PB97-964506
EPA/541/R-97/128
January 1998
EPA Superfund
Record of Decision:
Western Pacific Railroad Go.
Oroville, CA
9/30/1997
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Record of Decision
Western Pacific Railroad
Oroville, California
September 30, 1997
U.S. Environmental Protection Agency
Region IX, San Francisco
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TABLE OF CONTENTS
RECORD OF DECISION
PART I - DECLARATION
1.0 Statement of Basis and Purpose -1-
2.0. Assessment of the Site -1-
3.0 Description of the Remedy -1-
4.0 Statutory Determinations -2-
PART II - DECISION SUMMARY
1.0 Site Name, Location and Description -3-
2.0 Site History and Enforcement -3-
3.0 Highlights of Community Participation -4-
4.0 Scope and Role of Response Action -5-
5.0 Summary of Site Characteristics -5-
6.0 Summary of Site Risks -7-
6.1 Chemicals of Potential Concern -7-
6.2 Exposure Assessment -7-
6.3 Toxicity Assessment -9-
7.0 Applicable or Relevant and Appropriate Requirements -11-
8.0 Description of Alternatives -12-
8.1 Alternative 1 - No Action -12-
8.2 Alternative 2 - Property Use Restriction -12-
8.3 Alternative 3 - Limited Excavation, Off-Site Disposal and Property Use
Restriction -13-
9.0 Summary of Comparative Analysis of Alternatives .... -13-
9.1 Overall Protection of Human Health and the Environment -13-
9.2 Compliance with Applicable or Relevant and Appropriate
Requirements -14-
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9.3 Long-Term Effectiveness and Permanence -14-
9.4 Reduction of Toxicrty, Mobility and Volume Through Treatment -14-
9.5 Short-Term Effectiveness -14-
9.6 Implementability -15-
9.7 Cost -15-
9.8 State Acceptance -16-
9.9 Community Acceptance -16-
10.0 The Selected Remedy -16-
11.0 Statutory Determination -17-
11.1 Protection of Human Health and the Environment -17-
11.2 Applicable or Relevant and Appropriate Requirements (ARARs) .... -17-
11.3 Cost-Effectiveness -17-
11.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable , -17-
12.0 Documentation of Significant Changes -18-
PART III - RESPONSIVENESS SUMMARY
1.0 Summary of Major Comments -19-
2.0 Response to Written Comments -19-
3.0 Response to Formal Verbal Comments Made During the Public Meeting
Held July 29, 1997 -22-
Figures
Figure 1 - Site Location Map
Figure 2 - Study Area Map
Figure 3 - Soil Excavation Area
Attachments
Attachment A - Written Public Comments
Attachment B - Reporter's Transcript: Verbal Comment from Public Meeting
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RECORD OF DECISION
Western Pacific Railroad Superfund Site
Orovilie, California
EPA ID# CAD980894679
PART I - DECLARATION
1.0 Statement of Basis and Purpose
This Record of Decision (ROD) presents the selected final remedial action at the
Western Pacific Railroad Superfund Site (the Site) in Orovilie, California. This
document was developed in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), 42 U.S.C. §§ 9601
et seq. and, to the extent practicable, in accordance with the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based on the Administrative Record for the Site.
The State of California Department of Toxic Substances Control, as the lead
' state agency, concurs with this remedy.
2.0 Assessment of the Site
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in the ROD, may present a
threat to public health, welfare, or the environment.
3.0 Description of the Rerpedy
The remedy the Environmental Protection Agency has selected for soil includes
excavation of approximately 2,000 tons of soil in the area with the highest levels of
contamination. The remedy also includes restrictions on the future use of the property.
This remedial action is the final action for the Site. This Record of Decision also selects
the aquifer cleanup standard for the site. The selected remedy includes:
excavation of the top 1 foot of soil in the most contaminated 1 acre;
disposal of contaminated soil off-site in compliance with the Off-Site Rule;
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institutional controls including but not limited to restricting the future use of the
site to industrial use only, and
extraction and treatment of contaminated groundwater.
4.0 Statutory Determinations
The selected remedy is protective of human health and the environment, and
complies with the 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 technologies to the maximum extent
practicable. However, because treatment of the low-level threats at 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, the five year review will apply
to this action.
/ 4--30-4-7
Keith Takata Date
Director, Superfund Division, EPA Region IX
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RECORD OF DECISION
Western Pacific Railroad Superfund Site
Oroville, California
EPA ID# CAD980894679
PART II - DECISION SUMMARY
1.0 Site Name. Location and Description
The Western Pacific Railroad Site is located at the south end of the City of
Oroville in Butte County, California. The railroad property covers approximately 90
acres and is bounded on the west by 5th Avenue, on the east by Baggett Marysville
Road, and on the south by 5th Way. The Union Pacific Railroad line runs north/south
through the property (see Figure 1).
Of the 90 acres owned by Union Pacific Railroad, approximately 37 were
evaluated by EPA for hazardous waste contamination based on historical site use. The
37-acre Study Area consists of two adjacent parcels at the east edge of the property
where the historical site operations occurred. These two parcels are the Fueling Area
and the Unfenced Site Area, approximately 10 and 27 acres, respectively (see Figure
2).
2.0 Site History and Enforcement
The Western Pacific Railroad Site was an active fueling and maintenance yard
from the 1880's until 1970. Activities included locomotive fueling, routine maintenance,
and railcar repair such as welding, painting, fabricating and machining of raHears. In
1970 Western Pacific Railroad (WPRR) ceased its maintenance and repair activities
and leased the Fueling Area to Solano Railcar Company (SRC), an independent railcar
firm. SRC's activities included sandblasting, painting, welding, and machining railcars
up until approximately 1991. WPRR and the subsequent owner of the property, Union
Pacific Railroad (UPRR), continued to use the fueling tracks and drip pans until 1991.
In 1991 UPRR dismantled the remaining structures in the Fueling Area. The Fueling
Area is currently inactive and surrounded by a fence. UPRR continues to run daily
trains on the main rail line.
The Western Pacific Railroad Site was initially investigated by the California
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Regional Water Quality Control Board (RWQCB) in the 1980's. In 1989 the RWQCB
issued an Order to UPRR to investigate an on-slte waste pond and the Site
groundwater. In 1989 the waste pond was excavated and backfilled with clean fill;
groundwater monitoring wells were installed in the fueling area; and a leaking
underground storage tank at the southeast edge of the Fueling Area was removed.
On August 30,1990, the Site was added to the National Priorities List. EPA sent
a General Notice letter of liability to UPRR on August 29,1991. On August 27,1993,
EPA issued an Action Memo selecting groundwater extraction and treatment to contain
contaminants of concern at the site. On August 27,1993, EPA and UPRR signed an
Administrative Order on Consent for Removal Action wherein UPRR agreed to
implement a pump and treat system consistent with the Action Memo. On November
29,1993, EPA sent UPRR a Special Notice letter asking UPRR to submit a good faith
offer to conduct the remedial investigation and feasibility study for the Site. EPA and
UPRR signed an Administrative Order on Consent on March 15,1994, wherein UPRR
agreed to conduct the remedial investigation and feasibility study.
In 1994, in compliance with the Removal Action Order, UPRR installed a system
to pump and treat groundwater contaminated with volatile organic compounds. The
source of these contaminants was the leaking underground storage tank in the Fueling
Area. The primary contaminant is 1,1-DCE, with 1,1,1-TCA, 1,1-DCA and TCE present
in lower concentrations. The system included one extraction well, an air stripper, and a
reinjection well. In 1997, a second extraction well with a soil vapor extraction unit was
installed in order to optimize the pump and treat system. The removal action currently
being implemented has substantially reduced the concentrations of constituents of
concern in the aquifer.
3.0 Highlights of Community Participation
EPA sent a fact sheet to the community in January 1994 announcing the
installation of the groundwater pump and treat system. This fact sheet also discussed
the future soil investigation at the Site. EPA released a second fact sheet in June 1997
to update the community on the groundwater cleanup and to inform the community of
the results of the soil Risk Assessment and Feasibility Study. The Proposed Plan and
the Administrative Record were released to the public in July 1997. These documents
were made available to the public at the Butte County Library in Oroville and at the EPA
Records Center in San Francisco. A public comment period was held from July 16,
1997 through August 15, 1997. In addition, a public meeting was held on July 29
1997.
A response to comments received during the public comment period is included
in the Responsiveness Summary, which is part of this Record of Decision.
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REFERENCE. USGS 75' Quadrangle; Palermo, CA. 1870
Quadrangle
Location
DAMES & MOORE
SITE LOCATION MAP
Draft Focused Feasibility Study Report
Western Pacific Railroad Superfund Site
Oroville, California
730S«vm 1/2/87
FIGURE 1
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4.0 Scope and Role of Response Action
This ROD addresses contaminated soils impacted by waste oil and other
maintenance wastes and selects the final aquifer cleanup standards. It is anticipated
that the groundwater cleanup standard will be achieved at the conclusion of the
removal activities.
The selected remedial action is for the surface soil in the Fueling Area and will
address the threat posed by polycyciic aromatic hydrocarbons (PAHs).
5.0 Summary of Site Characteristics
A remedial investigation (Rl) was conducted at the Western Pacific Railroad Site
by UPRR as required by the Administrative Order on Consent. Rl activities included
surface and subsurface soil sampling and surface water pathway investigation. Soil
samples were taken over a 37-acre area east of the train tracks (see Figure 2). This
study area is comprised of two parcels; the 10-acre "Fueling Area" and the 27-acre
"Unfenced Area". The Fueling Area is where the railyard fueling and maintenance
operations took place. Structures included a-roundhouse and turntable, above- and
below-ground storage tanks, below- and above-grade oil/water separators, fueling
tracks and drip pans. All of the structures have been dismantled, and the area is
currently inactive and surrounded by a fence. The Unfenced Area is presently
undeveloped and contains a former railroad turnaround track. Portions of the Unfenced
Area were used as a railroad Marshalling Yard and a lumber transfer station. No
maintenance activities occurred in the Unfenced Area.
The surrounding land use is a mixture of residential and light industrial. There
are residences directly across Baggett Marysville Road at the east and northeast
portions of the Site and several residences to the south of the Site. The Koppers
Superfund Site is approximately one mile southwest of the Site.
A public drinking water well owned by UPRR and leased to the California Water
Service (CWS) is located just west of the tracks. CWS has agreed to take the well out
of service until further notice by UPRR.
The regional surface water flow is west towards the Feather River, located
approximately one mile west of the Site. A series of drainage ditches and culverts
divert surface water runoff away from the Site.
During the remedial investigation the soils were analyzed for metals, polycyciic
aromatic hydrocarbons (PAHs), benzene, toluene, ethylene and xylene (BTEX). The
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results of the surface and near-surface (2.5 to 4.5 feet below ground surface) soil
sampling are shown in the following tables:
Chemical of Concern in Surface
Soil
Arsenic
Copper
Chromium
Lead
PAHs as benzo[A] pyrene equivalent (BAP)
Benzene *
Toluene *
Maximum
Concentration
73.20 mg/kg
822mg/kg
284 mg/kg
810 mg/kg
28.29 mg/kg
2.1 jzg/kg
9.3 A*g/kg
Mean
Concentration
(Exposure Point
Concentration)
16.08 mg/kg
183.26 mg/kg
74.31 mg/kg
198.20 mg/kg
1.90 mg/kg
Detected in one sample only
Chemical of Concern in Near-
Surface Soil (2.5 to 4.5 ft bgs)
Arsenic
Copper
Chromium
Lead
PAHs as benzo[A] pyrene equivalent (BAP)
BTEX
Maximum
Concentration
11.7mg/Kg
14.8 mg/Kg
68.5 mg/Kg
6.05 mg/Kg
.05 mg/Kg
no detections
Mean
Concentration
3.34 mg/Kg
12.86 mg/Kg
62.64 mg/Kg
4.94 mg/Kg
.025 mg/Kg
The investigation identified areas of PAH-contaminated soils in the area adjacent
to the waste oil separator. Groundwater monitoring wells in the area indicate that these
chemicals have not migrated down to the groundwater. (The ongoing groundwater
removal action is for the VOC plume from the former leaking underground storage tank
at the southeast edge of the Fueling Area).
Based on the results of the remedial investigation, EPA has determined that
there are no principal threat wastes at the Site. The contaminants at the Site are low
level threat wastes because of their low concentration and low mobility.
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6.0 Summary of Site Risks
The baseline risk assessment estimates what risks the Site poses if no action
were taken. It provides the basis for taking action and identifies contaminants and the
exposure pathways that need to be addressed by the remedial action. This section of
the ROD summarizes the results of the baseline risk assessment for this site. Union
Pacific Railroad prepared the risk assessment pursuant to the Administrative Order on
Consent. The risk assessment is contained in the Final Remedial Investigation and
Risk Assessment Report, Volume 1, Chapter 6, June 2,1997.
Human Health Risk
6.1 Chemicals of Potential Concern
The chemicals of potential concern in the soil are PAHs, petroleum hydrocarbons
as diesel, benzene, toluene, ethylbenzene, and xylene (BTEX), arsenic, chromium, and
lead. The chemicals of potential concern in the airborne dust are BTEX, PAHs and 1,1-
DCE.
6.2 Exposure Assessment
The current land use is industrial at the Site. The surrounding area is a mix of
industrial and residential. The Koppers Superfund Site is less than a mile to the south
of the Site. The future land use at the Site is assumed to be industrial. This is based
on zoning in the area, the current use of the Site as a major rail line, the intentions of
the owner; Union Pacific Railroad to continue to operate the rail line, and the
abundance of suitable residential property outside of the industrial area.
The risk assessment evaluated potential human health risks under both current
conditions and reasonable future conditions. The potentially exposed populations in the
current use scenario are on-site workers, trespassers and off-site residents. The
potentially exposed populations in the future use scenario are the same as for the
current use scenario. The risk assessment did not evaluate residential exposure. Risk
under a residential exposure scenario would be significantly higher.
Under the industrial use scenario, the potential exposure pathways are dermal
contact, ingestion, and inhalation of vapors and airborne dust particles. The exposure
duration was assumed to be 25 years, 250 days per year.
The risk assessment looked at three potential exposure pathways for the soil:
inhalation of contaminated airborne dust, ingestion of contaminated soil, and dermal
contact with contaminated soil. Exposure to contaminated groundwater was not
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evaluated in this risk assessment because groundwater monitoring indicates there is no
contamination in the Fueling Area other than the VOC plume, which is being cleaned up
pursuant to a removal AOC. The chemicals of concern in the Fueling Area soil, PAHs,
metals, and hydrocarbons, are relatively immobile. While there were a few detections
in the groundwater of the more mobile chemicals (i.e., benzene and toluene) four years
ago, there have been no detections of PAHs, hydrocarbons, and metals in the
groundwater.
The risk assessment also evaluated the risk to off-site residents who might be
exposed to vapors or chemicals carried off-site by airborne dust particles. The
exposure frequency was assumed to be 350 days per year and the exposure duration
was assumed to be 30 years, including 6 years during childhood.
The exposure pathways were quantified through the use of standard exposure
factors and scenarios as defined in the Human Health Evaluation Manual,
Supplemental Guidance: Standard Default Exposure Factors (OSWER Directive
9285.6-03, May 1991).
The following tables show the potential exposures and risk calculations for the
Site. The concentrations are calculated as the 95% upper confidence limit (UCL).
Off-Site Resident: Risk via Particulate Inhalation
Chemical of Concern
Benzo(a)pyrene
Arsenic
Copper
Chromium
Benzene
Toluene
Soil Concentration
5 mg/kg
25 mg/kg
278 mg/kg
129 mg/kg
.27 mg/kg
1.3 mg/kg
Hazard Quotient
NA
8.96 x 10-5
7.97 x 10*
1.37x10
NA
1.25x10-"
Cancer Risk
4.35 xKT8
7.5 x 10*
NA
NA
6.67x1 0'12
NA
Off-Site Resident: Risk via Vapor Inhalation
Chemical of Concern
Benzene
Toluene
Air Concentration
.04 Mg/m3
.08 ^g/m3
Hazard Quotient
NA
4.86 x ID"1
Cancer Risk
5.22 x10'7
NA
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On-Site Worker: Risk via Vapor Inhalation
Chemical of Concern
Benzene
Toluene
Air Concentration
.(M/^g/m3
.08pg/m3
Hazard Quotient
NA
1.49x10"
Cancer Risk
2.45 x10'7
NA
On-Site Worker: Total Risk via Particulate Inhalation,
Soil Ingestion and Dermal Contact
Chemical of Concern
B(A)P
Arsenic
Chromium
Copper
Benzene
Toluene
Soil Concentration
5mg/kg
20mg/kg
129 mg/kg
248mg/kg
.27 mg/kg
1.3 mg/kg
Hazard Quotient
NA
4.4 x10"2
7X10-5
3.6x10^
NA
6.84 x 10*
Cancer Risk
2.58x10's
8.53 x 10*
NA
NA
1.01 X10"8
NA
Lead hazard is determined by lead levels in the blood. The on-site soil
concentration calculated for the risk assessment is 298.0 pg/g. The calculated blood
lead level for on-site workers is 3.7/zg/dl (deciliter), which is well below the action level
of
6.3 Toxicity Assessment
The risk assessment evaluated potential carcinogenic and non-carcinogenic
risks to on-site workers, trespassers and off-site residents. Excess lifetime cancer risks
are determined by multiplying the intake level with the cancer potency factor. These
risks are probabilities that are generally expressed in scientific notation (e.g., IxlO"6).
An excess lifetime cancer risk of IxlO"6 indicates that as a plausible upper bound, an
individual has a one in a million chance of developing cancer as a result of site-related
exposure to a carcinogen over a 70-year lifetime under specific exposure conditions at
the Site.
The total cancer risk for off-site residents is less than IxlO*. The non-cancer
risk to off-site residents was determined by assessing the child resident's exposure to
vapor and airborne particulate from the Site. The child resident is considered to be the
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most sensitive member of the population. The sum of all hazard quotients for air
exposure for the child resident was less than 0.05. This represents a safe level of
potential exposure, since a hazard quotient of 1.0 or less is generally considered to be
protective of the most sensitive members of the population.
The total cancer risk associated with workers in the Fueling Area is 35 x 10"6.
The total cancer risk estimated for exposure in the Unfenced Site Area is 13 x 10*.
The non-cancer health risk for on-site workers was also determined for exposure to site
soil. The sum of all hazard quotients for soil exposure was less than 0.1 for both the
Fueling Area and the Unfenced Site Area.
Although the risks under an industrial use scenario are within EPA's acceptable
risk range, there is uncertainty regarding the long-term future land use at the site. EPA
is taking action to ensure that the land use at the site does not result in exposure
outside the risk range.
The current PAH levels preclude residential use of the property without
remediation. The Region 9 Preliminary Remediation Goal (residential scenario) for the
most toxic PAH, benzo(a)pyrene is 0.06 mg/kg. At the site the B(a)P levels detected in
three composite surface samples from the most contaminated area are 20,14 and 8.4
mg/kg.
Ecological Risks
The chemicals of concern and the media of concern were the same for the
ecological risk as for the human health risk. The Site is located near the boundary of
the Sacramento Valley and the Sierra Nevada foothills.
The primary habitat found on the Site is non-native grassland. The Fueling Area
is highly disturbed with large areas of unvegetated concrete, gravel and weedy patches.
In the Unfenced Area, a few foothill pines and other species associated with the Foothill
Woodland plant community occur in a small portion of this area. The remainder of this
area is dominated by non-native grasses and other weedy species.
Animals observed during site visits include jackrabbit, turkey vulture, western
meadowlark and California ground squirrel. Other species that could be expected to
occur include American crow, scrub jay, deer mouse, western fence lizard, and
southern alligator lizard. No sensitive habitats or wildlife species were found on-site.
The Fueling Area lacks any habitat suitable for environmental receptors,
because there are no completed pathways of exposure between potential points of
contact and environmental receptors of concern.
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The Unfenced Area generally contains low quality wildlife habitat and very few
wildlife species. The very low levels of contamination in this area do not pose a threat
to plants and wildlife.
7.0 Applicable or Relevant and Appropriate Requirements
The following federal regulations have been determined to be applicable
requirements at the Western Pacific Railroad Site:
Clean Air Act 40 CFR 61: National Emission Standards for Hazardous Air
Pollutants. Identifies and establishes emission standards for specific chemicals.
Resource Conservation and Recovery Act f RCRA) Chapter 11. §66261 et seq.:
Regulations that apply to remedial action involving treatment, storage, or
disposal of sites with contaminants that include arsenic and chromium.
RCRA Chapter 13. §66263 et ssq.: Standards Applicable to Generators of
Hazardous Waste. Requires appropriate disposal of RCRA wastes transported
off-site.
RCRA Chapter 18. §66268 et seq.: Land Disposal Restrictions. Wastes are to
be reviewed to determine if they should be restricted from land disposal.
The following State of California regulations have been determined to be
applicable requirements at the Western Pacific Railroad Site:
California Air Resources Act. Health & Safety Code. Div.26 §39000 et seq.:
Regulates both nonvehicular and vehicular sources of air contaminants in
California. Emission from heavy equipment and excavation dusts will need to
comply with local Air Pollution Control District standards.
Hazardous Substances Account Act (CA "Superfund" LawV H & S Code. Div. 20.
Chapter 6.8. S25300 etseq.: Establishes state authority to clean up hazardous
substance releases.
Title 22 CCR. Div. 4.5 Chapter 11. §66261 et seq.: Identification and listing of
hazardous waste.
State Water Board Resolution 68-16: This applies to the reinjection of treated
water into the aquifer. Extracted water should be treated to non-detect prior to
reinjection into the aquifer.
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State Water Board Resolution 92-49. Paragraph III. G: EPA has determined that
the federal and more stringent State MCLs will satisfy the requirements of 92-49.
8.0 Description of Alternatives
Four remedial alternatives, including a no action alternative, were considered for
the soil at the Site. Three of the four alternatives are presented here. The fourth
alternative, Alternative 4, a large scale excavation, was screened out because the cost
was excessive (over $1,000,000) for the low levels of contamination present at the Site.
8. j Alternative 1 - No Action
Alternative 1 provides no means of controlling on-site exposure to residual
contaminants nor does it provide a means to ensure the future use of the property
remains industrial. This alternative is not protective of human health.
There are no capital or operation and maintenance costs associated with this
alternative.
8.2 Alternative 2 - Property Use Restriction
This alternative consists primarily of institutional controls. These controls would
provide notice and restrict use of the land at the Site to industrial uses. The controls
would be established by an effective and implementable mechanism such as (1) land
use restrictions per California State Code; (2) an enforceable component of a bilateral
agreement between UPRR and a regulatory agency; or (3) deed restrictions as part of a
property conveyance. Site access controls would continue to include a fence and
warning signs. Regular inspections of the Site would be required in the future to ensure
the land use remains industrial.
The direct capital cost for Alternative 2 is $0 because the fence and warning
signs are currently in place. Indirect (administrative) capital costs associated with
implementation of the land restriction agreement between EPA and UPRR is estimated
to be $10,000 total. Operation and maintenance costs for this alternative are
approximately $5,000 per year. The total 30-year present worth value of the Alternative
2 institutional controls is $76,000.
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83 Alternative 3 - Limited Fveavatton Off^fr* Disposal and Property Use Restriction
The objective of this alternative is to reduce potential exposure to carcinogenic
PAHs (measured as B(a)P equivalent) in the soil, such that the total excess cancer risk
for on-stte workers is approximately 1.1x10'5 or less. This would be achieved by
removing the top one foot of soil with the highest B(a)P concentrations in the Fueling
Area and reducing the residual mean soil concentration for B(a)P to 0.41 mg/Kg or less.
The area to be excavated is approximately 1 acre and is shown on Figure 3.
Contaminated soil would be transported off-site by UPRR railcars and disposed of in a
permitted facility in compliance with EPA's Off-Site Rule. The excavation area would be
backfilled with clean fill. This alternative also includes the property use restrictions
described in Alternative 2.
The field time estimated to implement the excavation portion of this alternative is
less than one month. EPA and UPRR expect to have institutional controls in place
within six months of the Record of Decision.
Costs were developed for a 30-year operating period. The direct capital cost for
the Limited Excavation and Off-Site Disposal is approximately $179,000. Indirect
capital (administrative) costs associated with implementing this alternative are expected
to be $122,000. Annual operation and maintenance costs are estimated to be $500 per
year. The total 30-year present worth value of Alternative 3 is estimated to be
$307,000.
9.0 Summary of Comparative Analysis of Alternatives
The purpose of this section is to present a comparative analysis of the
alternatives that were developed to remediate the soil. The comparative analysis is
made based on nine criteria. This section is organized by evaluation criteria. The
extent to which each of the three alternatives satisfies the criteria will be compared and
contrasted.
9.1 Overall Protection of Human Health and the Environment
Alternative 3 provides the most protection because contaminants are removed
from the Site, toxicity and volume of the contaminated soil is reduced, and risk is
lowered. Institutional controls will protect human health in the future by limiting property
use to industrial use only. Alternative 2, Property Restrictions, while adequately
protecting human health and the environment, is less protective because contaminant
levels are not reduced and the risk level is not lowered. Alternative 1. No Action,
provides adequate protection of human health and the environment under the current
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industrial use. However, it provides no controls to ensure the future use remains
industrial and not residential.
9.2 Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 2 complies with all ARARs and allows flexibility to provide additional
controls for dust emissions as appropriate. Alternative 3 also complies with ARARs,
including those that pertain to the removal and disposal of contaminated soil. Although
Alternative 1 meets the ARARs, it leaves the contamination in place and offers no
monitoring to ensure that air emissions and groundwater standards are met.
9.3 Long-Term Effectiveness and Permanence
Alternative 3 includes a permanent reduction in waste through off-site disposal at
the Site so it provides better long-term effectiveness than Alternatives 1 and 2.
Alternative 2 is less effective than Alternative 3 because it relies solely on institutional
controls, and does not include the excavation of contaminated soil which will reduce
human exposure to contamination. No long-term effectiveness is accomplished with
Alternative 1 because no controls would be in place to restrict future use of the Site to
industrial use only.
9 4 Reduction of Toxicitv. Mobility and Volume Through Treatment
None of the alternatives reduces the toxicity, mobility or volume of the soil
contaminated with PAHs through treatment. However, Alternative 3 will reduce the
toxicity. mobility and volume of PAH-contaminated soil at the Site because the soil will
be removed and transported off-site. This alternative is the only one that reduces
toxicity. mobility and volume of the contaminated soil.
95 Short-Term Effectiveness
Alternative 1 is effective in the short-term because Union Pacific Railroad, the
current property owner, has no plans to change the current site use, and the current
concentrations of hazardous substances in the soil are at EPA's acceptable risk levels.
Alternative 2 is equally effective in the short-term as Alternative 1.
Alternative 3 might have a slightly greater short-term risk to on-srte workers and
nearby residents than Alternatives 1 and 2 due to the potential for dispersion of
contaminants during excavation and transportation of contaminated soil. However, the
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BAGGETT MARYSVILLE RD,
150
i
Scale In Feet
EXPLANATION
IW-1
•$• 90-02 Monitoring Well
^- EW-1 Extraction WeB
-$• IW-1 Injection Well
x x— Fenced Area
90-01
(SB-17)
Limits of Soil Removal
Area
90-05
DAMES & MOORE
SOL EXCAVATION AREA
Western Pacific Railroad Super fund Site
Orovile, Cafifornla
00173-08V7505-044 mt| B75O3J 9/25/97
FIGURE 3
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actual excavation and backfilling is expected to take one week and effective measures
can be taken to minimize any potential exposure to contaminants.
9.6 Implementability
All three alternatives are implementable. Alternative 1 requires no
implementation. Alternative 2 involves primarily administrative tasks. Due to UPRR's
willingness to cooperate with EPA to restrict future property use, the coordination and
negotiation required for this alternative are feasible.
The technologies, materials, and services associated with the excavation,
backfilling and off-site disposal as required by Alternative 3 are readily available. The
administrative requirements of the institutional control portion of the remedy are similar
to those of Alternative 2.
9.7 Cost
There are no costs associated with Alternative 1. Costs associated with
Alternative 2 for a 30-year time period are estimated to be $76,000. The 30-year
present worth value for Alternative 3 is estimated to be $307,600, including the property
use restriction costs associated with this alternative.
Western Pacific Railroad Feasibility Study
Alternatives Cost Summary
Alternative 1
Alternative 2
Alternative 3
Description
No Action
Property
Restrictions
Excavation and
Property
Restrictions
Capital
Costs
$0
$10,000
$301,000
Annual
O&M Costs
$0
$5,000
$500
Present
Worth
$0
$76,388
$307,600
Note: Costs shown in the table are based on a 30-year period of operation.
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9.8 State Acceptance
The California Department of Toxic Substances Control, as the lead State
agency, concurs with this remedy. The Regional Water Quality Control Board also
concurs with this remedy.
9.9 Community Acceptance
Comments made by the only community speaker at the public meeting
questioned whether the proposed remedy, Alternative 3, was protective of human
health and the environment. Comments in writing also questioned the protectiveness of
the proposed remedy. The preference of commenters was for more soil to be
excavated. The public uniformly favored excavation.
10.0 The Selected Remedy
The selected alternative for the soil is Alternative 3, excavation and institutional
controls. This is because it is the most protective of human health and the
environment, is the most effective in the long-term, and is cost-effective.
The major components of this remedy are:
excavation of the top 1 foot of soil in the most contaminated 1 acre, and reducing
the residual mean soil concentration for B(a)P to 0.41 mg/Kg or less.
disposal of contaminated soil off-site in compliance with the Off-Site Rule, and
institutional controls including but not limited to restricting the future use of the
site to industrial use only .
The objective of this remedy is to reduce the risk to on-site workers at the Site
and to reduce future potential exposure to carcinogenic PAHs by prohibiting residential
use of the property. The clean-up standard for the PAH-contaminated soil is a residual
mean soil concentration for B(a)P of .41 mg/Kg or less. This will reduce the cancer risk
from exposure to this contaminant to workers to approximately 1x10'5.
The selected remedy for groundwater is extraction and treatment through air
stripping. The final aquifer cleanup standards are the federal and more stringent State
MCLsfoM,1-DCE, 1.1,1-TCA, 1,1-DCA, and TCE. If TPH as diesel is detected above
the current detection limit of .50 ppb in the treated groundwater, granular activated
carbon will be utilized.
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11.0 Statutory Determination
The selected remedy is protective of human health and the environment,
complies with applicable or relevant and appropriate requirements, and is cost-effective.
This remedy utilizes permanent solutions, to the maximum extent practicable. It does
not satisfy the statutory preference for treatment as a principal element because the
cost of treating the contaminated soil is excessive for the threat posed by the site.
A five-year review, pursuant to Section 121(c) of CERCLA, 42 U.S.C. §9621(c),
will be conducted at least once every five years after the initiation of the remedial action
to ensure the remedy provides adequate protection of human health and the
environment.
11.1 Protection of Human Health and the EnvirQnment
The selected remedy is protective of human health and the environment. The
objective of the remedy is to reduce contamination in the Site soil and lower cancer risk
so human health is protected. It provides for excavation of the most contaminated soil
as well as institutional controls for long-term protection from residual contamination.
11.2 Applicable or Relevant and Appropriate Requirements fARARs)
The selected remedy will comply with the identified applicable or relevant and
appropriate requirements. These ARARs include federal and state environmental and
public health regulations.
11.3 Cost-Effectiveness
The selected remedy is the most effective means of reducing contamination and
risk proportionate to its cost.
11.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected remedy provides for a permanent solution, and does not rely solely
on institutional controls to protect human health and the environment. The remedy
does not utilize alternative treatment technologies due to the high cost of such
treatments.
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12.0 Documentation of Significant Changes
The proposed plan for the Western Pacific Railroad Site was released for public
comment in July 1997. The proposed plan identifies Alternative 3, excavation and
institutional controls, as the preferred alternative. EPA reviewed all written and verbal
comments submitted during the public comment period. Upon review of these
comments, it was determined that no changes to the remedy, as it was originally
identified in the proposed plan, were necessary.
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RECORD OF DECISION
Western Pacific Railroad Superfund Site
Oroville, California
EPA ID# CAD980894679
PART ill - Responsiveness Summary
1.0 Summary of Major Comments
Most public comments were made by residential neighbors who have cancer and
question whether the selected remedy is protective of human health and the
environment. Residents' primary concern is that contaminated dust will blow across the
street and into their homes and yards.
2.0 Response to Written Comments
1. Letter from John Purcell, dated July 3Qf 1997 (Reference No. 1. Attachment A)
The letter includes comments on PAHs, arsenic, lead, diesel exhaust and cancer.
EPA's Response: EPA appreciates the concerns in this comment regarding the
polycyclic aromatic hydrocarbons (PAHs) in the soil and the threat the soil at the site
poses to human health. It is true that PAHs are carcinogenic (cause cancer). PAHs can
enter the body through the lungs, through dermal (skin) contact and by swallowing
food or dust particles that contain PAHs. PAHs are formed by the burning of oil, gas
and other organic substances. Commons sources are fuel burning engines, wood
burning stoves, cigarette smoke, creosote-treated wood and charcoal-broiled foods.
Using conservative assumptions about how long and how frequently people might be
exposed to contamination in the soil, EPA estimated the risk (or likelihood) of
increased cancer occurrence. The estimated "excess cancer risk" is described as the
increase in probability of developing cancer during one's lifetime compared to the
background probability of developing cancer (i.e., if no exposure to site contaminants
occurred). The background probability in California is approximately one in three
chances, or 330,000 in a million, of getting cancer from all other causes.
EPA uses a "target risk range" of 100 in one million to one in one million (10^ to 10*)
to manage risks as part of a Superfund cleanup. Risks that fall within or below this
range are acceptable, and therefore, generally do not warrant remedial action. Risks
greater than 100 in one million (10"*) generally warrant remedial action.
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If EPA calculates a one in a million (10*) excess cancer nsk from a given exposure, that
means if one million persons are exposed to the contaminant at a certain level over
their lifetime, then one cancer above the background chance, or the 330,001st cancer,
may appear in those million people from a particular exposure. To take into account
the uncertainties in the science, the risk numbers calculated are based on conservative
assumptions. In actuality, the risk is probably somewhat lower than calculated, and in
fact, may be zero.
Results from the Western Pacific Railroad Risk Assessment indicate current total
cancer risk from the Site to off-site residents is slightly less than 10*. In other words,
slightly less than one exposed person out of 1 million could get cancer from
contamination at the Site, based on our estimates. This risk to residents is well below
EPA's unacceptable risk level of 100 in one million.
Extensive sampling of both the soil at the Site and of the vapors emitted from the soil
show that the current level of PAHs at the Site is low and the health risk the soil poses
falls within EPA's acceptable risk range. The soil near the fence along Baggett
Marysville Road has lower levels of contamination than the soil near the former oil-
water separator. This indicates that the greater the distance from the oil-water
separator, the lower the levels of PAHs.
EPA believes that the selected remedy of removing the top one foot of contaminated
soil will be just as effective at protecting human health as a remedy that removes soil to
a greater depth. Human health and the environment are being protected from any
future potential exposure to contamination from the Site.
The commenter also expresses concern about arsenic and lead from paint chips. While
there are low levels of arsenic and lead in the soil, it is the PAHs that are present in
higher levels and pose a greater threat to human health at the Site. However, the
baseline risk assessment calculates total cancer risk from the Site and the numbers cited
below include the risk from PAHs, arsenic and other chemicals.
The commenter expresses concern about the threat to human health from the exhaust
of the engines that sit and idle along the rail line. EPA's risk assessment looked at risk
from releases from historical operations. It did not evaluate risk associated with
current operations such as exhaust from Union Pacific's train engines. EPA
acknowledges the health threat from the burning of diesel fuel. Current laws passed by
Congress prevent restrictions on emissions from mobile sources such as trains and
airplanes. Under EPA's new proposed air standards, there will be additional
requirements to limit the amount of particulates that can be released into the air.
However, the proposed standard applies only to new and remanufactured locomotives
and does not apply to existing locomotives.
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2. Comment from Linda Purcell dated July 30, 1997 (Reference No. 2. Attachment A)
Letter includes comments on threats to human health, high lead blood levels, and
cancer.
EPA's Response: EPA appreciates these concerns regarding the long-term effectiveness
and protectiveness of the selected remedy. The reader is referred to EPA's response to
written comment No. 1. The commenter also expresses concern about drinking the
water in her home. She does not indicate whether the water is from a private well on
her property or from public supply lines. The groundwater at the Site is sampled on a
regular basis. There is a plume of contaminated groundwater that is contained and will
not spread any further than its current boundaries. A system is in place to pump and
treat the contaminated groundwater. The groundwater in the Baggett Marysville Road
area flows to the southwest, away from the residences. In July 1997, a private drinking
water well of a residence on Baggett Marysville Road just south of the Site was sampled
and no contamination was detected in the water. No contamination from the Site has
ever been known to impact groundwater to the east of Baggett Marysville Road.
The commenter states that children in the neighborhood have high lead levels.
Because the levels of lead in soils at the Site are relatively low, it is unlikely that the
Site would be a source of high blood levels in the neighborhood children. The
commenter also states that people have cancer in 4 out of 5 homes in the
neighborhood. EPA has contacted the Butte County Public Health Office and will
discuss this issue further with that office.
3. Comment from Florence N. Jones dated July 31. 1997 (Ref. No. 3. Attachment A)
Letter includes comments on contaminated soil.
EPA's Response: The reader is referred to EPA's response to written comment No. 1.
The commenter also suggests that Union Pacific Railroad buy the homes and
properties east of Baggett Marysville Road. The contamination levels decrease away
from the oil-water separator and rail lines and the levels at the east edge of the property
along Baggett Marysville Road are quite low and well within EPA's risk range. For
the risk that the Site poses, EPA believes it is unnecessary for Union Pacific Railroad
to purchase the homes and property to the east of Baggett Marysville Road.
4. Comment frojn Kimberly Cook, undated (Ref. No. 4. Attachment A)
Letter includes comments on people in the neighborhood with cancer.
EPA's Response: EPA understands the commenter's concern about the Site's potential
threat to human health. The reader is referred to EPA's response to written comments
Numbers 1 and 2. The remedy EPA selects here will reduce cancer threats posed by
-21-
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the site, both through excavation and long-term institutional controls.
5. Letter from Valerie McGaha dated August 14r 1997 (Ref. No. 5. Attachment A)
Letter includes comment on cancer in the family.
EPA's Response: While EPA believes that the Site currently poses an acceptable level
of risk to off-site residents, EPA believes that removing contaminated soil will lower
the risk even more and be even more protective of human health and the environment.
3.0 Response to Formal Verbal Comments Made During the Public Meeting Held
July 29. 1997
1. CPmments from speaker John Purcell (Attachment B)
EPA's Response: The comments are largely the same as the written comment
submitted by Mr. Purcell. EPA shares Mr. Purcell's concerns about the effectiveness
and protectiveness of the remedy. EPA has selected the remedy because it is protective
of human health and the environment.
Mr. Purcell stated that he and neighbors have cancer. Although EPA is not in a
position to respond as to causes of specific cases of cancer, the remedy EPA selects
here, both contaminated soil excavation and removal and long-term use restrictions,
will reduce any cancer threat posed by the site.
Mr. Purcell also commented that a neighborhood boy suffered from cracked hands
after playing at the Site. EPA notes that a fence now surrounds the Fueling Area
preventing access to the Site. The clean dirt that will replace the excavated soil will
further limit exposure to contamination at the Site.
Lastly, signs will be posted on the fence in the Fueling Area warning people of the
hazardous waste at the Site.
-22-
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ATTACHMENT
A
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REFERENCE NO. 1
may submit this form and any additional written comments at today's
meeting or you may fold and seal this form and send it to the address on the back.
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Comments must be postmarked no later lhan AUGUST 13. 1997
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You may submit this form and any additional written comments at today's
meeting or you may fold and seal this form and send it to the address on the back.
Please Sign and Date:
Comments must be postmarked no l-atsr than AUGUST 15, 1997
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REFERENCE NO. 2
You may submit tiiis form and an/ additional written comments ST today's
meeting or you may fold and seal this form and send it to the address on the back.
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REFERENCE NO. 3
You may submit this form and any additional written comments at today's
meeting or you may fold and seal this form and send it to the address on the back.
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REFERENCE NO. 4
Holly Hadlock
Remedial Project Manager
U.S. E.P.A.
Re: Mercury Register
Cancer in rail yard area
Holly, I read this article and it really concerned me. i live off
of Monte Vista, and I was diagnoised with Cancer in Aug. 1995 at
the age of 29. I've lived at this address for 13 years. There have
been 4 people that I know on my street with cancer in ths past 5
or 7 years, and I dont know very many of my neighbors. This
concerns me. I would like to know what kind of surveys have
been done? How do you know if the soil has been contained to
that area? Are we getting cancer from the chemicals around L-S?
! have children, am I endangering their lives by living ;n irss
area? Please send me the information that you have stiair:c-:
and iook into this situation a iiltls fisher. ! i:iir.:< tr ;s irs;, c : :
bigger problem than you may realize, i knsv; ^he Copper piar.l
had an explosion a few y^ars back, tnat ;-.2£ always irssd-e me
wonder even though they said it was nothing to worry about i
think that people try tc cover up a ,ot of things. We also had a
tornado that went through our neighborhood. You can't *e-=i n"1-?
contairninated sol! can't be Diov/r ihrc'jgr the a'.r. I hc^e th?*
you are a sincere person and not one of those people ths: t:i; -•:•
i i-. 11 i « n _ j. c. i _:. ,• «....; . j :_i j i —:. w 11 c! C 0 i C, . Q 01 (_• j- \ i\( v/ i_ / \. i CJ L . •. >...
a young age, -:iie otr;ar inree neighbors were in their 30'sv.on2 of
them is dead. Thank you for taking the time to read my latter, i
am looking forward xo heari^q from vou.
Ver-' Cc'icerr«><
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REFERENCE NO. 5
August 14, 1997
Holly Hadlock
Remedial Project Manager, U.S. EPA
Mailcode SFD-7-1
75 Hawthorne St.
San Francisco CA 94105
re: Western Pacific Railroad Superfund Site
Dear Ms. Hadlock:
In 1977, my brother, Michael Denton Wilson, was
diagnosed with Non-Hodgkins Lymphoma at age 14.
Our family resided at 4715 Lincoln Blvd., Oroville,
California.
Upon his diagnosis, he was referred to Stanford Medical
Center in Palo Alto for treatment. Throughout his
treatment, he underwent excruciating and exhausting
testing, surgery, chemotherapy and extensive radiation
therapy. He became blind and paralyzed and was
essentially bed-ridden until his death in 1979.
Our family suffered greatly during his illness, not
only from astronomical medical and travel expenses, but
especially from the great tragedy of his suffering and
eventual death at age 17. He was such and intelligent
and artistic young man.
If this cleanup project could save one life and prevent
one family the hardship and grief my family endured,
progress will have been made.
Sincerely,
. --
Valerie McGaha
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ATTACHMENT
B
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
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19
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25
-000-
In Re: Western Pacific Railroad )
Superfund Site )
-oOo-
Palermo, California, Tuesday, July 29, 1997
-oOo-
REPORTER'S TRANSCRIPT
-oOo-
Reporter by:
Lesley E. Kay, C.S.R.
Certificate No. 6847
EMERALD DEPOSITION REPORTERS, Yuba City, CA (916) 751-3885
1
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1 microphone over to Jackie and the reporter is taking
2 this down. EPA will respond to them.
3 Thank you.
4 MS. LANE: Does anybody want to have a comment?
5 MR. PURCELL: Hello, everybody. I am John
6 Purcell. I live on Marysville Baggett Road straight
7 across the street from the cleanup site. There are
8 residents that now live there. Some of us have lived
9 there, probably, seven, eight, years. I've lived there,
10 probably, seven, eight, years. During that period of
11 time, I got lung cancer. They told me I'll probably die
12 April of next year. I tried to talk to people at the
13 Oroville Health Department and so on and it's kind of
14 like, "Thank you". They pass it on.
15 Now, do I say throw a rock? The railroad is
16 pretty big. The people next to me -- my friends -- he
17 had lung cancer. He had his lung taken out long ago.
18 He's doing radiation because he has tumors in his
19 brain. His son Brian went across the street, before
20 they put the fence up. It took him 45 minutes and his
21 hands were cracked to the bone and bleeding. The man
22 next door has prostate cancer. I come to find out
23 yesterday that the person on the corner has throat
24 cancer. I found out a while ago that the people from,
25 maybe, a couple of houses up, they went out to the
EMERALD DEPOSITION REPORTERS, Yuba City, CA (916) 751-3885
14
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1 University of California Davis to have their lungs also
2 operated on.
3 I smoked a lot of marijuana. I smoked a lot of
4 cigarettes in my life. The doctors tell me, "John, you
5 didn't get it from smoking marijuana. You didn't get it
6 from smoking tobacco. You got it from an airborne bug
7 that came from somewhere. What are you exposed to?" I
8 tried to tell everybody I am exposed to the dust that
9 blows from the dirt. How can they keep a fence -- put a
10 fence up to keep the dust where it sits? Bring your
11 fingers through my dust. Analyze my dust. See if it
12 does have the things it does have.
13 You people at the railroad are slowly killing the
14 people at Marysville Baggett Road. They're doing great
15 deals for covering up things but they don't look at the
16 people in the neighborhood. They don't look at the
17 children that play in the water that comes draining off
18 the fuel to go play with the pollywogs. They don't look
19 at their cracked hands. How do I say it? It is on
20 record at the hospital, that little boy's hands. The
21 water runoff into the ditches where the kids play, I can
22 see rainbows in the water. If I call up the people from
23 the environmental control they'll come out and they put
24 people in white suits and they clean it up but still the
25 children play in that water. They put a fence around
EMERALD DEPOSITION REPORTERS, Yuba City, CA (916) 751-3885
15
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1 that property. It doesn't have one sign telling anybody
2 to keep out of that area.
3 I don't know what to tell you people but I know
4 there's human lives. There are residents that live
5 there. We are trapped between two railroad tracks, the
6 one on Lincoln and the one further out. There's a
7 housing district there that must get blown dust from the
8 wind.
9 That's all I have to say.
10 Thank you.
11 MS. LANE: Thank you.
12 Are there any more comments?
13 (No response.)
14 MS. LANE: If there's no more comments or any
15 further comments, I'm going to close the meeting at this
16 time. But, if, in the future, between now and in August
17 15th, you have something further you'd like to talk to
18 us, don't hesitate to call us or write us so we can
19 include it in the Summary.
20 Thank you, again, for coming out tonight and
21 taking the time to let us know what's happening in your
22 community.
23 -oOo-
24 (Whereupon, the proceedings were concluded at the
25 hour of 7:45 p.m.)
EMERALD DEPOSITION REPORTERS, Yuba City, CA (916) 751-3885
16
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