PERMIT.
12
13
MR. BARRIS-BISHOP:
IF YOU WERE, I MEAN THE RISKS ARE
LOW.
I'M NOT SAYING THAT YOU ARE NOT GOING TO BECOME
14
EXPOSED, BUT WHAT I'M SAYING IS THAT THE RISKS ARE F~RLY
LOW THAT YOU WOULD NOT SUFFER SOME ADVERSE CONSEQUENCE FROM
15
16
THE CONTAMINATION, BUT THAT IS POSSIBLE, SO WHAT WE WANT TO
DO IS PREVENT THAT CONTAMINATION FROM OCCURRING IN THE
17
18
19
FUTURE, SO BY PROVIDING THIS CAP AND PREVENTING ANY
CONSTRUCTION ON IT, WE WOULD PREVENT ANYONE FROM COMING
20
21
INTO CONTACT WITH THE CONTAMINATION, AND THAT'S OUR FIRST
GOAL IS TO PREVENT ANY CONTAMINATION OR EXPOSURE TO
22
CONTAMINATION, POTENTIAL OR CURRENT, AND SINCE WE DON'T
HAVE A CURRENT EXPOSURE, WE'RE LOOKING TO THE FUTURE TO BE
23
24
PROTECTIVE, SO I THINK -- YOU BAD A QUESTION, MR. CABRAL?
25
MR. CABRAL:
LOUIS CABRAL.
WHEN YOU SAID -- ON THE
38
-------
1
2
ST. PAUL OVER THERE, IF YOU PUT A CAP ON IT AND I TAKE THIS
PIECE OF PAPER AND CAPPED IT AND STOPPED THE STUFF FROM
3
4
COMING UP, OKAY, HOW ABOUT THE STUFF GOING UNDERNEATH AND
GOING OUT FROM UNDERNEATH IT, WHAT ARE YOU GOING TO DO
5
ABOUT THAT?
6
THAT'S WHAT I SAID.
WE'RE GOING
MR. HARRIS-BISHOP:
7
TO BE LOOKING INTO HOW MUCH GAS IS ACTUALLY COMING UP, AND
8
9
IF WE DO SEE GAS COMING UP, WE WILL HAVE THESE WELLS IN
PLACE TO REMOVE IT.
WE ALSO HAVE A PROPOSAL THAT'S
10
INCLUDED IN THE FEASIBILITY STUDY THAT WOULD INCLUDE
11 UNDERLAYING THE PLASTIC LINER WITH PERFORATED PVC TUBING
12
13
THAT :WOULD BE RUN INTO THE PUMP SYSTEM TO PULL OUT ALL THE
GAS.
14
MR. CABRAL:
I'M SAYING IT'S BARD HERE, AND IT'S BARD
15
HERE, BUT IT'S STILL GOING UNDERNEATH AND GOING THIS WAY
16
( INDICATING) .
MR. HARRIS-BISHOP:
THAT'S WHY WE WOULD BE PUMPING TO
17
18
REMOVE THAT GAS.
I RECOGNIZE THAT THAT'S A CONCERN, AND
19
THAT'S A CONCERN OF MINE IS IF WE ASSUME TBAT THE GAS IS
20
21
COMING UP FROM THE SOIL ALREADY, AND WE JUST BAVEN'T BEEN
ABLE TO DETECT IT, BUT IF WE PUT A CAP DOWN OR -- YOU KNOW,
22
WE WANT TO MAKE SURE THAT THAT DOESN'T HAPPEN.
THAT'S WHY
23
24
WE'VB INCLUDED THE GAS --
MR. CABRAL:
THE FENCE WILL NOT HOLD.
25
MR. HARRIS-BISHOP:
PARDON?
39
-------
.10
11
MR. . CABRAL:
THE FENCE WILL NOT HOLD ON THAT DOTTED
1
2
LINE ON THE ST.. PAUL SIDE.
THE FENCE WILL NOT HOLD?
THE GAS.
NO, NO, NO, NO.
IN FACT, THIS IS
3
4
MR. BARRIS-BISHOP:
6
A PARKING LOT THROUGH HERE (INDICATING).
WE'RE GOING TO
7
8
MR. CABRAL:
HAVE PIPING AND PUMPS AND VAPOR WELLS TO --
YOU CAN 'T TELL ME GAS IS SMART ENOUGH TO
9
GO INTO THE PIPES.
MR. CABRAL:
RIGHT.
WELL, IT'S GOING TO RISE BECAUSE
12
13
METHANE RISES, .AND SO THEN WE'RE GOING TO BE COLLECTING IT .
THROUGH THOSE PIPES, AND THOSE PIPES WILL BE ATTACHED TO A
PUMP THAT PULLS THE AIR AND CREATES A VACUUM THAT WILL SUCK
SYSTEM.
IT INTO A TREATMENT -- A COLLECTION AND THEN BURNING
15
16
FATHER GALLAGHER:
DOING AT SHERATON INDUSTRY HILLS?
YOU MEAN SIMILAR TO WHAT THEY'RE
17
18
MR. HARRIS-BISHOP:
5
MR. BARRIS-BISHOP:
YEAH, I BELIEVE --
19
FATHER GALLAGHER:
COMPLETELY OPERATED BY THE METHANE GAS THAT IS COMING FROM
THAT IS A HOTEL COMPLEX THAT IS
20
21
22
THAT LANDFILL BELOW IT.
MR. BARRIS-BISHOP:
POWERING THEIR GENERATOR OR SOMETHING.
I HAVE A COUPLE OTHER --
23
24
25
FATHER GALLAGHER:
MR. BARRIS-BISHOP:
MR. HARRIS-BISHOP:
14
SO -- YES, SIR.
YEAH .
I BELIEVE THEY USE IT AS
US-HUB .
40
-------
1
2
FATHER GALLAGHER:
ALL OF THIS -- I DON'T KNOW IF THIS
IS A QUESTION OR COMMENT OR SOMETHING, BUT IT DOES STRIKE
ME AS BEING A LITTLE BIT STRANGE THAT WE ALREADY HAVE A
3
4
CITY GOVERNMENT EMPOWERED TO MAKE DECISIONS FOR THE PEOPLE
WITHIN THE CITY BUT THAT THE E.P.A. WOULD COME IN AND
5
6
BECOME MORE RESTRICTIVE THAN YOU FEEL THAT THE CITY OF
7
SANTA FE SPRINGS WOULD BE WITH OUR ALREADY ELECTED
8 .OFFICIALS, AND YOU WOULD PUT SOMETHING -- YOU WOULD FORCE
9
THE CITY TO COMPLY BEYOND JUST THE NORMAL LEVEL OF CONCERN
10
11
THAT THE PEOPLE WHO LIVE RIGHT HERE IN THE CITY WOULD
ALREADY HAVE ABOUT WHAT IS GOING ON IN THE CITY.
THAT
12
13
WOULD BE ONE THING THAT I WOULD -- WOULD SAY.
. GALLAGHER.
THE SECOND THING IS -- IT HAS TO DO
14
WITH THE WHOLE IDEA ABOUT THE WORD CONTAMINATION IS THAT,
YOU KNOW, THERE'S A LOT OF PARENTS HERE WHO HAVE CHILDREN
15
16
WHO GO TO ST. PAUL, AND WHEN PEOPLE THINK CONTAMINATION, I
17
18
THINK THAT A LOT OF TIMES THEY'RE THINKING ABOUT NUCLEAR
CONTAMINATION, THE THREAT OF WHAT IS AIRBORN, WHAT IS
SOIL-BORN, AND I WAS LED TO UNDERSTAND IN OUR CONVERSATIONS
19
20
THAT ACTUALLY THAT WHATEVER CONTAMINATION THERE IS REALLY A
21
METALLIC CONTAMINATION FROM A VERY MINOR KIND OF A NORMAL
22
23
INDUSTRY OUTPUT LIKE OIL, SLUDGE THAT WAS A PART OF WHAT
WAS GOING ON HERE, AND ACTUALLY THAT WILL NOT OOZE FROM ONE
PIECE OF PROPERTY TO THE NEXT PIECE OF PROPERTY WITHOUT ANY
24
25
KIND OF A MAJOR CATASTROPHE.
41
-------
1
YEAH .
LIKE I SAID, THE RISKS THAT
MR. HARRIS-BISHOP:
2
3
ARE POSED BY THE SITE CURRENTLY ARE VERY LOW, ALMOST WITHIN
WHAT E.P.A.'S CONSIDERS SAFE ALREADY.
WHAT WE WANT TO MAKE
4
SURE WE DO IS BE PROTECTIVE IN THE LONG TERM AND IN THE
5
6
FUTURE, AND THAT'S WHY WE DON'T WANT TO WAIT UNTIL SOMEONE
STARTS TO DIG AND BECOMES EXPOSED TO ADDRESS THE PROBLEMS,
7
SO WE'RE TRYING TO BE PROTECTIVE AND PREVENTIVE IN THAT
8
9
RESPECT.
AS FAR AS, YOU KNOW, THE CITY OF SANTA FE SPRINGS
10
NOT BEING PROTECTIVE, I WOULDN'T SAY THAT AT ALL.
RIGHT
11 .NOW, LIKE I SAID, THIS IS, YOU KNOW, PROTECTIVE.
THERE'S
12
13
NOT A RISK POSED BY THE SITE CURRENTLY, SO WHAT WE'RE DOING
IS THIS IS E.P.A.'S JOB IS TO ENSURE PROTEC~NESS IN THE
14
LONG TERM, AND THAT'S WHAT WE'RE TRYING TO DO.
15
YES, MA'AM.
16
MS. AGUILAR:
MY NAME'S VIRGINIA AGUILAR, AND FROM THE
17
FIELD OF ST. PAUL'S TO THE AREA YOU REFER TO, IT'S ABOUT
FIVE FEET HIGH IF YOU VIEW IT, SO YOU SAY THAT AREA IS FIVE
18
19
FEET.
YOU'RE ALREADY -- THAT LEVEL WOULD BE CONTAMINATED,
20
AND THEN YOU'RE GOING TO BRING ALL THAT DIRT FROM ALL
21
AROUND IT AND PILE IT ON TOP AND THEN ANOTHER CAP.
HOW
22
23
HIGH IS THIS GOING TO BE?
MR. BARRIS-BISHOP:
I DON'T THINK WE'RE GOING TO BE .
24
MORE THAN ABOUT A FOOT AND HALF ABOVE WHAT IS CURRENTLY
THERE, AND I THINK THAT'S AN OVERESTIMATE BECAUSE WE DO
25
42
-------
1
2
JIA VB -- IN THAT AREA IT'S NOT VERY SMOOTH, AND 'I'BE AREA
OVER AT ST. PAUL'S IS A LOT HIGHER, BUT THAT'S ALSO ADDED
3
SOIL THAT THEY BROUGHT IN WHEN THEY CLOSED THE SITE.
YOU
4
KNOW, THE RESERVOIR WAS REMOVED FROM THIS HIGH SCHOOL
ATHLETIC FIELD, AND THEN THEY PILED DIRT ALL AROUND IT, AND
5
6
THEY BROUGHT IT UP TO ITS CURRENT SITE.
7
MS. AGUILAR:
YOU SAID IT'S FIVE FEET AND THEN
8
9
CONTAMINATION.
IT IS ABOUT FIVE FEET WHERE YOU' HE
STANDING.
10
MR. BARRIS-BISHOP:
IT'S ACTUALLY -- IT'S FIVE FEET,
11
12
AND SO IF YOU LOOK AT IT FROM THE SIDE, WE'RE ALSO TALKING
AT LEAST FIVE FEET OF SOIL WAS BROUGHT IN ON THE INSIDE.
13
14
THEY MOSTLY DUMPED -- LET ME GET THE AERIAL PHOTOGRAPH.
EITHER WE DETECTED LEAKS OR STANDING LIQUIDS AROUND HERE
(INDICATING) BACK WHEN ALL THIS WAS LEVEL, AND THEN THEY
15
16
BROUGHT IN A LOT OF SOIL TO BRING IT TO THE CURRENT
17
CONFIGURATION.
WHAT WE WANT TO DO IS WITH THE CAP COVER
18 ANY OF THAT AREA THAT'S ELEVATED FROM SANTA -- ST. PAUL'S
19
20
HIGH SCHOOL AND COVER IT WITH ASPHALT TO MAKE SURE THAT NO
ONE -- YOU KNOW, NONE OF THAT CONTAMINATION COULD SEEP
21
THROUGH.
IT HASN'T, YOU KNOW, IN 30 YEARS SINCE IT'S BEEN
22
23
CLOSED, BUT WE WANT TO MAKE SURE THAT IT DOESN'T HAPPEN
UNDER SOME, YOU KNOW, CIRCUMSTANCES.
24
25
MS. AGUILAR:
SO ACTUALLY IT'S GOING TO BE LIKE
CONTAMINATION AND THEN THE DIRT YOU PUT IN AND THEN THE
43
-------
1
2
CONTAMINATION ON TOP OF THAT THAT'S ON THE SIDES AROUND
THERE ?
3
4
MR. BARRIS-BISHOP:
YEAH .
LET ME --
MS. AGUILAR:
SOUNDS GREAT.
5
IT WILL LOOK LIKE -- WHAT WE HAVE
MR. BARRIS-BISHOP:
6
CURRENTLY HAVE IS THIS CONFIGURATION RIGHT HERE
(INDICATING), THIS CONTAMINATED SOIL AND THEN THE SOIL
7
8
THAT'S ON THE COVER.
IN SOME PLACES, IT'S ACTUALLY ABOUT
9
15 FEET DEEP BEFORE WE DETECTED ANY CONTAMINATION, BUT
10
GENERALLY IT IS FIVE FEET.
11
12
MS. AGUILAR:
AND THEN THE SOIL THAT'S CONTAMINATED,
YOU'RE GOING TO DIG IT OUT AND PUT IT ON TOP OF THAT.
AND
13
14
THAT DOESN'T CAUSE DEBRIS AROUND, THAT WOULD BE LIKE
CLEANING IT OUT?
15
MR. BARRIS-BISHOP:
IT WOULD BE -- IT'S A LOT LESS,
16 AND WE COULD CONTROL THAT WITH DUST SUPPRESSION EQUIPMENT.
17
WE'RE GOING TO HAVE TO MONITOR TO MAKE SURE WE'RE NOT
18
IMPACTING ANY AIR QUALITY.
THAT'S ONE OF THE LAWS TBAT WE
19
HAVE TO OBEY BY DOING THIS, SO WE'RE NOT GOING TO
CONTAMINATE OR CONTRIBUTE TO ANY FURTHER AIR CONTAMINATION
20
21
THAN ALREADY EXISTS.
ALSO, WHAT WE'RE GOING TO BE DOING IS
22 WE'RE NOT GOING TO BE PUTTING IT RIGHT UP ALONG THIS
23
BOUNDARY HERE.
WHAT WE WANT TO MAKE SURE IS THAT THE CAP
24
HAS UNIFORM DRAINAGE, SO IT'S GOING TO PROBABLY BE MOUNTED
IN THE CENTER HERE SO WE CAN RAVE SOME KIND UNIFORM
25
44
-------
1
2
DRAINAGE ALONG THE EDGES, SO I DON'T THINK YOU'RE GOING TO
BE SEEING A LARGE INCREASE IN THE GRADE ABOVE SANTA FE
3
SPRINGS HIGH SCHOOL.
4
5
MR. OPALSKI:
THERE'S ANOTHER ELEMENT ABOUT THE
CURRENT CONDITIONS, walCH IS IF THIS IS -- IF THIS IS THE
6
SURFACE OF THE SOIL COVER THAT'S ON THERE RIGHT NOW?
IT'S
7
NOT LIKE THIS (INDICATING).
8
NO, IT'S LIKE THIS (INDICATING).
ACTUALLY, IT'S SUPPOSED TO BE KIND OF
MS. AGUILAR:
9
10
MR. OPALSKI:
LIKE THAT, BUT IT'S ACTUALLY MORE LIKE GOT PITS IN IT.
11 IT'S A SURFACE THAT LOOKS MORE LIKE THAT (INDICATING), SO
12
WHEN WE'RE ADDING THE SOIL IN, PART OF THE POINT WILL BE TO
ADD IN THE EXCAVATED SOIL TO SMOOTH OUT THE SURFACE.
13
14
MR. CABRAL:
ISN'T THAT CONTAMINATED STUFF YOU'RE
15
16
PUTTING IN NOW?
MR. OPALSKI:
YEAH .
17
MR. BARRIS-BISHOP:
LOW LEVEL CONTAMINATION, PROBABLY
18
AT A LEVEL THAT WOULDN'T EXCEED SHORT-TERM EXPOSURE WITH NO
19
20
RESTRICTION.
WHAT WE WANT TO DO IS IF YOU'RE EXPOSED TO
THIS MATERIAL OVER A LONG PERIOD OF TIME, 70 YEARS LIVING
IN IT, YOU WOULD HAVE A POTENTIAL -- AN INCREASED RISK OF
21
22
CANCER.
23
24
MR. CABRAL:
WHY NOT JUST GET IT AND TAKE IT OUT OF
THE AREA COMPLETELY?
25
MR. HARRIS-BISBOP:
WE ACTUALLY LOOKED AT THAT, AND
45
-------
1
THAT WAS THE FOURTH ALTERNATIVE.
IT BECOMES A LOT MORE
2
3
EXPENSE, AND THEN WHAT WE'RE DOING IS WE'RE PUTTING IT INTO
A TRUCK, TRUCKING IT THROUGH YOUR NEIGHBORHOODS TO THE
4
5
FREEWAY TO THEN PUT IT INTO THE. DIRT SOMEWHERE ELSE WHEN IT
REALLY POSES VERY LITTLE RISK RIGHT NOW.
WHAT WE WANT TO
6
DO THOUGH -- THE REASON WE'RE EXCAVATING IT IS SO WE CAN
7
FREE UP THE PROPERTY THAT IS CONTAMINATED AND UNDEVELOPED
8
9
FOR SOME FURTHER DEVELOPMENT, BUT LIKE I WANT TO JUST POINT
OUT AND JUST REMIND EVERYONE THAT WHAT WE'RE TALKING ABOUT
10
HERE IS E.P.A. 'S PROPOSED ALTERNATIVE, AND WE CAN LOOK AT A
11 . LOT OF DIFFERENT ALTERNATIVES HERE.
SOME OF THE THINGS
12
13
THAT WE'VE SPOKEN TO, AND I SPOKE TO THE CITY COUNCIL LAST
THURSDAY NIGHT AND SPOKE TO SOME OF THE PROPERTY OWNERS
14
15
THURSDAY AND THEN AGAIN TODAY, IS SOME KIND OF HYBRID OF
THAT, SO, YOU KNOW, IF WE WANT GRASS OVER A PORTION OF IT
16
17
AND ASPHALT OVER A PORTION OF IT, WE CAN WORK WITH THAT.
WHAT WE WANT TO DO IS MAKE SURE WE'RE PROTECTIVE, AND WE
18
HAVE A LOT OF ALTERNATIVES.
ALL THESE ALTERNATIVES OFFER
19
20
VARYING DEGREES OF PROTECTION.
WE FEEL THAT THIS ONE
MEETS -- THE MOST PROTECTIVE GOALS AND STILL MEETS WITH
21
ACCEPTANCE AND, YOU KNOW, FUTURE USE AND ECONOMIC
22
23
DEVELOPMENT OF THE AREA.
IF OUR PROPOSAL IS NOT ACCEPTABLE TO THE
24
25
COMMUNITY, THAT'S WHAT WE'RE HERE TO DISCUSS TONIGHT AND
TAKE YOUR COMMENTS ON, AND, YOU KNOW -- BECAUSE SINCE WE
46
-------
1
2
HAVEN'T MADE OUR DECISION, WE'RE GOING TO GO BACK AND TAKE
YOUR COMMENTS AND THEN USE THOSE TO ADJUST OUR DECISION.
3
4
MS. HERRERA:
RUSTY?
MR. BARRIS-BISHOP:
YES, MA'AM.
5
6
MY NAME IS MARYSOL CAMERENE, AND THE
MS. CAMERENE :
7
CONTAINMENT OPTION 3C, E.P.A.'S PREFERRED ALTERNATIVE, IF
THAT IS CHOSEN, HOW LONG WILL IT TAKE THAT WHOLE PROCESS TO
8 . TAKE CARE OF THAT PREFERRED ALTERNATIVE?
SECONDLY, WHO
9
WILL BE VOTING FOR IT, THE CITY OF SANTA FE SPRINGS?
WILL DETERMINE THE ALTERNATIVE?
WHO
10
11
MR. BARRIS-BISHOP:
THIS IS AN E.P.A. PROJECT, 50
12
13
E.P.A. WILL BE MAKING THIS DECISION ALONG WITH THE
COMMUNITY, AND THAT'S WHY WE'RE HERE TO MAKE THIS DECISION
14
OR START MAKING THIS DECISION TONIGHT.
WE ENVISION -- WHAT
15
WE'LL DO IS ONCE WE MAKE OUR DECISION AND WRITE UP THAT
16
RECORD OF DECISION, WE HAVE TO LET EVERYONE KNOW THAT WE
17
18
MADE THE DECISION AND THEN GIVE THE PEOPLE THAT WE
DETERMINE MAY BE POTENTIALLY RESPONSIBLE FOR THE
19
CONTAMINATION TO COME FORWARD, AND WE HAVE TO GIVE THEM THE
20
OPPORTUNITY TO DO THIS WORK FOR US.
SO FAR E.P.A. HAS DONE
21
IT.
WE PROPOSED TO THE POTENTIALLY RESPONSIBLE PARTY BACK
22
23
IN '88 TO HAVE THEM DO THE WORK, AND WE DIDN'T HAVE ANYONE
COME FORWARD AND AGREE TO DO THIS WORK, SO E.P.A., WE WENT
24
25
FORWARD AND DID IT.
WE WILL AGAIN GO FORWARD AND ASK THEM TO
47
-------
1
2
IMPLEMENT THIS DESIGN AND THE REMEDIAL ACTION, AND IF WE
DON'T GET ANY TAKERS, E.P.A. WILL AGAIN DO IT, AND WE HOPE
3
TO START ~- WE HAVE, YOU KNOW, STATUTORY LIMITS.
WE HAVE
4
5
TO GIVE PEOPLE AT LEAST, I THINK, 60 DAYS INITIALLY AND
THEN ANOTHER 60 DAYS AFTER THAT, SO IT WOULD BE AT LEAST
6
7
FOUR MONTHS AFTER WE STARTED BEFORE WE COULD DO ANYTHING,
BUT I'D ENVISION US GETTING STARTED BY EARLY -- BY THE
8
9
PROBABLY MARCH OR APRIL TIME FRAME
MIDDLE OF NEXT YEAR.
WOULD PROBABLY BE THE EARLIEST WE CAN GET STARTED.
10
11
YES, FATHER.
FATHER GALLAGHER:
A QUESTION ABOUT THE ENCAPSULATION
12
13
WHEN WE HAD OUR DISCUSSION, YOU LED ME TO
OF THAT AREA.
BELIEVE THAT IF THE AREA REMAINED GRASSY, THEN NOTHING
14
COULD REALLY OCCUR ON THAT -- ON THAT PROPERTY IN TERMS OF
15
16
ANY KIND OF BUSINESS VENTURE.
MR. HARRIS-BISHOP:
YEAH, BECAUSE WE --
17
FATHER GALLAGHER:
IN THE FUTURE.
BUT IF IT'S
18
19
ASPBALTED, THEN IT COULD BE USED FOR SOME KIND OF A LIMITED
BUSINESS VENTURE.
20
21
MR. HARRIS-BISHOP:
YEAH .
FATHER GALLAGHER:
FOR EXAMPLE.
22
23
THEN I WAS WONDERING ABOUT THE SAFETY.
FOR
EXAMPLE, IF YOU HAVE A SCHOOL YARD OR A PLAYING FIELD WHERE
THERE ARE CONSISTENTLY STUDENTS PLAYING AND A HIGHER
24
25
ELEVATED ASPHALT COVERED AREA PROPERTY THAT COULD BECOME
48
-------
-
1
2
ANY NUMBER OF DIFFERENT THINGS WHERE WE WOULD CONTINUALLY
HAVE TO BE WORRIED OF LOOKING UP AND WONDERING WHAT IS --
3
4
WHAT COULD POSSIBLY BE COMING FROM THAT HIGHER ELEVATION AT
5
ALL, I THINK THERE WOULD BE SOME LIABILITY ON THE PART OF
THE GOVERNMENT FOR AC -- OR FOR PUTTING IN SOMETHING WHERE
6
WE WOULD BE CONCERNED ABOUT -- I WOULD ALWAYS BE CONCERNED
7
ABOUT WELL, WHAT'S HAPPENING OVER THERE WHICH WE HAVE NO
8.CONTROL OVER?
I WOULD HAVE CONTROL OVER WHO WAS ON OUR
9
PROPERTY, BUT I WOULDN'T HAVE CONTROL OVER WHO IS STANDING
ON THE -- ON THE PIECE OF PROPERTY ABOVE US LOOKING DOWN AT
10
11 . THE STUDENTS WHO ARE UNPROTECTED.
SO, YOU KNOW, IT'S
12
SIMPLY A QUESTION OR A COMMENT, BUT I 00 THINK THAT THERE'D
13
SOME GOVERNMENTAL LIABILITY IF SOMETHING WERE TO OCCUR.
14
OKAY.
LET ME SAY THAT IS A GOOD
MR. HARRIS-BISHOP:
15
COMMENT THAT WE PROBABLY SHOULD, YOU KNOW, ADDRESS OR AT
LEAST HAVE RECORDED AGAIN DURING THE FORMAL COMMENT
16
17 'PERIOD.
I GUESS WE MAY BE MOVING INTO THAT PERIOD ANYWAY.
18
19
LET ME -- IF YOU'D LIKE TO BRING THAT UP AGAIN -- UNLESS
WE'RE FINISHED WITH QUESTIONS.
20
MS. HERRERA:
ACTUALLY, I THINK WE WILL PROBABLY WANT
21
TO COME BACK TO QUESTIONS BECAUSE WE WANT TO MAKE SURE WE
22
23
TAKE ALL THE COMMENTS.
SO WHY DON'T WE OPEN THE COMMENT
PERIOD RIGHT NOW, AND IF WE HAVE TIME AFTER THE COMMENT
PERIOD, THEN WE CAN COME BACK TO THE QUESTIONS.
24
25
MR. HARRIS-BISHOP:
AND I'LL BE -- WE'LL BE HERE AS
49
-------
1
LATE AS YOU ALL NEED US TO BE TO ANSWER QUESTIONS, SO WE'RE
2 NOW OFFICIALLY IN THE FORMAL COMMENT PERIOD.
3
4
AND WE WILL NOT RESPOND TO YOUR COMMENTS
MS. HERRERA:
TONIGHT.
5
6
MR. SHARP :
ALBERT SHARP, AND THIS IS REALLY A
QUESTION.
WHY WASN'T BIO REMEDIATION PUT IN THERE AS ONE
7
8
IT'S A METHOD WE'VE USED SUCCESSFULLY
OF THE ALTERNATIVES?
OF CLEANING UP SOME OF THE OIL PROPERTIES IN THE CITY THE
CITY WANTED TO REDEVELOP DURING THE REDEVELOPMENT AGENCY.
9
10
I DON'T SEE THAT LISTED AS ANY TYPE OF ALTERNATIVE, YET
lIlT'S PROBABLY THE MOST SUCCESSFUL METHOD CURRENTLY USED
12
13
THROUGHOUT THE WORLD.
MR. HARRIS-BISHOP:
WE DID ACTUALLY LOOK AT BIO
14
REMEDIATION THE PROBLEM IS WE HAVE ARSENIC IN THE SOIL AT
15
16
ELEVATED LEVELS THAT IS NOT GOING -- BIO REMEDIATION ISN'T
GOING TO DO ANYTHING ABOUT THAT.
17
MR. SHARP:
BUT IF WE CLEANED UP EVERYTHING EXCEPT THE
18
19
ARSENIC, THEN IT WOULD BE A SIMPLE THING TO ISOLATE AND
REMOVE.
20
MR. HARRIS-BISHOP:
ACTUALLY, THAT'S THE WHOLE POINT
21
IS THAT WE HAVE ARSENIC THROUGHOUT THIS SITE, AND ARSENIC
IS WHAT DRIVES THIS WHOLE RISK, SO THAT WE COULDN'T -- I
22
23 MEAN WE HAVE ARSENIC IN ALMOST EVERY SOIL BORING THAT'S AT
24
ELEVATED LEVELS FOR A HEALTH CONCERN SO THAT WE COULDN'T
25
ISOLATE ARSENIC.
BASICALLY WE'D BE EXCAVATING THAT
50
-------
1
ENTIRE -- THE ENTIRE SITE SINCE BIO REMEDIATION IS GOING ON
2 ALREADY TO SOME EXTENT.
THAT'S THE REASON WHY. METHANE IS
3
IT'S TAKING CARE OF THE ORGANIC
BEING GENERATED.
4
CONSTITUENTS, WHICH ISN'T THE MAIN FACTOR IN THE RISK.
THE
5
MAIN FACTOR IN THE RISK BAS BEEN THE METALS AS FAR AS --
6
THAT'S WHAT I'VE DETERMINED SO FAR.
DID YOU HAVE A QUESTION OR A COMMENT, MISS?
7
8
MARYSOL CAMERENE.
IN WHAT PHASE DID
MS. CAMERENE :
9
10
YOU CHOOSE THE 3C ALTERNATIVE, BECAUSE IT IS LESS
EXPENSIVE?
11
IT'S ACTUALLY ABOUT -- WE
MR. HARRIS-BISHOP:
NO.
12 LOOK AT -- IN THE FACT SHEET WE TALK ABOUT SELECTING A
13
REMEDY, AND WE LOOK AT NINE CRITERIA.
COST IS ONLY ONE OF
14
15
COMMUNITY ACCEPTANCE IS ALSO ONE OF THEM.
THE FIRST
THEM.
ONE WE LOOK AT IS TO BE PROTECTIVE, AND THIS ALTERNATIVE IS
16
17
PROTECTIVE.
THEN WE LOOK AT -- IF YOU WANT TO GO THROUGH
THEM WITH ME IF EVERYONE BAS A COPY.
THEN THE NEXT ONE IS
18
COMPLIANCE WITH A.R.A.R.S., WHICH ARE THE REGULATIONS WE
HAVE TO COMPLY WITH WHILE WE'RE DOING OUR WORK; LONG-TERM
19
20
21
EFFECTIVENESS, WHICH I SAID IS WHY WE'RE DOING THIS RATHER
THAN JUST WAITING UNTIL SOMEONE BECOMES EXPOSED.
THIS IS
22
23
PROTECTING THE LONG TERM.
REDUCTION OF TOXICITY, MOBILITY OR VOLUME IS.
ANOTHER ALTERNATIVE WE NORMALLY LOOX AT waICH INVOLVES A
24
25
TREATMENT OPTION.
WE DID EVALUATE DIFFERENT TREATMENT
51
-------
1
2
ALTERNATIVES, BUT NONE OF THEM WERE EFFECTIVE FOR REDUCING
THE TOTAL RISK THAT WE HAVE AT THIS SITE.
WE ARE GOING TO
3
4
BE REDUCING SOME OF THAT VOLUME THROUGH THE GAS TREATMENT
SYSTEM IF THAT'S NECESSARY.
WE'RE ALSO REDUCING MOBILITY
5
6
BECAUSE WE'RE PREVENTING WATER FROM FLUSHING ANY
CONTAMINANTS INTO THE GROUNDWATER.
THEN COST, SHORT-TERM
7
8
EFFECTIVENESS, IMPLEMENTABILITY, WHICH. MEANS ARE WE TALKING
ABOUT TRYING TO BUILD SOMETHING THAT'S REALLY DIFFICULT.
9
10
ASPHALT PAVING IS A FAIRLY COMMON PRACTICE, SO WE WOULDN'T
HAVE THAT IMPLEMENTABLE PROBLEM, AND THEN THE LAST TWO ARE
11
12
STATE AND COMMUNITY ACCEPTANCE, SO WE TAKE A LOOK AT ALL
THESE CRITERIA IN MAKING OUR DECISION, AND THERE'S ACTUALLY
13
14
A TABLE IN THE FEASIBILITY STUDY THAT SAYS BOW WE FEEL THAT
EACH OF THESE SEVEN MEETS THESE CRITERIA, AND SO IF YOU
FEEL THAT ONE COMPONENT OF OUR -- AN ALTERNATIVE WOULD WORK
15
16
BETTER, THAT'S WHAT WE'D LIKE TO BEAR FROM .YOU.
17
I ALSO WANT TO STRESS IF YOU DON'T WANT TO MAKE
18
YOUR COMMENTS EARLIER TODAY, THE COMMENT PERIOD GOES UNTIL
SEPTEMBER 12, AND WE ACCEPT WRITTEN COMMENTS, AND MY
19
20
ADDRESS IS ON THE BACK OF THE FACT SHEET, SO YOU CAN JUST
21
WRITE A LETTER TO ME.
YOU CAN HANDWRITE IT; IT DOESN'T
22
23
MATTER.
AND SEND IT TO ME, AND THAT WILL BE INCORPORATED
INTO OUR RECORD OF DECISION, AND THEN I'LL BE ADDRESSING
THOSE COMMENTS AS WELL AS ANY OF THE COMMENTS THAT WE'RE
24
25
BAVING HERE TONIGHT.
52
-------
1
2
MR. CABRAL:
ON THAT GAS YOU WERE PICKING UP, HOW ARE
THEY GOING TO EXPOSE IT, GET RID OF IT?
3
MR. BARRIS-BISHOP:
WE'LL BE FLARING IT SINCE IT'S
4
5
METHANE IS THE PREDOMINANT --
MR. CABRAL:
DOESN'T THAT MAKE A GREAT NOISE?
6
MR. BARRIS-BISHOP:
BURNING METHANE?
7
8
MR. CABRAL:
YES.
MR. BARRIS-BISHOP:
NO.
IT'S GOING TO BE LIKE A SMALL
9
IT SHOULDN'T HAVE ANY EFFECT -- IT SHOULDN'T BE
BURNER.
10
VERY NOISY.
11
THE ONES UP AT ROSE HILLS, THAT MAKES A
MR. CABRAL:
12
13
LOT OF NOISE.
MR. HARRIS-BISHOP:
THE VOLUME THAT WE'RE TALKING
14
15
IN FACT, WE MAY NOT EVEN
ABOUT IS A LOT SMALLER METHANE.
16
HAVE ENOUGH METHANE TO IGNITE, SO WE'LL HAVE -- THOSE ARE
GOING TO BE THINGS THAT WE HAVE TO EVALUATE.
17
IN OTHER WORDS, YOU'RE GOING TO SAVE IT
MR. CABRAL:
18
AND LET IT GO INTO THE AIR.
19
MR. HARRIS-BISHOP:
I DON'T KNOW IF WE'RE ALLOWED TO
20
DO THAT BASED ON THE AIR QUALITY IN THIS AREA.
IF IT ISN'T
21
CONSIDERED TO BE AN ADDITIONAL, YOU KNOW, CONTAMINANT --
22
I'M SURE IT WOULD BE THOUGH.
WE WOULD HAVE TO DO
23
SOMETHING, EITHER CONTAIN IT AND HAUL IT OFF-SITE OR ELSE
24
25
IGNITE IT WHENEVER IT BECOMES INTO THAT KIND OF
CONCENTRATION.
.53
-------
1
2
SO THAT WOULD BE MAKING A GREAT NOISE.
HR. CABRAL:
MR. HARRIS-BISHOP:
I DON'T -- IT'S LIKE A GAS BURNER
3
WE'RE NOT TALKING ABOUT A LARGE VOLUME OF
ON YOUR OVEN.
4
5
GAS HERE.
MR. CABRAL:
I'VB WORKED ON THE ONE IN ROSE HILLS, AND
6
THAT MAKES A LOT OF NOISE.
7
THAT'S A LEGITIMATE COMMENT THAT
MR. HARRIS-BISHOP:
8
WE'LL LOOK INTO.
9
10
MS. HERRERA:
RUSTY, WE'RE RUNNING OUT OF TIME, SO WE
WANT TO MAKE SURE EVERYBODY BAS A CHANCE TO EXPRESS THEIR
11
12
COMMENTS, AND IF WE HAVE EXTRA TIME, THEN WE'RE GOING TO GO
BACK TO THE QUESTION AND ANSWER SESSION.
13
MR. HARRIS-BISHOP:
I THINK THOSE ARE GOOD COMMENTS.
14
MS. HERRERA:
RIGHT NOW WE'D LIKE TO ENCOURAGE ANYONE
15
THAT BAS ANY COMMENTS TO STATE THEM FOR THE RECORD.
16
MS. AGUILAR:
WHEN IS THE FINAL DECISION?
17
MR. HARRIS-BISHOP:
WE'RE HOPING TO MAKE THAT BY THE
18
19
END OF SEPTEMBER.
ONCE THIS PUBLIC COMMENT PERIOD IS OVER,
WE'LL TAKE ALL THE COMMENTS THAT WE HAVE, AND WE'LL ADDRESS
THEM ALL, AND THEN WE WRITE OUR RECORD OF DECISION, walCH
20
21
INCLUDES, YOU KNOW, THE SITE BACKGROUND, THE RESPONSIVENESS
SUMMARY TO ALL THE COMMENTS, AND IF IT'S SIGNIFICANTLY
22
23
DIFFERENT FROM OUR PROPOSED PLAN, WE'LL ~ITE DOWN WHAT THE
SIGNIFICANT DIFFERENCES ARE IN THAT.
24
25
MS. AGUILAR:
SO IF CITIZENS DECIDE THAT THEY DON'T
54
-------
1
2
AGREE WITH YOU, HOW DO THEY -- WOULD IT BE LIKE EACH
INDIVIDUAL PERSON OR ONE BIG GROUP OR BOW DO YOU DO THAT?
3
YOU CAN --
MS. HERRERA:
4
MR. HARRIS-BISHOP:
ACTUALLY, YOU CAN SUBMIT LETTERS
5
6
TO ME INDIVIDUALLY OR, YOU KNOW, IF YOU HAVE A NEIGHBORHOOD
COMMUNITY GROUP OR SOMETHING LIKE THAT, YOU COULD SUBMIT A
7
LETTER UNDER THEM WITH THE UNDERSIGNED OR SOMETHING.
IT'S
8
NOT -- IT'S MORE WHAT THE -- THE COMMENT IS.
IF IT'S
9
10
SOMETHING THAT, YOU KNOW, YOU'RE JUST DRAMATICALLY OPPOSED
TO US DOING, THEN WE HAVE TO LOOK AT DOING SOMETHING
11 . DIFFERENT.
IT'S A TRADEOFF, AND THAT'S WHY I PRESENTED ALL
12
13
SEVEN OF THESE BECAUSE ALL OF THESE HAVE, YOU KNOW,
ACCEPTABILITY AND UNACCEPTABLE ELEMENTS OF IT, SO E.P.A., I
14
THINK -- EXCEPT FOR THE NO ACTION ALTERNATIVE, ALL OF THESE
OFFER SOME LEVEL OF PROTECTION THAT -- WITH THE, YOU KNOW,
15
16
17
PROPER CONTROL.
SOME OF THEM MAY TAKE MORE WORK AS FAR AS
THE CITY CONTROLLING IT OR THE STATE COMING IN AND, YOU
KNOW, MONITORING IT OR E.P.A. DOING MORE WORK TO BE
18
19
PROTECTIVE, BUT ALL OF THESE OFFER A LEVEL OF PROTECTION,
AND IT'S LISTED IN THE FACT SHEET SO THAT WE CAN -- OUR
20
21
GOAL TO BE PROTECTIVE, BUT WE ALSO WANT TO MEET COMMUNITY
22
23
NEEDS, SO IF THE COMMUNITY IS OPPOSED TO THIS, WE'LL TAKE
THOSE -- THAT COMMENT BACK, AND WE'LL WORK WITH IT AT OUR
24
OFFICE.
25
AND THEN -- I MEAN THIS ISN'T THE FINAL PART OF,
55
-------
1
2
YOU KNOW, THE COMMUNITY INVOLVEMENT.
ONCE WE WRITE OUR
RECORD OF DECISION, WE'LL LET EVERYONE KNOW WHAT THAT
3
WHEN WE IMPLEMENT DESIGN, WHEN WE START DOING
DECISION IS.
4
THE DESIGN WORK, walCH WILL BE IN PHASES, WE'LL BE LETTING
PEOPLE KNOW HOW THE DESIGN IS GOING, WHAT WE PROPOSE TO DO
5
6
AND HOW THE DESIGN IS COMING OUT, AND PEOPLE WOULD HAVE THE
7
8
OPPORTUNITY TO COMMENT AGAIN AT THAT TIME, SO IT'S -- THIS
IS ONLY THE START OF, YOU KNOW, THE PROCESS.
9
10
MS. AGUILAR:
I HAVE A SMALL QUESTION BETWEEN 3C AND
3D.
NOW, IT SAYS -- ON BOTH OF THEM IT SAYS LIMITED
11
12
EXCAVATION.
ON THE ONE THAT YOU PROPOSE, IS THAT THE ONE
WHERE YOU TAKE THE STUFF AROUND AND PILE IT IN THE MIDDLE?
13
14
MR. HARRIS-BISHOP:
YEAH .
MS. AGUILAR:
AND THEN THE THIRD ONE IS THE ONE WHERE
15
16
YOU JUST CAP EVERYTHING IN GENERAL?
MR. HARRIS-BISHOP:
THE SECOND ONE ACTUALLY, THE ONE
17
THAT SAYS ASPHALT CAP-NO EXCAVATION?
WE'D BE CAPPING ANY
18
AREA THAT HAD -- THAT ISN'T ALREADY PAVED ON THAT SITE
19
BASICALLY.
20
MS. AGUILAR:
SO IT WOULD BE THE WHOLE ENTIRE PLACE,
21
INCLUDING SOME OF THE PINK SITES YOU HAVE THERE.
WOULD BE 3B, NO EXCAVATION.
SO IT
22
23
MR. HARRIS-BISHOP:
YEAH .
AND THEN 3A IS ALSO A NO
24
25
EXCAVATION ALTERNATIVE WHERE WE'D HAVE JUST SOIL AND
VEGETATION EVERYWHERE RATHER THAN ASPHALT.
56
-------
1
2
IN OTHER WORDS, PLANTS AND STUFF.
MS. AGUILAR:
MR. HARRIS-BISHOP:
PLANTS, GRASS.
PROBABLY NICER
3
THAN THE STUFF RIGHT NOW THAT'S THERE.
WE'VE GOT ALL THOSE
4
WE WOULD VEGETATE SO IT WOULD BE A LOW MAINTENANCE
WEEDS.
5
6
AREA .
MS. AGUILAR:
BETWEEN C AND D, I DIDN'T QUITE GET
7
ONE BAS ASPHALT, AND THE OTHER ONE JUST HAS --
THAT.
8
9
WHAT'S --
MR. HARRIS-BISHOP:
ACTUALLY, THE R.C.R.A. CAP waICH
10
11
IS DESCRIBED IN THE REGULATIONS IS MORE LEVELS, MORE LAYERS
BETWEEN THE ASPHALT CAP AND THE -- AND THE BOTTOM.
THERE'S
12
13
ACTUALLY AN OPTION UNDER A R.C.R.A. CAP TO MAKE SOIL ON TOP
OF EVERYTHING ELSE, SO WE WOULD HAVE .THESE ADDITIONAL
BARRIERS, BASICALLY MORE PLASTIC LAYERS AND MORE ROCK
14
15
LAYERS, AND THEN WE'D HAVE EITHER ASPHALT OR SOIL ON TOP OF
16
THAT, BUT LIKE I SAID, THAT'S AT LEAST FIVE FEET THICK, THE
R. C . R. A. CAP, SO THAT JUST ADDS A HUGE, AN EVEN LARGER
17
18
GRADE ABOVE THE SCHOOL AND ABOVE THE REST OF THE PROPERTY,
19
BUT WE DID EVALUATE THAT, AND THAT'S INCLUDED IN THE FACT
20
SHEET, THE COSTS.
21
IF I CAN JUST TAKE A BREAK.
I NEED TO RUN AND
22
23
GET A GLASS OF WATER OR GET A DRINK.
MR. OPALSKI:
ANY OTHER COMMENTS?
24
25
MS. HERRERA:
ANY OTHER COMMENTS?
FATHER GALLAGHER:
ARE YOU ON THE COMMENT SECTION?
57
-------
1
2
YEAH, COMMENT SECTION.
MS. HERRERA:
FATHER GALLAGHER:
I UNDERSTOOD THE COMMENT SECTION
3 WAS GOING TO HAVE NO ANSWERS TO IT, SO . . .
4
5
THAT'S RIGHT.
SO THIS IS A GOOD TIME
MS. HERRERA:
FOR THE COMMENT SECTION.
I'M HAVING A HARD TIME KEEPING
6
RUSTY QUIET.
FATHER GALLAGHER:
WHICH SECTION IS WHICH SECTION?
7
8
THIS IS THE COMMENT PERIOD SO GO AHEAD
MS. HERRERA:
9
10
AND STATE YOUR COMMENTS IF YOU HAVE ANY.
MR. SHARP:
MY NAME'S ALBERT SHARP.
ONCE AGAIN, I
11 THINK THERE ARE MORE OF THE PEOPLE HERE -- I THINK WE HAVE
12
MORE QUESTIONS WE WANT TO ASK, AND I DON'T KNOW THAT THE
COMMENTS REALLY MATTER TO US AT THIS POINT IN TIME.
13
14
MR. BARRIS-BISHOP:
OKAY.
15
MR. SHARP :
WE CAME HERE TO ASK SPECIFIC QUESTIONS,
16 AND I THINK WE OUGHT TO SACK THE COMMENT PERIOD AND ASK THE
17
QUESTIONS SO THE NEIGHBORS COULD HAVE THEM ANSWERED.
I HAVE A QUESTION -- ALBERT SHARP IS ASKING THE
18
19
20
QUESTION -- DO YOU HAVE THE MONBY?
HALF MILLION TO SPEND ON THIS 3C?
DO YOU HAVE FIVE AND A
21
MR. BARRIS-BISHOP:
WE DON'T HAVE IT RIGHT NOW.
WHAT
22
23
WE HAVE TO DO IS. GET IT FROM E.P.A. HEADQUARTERS AND MAKE
SURE THAT IT'S BUDGETED BY CONGRESS.
24
25
MR. SHARP :
AND WHAT IS THE LIKELIHOOD OF THAT
HAPPENING IN MY LIFETIME?
58
-------
1
2
MR. HARRIS-BISHOP:
IT'S VERY GOOD.
WE ARE NOT
TALKING ABOUT -- E~P.A. MANAGEMENT BAS APPROVED OF THIS 50
3
4
FAR, SO I MEAN IT'S NOT SOMETHING THAT IS THAT
CONTROVERSIAL AS FAR AS E.P.A. IS CONCERNED THAT WE'RE
5
6
GOING TO BE SPENDING A LOT OF MONEY THAT MAY NOT BE
EFFECTIVE.
I DON'T THINK -- I DON'T ENVISION THAT BEING A
7
8
WE CLEAN UP -- WE'RE DOING THIS KIND OF WORK ALL
PROBLEM.
OVER THE STATE, ALL OVER THE COUNTRY.
9
YES, MA'AM.
10
MS. CABRAL:
IRENE CABRAL.
SO WHO IS GOING TO MAKE
11
THE FINAL DECISION WHAT IS GOING TO BE DONE, E.P.A.,
12
COUNCIL?
13
14
MR. BARRIS-BISHOP:
E. P . A. DOES BECAUSE WE'RE THE LEAD
AGENCY, AND THIS IS OUR JOB TO MAKE THESE DECISIONS, BUT
15
WHY WE'RE HERE IS TO BRING THE PUBLIC INTO THE
16
DECISION-MAKING PROCESS, AND THAT'S --
17
MS. CABRAL:
BUT THEY'RE NOT GOING TO HAVE THE FINAL
18
DECISION, THE PUBLIC.
19
MR. BARRIS-BISHOP:
THAT'S WHY WE'RE HERE TONIGHT.
20
MS. CABRAL:
YOU'RE JUST GOING TO TAKE COMMENTS.
21
MR. HARRIS-BISHOP:
AND THAT AFFECTS OUR DECISION.
IF
22
EVERYONE SAYS, YOU KNOW, "NO, WE DON'T WANT YOU TO DO
23
24
THIS," THAT'S SOMETHING THAT WE HAVE TO TAKE INTO ACCOUNT,
AND WE CAN'T JUST GO AGAINST THE COMMUNITY IN IMPLEMENTING
25
THIS AND MAKING OUR DECISION AND JUST GOING ON.
THAT'S WHY
59
-------
1
2
WE'RE HERE BECAUSE WE WANT TO MAKE SURE '1'BE COMMUNITY
ACCEPTS WHAT WE'RE DOING AND THAT THEY HAVE PARTICIPATION
3
4
IN THE PROCESS.
YES, SIR, MR. CABRAL.
5
6
I DON'T LIVE IN SANTA FE SPRINGS.
I LIVE
MR. CABRAL:
IN SOUTH WHITTIER.
7
THAT'S FINE.
MR. HARRIS-BISHOP:
8
9
BUT I'M QUITE CONCERNED ABOUT WHAT'S
MR. CABRAL:
10
HAPPENING HERE, AND IS MY VOTE GOING TO BE COUNTED OR IS IT
GOING TO BE JUST THE PEOPLE THAT LIVE AROUND IT?
11
12
MR. W\RRIS-BISHOP:
WELL, I THINK THAT ACTUALLY THE
BOUNDARY OF SANTA FE SPRINGS STOPS AROUND THE SITE.
WHAT
13
WE'RE CONCERNED WITH IS PEOPLE WHO ARE AFFECTED BY THE
14
SITE.
15
16
MR. CABRAL:
YEAH, BUT IT'S ALL CONSTRUCTION AROUND
IT, AND THERE'S A SCHOOL, AND FATHER GALLAGHER AND BROTHER
DENNIS ACTUALLY LIVE IN THERE AND MAYBE A DOZEN OTHER
17
18
PEOPLE.
BUT ON THE OTHER SIDE ACROSS THE STREET, ARE THEY
19
GOING TO HAVE A CHANCE TO VOTE, AND IF THEY KNOW NOTHING
ABOUT IT, BOW ARE THEY GOING TO MAKE A DECISION?
20
21
MR. OPALSKI:
LET ME CLARIFY THAT IT'S NOT REALLY A
22
23
VOTE.
MR. CABRAL:
THEN WHY ARE WE HERE THEN?
BECAUSE THE COMMENTS DO MAKE A
24
MR. OPALSKI:
25
DIFFERENCE.
60
-------
1
2
I MEAN IF YOU'RE GOING TO DO IT
MR. CABRAL:
REGARDLESS WHAT YOU'RE GOING TO DO, WE'RE WASTING OUR TIME
3
BEING HERE.
4
WE'RE GOING TO CONSIDER ALL THE COMMENTS
MR. OPALSKI:
5
NO MATTER WHERE THEY COME FROM.
6
IN OTHER WORDS, WHAT YOU'RE SAYING IS
MR. CABRAL:
7
WHATEVER WE SAY IS NOT GOING TO MAKE ANY DIFFERENCE.
8
9
NO, THAT'S NOT WHAT I'M SAYING.
I'M
MR. OPALSKI:
SAYING WE'RE GOING TO CONSIDER ALL THE COMMENTS.
10
11
HOW
MR. CABRAL:
BUT THAT'S ALSO WHAT I'M SAYING.
MANY PEOPLE IS IT GOING TO TAKE TO MAKE A DECISION IF WE
12
DON'T WANT IT?
13
14
MR. OPALSKI:
WELL, THIS IS ANOTHER THING I WANT TO
CLARIFY.
IF YOU ARE NOT LIKING THE PREFERRED ALTERNATIVE,
15
16
WE NEED TO HEAR MORE THAN THAT YOU JUST DON'T LIKE IT.
WE
NEED TO HEAR WHY BECAUSE THERE ARE OTHER CRITERIA WE HAVE
17
18
TO LOOK AT ASIDE FROM COMMUNITY ACCEPTANCE, FOR INSTANCE,
PROTECTIVENESS.
WE HAVE A BASELINE RESPONSIBILITY TO MAKE
19
20
SURE THIS REMEDY IS PROTECTIVE ESSENTIALLY NO MATTER WHAT
OTHER PEOPLE ARE FEELING ABOUT IT, SO IF IN OUR
PROFESSIONAL JUDGMENT IT'S SOMETHING THAT OTHER PEOPLE ARE
21
22
23
WANTING THAT'S NOT PROTECTIVE, WE ARB OTHERWISE BOUND NOT
TO ALLOW THAT TO GO FORWARD, OKAY?
SO IT'S -- COMMUNITY
24
ACCEPTANCE IS ONE OF THE CRITERIA WE LOOK AT, AND,
THEREFORE, WE WANT TO LOOK AT ALL 1'BE COMMENTS THAT COME
25
61
-------
1-
1
2
IT DOESN'T REALLY MA'l"l'ER WHERE YOU LIVE.
WE CONSIDER
IN.
ALL THE COMMENTS.
3
YES, MA'AM.
4
5
VIRGINIA AGUILAR.
MY COMMENT IS THAT
MS. AGUILAR:
6
THE -- WE HAVE CHILDREN PLAYING OUT THERE EVERY DAY HARD,
BREATHING HARD, BREATHING THAT GAS YOU'RE GOING TO PUT UP
7
IN THE AIR HARD RIGHT NEXT TO IT.
I'M TALKING A FEW FEET
8
FROM THERE.
WHY CAN'T THEY JUST CLEAN IT?
CLEAN IT.
9
10
MR. HARRIS-BISHOP:
THIS IS JUST COMMENT.
WELL, I
WOULD LIKE TO ADDRESS IT JUST TO SAY I EXPLAINED IT
11
EARLIER.
BY DIGGING THAT UP, WE'RE CAUSING A MUCH HIGHER
12
SHORT-TERM RISK THAT WE'RE NOT GOING TO BE ELIMINATING, YOU
KNOW, ULTIMATELY THAT MUCH OF A RISK FOR THE AMOUNT OF WORK
13
14
AND THE AMOUNT OF MONEY THAT THAT COSTS.
I MEAN IT'S
15
16
ENORMOUSLY EXPENSIVE, 20 TIMES --
MR. CABRAL:
HOW MUCH IS --
17
18
MR. HARRIS-BISHOP:
AND WHAT WE HAVE RIGHT HERE IS WE
DON'T HAVE A CURRENT RISK.
WE DON'T HAVE A RISK POSED TO
19
THE PEOPLE, THE STUDENTS, AND MARILYN UNDERWOOD IS A
TOXICOLOGIST WHO HAS REVIEWED THIS FOR THE STATE AND HAS
20
21
THE SAME OPINION, THAT THE CURRENT RISK TO THIS SITE --
POSED BY THE SITE ARE VERY LOW, AND WHAT WE WANT TO DO IS
22
23
MAKE SURE THAT OUR REMEDY AND WHATEVER DECISION THAT WE
24
25
COME TO IS PROTECTIVE, AND THAT'S OUR FIRST GOAL.
RIGHT
NOW THERE'S NOT A CURRENT RISK PROPOSED BY THE SITE.
62
-------
15
16
1
2
MR. MORENO:
I HAVE A COMMENT AND A QUESTION.
MR. HARRIS-BISHOP:
YES, SIR.
3
4
THAT'S WHAT OFFICIALS AND COMPANY OWNERS
MR. MORENO:
AND FACTORY OWNERS SAID IN TEXAS, THAT THERE WAS NO RISK,
5
SO THAT'S MY COMMENT.
AND I HAVE A QUESTION.
DURING THE
6
PERIOD OF EXCAVATION, THE KIDS, THEY'RE GOING TO BE EXPOSED
TO THE GASES, ESPECIALLY MORE THAN THE TIME THAT IT'S
7
8
COVERED UP.
WOULD THEY BE CLOSING THE SCHOOL DURING THAT
9
PERIOD OF TIME OR -- I KNOW IT MAY NOT BE A QUESTION FOR
10
YOU, BUT THAT WOULD BE MY CONCERN.
11
MR. HARRIS-BISHOP:
WHAT WE'RE DOING -- THAT'S A
12
13
CONCERN OF OURS TOO, TO MAKE SURE THAT WE'RE NOT IMPACTING
ANYBODY'S HEALTH AND ANYBODY'S BUSINESS, SO WHAT WE'RE
14
GOING TO DO IS WORK WITH THE SCHOOL TO MAKE SURE -- WE
COULD DO THIS EXCAVATION DURING NON-SCHOOL YEAR.
I MEAN
SCHOOL'S OUT FOR A COUPLE MONTHS IN THE SUMMER.
WE CAN DO
17
IT, YOU KNOW, ALONG WITH ANYONE ELSE'S PLANS IF THERE'S
SOMETHING THAT'S IMPACTING ACROSS THE STREET AT THE
18
19
BUSINESS NEXT STORE.
WHAT WE ARE GOING TO BE DOING THOUGH
20
IS TAKING PRECAUTIONS WITH DUST SUPPRESSION TO LIMIT THE
21
AMOUNT OF DUST THAT IS GENERATED.
WE RAVE TO COMPLY WITH
22
LAWS, CALIFORNIA REGULATIONS AS TO HOW MUCH CAN BE EMITTED
23
24
ANYWAY, SO WE ARE GOING TO HAVE TO BE WITBIN THOSE
REQUIREMENTS, SO THE LAWS ARE PROTECTIVE, AND WE'RE GOING
25
TO MAKE SURE OUR ACTIONS ARE ALSO PROTECTIVEo
63
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1 MS. HERRERA: WILL YOU STATE YOUR .NAME FOR THE RECORD?
2 MR. MORENO: RICK MORENO, M-O-R-E-N-O.
3 MS. HERRERA: THERE'S A QUESTION IN THE BACK.
4 MR. CALDERONE: MY NAME'S DENNIS CALDERONE. YOU HAVE
5 ALL THESE STUDIES.
HAVE YOU EVER HAD A STUDY ON HEALTH OR
6
THE PEOPLE THAT ARE AROUND THAT AREA AS FAR AS I MEAN, YOU
KNOW, CERTAIN HEALTH DANGERS OR WHATEVER'S IN THAT CERTAIN
7
8 AREA OR DO YOU BAVE ANY?
9
10
'"
MR. HARRIS-BISHOP:
MARILYN, DO YOU WANT TO TAKE TBAT?
MS. UNDERWOOD:
I'M FROM THE CALIFORNIA DEPARTMENT OF
11
HEALTH SERVICES.
WE HAVE ACTUALLY A COOPERATIVE AGREEMENT
12
WITH THE FEDERAL AGENCY TO LOOK AT HEALTH ISSUES AROUND
13
SUPERFUND SITES.
THIS AGENCY BAD LOOKED AT THAT -- NOT
14
15
BUT THIS AGENCY LOOKED AT THE SITE IN 1988, FELT
D.H.S.,
THAT IT MIGHT POSE A POTENTIAL PATHWAY OF CONCERN OR HEALTH
16
17
CONCERN.
AT THAT POINT, THERE WAS VERY LITTLE DATA.
I'M
JUST IN THE PROCESS OF REVIEWING THE SITE RIGHT NOW, AND I
THINK BASED ON WHAT I SEE, I WOULD NOT SAY THAT THERE'S A
18
19
20
NEED FOR A HEALTH STUDY AROUND THIS AREA BECAUSE I DON'T
THINK THERE'S BEEN PATHWAYS OF EXPOSURE THAT WOULD ELICIT
21
22
ENOUGH -- ANY DISEASE ACTUALLY IN THIS AREA TO SEE, SO IF I
FELT -- AND WE DO THIS ACROSS CALIFORNIA.
I HAVE REVIEWED
23
24
OTHER SITES WHERE I THINK IT'S SOMETHING THAT'S WARRANTED,
TO DO A HEALTH STUDY.
25
MR. CALDERONE:
THEY WERE TALKING ABOUT THE AREA AND
64
-------
1
2
EVERYTHING ELSE, BUT I DON'T KNOW IF THEY MENTIONED
PEOPLE'S HEALTH.
3
MR. BARRIS-BISHOP:
WHAT I WANT TO STRESS IS WE DON'T
4
CURRENTLY HAVE THAT EXPOSURE, AND WE WANT TO MAKE SURE WE
DON'T HAVE THAT EXPOSURE IN THE FUTURE.
5
6
YES, SIR.
7
FATHER GALLAGHER:
AND MY POINT WOULD BE THE POINT
8
9
THAT I HAVE MADE BEFORE IS THAT I THINK THAT THERE SHOULD
BE A CLARIFICATION ABOUT THE WORD CONTAMINATION BECAUSE
10
11
THERE IS -- CONCERN OBVIOUSLY BAS BEEN EXPRESSED BY SOME
PEOPLE AND COMMENTS THAT DAVE BEEN MADE IN TERMS OF, YOU
12
KNOW, LIKE IS THERE A GREATER INCIDENT OF LUNG CANCER?
IS
13
THERE A GREATER INCIDENT OF SOME KIND OF PROBLEM OF HEALTH
14
BASICALLY BECAUSE OF THE -- OF THE LOCATION OF THE WASTE
15
DUMP NEAR US, AND THAT IS WHERE I THINK THAT THERE IS A
PROBLEM BECAUSE YOU VERY QUICKLY GO TO A POINT WHERE YOU
16
17
SAY WELL, THERE'S METHANE GAS BEING USED TO OPERATE THE
18
SHERATON INDUSTRY HILLS, AND PEOPLE ARE OUT THERE PLAYING
GOLF EVERY DAY, AND ALL OF US WHO LIVE IN WHITTIER ARE
19
20
RECEIVING ALL OF THE EMISSIONS THAT ARE COMING FROM A
21
NUMBER OF THE PLANTS IN SANTA FE SPRINGS ALL THE TIME, SO I
22
THINK THAT WHAT WE'RE TRYING TO DO IS TRYING TO FIND OUT
23
24
WELL, IS THERE A REASON FOR US TO BE CONCERNED ABOUT THE
25
HEALTH OF OUR CHILDREN, THE PEOPLE WHO LIVE ACROSS THE
STREET, YOU KNOW, BASED ON THIS, AND THAT IS EXACTLY WHAT
6S
-------
1
I'M HOPING THAT IS GOING TO BE DISCUSSED AS PART OF THE
PUBLIC SERVICE INVOLVED WITH THIS.
2
3
SO -- AND I'D LIKE TO MAKE A COMMENT NOW.
YOU
4
DON'T HAVE TO ANSWER IT THOUGH BECAUSE I'D LIKE TO -- MY
5
6
NAME'S ROBERT GALLAGHER.
I'M THE PRINCIPAL OF ST. PAUL
HIGH SCHOOL.
I WOULD LIKE TO SAY THAT WE ARE VERY
7
APPRECIATIVE OF THE WORK OF THE E.P.A.
THE SCHOOL HAS
8
COOPERATED WITH A NUMBER OF THE STUDIES THAT HAVE GONE ON
9
IN TERMS OF WHETHER OR NOT THERE IS SOME PROBLEM, AIRBORN
OR SOIL-BORN, IN TERMS OF THE HEALTH OF OUR STUDENTS OR
10
11 . ANYTHING THAT WE SHOULD BE CONCERNED ABOUT.
IF IN
12
13
CONJUNCTION WITH THE CITY OF SANTA FE SPRINGS, WHO WE
BELIEVE ARE RESPONSIBLE INDIVIDUALS ELECTED BY THE MEMBERS
14
OF THE CITY, THAT SOMETHING SHOULD BE DECIDED TO BE DONE ON
THAT PROPERTY, THAT WE WOULD PREFER THAT NOTHING WOULD BE
15
16
ABOVE THE LEVEL OF THE PROPERTY IN TERMS OF BUSINESS WHERE
17
18
WE WOULD HAVE TO BE CONCERNED ABOUT THE SAFETY OF THE
STUDENTS AT SOME FUTURE DATE BASED ON A DECISION OF
19
SOMEBODY OTHER THAN US ABOUT WHO IS GOING TO OWN THAT
20
21
PROPERTY OR USE THAT PROPERTY OR WE WOULD WANT SOMETHING,
FOR EXAMPLE, A WALL OR THE GOVERNMENT TO PROVIDE SOME KIND
22
OF PROTECTION SO THAT WE WOULD NOT HAVE TO BE CONCERNED
23
24
ABOUT THE SAFETY OF OUR STUDENTS, SO IF WE BAD A COMMENT TQ
MAKE, I WOULD THINK THAT IT WOULD BE THAT WE WOULD PREFER
25
THAT IT NOT BE ASPHALT, THAT IT WOULD REMAIN EXACTLY THE
66
-------
-
1
2
WAY IT IS, AND IF THERE IS ABSOLUTELY NO PROBLEM RIGHT NOW
AND IF I COULD BUILD A HOUSE THERE THAT I COULD LIVE ON FOR
3
4
70 YEARS WITH NO PROBLEM, WELL, THEN I WOULD JUST ASSUME
SEE THAT THINGS BE LEFT AS THEY ARE. RIGHT AT THIS MOMENT.
5
HR. BARRIS-BISHOP:
THANK. YOU.
6
HR. SHARP:
ALBERT SHARP.
COMMENT:
ALONG WITH FATHER
7
8
GALLAGHER, I AS A CITY COUNCILMAN IN THIS CITY HAVE NO
DESIRE TO SEE ANYTHING HAPPEN ON THAT SITE AS FAR AS A
9
10
STORAGE YARD OR ANYTHING.
I THINK EVERY MEMBER OF THE
E.P.A.
IN THIS ROOM KNOWS HOW I FEEL ABOUT PUTTING ASPHALT
11
DOWN.
I DON'T WANT TO SEE A BLACK OR A GREEN MOUNTAIN.
AS
12
13
FAR AS I'M CONCERNED, IF THERE'S NOTHING WRONG WITH THE
SOIL, WHY DON'T WE. JUST PLANT WILD FLOWERS OVER IT, MAKE IT
14
15
AS AESTHETICALLY PLEASING TO THE COMMUNITY AS WE POSSIBLY
CAN AND LET THAT SLEEPING DOG LIE IF THERE'S NO -- ALL
16
WE'RE DOING IS JUST COVERING IT SO SOMEONE CAN COME IN AND
17
SET SOME TRACTORS AND TRUCKS AND TRAVEL TRAILERS AND
18 WHATEVER ELSE ON IT.
NO, I'M NOT IN FAVOR OF THAT.
19
HR. BARRIS-BISHOP:
THANK YOU.
20
HR. SHARP:
BUT I DON'T KNOW HOW MUCH VOICE THE CITY
21
OF SANTA FE SPRINGS EVEN HAS.
22
23
HR. BARRIS-BISHOP:
I WOULD LIKE TO JUST REITERATE
THAT IT IS IMPORTANT THAT WE HEAR THESE COMMENTS.
THAT'S?
24
25
WHY WE LOOKED AT A LOT OF THESE DIFFERENT ALTERNATIVES, AND
THEY'RE ALL OPEN FOR COMMENT.
I THINK THAT'S DEFINITELY A
67
-------
1
2
LEGITIMATE CONCERN, AND IF WE CAN DETERMINE IF THAT'S
PROTECTIVE AND EVERYONE WANTS TO GO WITH THAT, WE CAN DO
3
4
I MEAN THERE'S GOING TO BE RESTRICTIONS ON THE USE
THAT.
OF THE PROPERTY ANYWAY, SO IF WE WANT TO JUST RESTRICT AND
MAKE IT A BEAUTIFUL GRASSY GREEN FIELD THAT EVERYONE CAN
5
6
DRIVE BY AND ENJOY, THAT'S A POSSIBILITY, AND THAT'S ONE OF
7
8
THE ALTERNATIVES THAT WE LOOKED AT.
IT'S ALSO -- WE COULD
MIX COMPONENTS OF THE ALTERNATIVES SO THAT WE HAVE -- WE'VE
9
10
ALREADY GOT A PARKING LOT OVER PART OF THE AREA WHERE SANTA
WE CAN WORK AROUND THAT.
FE SPRINGS STORAGE IS.
THERE'S A
11
12
LOT OF DIFFERENT ALTERNATIVES WE HAVE.
I MEAN I REALLY DO
APPRECIATE THESE COMMENTS BECAUSE IT WILL HELP ME GO BACK,
13
AND WHEN WE'RE WRITING THE DECISION, IF WE COME UP WITH
14
SOMETHING DIFFERENT, YOU'LL KNOW BECAUSE WHEN WE COME OUT
AND TELL YOU WHAT OUR DECISION IS, IT'S GOING TO -- IT
15
16
WON'T BE A PROPOSED PLAN IF EVERYONE FEELS THAT WE NEED TO
17
DO SOMETHING DIFFERENT.
18
MS. HERRERA:
THERE'S SOMEONE ELSE IN THE BACK.
19
MS. CALDERONE:
MY NAME IS DEBORAH CALDERONE,
20
21
C-A-L-D-E-R-O-N-E, AND MY COMMENT AND CONCERN BASICALLY
GOES BACK TO SEISMIC ACTIVITY.
I HAVE CHILDREN THAT GO TO
22
ST. PAUL.
IF WE HAVE A MAJOR CATASTROPHE -- IT COULD BE
23
TODAY, TOMORROW, TEN YEARS FROM NOW -- MY KIDS HAVE TO GO
24
OUT THERE ON THAT FIELD.
IS THERE ANY WARNING SIGNS, BELLS
25
OR SOMETHING TO SAY THAT, YOU KNOW, THERE IS TOXIC WASTE
68
-------
1 GOING OUT IN THE AIR, METHANE GAS? ARB THEY GOING TO BE
2
3
EXPOSED AND HARMED BY THIS IF THEY'RE OUT THERE IN THE
FIELD?
I MEAN WHAT IS THE LIMITS TO WHERE THEY WOULD BE
4
EXPOSED?
5
MR. BARRIS-BISHOP: . I DON'T KNOW IF I CAN ANSWER YOUR
6
QUESTION RIGHT NOW.
I DON'T ENVISION THAT IF WE HAD AN
7
8
EARTHQUAKE -- I MEAN THERE WAS A SIGNIFICANT EARTHQUAKE
HERE, I THINK, IN THE LATE '80'S THAT WE DIDN'T SEE ANY --
9
10
YOU KNOW, DISTINCTIVE SHIFT IN ANY STRUCTURE AT THE SITE.
WHAT WE WOULD BE DOING THOUGH IS TO MAKE SURE THAT THAT'S
11
12
PROTECTIVE.
IF THERE WERE, YOU KNOW, SOME KIND OF RELEASE,
THEN WE WOULD HAVE TO ADDRESS IT AT THAT TIME.
I CAN'T SAY
13
RIGHT ~OWTHAT IF THERE IS SOME EARTHQUAKE, THAT NOTHING IS
GOING TO HAPPEN BECAUSE I CAN ENVISION A PRETTY BIG
14
15
16
EARTHQUAKE.
MS. CALDERONE :
COMMENTS WERE MADE BY THE STUDENTS
17
THAT THEY SAW FOG OR STEAM COME FROM THIS AREA AFTER ONE OF
18
19
THE LAST EARTHQUAKES.
THAT WAS MY CONCERN IS HOW MUCH WAS
TRUTH TO IT OR NOT?
I DON'T KNOW.
20
MR. BARRIS-BISHOP:
I'M NOT AWARE OF THAT AT ALL.
I
21
DON'T THINK THAT YOU WOULD BE ABLE TO SEE METHANE IF IT
22 WERE RISING.
IT'S A --
23
24
FATHER GALLAGHER:
THAT'S A CLARIFICATION ON THAT.
THERE WAS NOTHING THAT CAME FROM THAT PIECB OF PROPERTY AT
25 ALL; THAT THERE WAS A GAS BUBBLE OR A GAS CmUD THAT CAME
69
-------
1
2
OVER THE AREA THAT CAME FROM A DIFFERENT INDUSTRIAL SITE IN
THE CITY OF SANTA FE SPRINGS, BUT IT BAD NOTHING TO DO WITH
3
4
THAT PIECE OF PROPERTY RIGHT NEXT '1'0 IT, AND I THINK
MR. SHARP WOULD AGREE WITH THAT.
5
MR. BARRIS-BISHOP:
WHAT WE'VB DETECTED THUS FAR HAS
6
JUST BEEN FAIRLY SMALL, AND I CAN'T ENVISION SOMETHING
COMING UP THAT WE COULD SEE, .BUT WE'LL KEEP MONITORING
7
8
9
THAT, AND ANY OF THESE ALTERNATIVES, WE'LL CONTINUE TO
MONITOR THE GAS AND THE GROUNDWATER TO MAKE SURE THAT WE
10 ARE MAINTAINING PROTECTIVENESS.
11
12
YES, SIR, MR. CALDERONE.
MR. CALDERONE:
MY NAME IS DENNIS CALDERONE.
YOU'RE
13
14
TALKING ABOUT PUTTING THE DAISIES AND EVERYTHING.
IS THERE
ANY WAY THAT YOU CAN PUT A NICER LOOKING FENCE INSTEAD OF
15
BARBED WIRE OR A HIGHER FENCE?
16
MR. BARRIS-BISHOP:
I THINK THAT'S A LEGITIMATE
17
COMMENT.
THAT'S SOMETHING WE'LL LOOK INTO.
18
19
MR. MORENO:
RICK MORENO.
TO BE A SUPERFUND SITE,
DOES THAT MEAN THAT THIS SOIL IS EXTREMELY CONTAMINATED OR
IS IT JUST -- YOU KNOW, IT JUST DOESN'T GET ON THE
20
21
SUPERFUND SITE JUST FOR NOTHING, RIGHT?
22
23
MR. HARRIS-BISHOP:
WHAT WE DO WHEN WE'RE DOING THIS
PRELIMINARY INVESTIGATION, BEFORE IT'S LISTED ON THE
NATIONAL PRIORITIES LIST, WE MAKE A LOT OF ASSUMPTIONS.
WE
24
25
TAKE A LIMITED NUMBER OF SAMPLES AND THEN PUT IT INTO A
70
-------
1
2
MODEL TO SEE IF IT COULD POTENTIALLY CAUSE A PROBLEM.
A
PROBLEM WITH ANY MODEL IS THAT YOU MAKE ASSUMPTIONS, AND,
YOU KNOW, THE NUMBERS CAME OUT, AND WE SAID THIS IS
3
4
POTENTIALLY ENOUGH FOR --
5
SO IT IS VERY CONTAMINATED PROBABLY.
MR. MORENO:
6
I WOULDN'T SAY IT'S VERY
MR. BARRIS-BISHOP:
7
8
IT'S JUST THAT OUR ASSUMPTIONS WERE --
CONTAMINATED.
MR. MORENO:
MORE THAN JUST A LITTLE BIT.
9
10
OUR ASSUMPTIONS LED US TO BELIEVE
MR. BARRIS-BISHOP:
THAT IT WOULD BE MORE CONTAMINATED THAN WE ULTIMATELY IN
11
DOING OUR THOROUGH INVESTIGATION THAT WE DID FOUND IT TO
12
13
WHAT WE FOUND IS THAT -- I MEAN THERE ARE CONTAMINANTS
BE.
HERE THAT ARE OF CONCERN.
THEY'RE MOSTLY DEEP.
THEY'RE
14
NOT READILY ACCESSIBLE TO THE PUBLIC, BUT AS I SAID, IN THE
15
FUTURE THEY COULD BE BY SOMEONE GOING OUT THERE.
16
MR. MORENO:
IF THERE'S AN EARTHQUAKE OR WHATEVER.
17
MR. BARRIS-BISHOP:
I DON'T THINK IF THERE'S AN
18
EARTHQUAKE, YOU'D SEE AN EXPLOSION DOWN AT 35 FEET.
19
20
MR. MORENO:
BECAUSE THE KIDS DID SEE THAT CLOUD COMB
FROM THAT SOIL.
21
MR. BARRIS-BISHOP:
AS FATHER GALLAGHER SAID, THAT WAS
22
FROM ANOTHER FACILITY.
23
24
MR. MORENO:
NO, THAT WAS THAT SITE, 43 ACRE SITE WE
ARE TALKING ABOUT.
25
MR. BARRIS-BISHOP:
ACTUALLY, I CAN'T SPEAK TO THAT AT
71
-------
1
2
ALL BECAUSE I CAN'T ENVISION ANYTHING -- SOMETHING THAT YOU
COULD SEE COMING FROM THE SITE.
CONTAMINATION IS JUST NOT --
IT'S JUST NOT -- THE
3
4
AND THERE HAVE BEEN REPORTS OF ODORS.
I
MR. MORENO:
5
DON'T KNOW HOW MANY PEOPLE HAVE GOTTEN SICK. THERE'S
6
BEEN -- THERE HAVE BEEN THOSE REPORTS.
7
WELL, IT'S A DEFINITE COMMENT.
MR. HARRIS-BISHOP:
8
9
MR. MORENO:
DEPENDING ON THE DIRECTION OF THE WIND.
MR. HARRIS-BISHOP:
I'LL TAKE A LOOK AND SEE IF I CAN
10
FIND 0U'1' ANYTHING.
FROM MY PERSONAL OPINION AND WHEN I
11 . HAVE EVALUATED, I CAN'T SEE --
12
MR. MORENO:
THE REASON -- I'M A ST. PAUL PARENT AS
13
WELL .
I'VE HAD TWO KIDS GRADUATE FROM THERE, AND I HAVE
14
ONE THAT'S CURRENTLY ATTENDING, AND WE HAVE TWO MORE COMING
UP, SO WE'RE GOING TO BE ASSOCIATED WITH ST. PAUL FOR MANY,
15
16
17
MANY YEARS, AND --
MR. HARRIS-BISHOP:
I DEFINITELY UNDERSTAND YOUR
18
19
CONCERN.
THAT'S WHY I AM HERE.
MR. MORENO:
WE'RE CONCERNED WITH OUR KIDS AND THEN
20
21
THE OFFSPRING AS WELL.
WHAT WILL HAPPEN 30 YEARS DOWN THE
LINE, WE DON'T KNOW.
22
MR. HARRIS-BISHOP:
I UNDERSTAND.
THAT'S WHY WE'RE
23
HERE.
THAT'S WHY I FEEL CONFIDENT IN SAYING THAT --
24
MR. MORENO:
WE'RE ASKING YOU BECAUSE YOU HAVE OTHER
25
EXPERIENCES.
DO YOU HAVE OTHER SIMILAR SITES?
72
-------
1
2
MR. HARRIS-BISHOP:
I ACTUALLY DON'T HAVE ANY SITES
3
THAT ARE LIKE W.D.I., BUT BASED ON THE EVIDENCE FROM WHAT
WE'VE SEEN AT W. D. I., THE RISKS JUST ARE VERY, VERY
4
SMALL --
5
6
MR. MORENO:
BECAUSE WE'RE VERY CONCERNED BECAUSE YOU
HEAR OF WHAT GOES ON IN TEXAS AND MEXICO AND OTHER AREAS
7
8
AND EVEN IN CALIFORNIA, AND IT'S -- IT'S VERY -- YOU KNOW,
YOU HAVE NIGHTMARES OVER THIS, AT LEAST I DO.
9
10
THAT'S WHY WE'RE HERE TO TAKE
MR. HARRIS-BISHOP:
YOUR -- LISTEN TO YOUR CONCERNS AND ADDRESS THEM, AND I'LL
11
BE THE FIRST ONE TO SAY I THINK THAT THE SITE'S RISKS --
12
13
RISKS POSED BY THE SITE ARE --
MR. MORENO:
JUST THAT ONE RISK THAT YOU'RE TALKING
14
ABOUT.
IF IT'S JUST A MINIMUM RISK, THE RISK EXISTS.
15
16
MR. HARRIS-BISHOP:
YES, SIR, I UNDERSTAND.
ANDY?
17
LAZ ZARETTO.
BAS THE E.P.A. DEVELOPED
MR. LAZ ZARETTO:
18
A PROFILE, A TOPOGRAPHIC PROFILE, OF HOW THE SITE WOULD
19
20
LOOK AFTER THE IMPLEMENTATION OF THE ALTERNATIVE?
MR. BARRIS-BISHOP:
NO.
THAT WOULD BE DONE DURING ANY
21
22
DESIGN THAT WE DO ULTIMATELY FOR THE SITE.
I MEAN THE ONLY
THING I HAVE IS KIND OF THIS REALLY ROUGH SCHEMATIC walCH
23
24
MORE -- MORE OR LESS REALLY JUST SHOWS THE LAYERS THAT
WE'RE GOING TO HAVE --
25
MR. LAZ ZARETTO:
THEN I WOULD MAKE THE COMMENT THAT
73
-------
1
2
SOME WORK BEFOREHAND SHOULD BE DONE TO MAKE REPRESENTATION
OF HOW -- BOW THE SITE WILL LOOK GIVEN THE FACT THAT MORE
3
4
BARTH IS GOING TO BE PLACED ON TOP SO THAT THERE'S SOME
GOOD IDEA SO PEOPLE CAN MAKE, I THINK, AN INFORMED DECISION
5
6
OF HOW IT'S GOING TO LOOK ULTIMATELY.
MR. HARRIS-BISHOP:
ABOUT HOW HIGH OR SOMETHING --
7
8
MR. LAZ ZARBTTO:
I'D LIKE TO ASK ONE MORE QUESTION
WHILE I HAVE THE FLOOR.
IN THE AREAS ALONG GREENLEAF THAT
9
10
ARE SHOWN IN PINK, THE HATCHED PINK, WHAT IS THE NATURE OF
THE CONTAMINATION ALONG THOSE PROPERTIES, DO YOU KNOW
11
12
OFFHAND?
MR. HARRIS-BISHOP:
OFFHAND, I KNOW THAT WE HAVE
13
ELEVATED LEVELS OF ARSENIC AND THALLIUM, AND WE ALSO
DETECTED IN HERE (INDICATING) SOME ELEVATED LEVELS OF
14
15
16
CHROMIUM NEAR THE SURFACE, AND I BELIEVE BENZOPYRENE IS
ANOTHER ONE, walCH IS A PETROLEUM DERIVATIVE THAT I THINK
17 -IS A POTENTIAL HUMAN CARCINOGEN.
ALL OF THESE WERE FOUND
18
AT RELATIVELY LOW LEVELS, BUT SINCE WE'RE GOING TO BE --
19
SINCE WE CAN GET TO IT, THAT'S WHY WE WANT TO GET TO IT IF
WE CAN, BUT IN THE FEASIBILITY STUDY IT LAYS OUT THE
20
21
CONTAMINATION THAT WE FOUND AT EACH OF THOSE AREAS.
WE
22
DIVIDED THE SITE INTO EIGHT SUBAREAS AND LOOKED AT THEM AND
KIND OF CATEGORIZED WHAT CONTAMINATION WE FOUND BASED ON
23
24
HISTORICAL RECORDS OF THE SITE.
25
MR. LAZ ZARBTTO:
IF I COULD HAVE A FOLLOW-UP QUESTION
74
-------
1
2
OF THAT, RUSTY.
ON THOSE PROPERTIES THAT ARE ON THE
3
PERIPHERY BUT NOT MARKED IN PINK, IF I UNDERSTOOD WHAT YOU
WERE SAYING EARLIER, THAT THERE MIGHT BE DEED RESTRICTIONS
4
PLACED ON SOME OF THOSE PROPERTIES.
HAVE YOU IDENTIFIED
5
walCH PROPERTIES MIGHT HAVE DEED RESTRICTIONS, FOR EXAMPLE,
OR WHAT OTHER KIND OF LAND USE CONTROLS AND HAVE YOU
6
7
8
IDENTIFIED WHAT KIND OF LAND USE CONTROLS THAT WOULD GO
WITH EACH OF THE PROPERTIES?
9
10
MR. BARRIS-BISHOP:
NO, WE HAVEN'T.
THAT'S SOMETHING
THAT WOULD BE PART OF THE DESIGN PHASE IN DESIGNING THE
11 . INSTITUTIONAL CONTROLS FOR PROTECTIVENESS BUT STILL
12
ALLOWING SOME FLEXIBILITY.
I CAN SAY MOST OF THE PARCELS
13
14
DO HAVE SOME LEVEL OF CONTAMINATION.
SOME OF IT MAY BE
DOWN ONLY AT 20 FEET SO THAT WE CAN PRETTY MUCH -- I THINK
15
WE COULD SAY WE'D ALLOW ALMOST UNLIMITED DEVELOPMENT AS
16
LONG AS YOU DON'T DIG DOWN PAST 20 FEET, SO -- BUT WE WOULD
17 .BE DOING THAT ON A PARCEL BY PARCEL BASIS DURING THE DESIGN
18
TO HAVE A MORE ACCURATE DEPICTION OF THE CONTAMINATION OF
19
EACH PARCEL.
20
WHAT WE DID DURING THE REMEDIAL INVESTIGATION IS
LOOKED AT IT ON A SITE-WIDE BASIS, BUT THAT IS SOMETHING
21
22
23
THAT WE WOULD HAVE TO ADDRESS DURING THE DESIGN.
MR. LAZZARETTO:
THANK YOU.
24
25
MS. HERRERA:
WE HAVE A QUESTION IN THE BACK.
SHE CHANGED HER MIND.
DO YOU STILL WANT TO MAKE
75
-------
1
2
A COMMENT?
MR. BARRIS-BISHOP:
IN THE BACK?
3
4
HOW MANY PEOPLE IN THE MEDIA KNOW ABOUT
MS. CAMERENE :
THIS MEETING?
DID YOU PUBLISH IT IN THE NEWSPAPER?
5
6
MR. BARRIS-BISHOP: "WE HAVE A MAILING LIST OF OVER
100, I THINK, RIGHT NOW THAT WE MAILED A FACT SHEET OUT
7
8
TO.
WE TOOK OUT ADVERTISEMENTS IN THE NEWSPAPER, AND WE
HAVE TWO REPORTERS RIGHT HERE, MICHAEL SPRAGUE FROM THE
WHITTIER DAILY NEWS AND PSYCHE PASCUAL FROM THE LOS ANGELES
9
10
TIMES, AND THEY BOTH WROTE ARTICLES CONCERNING THIS PUBLIC
11 . MEETING AND ARTICLES PREVIOUSLY -- I KNOW MIKE HAS WRITTEN
12
SEVERAL ARTICLES ABOUT THE SITE.
13
14
MS. CAME RENE :
AND THE SECOND THING IS IGNORANCE IS
THE BIGGEST ENEMY OF EVERYBODY, AND THIS COMES AS A
SURPRISE WHAT IS GOING ON AND HOW TO PUT THE REMEDY, AND
15
16
IT'S LIKE -- I MEAN THERE'S TOO MANY THINGS IN THE AIR.
17
WHAT IS THE DECISION?
IT'S KIND OF CONFUSING.
LIKE FATHER
18 . GALLAGHER SAYS, LEAVE IT LIKE IT IS OR GET INTO, YOU KNOW,
19
20
THAT WILL TAKE A YEAR, TWO YEARS, THE EXPOSURE?
KNOW.
I DON'T
21
22
MR. BARRIS-BISHOP:
LIKE I SAID, I WANT TO EXPRESS
JUST ONE MORE TIME E.P.A. IS GOING TO MAKE SURE THAT
23
WHATEVER WE DO IS PROTECTIVE FIRST OFF.
THAT'S OUR GOAL,
24
25
AND SO ANYTHING THAT WE DO IS GOING TO BE PROTECTIVE.
IF
WE CAN MAKE CONCESSIONS TO THE PUBLIC TO DO SOMETHING THAT
76
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1
2
THEY WOULD LIKE BETTER AND IT'S STILL PROTECTIVE, WE WILL
DO THAT, AND IF THE CITY COUNSEL HAS PROVISIONS THAT THEY
3 WOULD LIKE INCLUDED AND THEY'RE STILL PROTECTIVE, WE WILL
4
WE CAN'T GO OUT AND SPEND 100 MILLION DOLLARS TO
DO THAT.
5
6
PAINT THAT PAVEMENT BRIGHT BLUE SO EVERYONE LIKES IT OR
BUILD A SOCCER FIELD OR SOMETHING LIKE THAT, BUT WE CAN BE
7
8
WITHIN REASON TO TAKE INTO ACCOUNT YOUR CONCERNS SO THAT WE
ADDRESS THEM APPROPRIATELY.
9
FATHER GALLAGHER?
10
THIS IS A COMMENT, AN ADDITIONAL
FATHER GALLAGHER:
11
COMMENT; THAT I THINK THAT SOME PEOPLE HAVE INDICATED HERE
12
13
THIS EVENING THAT THEY'RE A LITTLE BIT CONFUSED.
IF YOU
WILL NOT TAKE AWAY EVERYTHING THAT IS ON THE PROPERTY RIGHT
14
NOW, WHY WOULD YOU EVER ACCEPT THAT WE WOULD WANT YOU TO
15
DIG IN SOME OF THE AREA THAT YOU CONSIDER CONTAMINATED AND
16
PUT THAT CONTAMINATED SOIL ON TOP OF FIVE FEET OF SOIL THAT
17
IS NOT CONTAMINATED AND THEN GUARANTEE US THAT THAT IS
18
GOING TO BE PROTECTED BY WHATEVER YOU DO WITH IT WHEN
19
YOU'RE USING THE ARGUMENT THAT IT WOULD BE SAFER FOR US TO
20
NOT -- NOT TO TOUCH -- NOT TO MOVE IT FROM THAT AREA AT
21
ALL?
SO THAT'S WHY I THINK THAT THERE HAS TO BE A
22
23
CLARIFICATION ABOUT THE WORD CONTAMINATION BECAUSE I HAVE
BEEN LED TO BELIEVE THAT WE'RE USING THE WORD
24
CONTAMINATION, AND THERE IS PROBABLY A POSSIBILITY OF
CONTAMINATION ON THAT PIECE OF PROPERTY THAT MIGHT NOT BE
25
77
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1
ANY DIFFERENT THAN THE BACK YARD OF SOMEBODY IN SANTA FE
SPRINGS IN SOME AREAS OF CONTAMINATION.
2
3
MR. BARRIS-BISHOP:
WELL, WHAT WE'RE GOING TO BE --
4
THE MATERIAL THAT WE'D BE EXCAVATING IS AT AN ELEVATED
5
IT'S NOT SOMETHING THAT IS GOING TO POSE A THREAT
LEVEL.
6
7
WE WOULDN'T EXCAVATE THIS
ONCE IT'S UNDER THAT CAP.
MATERIAL AND PUT IT IN THE MIDDLE AND THEN JUST LEAVE IT
8
THAT'S WHY WE WANT TO PUT THE CAP DOWN, TO PREVENT
THERE.
9
THAT WOULD BE -- THAT
ANYONE FROM COMING INTO CONTACT.
10
11
WOULD PREVENT ANY EXPOSURE.
THE OTHER ALTERNATIVE THAT WE
HAVE WHERE WE EXCAVATE AND THEN CONSOLIDATE THE MATERIAL
12
13
WITH THE CAP, THAT'S THE GOAL OF THE CAP IS TO PREVENT ANY
FUTURE CONTAMINATION.
IT'S A PHYSICAL BARRIER TO THE
14
CONTAMINATION.
IF WE DON'T DO ANYTHING ABOUT IT, THEN WE
15
RISK SOMEONE COMING ALONG AND EVENTUALLY COMING INTO
16
CONTACT WITH IT AND NOT TAKING THE PRECAUTIONS THAT E.P.A.
17
WILL TAKE WHEN WE DO THE EXCAVATION, SO I MEAN THERE IS --
LIKE I SAID, THERE'S ARSENIC THAT IS THERE THAT'S AT
18
19
20
ELEVATED LEVELS.
WE HAVE A BACKGROUND LEVEL OF ARSENIC IN
THE CITY, IN CALIFORNIA, BUT WE'RE TALKING ABOUT ELEVATED
21
22
LEVELS FROM THAT THAT WE'VE FOUND HERE.
MARILYN, YOU WANT TO ANSWER THAT?
23
MS. UNDERWOOD:
I JUST WANT TO MAKE A STATEMENT.
THE
24
STUFF THAT'S IN THE GROUND IS NOT JUST LIKE YOUR BACK YARD
25
SOIL.
E.P.A. DOESN'T GO AROUND CLEANING UP SITES .AND
78
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1
2
WORRYING ABOUT SITES THAT ARE BACK YARD SOIL, SO IF BE
IMPLIED THAT THAT'S TRUE, THAT'S NOT TRUE.
THERE'S MORE
3
THERE'S A NUMBER OF COMPOUNDS
THAN JUST ARSENIC THERE.
4
THAT EXCEED HEALTH CRITERIA ACCORDING TO THE DEVELOPMENT BY
BOTH THE STATE AND FEDERAL AGENCIES ABOUT WHAT IS
5
6
ACCEPTABLE LEVELS IN SOIL, AND THAT SOMEWHAT IS BASED ON
THE FACT THAT OBVIOUSLY IF THIS STUFF WAS ALL AT THE
7
8
9
SURFACE, IT WOULD BE MUCH MORE OF A CONCERN TO EVERYBODY
HERE, BUT BECAUSE IT'S BURIED, IT'S NOT OBVIOUSLY POSING AN
10
THE CONCERN ALSO THEN IS WHILE ALL OF
IMMEDIATE CONCERN.
11
THIS CAN GO DOWN INTO THE GROUNDWATER, MANY OF THESE
12
13
THEY CAN MOVE DOWN INTO THE
COMPOUNDS ARE FAIRLY MOBILE.
GROUNDWATER, AND YOU DO GET -- EVENTUALLY IF YOU DON'T
14
WATCH OUT, IT WILL BE ALL THE WAY DOWN IN THE DRINKING
15
WATER SOURCE FOR PEOPLE IN THIS AREA, SO YOU WANT TO STOP
THE INFILTRATION INTO THE GROUNDWATER.
16
17
THE LAST WAY YOU CAN GET EXPOSED IS THROUGH THE
18
19
AIR THROUGH THE GASES ESCAPING, AND, AGAIN, YOU WANT TO TRY
TO MINIMIZE THAT, AND THEY'RE GOING TO TRY TO MINIMIZE THAT
BY PULLING THE GASES OUT IF THERE IS ANY SUBSTANTIAL
20
21
ACCUMULATION OF THOSE, SO -- BUT TO IMPLY THAT THIS IS A,
YOU KNOW -- THIS IS AN INNOCUOUS SITE, YOU DON'T HAVE TO
22
23
WORRY ABOUT CHEMICALS HERE IS WRONG.
IT'S NOT, BUT IT
24
HAPPENS TO BE BURIED.
NOW YOU'RE GOING TO TAKE STEPS TO
25
KEEP IT FROM EVER BEING EXPOSED TO PEOPLE, OKAY?
79
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2
YOU KNOW, LIKE LET'S TAKE THE
FATHER GALLAGHER:
SCENARIO IT'S BURIED NOW AND THERE'S AN EARTHQUAKE, A
3
UNDER THE GROUND RIGHT NOW YOU MIGHT
SIZEABLE EARTHQUAKE.
4
HAVE SOME KIND OF A FISSURE THAT WOULD COME ABOUT AND THAT
A CERTAIN AMOUNT OF GROUND UNDERNEATH THE GROUND LEVELS
5
6
WOULD BE BROKEN UP INTO SOME KIND OF A CAVERN OR SOMETHING
7
8
ELSE LIKE THAT, BUT THEN YOU'RE SAYING TO ALL THESE PEOPLE
WELL, YOU'RE GOING TO PROVIDE THIS PLASTIC SHEET ON TOP OF
9
WHAT IS GOING TO BE ON TOP OF THE GROUND WHERE THE SHAKING
10
MIGHT GO ON AND RIP THAT PLASTIC SHEET, AND THEN WE'RE
GOING TO HAVE CONTAMINATED SOIL RIGHT UP THERE NEAR THE TOP
11
12
OF THE --
13
RIGHT.
I DEFINITELY AS A TOXICOLOGIST
MS. UNDERWOOD:
14
WOULD BE CONCERNED ABOUT MAKING IT SAFE FOR SEISMIC
15
ACTIVITY, SO I THINK YOU HAVE A VERY GOOD POINT.
16
MR. HARRIS-BISHOP:
LET ME JUST REITERATE THAT WE'RE
17
NOT JUST GOING TO PAVE THE SITE AND LEAVE.
WE'LL BE BACK
18
HERE SAMPLING EVERY YEAR.
WE'LL BE LOOKING AT THE
19
INTEGRITY OF THE CAP.
I MEAN IF WHITTIER GETS AN
20
21
EARTHQUAKE, THAT WOULD BE SOMETHING THAT WE'D HAVE TO SAY
LET'S GO TAKE A LOOK AT THAT.
THE LONG-TERM OPERATION OF
22
MAINTENANCE IS SOMETHING THAT WILL BE CONTINUAL AS LONG AS
23
24
THIS REMEDY IS IN PLACE, AND WE'LL BE LOOKING AT IT TO MAKE
SURE THAT WHATEVER WE DO, YOU KNOW, THE GROUNDWATER IS
25
PROTECTED, THE AIR IS NOT BEING IMPACTED AND THE
80
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1
2
CONTAMINATION IS NOT MOVING.
THAT'S -- SO EVERY YEAR WE'LL
BE -- WE'LL BE DOING SAMPLING, EVERY FIVE YEARS WE'LL BE
3
4
EVALUATING TO MAKE SURE WE'LL STILL BE PROTECTIVE.
THAT'S
OUR GOAL.
5
BROTHER DENNIS?
6
I'VE LIVED IN SANTA FE SPRINGS LIKE
BROTHER DENNIS:
7
FROM 1965 ON, AND I'M AWARE THAT MOST OF THE TIME -- NOT
ALL THE TIME -- BUT I'M QUITE AWARE THE CITY BAS SPENT
8
9
LARGE AMOUNTS OF MONEY ON THE AESTHETICS OF THE CITY AND
10
PUTTING IN SOMETHING -- HOW MANY ACRES OF ASPHALT?
11
12
THIS IS ABOUT 18 -- THE WHOLE
MR. HARRIS-BISHOP:
SITE'S 43, AND I THINK THIS IS ACTUALLY --
13
MY CONCERN IS THAT'S A FAIRLY "UGLY
BROTHER DENNIS:
14
LOOKING THING, AND I OBVIOUSLY WOULD BE MORE -- THE GREEN
FIELD IS OBVIOUSLY MORE PLEASING TO LOOK AT.
15
16
MS. AGUILAR:
SPECIFICALLY, CLEANING IT UP, HOW LONG
17
WOULD IT TAKE?
18
TO --"TO DO ALL THE EXCAVATION?
MR. HARRIS-BISHOP:
I
19
20
DIDN'T ACTUALLY GO -- CALCULATE IT AS FAR AS CLEANING IT
UP.
I COULD TELL YOU THAT WE'D BE TALKING ABOUT ALMOST
21
750,000 CUBIC YARDS.
22
23
MS. AGUILAR:
AND WHAT DO YOU DO WITH IT WHEN YOU TAKE
IT OUT?
24
25
MR. HARRIS-BISHOP:
WE'D PUT IT IN THE GROUND
SOMEWHERE ELSE.
WE WOULD BASICALLY TAKE IT TO A LAND --
81
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2
YOU'RE NOT GOING TO DO THAT.
MR. MORENO:
MR. ~S-BISHOP:
NO.
THAT WAS SOMETHING THAT WE
3
4
LOOKED AT AND THEN REJECTED BECAUSE OF THE INCREASED RISKS
INVOLVED WITH IT AND THE COSTS.
5
WHAT DO YOU DO WHEN YOU CLEAN IT UP?
MS. AGUILAR:
6
WHAT DO YOU DO WHEN YOU CLEAN SOMETHING UP?
7
8
MR. HARRIS-BISHOP:
WHEN WE CLEAN IT UP.
RIGHT.
REMOVE THE SOIL, THE ENTIRE
MS. AGUILAR:
9
THING OR --
10
MR. HARRIS-BISHOP:
THAT'S WHAT WE WOULD NEED TO DO
11
12
HERE BECAUSE WE DON'T HAVE THE TECHNOLOGY IN PLACE THAT
COULD CLEAN IT WHILE IT'S DOWN THERE.
YOU KNOW, MAYBE IN
13
100 YEARS WE WOULD HAVE SOMETHING THAT COULD DO THAT.
14
MR. MORENO:
HOW ABOUT THAT BIO REMEDIATION THAT
15
16
MR. SHARP TALKED ABOUT?
MR. HARRIS-BISHOP:
BIO REMEDIATION DOESN'T ADDRESS --
17
18
MR. MORENO:
OR SOIL FARMING.
THERE'S A LOT OF
OTHER --
19
20
MR. BARRIS-BISHOP:
ANYTHING THAT RELIES ON SOME KIND
OF BIOLOGICAL ELEMENT, IT WORKS BY HAVING SOMETHING TO FEED
21
ON.
THEY'RE NOT GOING TO FEED ON ARSENIC, AND SO
22
23
BIOLOGICAL ORGANISMS AREN'T GOING TO WORK TO ADDRESS THE
CONTAMINATION OF THE SITE.
SINCE WE HAVE MULTIPLE
24
CONTAMINATION, THAT'S WHERE WE RAN INTO THE PROBLEM WHERE
25
WE DON'T HAVE ONE EASY THING THAT WE CAN TAKE CARE OF.
I
82
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2
WOULD LOVE TO HAVE SOMETHING THAT WE COULD INJECT INTO THE
GROUND AND MAKE THE SITE SAFE, BUT WE DON'T HAVE THAT
3
4
OPTION RIGHT NOW.
MS. AGUILAR:
WHAT WOULD BE ENTAILED TO CLEAN IT?
5
YOU'D TAKE THE SOIL --
6
7
MR. BARRIS-BISHOP:
WE DIG UP EVERYTHING THAT'S IN THE
RESERVOIR, EVERYTHING AROUND THE RESERVOIR THAT'S
8
CONTAMINATED, THE WHOLE SITE.
EVERYTHING UNDER THOSE
9
PROPERTIES THAT ALREADY HAVE BUILDINGS AND PARKING LOTS
10
HAVE SOIL THAT WE CONSIDER TO BE CONTAMINATED AS WELL.
11
12
WE'D HAVE TO REMOVE ALL THAT AND THEN PUT IT INTO TRUCKS
AND HAUL IT TO A FACILITY THAT IS PERMITTED TO TAKE ON THAT
13
RISK.
WE'D HAVE TO BASICALLY JUST PUT IT INTO A TRUCK,
14
TAKE IT TO A FACILITY WHERE THEY WOULD PUT IT INTO THE
15
GROUND AND ULTIMATELY PUT AN ASPHALT TOP ON IT.
16
MS. AGUILAR:
WHERE WOULD THIS BE?
17
MR. HARRIS-BISHOP:
IT'S IN KETTLEMAN CITY IS ACTUALLY
18
19
THE HAZARDOUS WASTE FACILITY.
MS. AGUILAR:
WHERE?
20
MR. HARRIS-BISHOP:
KETTLEMAN CITY.
IT'S IN EASTERN
21
CALIFORNIA.
22
MR. LAZ ZARETTO:
KERN COUNTY.
23
24
MS. AGUILAR:
WHAT WOULD THEY DO, TRUCKLOADS FULL?
MR. HARRIS-BISHOP:
WE'RE TALKING ABOUT -- A TRUCK
25
HOLDS, I THINK, 15 CUBIC YARDS, A REGULAR DUMP TRUCK, 50
83
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1
2
WE'RE TALKING ABOUT SEVERAL THOUSANDS OF THOSE TRUCKS
RUNNING THROUGH TO HAUL THIS AWAY.
IT WOULD TAKE A VERY
3
4
LONG TIME.
MS. AGUILAR:
AND THEN YOU WOULD REFILL IT?
5
MR. HARRIS-BISHOP WE WOULD HAVE TO BRING IN A WHOLE
6
7
THAT'S A LOT OF DIRT THAT WE'D HAVE TO
LOT OF CLEAN DIRT.
FIND, MAKE SURE THAT THAT'S CLEAN AND THEN PUT IT THERE TO
CLEAN UP THE SITE, AND IT'S JUST -- IT WOULD BE A HUGE
8
9
PROJECT FOR NOT REALLY MINIMIZING THE RISK THAT MUCH.
IF
10
THERE WAS SOMETHING THERE THAT WAS CAUSING AN IMMEDIATE
11 HEALTH THREAT AND WE DIDN'T HAVE ANY OTHER CHOICES, THAT'S
12
13
WHAT WE'D DO.
MS. AGUILAR:
HAVE YOU DONE IT IN OTHER SITES HERE IN
14
SANTA FE SPRINGS?
15
16
MR. HARRIS-BISHOP:
I DON'T THINK SO.
I THINK THIS
IS THE ONLY FEDERAL SUPERFUND SITE THAT WE HAVE IN SANTA FE
17
SPRINGS.
18
MS. AGUILAR:
THEN THIS IS FUNDED BY THE FEDERAL
19
GOVERNMENT.
20
21
MR. HARRIS-BISHOP:
SO FAR IT HAS BEEN.
WHAT WE
ULTIMATELY -- OUR GOAL IS TO HAVE THE PEOPLE WHO ARE
RESPONSIBLE FOR THE CONTAMINATION, MAINLY THE GENERATORS
22
23
WHO GENERATED THE WASTE AND PUT IT THERE -- WE'D LIKE TO
24
HAVE THEM PAY FOR IT, AND THAT'S THE GOAL OF THE AGENCY IN
25
THE LONG TERM.
IF WE END UP PAYING FOR THE WHOLE SITE UP
84
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1
2
MR. MORENO:
DOES IT STOP AT THE BOUNDARY, THE SOIL
CONTAMINATION?
3
4
MR. HARRIS-BISHOP:
PRETTY MUCH.
MS. HERRERA:
WE'RE DEFINITELY RUNNING OUT OF TIME.
5
WE ONLY HAVE A COUPLE OF MImrrES LEFT.
I WOULD LIKE TO
6
INVITE ANYBODY WHO BAS A COMMENT TO GO AHEAD AND STATE IT.
7
FATHER GALLAGHER:
ONE COMMENT, AND IT WOULD BE A
8 VERY BRIEF ONE, IS THAT I'D LIKE TO REITERATE THAT THE
9
POSITION OF THE SCHOOL IS THAT WE'D BE VERY RELUCTANT TO
10
HAVE ANY BUSINESS UP ABOVE THE LEVEL OF THE SCHOOL YARD
11 . WHERE WE WOULD HAVE TO BE CONCERNED ABOUT THE SAFETY OF THE
12
13
STUDENTS AND ALWAYS BE WONDERING WELL, WHO WAS GOING TO BE
LOOKING DOWN ON THEM SINCE -- SINCE THE FIELD IS USED FOR A
14
15
LOT OF DIFFERENT ACTIVITIES, SO THIS IS A DIFFERENT SAFETY,
SO I WOULD HOPE THAT THE E.P.A. WOULD ALSO ALLOW FOR THAT
16
17
IF THEY'RE GOING TO BE MAKING SOME KIND OF IMPROVEMENTS IN
THE AREA.
18
19
MR. HARRIS-BISHOP:
THANK YOU.
ARE THERE ANY OTHER COMMENTS?
20
21
MS. HERRERA:
ANY OTHER COMMENTS?
MR. HARRIS-BISHOP:
I'LL BE HERE -- GO AHEAD.
22
MS. HERRERA:
WE WOULD LIKE TO CLOSE THE MEETING
23
BECAUSE WE HAVE TO LEAVE BY NINE O'CLOCK, BUT I WANT TO
THANK YOU ALL FOR ATTENDING OUR MEETING ONCE AGAIN, AND
24
25
ALSO I WANT TO REMIND YOU THAT WE STILL ARE DURING THE
86
-------
1
2
FRONT, WE'LL GO AFTER THEM ONCE WE'VE COMPLETED IT.
ASK THEM TO PAY US BACK.
WE'LL
3
ARE THEY OIL COMPANIES?
MR. MORENO:
4
OIL COMPANIES ARE INVOLVED AND
MR. BARRIS-BISHOP:
5
SOME OTHER COMPANIES THAT HAD -- THAT HAD GENERATED WASTE,
AND THEY DISPOSED OF IT IN THERE.
6
7
SO THEN SOMEBODY WHERE YOU PUT ALL THIS
MS. AGUILAR:
8
9
STUFF OVER THERE BUILDS A SCHOOL AND BUILDS A TOWN ALL
AROUND IT, AND IT STARTS ALL OVER AGAIN, HUH?
10
MR. BARRIS-BISHOP:
THAT'S ALREADY A PERMITTED
11
12
FACILITY, SO THEY WOULD HAVE CONTROLS ALREADY IN PLACE, SO
WE WOULDN'T HAVE THIS SITUATION AGAIN.
13
14
MS. AGUILAR:
EXCUSE ME, BUT HAVE YOU TESTED -- HAS
THE FIELD AT ST. PAUL'S BEEN TESTED?
15
16
MR. BARRIS-BISHOP:
BMM-HMM.
WE PUT IN, I THINK,
EIGHT SOIL BORINGS ON THE FOOTBALL FIELD.
I THINK FATHER
17
GALLAGHER KNOWS WE KIND OF PUNCHED SOME HOLES AND WENT DOWN
18
QUITE DEEP AND FOUND THAT WE DON'T HAVE THE SAME KINDS OF
19
CONTAMINATION THAT WE HAVE ON THE SITE.
WE CONSIDER THOSE
20
TO BE BACKGROUND SOIL LEVELS, AND THEY'RE, YOU KNOW, FAIRLY
21
CONSISTENT WITH WHAT WE KNOW IN THE SURROUNDING AREA, SO IT
22
DOESN'T LOOK LIKE THE ACTIVITY THAT OCCURRED AT WASTE
23
DISPOSAL EVER IMPACTED THE HIGH SCHOOL PROPERTY EVEN BEFORE
24
THE HIGH SCHOOL WAS THERE, SO -- BUT WE DID LOOK, AND WE
HAVE -- AND WE ARE MONITORING THE GROUNDWATER ALSO.
25
85
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1
2
PUBLIC COMMENT PERIOD, SO IF YOU DIDN'T GET A CHANCE TO
SUBMIT YOUR COMMENT TONIGHT OR YOU NEED SOME MORE TIME TO
3
THINK ABOtPI' IT, YOU CAN ALWAYS SEND YOUR COMMENTS BEFORE
SEPTEMBER 12, AND OUR ADDRESS IS IN THE BACK OF THE FACT
4
5
SHEET, AND I HOPE YOU ALL GET A CHANCE TO PICK UP ONE IF
YOU DID NOT RECEIVE ONE IN THE MAIL.
6
7
MR. SHARP:
HOW WILL YOU NOTIFY THE COMMUNITY OF THE
8
9
E.P.A.'S DECISION?
MS. HERRERA:
WE WILL SEND A FACT SHEET TO EVERYBODY'S
10
11
HOME.
MR. SHARP:
TO ONLY THOSE PEOPLE WHO HAVE REGISTERED
12
13
THEIR ADDRESSES WITH E.P.A.?
MS. HERRERA:
WELL --
14
OR WILL YOU MAKE A GENERAL MAILING OF THE
MR. SHARP :
15
ENTIRE WHITTIER, SOUTH WHITTIER, SANTA FE SPRINGS AND THE
ADJACENT COMMUNITIES?
16
17
MS. HERRERA:
WE HAVE A MAILING LIST OF 100 -- WE HAVE
18
19
100 NAMES IN THE MAILING LIST, AND ALSO OUR FACT SHEETS
ALSO HAVE A COUPON ON THEM THAT THEY CAN RETURN TO US, AND
20
21
WE KEEP UPDATING OUR MAILING LIST WITH THE NEW ADDRESSES
AND NEW NAMES THAT WE RECEIVE, AND IF YOU HAVE ANY
SUGGESTIONS FOR US OF HOW TO IMPROVE OUR MAILING, I'LL BE
22
23
GLAD TO TAKE THEM.
24
25
MR. HARRIS-BISHOP:
WE ALSO DO -- I THINK WE'LL DO A
PRESS RELEASE AT THAT TIME ALSO TO LET EVERYONE KNOW THAT
87
-------
1
2
WE HAVE MADE THAT DECISION AND WHAT THAT DECISION IS.
MS. HERRERA:
AND ALSO WE PUT AN AD IN THE NEWSPAPER.
3
4
MR. HARRIS-BISHOP:
AND THEN THE DECISION DOCUMENT
WILL BE AVAILABLE IN THE LIBRARY FOR ANYONE TO COME IN AND
5
6
LOOK AT.
MR. SHARP:
THERE WON'T BE " A FURTHER PUBLIC MEETING TO
7
IDENTIFY WHAT THAT IS TO THE PUBLIC.
8
9
NO, NOT UNTIL WE'VE -- ONCE WE'VE
MR. HARRIS-BISHOP:
FINISHED THE PUBLIC COMMENT PERIOD, WHICH GOES ON FOR
10
11
ANOTHER WEEK AND A HALF, THEN THAT'S WHEN WE, YOU KNOW,
STOP AND DEVELOP OUR DECISION DOCUMENT, AND THEN WE COME
OUT AND TELL EVERYONE WHAT THE DECISION IS AND THEN GO
12
13
FORWARD WITH DESIGN, AND THEN WE HAVE MORE OPPORTUNITIES
FOR PUBLIC COMMENT AT THAT TIME.
14
15
16
WHEN WERE YOU HAVING YOUR NEXT COMMENT
MS. MORENO:
MEETING?
17
18
MR. HARRIS-BISHOP:
I DON'T KNOW YET EXACTLY.
IT WILL
BE NEAR THE BEGINNING OF THE DESIGN PHASE, SO I'M HOPING
SOMETIME IN THE BEGINNING OF THE NEXT YEAR, MARCH.
19
20
MS. MORENO:
I'M TALKING ABOUT THE COMMENT PHASE OF
21
THIS PLAN, THIS PROGRAM.
BETWEEN -- BETWEEN AUGUST 12TH
22
23
AND SEPTEMBER 12TH?
AND SEPTEMBER 12TH, YEAH.
MR. BARRIS-BISHOP:
THAT'S
24
THE PUBLIC COMMENT PERIOD FOR MAKING THE DECISION.
25
MS. MORENO:
ARE YOU GOING TO HAVE ANOTHER MEETING
88
-------
1
2
SUCH AS THIS?
MR. HARRIS-BISHOP:
NO, THIS IS THE ONLY ONE WE HAVE
3
4
UNLESS -- THE ONLY THING I CAN OFFER IS IF THERE'S A
COMMUNITY GROUP THAT WOULD LIKE ME TO MAKE THIS
5
PRESENTATION AGAIN, I CAN PROBABLY COME BACK DOWN BEFORE
THE END OF THE PUBLIC COMMENT PERIOD TO DO THAT.
6
7
WE NEED TO KNOW QUICKLY THOUGH.
MR. OPALSKI:
8
MR. HARRIS-BISHOP:
WE NEED TO KNOW BECAUSE IT'S
9
BECOMING THE END OF THE FISCAL YEAR, AND WE WOULD HAVE TO
10
MAKE SURE WE HAVE THE MONEY TO DO THAT.
IT'S POSSIBLE IF
11
WE HAVE ENOUGH INTEREST, WE COULD DO THAT AGAIN.
I'M
12
ALWAYS WILLING TO TALK ON THE PHONE OR YOU CAN CALL -- WE
13
HAVE A TOLL FREE NUMBER THAT YOU CAN LEAVE A MESSAGE, AND
14
THEN I CAN CALL YOU BACK.
15
I WANT TO STRESS THAT FOR OFFICIAL COMMENTS, WE
NEED TO HAVE THEM EITHER RECORDED BY THE COURT REPORTER OR
16
17
IN WRITING, AND THEN WE WILL BE ADDRESSING THEM ALL DURING
18
THAT RECORD OF DECISION DOCUMENT, AND WE'LL BE
INCORPORATING ALL YOUR LETTERS AND THEN HOW WE RESPONDED
19
20
TO THEM.
21
MR. OPALSKI:
LET ME CLARIFY FOR TONIGHT'S MEETING
22
BECAUSE THERE WAS THIS SORT OF BRINGING TOGETHER OF
23
QUESTIONS AND ANSWERS AND COMMENTS, AND WE'RE GOING TO BE
DOING OUR BEST AT LOOKING AT THE TRANSCRIPT AND GLEANING
24
25
OUT EVERYTHING, QUESTIONS AND COMMENTS AND WHATEVER, SO
89
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22
23
24
25
1
THAT WE'LL BE RESPONDING TO ALL THE SIGNIFICANT COMMENTS,
WHETHER THEY WERE PUT IN A QUESTION FORM OR COMMENT FORM,
2
3
4
IN THE RESPONSIVENESS SUMMARY, SO DON'T -- WE'RE MORE BUNG
UP WITH THEM THAN YOU ARB, SO JUST SO YOU KNOW, THAT'S HOW
5
6
WE'RE GOING TO HANDLE IT.
MR. BARRIS-BISHOP:
AND I WANT TO ENCOURAGE YOU ALL IF
7
YOU DO THINK OF SOMETHING, YOU KNOW, TO WRITE IT DOWN, TO
8
9
SEND IT TO ME, AND I REALLY APPRECIATE IT.
THANK YOU ALL
FOR COMING AND LISTENING.
IF YOU HAVE ANY OTHER
10
QUESTIONS OR IF YOU KNOW ANYONE ELSE WHO WOULD LIKE TO GET
11
IN ON OUR MAILING LIST, PLEASE LET US KNOW AND GIVE THEM A
12
FACT SHEET SO THEY CAN COME ON OUR MAILING LIST.
THANK
13
yOU.
14
(WHEREUPON THE MEETING WAS CONCLUDED AT 9: 00 P. M. )
15
16
17
18
19
20
21
90
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1
2
3
CERTIFICATION
4
5
I, KAREN M. KLEIN, CERTIFIED SHORTHAND REPORTER
NO. 5368, DO HEREBY CERTIFY THAT THE WITHIN
6
7
TRANSCRIPT OF PROCEEDINGS WAS TAKEN DOWN BY ME IN SHORTHAND
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AT THE TIME AND PLACE THEREIN SET FORTH AND WAS THEREAFTER
TRANSCRIBED INTO TYPEWRITING UNDER MY SUPERVISION AND
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DIRECTION.
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I FURTHER CERTIFY THAT THE FOREGOING 90 PAGES CONTAIN
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A TRUE AND CORRECT TRANSCRIPTION OF MY SHORTHAND NOTES SO
TAKEN.
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I FURTHER CERTIFY THAT I AM NEITHER COUNSEL FOR NOR
RELATED TO ANY PARTY TO SAID ACTION NOR IN ANYWISE
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INTERESTED IN THE RESULT OR OUTCOME THEREOF.
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WITNESS MY HAND THIS 6TH DAY OF SEPTEMBER, 1993.
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l*~l#T-- -m -ic CQt,--.
KAREN M. KLEIN, CSR NO. 5368, CM
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91
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