PB97-964509
EPA/541/R-97/131
January 1998
EPA Superfund
Record of Decision:
Del Amo Facility Waste Pits OU
Los Angeles, CA
9/5/1997
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
RECORD. OF DECISION
Del Amo Waste Pits Operatic Unit
Del AJTIO Facility Proposed Superruna Site
Los Angeles, CA
SFUND RECORDS CTR
0639-01335
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TABLE OF CONTENTS
PART I - DECLARATION page 2
1.1- Site Name and Location 2
1.2 - Statement of Basis and Purpose 2
1.3 - Assessment of the Site 2
1.4 - Description of the Selected Remedy 2
1.5 - Statutory Determinations 3
1.6 - Signature 3
PART II - DECISION SUMMARY page 4
2.1- Name, Location, Description 4
2.2 - Site History and Enforcement Actions 6
2.3 - Highlights of Community Participation 9
2.4 - Scope and Role of OU or Response Action 11
2.5 - Summary of Site Characteristics 12
2.6 - Summary of Site Risks 16
2.7 - Description of Alternatives 21
2.8 - Summary of Comparative Analysis
of Alternatives 26
2.9 - The Selected Remedy 37
2.10- Statutory Determinations 47
2.11- Documentation of Significant Changes 49
PART III - ARARs Attachment A
PART IV - RESPONSE SUMMARY Attachment B
FIGURES
Figure 1 - Location Map page 5
Figure 2 - Waste Pits Area 7
Figure 3 - Extent of Cap 22
TABLES
Table 1 - Chemicals of Concern at Waste
Pits Area page 13
Table 2 - Toxicity Criteria for Chemicals
of Potential Concern 18
Table 3 - Maximum Risks 20
Table 4 - Cost Estimates 33
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I. DECLARATION
1.1 Site Name and Location
Proposed Del Amo Superfund Site
Los Angeles, CA
1.2 Statement of Basis and Purpose
This decision document presents the selected remedial action for the Del Amo Waste Pits
Operable Unit (Waste Pits OU) of the Proposed Del Amo Superfund Site (Del Amo Site), in Los
Angeles, California, chosen 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) and, to the extent practicable, the National
Contingency Plan (NCP). This decision is based on the Administrative Record.
The State of California concurs with the selected remedy.
1.3 Assessment of the Site
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
1.4 Description of the Selected Remedy
The remedy selected in this ROD for the Del Amo Waste Pits Operable Unit is the first of
three planned RODs for the Del Amo Site. This ROD addresses the waste, soil and subsurface
gas contaminated by hazardous substances within the 4-acre Waste Pits Area of the Del Amo
Site (see Figure 1). This ROD selects a final remedy for the Waste Pits Area addressing potential
human exposures to waste pit contaminants at or near the ground surface. This ROD also selects
an interim groundwater remedy for the Waste Pits Area by selecting measures to prevent
continued migration of hazardous substances from the waste pits or surrounding soil to the
groundwater. The Waste Pits Area is one of many sources of groundwater contamination at the
overall Del Amo Site.
The remedy selected in this ROD addresses the principal threat remaining at the Waste
Pits Area by selecting actions that will prevent future releases of hazardous substances from the
remaining waste materials present in the waste pits, either upward to the surface, downward into
the groundwater, or laterally out from the pits, that would create unacceptable risks to public
health or welfare or the environment. The ROD also selects measures intended to prevent
additional contamination of groundwater beneath the Waste Pits Area by selecting response
actions to clean-up hazardous substance contamination that had been previously released from
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the waste pits and is currently present in the vadose zone soils.
The major components of the selected remedy for this action include:
- Placement of a RCRA-equivalent cap over the Waste Pits Area as described in this
ROD and associated soil gas monitoring;
- Installation of surface water controls to prevent ponding of water on the cap and to
prevent runoff onto adjacent properties;
- Installation and operation of a soil vapor extraction system (SVE) beneath the Waste
Pits Area to achieve the interim soil remediation standards established in this ROD;
- Installation of security fencing around the treatment units associated with the cap and
SVE systems;
- Implementation of deed restrictions prohibiting future residential use of the Waste Pit
Area and prohibiting any future use of the Waste Pits Area that could threaten the
integrity of the RCRA equivalent cap;
- Long-term operation and maintenance of all of the above and related components of
the remedy selected in this ROD.
1.5 Statutory Determinations
The selected remedy is protective of human health and the environment, complies with
federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum extent practicable. Components
of the selected final remedy satisfy the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining on-Site above health-
based levels, a review will be conducted at least once every five years after commencement of
the remedial action to ensure that the remedy continues to provide adequate protection of public
health or welfare or the environment.
1.6 Sinature
A- Taiax-!^ ^-5-3 "7
Keith A. Takata, Director DATE
Super-fund Division
U.S. Environmental Protection Agency, Region IX
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II. DECISION SUMMARY
2.1 Name, Location. Description
The proposed Del Amo Superfund Site (Del Amo Site) is located in the city of Los
Angeles, California. (See Location Map - Figure 1). It is located in a section of the city known
as the Harbor Gateway, a narrow appendage of the city approximately a half mile wide that
extends from the main body of the city south to the coast near Long Beach, CA. The Site sits
approximately 6 miles south of the main body of the city and 10 miles north of the Pacific Coast.
To date, EPA's investigation of the Site has focused on the 280 acres formerly occupied by a
synthetic rubber manufacturing operation and on the associated groundwater contamination. The
subject of this ROD is the Waste Pits Area, a 4-acre portion of the Site that sits at the southern
boundary of the area formerly occupied by the synthetic rubber manufacturing operation. The
Waste Pits Area consists of two parcels: Lot 36 and Lot 37, as identified on the Los Angeles
County Assessor's Map Number 7351-034 Northwest.
The proposed Del Amo Site sits adjacent to the junction of Interstate Highways 405 (the
San Diego Freeway) and 110 (the Harbor Freeway). The City of Los Angeles appendage, within
which sits the Site, and the adjacent unincorporated areas, are sandwiched between the cities of
Torrance to the west and Carson to the east. The area that was once occupied by the synthetic
rubber manufacturing operation is bounded by 190th St. on the north, Del Amo Blvd. on the
south, roughly Normandie Ave. on the west, and Interstate 110 on the east.
The Waste Pits Area encompasses approximately 4 acres and sits adjacent to the southern
Site boundary of the area once occupied by synthetic rubber manufacturing operation. The
Waste Pits Area is bounded by industrial and commercial development on the north and Del
Amo Boulevard with adjacent residences on the south. Electrical power transmission easements
run along the Waste Pits Area's northern and southern boundaries, and two major underground
petroleum and chemical pipeline corridors run along it's southern boundary. The adjacent area
south of the Waste Pits Area is a residential community, within the jurisdiction of unincorporated
Los Angeles County.
Today, the area formerly occupied by the synthetic rubber manufacturing operation is
mostly being used for light industrial and commercial purposes, including food processing, light
manufacturing, and warehousing. There are a few vacant parcels that have not been redeveloped,
including the Waste Pits Area. The adjacent lands to the north are also used for light industrial
and commercial purposes, as are the lands on the west (which include several aircraft
manufacturing facilities and active chemical plants). The land adjacent to the Site on the east is a
freeway, and the adjacent lands on the south are residential. Del Amo Boulevard separates the
Waste Pits Area from residents' backyards. The fronts of these residences are on 204th St.
To the west, the Montrose Chemical Corporation of California manufactured the pesticide
DDT from 1947 until 1982 at 20201 Normandie Avenue. The Montrose plant property and areas
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impacted by releases from that property, the Montrose Chemical Corporation Superfund Site,
were added to the Superfund National Priorities List in 1989.
The land upon which the Del Amo Site sits is a relatively flat alluvial plain. Underlying
the Site are alluvial deposits of sands, silts, and clays that extend down hundreds of feet. These
deposits contain four distinct and separate aquifers, the third and fourth (deepest) of which are
used for municipal drinking water. There are no surface water resources at the Site.
To date, no man-made structures from the original synthetic rubber manufacturing
operations have been discovered with the exception of the waste pits and ponds in the Waste Pits
Area. The Waste Pits Area contains the most concentrated sources of waste materials generated
by the synthetic rubber operations, as well as other related hazardous substance contamination.
The Waste Pits Area, a series of six former waste disposal pits and four former evaporation
ponds, had been covered or filled with soil at various points in the past.
FORMER
COPOLYMER
PLANT
LOCATION MAP
DEL AMO STUDY AREA
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2.2 Site History and Enforcement Actions
From 1943 until 1972, a synthetic rubber manufacturing operation, consisting of three
separate plants, covered 280 acres at the Site. Built to produce synthetic rubber during World
War II, the 280-acre operation, from 1942 until 1955, consisted of a styrene plant operated by
Dow Chemical Co., a butadiene plant operated by Shell Oil Co., and a synthetic rubber
(copolymer) plant operated by U.S. Rubber Co., Goodyear Tire & Rubber Co., and others.
During this period, the United States owned all three plants, which were operated by the above-
noted companies under agreements with the United States. In 1955, the United States sold all
three plants to Shell Oil Company and Shell continued to operate these plants until 1971.
Synthetic rubber was produced by manufacturing styrene and butadiene separately,
piping them to the rubber plant, and then chemically synthesizing the two into synthetic rubber.
(See Figure 1 - Location Map). Raw materials and finished products were stored primarily in
aboveground tanks. Some feedstock chemicals, particularly benzene, were delivered via
underground pipeline from off-site sources. The styrene plant consisted of approximately 106
acres. The primary feedstocks for styrene manufacture were propane and crude benzene. Other
chemicals used or produced in the process include toluene, ethylbenzene, styrene, caustic,
hydrochloric acid, and sulfuric acid. The butadiene plant consisted of approximately 90 acres.
Butadiene is a gas at standard temperature and pressure. Butadiene feedstock including a
mixture of butane, butylene, and butadiene, were received primarily by pipeline. The
copolymer plant occupied approximately 82 acres. Synthetic rubber was produced in a series
of reactions by combining styrene and butadiene with lesser amounts of other chemicals
including soap solutions and acid solutions.
Within each plant, wastes from the production processes were directed into separator
units. Settled sludge from the separator units was disposed of either off-site or in a waste
disposal area located on-Site. Waste disposal impoundments were located on two parcels (the
Waste Pits Area) covering a total of approximately 4 acres at the southern boundary of the
styrene plant, including four evaporation ponds (referred to as pits 1-A through 1-C and the
eastern evaporation pond) and six waste pits (referred to as pits 2-A through 2-F). The 1-
series evaporation ponds received aqueous waste, and the 2-series pits received semi-viscous to
viscous wastes. All of the pits and ponds were unlined. (See Figure 2 - Waste Pits Area). The
2-series pits received an aluminum chloride complex, containing a large amount of
hydrocarbons. The 2-series pits also received heavy impurities and tars, including sulfur tars
from the styrene purification process. The four 1-series evaporation ponds received a variety of
materials, including acid sludge (a by-product of the treatment of benzene and sulfuric acid),
kaolin clay (used to dehydrate alcohol and produce ethylene) and lime slurry (a by-product of a
zeolite softening system). The evaporation ponds also received the heavy hydrocarbons that had
settled at the bottom of the water skimmers in the styrene plant.
Upon closure of the three plants by Shell Oil Company in 1972, the unlined pits and
ponds that were still open were covered with soil and surrounded by a double row of chain link
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FIGURE 2
WASTE PIT AREA
DEL AMO PITS
WASTE PIT
tc
WASTE PfT
IB
prr ,.A
(EXCAVATED)
EASTERN
EVAPORABON
PONO
DEL AMO ALLEY
nnnnnDD dMnDiiDDDDDoDorf
an
Du
D
DEL AMO BOULEVARD
a WEST 204TH STREET
~lg I I? I
i i
i
D
AVENUE
nfl
fence. In 1972, Shell sold the facility and the property to a development company and the three
plants were dismantled. Most of the 280-acre area once occupied by the synthetic rubber
manufacturing operation has since been redeveloped as an industrial park.
In 1983, the California Department of Toxic Substances Control (DTSC) began
investigating waste disposal areas within the Waste Pits Area. In 1984, contamination was
discovered in the waste pits area and underlying soils. From 1985 until 1991, Dow Chemical
Company, Shell Oil Company and G.P. Holdings conducted RI/FS activities for Lot 36 under
a Memorandum of Agreement and subsequently under an Administrative Order with the
California Department of Toxic Substance Control (DTSC). In 1991, DTSC issued a Notice
of Non-Compliance and terminated the Administrative Order.
In July 1991, EPA proposed the Del Amo Site be added to EPA's National Priorities List
(NPL). Shortly after that, DTSC turned over regulatory responsibility for the Site to EPA. In
June 1996, EPA re-proposed the Site with updated technical information.
On May 7, 1992, EPA, DTSC, and two potentially responsible parties, the Shell Oil
Company and the Dow Chemical Company, entered into a Administrative Order on Consent
(U.S. EPA Docket No. 92-13) agreeing to perform an remedial investigation and feasibility
study for the Site. In addition, Dow and Shell agreed to perform an accelerated RI/FS for the
Waste Pits Area. The purpose of these activities was to determine the nature and extent of
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contamination at the Site and to determine feasible remediation options for the Site.
On July 15, 1994, EPA issued a Unilateral Administrative Order to the Shell Oil
Company following the discovery of small areas or seeps of exposed waste at Pits 2-B and 2-A.
The Order requires Shell to conduct regular inspection and maintenance of the Waste Pit Area
and in particular, to detect and cover or remove exposed waste material.
The focused RI/FS for the Waste Pits Area is contained in two documents - the Waste
Excavation Feasibility Study (WEFS) and the Focused Feasibility Study (FFS). Information
and analysis meeting Superftind requirements for a remedial investigation and baseline risk
assessment are contained in the FFSC Chapter 2 and Chapter 3, respectively, and related
appendices. On November 30, 1994, EPA issued a Notice of Tentative Disapproval to the
PRPs for the Waste Excavation Feasibility Study and the Focused Feasibility Study (FFS) for
the Waste Pits Area. These documents were unacceptable due to their "overall poor quality,
inaccurate or inappropriate assumptions, and inaccurate and unfounded conclusions." EPA
required the PRPs to make significant revisions to the reports. In July 1995, EPA issued a
Notice of Disapproval of the Waste Excavation FS on the grounds that it significantly failed to
adequately address EPA comments. EPA then prepared a Waste Excavation Feasibility Study,
which the PRPs incorporated into a revised FFS. EPA finally approved the revised Focused
Feasibility Study Report for the Waste Pits Area in December, 1996.
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2.3 Highlights of Community Participation
This ROD (including the Response Summary) presents the selected remedial action for
the proposed Del Amo Site Waste Pit Operable Unit. The remedial action is chosen in
accordance with CERCLA, as amended by SARA, and to the extent practicable, in accordance
with the National Contingency Plan. The decision for the Waste Pit Operable Unit is based on
the Administrative Record established for this action.
On December 16, 1996, EPA issued the Proposed Plan for the Del Amo Waste Pit
Operable Unit, and sought public comments on the Proposed Plan. On that date, a copy of the
Administrative Record for the Proposed Plan, which included the Focused Feasibility Study
and the Waste Excavation Feasibility Study, was placed in the local repositories near the Del
Amo Site - the Torrance Public Library and the Carson Public Library. EPA established a 60-
day period for the public to provide comments on the plan. During the comment period, EPA
held a public meeting at the Torrance Cultural Arts Center, in Torrance, CA, to discuss the
Proposed Plan with the public and receive public comments. The public comment period
ended on February 13, 1997. The Proposed Plan and the subsequent invitation to the public
meeting were both mailed to the entire Site mailing list, which includes approximately 1800
residents and other concerned citizens. In addition, the issuance of the Proposed Plan and the
location and date of the Proposed Plan Public Meeting were advertised in the local newspaper,
the Torrance Daily Breeze. In response to the comments EPA received from the public, EPA
prepared a Response Summary, which is part of this ROD.
EPA has conducted frequent public meetings since March 1994, approximately every two
to three months, to present and discuss information and issues concerning both the proposed Del
Amo Site and the adjacent Montrose Chemical Corporation NPL Superfund Site. Since assuming
the lead for the Del Amo Site from the State of California in 1991, EPA has issued 22 Fact
Sheets explaining the results of the RI sampling, the neighborhood sampling, the Site history, the
Superfund process, and other matters. In addition, EPA held a community workshop to describe
potential remedial alternatives in February 1996, upon initial development of draft remedial
alternatives in the Focused Feasibility Study for the Waste Pits Area.
EPA made particular efforts to inform and communicate with the community regarding
sampling conducted by EPA in residential areas adjacent to the southern boundary of the Waste
Pits Area. In October 1993 and February 1994, EPA conducted soil sampling in residential lots
adjacent to the Waste Pits Area and other residential lots adjacent to the southern boundary of the
property formerly occupied by the Styrene Plant. The results of this sampling found
contaminants associated with the Del Amo Site but at levels that did not pose an unacceptable
risk to human health. EPA provided these sampling results, by letter, to owners and occupants of
the properties sampled by EPA. EPA also discussed these results in a community meeting held
on March 22, 1995 at Halldale School Auditorium near the site.
In the summer of 1994, EPA conducted air monitoring at the Waste Pits Area and
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indoor/outdoor air monitoring at residential lots adjacent to the Waste Pits Area. These sampling
results and the results of other sampling including soil, indoor dust and drinking water sampling,
were presented in public meetings, held on May 24, 1995, and subsequent dates, at Residence
Inn, Torrance. These results also did not find contaminants associated with the Waste Pits Area
or the Del Amo Site at unacceptable levels. These sampling results were provided, via
correspondence from EPA, to occupants and owners of the parcels sampled.
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2.4 Scope and Role of OU or Response Action
This ROD is for the Waste Pits Area at the proposed Del Amo Site, the first of three
planned remedial decisions for the Site. An "operable unit" is a portion of a Site for which EPA
selects a remedial action separately from the other operable units or the overall Site. Operable
units can be defined by distinct physical areas of a Site, contaminated medium (e.g. ground water
vs. soils), or contaminants (e.g. metals vs. solvents). For the proposed Del Amo Site, EPA has
broken RI/FS activities into three components: the Waste Pits Area, groundwater, and the
remainder of the proposed Del Amo Site (primarily soil contamination). EPA's management
approach to groundwater and other Del Amo Site RI/FS investigations may be changed at EPA's
discretion.
Because the Waste Pits Area was the largest and most concentrated known source of
hazardous substance contamination at the proposed Del Amo Site, and because of its close
proximity to residences, EPA decided it was appropriate to accelerate the schedule for the Waste
Pits Operable Unit RI/FS.
This Record of Decision for the Waste Pits Operable Unit is a final remedial decision for
the Waste Pits area, addressing the potential for human exposure to hazardous substances on or
near the ground surface of the two lots (Lot 36 and Lot 37) that make up the Waste Pits Area.
However, this ROD is an interim remedial decision for groundwater by addressing the potential
for migration of hazardous substances at the Waste Pits area from the waste material, soil or to
groundwater. This ROD is an interim remedial decision for groundwater because the actions
selected in this ROD pertain only to the Waste Pits area as a groundwater contaminant source.
There are other areas that are sources of groundwater contamination at the Del Amo Site in
addition to the Waste Pits Area. Generally, EPA selects interim actions which are anticipated to
be consistent with a final remedy. The groundwater operable unit ROD will select final remedial
actions, if any, for the Site-wide groundwater contamination. In so doing, the groundwater
operable unit ROD may include adjustments to groundwater-related decisions made in this ROD.
This ROD does not make any remedial decision concerning the groundwater beneath the Waste
Pits Area or any other area of the proposed Del Amo Site.
A decision concerning remedial actions, if any, to address groundwater contamination
will likely be the next remedial decision made by EPA for the proposed Del Amo Site.
Groundwater contamination at the Site (including known human carcinogens) appears to exhibit
the potential to spread and to reach aquifers being used for drinking water unless response
activities are taken. Any principal threats associated with the groundwater will be identified in
the studies, remedial plans and selections for the groundwater operable unit. The third and final
EPA ROD will address the remainder of the proposed Del Amo Site other than the waste pits and
groundwater, principally soil contamination. Any principal threats associated with soils in the
rest of the Del Amo facility will be identified in the studies, remedial plans and selections for the
operable unit covering the remainder of the Del Amo Site.
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2.5 Summary of Site Characteristics
The Waste Pits Area consists of four former evaporation ponds and six former disposal
pits on two lots (Lots 36 and 37 of the Los Angeles County Assessors Map Number 7351-034
Northwest). See Figure 2. The former evaporation ponds have been designated as "Pits 1 A,
IB, 1C," and the "Eastern Evaporation Pond." The former disposal pits have been designated
as "Pits 2A, 2B, 2C, 2D, 2E, and 2F." All of the series 2 Pits and Pits IB and 1C are located
on Lot 36, which is owned by a subsidiary of Shell Oil Company, Triton Diagnostics.
Currently, Lot 36 of the Waste Pits Area is a vacant lot, surrounded by a double row of chain-
link fencing and covered by soil fill and weeds. An earthen mound approximately 15 feet high
is present over the western portion of the area. Pursuant to a unilateral administrative order,
Shell Oil Company conducts regular inspections of Lot 36 as well as regular fence
maintenance and weed mowing. Pit 1-A and the Eastern Evaporation Pond are located on Lot
37 which is owned by Western Waste Industries. Lot 37 is also currently a vacant lot covered
by soil fill and vegetation and surrounded by a double row chain-link fence.
The waste material in the pits contains two main types of hazardous substances that are
of concern: semi-volatile organic compounds (SVOCs) and volatile organic compounds
(VOCs) (see Table 1). Soil beneath and adjacent to the waste material is also contaminated
with SVOCs and VOCs. Benzene, a VOC and known human carcinogen, is the most
frequently found hazardous substance and is present in the highest concentration of all VOCs
found in the waste, the soil, and the groundwater of the Waste Pits Area. The SVOCs found
most often and in the highest concentration in both the waste and soil of all Polycyclic
aromatic hydrocarbons (PAHs) is naphthalene. Naphthalene is not classified as a human
carcinogen, but it can cause a number of adverse health effects in humans resulting from acute
or chronic exposure, including cataracts, dermatitis, and anemia. Concentrations of metals
detected in the waste pits were below PRGs (preliminary remediation goals) except for arsenic.
Arsenic was detected at a concentration of 25 mg/kg, which exceeds arsenic's PRO of 2.4
mg/kg. This is consistent with background levels of arsenic in California soils, which
typically have such elevated concentrations. Hydrogen sulfide (H2S) was also found, with the
maximum emission rate being from the 2-series pits, 2-C, 2-D and 2-F, at 11,060 mg/m2/min,
upon disturbance.
The waste material in pits IB and 1C (former evaporation ponds) is covered with 2-4
feet of soil fill, and the waste extends down an average of 9 feet. The waste material in the 2-
series pits (former disposal pits 2A - 2F) is covered with 3-15 feet of soil fill, and the waste
extends down 21 to 32 feet. The estimated volume of the waste material itself is 15,600 yd3,
and the estimated volume of very heavily contaminated soil adjacent to the waste material is
17,100 yd3. Beneath several of the pits, contaminated soil extends down to the water table, a
depth of approximately 60 feet. The lateral extent of the contaminated soil is roughly confined
within the inner fence that surrounds the pits. The estimated volume of these farther reaches
of contaminated soil surrounding the pits is 300,000 yd3.
The groundwater beneath the pits is heavily laden with hazardous substances from both
the waste pits as well as other upgradient sources. The predominant contaminants present in
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the groundwater beneath and immediately downgradient of the pits are: benzene, ranging from
12,000 ppb to 470,000 ppb and averaging 171,000 ppb in the monitoring wells as of the late
1996 sampling round, ethylbenzene ranging from less than 100 ppb to 15,000 ppb and
averaging 4,200 ppb, and phenol, ranging from 29 ppb to 440 ppb and averaging 180 ppb in
the same monitoring round. The data shows a sharp rise in groundwater contaminant
concentrations in the immediate vicinity of the Waste Pits Area, as compared to the monitoring
wells further upgradient. This is indicative of the Waste Pits Area being a source of
groundwater contamination. If the Waste Pits were not a source, the groundwater contaminant
concentrations from upgradient sources would decline as the water moved downgradient.
Thus, the data clearly indicates that contaminants from the waste pits are migrating to and
causing significant contamination of the underlying groundwater. The data also shows there is
contamination in the soil underlying the waste pits. Contamination has migrated through the
waste pits and into the vadose zone.
TABLE 1 - Chemicals of Concern at Waste Pits Area
(parts per million, ppm)
Chemical
Total Semi-volatile
Organic Compounds
Total Volatile
Organic Compounds
1-Series Pits
1,000 ppm -
38,000 ppm
126 ppm -
4,600 ppm
2-Series Pits
22 ppm -
30,200 ppm
2,300 ppm -
117,000 ppm
Soil Below
1 ppm-
10, 199 ppm
ND*-
42,640 ppm
Soil Adjacent
ND*-
1,393 ppm
ND*-
10,400 ppm
*Not Detected
Pit 1-A was excavated in the mid-1980's and soil contamination data was collected
beneath the excavation floor before the excavation was backfilled with clean soil. The
excavation was 6 feet deep at the eastern end, 25 feet deep at the western end, and covered the
areal extent of Pit 1-A. Contaminant concentrations in the soil beneath the floor of the
excavation ranged from nondetect to 16,000 ppm for naphthalene and from nondetect to
13,000 ppm for phenanthrene. It is believed that, similar to other pits, contamination in the
soil beneath Pit 1-A extends to the water table.
Based on the analytical results from soil borings reported in the FFS, EPA has
concluded that the Eastern Evaporation Pond does not contain soil contamination at
unacceptable levels. Therefore given available information, EPA in this record of decision is
determining that no remedial action at the Eastern Evaporation Pond is warranted at this time.
The exposure pathways of concern for the Waste Pits Area are groundwater exposure
and surface exposure. The possibility of volatile contaminants migrating to nearby homes and
causing exposure to residents was investigated, but EPA found it not to be an exposure
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pathway of concern. The ground water beneath the Waste Pits is heavily laden with
contaminants from the pits, as shown by the high contaminant levels found in the groundwater
investigations. To investigate potential surface exposures, air emission tests were conducted
above the waste and adjacent contaminated soil. Results indicated that all the pits contain
waste that is capable of emitting significant levels of VOCs into the ah- if disturbed (i.e.
excavated). The 2-series pits are capable of emitting significant levels of hydrogen sulfide
(H2S) gas if the waste conies into contact with air. Emissions of benzene and H2S gas into the
atmosphere are of greatest concern due to adverse health effects that could result from
exposure.
Emissions were measured during a "downhole flux monitoring" investigation, the
results of which are summarized in a report entitled "Data Summary Report, Measurement of
Emissions Rates and Specifications of Vapor Phase Contaminants from Disturbed Waste,"
prepared by Dames & Moore, dated April 30,1996. This investigation found VOC emissions
including benzene, toluene, ethylbenzene and styrene. Benzene was found at a maximum
concentration of 24,000 mg/kg at 35 ft bgs (below ground surface) and ethylbenzene at a
maximum concentration of 18,000 mg/kg, also at 35 ft bgs. VOC concentrations were less in
1-B and 1-C then in the 2-Series pits. SVOCs detected in the pits included anthracene,
chrysene, fluorene and naphthalene. Hydrocarbon emissions were higher in the 2-Series pits
(104 -105 /ig/nWmin) than the 1-B and 1-C pits (10s -106 /ig/m2/min). Hydrogen sulfide (H2S)
was found, with the maximum emission rate being from the 2-series pits, 2-C, 2-D and 2-F, at
11,060 mg/m2/min. Non-methane hydrocarbons were found at a maximum concentration of
50,000 ppmv (parts per million volume).
Soil gas and air monitoring were also conducted in the vicinity of the pits and
fenceline, the results of which are summarized in "Final Report, Ambient Air, Surface Flux,
and Soil Gas Characterization" prepared by CH2M Hill, dated January 26, 1996. The ambient
air monitoring detected benzene in the range of 0.57 - 3.2 ppbv, which is within background
concentration ranges. Soil gas testing found benzene (maximum concentration 35 ppbv),
toluene (51 ppbv), 1,2 xylene (43 ppbv), and styrene (3.1 ppbv). These concentrations do not
result in indoor concentrations above PRGs in adjacent residential properties. Surface Flux
testing revealed a maximum benzene concentration of 180 ppbv, a maximum styrene
concentration of 9.3 ppbv, and a maximum hydrogen sulfide concentration of 9 ppbv. This
value is within the range of background ambient air concentrations.
The backyard soil samples from residences on 204th street are summarized in a
memorandum from Tom Dunkelman, then Project Manager for the EPA, dated December 3,
1993. The results showed that arsenic, total chromium and benzo pyrene were all below
PRG's. DDT was the only contaminant that was found in concentrations above the PRGs,
which is attributed to the Montrose Site.
Residential indoor and outdoor air monitoring was summarized in the report entitled
"Final Report, Residential Indoor Air Characterization Study, West 204th Street Temporary
14
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Relocation Zone" prepared by CH2M Hill, dated March 16, 1996. Benzene was found above
its PRO of 7.0 ppbv at two residences. In the first residence, 1051 204th St, the concentration
was 11.6 ppbv; upon additional testing, however, benzene was found to be below its PRO.
The original value was thought to be from a gas line leak. At the second residence, 1063
204th St., benzene was found at a concentration of 8.7 ppbv. Household cleaning products
were removed and additional testing was performed where benzene was found to be below its
PRO. The backyard air sampling found the ambient air to be within background
concentrations.
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2.6 Summary of Site Risks
To determine the potential health risks resulting from contamination at hazardous waste
Sites, EPA conducts risk assessments. An EPA risk assessment estimates the potential adverse
effects on human health from potential exposure to Site chemicals using Site data and a
theoretical model. To do this, the risk assessment must first assume how the area and its
surroundings are to be used, determine who might be affected by the Site, and ascertain the
pathway by which they may be affected. The risk assessment must then utilize Site data to
determine which chemicals people may be exposed to and at what concentrations, and then
select assumptions for the frequency and duration of the exposure. Finally, health information
about each chemical is combined with all the other data and assumptions mentioned, to
calculate the risk. Conservative assumptions as well as limitations to both our knowledge and
the risk calculations must be recognized when drawing conclusions and utilizing these
calculations to make'remedial decisions.
As stated in Chapter 3 of the FFS, the waste pits baseline risk assessment (risk
assessment) assumed that the future use of the Waste Pits Area would remain consistent with
current uses, and that the current conditions of the Waste Pits Area would remain in the
future. These assumptions include the Waste Pits Area being surrounded by a double row of
chain-link fence, soil fill covering the waste, and the area being routinely inspected and
maintained. The risk assessment also assumed that the people most affected by any hazardous
substance releases from the Waste Pits Area would be residents located at the fence line on the
south side of the pits, office workers located at the northern fence line, and a maintenance
worker on the waste pits Site itself. Finally, it assumed that the existing controls described
above would prevent direct contact with waste and contaminated soil, and therefore, the only
pathway by which people could be exposed to the chemicals at or near the ground surface
would be from inhaling chemical vapors.
The risk assessment did not quantitatively evaluate potential future exposures that might
occur if conditions at the Waste Pits Area were to change (e.g., if the soil fill cover over the
waste were allowed to erode,). If those conditions should change, exposures and resultant
risks to humans at or in the vicinity of the Waste Pits Area would likely be substantially higher
and at unacceptable levels.
The risk assessment also did not quantitatively evaluate risks associated with
contaminated groundwater. Because this ROD selects an interim, not final action for
groundwater, potential risks associated with groundwater will be assessed separately and
presented at the time EPA issues its proposed remedial plan for groundwater at the Del Amo
Site. While groundwater risks are not included in the risk assessment that is presented in the
FFS, it should be noted that it is unlikely that any persons would be exposed to vapors from the
pits and the groundwater contaminated by the pits at the same time. EPA believes that these two
types of risk can be considered independently.
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The risk assessment evaluated current and future risks in order to provide a basis for
cleanup decisions contained in this ROD. The risk assessment did not evaluate past exposures to
hazardous substances that may have been released from the Waste Pits Area in the past nor does
the risk assessment evaluate the possible health effects that could arise from those exposures, if
they existed.
The risk assessment was performed utilizing Site data from soil gas and "flux chamber"
sampling of the waste material and adjacent soil at the Waste Pits Area. All contaminants
detected in these sampling events were then evaluated by the risk assessment (see Table 2 for the
contaminant list). To define the contaminant concentrations to which residents, office workers,
and maintenance workers would be exposed under various scenarios, the flux chamber data were
used as input to an air dispersion model. The model calculated the hypothetical contaminant
concentrations at the fence lines surrounding the pits, where it was assumed the office workers
and residents would be located.
The reasonable maximum exposures were calculated using conservative assumptions.
These included: (1) assuming that the emissions emanate from both the waste and the
surrounding soil; (2) assuming that all of the area of waste pits emit at the maximum emission
rate ever measured at any point on the pits; (3) assuming that the soil adjacent to the pits emits at
the same rate as the pits; and (4) assuming that the exposed populations are working or living
directly at the fence line. An air dispersion model was used to assist in making these evaluations.
It was assumed that the maintenance workers would be present at the Waste Pits Area. The risk
assessment assumed that the neighboring residents live at the fence line 24 hours/day, 350
days/year, for 30 years, and that the office workers are working at the fence line 10 hours/day, 5
days/week, for 25 years. The assessment compared Site maintenance workers' potential
exposure to the OSHA Permissible Exposure Limits (PELs) for the workplace because they
would be expected to work at the Waste Pits Area only periodically.
EPA uses two different indicators that describe a chemical's potential health effects: the
"carcinogenic effects" and the "non-carcinogenic effects." To calculate carcinogenic effects, the
risk assessment began with "cancer potency factors" (CPFs). The cancer potency factors for the
chemicals of concern for the waste pits are shown in Table 2. Cancer potency factors have been
developed by EPA's Carcinogenic Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals. CPFs, which are expressed in
units of (mg/kg-day)'1, are multiplied by the estimated intake of a potential carcinogen, in mg/kg-
day, to provide an upper-bound estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects the conservative estimate of the
risks calculated from the CPF. Use of this approach makes under-estimation of the actual cancer
risk highly unlikely. Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied.
Excess lifetime cancer risks were then determined by multiplying the chemical intake
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level with the cancer potency factor. These risks are probabilities that are generally expressed in
scientific notation (e.g., IxlO"6 or 1E-6). An excess lifetime cancer risk of IxlO"6 indicated that,
as a plausible upper bound, an individual has an extra one in one million chance of developing
cancer as a result of Site-related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions at a Site.
Non-carcinogenic effects are calculated using factors called "Reference doses" (RfDs).
The Reference doses for the chemicals of concern for the waste pits are shown in Table 2.
Reference doses have been developed by EPA for indicating the potential for adverse health
effects from exposure to chemicals exhibiting non-carcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of maximum quantities to which someone,
including sensitive individuals, can be exposed for a long period of time without appreciable risk
of harmful effects. Estimated intakes of chemicals from environmental media (e.g., the amount
of a chemical ingested from contaminated drinking water) can be compared to the RfD. RfDs are
derived from human epidemiological studies or animal studies to which uncertainty factors have
been applied (e.g., to account for the use of animal data to predict effects on humans). These
uncertainty factors help ensure that RfDs will not underestimate the potential for adverse non-
carcinogenic effects to occur.
TABLE 2
TOXICITY CRITERIA FOR CHEMICALS OF POTENTIAL CONCERN
j" Chemicals
of
Potential Concern ,
3enzene
sec-Butylbenzene
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
Ethylbenzene
Hydrogen sulfide
Isopropylbenzene
Isopropyltoluene
Methylene chloride
Napthalene
Phenanthrene
n-Propylbenzene
Styrene
Tetrachloroethene
Toluene
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
(Xylene (mixed)
Cancer
Classification
A
nd
D
C
D
nd
nd
nd
B2
D
nd
nd
nd
nd
D
nd
nd
D
Oral Ingestion
Slope Factor
(kg-d/mg}_
0.029
0.024
0.0075
0.052
!
Reference Dose
(mg/kg-d)
0.0017
0.01
0.09
0.23
0.10
0.003
0.04
0.20
0.06
0.04
0.04
0.04
0.20
0.01
0.20
0.05
0.05
2.00
Inhalation
Slope Factor
Jkg-d/mgL
0.029
0.024
0.0016
0.002
Reference Dose
(mg/kg-d)
0.0017
0.01
0.057
0.23
0.29
0.00029
0.0026
0.11
0.86
0.04
0.04
0.0026
0.29
0.01
0.11
0.05
0.05
0.20 |
Cancer Classification:
A = human carcinogen; 81 = probable human carcinogen, limited human data;
B2 = probable human carcinogen (sufficient evidence in animals, inadequate or no evidence in humans);
C = possible human carcinogen; D = not classifiable as to human carcinogenicity;
nd = no data.
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Potential concern for non-carcinogenic effects of a single contaminant in a single medium
is expressed as the Hazard Quotient ("HQ," the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's reference dose). By adding
the HQs for all contaminants within a medium or across all media to which a given population
may reasonably by exposed, the Hazard Index (HI) can be generated. The HI provides a useful
reference point for gauging the potential significance of multiple contaminant exposures within a
single medium or across media. A Hazard Index of 1 or greater indicates the potential for
adverse health effects from exposure to the chemicals at the given concentrations and exposure
durations.
For surface emission exposures, the risk assessment results show that the maximum
cumulative risk to the residents is 2x10"* (2 in one million lifetime chance of death by cancer),
the maximum cumulative risk to the office worker is 3xlO'7 (3 in ten million lifetime chance of
death by cancer), and the maintenance worker's exposure is always below the OSHA Permissible
Exposure Limit. When evaluating non-cancer effects, the risk assessment found that the Hazard
Index for all the contaminants in all the exposure scenarios is less than 1, indicating that persons
would not be exposed to waste pits contaminants above levels of concern.
Based on the assumptions described above, the results of the waste pits risk assessment
indicate that contaminants do not currently pose an unacceptable threat to human health for
persons living or working at the ground surface at or near the pits, provided that the physical
conditions and emissions rates from the pits stay as they are today, (see Table 3). However,
while surface risks under current conditions are acceptable, there remains nonetheless a
significant possibility that a release of hazardous substances could occur that would result in an
unacceptable risk. Specifically, if the waste pits were disturbed, significant emissions of volatile
contaminants, particularly hydrogen sulfide, could be released, which could pose a significant
and unacceptable risk to the public. There is substantial uncertainty regarding the reliability of
the risk assessment assumption that the existing conditions (i.e. fencing) is adequate to prevent
human intrusions into the Site and potential human incursions into the waste itself. Any future
development activities which include trenching or excavations for structures, pipeline or utilities
would result in disturbance of the soil and waste materials resulting in the release of hazardous
substance. Such human incursions could result from digging since the 1-series pits are only
covered with 2-4 feet of soil. Finally, natural incursions could take place that would expose
waste material to the surface, such as acute erosion from large storm events (the 1 -series pits are
only covered with 2-4 feet of soil). Emissions testing of disturbed waste, conducted in 1974 and
1992, indicate that upon disturbance, the waste material can emit volatile contaminants at
concentrations as high as 11,060 mg/m2/min hydrogen sulfide, 68,000 mg/m2/min benzene and
1000 mg/m2/min styrene. Acute exposure to these contaminants can cause irritation, dizziness,
suffocation, and even death.
EPA's policy on utilizing baseline risk assessments in making risk management and
remediation decisions is set out in OSWER Directive 9355.0-30, dated April 22, 1991. This
policy states, in part, that the criterion of a baseline risk from Site conditions sufficient to warrant
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remedial action can be met where Maximum Contaminant Levels (MCLs) are exceeded in
groundwater at the Site. The groundwater beneath the waste pits Site contains contaminant
concentrations in excess of MCLs as a direct result of uncontrolled migration of waste pits
contamination into the groundwater. The FFS states, in Chapter 4, that "When material was first
deposited in the waste pits ... it is likely that there was some amount of free liquid (e.g. aqueous
phase contamination) which migrated downward through the soil until it reached groundwater."
Consistent with EPA policy, this exceedance of MCLs in groundwater beneath the pits supports
the need for remedial action. In this ROD, the major remedial actions selected by EPA will
result in protection of groundwater. The RCRA-equivalent cap will prevent surface water
infiltration into the Waste Pits Area which could otherwise act to carry hazardous substances,
present in the waste material or vadose zone, down into the groundwater. The SVE system will
act to protect groundwater by removing hazardous substances that are present in the vadose zone
at the Waste Pits Area or that may be released into the vadose zone in the future from the waste
materials. All groundwater under the pits is classified as a potential future drinking water source
by the State of California.
Given these uncertainties and potential risks, EPA has determined that actual or
threatened releases of hazardous substances from this Site, if not addressed by implementing the
response actions selected in this ROD, may present an imminent and substantial endangerment to
public health, welfare, or the environment.
An assessment of ecological risks was performed when the State of California was the
lead agency for the Site. That assessment concluded that no plant species listed as rare and
endangered or sensitive were observed at the Site or in the immediate Site vicinity. EPA is
adopting these conclusions and relying on them for the purposes of this ROD.
TABLE 3
MAXIMUM RISKS
Exposed Population
Residents
Office Workers
Maintenance Workers
Cumulative
Cancer Risk
2x10e-6
3x10e-7
Cumulative
Non-Cancer
Hazard Index
0.4 (children)
0.04 (adults)
Percentage of Workplace
PEL * Exposed to
0.09% (Benzene)
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2.7 Description of Alternatives
The alternatives considered by EPA as possible cleanup options for contaminated waste
and soil at the Waste Pits Area are described below.
ALTERNATIVE 1: NO ACTION
Under this alternative, no action would be taken at the Waste Pits Area. No
remediation or monitoring of contaminated media would occur, and no access or deed
restrictions would be implemented. This alternative satisfies the NCP requirement for
inclusion of a no-action or no-further action alternative among the options considered.
Alternative 1 would neither reduce any site-related surface risk (described in Section 2.6 -
"Summary of Site Risks") nor do anything to prevent contamination from the pits from
continuing to threaten groundwater. There would be no cost for Alternative 1. This
Alternative would not comply with the major Applicable or Relevant and Appropriate
Requirements (ARARs) regarding closure of hazardous waste disposal facilities.
ALTERNATIVE 2: INSTITUTIONAL CONTROLS
This alternative includes maintenance of the soil and vegetation cover currently present
on the site, installation of surface water controls to prevent ponding of water and runoff onto
adjacent properties, placement of deed restrictions prohibiting future residential use or any
other use that could impact the integrity of the soil cover, and upgrading and maintaining the
existing perimeter fence. This alternative also includes groundwater monitoring to evaluate
potential changes in groundwater conditions over time.
Alternative 2 would not reduce any site-related surface risk (described in Section 2.6 -
"Summary of Site Risks"). In particular, this alternative would do little to mitigate adverse
exposures of the public to waste pit contaminants in the event that the current cap is eroded,
disturbed, or displaced. In addition, this alternative would do nothing to prevent pits
contamination from continuing to migrate into the groundwater.
The cost of Alternative 2 would be approximately $790,000 (total present worth), but it
would not meet the major relevant and appropriate ARARs regarding closure of hazardous waste
disposal facilities. To prevent inappropriate future land use or development, this alternative
would require institutional controls that prohibit future residential use of the Waste Pits Area and
prohibiting future use which could impact the integrity of the cap.
ALTERNATIVES: RCRA-EOUIVALENTCAP
Under this alternative, a RCRA-equivalent cap would be constructed over the waste and
contaminated soil. There are approximately 15,600 yd3 of waste in the pits and approximately
317,100 yd3 of contaminated soil surrounding the pits that would be covered by the cap. Based
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on existing information, the cap would cover slightly less than 4 acres (See Figure 3). The
RCRA-equivalent cap would consist of multiple layers, typically including a vegetated cover, a
marker bed, a drainage layer, a low permeability layer (including a high density plastic liner), a
gas collection layer, and a grading layer.
FIGURE 3
EXTENT OF CAP (APPROXIMATE)
DEL AMO ALLEY
nnn an
ID
dUID
DaDOrf1
DEL AMO BOULEVARD
WEST 2MTH STREET
\ 2 I
\ s r
Qflfln
nfl^D
yp nn
Extent of Cap
The major ARARs that would be met during implementation of this action include
closure requirements for hazardous waste disposal facilities. Monitoring associated with the cap
would include soil vapor monitoring at varying depths around the pits area, which would help
determine whether any vapors are migrating or spreading laterally out from under the cap. Final
design of the cap and monitoring system would be determined during the remedial design phase
of the project. Long-term maintenance of and repairs to the cap would also be conducted.
To prevent inappropriate future land use or development, this alternative would also
require deed restrictions, prohibiting future residential use of the Waste Pits Area and prohibiting
future use which could impact the integrity of the cap.
Alternative 3 would eliminate any surface risk associated with the waste pits area. It
would also reduce the amount of contamination migrating from the waste pits and adjacent soil
into the groundwater. It would accomplish this by preventing infiltration of water from the
ground surface; however, some amount of contamination would continue to migrate into the
groundwater via vapor migration and via advection in draining soil water.
The cost of Alternative Three would be approximately $2,833,000 in capital costs,
$1,410,000 in operation and maintenance costs, and a total of $4,243,000 (all costs are shown in
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terms of present worth).
Alternative 3 would require an estimated 6 to 12 months to design and construct.
ALTERNATIVE 4 RCRA-EQUIVALENT CAP AND SOIL VAPOR EXTRACTION
OF CONTAMINATED SOIL
This alternative consists of the those actions discussed in Alternative 3, and adds a soil
vapor extraction (S VE) component. Soil vapor extraction would physically remove volatile
contaminants from soil by moving them into the soil vapor and then removing the vapor for
treatment. Under Alternative 4, the SVE system would be designed to limit the amount of
contaminants that move from the waste pits or the soils beneath the pits into the groundwater.
The SVE system would be applied to the soils under and adjacent to the pits, including
both coarse and fine-grained soil layers. The SVE system would not be applied to the waste
material itself, because it is too dense and would not provide sufficient air permeability to allow
for vapor extraction. The extracted air stream would be treated to remove the contamination
prior to being vented into the atmosphere. The actual width and depth of the soil vapor
extraction zone would vary across the area to some degree, based on a highly detailed review of
soil characteristics and contaminant distribution to be made during remedial design and system
installation. In general, the SVE coverage would extend vertically from just below each pit to
just above the capillary fringe above the groundwater table. The SVE coverage would extend
horizontally such that SVE is active wherever soil and soil vapor concentrations exceed interim
soil remediation standards. It is estimated that the volume of soil within which the SVE system
would be applied is approximately 317,100 yd3.
Interim soil remediation standards would be established to protect groundwater from
significant additional contamination emanating from the waste pits. The focus of the SVE
action, cleaning the soil to the interim soil remediation standard, would be to ensure that: (1)
contaminants already in the soils under the pits do not continue to significantly contribute to
groundwater contamination or counter future groundwater remedial efforts, and (2) contaminants
still in the waste in the pits, which may leach out of the pits in the future, cannot pass through the
soils and significantly contribute to groundwater contamination or counter future groundwater
remedial efforts.
Major ARARs would be met during operation of the SVE system including emission
standards for the vapor treatment system.
This alternative also includes appropriate soil and soil gas monitoring to evaluate
remediation progress.
The cost of Alternative Four would be approximately $6,290,000 in capital costs,
$2,690,000 in operation and maintenance costs, and a total of $8,980,000 (all costs are shown
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in terms of present worth).
Alternative 4 would require an estimated 8 to 12 months to design and construct. It is
estimated that the SVE system would have to operate for five years before meeting the interim
soil performance standards. Upon reaching those goals, the SVE system would need to be
operated whenever more contaminants migrating from the pits and adjacent soil surpass the
remediation goals set in either this ROD or as revised by the future ground water ROD.
ALTERNATIVE 5 COMPLETE EXCAVATION OF 1 -SERIES AND 2-SERIES PITS
BENEATH AN ENCLOSURE. AND SOIL VAPOR EXTRACTION OF
CONTAMINATED SOIL
This alternative includes complete excavation and offsite disposal of waste within the 1
series pits and the 2 series pits, and excavation of contaminated soil 5 feet beneath and around
the boundary of these pits. The total excavation volume for Alternative 5 is estimated to be about
42,900 cubic yards. Upon removal of the waste, the risk posed by potential surface emissions
from the waste would be eliminated.
Expected high concentrations of VOC and hydrogen sulfide air emissions from disturbed
waste material would require that the excavation be performed under a temporary enclosure
equipped with a ventilation and emission control system. The ventilation system would reduce
the concentration of airborne contaminants inside the enclosure, although workers inside the
enclosure would still be required to wear protective clothing and self-contained breathing
apparatus (SCBA) tanks. Exhaust hoods would be used to capture emissions from the face of the
excavation and from the roll-off bins where excavated waste and soil would be stored prior to
offsite transport. Contaminated air exhausted from within the enclosure would be treated on-site
in a series of air treatment units prior to being released to the atmosphere. Upon excavation, the
waste and soil would be transported to an offsite incinerator for treatment.
The major ARARs that would be met during implementation of the excavation phase
include emission standards for the air containment and treatment system, disposal restrictions for
the excavated waste, and excavation requirements.
The excavated area would be backfilled and a low-permeability cap would be installed
after backfilling is complete. The cap would be designed with surface water controls to prevent
ponding of water on its surface and to prevent runoff onto adjacent properties. Since
contaminated soil beneath the waste would be left in place, a soil vapor extraction system as
described in Alternative 4 would be required. To prevent inappropriate future land use or
development, the alternative would also require deed restrictions. This alternative also includes
groundwater monitoring to evaluate potential changes in groundwater conditions over time
associated with the remediation.
Alternative 5 would require an estimated 2 years for excavation and backfilling.
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Equipment design, procurement and construction, system start-up and shakedown, dismantling
the enclosure and other equipment after excavation is complete would add an additional 2 years
to the project, bringing the total project duration to an estimated 4 years.
The cost of Alternative 5 would be approximately $95,820,000 in capital costs,
$1,490,000 in operation and maintenance costs, and a total of $97,310,000 (all costs are shown in
terms of present worth).
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2.8 Summary of Comparative Analysis of Alternatives
This section compares the remedial alternatives described in Section 2.7. The
comparative analysis provides the basis for determining which alternative presents the best
balance of EPA's nine Superfund evaluation criteria provided in 40 Code of Federal Regulations
Section 300.430 (f) (criteria listed below). The first two cleanup evaluation criteria are
considered threshold criteria that the selected remedial action must meet. The five primary
balancing criteria are balanced to achieve the best overall solution. The tv/6 modifying criteria,
state and community acceptance, are also considered in the remedy selection.
Threshold Criteria
1. Overall Protection of HumanHealth and the Environment addresses whether an
alternative provides adequate protection from unacceptable risks posed by the site.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether an alternative attains specific federal and state environmental
requirements and state facility siting requirements, or provides grounds for a waiver.
Primary Balancing Criteria
3. Long-Term Effectiveness andJPermanence refers to the degree to which an alternative
provides reliable protection of human health and the environment over time.
4. Reduction of Toxicity. Mobility, and Volume (TMV) through Treatment refers to the
degree to which an alternative uses treatment to reduce the health hazards of
contaminants, the movement of contaminants, or the quantity of contaminants at the site.
5. Cost evaluates the estimated capital, operation and maintenance, and indirect costs of
each alternative in comparison to other equally protective alternatives.
6. Short-Term Effectiveness addresses the degree to which human health and the
environment will be adversely impacted during construction and implementation of an
alternative.
7. ImplementabiUty refers to the technical and administrative feasibility of an alternative.
This includes technical difficulties and uncertainties and the availability of materials and
services. It also includes coordination of federal, state, and local government efforts.
Modifying Criteria
8. State Acceptance indicates whether the state agrees with, opposes, or has concerns about
the preferred alternative.
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9. Community Acceptance includes determining which components of the alternatives
people in the community support, have reservations about, or oppose.
The strengths and weaknesses of the alternatives were weighed to identify the alternative
providing the best balance with respect to the nine evaluation criteria.
Overall Protection of Human Health and the Environment
The NCP requires that all alternatives be assessed to determine whether they can
adequately protect human health and the environment, in both the short term and long term, from
unacceptable risks. These risks can be mitigated by eliminating, reducing, or controlling
exposure to hazardous substances, pollutants, or contaminants. Overall protection of human
health and the environment draws on the assessments of other evaluation criteria, especially
long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs.
Reduction of toxicity, mobility, and volume is another important criterion for this overall
evaluation.
Alternative 1: No Action. Of all the alternatives, Alternative 1 is the least protective of
human health and the environment. Alternative 1 would not comply with ARARs for closure of
hazardous waste disposal facilities (e.g. surface capping of areas that leave hazardous waste in
place). Under Alternative 1, unchecked erosion of the surface soil cover would occur and
eventually expose contamination that in some places is only two feet below the ground surface.
Such erosion could allow direct contact with contaminants, allow water runoff and wind to
transport contaminants to nearby yards, and allow vapors to escape into the air. This alternative
would do nothing to prevent human access to the area and potential human incursion into the
uppermost layers of waste. In addition, this alternative does nothing to prevent the downward
migration of contaminants to groundwater currently in the waste and soils, and would not prevent
contamination of groundwater caused by a rising water table contacting contaminated soil.
Each of the other alternatives incorporates, at a minimum, institutional controls to attempt
to prevent human access to the contaminated area and possible human incursion into the
uppermost waste layers. Several other alternatives incorporate source control measures to
prevent further migration of contamination into the underlying aquifer. Because Alternative 1
has no provisions to prevent either potential human incursions into the contamination, continued
contaminant migration into the underlying aquifer, or contamination of groundwater caused by a
rising water table contacting contaminated soil, it is not protective of human health and the
environment.
Alternative 2: Institutional Controls. Alternative 2 also would not comply with ARARs
for closure of hazardous waste disposal facilities. However, unlike Alternative 1, Alternative 2
would include site maintenance of the existing soil cover and site fencing. Such maintenance
would repair surface erosional problems before contamination can be exposed. In addition, this
alternative provides some degree of prevention against human trespassing and potential human
27
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incursion into the contamination by maintaining the existing perimeter chain-link fence.
However, a perimeter chain-link fence is not a reliable long-term deterrent against trespassing,
particularly given the proximity to residential properties. Finally, this alternative does nothing to
prevent the downward migration to groundwater of contaminants currently existing in the waste
and soils, and would not prevent contamination of groundwater caused by a rising water table
contacting contaminated soil.
Several other alternatives contain more permanent measures to prevent human incursion
into the contamination than does this alternative. Also, several other alternatives incorporate
source control measures to prevent further migration of contamination into the underlying
aquifer. Alternative 2 does not have lasting, reliable measures to prevent potential human
incursion and contact with the contamination, it has no provisions to prevent continued
contaminant migration into the underlying aquifer, and it has no provisions to prevent
contamination of groundwater caused by a rising water table coming into contact with
contaminated soil. Therefore, it is not protective of human health and the environment.
Alternative 3: RCRA-Equivalent Cap. Alternative 3 complies with ARARs for closure of
hazardous waste disposal facilities by providing an appropriate surface cap over areas where
hazardous waste is left in place. Construction of a RCRA-equivalent cap would result in a
permanent cover over the Waste Pit Area that would eliminate the direct contact, ingestion and
vapor inhalation exposure pathways that could result from uncontrolled erosion or human
incursion into the contamination. The cap also provides a significant physical barrier against
human incursions into the waste. In addition, the cap would provide some degree of
groundwater protection by preventing a large amount of rainwater from infiltrating through the
waste and contaminated soil. However, Alternative 3 would not eliminate the downward
migration to groundwater of contaminants currently existing in the waste and soil, and it would
not prevent contamination of groundwater caused by a rising water table contacting contaminated
soil.
Alternatives 3 and 4 provide the second highest level of access prevention, second only to
Alternative 5, which completely removes the waste material. Whereas it could still be
theoretically possible that a human could intrude upon the cap and dig through it to expose
contamination, the undertaking would be so significant as to render the possibility extremely
unlikely. Regarding source control, Alternative 3 does not go as far as either Alternatives 4 or 5.
Alternative 3 does nothing to eliminate the other possible mechanism, vapor migration, whereby
the contamination could continue to impact the groundwater. Alternative 4 and 5 both
accomplish that goal through active remediation. The State Water Resources Control Board
considers groundwater beneath the pits a potential future drinking water source. For these
reasons, Alternative 3 is not fully protective of human health and the environment.
Alternative 4: RCRA-Equiyalent Cap and Soil Vapor Extraction. Alternative 4 complies
with ARARs for closure of hazardous waste disposal facilities by providing an appropriate
surface cap over areas where hazardous waste is left in place. This cap would achieve the same
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objectives as the cap described in Alternative 3. In addition to the degree of groundwater
protection provided by the cap, Alternative 4 also would utilize Soil Vapor Extraction to provide
an even greater degree of protection for the groundwater by removing migrating volatile
chemicals from the soil above the water table. This would protect the groundwater aquifer from
the downward migration of contaminants that currently exist in the waste and soil, and it will
also prevent significant contamination of groundwater caused by a rising water table coming into
contact with contaminated soil.
Alternative 4, as was true for Alternative 3, would provide the second highest level of
access prevention, second only to Alternative 5, which completely removes the waste material.
The source control provided by Alternative 4 goes farther than Alternative 3 by removing
volatile contaminants from the soil above the water table via Soil Vapor Extraction. However,
Alternative 4 does not go as far as Alternative 5, which completely removes the contaminant
source material. Because the State Water Resources Control Board considers groundwater
beneath the pits a potential future source of drinking water, protection of the groundwater
becomes an important factor in comparing the alternatives. Consequently, Alternative 4 is
considered to be fully protective of human health and the environment.
Alternative 5: Complete Excavation of 1-Serjes and 2-Series Pits Beneath an Enclosure
and Soil Vapor Extraction of Contaminated Soil. Alternative 5 complies with ARARs for
closure of hazardous waste disposal facilities by excavating and removing the remaining
hazardous waste mass and providing an appropriate cap for areas with soil contamination. By
removing the waste mass, this alternative eliminates possible human exposures from direct
contact, ingestion and vapor inhalation pathways at the surface. In addition, the waste would no
longer be a source of groundwater contamination. The remaining soil contamination would be
remediated with a Soil Vapor Extraction system. The SVE system would protect the groundwater
from the downward migration of the contaminants remaining in the soil, and it would prevent
significant contamination of groundwater caused by a rising water table contacting the
contaminated soil. Alternative 5 would provide the greatest and most permanent protection of
human health and the environment in the long term because the contaminated waste mass would
be completely and permanently removed from the site. This eliminates the need to perpetually
maintain containment mechanisms, which are necessary in the alternatives that leave waste in
place.
Alternative 5 provides the highest level of prevention of direct human contact because it
completely removes the waste mass. This removal also provides the highest level of source
control against further contamination to the underlying groundwater. The soil contamination
remaining after the removal would be removed with the same SVE system as described in
Alternative 4. For these reasons, Alternative 5 is considered to be fully protective of human
health and the environment.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
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Alternatives 1 and 2 do not comply with ARARs. Alternatives 1 and 2 do not meet
federal and state laws and regulations identified in Attachment A regarding the safe closure and
post-closure of hazardous waste facilities. Because Alternatives 1 and 2 do not comply with the
threshold criterion of Compliance with ARARs, they are not selected as a remedy for the waste
pits.
Alternatives 3, 4 and 5 comply with all ARARs.
Long-Term Effectiveness and Permanence
Long-term effectiveness is evaluated through two criteria: the magnitude of the residual
risk remaining after the remedy is implemented, and the adequacy and reliability of engineering
and institutional controls.
The magnitude of the residual risks is typically gaged by the risks remaining from
untreated waste after the conclusion of remedial activities. The risk of further groundwater
contamination posed by the waste material left in place after remediation is completed would be
the same for Alternatives 1,2, and 3, is significantly less for Alternative 4, and is least of all for
Alternative 5. Each of the first 3 alternatives (No Action, Institutional Controls, and Cap
alternatives) would leave all the waste material in place. These alternatives do not treat or
remove any amount of existing contamination, allowing contaminants to continue to migrate into
the underlying groundwater aquifer. Alternative 4 (Cap and SVE) would remove a significant
amount of VOC contamination from the vadose soils below the pits in order to significantly
reduce the continued migration of contaminants from the waste pits and surrounding soil into the
groundwater aquifer. Details regarding the exact degree of remediation that the SVE system
would accomplish are provided in Section 2.9, The Selected Remedy. By strategically removing
contamination in this way, Alternative 4 would, in the long run, prevent additional contamination
of groundwater beneath the Waste Pits Area. For this reason, Alternative 4 is superior to
Alternatives 1, 2, and 3 with regards to residual risk from contamination left in place.
Alternative 5 (Excavation, Incineration, SVE, and Cap) would remove the waste material via
excavation and utilize soil vapor extraction to remove the residual contamination remaining in
the unexcavated soil. This alternative removes the most contamination and leaves the least
residual risk of all the alternatives.
The "adequacy and reliability of controls" criteria pertains to the adequacy and suitability
of controls that are used to manage residuals or untreated wastes that would remain at the site.
The adequacy of these controls for each alternative varies significantly. The potential risks
associated with the remaining waste include both surface exposure risks and risks associated with
further contaminant impacts to groundwater. Alternative 1 (No Action) provides no engineering
or institutional controls to manage either surface or groundwater risks from remaining
contamination. Alternative 2 (Institutional Controls) provides minor institutional controls to
prevent surface exposures, consisting of security fencing to prevent human access, and
maintenance of the surface soil cover to repair erosional damage. Neither of these first two
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alternatives provide any controls against further contaminant impact to the groundwater.
Alternative 3 (Cap) provides significant and highly effective engineering controls against
surface exposures to remaining contamination by constructing a RCRA-equivalent cap over the
remaining waste and contaminated soil. The cap also provides a moderate level of control to
lessen the continued contaminant migration to groundwater. The cap provides this control by
eliminating the possibility for precipitation that falls directly on the cap to infiltrate through the
waste and contaminated soil and transport contaminants to the groundwater. There would still be
the possibility, however, for precipitation falling near the cap to spread under the cap as it
infiltrates, thus transporting some contaminants to the groundwater. These effects, however,
would be less than without the cap. In addition, there remains the possibility that the water table,
which has been steadily rising, will continue to do so and thus contact contaminated vadose soils,
adding to the contamination already in the water. Alternative 4 (Cap and SVE) provides the
same significant and highly effective engineering controls against surface exposures as does
Alternative 3. Alternative 4 provides, however, a much more significant level of control against
continued contaminant migration to groundwater. The SVE system beneath the waste would
capture a significant amount of the contaminants between the waste and the water table, thus
minimizing further contaminant migration and minimizing the additional contamination that
could be added to the groundwater as the water table rises. Alternative 5 (Excavation,
Incineration, SVE, and Cap)after removing the waste material and leaving only residual
contamination in the soil, will have minimized the need for engineering or institutional controls
for surface exposures. The engineering controls to minimize groundwater impacts from residual
soil contamination are the same as Alternative 4, consisting of an SVE system and a cap.
Reduction of Toxicity, Mobility, and Volume (TMV) through Treatment
This evaluation criterion addresses the statutory preference for selecting remedial actions
that permanently and significantly reduce toxicity, mobility, or volume through treatment. This
criterion is evaluated according to treatment processes used and materials treated; the amount of
hazardous materials destroyed or treated; expected reductions in the toxicity, mobility, and
volume; irreversibility of the treatment; and the type and quantity of treatment residuals.
Alternative 1 (No Action) and Alternative 2 (Institutional Controls) do not meet the
statutory preference for treatment by reducing the toxicity, mobility and volume of waste or
contaminated soil through treatment in any way. Alternative 3 (Cap) does not treat any waste.
All three of these alternatives leave approximately 15,600 cubic yards of waste and 317,100
cubic yards of contaminated vadose zone soil in place. Alternative 3, however, covers this waste
and soil with a RCRA - equivalent cap. The intrinsic toxicity, and volume of waste is unaffected
by this alternative. However, Alternative 3 would reduce the mobility of the contaminants by
preventing volatile gas emissions and limiting the amount of rainfall that will infiltrate the waste
and contaminated soil and transport contaminants to the groundwater. Alternative 3, however,
does not satisfy the statutory preference for treatment as defined in Section 121(b)(l) of the
Superfund law 42 U.S.C. § 9621(b)(l).
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Alternative 4 (Cap and SVE) provides for some reduction of toxicity, mobility, and
volume through treatment. This alternative contains an SVE component that will remove
volatile contaminants from the soil beneath the pits so that groundwater would not be
significantly affected by contaminants from the waste pits in the future. This will reduce the
toxicity and volume of the contaminants in the soils under the pits. The volume and toxicity of
the waste material in the pits, however, would be unaffected. The mobility of contaminants will
be reduced more than in Alternative 3 (Cap only) because the SVE would capture the volatile
contaminants before they reach the groundwater and become further mobilized. The vapors will
be treated by means of one of several treatment technologies such as thermal oxidation. SVE is
an irreversible treatment in that the contaminants, once removed, will stay removed. However,
under Alternative 4, the main mass of waste material would remain making it necessary for the
SVE system to continue removing any new contamination that enters the underlying vadose soil
from the waste pits. SVE would be applied to approximately 317,100 yd3 of soil. Alternative 4
leaves approximately 15,600 cubic yards of waste in the pits beneath the cap.
Alternative 5 (Excavation, Incineration, SVE and Cap) provides the highest level of
reduction in toxicity, mobility, and volume (TMV) by excavation and off-site incineration of
waste and soil vapor extraction of contaminated soil beneath the waste. The total excavation
volume for Alternative 5 is estimated to be about 42,000 cubic yards. This volume consists of
approximately 10,200 cubic yards of surface fill, 15,600 cubic yards of waste material, 5,200
cubic yards of contaminated soil adjacent to the pits, and 11,900 cubic yards of soil below the
pits. This action would drastically reduce the toxicity, mobility and volume of contaminants at
the site, and when the waste is destroyed at an off-site incinerator, its intrinsic toxicity and
volume will be permanently destroyed. There would be approximately 289,800 yd3 of
contaminated soil remaining after the excavation to which SVE would be applied. SVE would
permanently remove the volatile contaminants from these soils, thus reducing the toxicity and
volume of the contaminants in the soil.
Cost
A summary of the estimated costs for Alternative 3,4, and 5 is presented below. Cost
estimates for Alternatives 1 and 2 are not provided because these alternatives were found to not
be protective of human health and the environment. The cost estimates presented include capital
costs, operation and maintenance costs, and net present worth. An overview of the cost analysis
as well as detailed cost break-down for each alternative, are presented in the Focused Feasibility
Report.
As shown in Table 4, the operation and maintenance costs are relatively consistent for the
three alternatives, ranging from $1.4 million to $2.69 million. The capital costs, however, vary
drastically, ranging from $2.83 million to $95.82 million. The largest jump in capital costs
between alternatives, by far, is between Alternative 4 and 5 jumping from $6.29 million to
$95.82 million. The cost of the excavation and incineration aspect of Alternative 5 accounts for
this drastic capital cost difference. The cost of Alternative 5 is more than ten times the cost of
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Alternative 4, which is also protective of human health and the environment.
TABLE 4: Cost Estimates
Operation and Total Present
Alternative Capital (S) Maintenance (S) Worth (S)
1: No Action NA NA NA
2: Institutional Controls NA NA NA
3:RCRA-EquivalentCap 2,833,000 1,410,000 4,243,000
4:RCRA-Equivalent'Capand 6,290,000 2,690,000 8,980,000
Soil Vapor Extraction
5: Excavation, Incineration, 95,820,000 1,490,000 97,310,000
Soil Vapor Extraction, Cap.
Short-Term Effectiveness
Several factors are addressed in evaluating short-term effectiveness of the remedial
alternatives, including potential short-term risk to the community during implementation, threats
to workers during remedial actions, and potential adverse environmental impacts from
construction and implementation.
Risk to Community During Remedial Action Implementation. Alternatives 1 and 2 (No
Action and Institutional Controls) have no adverse short-term effects. Because there are no
remedial actions that would be taken for these alternatives, there would be no risk to the
community, workers, or environment associated with remedial action implementation. Under
Alternatives 3 (Cap) and 4 (Cap and SVE), the potential for short-term exposure to contaminants
during implementation would be limited and readily controllable. In Alternative 3, a RCRA-
equivalent cap would be constructed, requiring approximately 6 to 12 months of design and
construction activities. In Alternative 4, an SVE system would be constructed in addition to the
cap, requiring approximately 8 to 12 months combined to design and construct.
The effects on the community during both of these remedial actions, construction of a cap
and construction of an SVE system, are related to the actual construction activities. Such effects
include impacts from the dust generated during construction, increased vehicular traffic, air
quality impacts from motorized equipment, and noise. There is also the potential for releases of
volatile contaminants resulting from either accidental or intentional disturbances of the waste.
Such disturbances could occur during grading, well drilling or other construction activities.
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Whereas the potential for such releases can be mitigated with proper safety measures, they are
possibilities nonetheless. Should such releases occur, however, the impacts to the community
would be minor.
Alternative 5 (Excavation, Incineration, SVE and Cap) is expected to be more complex
and take a longer time to implement than the other alternatives, and its short-term effectiveness is
much more uncertain than other alternatives. This alternative would involve excavation of
hazardous waste beneath an enclosure, which is an uncommon task and presents potential safety
and health risks. The ability to protect the community during the excavation would be dependent
on the effectiveness of the enclosure, ventilation and emissions treatment system. A failure of the
enclosure or emissions treatment system could expose the community to elevated levels of
airborne contaminants. Because the excavation and subsequent backfilling would last an
estimated two years, and because the excavation activities would produce high levels of volatile
contaminants, the remedy has comparatively much higher short term risks.
Protection of Workers During Remedial Action. There would be a potential for adverse
health effects to workers resulting from exposure to hazardous substances during the construction
activities of either Alternative 3,4, or 5. Alternatives 1 and 2 have no construction activities.
The construction activities for Alternatives 3 (Cap) and 4(Cap and SVE) are essentially the same.
Both alternatives would involve surface grading and cap installation, as well as well drilling and
installation of surface treatment units. If the construction activities adhere to the site health and
safety plans and all regulatory requirements, the potential for exposure and adverse health effects
to workers would be minimized.
Alternative 5 (Excavation, Incineration, SVE and Cap) has a significantly greater
potential for adverse impacts to workers during implementation. Workers would be required to
operate in an environment where benzene concentrations could range as high as 69 to 207 ppm.
This is many times higher than the Occupational Safety and Health Administration (OSHA)
standard of 1 ppm for benzene. Hydrogen sulfide concentrations inside the enclosure could be as
high as 50 ppm, five times higher than its OSHA standard of 10 ppm and many times higher than
its odor threshold of 6 ppb. These exposures would be mitigated by wearing protective clothing
and SCBA tanks. However, because the project would last approximately 2 years, there would be
a potential for the protective measures to fail. In addition, operating in such an enclosure with
such personal protection gear would introduce the additional hazards of heat exhaustion, reduced
hearing and visibility, and slip, trip, and fall hazards. These hazards would be significant because
of the length of time the work would require. Working at this level of protection for prolonged
periods of time is not routine.
Environmental Impacts. The main potential environmental impact associated with
remedy implementation would be releases of volatile contaminants into the air. During
construction activities for Alternatives 3 and 4, there would be the potential for releases of
volatile contaminants resulting from disturbance of the waste. Such releases were described in
the "Risk to Community" subsection above. As described in that same section, Alternative 5 has
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. a greater potential for harmful releases of volatile contaminants into the environment than do
Alternatives 3 and 4. This is due to the fact that Alternative 5 involves extreme disturbance of
the waste material containing high concentrations of volatile contaminants, in an enclosed space,
for a substantial period of time.
Implementability
This evaluation criterion addressed the technical feasibility, the availability of services
and materials, and the administrative feasibility of each alternative. The technical feasibility
includes the ability to construct and operate the technology, the relative ease of undertaking the
remedial action and the ability to monitor its effectiveness. The availability of services and
materials addresses the availability of the necessary equipment, technology, services, and other
resources to construct the remedial action. The administrative feasibility considers the activities
needed to coordinate and obtain approvals from other agencies.
Technical Feasibility. The technical feasibility of Alternatives 3 and 4 is very good.
Alternatives 1 and 2 do not involve any construction activities, so they will not be included in
this discussion. Caps and SVE systems are common technologies today and have been
successfully employed at many sites. Alternative 5 is implementable, however, the enclosed
excavation aspects of Alterative 5 present a number of technical constraints that would need to be
overcome. These constraints include limited operating room for the excavation equipment, the
need for an effective high volume ventilation and air treatment system, the necessary use of at
least level B personal protection gear for workers, the need for and use of an effective vapor
suppressing foam, and the need for customized waste handling techniques. These constraints can
be addressed during design and trial-runs, but nonetheless pose some additional problems that
other alternatives do not have.
Availability of Services and Materials. All services and materials needed to construct a
RCRA-equivalent cap and SVE system, as required in Alternatives 3 and 4, are readily available.
Alternatives 1 and 2 do not include any construction activities, so they will not be discussed here.
For the cap and SVE system construction, there are a number of qualified bidders who could
offer competitive bids. For Alternative 5, there is good availability of materials and services for
the excavation work; the materials and services for the enclosure, ventilation, and air treatment
work are generally available as well. Although few contractors in the Southern California area
have experience constructing such enclosures and treatment systems, the availability of such
services in the United States at large is good. Hazardous waste transporters are readily available
in Southern California for transporting the waste material off-site to an incinerator.
Administrative Feasibility. Except for Alternative 1 (No Action) all the alternatives
would require some administrative effort, including the implementation of institutional controls
and coordination with other agencies regarding permits (or meeting the substantive requirements
thereof)- For Alternative 2, interagency coordination to implement deed restrictions would be
required. Alternatives 3 and 4 would also require coordination with State and local agencies in
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order to comply with substantive requirements for grading and air and water discharges.
Compliance with the technical requirements of these permits is considered to be relatively
simple, and therefore it is expected that complying with the permit requirements will
administratively be relatively simple as well. Alternative 5 would involve a greater
administrative effort due to the complex enclosure and ventilation system, the hazardous working
conditions, the off-site transportation of hazardous waste, and the incineration of the hazardous
waste. The proposed ventilation and treatment system has been utilized in the area before (and
has met local air permit requirements) but not at the scale that would be needed for this project.
However, it is expected that it will be technically feasible to meet the relevant and substantive
South Coast Air Quality Management District requirements with the proposed technology. It is
expected that off-site incineration of the waste will be administratively feasible as well; however,
adequate time will be needed to prepare applications and obtain permits for this disposal method
well in advance of the initiation of site work.
State Acceptance
The State of California has concurred with EPA's selected remedy.
Community Acceptance
EPA received 12 sets of written comments from individuals, organizations, and agencies
regarding EPA's Proposed Plan, as well as 16 verbal comments during its public meeting. These
comments, and EPA's responses to the comments, are presented in the Response Summary in
Part IV of this ROD.
Many of the comments received from the public expressed support for EPA's proposed
remedy; others did not. Some commentors recommended that EPA select Alternative 5. EPA
has determined that the preferred alternative presented in the Proposed Plan, Alternative 4, is the
most appropriate remedy, and EPA has provided responses to those commentors that preferred
other alternatives in the attached Response Summary.
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2.9 The Selected Remedy
After considering CERCLA's statutory requirements, the detailed comparison of the
alternatives using the nine criteria, and the public comments, EPA, in consultation with the State
of California, has determined that the most appropriate remedy for addressing the contaminated
waste and soil at the Del Amo Site Waste Pit Operable Unit is Alternative 4: "RCRA-Equivalent
Cap and Soil Vapor Extraction." This alternative will isolate the waste material by installing a
RCRA-equivalent cap over the surface of Lots 36 and 37 (as shown in Figure 3) and conducting
soil vapor extraction beneath the waste, and adjacent contaminated soil, and above the water
table. The remedy also requires deed restrictions, security fencing, and long-term monitoring
and maintenance. EPA also believes that Alternative 4 is the most appropriate alternative for
addressing, on an interim basis, the waste pits' contribution to contaminated groundwater.
The selected remedy does not constitute a remedial decision for currently contaminated
groundwater at the proposed Del Amo Site or a remedial decision for contaminated soil/vadose
zone areas of the Del Amo Site beyond the Waste Pits Area.
In considering the nine criteria and selecting Alternative 4, EPA assumed that the
properties along 204th Street immediately adjacent to the Waste Pits Area will be permanently
removed from residential or related uses as a result of the private non-CERCLA buy-out
agreement between community residents and several responsible parties under which residential
property adjacent to the Waste Pits Area will be removed from residential use. Because of this
assumption, EPA did not evaluate the purchase of any residential properties or permanent
relocation of any residents. In the event that properties on 204th Street adjacent to the Waste Pits
Area are not removed from residential uses, EPA reserves the right to revaluate the remedy
selected in this ROD.
Based on the Comparative Summary (presented in Section 2.8), Alternative 4 was found
to be the best remediation alternative for the Waste Pits Area. The criteria that weighed most
heavily in this decision were the threshold criteria of Protection of Human Health and the
Environment, compliance with ARARs, and the balancing criteria of Short-Term Effectiveness
and Cost. Alternative 4 (Cap and SVE) was one of only two alternatives that met the threshold
criteria of Protection of Human Health and the Environment, the other alternative being
Alternative 5 (Excavation, SVE, and Cap). Alternative 3, RCRA-Equivalent Cap, was found not
to be fully protective of human health and the environment because it did very little to prevent
further migration of the contaminants into the underlying groundwater. The cap utilized in
Alternative 3 would provide some protection against rainwater infiltration, which is one
mechanism for contaminant transport, but the cap's effectiveness in this regard is limited and
there would still remain the vapor diffusion mechanism for contaminant transport.
In comparing the two alternatives that met the threshold criteria of Protection of Human
Health and the Environment, Alternatives 4 and 5, the balancing criteria weighed more heavily in
favor of Alternative 4. Alternative 5 was superior to Alternative 4 when compared to the criteria
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of Reduction of Toxicity, Mobility, and Volume (TMV) through Treatment and Long-Term
Effectiveness and Permanence. However, Alternative 4 was superior to Alternative 5 when
compared to the criteria of Implementability, Short-Term Effectiveness, and Cost.
Overall, the positive aspects and limited negative aspects of Alternative 4 outweighed the
positive aspects and substantial negative aspects of Alternative 5. Specifically, Alternative 4
would provide good Reduction of TMV through Treatment, good Long-Term Effectiveness and
Permanence, and relatively minor negative Short-Term Effects. Alternative 5, however, would
provide superior Reduction of TMV through Treatment and superior Long-Term Effectiveness
and Permanence, but the Short-Term Effects could be substantial and harmful to both the
community and the on-site workers, and the Cost would be approximately ten times greater than
Alternative 4. For this reason, Alternative 4 was chosen as the selected Remedial Action.
In further support of the decision to select Alternative 4, the State of California and a
substantial portion of the community supported this alternative. The Del Amo Action
Committee concurred but suggested that additional research in Biodegradation be conducted by
the EPA.
Regardless of the type of remedy selected in the groundwater ROD, EPA believes that
controlling the continuing source of contamination, as provided by Alternative 4, is prudent and
appropriate. If drinking water-based cleanup standards were to be waived by the groundwater
ROD, the containment of groundwater beneath the pits would be required for an indefinite
period, possibly for centuries. Given this, it is appropriate to take reasonable steps to prevent
additional waste pits contaminants from reaching the groundwater. This would lend greater
long-term effectiveness and certainty during the very long period for which the groundwater
remedy would have to be effective. Moreover, state and federal policies and regulations
pertaining to zones of indefinite groundwater containment generally require source control, such
as the SVE system would afford the soils under the pits, as part of a containment approach. On
the other hand, if the groundwater ROD selects drinking water standards as the cleanup goal for
the groundwater beneath the pits, the SVE action would be vital for such goals to be achieved.
Therefore, the basis for selecting Alternative 4 over Alternative 3 is present regardless of the
conclusions of the final groundwater ROD. Consequently, the SVE component of the selected
remedy appears at this time to be consistent with the final remedial actions for the Del Amo Site.
DESCRIPTION AND SPECIFICATION OF THE REMEDY
The remedy selected by this ROD is described below. The remedy as designed and
implemented shall meet all requirements and specifications described herein. Further, the
remedy as designed and implemented must meet all ARARs as identified in Attachment A.
The selected remedy for clean-up of the Waste Pits Area consists of the following
components:
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(1) A RCRA-equivalent cap,
(2) Soil vapor monitoring,
(3) Surface water controls,
(5) Soil vapor extraction,
(6) Security fencing,
(7) Deed restrictions, and
(8) Long-term operation and maintenance.
RCRA-Equivalent Cap and Associated Monitoring
The RCRA-equivalent cap (meeting all identified ARARs) shall be constructed over the
waste and contaminated soil. Based on existing information, the cap will cover slightly less than
4 acres. The cap shall be applied over all waste pits (1 A, IB, 1C, 2A, 2B, 2C, 2D, 2E, 2F) and
related area as depicted in Figure 3. The cap shall include, among other things, a surface water
drainage layer, a low-permeability layer, and a gas collection layer.
The objectives of the cap are:
(1) to prevent direct human contact with contaminants;
(2) to prevent generation of uncontrolled runoff and wind blown dust;
(3) to prevent the emission of contaminants into the air;
(4) to prevent rainwater from washing through the waste pits and carrying contaminants into
the groundwater; and
(5) to prevent rainwater from washing through the contaminated vadose zone soils below the
pits and carrying them into the groundwater.
Consistent with identified ARARS: the physical barrier created by the cap shall prevent
direct human contact with the contaminants, the surface water collection and diversion system
associated with the cap shall prevent uncontrolled runoff, the impermeable barrier created by the
cap shall prevent rainwater from infiltrating the soil and transporting contaminants into the
groundwater, and the cap's vapor collection and treatment system shall prevent the emission of
unacceptable levels of contaminants into the air.
All of the ARARs identified in Attachment A which pertain to the cap shall be attained.
The major ARARs that would be met during implementation of this action, including those
specified by Title 22 of the California Code of Regulations, describe closure requirements for
hazardous waste disposal facilities. The closure requirements specify that the design of the cap
shall be sufficient to prevent damage due to settling and earthquakes. Any treatment units
associated with the cap must have security fencing. The cap also must be designed with surface
water controls to prevent ponding of water on its surface and to prevent runoff onto adjacent
properties. Required monitoring associated with the cap includes soil vapor monitoring. The
soil vapor monitoring is to be conducted at varying depths around the pits area in order to help
determine whether any vapors are migrating or spreading laterally out from under the cap. These
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monitoring points could be located within the Waste Pits Area (lots 36 and 37) or on adjacent
properties.
Final design of the cap and monitoring system shall be determined during the remedial
design phase of the project. Such design items include (but are not limited to) layers and
materials to be used in the cap, surface land-use and landscaping, location and depth of soil gas
monitoring points, soil gas treatment system technology, and final areal extent of the cap. These
and all other design items shall all meet the parameters for the cap as set forth in this ROD,
including ARARs that pertain to the cap.
Security fencing, to meet State ARARs, shall be installed around any treatment units
associated with the cap that could potentially present a target for unauthorized access or
tampering.
Long-term maintenance and repairs to the cap shall be conducted as part of this remedy
for as long as the waste material remains at the Site. The maintenance and repairs shall be
carried out on a schedule with a frequency such that the effectiveness of the cap and its
compliance with the requirements of this ROD are maintained at all times. If the cap is at any
point unable to be repaired without replacement, such as when it has reached the end of its
natural life, then the cap shall be replaced so long as the waste remains in the pits.
A long-term operation and maintenance plan for the cap shall be established and
approved by EPA before the cap is constructed. This plan shall provide, at a minimum:
1) Specification of all activities necessary to ensure complete maintenance and repairs of the
cap over its lifetime and comply with ARARs relating to such maintenance and repair;
2) The schedule and frequency for maintaining the cap and for the execution of all activities
identified;
3) Specification of all monitoring, analysis, sampling and other tests necessary to ensure the
performance and integrity of the cap and identify cap components requiring repair or
replacement;
4) Specification of the schedule and frequency for such monitoring, analysis, sampling, or
other tests;
5) Specification of all regulatory agencies and persons within those agencies to which
results and confirmation of maintenance and repairs shall be sent, and approvals which
shall be necessary.
Once the operations and maintenance plan is approved by EPA, the requirements in it
shall become part of the approved remedy for the site. The operations and maintenance plan
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shall not conflict with or negate any requirements or specifications of this ROD.
Soil Vapor Extraction and Associated Monitoring
The SVE system shall be designed to remove contaminants from the soil via the vapor
phase in order to limit the amount of contaminants that migrate from the waste pits and
surrounding soil into the groundwater, according to the specifications and requirements provided
below.
The objectives of the SVE System are:
(1) to protect groundwater from contaminants that migrate out of the pits;
(2) to protect groundwater from contaminants that migrate out of the vadose soil below the
pits; and
(3) to protect groundwater from contaminants in the soil below the pits in the event that the
water table rises into the contaminated soil.
This remedy shall include design, installation, operation, and long-term maintenance of a
soil vapor extraction (SVE) system to meet the above objectives and all requirements as specified
below. The SVE system shall be applied to the unsaturated soils under the waste pits and above
the groundwater, in the soil areas as defined below. The SVE system shall clean these soils to an
interim soil standard as specified in this ROD. A monitoring system shall be established, for the
soils and soil vapor under the pits, to monitor the remediation progress. The SVE system shall
establish and maintain a zone of soil under the waste pits (see section entitled "Where SVE Shall
Be Applied" for locational details) which does not exceed the interim soil standard.
Incremental Groundwater Contribution. The SVE portion of this remedy shall be
designed to limit the additional contamination the waste pits and adjacent contaminated soil shall
be allowed to contribute to groundwater now and in the future. The groundwater beneath the
waste pits currently is highly contaminated from both the waste pits themselves and other
upgradient sources. The incremental groundwater contribution is defined as the amount by
which the soils under the pits would be able to increase the groundwater contaminant
concentration if the groundwater were clean today. The SVE action, by maintaining a cleaned
zone of soil, will place a limit on this incremental contribution.
The contaminant concentrations in groundwater, according to the groundwater sampling
and analysis conducted in late 1996, currently range from 12,000 ppb to 470,000 ppb benzene,
less than 100 ppb to 15,000 ppb ethylbenzene, and 29 ppb to 440 ppb phenol, among others. The
exact wells to be used in calculating the existing groundwater concentrations of these
contaminants and any other contaminants amenable to SVE treatment for determining the
allowable incremental groundwater contribution, will be determined during design.
SVE Cleanup Standards. Because of potential physical constraints in the subsurface
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under the waste pits, this ROD establishes two methods for calculating the interim soil standard
to which the soils under the waste pits shall be cleaned and maintained by the SVE system. Only
one of these methods shall be used; this ROD establishes the rules for when either method shall
be used. This is fully explained in the following discussion.
EPA recognizes that the groundwater under the pits is currently highly contaminated and
EPA has determined that it would not be appropriate to set an incremental contribution limit that
assumes the groundwater is clean today. Therefore, the SVE cleanup shall focus on ensuring that
the incremental groundwater contribution resulting from migrating pits contaminants remains an
insignificant fraction of the existing groundwater contamination. Rather than set an interim soil
standard that is a fixed value, the standard shall be tied to a fixed percentage of the groundwater
contaminant concentration. As the groundwater contaminant concentration varies, the
incremental groundwater contribution would vary with it. For example, if the groundwater
concentration becomes lower due to natural or human-induced effects, the soil standard that
SVE must achieve shall become correspondingly lower, as calculated by the methods outlined
below. If, in the groundwater ROD, EPA were to select the requirement that the groundwater
under the pits were to be cleaned to drinking water standards, then the interim soil standard
would automatically become stringent enough to attain that standard.
The performance standard for the SVE system shall be that the pits will not be able to
cause an incremental groundwater contribution in excess of 0.5% of the existing groundwater
concentration, at any point in time. When a final groundwater remediation standard is selected
by the groundwater ROD, the incremental contribution shall be limited to 0.5% of the
groundwater concentration at the time. The groundwater ROD will address any potential
changes to this requirement if the groundwater contaminant concentrations ever approach
federally mandated remediation levels.
Rationale for Two Methods of Calculating Interim Soil Standards for SVE. There may
be areas in the soil beneath the waste pits that have such low air permeabilities due to fine-
grained stratigraphic materials that it may be impractical or impossible to implement an effective
SVE system in those areas. This does not apply to all materials under the waste pits, most of
which will be amenable to SVE treatment. The focused feasibility study (FFS) and EPA's
proposed plan for this remedy specified a method for calculating the interim soil standard for
SVE; this method was based on the assumption that most all soils subject to SVE would be
cleaned to the same soil concentration value such that the incremental groundwater contribution
did not exceed 0.5% of the existing groundwater concentration. This calculation method shall be
termed "Method A."
In the event that, during remedial design, it is found that SVE cannot be operated in
significant portions of the soils beneath the pits, then Method A would not be appropriate. If
only a subset of the soils are cleaned to the standard as calculated by Method A, then the
incremental concentration would exceed 0.5% of existing groundwater concentrations. Should
this situation exist, this ROD specifies that Method B shall be used to calculate the interim soil
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standard.
Method A: To Be Used When Most All Soils Can Be Cleaned To The Same Level. An
overall attenuation factor of 10 shall be assumed as a ratio between soil and groundwater
concentrations. EPA's proposed plan explained that while many physical parameters must be
combined to derive the true value of the overall attenuation factor, EPA believes that 10 is a
conservative but reasonable value within the range of possible values for this factor. Based on
this belief, the following equation shall be used to determine the interim soil standard for SVE
under Method A:
S = (GWE * 0.005) * 10 = (GWE * 0.05)
where
S = Interim Soil Standard for SVE
GWE = Existing Groundwater Concentration (as defined by this ROD)
0.005 = 0.5% interim soil standard as described above
10 = overall attenuation factor to be used
As an example, if the existing groundwater concentration is found to be 100,000 parts per
billion (ppb), then the SVE system would be required to maintain all soils in the zone subject to
SVE at 5000 ppb. This standard shall be applied independently to all chemicals in groundwater
and in soils under the waste pits. The SVE system shall be operated such that the soils are
maintained at or below this standard indefinitely. If the existing groundwater concentration
changes, then the interim soil standard shall be adjusted based on the same calculation.
The "attenuation" refers to the decrease in concentration of contaminants as the
contaminant passes through the soil away from a fixed source. Processes such as natural
biodegradation and adsorption may occur in the intervening soil, causing concentrations to be
less at the water table than directly under the pits. The degree of attenuation from all the
processes and causes in the soil under the pits is not known. However, a reasonable range for
this total attenuation can be assumed. It is conservative to assume that the real attenuation factor
is in the low end of its reasonable possible range. This conservative assumption tends to
underestimate the amount of attenuation and, therefore, overestimate the amount of contaminants
arriving at groundwater over time. Conversely, assuming the real attenuation factor is in the high
end of its reasonable possible range may underestimate the amount of contaminants arriving at
the water table. The interim soil standard chosen by EPA was on the conservative end of the
range.
Method B: To Be Used When All Soils Cannot Be Cleaned To The Same Level Because
of Low Air Permeabilities in Certain Soil Areas. In the event that SVE cannot be applied to all
areas of soil under the pits due to low air permeability of certain soils, then the equation in
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Method A and the assumed attenuation factor of 10, shall not apply. Rather, the remedial design
shall establish a vadose zone transport model, approved by EPA, that shall be configured to
evaluate the contributions from all areas of soil under the pits. The model shall estimate the
incremental concentration due to both (1) the soils to which SVE can be applied, as well as (2)
the soils to which SVE cannot be applied. The interim soil standard for SVE shall be set such
that when the soils to which SVE can be applied are cleaned to that value, the overall incremental
contribution from the waste pits does not exceed 0.5% of the existing groundwater concentration.
The SVE system shall be run such that soils are maintained at levels that will maintain this
condition indefinitely. If the existing groundwater concentration changes, then the interim soil
standard shall be adjusted based on the same model and calculation.
Where SVE Shall Be Applied. The depth of the SVE application shall be between the
capillary fringe above the water table and just below the bottom of each waste pit. The areal
extent of the SVE application shall extend all across the pits themselves and laterally beyond the
boundaries of the pits in all directions to whatever distance is necessary such that all interim soil
standards as specified in this ROD are met. This could extend beyond the boundaries of lots 36
and lot 37. The SVE system shall be applied so as to address soil contamination which has
emanated or is emanating from the waste pits, and will not be designed to address contamination
if it is emanating solely from other sources.
This ROD recognizes the following limitations to the application and operation of the
SVE system. The SVE system shall not be applied to the waste itself. If the SVE system applies
too strong a pneumatic influence near the bottom of the waste pits, it may have the undesirable
effect of drawing contaminants directly downward out of the waste pits. Similarly, if a
significant pneumatic influence from the SVE system is applied too close to the capillary fringe,
it may have the undesirable effect of pulling-in volatile contaminants that exist in the capillary
fringe as a result of off-gassing and capillary contaminants from the groundwater. The SVE
system shall be designed to minimize these undesirable effects. It is not however, a requirement
of this ROD that the pneumatic influence near the pits' bottom or near the capillary fringe be
reduced to zero; this may not be possible. Rather, the influence near these areas shall be lessened
as necessary to reduce or eliminate those undesirable effects.
SVE Monitoring. The remediation progress of the SVE system shall be monitored with
appropriate soil and soil gas monitoring. This ROD recognizes that contaminants may exist, at
any given location, in one or more of several phases, including sorbed to soil, soil vapor,
dissolved in soil moisture, and residual phase. If only one phase is measured, the amount of
contamination in other phases shall be calculated based on supportable partitioning relationships,
and the contamination in all phases shall be included in estimating the impact to groundwater.
Other Requirements. The SVE system shall be designed with the appropriate safety
features required to allow safe unattended operation. The soil vapor extraction and treatment
system shall be inspected and monitored on a regular basis and repaired as needed. Appropriate
security fencing, required by State ARARs, shall be installed around the SVE treatment units.
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A long-term operation and maintenance plan shall be written for the SVE system. This
plan shall be completed and approved by EPA prior to the operation of the system. The plan
shall include, at a minimum, all of the following details:
1) Specification of all activities necessary to meet all ARARs and other requirements put
forth by this ROD, and a schedule and frequency by which all such activities shall take
place;
2) Specification of all activities necessary to operate and maintain the system in safe
working order, and a schedule and plan of execution for all such activities;
3) Specification of all sampling, testing, and monitoring associated with operation and
maintenance of the system and the scheduling and frequency for these actions;
4) Specification of all sampling, testing, and monitoring associated with verifying the
performance of the SVE system and the scheduling and frequency for those actions.
The SVE system shall meet all ARARs specified in this ROD that pertain to the SVE
system and its components. The major ARARs that would be met during implementation of the
SVE system include emission standards for the vapor treatment system and monitoring
requirements for response actions for hazardous waste facility closure. Such monitoring includes
groundwater monitoring to evaluate potential changes in groundwater conditions over time
associated with the remediation.
Deed Restrictions
To prevent inappropriate future land use or development, the remedy also requires deed
restrictions, prohibiting future residential use of the Waste Pits Area and prohibiting any future
use which could impact the integrity of the cap.
Cost and Time for Remedy
The cost of the selected remedy would be approximately $6,290,000 in capital costs,
$2,690,000 in operation and maintenance costs, and a total of $8,980,000 (all costs are shown
in terms of present worth).
The remedy would require an estimated 8 to 12 months to design and construct. It is
estimated that the SVE system would have to operate for five years before meeting the interim
soil performance standards. Upon reaching those goals, the SVE system would need to be
operated whenever more contaminants migrating from the pits and adjacent soil surpass the
remediation goals set in either this ROD or revised by the future groundwater ROD.
5-Year Review
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As required by CERCLA Section 121c 42 U.S.C.§ 9621 (c), a review shall be conducted
every 5 years as long as waste remains at the site at levels that prevent unrestricted use. This 5-
Year Review shall determine whether the implemented remedy remains protective of human
health and the environment. If the remedy is no longer protective, then a remedy should be
selected that will be protective. As remediation technologies continue to be developed in the
future, there may be technological advances (e.g. bioremediation) that can be utilized for safe,
efficient elimination of the waste.
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2.10 Statutory Determinations
Under its legal authorities, EPA's primary responsibility at Superrund Sites is to
undertake remedial actions that achieve adequate protection of human health and the
environment, see 42 U.S.C.§9604(a). In addition, section 121 of CERCLA establishes several
other statutory requirements and preferences. These specify that when complete, the selected
remedial action for this site must comply with applicable or relevant and appropriate
environmental standards established under Federal and State environmental laws unless a
statutory waiver is justified. The selected remedy also must be cost-effective and utilize
permanent solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. Finally, the statute includes a preference for remedies that
employ treatment that permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following sections discuss how the selected
remedy meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment through capping the
contaminated waste and soil and implementing soil vapor extraction in the vadose soil beneath
the waste pits. This work will be done in accordance with ARARs identified by this ROD.
Capping the waste pits area will eliminate the threat of exposure to volatile contaminants
from the waste pits. There is currently a significant possibility that a release of hazardous
substances could occur due to disturbance of the waste. Such a release would result in an
unacceptable risk to the public. This potential risk would be eliminated by a surface cap. Such a
cap would reduce contaminant migration to the groundwater. Implementing SVE as an interim
action will also reduce the continued migration of contaminants from the waste material into the
groundwater to a negligible amount.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy of cap and SVE will comply with all applicable or relevant and
appropriate chemical-specific, action-specific, and location-specific requirements (ARARS).
The ARARs are presented in Attachment A.
Cost-Effectiveness
The selected remedy is cost-effective because it has been determined to provide overall
effectiveness proportional to its costs, the net present worth value being $8,980,000. The
estimated costs of the selected remedy are within an order of magnitude of (just over two times)
the costs associated with on Alternative 3, capping only, and yet the selected remedy assures a
much higher degree of certainty that the remedy will be protective of the groundwater due to the
action of the SVE system. While the selected remedy effectively reduces the hazards posed by
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all of the contaminants at the site, its costs are less than 10% of the cost of alternative 5,
excavation, incineration, SVE and cap.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource
Recovery Technologies) to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in a cost-effective manner for the
final source control operable unit at the Del Amo Waste Pits. Vapor extraction and treatment
technologies will be utilized both as part of the cap and the SVE system to extract and treat
hazardous substances. Of those alternatives that are protective of human health and the
environment and comply with ARARs, EPA has determined that this selected remedy provides
the best balance of tradeoffs in terms of long-term effectiveness and permanence, reduction in
toxicity, mobility, or'volume achieved through treatment, short-term effectiveness,
implementability, cost, and considering both the statutory preference for treatment as principal
element and State and community acceptance.
While the selected remedy does not offer as high a degree of long-term effectiveness and
permanence as the excavation alternative, it will significantly reduce the inherent hazards posed
by the contaminated soils through a cap that eliminates surface exposure and SVE system that
significantly reduces the continued migration of contamination to the groundwater.
The selected remedy addresses the principal threats posed by the contaminated waste and
soil, achieving significant reduction of their impacts to groundwater. The selected remedy is
more effective than the other treatment option in the short-term, as there will be no danger of
releases of site-related contaminants during remedy implementation. The implementability of
the selected remedy is comparable to the non-treatment alternatives and significantly better than
the excavation option. The selected remedy is also the least costly treatment option.
The selection of SVE treatment of the contaminated soil is consistent with program
expectations that indicate that highly toxic and mobile contaminants are a priority for treatment
and their treatment is often necessary to ensure the long-term effectiveness of a remedy.
Preference for Treatment
The Section 121(b) of CERCLA requires EPA to use some form of active treatment (or a
combination of treatment and containment) to address principal threats, wherever this is
practical. A principal threat is material that contains hazardous substances, acts as a reservoir for
further migration of contamination, and presents a risk if exposure occurred. The waste material
contained in the Del Amo pits and the soil beneath the pits are considered a principal threat to
human health due to their high benzene content. Benzene is a highly toxic and highly mobile
contaminant. The statutory preference for remedies that employ treatment as a principal element
is satisfied.
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2.11 Documentation of Significant Changes
There were significant changes to the Proposed Plan's preferred alternative made in this
ROD. The first change is that an alternative method of calculating the interim soil standard was
put forth in the ROD to address the case where significant portions of the soils under the waste
pits are found, during remedial design, not to be amenable to SVE due to low air permeability.
The alternative method (Method B, as presented above) still preserves the overall performance
objective of limiting the incremental groundwater concentration due to soil contamination
beneath the pits to 0.5% of the existing groundwater concentration. This change was made, in
part, to address comments to the proposed plan by the responsible parties and will ensure
protectiveness of the remedy under a wider range of situations.
The second change is that we changed terminology from "short-term performance
standard" to "interim soil standard," and we changed "long-term performance standard" to
"standards to be selected in the final groundwater ROD."
The third change is that groundwater monitoring will not be a required element of this
ROD. In the Proposed Plan, groundwater monitoring was included in the remedy description for
the purpose of monitoring potential changes in groundwater conditions over time due to the
effects of the remediation. Upon further consideration, EPA has determined that the groundwater
contaminant concentrations beneath the pits are currently too high and will remain so in the near
future, and therefore it is not possible to discern the effects of the cap and SVE system on the
groundwater concentrations. If such effects become discernable in the future, groundwater
monitoring will be required to so monitor these effects. Groundwater monitoring in the waste
pits area will be performed as part of the final groundwater ROD. Such monitoring will be
specified in the groundwater ROD.
The final change is that this ROD does not provide for subsequent investigations to
determine whether Pit 1A and adjacent areas should be covered by the RCRA-equivalent cap.
The Proposed Plan stated that additional soil samples may be taken during design to determine
the appropriateness of extending the selected clean-up plan to Pit 1 A. However, the 1984 DHS
report stated that contamination existed below the floor of the 1983-84 excavation. Although
there was no quality assurance provided for these findings, this data is consistent with later data,
taken beneath the other waste pits, that found contamination extending all the way to the water
table. Because remaining contaminated soil still exists and such contamination could negatively
impact the groundwater, EPA has decided, based on further review of available information, that
Pit 1-A and adjacent soil as shown in Figure 3 should be covered with a RCRA-equivalent cap.
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Attachment A
APPLICABLE/APPROPRIATE AND RELEVANT REQUIREMENTS
1. Applicable/Appropriate and Relevant Requirements
The following legal requirements are determined by this ROD to be applicable or
appropriate and relevant requirements for the selected remedial action pursuant to Section
121(d)(2), 42 U.S.C. § 9621(d)(2). Applicable requirements are identified by (A) and
appropriate and relevant requirements are identified by (R).
Only the substantive portions of the requirements identified below are ARARs as
opposed to administrative requirements, including permitting requirements, which are not
ARARs. See 42 U.S.C. § 9621(d)(2) and (e)(l); U.S. EPA, Compliance with Other Laws
Manual-Interim Final at 1-11, 1-12 (EPA 540/G-89/006) (August 1988).
a. Hazardous Waste Management ARARs
(Implementing relevant portions of the California Hazardous Waste Control Act, Cal. Health and
Safety Code Section 2500 el seq. and the Resource Conservation and Control Act, 42 U.S.C. §
6901 et seq. under EPA authorization pursuant to 42 U.S.C § 6926)
It is not yet known whether waste meeting the criteria for designation of hazardous waste
will be generated by the components of the selected remedial action, the SVE system and the gas
collection component of the RCRA-equivalent cap. Consequently, certain of the ARARs
identified below are designated as both applicable and appropriate and relevant to these
components of the selected remedial action. If for example, the SVE system, collects
vapor/water with concentrations of contaminants meeting the hazardous waste toxicity criteria in
the California regulations, then these hazardous waste management ARARs would be applicable
ARARs for the SVE system because that system is collecting and treating hazardous waste.
If, on the other hand, the SVE system handles vapor/water that does not meet the
regulations' criteria for hazardous waste designation, these ARARs would be relevant and
appropriate ARARs for the SVE or gas collection system. The determination that such ARARs
should be relevant is based on: 1) the fact that the waste which was disposed in the Waste Pit
Area would be regulated RCRA hazardous waste if that waste were disposed of today and the
treatment of that waste would be considered treatment of regulated hazardous waste, and 2) that
contamination present in vapors generated by the SVE or gas collection system derives from
waste which, except for the date of disposal, would otherwise have been defined as listed
hazardous waste. See FFS Chapter 2 (Site Characterization-concentrations of hazardous
substances in remaining waste and soils); 22 CCR § 66261.24 (toxicity criteria for benzene); 22
CCR § 66261.31 (hazardous waste from non-specific sources-F003, F005); and 22 CCR §
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66261.33 (discarded, intermediate or off specification commercial chemical products-U019
benzene). See alSQ, 40 C.F.R. § 261.3(c)(2) (derived-from rule) and 40 C.F.R. § 261.3(a)(2)
(mixture rule). The determination that these ARARs are appropriate rests on two factors: 1) the
proximity of the SVE vapor/water collection and treatment system and cap gas collection
treatment system to adjacent residential properties (beyond the area being removed from
residential use by the private non-CERCLA buyout on 204th Street immediately adjacent to the
Waste Pit Area) and 2) the fact that one of the key contaminants, benzene is a known human
carcinogen and is present at high concentrations. See FFS Chapter 2 and Figures 1.3.1-1 + 2.2.1-
3.
The SVE system, excluding the thermal/catalytic oxidizer unit, is defined for purposes of
applying the ARARs identified below as a miscellaneous unit. The thermal/catalytic oxidizer
unit is defined for purposes of applying the ARARs identified below as an incinerator. The
application of these definitions is based on the EPA's reading of how these terms are defined in
the relevant regulations.
22 CCR Part 261 Criteria for Identifying Hazardous Waste (A)
22 CCR § 66262.11 Hazardous Waste Determination by Generators (A)
22 CCR § 66262.34 Accumulation Time (A)
22 CCR § 66264.14 (a), (b) Hazardous Waste Facility General Security Requirements (A)
22 CCR § 66264.15 General Facility Inspection Requirements (A) for the SVE system including
the vapor/water treatment portions of the SVE system
22 CCR § 66264.17 Hazardous Waste Facility General Requirements for Ignitable, Reactive or
Incompatible Wastes (A)
22 CCR § 66264.25 Hazardous Waste Facility Seismic and Precipitation Design Standards (A)
22 CCR § 66264.31 Preparedness & Prevention-Design and Operation of Facility (A)
22 CCR § 66264.32 Preparedness & Prevention-Required Equipment (A)
22 CCR § 66264.33 Preparedness & Prevention-Testing & Maintenance (A)
22 CCR § 66264.34 Preparedness & Prevention-Access to Communications or Alarm (A)
22 CCR § 66264.35 Preparedness & Prevention-Required Aisle Space (A)
22 CCR § 66264.37 Preparedness & Prevention-Arrangements with Local Authorities (A)
22 CCR § 66264.51 Contingency Plan-Purpose and Implementation (A)
22 CCR § 66264.52 Contingency Plan-Content (A)
22 CCR § 66264.53(a) Contingency Plan-Copies of Plan (A)
22 CCR § 66264.54 Contingency Plan-Amendment (A)
22 CCR § 66264.55 Contingency Plan-Emergency Coordinator (A)
22 CCR § 66264.56 Contingency Plan-Emergency Procedures (A)
22 CCR § 66264.111 Hazardous Waste Facility Closure Performance Standard (R) for the
RCRA-equivalent cap (A) for the SVE system
22 CCR § 66264.114 Hazardous Waste Facility-Closure Disposal and Decontamination of
Equipment, Structures and Soils (A) for SVE system
22 CCR § 66264.117 (a), (b)(l)(excluding reference to Article 6) and (d) Hazardous Waste
Facility Postclosure Care and Use of Property (R) for the RCRA equivalent cap (A) for
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SVE system
22 CCR § 66264.119 (a)(rcgarding notice to the local zoning authority), and (b)(l) Hazardous
Waste Facility Post Closure Notices (R) for RCRA equivalent Cap and (A) for SVE system
22 CCR § 66264.171-66264.178 Use and Management of Containers (A) however, the time
period for onsite storage of any hazardous waste is governed by 22 CCR 22262.34
Accumulation Time requirements.
22 CCR § 66264.228 (a)(2)(C), (b)(l), (b)(2), (b)(4), (b)(5), (b)(6), (e)(17), (e)(19), (h), 0), (k),
(m), (o), (p), and (q); Hazardous Waste Facility Closure and Post Closure Care for
Surface Impoundments (R)
22 CCR § 66264.310 (a), (b)(l), (b)(2), (b)(4), (b)(5), (b)(6), © and (d) Hazardous Waste Facility
Closure and Post Closure for Landfills (R)
22 CCR § 66264.341 Hazardous Waste Incinerators Waste Analysis (A/R)
22 CCR § 66264.342 Hazardous Waste Incinerators POHCs (A/R)
22 CCR § 66264.343" Hazardous Waste Incinerators Performance Standards (A/R)
22 CCR § 66264.344(A/R) Hazardous Waste Incinerators Permits (A) (substantive requirement
of subsection (a) only)
22 CCR § 66264.345 Hazardous Waste Incinerators Operation Requirements (A/R)
22 CCR § 66264.347 Hazardous Waste Incinerators Monitoring and Inspection Requirements
(A/R)
22 CCR § 66264.351 Hazardous Waste Incinerator Closure (A/R)
22 CCR § 66264.1101 Containment Buildings-Design and Operating Standards (A)
22 CCR § 66268.1 Hazardous Waste Land Disposal Restrictions (A)
22 CCR § 66268.3 Hazardous Waste Dilution Prohibition as Substitute for Treatment (A/R)
22 CCR § 66268 Article 4 Hazardous Waste Treatment Standards (A) Article 10 Hazardous
Waste - Non RCRA Wastes Land Disposal Restrictions (A)
Article 11 Hazardous Waste-Non RCRA Waste Treatment Standards (A)
b. Air Pollution Prevention Requirements
(Implementing relevant portions of Division 26 of the Cal. Health and Safety Code and the Clean
Air Act, 42 U.S.C § §7401 et seq.)
South Coast Air Quality Management District (SCAQMD)
SCAQMD Regulation IV, Prohibitions
Rule 401 Visible Emissions (A)
Rule 402 Nuisance (A)
Rule 403 Fugitive Dust (A)
Rule 473 Disposal of Solid and Liquid Wastes (A)
SCAQMD Regulation X NESHAP For Benzene (substantive standards only)(A)
SCAQMD Regulation XI, Source Specific Standards
Rule 1150.2 Control of Gaseous Emissions from Inactive Landfills (A)
Rule 1166 VOC Emissions from Soil Decontamination (A)
SCAQMD Regulation XIII, New Source Review
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Rule 1303 Attainment of State and Federal Ambient Air
Quality Standards /A)
Rule 1401 New Source Review of Carcinogenic Air Contaminants
(substantive standards only) (A)
SCAQMD Regulation XIV Toxics (substantive standards only)
2. Legal Requirement of Independent Legal Applicability to the Selected Remedial Action
The selected remedial action may trigger additional legal requirements. These
requirements are not identified as ARARs in this ROD either because such requirements do not
meet the definitional prerequisites to be identified as an ARAR for onsite activities or such
requirements are triggered by offsite activities. See generally. 42 U.S.C § 962l(d). These
requirements could be applicable to portions of the selected remedial of their own legal force,
independent of the provisions of Section 121(d)(2) of CERCLA. The requirements identified
below are presented for the informational purposes only. Any determination the legal
applicability of such requirements ultimately rests with the governmental entity charged with
implementing and enforcing compliance with such requirements.
CERCLA Section 121 (d)(3) requirements regarding offsite disposal of Superrund Waste
CERCLA Section 103 notification requirements and comparable provisions of California law
California Porter Cologne Act (implementing both state law and the federal NPDES program)
concerning issuance of waste discharge requirements for point source discharges of water from
the Waste Pit Area to offsite storm sewer conveyances
Los Angeles County Sanitation District Wastewater Ordinance, as amended, concerning
discharges of water from the Waste Pit Area to the LACSD sanitary sewer system offsite
Provisions of Title 22 of the California Code of Regulations relating to offsite shipments of
hazardous waste, including but not limited to manifest requirements, transportation requirements
and offsite disposal/treatment requirements
Federal and State Occupational Health and Safety Act requirements
3. Guidance and Advisories To Be Considered
Certain non-promulgated advisories or guidance that are otherwise not legally binding
may be identified in a ROD as guidance or advisories "to be considered" (TBC) particularly to
aid the design and implementation of CERCLA remedial actions. For this Record of Decision,
the advisories and guidance set out below are determined to be TBCs for the selected remedy:
Hydrologic Performance of Landfill Performance (HELP) Mode, Vol I and II, EPA/530-SW-84-
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009 and EPA/530-SW-84-010
Landfill and Surface Impoundment Evaluation-EPA Technical Resource Document
Evaluating Cover Systems for Solid and Hazardous Waste-EPA Technical Resource Document
SCAQMD Best Available Control Technology (BACT) Guidelines Document
EPA Region IX Preliminary Remediation Goals (PRGs) 1996
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
RECORD OF DECISION
jot
Del Amo Waste Pits Operable Unit
Del Amo Facility Proposed Superfund Site
Los Angeles, CA
PART IV - RESPONSE SUMMARY
(ATTACHMENT B)
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TABLE OF CONTENTS
Part IV—Response Summary Attachment B
RESPONSE SUMMARY page 1
I. RESPONSES TO WRITTEN COMMENTS page 2
Subject: Funding for Research in Bioremediation 2
Subject: Long-term Effectiveness and Permanence of the
Selected Remedy 4
Subject: Uncertainties and Inadequacies in Baseline
Human Health Risk Assessment Process 8
Subject: Letter from Shell Oil Company Regarding SVE
Design and Cost-Related Issues 9
Subject: Letter from Dames & Moore Regarding
Various Issues, as Noted 15
Subject: Letter from California Department of Toxic Substances
Control (DTSC) Regarding the Final Focused Feasibility
Study Report, Del Amo Waste Pits Area, Geologic,
Engineering, and Toxicologic Issues 19
II. RESPONSES TO FORMAL VERBAL COMMENTS MADE
DURING THE PUBLIC MEETING HELD JANUARY 29,1997 page 24
III. RESPONSES TO INFORMAL VERBAL COMMENTS
MADE DURING QUESTION AND ANSWER PERIOD
DURING THE DEL AMO PUBLIC MEETING HELD
JANUARY 29,1997 page 26
REFERENCES (1-13)—Correspondence and Transcripts of Proceedings
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Response Summary
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Response Summary
This response summary presents the U.S. Environmental Protection Agency's (EPA)
responses to the public comments on the Del Amo Waste Pits Area Proposed Plan. In
December 1996, the EPA published the Proposed Plan for the Waste Pits Area of the Del
Amo Superfund site located in Torrance, California. The Proposed Plan announced
EPA's proposed remedy for the Waste Pits Area and requested written and oral public
comments on this plan. A 60-day public comment period began December 16,1996, and
closed on February 13,1997. A public meeting was also held on January 29,1997, for the
purpose of answering questions regarding the preferred remedy. Written and oral
comments from the attending public were collected at this meeting.
The responses have been divided into the following categories:
I. Responses to written comments.
II. Responses to formal oral comments made during the public meeting held on
January 29,1997.
IE. Responses to informal oral comments made during the question and answer session
of the public meeting held on January 29,1997.
The response to comments are also organized by subjects under Category I. Copies of
the original letters and the transcript of the proceedings of the January 29,1997, public
meeting are included in Attachment A.
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I. Responses to
Written Comments
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I. Responses to Written Comments
Subject: Funding for Research in Bioremediation
1. Letter from Cynthia Babich titled; Comments from the Del Amo Action Committee
Presented at the Public Meeting January 29.1996; no date (Reference No. 1)
EPA's Response:. Of the many issues raised in this letter, three categories stand out as
being directly related to the selected Waste-Pits remedy, which is the focus of this
response summary: (1) the desire for a permanent remedy that is highly effective in the
long-term so that future generations do not inherit the problem and people are not
exposed to the waste pit contaminants; (2) a desire to see more research performed on
bioremediation technologies (which utilize microorganisms to degrade contaminants),
preferably by the PRPs; and (3) concerns about current emissions from the pits and
about the soil vapor extraction system with respect to emissions from beneath the cap.
EPA will address the concerns about bioremediation and emissions/SVE in this section.
The commenter's concerns about permanence and long-term effectiveness are addressed
in the next subject category.
The commenter expressed a desire to have more research on bioremediation
technologies and to enhance the potential for evolving technologies.
EPA evaluated the potential application of ex-situ bioremediation at the Del Amo Waste
Pits and concluded that it was less effective than the alternative selected in this ROD.
EPA also considered the potential application of in-situ bioremediation but found that
the technology has not evolved to the point where it is implementable for this site.
However, EPA will consider this technology again, at the 5-year review period, if the
selected remedy is not protective.
Bioremediation is a promising technology for many types of wastes and contamination
encountered in the Superfund program, and we share the commenter's sentiment that
research and development of lower-cost, permanent, and effective cleanup technologies,
including bioremediation, is beneficial throughout the EPA Superfund program and the
private sector. Much research in these areas is already under way. At present, however,
bioremediation technology has not evolved to the point at which it would be useful and
effective on the specific waste found in the Del Amo Waste Pits. EPA wishes to make
clear why bioremediation was screened out as a remedial alternative in this case.
The Del Amo Pits site poses some special problems with bioremediation. As shown in
the focused feasibility study, excavating the material could potentially prove difficult
and could potentially create short-term risks. As discussed more thoroughly in the
response to the next comment, in order to avoid these problems, it would be necessary
to bioremediate the waste in situ (in place) without excavating it. In most cases, in-situ
bioremediation technologies involve moving fluids and substances through the waste
material. These substances, including nutrients, are necessary for the microorganisms to
grow and thrive. The waste material in the pits has very little void space, or porosity,
making it almost impossible to move fluids through it.
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In a site like the Del Amo Waste Pits, where it is almost impossible to move fluids
through the material, it is also almost impossible to supply the microorganisms with the
substances they need to thrive and consequently break down the contaminants. This
limitation renders in-situ bioremediation of the waste infeasible. Therefore, one of the
complicating factors at the Del Amo Pits site is the difficulty of getting the things
microorganisms need for food, breathing, and growth.
Microorganisms need certain things to grow; they need food and they need to breathe.
The foods microorganisms use are called electron donors. The substances micro-
organisms breathe are called electron acceptors. This is because the chemical reactions
that microorganisms perform to obtain energy move electrons from the electron donors
(food) to the electron acceptors (breathing substance). Many microorganisms breath
oxygen. Other microorganisms breathe what we call alternative electron acceptors such
as nitrate, sulfate, iron, or carbon dioxide. The foods microorganisms use include many
organic chemicals and may include the chemicals that are in the waste material. In
some cases, which we call cometabolism, microorganisms eat one substance as food and
accidentally degrade another substance just because the other substance is there. Many
waste chemicals fall into this cometabolism category in that the organisms cannot use
the waste chemicals as food but will degrade the chemicals if there is food available.
Microorganisms also need other chemicals to grow. Microorganisms have proteins and
proteins have nitrogen. Therefore, microorganisms need a nitrogen source to produce
the proteins they need to grow. Most microorganisms cannot use the molecular
nitrogen that is found in the atmosphere but must have nitrogen in the form of
ammonia or nitrate. Therefore, ammonia or nitrate needs to be provided during
bioremediation for microorganisms to grow. Microorganisms also need other nutrients
such as phosphate, sodium, potassium, magnesium, calcium, and other minerals to have
a balanced, healthy diet that allows their growth to be optimized. Another problem in
the pits is the high concentrations of contaminants in the waste itself. Numerous
studies show that many man-made chemicals are toxic to microorganisms at high
concentrations just as they are toxic to people at high concentrations. In most cases
where bioremediation is shown to work, the contaminant compounds are present at
dilute concentrations in soils or water. The focused feasibility study shows that
concentrations of the compounds in the waste material are very high. If organisms
could be found or created that can live in and degrade such high concentrations of
contaminants as those found in the waste material, and transport technologies could be
developed that could transport the organisms with electron acceptors (oxygen, nitrate,
ferric iron, sulfate) and nutrients into the waste material and distribute them throughout
the waste material, then bioremediation may become a feasible alternative. At this time,
however, such organisms and technologies do not appear to exist.
Some biological degradation of waste materials may already be occurring in soils
surrounding me wastes or, perhaps, in the waste itself, although at very low rates. The
presence of hydrogen sulfide is possible evidence of biological transformations. When
sulfate is used as an electron acceptor by microorganisms, hydrogen sulfide is
produced. Hydrogen sulfide was never disposed of at the Waste Pits but exists there
today. Therefore, hydrogen sulfide might be produced by microorganisms which could
be using waste materials as electron donors (food). The construction of a cap will not
stop any biological degradation that might be occurring. Additionally, the SVE system
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will draw oxygen into the subsurface which can possibly increase the rate of biological
degradation in soils surrounding the pits where pollutant concentrations are more
dilute than in the waste materials. However, even if such degradation is occurring, it is
not occurring at a rate sufficient to rely upon it as a remedial action.
In light of this, EPA believes Alternative 4 provides the best available solution to protect
public health and the environment.
Finally, EPA would like to clarify a few points made in the comment letter pertaining to
current exposures from the pits and the SVE system.
The ambient air study that evaluated possible emissions from the Waste Pits found that
it was not possible to distinguish between the background air quality in the region and
chemicals that could have been emitted from the Waste Pits. Additionally, dispersion
modeling was conducted which evaluated the concentrations of chemicals at the fence
line should emissions from the Waste Pits be occurring. These studies indicated that
possible concentrations at the fence line would not create unacceptable health risks in
accordance with EPA policy.
The commenter also expressed concern that vapor might build up under the cap. When
the tops of the pits are sealed with an impermeable liner, it may become possible for
vapors to accumulate beneath the liner. These accumulated vapors, if not controlled,
could potentially vent to the atmosphere periodically, like a burping effect, in events
where relatively high concentrations of vapors are emitted at one time, resulting in odor
nuisance and, possibly, short-term hazards. Rather than allowing any accumulated
vapors to vent to the atmosphere, Alternative 4 includes a vapor collection system. This
does not mean that vapors are currently being emitted at such concentrations as to cause
an unacceptable health risk to persons at the fence line. In fact, the studies conducted
indicate the opposite, that any vapors potentially being emitted at this time are at such
concentrations that risks at the fenceline are not unacceptable by EPA standards.
Alternative 4 does not include any groundwater extraction. Alternative 4 includes only
Soil Vapor Extraction (SVE). SVE removes vapors from the soils above the
groundwater. The groundwater remedy will be selected following completion of the
groundwater investigation.
Subject: Long-term Effectiveness and Permanence of the Selected Remedy
1. Letter from Randall E. Hartman dated January 9.1979 (Reference No. 2)
EPA's Response: EPA appreciates the concerns listed in the letter regarding long-term
effectiveness and permanence of the selected remedy. EPA's consideration of these
concerns was incorporated into the evaluation of alternatives and the selection of
Alternative 4. EPA strongly shares the commenter's concern that the remedy be
permanent and protective of human health in the long term. At the same time, it is
important to understand that, in making its selection of a remedial alternative, EPA
must consider nine factors, only two of which are permanence and long-term
effectiveness. EPA must also consider protectiveness of human health and the
environment, compliance with other environmental laws and regulations, short-term
effectiveness, implementability, cost, and state and community acceptance. EPA's
selection of an alternative is based on a balancing of all of these criteria.
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That stated, it is true that the most immediate degree of permanence and long-term
effectiveness would be derived from destroying the waste in the pits completely, either
by removing it first before treating it or treating it while still in place. Alternative 4 is
permanent and effective, but it does require long-term maintenance to make sure it
remains effective. In contrast, Alternative 5 provides a relatively immediate
permanence that is not subject to the need for future maintenance.
EPA studied both excavation as well as the possibility of treating the waste in place.
Unfortunately, the studies conducted to date indicate that there are not technologies
available that can destroy the waste safely and effectively without excavating. This is
because technologies for treating the waste in place generally require that various
substances infiltrate or be circulated through the waste. The waste in the pits is highly
viscous and has low permeability; in short, substances cannot practically or effectively
be moved through it. Other technologies which might, for instance, heat the waste to
make it less viscous, would create problems with volatilizing and releasing chemicals in
the waste near to the neighborhood. EPA considered these problems and the potential
for complications with implementability and short-term effectiveness and determined
that the problems outweigh the benefits of in-place treatment. Therefore, EPA screened
out the in-place treatment options.
EPA very seriously considered the excavation option, Alternative 5. Unfortunately,
many complications could arise with respect to excavation at the Del Amo Waste Pits.
The first of these is the potential hazard involved, both to the workers and to the nearby
residents, in trying to remove the waste from the pits over an extended time period. It is
true that in principle, excavation could be safely performed under an enclosure, but the
proximity of the pits to the residential area raises the specter of uncertainty regarding
considerations. The VOC emissions from the waste material during excavation are
expected to be most severe and, should vapor control equipment fail during
construction, the public could be at substantially greater risk than if the material were
left in place. Also, as the commenter points out, wastes being removed from the site
have to be taken somewhere else. While it is possible to incinerate the wastes to very
low and safe residual levels, this still requires that the waste be transported from the site
to another area. While an incinerator could be built near the pits themselves and could
be operated safely, EPA rejected this option.
Finally, there is the cost of excavation and incineration, which is more than ten times as
much as Alternative 4, capping plus soil vapor extraction (SVE). While it is tempting to
demand that the waste be excavated regardless of the cost, the cost differences are
dramatic and they must be considered and balanced with all the other criteria. In this
case, this cost difference reinforces the issues concerning implementability and potential
short-term risks and uncertainties just described.
If EPA did not believe that Alternative 4 would be protective of human health, then
EPA would be selecting the excavation alternative. However, the cap and SVE will fully
protect persons surrounding the pits from exposure to waste pit contaminants, as well
as eliminate the pits as a significant source of groundwater contamination. Moreover,
because Alternative 4 calls for the long-term operation and maintenance of the SVE
system and cap, this protection will be permanent. Thus, on balance, while the
excavation option would have required less long-term maintenance, EPA believes that
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the selected alternative will be just as effective at protecting human health at a cost that
is one-tenth as much, and is therefore the appropriate remedy in this case.
2. Letter from Lawrence Smith dated January 21.1997 (Reference No. 3)
EPA's Response: Although Alternative 4 does not treat waste material in the Waste
Pits, the SVE system does treat contaminated soils. Because of this treatment of
contaminated soils, the alternative will reduce toxicity, mobility, and volume of
contaminated media associated with past waste disposal practices. EPA shares the
concern that treating the waste material itself would be a more favorable alternative
because of the long-term permanence and the greater reduction in toxicity, mobility,
and volume. For further discussion of this topic, the commenter is referred to the
response to Randall E. Hartman above.
EPA concurs that the SVE system may need to be maintained indefinitely to order to
adequately capture VOCs that migrate from the waste material into surrounding soils.
Although the Proposed Plan was not specific regarding the operational details of the
SVE system, a monitoring system will be installed with the SVE system which will be
used to assess when the SVE system needs to be re-started after it has been shut down.
It is not being predicted at this time that the SVE system will be shut off after 5 years.
Rather, it was intended that the public be aware that the SVE system may not operate
continuously forever, but after some time, say 5 years, the SVE system may operate
intermittently to capture whatever VOCs migrate at that time from the waste into
surrounding soils. The SVE system will operate continuously until the monitoring
system indicates that soil and soil vapor concentrations are below the interim soil
performance standards. This period of time could be on the order of 5 years, but may be
longer or shorter depending on subsurface conditions during operation. When soil
concentrations drop below the performance standards and the SVE system is shut
down, subsurface monitoring will continue and, should performance standards be
exceeded due to migration from the Waste Pits, the SVE system will be restarted.
EPA anticipates that the SVE system will be capable of removing contamination in soils
to the part per billion level in the coarser materials. However, the interim soils cleanup
standard EPA is selecting in this ROD is tied to the existing groundwater contamination
level. This is appropriate because the groundwater contamination levels under the pits
are already high. The ROD specifies that the Waste Pits will never be able to increase
the existing concentrations by more than 0.5 percent. If, in the course of selecting a
groundwater remedy, EPA selects a highly stringent cleanup standard for groundwater,
then the cleanup level for the soils under the pits will be reduced to a more stringent
level to ensure that standard can be met for groundwater. In the interim, the current
soil standard will ensure that the amount that the pits can contribute to groundwater
remains insignificant relative to what is already there. At present, this level is in the
rangeof 5 parts per million in soil.
In the preliminary design prepared for the feasibility study, a catalytic oxidation system
was used to treat the extracted vapors. However, the final selection of the vapor treat-
ment system to be used will be made during the remedial design process. A catalytic
oxidation system uses heat and a catalyst to destroy organic chemicals. The catalyst is
typically a reactive metal surface that speeds the destruction of organic chemicals.
Using a catalyst lowers the temperature required to destroy the chemicals, reduces the
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production of nitrous oxides, and increases the amount of organic chemical destruction
that occurs during the process. Such systems are in place throughout Southern
California to treat vapors extracted from VOC contaminated soils. Any liquids that are
produced by the system will be collected, characterized, and transported to an
appropriately permitted offsite commercial treatment or disposal facility. The catalytic
oxidation system will meet all South Coast Air Quality Management District
(SCAQMD) source review criteria and the effects on air quality will be in accordance
with SCAQMD rules and regulations and State RCRA regulations.
The alternative of bioremediation was considered during the initial stages of the
feasibility study process. Laboratory studies were conducted with waste material to
assess the ability of microorganisms to degrade the material. The laboratory studies
indicated that bioremediation would not be a feasible alternative. For the same reasons
that SVE is infeasible in the waste material, a positive pressure system would also be
infeasible. The waste materials are a tar-like, viscous substance which have little
internal void space or porosity. Because of this, vapors cannot move through the waste
materials. Hence, it is impossible to extract vapors from or push air through the waste
materials.
3. Comment from Barbara Stockwell dated January 29.1997 (Reference No. 4)
EPA's Response: EPA appreciates the concerns in this comment regarding the
long-term effectiveness and permanence of the selected remedy. The reader is referred
to EPA's response to this issue above in the response to Randall E. Hartman. In short,
while Alternative 5 would confer certain benefits with regard to permanence and
long-term effectiveness, Alternative 4 is, on balance in consideration of all the remedy
selection criteria, the most appropriate remedy in this particular case. With respect to
bioremediation, the reader is referred to EPA's response to Ms. Cynthia Babich on this
issue, above. Bioremediation was considered during the initial stages of the feasibility
study and a laboratory study was commissioned. The laboratory study indicated that
bioremediation would not be feasible for these waste materials. In light of these issues,
EPA believes that the selected alternative provides the best protection of the public from
the waste materials that can be devised with available technologies.
4. Comment from Robert Frame dated February 4.1997 (Reference No. 5)
EPA's Response^In accordance with Section 121(c) of the Superfund law, EPA intends
to continue to evaluate the performance of this remedy every 5 years after the remedy is
implemented. As technological innovations arise, there may be opportunities to explore
utilizing such innovations.
5. Letter from the Toxics Assessment Group dated February 13.1997; Summary and
Let's Get Something Out of This Situation (Reference No. 6)
EPA's Response: EPA appreciates the concerns regarding the long-term effectiveness
and permanence of the remedy. The reader is referred to EPA's response to Randall E.
Hartman on this issue, above. The commenter also expressed concerns about the
consideration of cost in EPA's remedial decision-making. EPA is required to consider
cost as one among nine criteria in its decisionmaking process. However, as stated in our
response to Mr. Hartman, in this case, the dramatically higher cost of Alternative 5
merely serves to reinforce several other factors working against that alternative.
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Alternative 4 does require long-term maintenance that Alternative 5 does not require.
However, on balance, EPA believes that this added benefit in permanence and
long-term effectiveness does not justify increasing the cost of the remedy by 10 times,
when it is considered that (1) Alternative 4 provides equivalent protection of human
health, (2) Alternative 4 can be designed and implemented using monitoring and
controls in a manner such that long-term effectiveness and permanence are assured, and
(3) Alternative 5 presents a host of implementability and short-term effectiveness
problems (risks and uncertainties while the action is executed), as discussed above in
our response to Mr. Hartman. Accordingly, in considering all the remedy selection
criteria mandated by law and the site-specific situation at the Waste Pits, EPA believes
that Alternative 4 is the most appropriate remedial action for the Waste Pits.
Del Amo is, as the commenter suggests, a prime example of a site in need of a
cost-effective remediation technology that can destroy the waste safely. Bioremediation
holds much potential for organic wastes such as those at Del Amo. However, bio-
remediation has been evaluated at this site and does not appear feasible. A more
detailed description of some of the issues involved with bioremediation at Del Amo has
been provided in response to Cynthia Babich's letter, above. Implementing
Alternative 4 would not prevent bioremediation or other remedial technology from
being considered for use at Del Amo should promising technologies become available at
a later date.
Subject: Uncertainties and Inadequacies in Baseline Human Health Risk
Assessment Process
1. Letter from the Toxics Assessment Group dated February 13.1997; Comments on the
Baseline Health Risk Assessment (Reference No. 6)
EPA's Response: EPA acknowledges that there are some uncertainties in the baseline
human health risk assessment process, but it is the only quantitative tool available to
assess what, if not all, of the risks may be arising from the presence of a hazardous
waste site. EPA is sponsoring significant research into risk assessment to continually
improve this tool to take into account more of the factors described by the comment and
to more completely assess the effects of hazardous chemicals on human and ecological
health. This does not mean the existing tool has little or no value. Risk assessment is
grounded in valid scientific principles and makes use of these principles in a logical,
consistent fashion to estimate what the likelihood is of a person experiencing an adverse
health effect due to exposure to a contaminant.
The commenter is correct to assert and list several of the uncertain factors associated
with risk assessment. However, EPA risk assessments address these uncertainties by
introducing conservative safety factors on the toxicological data. For example, for
noncancer effects, if studies show that no adverse health effects have been observed
when persons or animals are exposed below a certain concentration, EPA does not
simply use that concentration as the "safe" level. Rather, a safety factor is introduced of
at least 100 times, and sometimes as much as 5,000 times. The more uncertain EPA is
about the particular toxicological data, the greater the safety factor used.
When estimating the exposure that persons may have, conservative assumptions are
again used. In the case of the Waste Pits, samples of volatile emissions were taken from
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all over the pits. In some areas, the emissions were greater than in other areas and in
many areas there were no measurable emissions at all. However, when EPA calculated
the risk, it assumed that the entire area of the pits were emitting volatiles at the highest
concentration ever found anywhere on the pits. This is dearly a highly conservative
treatment of the data; that is, it would err on the side of higher risk estimates. Then,
EPA assumed that residents were living, not in houses across the street from the pits,
but right at the fenceline of the pits, and that they stayed at the fenceline, breathing and
touching the soil, all day and all night for 30 years. Even with all of these conservative
assumptions, the noncancer risks due to the Waste Pits for a person living at the
fenceline were calculated to be 2/5, where 1 and above indicate unsafe levels. The
cancer risks were on the order of two in 1 million. These values mean that there is a
2 in 1 million chance that an individual exposed to a chemical under conservative
exposure assumptions will contract cancer as a result of that exposure. These values are
significantly lower than the national average of one in four persons contracting cancer
in their lifetime.
Finally, the commenter states that the reality is that people in the neighborhood are sick
and, therefore, it does not matter what a risk assessment says. There is no dispute that
the persons in this community have experienced health problems. EPA is concerned, as
we believe the community should be concerned, with finding what is, and what is not,
causing those health problems. The finding by the risk assessment that there are no
unacceptable levels of exposures to chemicals from the Waste Pits near the ground
surface does not negate or deny the existence of health effects. It merely states that,
based on the available data, the Waste Pits as they exist today do not appear to be the
cause of unacceptable exposures. Such a finding does not rule out the possibility that
unacceptable exposures to Waste Pits contaminants may have existed in the past, nor
that some other sources of contamination may exist and that these may be causing the
health effects experienced by the community.
Subject: Letter from Shell Oil Company Regarding SVE Design and Cost-Related
Issues
1. Letter from Shell Oil Company dated February 3.1997. First comment (Reference
No. 7)
EPA's Response^ The design details for the cap in the Proposed Plari, which are cited
by the commenter, are provided to illustrate the remedy and are not intended to specify
the final design of the cap. Such details will be finalized during the design stage and
review process, such that RCRA performance criteria for caps will be met. This process
will ensure that the remedy is designed to meet the remedial objectives and ARARs.
2. Letter from Shell Oil Company dated February 3.1997. Second comment (Reference
No. 7)
EPA's Response: There is no description of the SVE system later in the Proposed Plan or
in the supplement to the Proposed Plan specifying the top of well screens to be 5 feet
below the bottoms of the Waste Pits. Regardless, the ROD does not specify a depth for
the well screens. The final design details will be selected during the remedial design
and review process. This process will ensure that the remedy is designed to meet the
remedial objectives. The ROD requires that the influence of SVE extend from the
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bottom of the Waste Pits to the capillary fringe; however, it acknowledges that pulling
contaminants directly off the water table or out of the pits is not desirable and specifies
that the design account for this and reduce the pneumatic influences near the bottom of
the pits and the top of the capillary fringe. At the same time, it explicitly does not
require that these influences be reduced to zero; rather, that they be reduced enough to
reasonably reduce the pulling effect that may occur. It may not be possible to install
SVE such that no such pulling occurs at all. The goal of SVE shall be to reduce soil
concentrations to the interim soil standard in as much of the soils under the pits as
possible; physical and design constraints will then be taken into account.
3. Letter from Shell Oil Company dated February 3.1997. Third comment (Reference
No. 7)
EPA's Response: The cost estimate for Alternative 4 in the FFS is different from the one
provided in the Proposed Plan. EPA requested and received a cost estimate from
Dames & Moore, author of the FFS report on behalf of Shell Oil and Dow Chemical, for
a SVE system that is preferred by EPA. This cost estimate was provided in a fax memo
from Dave Laney, Dames & Moore, to EPA dated 11/6/96 (Reference No. 8), and is
evaluated in the Administrative Record. The preferred SVE system is one that can be
applied to both coarse- and fine-grained soil layers.
4. Letter from Shell Oil Company dated February 3.1997. Fourth comment
(Reference No. 7)
EPA's Response: A key assumption in EPA's nine criteria evaluation of the alternatives
was the absence of people residing on 204th Street immediately adjacent to the waste pit
property. Should this assumption fail, EPA would need to evaluate the impact on the
continued validity of the analyses supporting the selection of remedial actions for the
Waste Pits. The current evaluation of alternatives in the feasibility study, Proposed
Plan, and ROD does not include the cost of purchasing property or permanently
relocating people.
5. Letter from Shell Oil Company dated February 3.1997. Fifth comment (Reference
No. 7)
EPA's Response: EPA believes that the length of time required for the SVE system to
operate to meet interim soil performance standards cannot be predicted with a high
degree of accuracy at this time. We agree with the commenter that such time estimates
will have to be verified by data collected during the remedial design phase. The length
of time the SVE system will have to operate continuously before interim soil standards
are attained will be dependent on the SVE performance monitoring results. Such time
can be less than or greater than 5 years. However, while this time may vary due to
physical limitations, the 5-year period was stated in the Proposed Plan with the
intention that the SVE system be designed to achieve interim soil standards in about
5 years, if it is possible to do so. Thus, the system should not be intentionally designed
to take longer to achieve interim soil standards for reasons other than physical
constraint.
Additionally, monitoring will take place indefinitely. Should performance standards be
exceeded after the SVE system is shut down, the SVE system will be re-started and
operated until performance standards are once again met.
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6. Letter from Shell Oil Company dated February 3.1997. Second page of comments.
second paragraph (Reference No. 7)
EPA's Response: This comment pertains to EPA's specification that the SVE system
shall be applied to both coarse-grained and fine-grained soils under the Waste Pits.
EPA has addressed this comment by making changes in the ROD not originally
reflected in the Proposed Plan. First, the ROD acknowledges that there is uncertainty
regarding the continuity of coarse-grained units across the site and the ability of SVE to
be effective in fine-grained units where air permeability may be low. There is
insufficient information today to indicate the exact distribution, not only of
"fine-grained" materials, but where those fine materials are so fine that they would
compromise the effectiveness of SVE. However, EPA has agreed with the commenter
that there is significant soil heterogeneity and there are likely to be some soil areas
under the pits that will not be amenable to SVE. At the same time, we recognize that the
data necessary to define these areas spatially with some precision will have to be
obtained in remedial design.
If the size of the areas not amenable to SVE turns out to be significant, it will pose a
problem for the interim soil standards. The interim soil standards were selected in the
focused feasibility study using relatively simple calculations (based on an "overall"
attenuation factor) and the assumption that all of the soil under the pits will be cleaned
to a certain fixed level. If some of the soil is cleaned to that level, but other portions are
left at higher concentrations, then the overarching standard of keeping the Waste Pits'
incremental groundwater contribution below 0.5 percent of the existing groundwater
concentrations would not be met. The areas that were not cleaned would contribute
more contamination than the calculation assumed, resulting in a greater incremental
impact than the standard would allow. For this reason, EPA must start with the
assumption that SVE will be applied to all soils under the pits, and cannot agree to
specify in the remedy that SVE be applied only to the coarse-grained materials.
To resolve this issue, one must address the physical constraint of potentially not being
able to apply SVE to certain soils of low air permeability, while still meeting the overall
goal of limiting the incremental contribution from the pits to 0.5 percent of the existing
groundwater contamination. To do so, EPA has modified the ROD to provide for two
means of calculating the interim soil standard. In the event that the extent of the soils
not amenable to SVE is found to be insignificant, then SVE shall be applied to all soils
under the pits, as in the Proposed Plan, and the soil cleanup standard shall be calculated
as shown in the Proposed Plan, based on an overall attenuation factor of 10. In the
event that the areas not amenable to SVE are significant, a performance-based approach
shall be used, holding the 0.5 percent incremental contribution standard as the driving
factor. In this case, the use of the "overall" attenuation factor shall be abandoned. A
modeling approach shall be established, during remedial design, that will calculate both
the contributions from areas to which SVE is applied and the contributions from areas to
which SVE cannot applied. The areas to which SVE can be applied will be cleaned to
whatever level is necessary such that the total contribution from the pits, as calculated
by the model, cannot cause an incremental groundwater contribution in excess of
0.5 percent of the existing groundwater concentration.
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Subsequently, as stated in the supplement to the Proposed Plan, the exact width and
depth of the SVE treatment zone will vary somewhat from location to location
depending on the soil conditions and contaminant concentrations and distribution.
7. Letter from Shell Oil Company dated February 3.1997. Second page of comments.
third paragraph (Reference No. 7)
EFA's Response: Simply stated, the "attenuation factor," as it is used in this calculation,
defines what fraction of a given soil concentration will be found in groundwater under
that soil. The attenuation factor used in the remedial selection should ultimately reflect
conditions at the site that control fate and transport of VOCs through the soil. In EPA's
Proposed Plan, a single "overall" attenuation factor was used, representing the
combination of many physical parameters that differ spatially at the site. Many of the
values of these parameters are uncertain and our knowledge about them is limited. This
approach is highly simplifying and introduces a high level of uncertainty in the estimate
of the value of the overall attenuation factor. It is indirect in that it attempts to broadly
evaluate a reasonable maximum and minimum for the overall factor without directly
calculating or considering the parameters of which it is composed. The use of this
simple approach is acceptable only if (1) its limitations are acknowledged and
incorporated into any decision using the attenuation factor, (2) one does not attempt to
refine the value of the attenuation factor with this approach beyond what is technically
supportable, and (3) one uses a reasonably conservative value within the range of
possible attenuation factors, given the uncertainties involved.
Given this, EPA has determined that a reasonably conservative value for this factor is
10. If one were to try to refine the value of the true attenuation factor (by increasing its
accuracy or confidence in its value), as the commenter seems to want to do, one would
have to take the more complicated approach of directly deriving the value of the
attenuation factor by evaluating the physical parameters of which it is composed, and
performing more sophisticated calculations and/or modeling. The commenter suggests
"using different overall attenuation factors for different soil types at various distances
above the groundwater." This more complex approach could be supportable, but is
tantamount to abandoning the concept of "overall attenuation factor" and performing
the fully-detailed calculations and/or modeling that would be necessary to evaluate
contaminant movement in the vadose zone utilizing all physical parameters as these
parameters continuously vary spatially. This effort was not performed by the Focused
Feasibility Study.
As stated above, EPA has introduced in the ROD a second method for computing the
interim soil standard in the event that SVE cannot address significant areas of soil due
to low air permeabilities. In this case, the simple approach of an "overall attenuation
factor" is abandoned because it is no longer technically appropriate. Instead, a more
sophisticated modeling approach would be required to evaluate the actual value of the
physical parameters and the possible movement of contaminants from soils to
groundwater. Models such as VLEACH could be used for this purpose.
The commenter references 100 as a more appropriate attenuation factor "since it is often
assumed for evaluation of waste at RCRA facilities." While a value of 100 may have
been assumed for an attenuation factor at some sites, EPA is not aware of any standard
or basis by which this value is intended to be used for all sites. In particular, use of a
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RCRA facility attenuation factor may not be appropriate in this instance given the
significant releases of hazardous substances that have occurred over time from the
Waste Pits. By contrast, RCRA facilities are designed and regulated to prevent releases
of hazardous substances - particularly the kind of significant releases that have occurred
at the Waste Pits. Using an "overall" attenuation factor is a simplification of many
physical parameters that differ greatly between sites and even within each site, and the
implication that a single value such as 100 applies to all sites, and thereby should apply
to the Waste Pits, is without merit.
8. Letter from Shell Oil Company dated February 3.1997. Second page of comments.
fourth paragraph (Reference No. 7)
EFA's Response^ The commenter states that some engineering disciplines consider less
than one order of magnitude difference in the value of any parameter as negligible. The
implication of this statement is that engineering disciplines have defined the words
"small" or "insignificant" absolutely and regardless of context as being "less than an
order of magnitude." Such an implication would be untrue. Similarly, less than one
order of magnitude of difference in hydraulic conductivity of an aquifer may be
negligible when estimating the yield of a water supply well, but this order of magnitude
difference is not irrelevant to evaluating whether an increase in groundwater
contamination is negligible. "Significance" is relative: there is no "engineering" basis to a
claim that "significant" can be defined outside of its context.
The Soil Vapor Extraction system for the Waste Pits is a source control measure. That is,
it seeks to remove the Waste Pits as a source of additional contamination to
groundwater. On this basis alone, it could be argued that EPA should select a soil
cleanup standard such that incremental contribution from the pits would not exceed the
value of a drinking water standard. EPA has decided not to impose so stringent a
standard because of the very high levels of contamination already in the groundwater.
However, the goal of the SVE source control is to make the incremental contribution of
the pits truly insignificant in relation to the existing groundwater contamination, so as
to not counter any groundwater remediation efforts and ensure that the groundwater
contamination does not worsen. We disagree that continuing to allow the pits to
contaminate the groundwater by 10 percent of the existing groundwater concentration
would be an insignificant contribution. While there is no magic calculation that will
allow one to absolutely define 0.5 percent as "insignificant," EPA believes that using this
percentage is justified in that it is small while still permitting a standard for soil as much
as 5000 times less stringent than what would be permitted if drinking water standards
were the basis from which the soil standard was derived, and it mitigates the
uncertainties associated with determining the true incremental groundwater
contribution caused by any given soil concentration.
9. Fax Letter from The EOF Group dated February 13.1997 (Reference No. 9)
EPA's Response;
1- Stringency of Clean-up. EPA disagrees that the interim soil standard is overly
stringent. In earlier evaluations, EPA was considering requiring an application of SVE
that would have cleaned the soils under the pits such that the remaining contamination,
if it entered the groundwater, would not raise the groundwater contamination by more
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than the value of the MCL (1 ppb benzene). EPA's Proposed Plan recognized that the
groundwater beneath the pits was already highly contaminated (up to 500,000 ppb
benzene), and it instead set the soil standard, on an interim basis, so as to limit the
incremental Waste Pits contribution to groundwater to 0.5 percent of the existing
groundwater concentration. EPA's Proposed Plan relaxed the clean-up standard
considered earlier because the additional contaminant contribution to the groundwater
from the pits would still be a tiny amount compared to the existing groundwater
contamination. (If the existing groundwater concentration is reduced in the future, the
SVE clean-up standard will be lowered as well, so as to remain 0.5 percent of the new
groundwater concentration). For these reasons, EPA believes it's interim soil standard is
not overly stringent or "intensive;" in fact, it is already as much as 5000 times less
stringent than many of EPA's other source control remedies for which cleaning-up
groundwater to the MCL is the goal.
2. Extent of Clean-up. Contrary to the suggestion of the commenter, this remedy does
not include a full soil cleanup, rather, it seeks to contain the contamination, preventing
it from reaching groundwater in significant quantities. The quantity of contamination
that the waste and soil would be allowed to contribute to the already-contaminated
groundwater beneath the Waste Pits will be a small amount (0.5 percent of existing
groundwater contaminant concentrations). The soil clean-up level, therefore, is based
on the "incremental" contamination that waste and contaminated soil could add to the
groundwater. The calculation of this allowable contamination increment is based on
the potential contaminant contribution from all vadose soil beneath the pits. Had EPA
selected a "full soil cleanup," it would have required that the soils be cleaned to far
lower levels than those implied by the interim soil standard.
The EOF memo suggests that EPA should not apply the SVE to the fine-grained vadose
soils beneath the Waste Pits, as EPA's Proposed Plan calls for, but only to the
coarse-grained soils. If we were to do this, the cleanup level would only account for
these coarse-grained soil layers that were being cleaned. The rest of the soil layers
would continue to release their contamination to the groundwater, and their
contamination would not be included in the allowable contamination increment
calculation. Thus, there would be more contamination migrating into the groundwater
beneath the Waste Pits than what the clean-up goal was aiming for. The goal of keeping
the incremental contamination's effect on groundwater to below 0.5 percent of existing
groundwater concentrations would be illusory - the soils under the pits would be
adding to groundwater contamination at far greater levels. Finally, it is unclear if
coarse-grained units are continuous across the size and that if removing VOCs from
these units would capture all VOCs migrating from surrounding fine-grained units.
Thus, depending on the coarse-grained units to protect groundwater from migration of
VOCs from the fine-grained units may be unjustified at this site. Therefore, the cleanup
level for the vadose soils beneath the pits should account for all soils under the pits, not
just certain soil layers, especially since the waste will remain in place "indefinitely."
EPA understands the commenter's concern that there may be fine-grained soils which
have such low air permeability that they cannot be addressed by SVE. To address this
concern, EPA has provided in the ROD a second method for calculating the interim soil
standard in the event that the extent of soils that are not amenable to SVE due to low air
permeability is significant. This approach will ensure that the goal of limiting the
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incremental contribution from the pits to 0.5 percent of the incremental groundwater
concentration will be met even if some areas under the pits are not subject to SVE after
remedial design. See also EPA's other responses to this issue, above.
3. Role of Groundwater Clean-up. In the Waste Pits remedy, EPA has selected source
control measures in order to address the contaminated groundwater. EPA recognizes
that there is evidence of groundwater plume stability and natural attenuation
mechanisms in the two upper groundwater units. However, EPA also recognizes that
there is less evidence of such stability and attenuation mechanisms in the third unit, the
C-Sand, and below. In addition, present plume stability is not guaranteed to last
forever. Moreover, if the groundwater does remain contaminated for a very long time
with the waste remaining in place, a reasonable amount of mass removal in the vadose
zone will reduce the long-term uncertainty and increase the long-term effectiveness of
the groundwater remedy. This is consistent with State and EPA approaches to NAPL
releases, even in cases where natural attenuation is applied to groundwater.
Finally, the soils are not the only source of contamination here, but the waste itself
(which is itself both voluminous and significant contamination) is being left in place
indefinitely. Should contaminants from this waste arrive at groundwater, there is no
guarantee that there would be plume stability in either the lateral or vertical directions.
For these reasons, EPA believes it is prudent to implement source control measures, as
outlined in the Waste Pits remedy, in order to add to the long-term effectiveness and
permanence of the selected remedy for the Waste Pits.
Subject: Letter from Dames & Moore Regarding Various Issues, as Noted
1. Comment from Dames & Moore dated January 24.1997; Non-Technical Editorial &
Typographic Corrections: Use of the Term "cleanup"(Reference No. 10)
EPA's Response: The concern of the commenter as to the interpretation of the word
"cleanup" by the public is noted. However, EPA has not explicitly or implicitly defined
the term "cleanup" to mean "restoration" in the Proposed Plan or the ROD. "Cleanup" is
a more widely used and understood term than "remedial action" and is therefore used
appropriately in the Proposed Plan where it occurs. A specification as to the degree of
cleanup is not contained within the term itself; moreover, the degree being selected by
EPA is specified explicitly.
2. Comment from Dames & Moore dated January 24.1997; Non-Technical Editorial &
Typographic Corrections: Use of the Term "data" (Reference No. 10)
EPA's Response: Duly noted.
3. Comment from Dames & Moore dated January 24.1997; Non-Technical Editorial &
Typographic Corrections; Use of the Term "Waste Pit Area" (Reference No. 10)
EPA's Response: Duly noted.
4. Comment from Dames & Moore dated January 24.1997: Non-Technical Editorial &
Typographic Corrections: Payc 4. Item No, 2—Uncertain Long-term Controls
(Reference No. 10)
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EPA's Response: EPA believes the statements made are correct and true and are based
on both observations of the pits site and on the experience of EPA in dealing with such
sites and remedies. Because the current cover on the pits is temporary and requires
regular maintenance, the pits are subject to wind erosion, water erosion, and water
infiltration. The pits have also been known to ooze waste onto the surface. Therefore, it
is not unreasonable to state that there is a "significant possibility that exposures may
occur in the future" or that there is a "significant uncertainty as to whether existing
controls would be maintained as long as the waste remains in place." The commenter
requests clarification as to whether "possibility" means "probability." EPA used the
word "possibility," not "probability." EPA has not quantitatively calculated the
probability of these occurrences.
5. Comment from Dames & Moore dated January 24.1997; Non-Technical Editorial &
Typographic Corrections: Page 5. Alternative 3. Last Bullet (Reference No. 10)
EPA's Response: Duly noted.
6. Comment from Dames & Moore dated January 24.1997; Non-Technical Editorial &
Typographic Corrections: Page 5, Last Two Bullets in Column 1 (Reference No. 10)
EPA's Response: Duly noted.
7. Comment from Dames & Moore dated January 24.1997; Non-Technical Editorial &
Typographic Corrections; Page 12, Reduction ofToxicity. Mobility, and Volume (TMV)
Through Treatment (Reference No^ 10)
EPA's Response: Duly noted.
8. Comment from Dames & Moore dated January 24.1997; Non-Technical Editorial &
Typographic Corrections: Supplement, Page 1 Purpose of Soil Vapor Extraction,
Para. 3. 3rd Sentence (Reference No. 10)
EPA's Response: Duly noted.
9. Comment from Dames & Moore dated January 24.1997; Non-Technical Editorial &
Typographic Corrections: Supplement, Throughout (Reference No. 10)
EPA's Response: Duly noted.
10. Comment from Dames & Moore dated January 24.1997; Technical Corrections to
Background Information; Page 1, Para. 5/Figure 1 (Reference No. 10)
EPA's Response: Duly noted.
11. Comment from Dames & Moore dated January 24.1997; Technical Corrections to
Background Information: Page 1. Para. 7 (2nd Para. Under Site Characterizations
(Reference No. 10)
EPA's Response: Duly noted.
12. Comment from Dames & Moore dated January 24.1997; Technical Corrections to
Background Information: Pave 2.1st Partial Para. (Reference No. 10)
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EPA's Response: Although there are significant areas within the fence line not
contaminated above levels of concern, there are also significant areas outside the pits
that are contaminated substantially above levels of concern. The statement in the
Proposed Plan is true and does not imply in any way that all soils within the fence line
are contaminated.
13. Comment from Dames & Moore dated January 24.1997; Technical Corrections to
Background Information: Page 2. 2nd full Parfl.(Reference No. 10)
EPA's Response: Under present conditions, if the waste comes into contact with air, it
has been disturbed and, therefore, will emit hydrogen sulfide as well as VOCs.
14. Comment from Dames & Moore dated January 24.1997; Technical Corrections to
Background Information; Table 1 (Reference No. 10)
EPA's Response: Although the highest concentrations of soil contamination are within
5 feet of waste, significant concentrations of contaminants are found at relatively large
distances from waste. For example 1,000 ppm benzene has been detected 60 feet from
waste. Making such a clarification as suggested would unnecessarily downplay the
extent of contamination beyond the pits.
15. Comment from Dames & Moore dated January 24.1997; Technical Corrections to
Background Information: Page 6, Column 1,1st Partial Para. (Reference No. 10)
EPA's Response: Duly noted.
16. Comment from Dames & Moore dated January 24.1997; Technical Corrections to
Background Information; Page 7. Reasons for EPA's Proposed Remedy, 1st Para.
(Reference No. 10)
EPA's Response: Duly noted.
17. Comment from Dames & Moore dated January 24.1997: Technical Corrections to
Background Information; Supplement, Page 2, Box (Reference No. 10)
EPA's Response: Duly noted.
18. Comment from Dames & Moore dated January 24.1997; Administrative and
Procedural Clarifications; Page 1. Para. 5, Sentence 2/Page 7, 3rd Para./Supplement
Page 1. Purpose of Soil Vapor Extraction. Para. 1 (Reference No. 10)
EPA's Response: This remedy is an interim action for groundwater. An interim action
is a remedial action, not inconsistent with the anticipated final action, that in an early
time frame initiates some part of an overall cleanup action without completing it. It is
correct that no actions are evaluated in the FFS for cleanup of the contaminated
groundwater itself. This interim action does not provide that type of action for the
groundwater. Rather, it serves the function of controlling the Waste Pits and the soils
below them as a source of future contamination for groundwater. This will serve as one
component of the overall groundwater remedy, which later will include actions for the
contaminated groundwater itself.
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The commenter questions whether this interim action for waste and soils might be
replaced or augmented in the nature with respect to groundwater. The answer is yes.
The groundwater ROD will select final groundwater cleanup standards. If necessary,
the interim soil standards in the Waste Pits ROD would be modified to allow for
meeting the groundwater cleanup standards. Contrary to the commenter's
understanding, this ROD is not "final with respect to soils." Rather, it is final with
respect to surface exposures at the ground surface, and interim with respect to
protection of groundwater. Therefore, soil cleanup standards may change as a result of
final groundwater actions.
19. Comment from Dames & Moore dated January 24.1997; Administrative and
Procedural Clarifications: Pagel, Column 2.1st Para. (Reference No. 10)
EPA's Response: The term "soil contamination" is actually shorthand for the presence
of waste pit contaminants in any of four phases: adsorbed to soils, in the vapor phase, in
the water phase (e.g., dissolved in soil moisture), and in the residual phase.
Contaminants can reside "in the soils" in any of these phases. Based on partitioning
relationships, a measurement of the amount of contaminant in any one of these phases
implies a certain amount of contaminant in the remaining phases. Any soil standard
that is based on one of these phases must take into account the total mass of
contaminant present in all the phases and how the mass in each phase might be
transported to groundwater. Therefore, it is true that the interim soil standard does not
apply to "subsurface gases" alone but to all phases of contaminants present in soils
under the Waste Pits.
The purpose of the remedy, however, is to address subsurface gas as well as subsurface
soil contamination. These emissions, if they were to occur, would occur in the form of
escaping subsurface gases. It is true that subsurface gases will be controlled from above
by a vapor collection system built into the cap and from below by the SVE system. The
SVE system will be operated to reduce soil concentrations (as present in all phases) to a
performance standard. However, it is important to explain that subsurface vapors will
be controlled by the SVE system.
20. Comment from Dames & Moore dated January 24,1997; Administrative and
Procedural Clarifications: Page 4. Item 1 (Preference for Treatment)/Page 7. Reasons
for EPA's Proposed Remedy. 5th ParaJPage 12. Reduction ofToxicity. Mobility, and
Volume (Reference No. 10)
EFA's Response: The Proposed Plan does not state, in contrast to the commenter's
claim, that any alternative which does not include treatment as a principal element
should be rejected. This is merely one consideration among many in making remedial
decisions. The preference for treatment as a principal element is a statutory and
regulatory requirement. The statute, in particular, has not changed since 1986 and still
contains the language requiring it. This preference has always been just that, a
preference. As such, there has never been a time in which containment alone was not
"acceptable under certain circumstances," particularly when considered on balance with
the other NCP remedy selection criteria. While EPA's published policies on the
preference for treatment as a principal element speak for themselves, preference for
treatment remains a factor which is to be considered in conjunction with the nine
criteria and it was, therefore, considered in this case.
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21. Comment from Dames & Moore dated January 24.1997; Administrative and
Procedural Clarifications: Page 4. Item 4 (Compliance With ARARs) (Reference
No. 10)
EPA's Response: The term "ARAR" means "Applicable, or Relevant and Appropriate
Requirement." ARARs are either applicable, or relevant and appropriate. If an ARAR
applies directly to the site or the remedial action, it is applicable. However, EPA can
determine that, even though the ARAR does not directly apply, it is nonetheless
relevant and appropriate. EPA has identified certain hazardous waste facility closure
and post closure requirements, established in state regulations, as relevant and
appropriate legal requirements that the selected remedial action must meet. Section 121
(d) of the Superfund law provides that remedial actions conducted on-site must meet
substantive environmental protection requirements. However, the law also provides
that no state, federal or local permit is required to conduct remedial actions onsite
provided that the substantive environmental protection standards have been identified
and complied with. See42U.S.C. 9621(e).
22. Comment from Dames & Moore dated January 24.1997; Administrative and
Procedural Clarifications; Page 6. First Full Para. In Column 3 (Reference No. 10)
EPA's Response: Duly noted.
Subject: Letter from California Department of Toxic Substances Control (DTSC)
Regarding the Final Focused Feasibility Study Report, Del Amo Waste Pits Area,
Geologic, Engineering, and Toxicologic Issues
1. Letter from California DTSC dated December 11.1996; Specific Geologic Comments.
Comment 1 (Reference No^ 11)
EPA's Response: EPA agrees that some soil gas monitoring points, either within the
Waste Pits area or on adjacent properties, are needed on all sides of the Pits. The exact
number, location, and design of these points will be determined during the Remedial
Design phase of the project.
2. Letter from California DTSC dated December 11.1996; Specific Geologic Comments.
Comment 2 (Reference No. 11)
EPA's Response: EPA agrees that rising groundwater at the site is a design
consideration. It is anticipated that the impact of rising groundwater on the SVE system
will be addressed during the Remedial Design phase of the project.
3. Letter from California DTSC dated December 11.1996; Specific Geologic Comments.
Comment 3 (Reference No. 11)
EFA's Response: EPA believes that after the initial period of continuous operation,
asymptotic concentrations will be reached. It will then be possible to turn off the SVE
system and to monitor the concentration of soil vapor. If monitoring indicates that soil
vapor has increased above levels of concern, the SVE system will be re-activated. The
process by which these decisions will be made will be included in an Operations &
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Maintenance Plan to be initially developed during the Remedial Design phase of the
project.
EPA has identified specific ARARs in the ROD pertaining to this type of monitoring.
4. Letter from California DTSC dated December 11.1996; General Engineering
Comments. Comment 1 (Reference No. 11)
EPA's Response: EPA agrees that the monitoring information requested by DTSC is
needed. However, the SVE performance standard selected in this ROD is incorrectly
stated in DTSC's comment. It is true that the purpose of the SVE system is to reduce soil
contaminant concentrations below the Waste Pits. However, the standard is for the
containment concentrations to be reduced to a level such that the Waste Pits could not
incrementally contribute to groundwater more than 0.5 percent of the existing
groundwater concentration at any point in the future. Should the "existing
groundwater concentration" change, then the standard would change as well to remain
at 0.5 percent.
5. Letter from California DTSC dated December 11.1996; General Engineering
Comments. Comment la (Reference No. 11)
EPA's Response: A proposed soil gas monitoring plan for lateral migration of all mobile
contaminants from the Waste Pits, to assess whether cleanup objectives have been met,
will be developed during the Remedial Design phase of the project. It should be noted
that not all contaminants found in the Waste Pits are necessarily considered mobile,
based on soil and individual contaminant characteristics.
EPA has identified specific ARARs pertaining to this monitoring.
6. Letter from California DTSC dated December 11.1996; General Engineering
Comments. Comment Ib (Reference No. 11)
EPA's Response; The physical parameters to be measured to assure that clean-up
objectives have been met will be developed during the Remedial Design phase of the
project.
7. Letter from California DTSC dated December 11.1996; General Engineering
Comments. Comment Ic (Reference No. 11)
EPA's Response; Groundwater monitoring will not be used to measure the SVE
system's impacts on the groundwater. The groundwater directly beneath the Pits is so
highly contaminated that the SVE system's impacts to the groundwater contaminant
concentrations, at least in the near future, will be indiscernible.
8. Letter from California DTSC dated December 11.1996; General Engineering
Comments. Comment 2 (Reference No. 11)
EPA's Response: As discussed in Section 2.9 of the ROD, "The Selected Remedy,"
subsection entitled "Where SVE Shall Be Applied," the SVE system shall extend laterally
to include areas all across the Pits themselves and laterally beyond the boundaries of the
Pits to whatever distance is necessary such that all interim soil standards specified in
this ROD are met. This distance could extend beyond the boundaries of lots 36 and 37.
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The application of SVE shall address soil contamination that has emanated from the
Waste Pits, but not contamination emanating solely from other sources.
9. Letter from California DTSC dated December 11.1996; General Engineering
Comments. Comment 2b (Reference No.ll)
EPA's Response: The purpose of SVE at this site is as a containment technology that is
used to establish a contiguous horizontal barrier against the vertical migration of vapor
phase contaminants that could further contaminate groundwater. SVE will also reduce
future groundwater contamination that could occur if water levels rise into the vadose
zone soil that has been targeted by the technology.
The thickness of the SVE capture zone at every point under the Waste Pits has not yet
been determined. The ROD specifies that if Method A is to be used to calculate the
interim soil standard, then all of the soils between the capillary fringe and just below the
Waste Pits will be subject to SVE. However, if significant areas of soils under the Pits
will not be amenable to SVE due to lack of air permeability, then Method B will be used
and the thickness of the SVE zone will vary according to location under the Pits.
However, either way, the incremental contribution from the Pits will be limited to
0.5 percent of the existing groundwater contaminant concentration. Modeling and/or
other techniques necessary to develop and operate an effective SVE system will be
evaluated and implemented, as appropriate, during the Remedial Design phase of the
project.
10. Letter from California DTSC dated December 11.1996; General Engineering
Comments. Comment 3 (Reference No. 11)
EPA's Response: Figure 7.4.1-2 is an idealized conceptual view of a possible SVE well
configuration, viewed along a generalized east-west line of section beneath the Waste
Pits. Similarly, Figure 7.5.2-2 is a view showing the waste and adjacent soil materials
that would be excavated per Alternative 5. Due to the complex distribution of
contaminants in the soils below the Waste Pits area, all plan view and cross-sectional
graphics presenting the soils contaminant data should be viewed in the context of the
conceptual remedies. Figures 2.2.2-3 through 2.2.2-9 of the FFS Report show all
available soils data plotted on seven separate cross-sectional views transecting the
Waste Pits area. Collectively, these figures provide a good presentation of the variable
distribution of soil contamination across the site, as well as the data points that provide
the basis for our current understanding of contaminant distribution.
11. Letter from California DTSC dated December 11.1996: Specific Engineering
Comments. Comment 4 (Reference No. 11)
EPA's Response: EPA agrees with this statement and a version of the figure that
includes the note suggested by DTSC is attached to this response (Reference No. 12).
12. Letter from California PTSC dated December 11.1996; Specific Engineering
Comments. Comment 5 (Reference No. 11)
EPA's Response^ Estimates already include the cost of monitoring probes to the east
and west of all Pits and, in some cases, they also include the cost of monitoring probes
to the north and south. An analysis of the cost of adding additional monitoring probes
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to the north and south of the Pits was performed. If it is assumed that a maximum of 18
of these monitoring probes will be installed to the north and south of the Pits, the cost to
construct and sample the probes would be approximately $300,000. For those SVE
design scenarios that are at least equal in size to the conceptual SVE design assumed for
Alternative 4 (see FFS Tables 8.3-1, 8.3-2, 8.4-1, and 8.4-2), this represents an increase of 1
to 18 percent when compared to the cost estimates that were included in the
December 10,1996, FFS report.
13. Letter from California DTSC dated December 11.1996; Specific Engineering
Comments. Comment 6 (Reference No. 11)
EPA's Response: The purpose of Table 8.5-1 is to simplify and "bracket" the cost of all
the various SVE design scenarios and cases that are discussed in Section 8 of the FFS
Report. While it would be possible to assemble a table that showed the cost of each and
every possible combination of SVE designs that would be necessary to accomplish the
different short- and long-term performance standards for different types of soil, EPA
believes that these costs would not fall outside the range that is presented in Table 8.5-1
as currently configured ($3 to >$10.9 million). Therefore, the value of this exercise does
not appear to be merited at this time.
14. Letter from California DTSC dated December 11.1996; Specific Engineering
Comments. Comment 7 (Reference No. 11)
EPA's Response: EPA has reviewed this request and believes that the purpose of these
estimates may be misunderstood by DTSC. To evaluate the effect of the contingency as
part of a sensitivity analysis, all elements of the estimates in Tables F-2d and F-2e were
kept the same as the estimate in Table F-2a, except for the contingency. The same is true
of the estimates in Tables F-3d and F-3e when compared to Table F-3a and Tables F-4d,
and F-4e when compared to Table F-4a. If the contingency in all these tables is set at
15 percent, all of the estimates will be the same for the alternatives in question and all of
the tables that are mentioned in this comment will be redundant with other tables in
Appendix F.
15. Letter from California PTSC dated December 11.1996; Specific Engineering
Comments. Comment 8 (Reference No. 11)
EPA's Response: EPA has reviewed this issue and believes that the problem is that the
table says 8 percent when, in fact, 7.5 percent was used in the calculation. The problem
occurred due to a rounding error in Excel.
16. Letter from California PTSC dated December 11.1996; Alternative 4—RCRA—
Equivalent Cap + Soil Vapor Extraction (SVE). Comment 1 (Reference No. 11)
EPA's Response: The reason the SVE monitoring costs in DTSC's estimate were so high
relative to Dames & Moore's is because DTSC assumed continuous operation of the SVE
system for years 4 through 30 and Dames & Moore did not. Since both DTSC and
Dames & Moore agree that SVE operation likely will not be continuous during this time,
EPA believes that DTSC has overestimated the cost of this work.
17. Letter from California DTSC dated December 11.1996; Alternative 4—RCRA—
Equivalent Cap + Soil Vapor Extraction (SVE). Comment 2 (Reference No. 11)
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EPA's Response: EPA agrees that the SVE O&M item was double-counted in DTSC's
cost estimate that used the RACER cost-estimating system.
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II. Responses to Formal
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II. Responses to Formal Verbal Comments
Made During the Public Meeting Held
January 29,1997
1. Comment from Public Meeting held January 29,1997; speaker Cynthia Babich
EPA's Response: The comments are largely the same as the letter submitted by Ms.
Babich. EPA shares Ms. Babich's concerns regarding the long- and short-term
effectiveness of the remedy. A detailed response is provided in response to Ms. Babich's
letter.
2. Comment from Public Meeting held January 29.1997; speaker Kim Simpson
EPA's Response: Based on the established principles of chemistry and physics,
experience, and available information, EPA is highly skeptical regarding the claims
made by Mr. Simpson, and finds that it is not appropriate to place any confidence in or
reliance on those claims. It is questionable as to whether Mr. Simpson has reviewed the
available engineering information regarding the waste at the Pits Site. If Mr. Simpson's
technology depends, as it appears it does, on the ability of a chemical to percolate into a
soil matrix, then it does not appear feasible at the Pits Site because the waste material
has no porosity into which a fluid could percolate. If EPA had procured the services of
Mr. Simpson in the past and made use of Mr. Simpson's technology as an innovative
technology, as Mr. Simpson claimed, it would be listed in the Superfund Innovative
Technology Evaluation (SITE) program. A search of the SITE database has shown that
Simpson Environmental is not listed. Mr. Simpson's claim to have completely cleaned
up several Superfund sites is false as EPA is well aware of the sites and the fact that the
cleanup at those sites is not completed nor is Mr. Simpson's technology in use there.
Mr. Simpson has not provided any information to EPA that would substantiate his
claims nor provided even the basic chemical principles by which his technology could
conceivably succeed in addressing the waste in the pits.
In addition to the physical impediments just described, a basic knowledge of chemical
reactivity would suggest that the claims made by Mr. Simpson regarding the ability of
his material to catalyze oxidation of the waste materials at the rates specified are not
valid. Mr. Simpson claims that all the waste could be oxidized in 6 months. Setting
aside the unlikeliness that this technology could accomplish oxidation of the pits
material at all, the feat itself, were it to occur, implies unrealistic conditions. Oxidizing
the waste would produce heat. The amount of heat produced by oxidizing all the waste
in 6 months would be so large that the material in the pits would literally be a burning
conflagration. This heat can be estimated by multiplying the amount of heat potential in
British Thermal Units (BTUs) in the waste by the total amount of waste. This calculation
suggests that Mr. Simpson's technology would generate 36,521,294 BTUs of heat every
hour while the waste is being oxidized. This would be equivalent to 10.7 megawatts, the
equivalent of 107,000100-watt light bulbs going at once, or enough power to light a
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town of perhaps 5,000 homes. Of course, it would be virtually impossible to cause any
oxidation at all with this chemical because, as mentioned, there is no way to get the
chemical to infiltrate the waste. If the claims made by Mr. Simpson are true, that by
simply sprinkling his chemical on the surface of the waste material he will generate
10.7 megawatts of power and thereby destroy all the waste, this technology would be
very valuable to the energy generation industry, much less the environmental cleanup
industry. However, this technology is not known or proven and thermodynamic
principles of chemical reactivity suggest that Mr. Simpson's claims are highly suspect.
The Responsible Parties involved at the site requested that Mr. Simpson provide
scientific information regarding how his technology works and on which physical and
chemical principles it is based. Adequate information was not provided.
Mr. Simpson claimed in the public meeting that his company would be willing to
perform a test of the technology at the Waste Pits at no cost. However, given the lack of
any credible basis for believing such a test would be successful or useful, EPA will
neither seek nor approve such a test. Moreover, the test could fail in some ways which
are more pernicious than simply failing to destroy the waste. Such a test could well
worsen the Waste Pits problem, make it more difficult to control, cause waste migration,
liberate contaminants, or create new contaminants which presently do not exist in the
pits. Not enough is known about the effect of such a test to justify pursuing the matter
further. In short, EPA rejects the technology proposed by Mr. Simpson for the Del Amo
Waste Pits, and plans no further evaluation of this technology at this time.
3. Comment from Public Meeting held January 29.1997; speaker Chuck Paine
EPA's Response: Duly noted.
4. Comment from Public Meeting held January 29.1997; speaker Robert Evans
EPA's Response; EPA appreciates Mr. Evans' concerns regarding the need to provide a
long-term remedy to hazards potentially associated with this waste. The studies and
evaluations that have been conducted to date have shown Alternative 4 to be the best
balance of long-term effectiveness, short-term risks, permanence, implementability,
protection of human health, meeting environmental standards, and cost. If there were
currently available technologies that could effectively and safely treat the waste in place,
it is likely that EPA would have selected them for the remedy. Please see earlier EPA
responses to comments on the subject of Permanence and Long-term Effectiveness.
5. Comment from Public Meeting held January 29.1997; speaker Ms. Ponce
EPA's Response; Duly noted.
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MI. Hesponsesto
Informal Vernal Comments
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III. Responses to Informal Verbal Comments
Made During Question and Answer Period
During the Del Amo Public Meeting Held
January 29,1997
(Page and line numbers refer to Transcript of Proceedings, Reference 13)
1. Page 21. lines 11-20
EPA's Response: EPA appreciates the speaker's concerns about containing the waste
indefinitely. EPA refers the reader to its responses above under the subject: Permanence
and Long-term Effectiveness. These responses fully address this commenters' comment.
2. Page 25. lines 8-9
EPA's Response: The Proposed Plan states that the groundwater table is 60 feet below
the ground surface at the site.
3. Page 26. lines 1-5
EPA's Response: EPA appreciates this concern regarding long-term effectiveness and
permanence of the final remedy. EPA refers the reader to its responses above under the
subject: Permanence and Long-term Effectiveness. These responses fully address this
commenters' comment.
4. Page 30. lines 24-25. page 31. lines 1-2
EPA's Response; EPA shares this concern regarding safety of the remedy.
Alternative 4 includes a monitoring program to monitor the system for problems. When
a problem occurs, action will be taken to correct the problem and prevent hazards to the
community. The hazards that can occur due to a problem with Alternative 4 are
significantly less than the hazards that can occur due to a problem with Alternative 5.
There is very little likelihood that the community will experience any adverse effects
due to problems with Alternative 4.
5. Page 36. lines 24-25; page 37. line 1
EPA's Response; The wells will be designed to contain all vapors. They will be sealed
and connected to piping that runs to the vapor extraction and treatment equipment.
6. Page 40. lines 1-5
EPA's Response: A substantial number of caps have been implemented at municipal
landfills and Superfund sites, and EPA is not aware of notable cap failures. Please be
aware that EPA is highly concerned about the integrity of any remedial alternative
implemented. The proposed cap is not a "walk away" solution. The cap will be
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continuously monitored for an indefinite time period. When monitoring indicates that
the cap requires repair or replacement the work will be done. Additionally, the design
criteria for the cap will be to resist weathering, settlement, and seismic forces. Capping
technology is well developed and designing a cap to withstand reasonable seismic and
weathering forces is possible.
7. Page 42. lines 13-15
EPA's Response; EPA appreciates these concerns regarding long-term effectiveness
and permanence of the final remedy. EPA refers the reader to its responses above under
the subject: Permanence and Long-term Effectiveness. These responses fully address
this commenters' comment.
EPA's Response: The Newport-Inglewood structural zone, which extends from the foot
of Santa Monica Mountains near Beverly Hills southeastward to Newport Beach is
underlain by a series of folds and faults. The Newport-Inglewood Fault, located about
3 miles northwest of the Waste Pits, is the major structural feature mapped in the
vicinity of the Del Amo site.
9. Page 44. lines 1-3
EPA's Response: EPA has developed conceptual designs of the cap that allowed us to
evaluate its effectiveness. One of the designs is shown in the Proposed Plan on page 5.
Many of the details of cap design can change during the design phase. However, the
design criteria for the cap will not change. These design criteria will be a minimum
permeability to prevent escape of vapors or infiltration of rainwater, removal of
accumulated vapors, removal of accumulated rainwater, and resistance to anticipated
loadings including seismic loadings. The details of how these design criteria will be met
will be developed during the design stage. However, these details are not necessary to
evaluate the effectiveness of a cap at this time because capping is a mature technology
and we are certain that the design criteria developed can be met using available
materials and technologies. If these design criteria are met, the cap is expected to be
effective and meet the remedial objectives at the site.
10. Page 46. lines 16-22; Page 47. lines 12-18
EPA's Response; The reader is referred to EPA's response to the Toxics Assessment
Group, above. This response offers a discussion of EPA's treatment of cost as a criterion
in remedial selection, and addresses this commenter's comment.
11. Page 48. lines 23-25; Page 49. lines 2-4
EPA's Response; A conceptual design of the cap is shown in the Proposed Plan on page
5. The cap is expected to look generally like this although some details may change
during the design stage when better materials or methods may be developed. However,
to evaluate the effectiveness of the cap, the level of detail shown in the Proposed Plan is
generally sufficient. Capping is a well known and frequently used technology and we
believe mat a cap can be designed and built which will meet the design objectives of
preventing escape of vapors and infiltration of rainwater into the waste. The same can
be said for the vapor extraction system. The conceptual design has been developed and
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details will be worked out during design. However, vapor extraction is also a well
known and frequently used technology and we believe that a vapor extraction system
can be designed that will meet the objectives at the site of removing soil contamination
and preventing contamination of groundwater.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
RECORD OF DECISION
Del Amo Waste Pits Operable Unit
Del Amo Facility Proposed Superfund Site
Los Angeles, CA
PART IV - RESPONSE SUMMARY
(ATTACHMENT B)
References 1-13
m1Q2S80.04.02cvr2 9/97
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Reference 1
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COMMENTS FROM THE DEL AMO ACTION COMMITTEE
PRESENTED AT THE PUBLIC MEETING JANUARY 29, 1996
BY CYNTHIA BABICH
What I will tell you tonight comes two and a half years of researching, watching and
participating with the State and Federal Agencies working on our Superfund Site. This is
a projection of what needs to be done at the Waste Pits in the short term and in the long
term. We must state to these Agencies and Corporations what our needs are, but this
must be stated in the form of a demand to be heard clearly. We are committed to
following through with the work that has been started by the Del Amo Action Committee.
The Del Amo Action Committee knows that this community supports its efforts, but the
Agencies, Responsible Parties and our Political Representatives need to know as well.
There are representatives here tonight of all those who have a stake in this communities
future in one way or another. We have been negotiating over a year with many these
stakeholders on 204th Street Buyout Issues. Although we may have hate in our hearts for
the destruction many industries have caused, we do not and should not hate the
messenger. All warriors know the importance of knowing their enemies. Mr. Chuck Paine
is here tonight and has been working hard to come to some agreement on issues raised by
this Committee. We certainly do not agree on many things and he only knows if he has
been successful at putting himself in our shoes, but I can tell you he has tried very hard to
understand. There are many problems across our nation and if we can not even begin to
talk to each other about them then we are doomed. The EPA as well has risen to the
challenge on many occasions. I am telling you this so you can understand that this
committees anger is not at the individual trying to make some sense of this horrible
situation, it is with Federal and Corporate Polices that must be changed. This committee
tires of cheep talk we are gearing for action.
We have come here to talk about the EPA's Proposals for remediating, which some think
means cleaning up, the Del Amo Waste Pits. We will talk about current conditions and
future conditions. We already know from previous meetings what has occurred in the past
to this community, exposure to toxic chemicals from the Waste Pits and the Montrose
Facility, as well. This neighborhood is comprised of hardworking citizens of many
nationalities. Most of us are in the mid or low income range. Historically it has been
found that lower income communities have much more than their share of toxic problems.
There is a trend unfolding across the Country about Communities just like ours. Some
feel the reason for this is that lower income communities are so involved in making ends
meet that they may not even notice that they have these added dangers in their community.
The attitude which has caused this problem and which we as a Nation have been facing, is
called Environmental Racism. We are engaged in a struggle for Environmental Justice.
Many communities have been standing up, educating themselves and fighting hard for
what is theirs, should have been theirs and what will be theirs in the future. We can not
change the past, the present we may aher but the future we hope to forge for ourselves.
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The future of this community is very important. Many of us at this time, with the
knowledge of toxic exposure in the past and present in this community, don't hold out a
lot of hope for many adults. Our quality of life has been diminished, extensively in some
cases. We now look at the situation with brave hearts and optimistic minds. When we
look at our children, we wonder what the quality of life for them will be in the future?
This is what we have to make sure remains protected. A little boy on 204th street asked
me the other day where I lived and I told him in San Pedro. I was lucky enough to have
been under the EPA's temporary relocation, but feel torn between my community which I
dearly love and fear of my life from continued exposure. The air is fresher where I live
now, but I don't feel connected to this new community. I was going to ask this little boy
where he lived, but I was afraid he might tell me or what I might have to tell him, about
where he lived. That little boy and many other children in our neighborhood represent our
FUTURE. It would be disgraceful to condemn them to the same feelings we have now
about those that have blatantly dumped on this community. We are owed something for
our suffering. We are owed self respect and we are owed a future, which today remains
uncertain.
When we look at the remedies for the Waste Pits, (Containment or Excavation), many of
us from the beginning have felt it should be cleaned up. We didn't put it here, we didn't
ask for it to be put here and this community was here before the Del Amo Facility. What
many of us have come to understand is that it can't be cleaned up. Trying to clean it up
with current technology would mean risking our health again and risking the health of the
workers, because this stuff is so toxic it can kill people at high levels, like the levels in the
Waste Pits.
What happens after the toxins are dug up, if it can be done successfully? We have read
options from the EPA and h sounds as if it could be done, at a cost of over 100 Million
Dollars. What happens to it then? It gets shipped, trucked, railed to either a burial site,
like in Arizona or Nevada, where they dig another hole and bury it. Maybe this time the
hole with have a layer of concrete around it or some other protective measure, but it still is
not being taken care of. It is not being cleaned up. Or if it is to toxic to bury again it is
taken to another community, another Community like ours that has more than its share of
toxic problems. If it is going there this community has an incinerator that will burn the
contaminated material. This will expose the community to the residual burn off. They will
be exposed as well to the many dangers of an accident while all these shipments are
coming in. The Del Amo Action Committee stands in solidarity with those communities
and although we don't want our toxic problem, we certainly don't want to ship it off to
another community and cause them the same grief that we've had to endure.
So then what is the answer? We look at our current situation and we know from the
limited studies that have been done to date that we have been exposed in the past We
know that for at least the last two Summers toxic ooze has seeped up out the ground from
the waste pits. The dirt cover over the Waste Pits, which has been in place for over a
decade, has worn thin, blown away in the wind and washed away by the rains We are
being exposed currently, when you smell rotten eggs in the area that is Hydrogen Sulfide
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(H2S), a deadly chemical that can kill you. Why are we smelling it in our neighborhood?
H2S is one of the chemicals in the Waste Pits and this neighborhoods closest source. We
need to be protected from the ooze's that are occurring, from the vapors we are smelling
and from an eroding cap that was never up to par to begin with. We need to make sure
this is capped, as soon as possible. Option #4, Containment, which has been proposed by
the EPA has a venting system to burn off vapors that will be volitizing off the waste pits.
When past air samplings were done we were told, "No chemicals in the air were coming
from the Waste Pits", yet they are going to be venting these vapors that will be building up
under the plastic liners of the CAP and burn them off near the Eastern boundary of the
waste pit area somewhere. This sounds like chemicals do evaporate into our air space
from the Waste Pits. Option #4 will also be implementing ground water extraction. The
Waste Pits are continually adding Toxins into the groundwater so future contamination to
the groundwater would have to be stopped at the source. These pump extraction wells
will be located between the Waste Pits and the community. They will be pumping
groundwater until the site is cleaned up, which maybe never. What the committee has
asked the EPA to help us do is look into the Bioremediation Options for this site.
Bioremediation is when organisms are introduced into a contaminated environment and
encouraged to feed off of the contamination. The more they feed, the more they
reproduce and less and less contamination is left behind. This is the communities only
hope for a clean future. This is the legacy we have to leave to this community and to our
children.
Will we ever be able to walk away from this, look back and think that we have done
anything at all, besides leave the problem for another generation and another generation
and another generation? Isn't quality of life determined by a healthy mentality, as well as
a healthy body? How can we have a good quality of life when our minds have been
poisoned? We live in fear of the Superfund Sites in our neighborhood, we not only have
one we have TWO. A healthy mentality is important. It helps shape ones self confidence
and encourages us to stand up for ourselves by speaking out and seeking the information
needed to become an involved citizen.
Do we want to condemn our children and this community to deal with the knowledge that
they have deadly contamination just a CAP away from causing them harm once again.
What does this teach our children? Are they not good enough or important enough to
live in a healthy clean environment that they don't have to worry about? Or does make
them feel that they are not as important as other children not dealing with a toxic
neighborhood.
Some Corporations and Agencies have tried to pull the wool over some of us adults as to
the extent of contamination but, our children seem to know the difference. They are being
alerted about the environment and the dangers that have been caused and posed by the
Industrial Revolution. They are trying to find ways to secure their own future. They will
turn to us someday and will ask us why we didn't do anything. Those of you working for
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the Corporations and Government Entities Responsible for this mess and the Agencies
involved in the remediation can bet that your children will turn to you someday and ask
the same questions. What will your answer be? We did the best with what resources we
had at the time? We fought real hard to make sure that current exposure would be
stopped, we stood behind a CAP because we did not want to send our waste to other
communities.
Science is not advanced enough at this time to clean up the many messes all over the
Country, more research needs to be done. More research into Bioremediation of this
particular type of contamination. Some Bioremediation studies have been done in the in
1991. These studies were not very conclusive and 1991 was along time ago, a lot has
changed in the scientific world since then. Along with Option #4 we want resources set
aside for grants into Bioremediation Technologies. This will provide funding for research
on how and which organisms to introduce, so that one day maybe, 50 or 100 years from
now, nothing living in this neighborhood or the near vicinity will live with the threat of a
Superfund Site. We have all seen how the Government can shut down and Superfund
very existence is questionable. What if there was no more EPA. Our site in the future
could represent a now defunct and failed system, with nothing to stop the eroding and
leaching contaminants into our community once again. Can we turn to our children in the
future and tell them that we did the best we could with what we had at the time and we
stand behind the decisions made? Or will they turn to us and say we didn't stand up for
justice, although we did complain a little, shout a few times but ultimately we let people
die. That is what will happen, people have died from these toxins in the past, they are
dying today and if nothing is done to see that this contamination is removed, they will die
in the future. This is our neighborhood and this is our quality of live we are talking about.
The Agencies out here are required by law to listen to us. They know we are the people
who will have to live with the decisions that they will ultimately make for this community.
We've been told that clean up will cost one hundred million dollars or more, a cap on the
other hand costs approximately ten million. The estimated life span of a CAP is 30 years,
maybe longer. Were talking about replacing something every thirty to fifty years. This is
not a permanent solution. We need a solid future in this neighborhood. We need to keep
fighting for solutions. The money that is not being spent on this clean up is a large
amount. There is a big difference between 10 and 100 Million Dollars. One Million
Dollars to some of us is more then we can imagine. Although I can tell you that one
million would go along way towards solving our problems in the future through
bioremediation, as well as other sites with similar contamination. Someday this
community could again be as beautiful as before the toxins came. Its residents will once
again be feel comfortable with where they live. The Children can say, "we live in a
community that once was contaminated with toxic poison, but our community is evolving,
learning and educating and helping others understand that things can change. Industries
that have made mistakes in the past can start going back to change things that have
occurred in the past and can make a difference. It has begun to happen here already with
the many stakeholders joining in the Buyout discussions, but we must continue.
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If the involved Agencies, Political Representatives and stakeholders will not stand beside
this community and push for the Bioremediation Grants that need to be made available,
then truly you are not doing a service to this community.
Please help us bring justice to this community, stand tall beside us. Know that you are
making changes not only for the future of our community, but for the future of all kinds of
communities all around the Country.
IF THE WORLD WAS ONLY A FEW FEET IN DIAMETER, FLOATING ABOVE A
FIELD SOMEWHERE, PEOPLE WOULD COME FORM EVERYWHERE TO
MARVEL AT IT. PEOPLE WOULD WALK AROUND IT, MARVELING AT ITS
BIG POOLS OF WATER, LITTLE POOLS AND THE WATER FLOWING
BETWEEN THE POOLS PEOPLE WOULD MARVEL AT THE BUMPS ON IT,
AND THE HOLES IN IT, AND THEY WOULD MARVEL AT THE VERY THIN
LAYER OF GAS SURROUNDING IT, AND THE WATER SUSPENDED IN THE
GAS THE PEOPLE WOULD MARVEL AT ALL THE CREATURES WALKING
AROUND THE FACE OF THE BALL, AND THE CREATURES IN THE WATER.
THE PEOPLE WOULD DECLARE IT PRECIOUS BECAUSE IT WAS THE ONLY
ONE, AND THEY WOULD PROTECT IT SO THAT IT WOULD NOT BE HURT
THE BALL WOULD BE THE GREATEST WONDER KNOWN, AND PEOPLE
WOULD COME TO BEHOLD IT, TO BE HEALED, TO GAIN KNOWLEDGE, TO
KNOW BEAUTY AND TO WONDER HOW IT COULD BE PEOPLE WOULD
LOVE IT, AND DEFEND IT WITH THEIR LIVES, BECAUSE THEY WOULD
SOMEHOW KNOW THAT THEIR LIVES, THEIR OWN ROUNDNESS, COULD BE
NOTHING WITHOUT IT
Please use this meeting to once again voice your concern about our toxic environment
even if you are angry. Freedom of speech is a powerful tool and we need to use it. We
need the help of the PRP's as well. If they do not want to put money aside for research
they will put pressure on this proposal and our fight will be harder. Mr. Paine I ask that
you continue to try to understand our needs and help us achieve the goals we have spoken
of here tonight, so that one day we may all be proud of a job well done
Please stand with the Del Amo Action Committee so there is no mistake that our
community is united in our fight and we will continue until we achieve justice.
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Reference 2
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1-9-97
Randall £ Hartman
20549 S. Vermont #8
Torrance, CA 90502
Dante Rodriguez (SFD 7-1)
U.S. EPA, 75 Hawthorne
San Francisco, CA 94105
Dear Mr. Rodriguez:
I am writing in regards to the Del Amo Waste Pits. I own a condo in the
Ponderosa West complex just next to the Pits. What I would really like to
see is monetary compensation from the creators of the toxic waste and from
the government for allowing this to happen but I doubt that will never
happen. I bought my condo about 6 yrs ago and have seen its value drop
almost 50%. About half of that loss is because of the market but the other
half I put on the fact that any time I sell, I have to show a disclaimer stating
that the property is next to 2 (or is it 3 now?) toxic Superfimd sites. When I
purchased the condo I received no such disclaimer and was in the dark about
any such sites.
This is why it is so important to stop producing toxic waste in the first
place and to make and enforce tough laws controlling the manufacturing and
disposal of toxic materials. As far as what to do about the Del Amo Pits I do
not think that Alt. 4 is enough and would rather see excavation and removal
of the waste as outlined in Alt. 5. I know it is expensive but it is permanent
and nothing would ever have to be done again in the future, no continual
maintenance would be required, and no VOC's would be escaping for me to
breathe. Another problem with Alt 4 is that our groundwater would still be
getting polluted I believe from continual seepage.
Thank you for allowing the public to comment on these proposals and
for holding public meetings. Also thank you for all past and future
correspondence on this issue.
Yours forji sustainable and healthy future,
Randall E Hartman
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Reference 3
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1706 Turmom Street
Carson, CA 90746
January 21, 1997
Dante Rodriguez
U.S. Environmental Protection Agency (SFD-7-1)
75 Hawthorne Street
San Francisco, CA 94105
Dear Mr. Rodriguez:
The purpose of this letter is to comment on your proposed plan for cleanup of the waste pits area
of the proposed Del Amo Superfund site. The proposed plan was published under the title "Del
Amo Proposed Superfund Site" Volume 2, Number 9, December 1996.
First, allow me to congratulate you on the fine job you have done so far keeping the public
informed as you progress through a very difficult process to cleanup this site. Your documents to
date, including this last one presenting your proposed plan, have been very well written. They
present some very technical information in an easily understandable format
I have a concern with the proposed plan. The proposed plan buries the waste material without
treatment It is simply left in place under a cap. The Soil Vapor Extraction (S VE) system
proposed would not be applied to the waste itself. The reason given for not selecting Alternative 3
(capping only) was that it "does not meet the statutory preference for treatment". I would contend
that Alternative 4 also does not meet the statutory preference for treatment in that the actual waste
materials are not treated.
The claim is made that the selected alternative will "prevent contaminants in waste and soil from
continuing to significantly contaminate grpundwater." I agree that the SVE system will remove
contaminants from soil around the waste pits; minimizing movement of contaminants during the
interval the SVE system is operating. Once the SVE system is shut down, however, contaminants
will once again start moving towards the groundwater from the waste pits, which will still be
intact The cap '.vill reduce the rate of movement, but will not eliminate it After the five-year
period when the SVE system will no longer be operating, this alternative becomes identical to
Alternative 3. Alternative 3 was found to be "not fully protective of human health and the
environment". A similar finding should be applied to Alternative 4 after five years.
I have some questions concerning the SVE system. What is the efficiency of the SVE system?
What levels of contaminants are expected to remain in treated soils? What system of treatment is
proposed for the contaminants once the SVE system pulls them to the surface? Incineration?
Condensation? If condensation, what will be done with the condensed liquid contaminants? What
are the potential impacts of the SVE system on air quality?
An alternative not listed is the use of bioremediation within the waste pits. This site would require
active aeration of the wastes in conjunction with the supply of water and nutrients to ensure active
degradation of the wastes. This would not require creation of a vacuum within the waste (a
consideration for not applying SVE to the wastes), but could be tied into an SVE system to treat air
exhausted from the waste pits accelerating the bioremediation treatment process. An SVE system,
similar to the one proposed for Alternative 4, would be required to prevent migration of
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Mr. Rodriguez -2- January 21, 1997
contaminants through the surrounding soils during the bioremediation process. This approach
would be more expensive than Alternative 4, but probably not as costly or hazardous as
Alternative 5 (complete excavation of the pits and S VE).
Thank you for the opportunity to comment on this very important issue. If you have any
questions, please contact me at (310) 732-3914.
Sincerely,
Lawrence J. Smith, Jr.
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Reference 4
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P U B L I C C O M M E N T F O R M
You may submit this form and any additional written comments at today's
* neeting or you may fold and seal this form and send it to the address on the back.
/ f
b
r
** &
Please Sign and
Signature
Date
\ddress ~Z. ^ 5
City
Zip
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Ciilil hero)
U.S. EPA, REGION 9
DANTE RODRIGUEZ (SFD-7-1)
75 HAWTHORNE
SAN FRANCISCO, CA 94105
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References
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P U B L I CCO M M E N T FORM
You may submit this form and any additional written comments at today's
7ieeting or you may fold and seal this form and send it to the address on the back.
thing, considered. I support the remedy for the Pel
Amo Pits. However I feel the piopused cap leaves much to be
desired. When better technology becomes available it should be
iere: Ho not consider this matter closed.
lea* Sign and Date:
Signature
Date
me
A.
^ ST
Zip
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References
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Toxics Assessment Cjroup
RESEARCH -AND-CONSULTING -SERVICES
PO BOX 73620 TELEPHONE (916) 753-0277
DAVIS CA 95617-3620 FAX <916) 763-5318
February 13. 1997
Dante Rodriguez (SFD-7-1)
Del Amo Project Manager
USEPA, Region 9
75 Hawthorne Street
San Francisco CA 94105
Re: Comments on the Final Focussed Feasibility Study Report (FFS) for the Del Amo
Waste Pits
Dear Mr. Rodriguez,
On behalf of the Del Amo Action Committee (DAAC), the Toxics Assessment Group
has reviewed the FFS. We offer the following comments, which are generally
focussed on the effect on the community and are written from the perspective of the
DAAC.
A technical critique would be of little value because the protocols in place for a
remediation process are such that technical comments will have no impact unless we
could demonstrate an inconceivable level of incompetence Of premeditated
malfeasance. Rather than spending our time on pointless technical nit-picking, we
have explained what we do not have as a result of the process and what it is that we
want.
SUMMARY
The community prefers Alternative 5. ("Complete excavation of waste and vapor
extraction of contaminated soil*) which actually makes en effort to clean up the site,
over Alternative 4. which is "cap and suck." This preference is expressed with full
understanding that short-term impacts of Alternative 5 are significant and are
measured in years, and that disruption of the community during cleanup wiH be
substantial. However, other alternatives do not remove the hazardous wastes and
offer less long-term assurance of protection of public health and the environment.
The preferred alternative of USEPA, Alternative 4. costs an order of magnitude less
to implement, because excavation of the waste materials is not part of the plan.
Intuitively, however, since more waste material remains in the ground, the long-term
assurance to the community is less.
T°*d T860-69Z-OTE -g UU/C d8C: EO Z6-Ei-qej
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The sad fact of cleanup efforts at the Del Amo Waste Pit*, as at most other
significantly contaminated sites, is that full cleanup Is not economically (at leest in the
short-term) or technically realistic. There will some amount of toxic material toft at
the she no manor what option is selected. The security of the community that no
health risks exist due to hazardous wastes is gone forever, regardless of any technical
or edministrative reassurances that may be forthcoming. Residents in the Del Amo
community can never again feel entirely secure that their persons and property are
free from toxic hazard.
Unfortunately for the community, what we really know after all the investigation is
that our neighborhood will never be cleaned up. The best cleanup alternative for the
Del Amo Weste Pits, which is unlikely to be implemented because of cost, still leaves
tens of thousands of cubic yards of contaminated soil in place. The other alternatives
don't even pretend to remove the worst of the contamination. And none of these
alternatives even addresses groundwater contamination or DDT contamination.
Since the choices of the community range from less-than-desirable to downright
awful, we feel that we can at least contribute something to make things better by
using our site as a demonstration for evolving remediation technology. The Del Amo
Action Committee favors using our plight to do some good for other communities
which will be faced with similar problems in the future.
The Del Amo Waste Pits site offers a good opportunity to explore remediation
technologies, such as, for example, a bioremediation demonstration project. Either
Alternative 4 or Alternative 5 will result in a considerable amount of local disruption
of the site. Both options will require many borings to install the SVE system. This
offers a greet opportunity to integrate a technology demonstration project at relatively
low marginal cost. Both installation and monitoring can be included in the design of
the system.
Most of the chemical species identified are reasonably susceptible to bioremediation;
the relatively low concentration of halogenated compounds contributes to the
suitability of the site for bioremediation.
COMMENTS ON THE BASELINE HEALTH RISK ASSESSMENT
A baseline health risk assessment is e regulatory construct which allows risk
assessors to evaluate potential adverse health risks presented by the contaminated
she. This information may ultimately assist the risk managers in determining the
appropriate remediation of the contaminated site. The health risk assessment looks
at chemical contamination and weighs the risks to the potentially exposed population.
However, no matter how complete, a health risk assessment has limitations which
must be understood. The following points are made regarding the overall adequacy
of the hearth risk assessment concept in assigning risk in the site remediation process
(we do not claim that this list is exhaustive):
Z°"d T860-G9Z-OTE
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1) Health risk assessments often suffer from a lack of information about the
health effects of chemicals. The risk assessors do not know the impacts
of all the chemical (and associated transformation products) that may be
present at the site;
2) Risk assessors are not able to assess the impacts of a complex mixture
of chemicals, including possibly significant synergistic effects;
3) Health risk assessments suffer from a lack of information about the fate,
transformation, and movement of chemicals through complex
environments;
4} Unseen spatial and chemical heterogeneity may severely limit the
usefulness of a heelth risk assessment {i.e., the risk assessors cannot
evaluate what they do not know is there);
5) Assumptions regarding exposure must be presented clearly and must be
relevant to the potentially exposed population;
6) Frequency of exposure, duration of exposure, routes of exposure and
other factors must be applicable to the site and the population at risk;
7) Health risk assessments are no stronger than the data on which they are
based;
8) The chemical sampling data are especially important. The risk assessors
must rely on well-characterized sampling and analytical data that are
complete and representative; and
9) Reasons for rejection of data from health risk assessments must be
clearly presented.
in addition, it is important to note that the question that has been most asked by the
community is whether or not their health has been compromised by past exposures
to toxic wastes. Under the baseline line health risk assessment construct, that
question is not answered in a baseline health risk assessment process.
Finally, it is important to identify what a baseline health risk assessment does not
evaluate when considering the impacts on human health. The following points help
demonstrate what a hearth risk assessment does not evaluate:
1) Health risk assessments do not eddress genetic differences that
predispose an individual to risk;
2) Health risk assessments do not address variability associated with
gender, age, diet, preexisting disease conditions, impacts on embryos
and infants, or exposure to mixtures of chemicals;
3) Health risk assessments do not address teratogens, neurotoxlcity,
reproductive health and fertility, immune suppressants, or immune-
compromised people; and
4} Hearth risk assessments do not address the cumulative or synergistic
effects of chemicals on human body.
The value of a Baseline Health Risk Assessment to an affected community is
debatable, though preparation of a Health Risk Assessment is required under the
E0"d I860-69Z-OTE
• CO
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National Contingency Plan. Usually, health effects due to exposure to toxics in the
soil are chronic and subtle. It is not like dealing with a plane crash, where the effects
are acute and easily observable, and the symptoms are easily related to cause. The
protocols in place for assessing health effects In a Baseline Health Risk Assessment
virtually guarantee that no significant health effects will be identified. The limitations
of a Baseline Health Risk Assessment identified above, put in the context of a culture
where one in every three or four people develop cancer over a lifetime, assure that
almost any effects to exposure to toxics will disappear into "background noise." This
is in fact what usually occurs. How many Baseline Heahh Risk Assessments have you
ever seen that show significant risk for a community?
Of course, cancer is not the only risk, and not the only effect. Baseline Health Risk
Assessments do not even measure most other types of demonstrable physical
ailments, and make no effort to measure stress or loss of enjoyment due to discovery
of toxics. The effects of stress are constant and insidious, and are not considered in
a Baseline Health Risk Assessment. We know that our neighborhood has been
effectively destroyed as a comfortable place to live, a place to call home. It doesn't
matter what a carefully constrained "assessment" says. We know that people have
been made sick, or worse, and that our homes are no longer comfortable and safe to
live in. The stress of the situation makes everything worse, and compromises the
health of those people whom the toxics haven't already affected. All the number
crunching in the world can't change reality.
LET'S GET SOMETHING POSITIVE OUT OF THIS SITUATION
The plain fact is that none of the alternatives offered the community represents full
cleanup and restoration of the local environment to its pre-contamination state. Even
Alternative 5 leaves tens of thousands of cubic yards of contaminated soil in place
with a Soil Vapor Extraction system in place to try to minimize future exposure of the
residents to toxic soil gas. Alternative 4 offers no removal at all, just a cap and Soil
Vapor Extraction. While this alternative is so much cheaper in the short run that it will
no doubt be the one chosen, it is certainly not the first choice of the community.
Alternative 4 may well wind up costing far more in the long run as well; thoughts of
Stringfeliow and Casmalia come to mind as examples of state-of-the-art situations at
the time that have proved to be disastrous in the long run. Knowledge of such
experiences does not lend confidence to the Del Amo community that our situation
will be different over the long term.
Whether Alternative 5 or Alternative 4 is chosen, the community seriously wants to
sea something positive emerge from our unfortunate experience. Therefore, we
strongly urge that our site be used for a demonstration project in experimental
remediation technology. It appears to us that our situation may be particularly well
suited to a bioremediation research project, but we don't necessarily want to limit our
request to bioremediation. However, given the species of chemicals identified, the
clear problems identified with excavation at the site, and the planned installation and
operation of a soil vapor extraction system, it appears to us that a bioremediation
= EO
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research project is a good fit. A properly designed demonstration project could
provide information that would be of value to other impacted communities.
Thank you for the opportunity to comment.
Sincerely.
Cynthia Babich
Del Amo Action Committee
Thomas C. Sparks
Toxics Assessment Group
TOTPL P. 06
T860-69Z-Oie
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Reference?
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Shell Chemical Company
Shell Oil Products Company
P. O. Box 25370
February 3,1997 s«m» AM, c» 82799
3611 S. Harbor, Sit 160
»* T^ T. j • Santa Ana. C§ 82704
Mr. Dante Rodriguez 714-427-3401
Remedial Project Manager 7i4-«27.3469 (Fax)
U.S. Environmental Protection Agency
75 Hawthorne Street
San Fransisco, CA 94105
RE: Proposed Plan, December 1996
Del Amo Waste Pit Area
Dear Mr. Rodriguez:
The Respondents have reviewed the Proposed Plan for the Del Amo Waste Pit Area. The purpose
of this letter is to transmit our comments on the plan and to provide a framework for remedy
design and implementation.
The Respondents believe that the Proposed Plan is comprehensive, informative and balanced.
The document reflects significant effort on the part of the agency, and is well written and easy to
understand. The Respondents agree with the Proposed Plan and the selected remedy and
appreciate the work which has been done to ensure that the Proposed Plan accurately represents
the facts as supported by existing data and analyses. The Respondents look forward to working
closely with EPA in the future to develop and further refine the design of the selected remedy so
that it provides reliable, long-term protection of human health and the environment, is easy to
implement and maintain and is cost-effective.
The Respondents believe that: (1) the available data and analyses support EPA's conclusion that
a RCRA-equivalent cap plus soil vapor extraction is more desirable man excavation as the
remedy for the site, and (2) flexibility must be maintained in the final design of the cap and the
design of the SVE system which are included in the selected remedy to ensure that it is effective
and practical and that it provides significant benefit (i.e. reduction of existing or potential
exposures) without excessive cost.
Attached to this letter are comments from the Respondents icgarding both of these issues.
Included are comments which address how the Proposed Plan discusses the risk assessment,
remedial alternatives, and the selected remedy. There are also comments which address the
design of the remedy and the development of performance standards as discussed in the Proposed
Plan Supplement. The Respondents believe the issues identified in this second set of comments
can best be addressed either in the ROD or during remedial design and we look forward to
assisting EPA during further evaluation of these issues in whatever way is most appropriate.
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COMMENTS ON PROPOSED PLAN
DEL AMO WASTE PIT AREA
DATED DECEMBER 1996
Selected Remedy
Page 5, Alternative 3 Description - The Proposed Plan lists layers of material which are included in
a "typical" RCRA-equivalent cap. A RCRA-equivalent cap is one which is designed and
constructed so as to meet RCRA performance standards, regardless of the type of material which is
used. RCRA and EPA guidance on RCRA caps lists performance standards but avoids
specifications regarding the type of material to be used. The Respondents agree with RCRA and the
EPA guidance because it encourages flexibility when designing these types of caps and covers.
Page 6, Column 1,1st Partial Para. - As clarified later in the Proposed Plan, the SVE system
would be applied to soils in a vertical extent from 5 feet below the waste pits to above the
groundwater. The reference here to soils "adjacent" to the pits implies application of SVE to shallow
soils around the perimeter of the pits. The Respondents believe that the design of the SVE system as
described later in the Proposed Plan is adequate without extraction wells in shallow soil around the
pits.
Page 6, Third Full Para. In Column 3 - The cost which is listed in the Proposed Plan for
Alternative 4 is included in the range of costs which are shown in the FFS Report for this
alternative, although neither the Proposed Plan nor the FFS Report provide information about, the •
development of this cost estimate or the items which it includes, as the FFS Report does for all of the
other alternatives. EPA should explain why the cost which is listed here differs from the FFS Report
so that it may be reproduced by the reader from documents available in the Administrative Record.
Page 7, Reasons for EPA's Proposed Remedy, 2nd Para. - The next to the last sentence in this
paragraph implies that EPA could buy residential property or permanently relocate people. The last
sentence in this paragraph implies that the remedy which has been selected would be inadequate if
buy-out does not occur. The Respondents believe both implications to be incorrect. Therefore, these
sentences should be modified to say that if buy-out fails, the EPA may need to re-evaluate the
alternatives and/or work with the Respondents to implement Alternative 4 in a way which ensures
that the concerns of nearby residents are adequately addressed.
Remedy Design and Supplement (may be best addressed in ROD or during remedial design)
Page 6, Column 2, Para. 4 - This paragraph states that the SVE system would be required to operate
for five years to meet short-term performance standards. Since the design is conceptual, this
assumption is appropriate for purposes of the Proposed Plan. However, the Respondents believe that
before the remedy is built as well as while it is in operation additional work will be necessary to
verify this assumption.
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Supplement to the Proposed Plan - The Supplement contains several SVE design assumptions
which appear to be reasonable for purposes of the Proposed Plan given that the design of the remedy
is conceptual. These include the assumption that an SVE system which targets both coarse- and fine-
grained soil would provide greater groundwater protection, that this system would be adequate to
address uncertainties in site specific data, and that this system would provide the "widest reasonable
buffer" between the contamination in the pits and groundwater. The conceptual design of the SVE
system included in the Proposed Plan is adequate for screening of alternatives and final selection of a
remedy. However, the Respondents believe that those assumptions should be revisited during
preparation of the ROD and/or during remedial design to ensure that the SVE system is reasonable,
practical, and cost effective (criteria which are listed in the Supplement). Some of the specific
assumptions which the Respondents believe should be revisited at that time are discussed below.
The text on page 2 of the Supplement states that there is higher certainty that groundwater will be
protected with Scenario 2. This assumes that protection of groundwater in soil below the pits would
be improved by the application of SVE to fine-grained soil in addition to coarse-grained soils.
However, protection of groundwater may be achieved by application of SVE to coarse-grained soil
alone (e.g. establishing a containment layer in the coarse-grained soils).
The text on page 3 of the Supplement, Soil Contribution to Groundwater, paragraph 1, indicates that
there is a need to split the difference between the range of attenuation factors, although there is no
documentation in either the Proposed Plan or the FFS Report which supports selection of 10 as an
appropriate value. It may be more appropriate to select a value of 100 since it is often assumed for
evaluation of waste at RCRA facilities. Assuming that an attenuation of 100 is appropriate, and
assuming EPA's incremental increase of 0.5 percent is appropriate, Case 3 from Table 1 of the
Supplement should be chosen for use in selecting the performance standards used to design the SVE
system. Since attenuation is affected by the distance of travel, permeability, carbon content and
moisture content of soil, another approach would be for EPA to use different attenuation factors for
different soil types at various distances above groundwater.
This same section discusses the definition of a "significant" incremental increase in groundwater
concentrations. The Respondents believe that neither the Proposed Plan nor the FFS Report provide
rationale which support the assumption that an incremental increase of 0.5 percent would be
insignificant while one of 2 percent would be significant and it is noted that in many engineering
disciplines, either of these (e.g. less than one order of magnitude) would be considered negligible.
EPA may want to consider defining significance in terms of the impact that the increase in
concentration has on the effectiveness of the remedy which is ultimately selected for groundwater.
For example, a significant incremental increase in groundwater concentration is that increase which
measurably reduces the effectiveness of the groundwater remedy selected for implementation at the
site.
We believe that further evaluation of these issues is needed to refine the design of the selected
remedy so that it provides reliable, long-term protection of human health and the environment, is
easy to implement and maintain and is cost effective. The Respondents will assist EPA in whatever
way is most appropriate in evaluating these issues further during preparation of the ROD and/or
remedial design.
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U.S. Environmental Protection Agency
Februarys, 1997
Page 2
Please contact me if you have questions about any of the comments or require additional
information.
Sincerely,
C.g.
C.B. Paine
Coordinator for Respondents
Attachment
cc: Gloria Conti, DTSC
Larry Bone, Dow
John Gustafson, Shell
John Dudley, Dames & Moore
Dave Laney, Dames & Moore
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References
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NOV- 6-96 WED 12:53 DAMES & MOORE
DAMES & MOORE
A DAMES & MOORE GROUP COMPAMy
FAX NO, 6028617431
U^
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Fax sheet
7500 Nonh Dreamy Draw Drive
Suite 145
Phoenix, Arizona 85020
£02371 1110 Tel
602161 7431 Fax
To
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Fa* Number
From
Date
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No. ofpago* —p Including COVOT «h««t I TMk/Job No. /J/O"7//1 —
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11/06/96 WED 12:53 [TX/RX NO 6231J
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NOV- 6-9B WED 12:54
DAHES & MOORE FAX NO. 6028617431 V.
The Proposed Plan should identify the elements of the remedy (i.e. RCRA-equivaleiit cap +
SVE) and should indicate that the design and cost of the remedy will depend on the
performance standards which are selected. The Proposed Plan should identify and discuss the
performance standards which have been agreed to by EPA and the Respondents and present
the range of costs which correspond to the various standards which are currently under
consideration. The two options include:
Option 1 for Presentation of Cost
Cost of remedy (assuming this is Alt 4) using minimum SVE system = $4.9 to $10.4 million
Cost of remedy (assuming this is Alt 4) using maximum SVE system = $5.1 to $15.4 million
It should be noted that this information has been added to page 7-39 of the FFS Report at the
request of Janet Rosati in response to comments in a letter dated October 18, 1996.
Option 2 for Presentation of Cost
Cost of remedy =* $5.6 to $8.98 million
This range assumes that the remedy will be either Alternative 4 or 4A (sec attached table).
11/06/96 WED 12:53 [TX/RX NO 6231)
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NOV- 6-96 WED 12:54
DAMES & HOORE
FAX NO. 6028617431
COST ELEMENT
1) RCRA-Equivalent Cap
a. Capital Costs
b. O$M Costs (30 years)
Subtotal (la+lb)
2) Soil Vapor Extraction
a. Capital Costs
b. O&M Costs
Subtotal (2a + 2b)
TOTAL
ALTERNATIVE 4{1)
$2,670,000
$1,410,000
$4.080.000 (
$970,000
$550,000 (3 years)
$1,520.000
$5,600.000 (^
ALTERNATIVE 4A
(EPA PROPOSED
REMEDY)™
$2.670,000
$1,410,000
's^ToibToSCK
$3,620.000
$1,280,000 (5 years)
1^4^0.000^
"$8^980,000^
monitoring weU clusters (30 depth discrete monitoring locations) and targets coarse grained
vadose zone soil only.
(a>The SVE system which is included in this alternative includes 140 extraction wells and 18
monitoring well clusters (54 depth discrete monitoring locations) and targets both fine and
coarse grained vadose zone soil. It is the same as Scenario 2. Case 2 shown in Table 8.4-1 of
the FFS Report.
11/08/96 WED 12:53 [TX/RX NO 6231]
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References
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r^OM'EOP tlROUP INC (THU) 2. I 3 97 I! : 4 ) /ST. 1 1 : < I ''NO. 4 26O5 6 6 O<; 3 P 1
THE EOF GROUP
1725 DeSales Street, N. W. 202/833-8940
Washington, D.C. 20036 Fax 202/833-8945
PLEASE DELIVER AS SOON AS POSSIBLE
TO: John Wise, EPA Regional Administrator
tax: 415 744-2499
FROM: Michael O'Bannon
DATE: 2/13/97
NUMBER OF PAGES: (including cover)
MESSAGE:
John,
Per our discussion this morning, here are the documents we need to take action on.
Michael
VERY IMPORTANT NOTE
Tbe information contained in tbit faaimile metiage it privileged and confidential information intended only for the me of the
recipient named above. If the reader ofthii menage it not the intended, or the employee or agent retpoiuible, diitribution or
copying oftbit document or itt contents it ttrictly prohibited. If you have received tbit document in error, plcaie immediately
notify u by telephone, and return the original faaimile to m at the above addrett via u.t. mail. Thank you.
-------
EOF CROUP INC
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TSOM HOP CROUP . M-
ITHU) 2. 13' 97 1 1 :43/ST. I 1 :41/'NO. 4260568043 P 7
THE EOF GROUP. INC.
The EPA staff approach would require many more wells to achieve the same interception
percentage. Be cause some of the soil layers are much less permeable, wells attempting
to achieve the goal in these layers will not have as large of an area I zone of influence.
Monitoring suggests that the groundwater plume beneath the pits has reached a steady-
state between lateral expansion and decay. Therefore, an intensive SVE system is not
necessary to halt the lateral migration of the plume.
EPA staff also suggest that a n intensive SVE system must clean up the soils so that
rising groundwater
In addition, the more aggressive SVE system increases the chance that the SVE system
will extract benzene from the capillary fringe between the vadose and saturated zone.
In other words, the EPA staff SVE system is likely to extract benzene from the highly-
contaminated groundwater.
Policy Analysis
The goals of the SVE system must be considered in the context of both the groundwater
and the pit remedies. While the groundwater remedy has not been selected, it is
reasonable to expect that the area immediately below the pits will be contaminated for
a long time.
The respondents proposed the 2 percent control objective for the SVE system. Given the
high level of contamination in the groundwater and the lack of lateral migration of the
current, uncontrolled plume, the additional stringency of the EPA staff alternative is
unnecessary.
The more expensive SVE system will not reduce human or ecological exposure to
groundwater contamination. It will also not reduce potential exposure since the plume
is not migrating beyond its current lateral extent.
The SVE system designed to prevent further migration to groundwater, not to clean it
up. EPA will address the groundwater remediation in the near future.
The EPA staff SVE design is more complex and prone to equipment failure. If the SVE
system is out of service more frequently due to repairs, the net flux of benzene to the
groundwater could be comparable to the 2 percent system.
Therefore, the respondents believe spending an additional $3.7 million (present worth)
to reduce the input concentration from 1/2000 to 1/8000 is not a cost-effective
expenditure.
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F,;OM EOF CROUP INC ITHU) 2. 13'9711:43/'3T. ll.1i.-N.Jt.i
THE HOP GROUP. INC
Next Steps
The ROD should contain a less complex and costly SVE system for the pit remedy.
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Reference 10
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JAN-24-97 FRI 17:42 DAMES & MOORE
FAX NO. 6028617431
P. 01
DAMES & MOORE
A DAMES* MOORE GROUP CQMfHNy "
Fax sheet
7500 North Dreamy Draw Drive
Suite 145
Phoenix. Arizona 15020
602 371 II10 Tel
602 S61 7431 Fix
Company
Fax Number
H Of 0
No. of page*
Oparator
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JAN-24-87 FRI 17:42 DANES & KOORE FAX NO. 6028617431 P.02
NON-TECHNICAL EDITORIAL * TYPOGRAPHIC CORRECTIONS
The use of die torn "cleanup" throughout the Proposed Plan and Supplement may Invoke a different
, mental Image b the public thaa nay be merited given the remedy which is proposed If this term means
' restoration, neither a cap nor me SVE system will "cleanup" waste or contaminated soIL Use of
"remediation", "remedial action" or "response action" may be man appropriate.
0 Data are generally plural, not singular (see Page 2,4* Full Para., 3* and 4* sentences).
The term "Waste Pit Area" should be capitalized whenever used. Because it is better defined, it may be
") beneficial to use mis term in place of "waste pit property", tbe "Del Amo Waste Pitt", etc.
Page 4, Item No. 2 - Uncertain Long-tern Controls - Several tamer absolute statements are made in mis
^ section. Example No. 1: "There is a significant poasibilily that exposures wfll occur in the future." Example
No. 2: "There Is significant uncertainty about whether existing controls win be maintained as long as waste
remains in place." The documentation to support these statements is missing from me Proposed Plan aad
the FFS Report Furthermore, use of the term "significant possibility" raises a question as to whether or not
mis is the same as a "probability". Perhaps these sentences should be reworded to improve their accuracy
and/or a reference should be provided to show work that EPA has done at this, or other sites, which support
the statements as they are currently worded
^ Page 5, Alternative 3, Last Bullet - As written, it sounds as though the concern is that rainwater will wash
sofl into groundwater. Shouldn't the word "contaminants" be inserted into this sentence?
Page 5, Lust Two Bullets In Column 1 - The objectives of the cap which are included in Alternative 3 are
b the same as the objectives of the cap included in Attantative 4. However, the way the objectives for
Alternative 4 are worded in the fourth and fifth bullets at the bottom of the second column on page 6 are
different man the way the objectives for Alternative 3 are worded Presumably, me reason for this
difference is that the objectives in question for Alternative 4 include both a cap and SVE. Wouldn't it be
better if the objectives for both alternatives were the same when discussing the cap? Wouldn't it be bettor if
objectives for SVE were listed separately from those of the cap for Alternative 4?
Page 12, Redaction of Taxiclty, Mobility and VotamtfTMV) Tfcrovgb Treatment - It appears that
1 TMV is abbreviated in the title of dils section but is used inconsistently or not at all Regardless of which is
the most appropriate, wouldn't ft be preferable if consistent use of either the abbreviation or the full name
occurs in the Proposed Plan and the ROD?
Supplement. Page 1, Purpose of Son Vapor Extraction, Para. 3,3rd Sentence • Would it be better to
c say "waste pits incremental groundwater contribution" rather than "waste pits inaemeotal groundwater
concentration"?
^ Supplement, Throughout • It is noted mat the terms "technical options", "SVE scenarios", and "cases"
are used throughout the Supplement Wouldn't it be better if these terms were defined or if they refer to the
same thing, mat only one of the terms be used consistently throughout the Supplement?
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JAN-24-97 FRI 17:43 DAMES & MOORE FAX NO. 6028617431 P.03
TECHNICAL CORRECTIONS TO BACKGROUND INFORMATION
(Eastern Evaporation Pond and Pit 1 -A) and u 3.7 acres iniize. (ttlso appears is though the 2 series pits
shown on Figure 1 are out of position and too close to homes. The Respondents have been required to
survey the WistePfcAroa and prepared numerous detailed plans, map* tod figures of the Waste Ph Am
over the last 12 yean and would appreciate to opportunity to assist EPA by providing figure* of the Waste
Pit Area to die agency for use in future publications.
Page 1, Para. 7 (2- Pan. Under Site Characteristics) - Average depth of waste below tend surface fat 1 -
Page 2, 1st Partial Para. - While the "lateral extent of the cc«tanoinstion b confined witnin the inner
, fence area" it ls primarily in a limited area directly below the outline of the former waste pits and ponds.
' As written, the text implies uniform or extensive contamination out to the fence line which is not the case.
There are significant areas within the fenced area which are not contaminated above levels of concern.
, Page 2, 2- FDD Para: • While HjS emissions do occur when waste is exposed to air, the waste must also
be disturbed. It is unlikely that exposure to air would cause H.S emissions.
Tabk 1 - When providing information about me concentration of Total VOCs and Total SVOCs in soli
*i beneath and adjacent to the waste pits, it is important to note the proximity of mis soil to the waste. For
example, most of the highest concentration of soil contamination is within 5 feet of the waste.
Page 6, Comma 1, 1st Partial Para. - While it is true that the me of SVE in waste would be ineffective,
the statement The SVE system would not be applied to the waste material itself; because it is too dense to
create a vacuum" provides an inaccurate description of the reason why this is so. Creating a vacuum locally
Y around an extraction well hi dense, noo-permeable materiab racb as the waste is easy. The low
permeability (ability to transmit flow) of the material limits the flow rate of air that can be generated even
at very high applied vacuums. It fa this low flow rate which limits the effectiveness of physical separation
techniques such u SVE in dense, non-permeable materials such as the waste.
Page 7, Reasons for EPA's Proposed Remedy, 1st Para. - EPA should check with the Deparment of
.., Toxic Substances Control (DISC) to see what it would l& e to be called. In the past, it has preferred "the
-' Department" to DTSC. This paragraph uses both. The same convention should be used throughout me
Proposed Plan and the ROD.
Supplement, Page 2, Box • The use of the word "pure" to describe aNAPL may be confusing to some
__ readers. Some NAPLs are mixture* of several or many chemicals and thus, they are not present in mebr
'( pure form. By the definition given fbrNAPL here, there are no NAPLs at me Del Amo site since mere are
no examples of "pure" benzene. A NAPL is • free Hquid mat is a sepmnaa phase (Illiquid gasoline) from
the moisture, vapor or solid components of the sofl matrix.
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JAN-24-87 FRI 17:44 DAMES & MOORE FAX NO, 6028617431 P. 04
ADMINISTRATIVE A/TO PROCEDURAL CLARIFICATIONS
Page 1, Pin. &, Sentence 2/Page 7,3rd ParajSupplemcmt Page 1, Purpose of Sofl Vapor Extraction,
Para.1 - K ippcan that the Proposed Pirn refers to Ifae remedy «• M interim measure fbr waste, toil
and/or groundwater. h was the Respondents' understanding that the selected remedy ii a final and not aa
interim remedy far waste and soil, and because h specifically excludes remedial technologies for
remediation of contaminated groundwater, It is not any Jdod of remedy (interim or otherwise) for mis
media. To say that the remedy k an interim fix for waste or soil implies mat further action may be taken in
the future to replace of significantly augment the remedy - something which the Respondents believe will
be unnecessary. To say that this b a groundwater remedy implies active remediation of this media —
something which is missing by intention from the conceptual design of all alternatives in the FFS Report
Page 1, Column 2,1st Para. - The Proposed Plan appears to say mat "Subsurface Gas" is a media which
must be treated separately from waste and sofl. "Subsurface Gas" is part of waste or "soIT and should not
}_ be considered as a separate media to be addressed by the remedy. The reme
-------
Jf
-------
Col/EPA
February 7, 1997
Department of Pete Wllson
Toxic Substances Governor
Control
James M. Strock
145 West Broadway. Mr . Dante Rodriguez """"*,
?»/;>/> 47 1 ... - _ . z -i „ x. • « Environmental
w U.S. Environmental Protection Agency
*«*. C4 R ion IX y
90802-4444 Code
75 Hawthorne Street
San Francisco, California 94105
Dear Mr. Rodriguez,
PROPOSED PLAN, DEL AMO WASTE PIT AREA
The Department of Toxic Substances Control (DTSC) has
reviewed the above referenced document, dated December,
1996, and attended the public meeting, held on January 29,
1997. The following comments pertain to the Final Focused
Feasibility Report and the Proposed Plan:
1. DTSC's comment letter of November 12, 1996, on the
Final Focused Feasibility Study, dated December 10,
1996, has not been addressed in the Proposed Plan.
2. DTSC's letter on State Applicable or Relevant and
Appropriate Requirements (ARARs) , dated August 7, 1996,
was not completely addressed in the Final Focused
Feasibility Study report.
Therefore, at this time DTSC does not concur with the
Proposed Plan remedy until these issues are resolved.
If you have any questions or would like to schedule a
meeting to resolve these issues, please contact Ms. Gloria
Conti at (562) 590-5566. Thank you".
Haissam Y. Salloum, P.E.
Unit Chief
Site Mitigation Cleanup Operations
Southern California Branch(B)
cc: See next page
-------
Mr. Dante Rodriguez
February 7, 1997
Page 2
cc: Mr. John Lyons, Esq.
Assistant Regional Counsel
U.S. EPA, Region IX
Mail Code RC-3-2
75 Hawthorne Street
San Francisco, California 94105
Mr. Randall Heldt, Esq.
Legal Department
Shell Oil Company
One Shell Plaza
Houston, Texas
Mr. C.B. (Chuck) Paine
Shell Oil Company
Environmental Remediation- West Coast
P.O. Box 25370
Santa Ana, California 92799
Mr. John Dudley
Dames and Moore
5425 Hollister Avenue, Suite 160
Santa Barbara, California 93111
Mr. Dave Laney
Dames and Moore
7500 North Dreamy Draw Drive, Suite 145
Phoenix, Arizona 85020
Mr. Jim Ross
California Regional Water Quality Control Board
101 Centre Plaza Drive
Monterey Park, California 91754-2156
Mr. Joe Tramma
South Coast Air Quality Management District
Stationary Source Compliance
21865 E. Copley Drive
Diamond Bar, California 91765-4182
Mr. Michael Martin
Department of Fish and Game
CERCLA/NRDA Unit
Marine Pollution Laboratory
20 Lower Ragsdale Drive, Suite 100
Monterey, California 93940
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FROn:OMNIFPX
TO:
415 744 2180
DEC 11, 1996
= 37Pn W985 P. 01
TELEFAX TRANSMITTAL FORM
CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
SITE MITIGATION BRANCH
Long Beach Office
245 W. Broadway, Suite 350
Long Beach, California 90802-444
(310) 590-5584/ (310) 590-4922 FAX
ColNet 8-$35-5584/8-635-4922 FAX
Dale: /«*V///%
To: JV,/^ ftoJr;*,jf^
Co./Dept.
Phone*
Fax #
# of Pages (including cover):
From: &*'/6/'s6t LA
/0
' _t-
rl I f
Co.
Phone #
Faxtf
Subject:
Comments:
D Urgent-Hand Carry!
D Confidential
D Information
D Per Your Request
D Please Comment
D Original Will Not Follow
-------
FROn:OMN,FflX TO: 4157442190 DEC 11, 1996 1:37PM 8985 P.02
Cal/EPA
December 11, 1996
Department of Pete Wllsm
Toxic Substances Governor
Control
James M. Sirock
245 West Broadway, Janet Rosati Secretary for
Suite425 U.S. Environmental Protection Agency bjmronmenial
l*ng Beach. CA Region IX Protection
90802-4444 Mail Code H-7-1
75 Hawthorne Street
San Francisco, California 94105
Dear Ms. Rosati,
FINAL FOCUSED FEASIBILITY STUDY REPORT, DEL AMO WASTE
PIT AREA
The Department of Toxic Substances Control (DTSC)
has reviewed the above referenced document, dated
September 4, 1996, as well as the responses to our
comments to the previous Final Focused Feasibility
Study Report (FFFS), dated September 30, 1996. The
following are DTSC's Geologic, Engineering, and
Toxicological comments.
SPECIFIC GEOLOGIC COMMENTS
l. Page 7-27 states that "at a minimum, this system
would include vapor extraction wells located
beneath each waste pit and multiple completion
monitoring wells at the end of and in between each
pit". Monitoring points are also necessary on the
north and south sides of the pits at various
depths. At a minimum there should be one set of
monitoring points no deeper than the pits
themselves and another set placed deeper than the
pits. The spatial variability of the sediments
makes it unreasonable not to monitor the sides of
the pits. It can not be assumed that the
performance observed between the pits will be the
same as that on the sides of the pits. In
addition, since there will be no remediation of
the pits themselves, monitoring on the sides of
the pits is necessary to demonstrate that the
conditions used in the risk assessment remain
relatively unchanged.
2. The report states that the groundwater in the
vicinity of the Del Amo Pits has been rising at a
rate of one foot per year. The capillary fringe
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FROn:OMNIFftX T0= 415 744 21B0 DEC 11. 1996 I'SBPM «985 P.03
Ms. Janet Roeati
December 11, 1996
Page 2
above the water table may be somewhere between
five to ten feet depending upon the grain size of
the deposits. Once the capillary fringe rises
into the vapor extraction wells the radius of
influence will be greatly reduced because it is
not possible to get airflow through a saturated
media. The conceptual plan for the SVE system
does not include a contingency plan to deal with
the rising groundwater. The rising groundwater
must be taken into consideration at this point in
the process in order to ensure that a viable
extraction system is eventually designed and
constructed.
3. Table 7.0-4 "Summary of Analyses for Short-Term
Effectiveness Del Amo Waste Pit Area" indicates
that remedial response objectives will be reached
for Alternative 4 in eight months to a year. It
is not clear how the system will be monitored
after the response objectives are reached. The
continued monitoring is important for a variety of
reasons. For example, the soil may become re-
contaminated by diffusion from the waste pits
above the soil; depending upon the design of the
SVE system unscreened zones within the soil may
re-contaminate the screened zones through
diffusion; and cleanup goals for groundwater will
change the goals for the contaminated soils. In
addition, since the soils may become re-
contaminated, the eight month to one year
operation time may be an underestimate of the
amount of time the SVE system will need to
operate. Continued monitoring and potential
restart of the SVE system must be clearly
addressed if SVE is chosen as the remedial
alternative.
GENERAL ENGINEERING COMMENTS
Included in the following sections are
clarifications in support of OTSC comments to the
responses made by Dames & Moore, regarding the cost
analysis DTSC performed on Alternatives 3 and 4
utilizing the RACER cost estimating software. These
clarifications were performed by Mr. Jesus Sotelo, for
Alternative 3, and Mr. Bal Lee, for Alternative 4, of
DTSC's Engineering Services Unit, and the detailed cost
estimates can be provided upon request. While there
remain discrepancies between DTSC'a cost estimates and
the FFFS, the cost estimates presented fall into the
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FROM:OriNIFflX TO: 415 744 2180 DEC 11. 1996 1 :38Pn «985 P.04
Ms. Janet Rosati
December 11, 1996
Page 3
acceptable accuracy range of + 50 percent to -30
percent as specified in EPA's Guidance for Conducting
Remedial Investigations and Feasibility Studies Under
CERCLA (October 1988).
1. The Report now refers to a performance standard
for Soil Vapor Extraction (SVE) that will be tied
with the goals for a ground water remedy. The
ground water remedy is to be selected after the
remedy for the waste pits. For this performance
standard, the SVE treatment system's purpose is to
reduce soil contaminant concentrations below the
waste pits. The concentrations will be reduced to
a level such that once the contaminants reach the
ground water, the contaminant concentrations are
no more than the Maximum Contaminant Level (MCL).
Given that a ground water remedy has yet to be
selected, we concur with this approach for
minimizing further impacts to the ground water.
However, we request that the following additional
information be provided:
a) A proposed monitoring plan, including
monitoring of lateral migration of all
contaminants (including Volatile Organic
Compounds (VOCs)) from the waste pits, to
assess when clean-up objectives have been
met;
b) Physical parameters to be measured to assure
the clean-up objectives have been met; and
c) Proposed ground water monitoring methods for
determining ground water impacts based on the
physical parameter measurements.
2. As recommended in DTSC's previous comments, we
suggest that the SVE treatment system be extended
to incorporate contaminated soil regions beyond
the footprint of the waste pits, but terminating
above the capillary fringe. This suggestion is
based on the following reasons:
a) one of the 4 principle goals which the cap
and SVE system will address is to "protect
future ground water users from contaminants
which may leach out of the pits in the
future," as stated on page 7-26 of the
Report. This goal is indicative of the
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FROrrOMNIFAX TO: 415 744 2180 DEC 11, 1996 i:39PM H985 P.05
Ms. Janet Rosati
December 11, 1996
Page 4
potential of contaminant migration beyond the
pits' perimeters; and
b) reiterating previous comments, Figures 2.2.2-
2, 2.2.2-3, 2.2.2-7, 2.2.2-8, and 2.2.2-9
indicate numerous zones of contaminated soil
at various depths which extend beyond the
pits' perimeters. Infiltrating rain water
migrating through these contaminated soil
zones will move unabated to the ground water.
The capture zone of the SVE treatment system
should be thick enough to prevent impacted
rain water infiltration from migrating to the
ground water. The Final Report should
contain modeling based justification to show
the proposed thickness of the capture zone
will prevent this possibility.
3. DTSC concurs that the graphical representation
indicating the areas of proposed treatment beneath
the waste pits is not applicable for alternatives
1, 2, and 3. However, a graphical representation
would clarify proposed treatment areas for
alternatives 4 and 5 beneath the waste pits. We
reiterate the need for a graphical representation
of the extent of contamination for proposed
interim treatment for alternatives 4 and 5. We
suggest Figures 7.4.1-2 and 7.5.2-2 be revised to
include the contamination levels beneath the waste
pits as shown in Figures 2.2.2-7 through 2.2.2-9
of the Report.
SPECIFIC ENGINEERING COMMENTS
4. (Figure 7.4.1-1) - In order to maintain
consistency with Section 8, we suggest this figure
include the following note: "The number and
location of SVE wells may change pending the
selected performance standard and/or if SVE is
used to target different areas of the vadose zone
soils."
5. (Page 8-3 Sections 8.3 and 8.4) - It is suggested
that the Costs of SVE Design Scenarios include
soil gas monitoring probes, at varying depths
around the perimeter of the pits, for containment
and prevention of lateral soil gas migration.
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FROM'OnNIFflX TO: 415 744 2180 DEC 11. 1996 1:39Pf1 «985 P.06
MB. Janet Rosati
December 11, 1996
Page 5
6. (Table 8.5-1) - It IB suggested that all 5 cases
of each scenario, for both short and long-term
performance standards, be included in this table.
7. (Appendix F) - We reiterate our previous comment
and suggest the same 15% contingency be applied
consistently to all discount rate scenario
analyses for the cost evaluation. It was evident
from the review of the cost tables that tables F-
2d. F-2e, F-3d, F-3e, F-4d, and P-4e remain
inconsistent with respect to the 15% contingency
used in the remainder of the tables. The total
capital costs of each alternative is impacted by
the chosen contingency percentage.
8. (Appendix F) - Table F-2d states a contingency of
7.5%, yet a contingency of 8% is used in computing
the direct cost. We suggest the same contingency
be used throughout the cost tables.
RACER COST ESTIMATE CLARIFICATIONS
Alternative 3 - RQRA-Equivalent: Cap
The Remedial Action Cost Engineering and
Requirements (RACER) system is developed by the U.S.
Air Force and is a PC-based environmental cost
estimating system that will accurately estimate costs
for all phases of remediation: Studies (PA/SI, RI/FS,
and RFI/CMS), Remedial Design, Remedial Action
(including Operations and Maintenance), and Site Work
and Utilities.
In response to the comments provided in Table 1,
Comparison of Selected Assumptions, DTSC Versus Dames &
Moore Cost Estimates, RCRA-Equivalent Cap Portion of
Alternatives 3 & 4, Focused Feasibility Study, Del Amo
Waste Pit Area, (Page 2 of 5), under item "Ground Water
Sampling During O&M," and under column "DTSC Estimate
of Cost of Item," the actual RACER default sampling
costs are not $1080 per VOC. Rather, this number is
the total number of samples collected and analyzed
during the 30 year period, for quarterly sampling at 9
samples each quarter. The actual RACER estimate for
the complete monitoring is $853,466 for 30 years. This
figure is in line with Dames & Moore's estimate of
$900,000 and the column "Additional Cost Because of
DTSC Assumptions" incorrectly calculated at $7.5
million should show a negative $46,000 or ($46,000).
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FROrrOMNIFftX
TO: 415 744 2180 DEC 11. 1996 1:40PM tt985 P. 07
Ms. Janet Rosati
December 11, 1996
Page 6
RACER includes other cost modifiers that are
identified ae Project Modifiers. The Project Modifiers
are listed and described below.
Qehedule Or Esca^gtion Factor
The Schedule module calculates the total duration
for Studies, Construction, and Operations & Maintenance
(O&M) for each site within the project. The start
date, along with the duration, will establish the
midpoint for the category. An escalation factor will be
calculated for each category with a valid start date
and duration. This escalation factor is used to
escalate all costs associated with the category for
reporting purposes. RACER states that the cost base of
the estimates is January 1995 (collected data from
vendors and past records of completed RAs) . Because of
this cost basis the estimate needs escalation to the
assumed construction time of June 1996. The 30 years of
O&M (until July 2011) were escalated and brought back
to the present worth.
Proect
Project management is the cost paid to government
agencies and/or contractors for contract management,
supervision, and oversight. This project management
task is not associated with the implementation of
specific Studies, RD, or RA tasks where project
management is applied in the individual models. It does
take into account reporting requirements of the
specific tasks as prescribed by the project contract.
Project management is similar to the Supervision,
Inspection, and Overhead (SIOH) payments made by the
Air Force to the Corps of Engineers and the Naval
Facilities Engineering Command for Military
Construction Program Contracts. Currently, the Air
Force uses several different service centers to
administer remediation contracts. These include the Air
Force Center for Environmental Excellence (AFCEE) , the
Army Corps of Engineers, and ORNL/HAZWRAP . The project
management cost charged by these different agencies
varies between different contracts. The default is 10%
for all project phases and contract types. The software
provides flexibility in the application of this cost
and the program user is encouraged to verify and modify
this value as appropriate prior to completing an
estimate. in this case, costs for Project Management
oversight were not included.
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FROn:OMNIFAX TO: 415 ?44 2180 DEC 11. 1996 i:40PM 8985 P.08
Me. Janet Rosati
December 11, 1996
Page 7
Contingencies
Contingencies are added to the project estimate to
allow for cost increases that may occur as a result of
unforeseen conditions and changes that normally occur
on remediation projects. We have followed the
methodology of RACER to include the contingency to the
total costs since this is a +30% to -50% cost estimate
and USEPA has done so on other sites, including
Stringfellow. It appears from the response to comments
that we are in agreement regarding what percent to
apply for contingencies (15%). It appears that our
contingencies (in dollar amounts) are to a greater
degree a small percentage of the total estimated cost
for Capital and OfcM.
Alternative 4 RCRA-Equivalent Cap ->• Soil Vapor
Extraction fSVEl
In DTSC's previous comments, we summarized RACER
cost estimates for Alternative 3 ($8 million) and
Alternative 4 ($10.9 million), which leads to the SVE
portion of the estimate for Alternative 4, which is
$2.9 million. The Report's SVE portion was $1.2
million ($3.7 and $4.9 million for Alternatives 3 and 4
respectively) . According to Table 2 in the Response to
DTSC Comments on the Final FPS Report, Del Amo Waste
Pit Area, we have overestimated the SVE estimate by
$2.6 million, (i.e., only $0.3 million is for SVE,
according to the Report). This is self-contradictory.
Most items in Table 2 are either inaccurate or very
minor cost items which should not be an issue for a
+30/-50 % cost estimate. After adjusting all corrected
Table costs (see the attached marked-up Table' 2) , our
SVE estimate is $2.3 million. The following are the
item-by-item responses to Table 2 items:
1. Field sampling mobile lab ($184,443, or $195,592
in our RACER output dated 6/10/96): This cost
corresponds to the item 33.02.96, Field
sampling/mobile lab, on page 22 of the Detail Cost
Report. This is for part of the 30 year O&M of
the SVE unit. In reality, the SVE unit will
operate continuously for the first 3-5 years,
followed by intermittent operation for perpetuity.
We made the assumption that the additional 25 - 27
years of continuous operation is equivalent to
total operational costs for intermittent operation
for perpetuity.
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FRCTPOMNIFOX TO: 415 744 2160 DEC 11, 1996 i:41PM 8985 P.09
Ms. Janet Rosati
December 11, 1996
Page 8
As indicated on the RACER output page, the cost of
$195,592 is for monthly SVE air effluent
monitoring for 30 years: 1)OVA rental for (2
days/mo)*(12 mo)*(30 years) (due to absence of on-
site FID module in RACER) , and 2) field
technician, (8 hrs/mo)M12 mo) * (30 years) .
2. SVE O&M ($1,123700): Because of the way RACER is
set up, this item has been double-counted (two SVE
modules were used for shallow and deep
contamination areas). This should be reduced by
one half, or by $561,852.
3. Lab cost for monitoring during O&M ($14,760) : This
is for off-site lab analysis of SVE air effluent
twice a year for 30 years. See the response #1
above for the rationale of using a 30 year O&M.
4. Contingency: DTSC's believes that its methodology
for calculating the contingency is appropriate.
See response to Table 1.
5. Escalation ($761,481): Page 1 of Project Cost
Report, RACER provides that l) the cost base of
RACER was 1/95 (needs escalation to the assumed
construction time of 6/96), and 2) 30 year O&M
(until July, 2011) was assumed for the SVE unit.
O&M costs were escalated and brought back to the
present-worth cost. See DTSC's response to FFPS's
Table 1 for details.
TOXICOLOOICAL COMMENTS
The revised Health Risk Assessment (HRA) contained
in this FPFS is adequate to assess the risk/hazard from
contaminants at the Del Amo Pits. DTSC would
ordinarily consider all pathways, however in this case,
the air exposure pathway has been found to be the major
contributor and the other pathways are incomplete. The
movement of contaminants to groundwater has not been
included in this HRA, but will be addressed for the
whole site when the Remedial Investigation for
groundwater is complete. It is expected that any
resultant hazard or risk identified from migration to
groundwater would be additive with the hazard and risk
from the air pathway.
-------
FROn:OMNIFRX TO: 415 744 2180 DEC 11, 1996 IMlPM 8985 P. 10
Ms. Janet Rosati
December 11, 1996
Page 9
If you have any questions, please contact Ms
Gloria Conti at (310) 590-5566. Thank you.
Sincerely,
4*&T~
Haiesam Y. Salloum, P.E.
Unit Chief
Site Mitigation Cleanup
Operations
Southern California
Branch
cc: Mr. C.B. (Chuck) Paine
Shell Oil Company
Environmental Remediation- West Coast
P.O. Box 25370
Santa Ana, California 92799
Mr. John Dudley
Dames and Moore
5425 Hollister Avenue, Suite 160
Santa Barbara, California 93111
Mr. Dave Laney
Dames and Moore
6 Hut ton Centre Drive, Suite 700
Santa Ana, California 92707
-------
SFUND RECORDS CTR
1050-01025
CallEPA
Department of
Toxic Substances
Control
August 7, 1996
AR0599
245 West Broadway, Janet Rosati
Suite 425 U.S. EPA, Region IX
Long Beach, CA Mail Code H-7-1
90802-4444 75 Hawthorne Street
San Francisco, California 94105
Dear Ms. Rosati,
DEL AMO PITS SUPERFUND SITE PROPOSED STATE APPLICABLE
AND RELEVANT OR APPROPRIATE REQUIREMENTS (ARARS)
The Department of Toxic Substances Control (DTSC)
submitted to the U.S. Environmental Protection Agency
(EPA), in January, 1994 and December, 1993, proposed
State ARARs from DTSC, the California Regional Water
Quality Control Board (RWQCB), South Coast Air Quality
Management District (SCAQMD), and the Department of
Fish and Game (F&G). These ARARs had been submitted
jointly for both the Montrose and Del Amo Pits
Superfund sites, since we had been working on these two
sites cooperatively. DTSC would like EPA to consider
all previously submitted ARARs, as well as the
additional ARARs included in this letter.
Copies of DTSC's letters with the attached ARARs
are enclosed. The following is an itemization of what
those letters included.
A. DTSC letter, dated January 14, 1994, to EPA
(Mr. Tom Dunkelman) contains:
1. RWQCB Memorandum, dated January 11, 1993
(sic.);
2. SCAQMD letter, dated January 11, 1994.
B. DTSC letter, dated December 2, 1993, to EPA
(Ms. Nancy Woo) contains:
1. DTSC attachment;
2. RWQCB Memorandum, dated November 29, 1993;
3. RWQCB Memorandum, dated October 19, 1993;
Pete Wilsor
Governoi
James M. Siroci
Secretary fo:
Environmenta.
Protectioi
-------
Ms. Janet Rosati
August 7, 1996
Page 2
4. SCAQMD letter, dated October 29, 1993,
5. F&G letter, dated October 15, 1993.
ADDITIONAL ARARS
1. Title 22, CCR Section 66262
2. Title 22, CCR Section 66264
3. Title 22, CCR Section 66264.90 or 66265.90 as
applicable.
4. Title 22, CCR Section 66268.100
5. Public Resources Code, Division 13, Section
27000, California Environmental Quality Act
(CEQA).
6. Health & Safety Code, Section 41700, Division
6, Part 4, Chapter 3 (California Clean Air
Act) .
7. DTSC Applied Action Levels are no longer
being used, and should therefore be deleted.
If you have any questions, please contact Ms.
Gloria Conti at (310) 590-5566. Thank you.
Haissam Y. Salloum, P.E.
Unit Chief
Site Mitigation Cleanup
Operations
Southern California Branch (B)
Enclosures
cc: Mr. John Lyons, Esq.
U.S. EPA, Region IX
Mail Code RC-3-2
75 Hawthorne Street
San Francisco, California 94105
-------
57ATI Of CALIFORNIA — ENVIRONMENTAL PROTECTION AGENCY
PETE WILSON.
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
245 W»»l B'oMSvcy. Sun* 350
Jiang B^ctx. CA 908OJ -**•**
January 14, 1994
Mr. Thomas J. Dunkelman
Remedial Project Manager
U.S. E.P.A. Region IX
75 Hawthorne Street
Mail Stop H-7-1
San Francisco, CA 94105-3901
Dear Mr. Dunkelman,
PROPOSED STATE ARARS FOR THE PROPOSED DEL AMO SUPERFUND SITE
The Department of Toxic Substances Control (Department) has
solicited Applicable or Relevant and Appropriate Requirements
(ARARs) from local and state agencies. Enclosed is a partial
submittal of ARARs from the California Regional Water Quality
Control Board and the South Coast Air Quality Management
District, in response to our request. An additional submittal
will be forthcoming.
If you have any questions please contact Gloria M. Conti at
(310) 590-5566.
Sincerely,
Haissam Y. (Salloum, P.E.
Unit Chief v
Site Mitigation Operations Branch
enclosures
-------
State of California
Memorandum
To Haissam Salloum
Department of Toxic Substances
:ontrol -
Dote: January 11 , 1993
File =100.315
Ross, Unit Chief
Site Cleanup Unit
From : CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD—LOS ANGELES REGION
101 C*nrre Ploio Drive, Monterey Pork, CA 91754-2156
Telephone: (713) 766-7500
Subjec1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR DEL AMO PITS SUPERFUND SITE - TORRANCE - (File 100.315)
This is to provide a response to your December 28,
regarding the above project.
1993, letter
Regarding the soil issues, at the site, we have the following
specific comments:
1. We support a combination of Alternatives 4 , 5 and 6 as
an appropriate remediation for the permanent closure of
the Del Amo Pits (Surface Impoundments), as described
below.
2. Specifically, the sump closure requirements of Chapter
15, Title 23, CCR would apply to the permanent closure of
these pits. We believe, based upon existing data, that
soils in these pits have a high liquid content including
substantial concentrations of Benzene at depths
significantly close to first ground water. For this
reason, a large potential exists for impact to
groundwater through a continuing source of such
compounds in aquifer units. To that end,-we will require
dewatering of these sump contents and a maximum effort to
consolidate these wastes in place before any full capping
option and VES installation is completed. In addition,
we continue to believe that a closure plan that more
accurately defines the limits of these contaminants and
includes a method (Liquid Extraction) for dewatering will
meet our requirements. A method such as pentrometer
testing to more quickly and accurately define the free
liquid zone along with an appropriate level of dewatering
(Liquid Extraction) is considered appropriate. in
addition, substantial ground water contamination is known
to have ocurred below the pit area.
-------
Haissam Salloum
Page 2
Therefore, the requirements of the California Water Code
beginning with Section 1300 also apply. We view the
Benzene as a continuing source of groundwater
contamination and will require cleanup and abatement of
this source and the ground water in accordance with
Section 13304 of the Code.
The above would be followed, or supplemented by vapor
extraction as proposed. Substantial technology exists to
ensure a successful completion of such a remedy.
3. We believe that the potential even exists for the
complete removal (Alternative 5) or recycling of the pit
materials and such an alternative should be explored at
the conclusion of Alternative 6 described in Item 2
above.
b. Regarding the groundwater issues, we have the following
specific comments:
1. State Board Resolutions 68-16, and 88-63 apply to all
aquifer units at this site. This includes the Bell flower
Aquitard Unit, the Bellflower Sands Unit and all lower
better quality aquifers. We will therefore, require
cleanup of all these aquifer units, to levels acceptable
to this Board, by responsible parties to the
contamination. Any deviation would require adoption by
this Board and the State Board of a Los Angeles River
Basin Plan amendment. Such an amendment for a single
site/facility is highly unlikely.
2. The Board will likely establish MCL's as cleanup levels
for groundwater(gw) units for Benzene, Hydrocarbon
and VOC contamination and metals.
3. We will propose to our Board establishment of an
appropriate cleanup level for any compound not presently
covered by an MCL.
-------
Haissam Salloum
Page 3
4. We would consider reinjection of treated groundwater into
upper aquifer units to accommodate cleanup under these
conditions:
Reinjected water would likely require pH between 6 and
9, temperature below 100°F, and Bioassay above 75%
fish survival.
Reinjection would be limited to the Bellflower Sands
unit during the initial startup of the system.
GW monitoring of the impact on the Gage Aquifer unit
from reinjected water into the upper Bellflower Sands
would be required on a quarterly basis during the
first year.
Establishment of a Regional Ground Water Group,
with Regional Board oversight, which will develop a
regional approach to cleanup of the upper Bellflower
units.
Some of the above could be authorized on signature of the Executive
Officer of this Regional Board to initialize cleanup. Formal Waste
Discharge Requirements and the formation of the work group under
direction of Water Board staff would follow.
If you have any questions, please call me at (213) 266-7550.
-------
South Coast
AIR QUALITY MANAGEMENT DISTRICT
21865 E. Copley Drive, Diamond Bar, CA 91765-4182 (909) 396-2000
January 11, 1994
Ms. Gloria Conti
Department of Toxic Substances Control
245 W. Broadway, Suite 425
Long Beach, CA 90802
Dear Ms. Conti:
This letter is in response to your letter dated December 27, 1993, for Applicable or
Relevant and Appropriate Requirements (ARARs) for the proposed Del Amo
Superfund Site.
The following District Rules and Regulations should be incorporated in the ARARs
for the site:
Regulation IV - Prohibitions
Rule 401 - Visible Emissions
This rule limits visible emissions from any point source to Ringlemann No. 1
or 20 percent opacity for 3 minutes in any hour period.
Rule 402 - Nuisance
This rule prohibits the discharge of any material (including odorous
compounds) that causes injury or annoyance to the public, property or
business or endangers human health, comfort, repose or safety.
Rule 403 - Fugitive Dust
This rule limits on site activities so that the concentrations of fugitive dust at
the property line shall not be visible. In addition, PM10 levels shall not
exceed 50 micrograms per cubic meter as determined by the difference
between upwind and downwind samples collected on high volume paniculate
matter samplers. These requirements do not apply if wind gusts exceed 25
miles per hour. The rule also requires every reasonable precaution to
minimize fugitive dust and the prevention and cleanup of any material
accidently deposited on paved streets. This rule shall not apply during life-
threatening situations or during a declared disaster or state of emergency.
-------
DTSC -2- January 11, 1994
Rule 473 - Disposal of Solid and Liquid Wastes
This rule requires incinerator for combustible refuse to be multiple-chamber
type (with secondary combustion) and limits incinerators with design burning
rates greater than 110 pounds per hour from releasing paniculate matter in
excess of 0.10 grain* per standard cubic foot of gas calculated to 12 percent
of carbon dioxide averaged over 15 minutes.
Regulation X - National Emissions Standards for Hazardous Air Pollutants
This regulation implements the provisions of Pan 61. Chapter I, Title 40 of
the Code of Federal Regulations (CFR) under the supervision of the
SCAQMD Executive Officer. It specifies emissions testing, monitoring, and
procedures for handling of hazardous pollutants such as beryllium, benzene,
mercury, vinyl chloride and asbestos.
Regulation XI - Source Specific Standards
Rule 1150 • Excavation of Landfill Sites
This Rule states that no person shall initiate excavation of an active or
inactive landfill without an Excavation Management Plan approved by the
SCAQMD Executive Officer. The plan shall provide information regarding
the quantity and characteristics of the material to be excavated and
transported, and shall identify mitigation measures including gas collection
and disposal, baling, encapsulating, covering the material and chemical
neutralizing.
Rule 1150.2 - Control of Gaseous Emissions from Inactive T-andfiUs
This rule limits gaseous emissions from inactive landfills. It requires
installation of perimeter probes and a gas collection and flaring system. It
also requires ambient air sampling and monitoring the surface of the landfill
for organic compounds as methane.
Rule 1166 - Volatile Organic Compound Emissions from Decontamination of Soil
This rule limits the emissions of volatile organic compounds (VOCs) from
contaminated soil to less than 50 ppm. For contaminated soil with a VOC
emission of 50 ppm or greater, an approved plan, describing removal
methods and mitigation measures, must be obtained from the District prior
to proceeding with the excavation. Uncontrolled spreading of contaminated
coil is not permitted.
-------
DISC -3- January 11, 1994
Regulation XIII - Nor Source Review
This rule applies to any new or modified equipment which may cause the
issuance of any nonattainment air contaminant, balogenated hydrocarbon or
ammonia. It requires al] emission increases to be offset and all equipment to
be constructed with BACT (Best Available Control Technology). It also
requires substantiation with modeling that the equipment will not cause a
significant increase in concentrations of specific contaminants
Regulation XTV. Toxics
This regulation specifies limits for cancer risk and excess cancer cases from
new stationary sources and modifications to existing stationary sources that
emit carcinogenic air contaminants. The rule establishes allowable emission
impacts for all such stationary sources requiring new permits pursuant to
SCAQMD Rules 201 or 203. Best Available Control Technology for Toxics
(T-BACT) will be required for any system where a lifetime (70 years)
maximum individual cancer risk of one in one million or greater is estimated
to occur. Limits arc calculated using risk factors for specific contaminants.
Best Available Control Technology (BACT) Guidelines Document
This document was compiled by SCAQMD. Although a guideline, it set up
BACT requirements for various types of equipment and processes. To
determine BACT, a cost effectiveness analyses must be made for the
Alternate Basic Equipment of Process and the Technologically Feasible
options. Modifications or relocations of existing equipment do not need to be
analyzed for Alternative Basic Equipment or Process. The option that can
be shown to be cost effective would constitute the required BACT.
Very truly yours,
JoeTramma
A.Q-A.C. Supervisor
Stationary Source Compliance
JMT
-------
il^TE 0: CALIFORNIA — ENVIRONMENTAL PROTECTION AGENCY PETE WILSON.
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
245 Writ BroMNvav. Suite 350
Long B«.ch. CA 9O802-4444
December 2, 1993
Nancy Woo
Remedial Project Manager
U.S. E.P.A. Region IX
75 Hawthorne Street
San Francisco, CA 94105-3901
Dear Ms. Woo,
PROPOSED STATE ARARS FOR THE MONTROSE SUPERFUND SITE
The Department of Toxic Substances Control (Department) has
solicited Applicable or Relevant and Appropriate Requirements
(ARARs) from local and state agencies. Enclosed are the
Department's ARARs and copies of transmittals from the various
agencies, in response to our request.
If you have any questions please contact Gloria M. Conti at
(310) 590-5566.
Sincerely,
Haissam Y. Salloum, P.E.
Unit Chief
Site Mitigation Operations Branch
enclosures
-------
ATTACHMENT
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
STATE ARARS
Using the Draft Detailed Analysis of Remedial Alternatives for
Soil (dated 10/28/93) as a baseline for State and Local ARARs, the
following corrections shall be incorporated.
Page (P.) 1, I.A., Requirements:
Replace "Section 25100-25395" with "Section 25100-25250";
Replace "Minimum Standards for Management of Hazardous and
Extremely Hazardous Wastes" with "Division 4.5, Environmental
Health Standards for Management of Hazardous Waste.";
P. 1, I.A., Comments:
Replace "Section 66300" with "Section 66001";
Replace "comply with permitting requirements" with "obtain
permits".
P. 1, I.A.I., Requirements:
Replace "Criteria for ..." with "Identification and listing of
Hazardous Waste, Title 22, CCR, Division 4.5, Chapter 11,
Articles 1-5, P 66261.1-.126.
P. 1, I.A.I., Comments:
The first sentence should read "Tests for identifying
hazardous waste and hazardous characteristics of waste are
described..."
P. 1, I.A.I, and a, Alternative:
Should read "S1-S7".
P. 5, 3, Comments:
Replace "November 1987" with "December 1990".
P. 5, 3, Comments:
Replace chemical table with the following:-
Benzene .0002 mg/L (human/water)
.00007 mg/m3 (human/air)
Chloroform .006 mg/L (human/water)
.0006 mg/m3 (human/air)
Ethylbenzene 2.0 mg/L (human/water)
.10 mg/m3 (human/air)
Methyl ethyl 2.0 mg/L (human/water)
ketone .30 mg/m3 (human/air)
-------
Toluene 2.0 mg/L (human/water)
.20 Bg/m3 (human/air)
Xylene 2.0 mg/L (human/water)
.40 mg/m3 (human/air)
30,000 mg/kg (human/soil)
P. 6, II.A, Comments:
Replace "67108" with "66264.25"
P. 7, Comments, first paragraph, and Alternative:
Process activities (P. 6) listed as Relevant and Appropriate
should concur with excavation activities, and should therefore
be noted as Relevant and Appropriate. This first paragraph
will have to be re-written to reflect this change.
P. 7, III.A., Requirements:
Replace "Section 25100-25395" with "Section 25100-25250".
P. 7, following III.A:
The following specific Health & Safety Code Sections shall be
added:
ARTICLE 5- Standards
1) Section 25150- Standards and regulations; adoption;
application, subsections (a) and (b).
Comments: The Department shall develop and apply standards
and regulations to the management of hazardous waste.
Applicable to S1-S7.
2) Section 25154- Unlawful management of hazardous waste.
Comments: It is unlawful to manage hazardous waste except as
provided in Chapter 6.5 of the Health & Safety Code.
Applicable to S1-S7.
3) Section 25155- Disposal of extremely hazardous waste:
removal of harmful properties or as specified by regulations.
Comments: Manage all extremely hazardous waste according to
regulations.
Applicable to S2-S7.
4) Section 25155.5- Disposal of certain kinds of hazardous
waste; incineration or acceptable treatment requirements.
Comments: Mandatory incineration of hazardous waste to be
2
-------
disposed of based on BTU value.
Applicable to S4-S7.
5) Section 25155.8- Landfills used for disposal of hazardous
wastes containing VOCs; air emissions monitoring and reporting
requirements.
Comments: Landfill operator must monitor air emissions and
report to the Department.
Relevant and Appropriate to S2-S7.
ARTICLE 6- Transportation
1) Section 25160- Manifest
Comment: Generator must generate a manifest for any hazardous
waste to be shipped off site.
Applicable to S2-S7.
ARTICLE 6.5- Hazardous Waste Haulers
1) Section 25167.1 - 25169.3
Comment: The requirements for haulers and their vehicles will
apply since off-site hauling would commence on site.
Applicable to S2-S7.
ARTICLE 7.7- Hazardous Waste Management Act of 1986
1) Section 25179.5- Disposal of liquid waste in hazardous
waste landfills prohibited.
Comment: No person shall dispose of liquid hazardous waste in
a hazardous waste landfill.
Applicable to S2-S7.
2) Section 25179.6- Land disposal of certain hazardous waste
prohibited; treatment standards.
Comment: Land disposal restrictions for hazardous waste.
Unless granted a variance, extension, exclusion or exemption,
or treated in accordance with treatment standard, land
disposal is prohibited.
Applicable to S2-S7.
ARTICLE 8- Enforcement
-------
1) Section 25189.5 (a)- Disposal, treatment or storage at, or
transportation to, facilities without permits or at
unauthorized points; punishment.
Comments: Subsection (a) prohibits the disposal of hazardous
waste, or causing it, at any unauthorized point.
Applicable to S2-S7.
2) Section 25189.7- Burning or incineration at unpermitted
facility or unauthorized point; punishment.
Comments: Incineration of hazardous waste at an unauthorized
point is prohibited.
Applicable to S4-S7.
ARTICLE 9- Permitting of Facilities
1) Section 25202.5- Restrictive easements, covenants,
restrictions, or servitudes.
Comments: The Department and the owner of a facility are to
enter agreements providing for deed restrictions as noted
above, to restrict land use.
Relevant and Appropriate for S1-S7.
2) Section 25203- Unlawful disposition of hazardous waste.
Comments: It is unlawful to dispose of hazardous waste except
at a permitted disposal site, facility, or site with a grant
of authorization.
Applicable to S1-S7.
ARTICLE 11- Hazardous Waste Disposal Land Use
1) Section 25221- Application for designation as hazardous
waste property or border zone property.
Comments: Owner of property with knowledge of hazardous waste
disposal on property shall apply to Department for
designation.
Applicable to S1-S7.
P. 8, 1., Alternative:
Should read "S1-S7".
P. 8, 2., Comments:
Replace "resulting from...accumulates" with "generated".
-------
P. 8, 2., Alternative:
Insert "S5", and delete "(on-site SGE)".
p. 8, 3, Comments:
Replace "66263.18" with "66263.46".
P. 8, 3, Applicable:
Off-site transport is subject to regulations, but should not
be an ARAR.
P. 8, 4, Requirements:
Add "Specifically, 66264.1, .18, .25; Articles 7,9,10,14,15"
and mark as Applicable.
P. 8, 4, Requirements:
Add "Article 6" and mark as Relevant and Appropriate.
P. 9, b, Alternative:
Should read "S2-S7".
P.9, b, Relevant and Appropriate:
Change to Applicable.
P. 11, d, Comments:
Delete "state permitted".
P. 11, d, Comments, second paragraph:
Replace "Improvement" with "Impoundment".
P. 11 & 12, d, To Be Considered:
Change to Relevant and Appropriate. Mark all of "d" as
Relevant and Appropriate.
P. 12, To Be Considered:
Change to Relevant and Appropriate.
P. 12, Comments, first paragraph:
Delete this paragraph-
P. 12, Comments, Landfills, second paragraph:
Delete this paragraph.
P. 12, e, Comments, a:
Insert "The California Code of Regulations on incinerators are
all applicable, except for the permit requirements."
P. 12, e, Comments, a:
Delete "Since permits...ARAR."
P. 12, e, Relevant and Appropriate:
Change to Applicable.
-------
P. 13, Comments:
Delete first, third, and fifth paragraphs.
P. 13, Relevant and Appropriate:
Change both to Applicable.
P. 14, f, Comments:
Delete from "These provisions...are TBCs." and replace with
"These provisions apply to hazardous waste facilities of the
specific types regulated. The Montrose Site is one of these,
and as such the regulations are fully applicable. The
regulations are applicable since they address units that are
used to treat, store or dispose of hazardous wastes that are
not otherwise addressed by the regulations."
P. 14, f, Comments:
Delete from "However,...are TBCs".
P. 14, f, To Be Considered:
Change to Applicable.
P. 14, g, Comments:
Replace "relevant and appropriate" with "applicable".
P. 14, g, Relevant and Appropriate:
Change to Applicable.
P. 15, h, Requirements:
Replace "Article 28" with "Articles 27 & 28" and "66264.1050"
With "66264.1030".
P. 15, h, Comments:
Delete from "However, to be...it sets" and replace with
"Article 28 is fully applicable. The substantive provisions
of Article 28 are applicable. They set" standards for
operation...
P. 15, h, Relevant and Appropriate:
Change to Applicable.
P. 15, 5:
This requirement is not necessary, but may be kept as To Be
Considered.
P. 16, 7, Alternative:
Replace "S4-S7" with "S2-S7".
P. 18, 8, Alternative and Applicable:
Insert "S2-S7" under Alternative and mark as Applicable.
-------
Post-It" brand tax transmittal memo 7671
Co.
0«pt.
From
• ot p»e«* »
Co.
Phon» »
Ft* *
Control - Long Beach
Environmental Pro»*cH»n Ap*nr
, November 29, 1993
, 100.315
J. E. ROBS, Unit Chief
Site Cleanup Unit
From : CALIFORNIA REGIONAL WATER OUAUTY CONTROL BOARD—IOS ANGELES REGION
!0» Centra MOM Dr>v«, M»»rw*y fork, CA 91754-3)56
TcUphen*: (313)264-7500
Subject, APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR MONTROSE AND DELAMO BOULEVARD, LOS ANGELES/TORRANCE SITE
This will supplement our General ARARs Memo of October 19, 1993.
a. Regarding the soil issues we have the following specific
comments:
1. We support the CAP option with modifications.
2. Based on the data presented by Montrose, as discussed at
previous joint meetings by Regulators/ we conclude that
all residual surface sludges have been removed from the
pit in the central processing area and the pit is
backfilled. Based on these facts, sump closure
requirements of Chapter 15, Title 23, CCR would not
apply. However, the facts do indicate that high
concentrations of the residual DNAPL may exist in a
substantial portion of the vadoze zone beneath and
surrounding the pit area. For this reason, a large
potential exists for impact to groundwater and increasing
concentrations of these DNAPL compounds in aquifer units.
Therefore, the requirements of the California Water Code
beginning with Section 1300 apply. We view the DNAPL as
a continuing source of groundwater contamination and will
require cleanup and abatement of this source in
accordance with Section 13304 of the Code. To that end,
we will require removal of the maximum amount of these
contaminants in a short time period. Vapor extraction
would not likely provide for a timely removal. We
continue to believe that a removal plan that more
accurately defines the limits of this contamination and
includes a method(Llguid Extraction) for dewatering will
meet our requirements. A method such as pentrometer
testing to more quickly and accurately define the DNAPL
zone along with an appropriate level of dewatering (Liquid
Extraction) should be considered. This could be followed,
or supplemented by, vapor extraction in the same zone.
-------
StOU el Coltfornio
Memorandum
To .Haissam Salloum
Department of Toxic Substances
Control - Long Beach
3- E. ROBB, Unit Chief
Site Cleanup Unit
From , CALIFORNIA REGIONAL WATER OUAUTY CONTROL BOARD—LOS ANGELES REGION
101 C*nl>* Ptoio Drtv*. A/Untoray Fart, CA 91734.7136
UI*ph0M: (313) 366-7500
Subject: APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARe)
FOR MONTROSE AND DELAMO BOULEVARD/ LOS ANGELES/TORRANCE SITE
This will supplement our General ARARs Memo of October 19, 1993.
a. Regarding the soil issues we have the following specific
comments:
1. We support the CAP option with modifications.
2. Based on the data presented by Montrose, as discussed at
previous joint meetings by Regulators, we conclude that
all residual surface sludges have been removed from the
pit in the central processing area and the pit is
backfilled. Based on these facts, sump closure
requirements of Chapter 15, Title 23, CCR would not
apply. However, the facts do indicate that high
concentrations of the residual DNAPL may exist in a
substantial portion of the vadoze zone beneath and
surrounding the pit area. For this reason, a large
potential exists for impact to groundwater and increasing
concentrations of these DNAPL compounds in aquifer units.
Therefore, the requirements of the California Water Code
beginning with Section 1300 apply. We view the DNAPL as
a continuing source of groundwater contamination and will
require cleanup and abatement of this source in
accordance with Section 13304 of the Code. To that end,
we will require removal of the maximum amount of these
contaminants in a short time period. Vapor extraction
would not likely provide for a timely removal. We
continue to believe that a removal plan that more
accurately defines the limits of this contamination and
includes a method(Liquid Extraction) for dewatering will
meet our requirements. A method such as pentrometer
testing to more quickly and accurately define the DNAPL
zone along with an appropriate level of dewatering (Liquid
Extraction) should be considered. This could be followed,
or supplemented by, vapor extraction in the same zone.
-------
Haissam Salloum
page 2
3. We do not believe the capping option off-site will be
effective in controlling the potential for ground water
and surface water contaminations. We believe the sane
Sections of the Water Code cited above apply and would
require removal and disposal of this shallow soil
contamination, especially contaminated soil within the
Normandie Ditch.
b. Regarding the groundwater issues, we have the following
specific commentsi
1. State Board Resolutions 68-16, and 88-63 apply to all
aquifer units at this site. This includes the Bellflower
Aguitard Unit, the Bellflower Sands Unit and all lower
better quality aquifers. We will therefore, require
cleanup of all these aquifer units to levels acceptable
to this Board. Any deviation would require adoption by
this Board and the State Board of a Los Angeles River
Basin Plan amendment. Such an amendment for a sinqle
site/facility is highly unlikely.
2. The Board will likely establish MCL's as cleanup levels
in all groundwater (gw) units for DDT, chlorobenze,
benzene, BHC, all other chlorinated and aromatic
compounds, and any metals.
3. We will propose to our Board establishment of an
appropriate cleanup level for PCBSA following submittal
and evaluation of the following items or the treated gw
containing PCBSA:
The EPA research data on this compound collected
during development of the ARARs.
. General Mineral Analysis to include Sulfates, Su If idee
along with pH before and after neutralization
VOC analysis by EPA 624 and Bioassay analysis
4. We would consider reinjection of treated groundwater
containing PCBSA into upper aquifer units under these
Conditions:
Reinjected water would likely require pH between 6 to
9, temperature below 100°F, and Bioassay above 75%
survival.
Reinjection would be limited to the Bellflower Sande
during the initial startup of the system.
-------
Haissam Salloom
page 3
GW monitoring of the impact on the Gage Aquifer unit
from reinjected water into the upper Bellflower Sands
would be monitored quarterly during the first year.
No cleanup limit for the compound PCBSA would likely
be enforced during this start up period.
During the startup period, staff will propose to this
Board for adoption a cleanup level for PCBSA following
evaluation of the above data including the effects of
neutralization on PCBSA and vertical migration trends
of the reinjected water and economical consideration
that are proposed by the discharger.
Establishment of a Regional Ground Water Group, with
Regional Board oversight, which will develope a
regional approach to cleanup of the upper Bellflower
units.
Some of the above could be authorized on signature of the Executive
Officer of this Regional Board to initialize cleanup. Formal Waste
Discharge Requirements and the formation of the work group under
direction of Water Board staff would follow.
If you have any questions, please call me at (213) 266-7550.
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Slot* of CoMotnio
Memorandum
Environmental PrOt»ct»on Ag»nry
: Haissam Salloum
Department of Toxic Substances
Control - Long Beach
Dote:
File :
October 19, 1993
100.0315
J.E. Ross, Unit Chief
* From
Subject
: QUALITY CONTROL BOARIX—LOS ANGELES REGION
101 C*n»r» Ploie Drrvc, M»r.l*»r fork. CA 91754-2156
ToUphon*: .(7)3)266-7500
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR THE MONTROSE AND DEL AMO BOULEVARD, LOS ANGELES/TORRANCE
SITES
As requested, we are providing the following Los Angeles
Regional Water Quality Control ^Board ARARs for the above
referenced facilities:
1.
Porter-Cologne Water Quality Control Act. This Act
requires the adoption of Water Quality Control Plans by
this Regional Board. These plans include:
a.
Los Angeles
incorporates:
River Basin (4B) Plan, which
b.
L. State Water Resources Control Board Resolution
No. 68-16, "Statement of Policy with Respect
to Maintaining High Quality of Waters in
California"; and
I. State Water Resources Control Board Resolution
No. 88-63, "Sources of Drinking Water" Policy;
Inland Surface Waters Plan;
Safe Drinking Water and Toxic Enforcement Act of 1986
(Proposition 65) ;
Title 23 of the California Code of Regulations, which
include Chapter 15, "Discharges of Waste to Land";
State Water Resources Control Board Resolution No. 92-49,
"Policies and Procedures for Investigation and Cleanup
and Abatement of Discharges Under Water Code Section
13304".
Please contact me at (213) 266-7550, or Keith Elliott at (213) 266-
7614 if you have any questions. _ .. .
OCT l> 1
TOXIC
-------
South Coast
AIR QUALITY MANAGEMENT DISTRICT
21865 E. Copley Drive. Diamond Bar. CA 91765-4182 (909) 396-2000
October 29, 1993
Ms. Gloria Conti
Department of Toxic Substances Control
245 W. Broadway, Suite 425
Long Beach, CA 90802
Dear Ms. Conti:
This letter is in response to your request, during our meeting on October 25, 1997, for
Applicable or Relevant and Appropriate Requirements (ARARs) for the Del Amo Pit Site
and the Montrose Plant Site.
The following District Rules and Regulations should be incorporated in the ARARs for
both sites:
Regulation IV - Prohibitions
Rule 401 - Visible Emissions
This rule limits visible emissions from any point source to Ringlemann No. 1 or 20
percent opacity for 3 minutes in any hour period.
Rule 402 - Nuisance
This rule prohibits the discharge of any material (including odorous compounds)
that causes injury or annoyance to the public, property or business or endangers
human health, comfort, repose or safety.
Rule 403 - Fugitive Dust
This rule limits on site activities so that the concentrations of fugitive dust at the
property line shall not be visible. In addition, PM10 levels shall not exceed 50
micrograms per cubic meter as determined by the difference between upwind and
downwind samples collected on high volume paniculate matter samplers. These
requirements do not apply if wind gusts exceed 25 miles per hour. The rule also
requires every reasonable precaution to minimize fugitive dust and the prevention
and cleanup of any material accidently deposited on paved streets. This rule shall
not apply during life-threatening situations or during a declared disaster or state of
emergency.
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DTSC -2- October 29, 1993
Rule 473 - Disposal of Solid and Liquid Wastes
This rule requires incinerator for combustible refuse to be multiple-chamber type
(with secondary combustion) and limits incinerators with design burning rates
greater than 110 pounds per hour from releasing paniculate matter in excess of 0.10
grains per standard cubic foot of gas calculated to 12 percent of carbon dioxide
averaged over 15 minutes.
Regulation X • National Emissions Standards for Hazardous Air Pollutants
This regulation implements the provisions of Part 61, Chapter I, Title 40 of the
Code of Federal Regulations (CFR) under the supervision of the SCAQMD
Executive Officer. It specifies emissions testing, monitoring, and procedures for
handling of hazardous pollutants such as beryllium, benzene, mercury, vinyl chloride
and asbestos.
Regulation XI - Source Specific Standards
Rule 1150 - Excavation of Landfill Sites
This Rule states that no person shall initiate excavation of an active or inactive
landfill without an Excavation Management Plan approved by the SCAQMD
Executive Officer. The plan shall provide information regarding the Quantity and
characteristics of the material to be excavated and transported, and shall identify
mitigation measures including gas collection and disposal, baling, encapsulating,
covering the material and chemical neutralizing.
Rule 1150.2 - Control of Gaseous Emissions from Inactive Landfills
This rule limits gaseous emissions from inactive landfills. It requires installation of
perimeter probes and a gas collection and flaring system. It also requires ambient
air sampling and monitoring the surface of the landfill for organic compounds as
methane.
Rule 1166 - Volatile Organic Compound Emissions from Decontamination of Soil
This rule limits the emissions of volatile organic compounds (VOCs) from.
contaminated soil to less than 50 ppm. For contaminated soil with a VOC emission
of 50 ppm or greater, an approved plan, describing removal methods and mitigation
measures, must be obtained from the District prior to proceeding with the
excavation. Uncontrolled spreading of contaminated coil is not permitted.
Regulation XIII - New Source Review
This rule applies to any new or modified equipment which may cause the issuance of
any nonattainment air contaminant, halogenated hydrocarbon or ammonia. It
requires all emission increases to be offset and all equipment to be constructed with
BACT (Best Available Control Technology). It also requires substantiation with
modeling that the equipment will not cause a significant increase in concentrations
of specific contaminants
-------
DTSC -3- October 29, 1993
Regulation XIV - Toxics
This regulation specifies limits for cancer risk and excess cancer cases from new
stationary sources and modifications to existing stationary sources that emit
carcinogenic air contaminants. The rule establishes allowable emission impacts for
all such stationary sources requiring new permits pursuant to SCAQMD Rules 201
or 203. Best Available Control Technology for Toxics (T-BACT) will be required
for any system where a lifetime (70 years) maximum individual cancer risk of one in
one million or greater is estimated to occur. Limits are calculated using risk factors
for specific contaminants.
Best Available Control Technology (BACT) Guidelines Document
This document was compiled by SCAQMD. Although a guideline, it set up BACT
requirements for various types of equipment and processes. To determine BACT, a
cost effectiveness analyses must be made for the Alternate Basic Equipment of
Process and the Technologically Feasible options. Modifications or relocations of
existing equipment do not need to be analyzed for Alternative Basic Equipment or
Process. The option that can be shown to be cost effective would constitute the
required BACT.
Very truly yours,
Joe Tramma
A.Q.A.C. Supervisor
Stationary Source Compliance
JMT
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Pete Wilson
SIATf O CALIFORNIA—1ME RESOURCES AGINC?
DEPARTMENT OF FISH AND GAME
CERCLA/NRDA Unit
Marine Pollution Laboratory
20 Lower Ragsdale Drive, Suite 100
Monterey, CA 93940
October 15, 1993
Ms. Gloria Conti
Site Mitigation Branch
Department of Toxic Substances Control
245 West Broadway, Suite 425
Long Beach, CA 90802
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR MONTROSE
SUPERFDND SITE
Dear Ms. Conti:
In connection with your request for fish and wildlife resource
laws and regulations, and pursuant to Section 104 (b) (2) of the
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) , the Department of Fish and Game hereby provides, for
your implementation, Applicable or Relevant and Appropriate
Requirements (ARAR's) for the protection of State fish and wildlife
resources at the subject site.
Additionally, this letter will serve to advise you of the
Department of Fish and Game's interest in coordinating any natural
resource damage assessment investigations as a State natural
resource (co) trustee, which may be necessary should the release(s)
of any hazardous materials at the subject landfill site cause
injuries to state natural resources, pursuant to CERCLA § 104 and
122.
The following State laws and statutes may apply to the RI/FS
actions at the subject site for the protection of fish and wildlife
resources and their habitats:
• Designation of the Department of Fish and Game as trustee for
State fish and wildlife resources: Fish and Game Code § 711.7;
» Taking for Scientific Purposes (§ 1001; 1002) .
• Requirements for releasing substances deleterious to fish and
wildlife: Fish and Game Code § 5650 (a) (b) , (f); 5651; and
12016;
• Illegal take of birds and mammals: Fish and Game Code § 3005;
• Relevant policies for the general protection and conservation
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Ms. Conti
Page 2
October 15, 1993
of fish and wildlife resources: Fish and Game Code § 1600 et
seq^.; 1700; 1750; 1801; and 2014; Water Code § 1243;
Requirements for endangered or rare species: Fish and Game
Code § 1900 et sea. ; 2050 et sea, to 2068; 2070; 2080; 2090 et
seq. to 2096;
Other Laws and Treaties:
• Federal Endangered Species Act of 1973;
• California Endangered Species Act (Fish and Game Code § 2050
et seg . ) .
I have enclosed copies of these laws and regulations for your
information. If any portion of these State laws is not considered
in the Ecological Risk Assessment phase (s) of the RI/FS process, I
will expect a written, justification, stating the rationale, legal
basis, and substantive reasons for their exclusion from ARAR,
consideration in the RI/FS. Please let me know if I can be of
further assistance. My telephone number is (408) 649-7178 and FAX
649-2894.
Sincerely,
Michael Martin, Ph.D.
Acting Staff Toxicologist
CERCLA/NRDA Project
Encl. F&G Code; Title 14 CCR
-------
Reference 12
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Shell Chemical Company
Shell Oil Products Company
P. O. Box 25370
May 2, 1 997 Santa Ana, Ca 92799
361 1 S Harbor. Sle 160
927M
Mr. Dante Rodriguez
U.S. Environmental Protection Agency 714-427-3469 (Fax)
Mail Drop SFD-7-1
75 Hawthorne Street
San Francisco, California 94105
LETTER FROM HAISSAM SALLOUM (DTSC) TO JANET ROSATI (EPA)
DATED DECEMBER 11, 1996
Dear Mr. Rodriguez:
Attached, please find Figure 7.4.1-1 which should have been included in our submittal dated
April 25, 1997.
Please contact me if you have questions or require additional information.
Sincerely,
C.B. Paine
Coordinator for Respondents
Attachment
cc: Gloria Conti, DTSC
Larry Bone, Dow
John Gustafson, Shell
John Dudley, Dames & Moore
Dave Laney, Dames & Moore
F:\SHARED\FFS\DELAMO.RSP
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LADWP Right -of-Way
ROR, . 35 feel
ROR2 a 45 (eel
Pit Pit Pit Pit Pit Pit Property Une and Fence
2-F 2-E 2-D 2-C . 2-B 2-A Lot 36,
Fence-
Pit
1-C
Pit
1-B
999/001
Lot 37
Pit 1-A
(excavated)
17 Wells
Chain Link Fence
3 Wells
DEL AMO BOULEVARD
N
60 120
LEGEND:
SCALE IN FEET
Source: Pit Boundaries Based on DWR 1947 Aerial Photograph
[ | Underground Petroleum Pipeline Corridor
50 mg/kg Benzene Concentration
'• Vapor Extraction Well and Radius of
.-' Remediation (ROR)
Note: The number and location of SVE wells may change
pending the selected performance standard and/or if SVE
Is used to target different areas of the vadose zone soils.
FIGURE 7.4.1-1
CONCEPTUAL WELL LAYOUT
SOIL VAPOR
EXTRACTION SYSTEM
Del Amo Waste Pit Area
ft DAMES & MOORE
-------
Reference 13
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PUBLIC MEETING
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
IN THE MATTER OF: )
)
DEL AMO PROPOSED )
SUPERFUND SITE )
TRANSCRIPT OF PROCEEDINGS
TORRANCE, CALIFORNIA
Wednesday, January 29, 1997
Fox Reporting, Inc.
Fox Transcriptions
Second Floor
801 South Flower Street
Los Angeles, CA 90017-4622
(213)688-9464
Fox Reporting, Inc.
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APPEARANCES:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY:
75 Hawthorne Street
San Francisco, CA 94105
Community Involvement Coordinator
Del Amo Project Manager
Montrose Project Manager
DAVID COOPER
(415) 744-2182
DANTE RODRIGUEZ
(415) 744-2239
JEFF DHONT
(415) 744-2399
SPEAKERS:
DEL AMO ACTION COMMITTEE
SIMPSON ENVIRONMENTAL RESEARCH
Cynthia Babich, Director
Ken Simpson
Ms. Ponce
Mr. Robert Evans
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PUBLIC MEETING
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
IN THE MATTER OF: )
)
DEL AMO PROPOSED )
SUPERFUND SITE )
TRANSCRIPT OF PROCEEDINGS, TAKEN AT TORRANCE CULTURAL ARTS
CENTER, 3330 CIVIC CENTER DRIVE, TORRANCE, CALIFORNIA, ON
WEDNESDAY, JANUARY 29, 1997, REPORTED BY LEE ST. JAMES, ERM.
Fox Reporting, Inc.
213-688-9464
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1 TORRANCE, CALIFORNIA, WEDNESDAY, JANUARY 29, 1997; P.M.
2
3 MR. COOPER: I want to welcome you tonight to this
4 public meeting to collect comments on the proposed plan for
5 the clean-up of the Del Amo Waste Pits.
6 My name is David Cooper. I'm a community
7 involvement coordinator for the U.S. Environmental Protection
8 Agency.
9 As I said, the purpose of this meeting is to
10 collect public comments, and the meeting is divided up into
11 basically two parts.
12 We'll have a short presentation of what EPA's
13 proposed plan is all about, and then we'll have a break where
14 we can re-set up the room for, put a microphone out front,
15 and then people who are interested in making public comments
16 can come forward and do so.
17 But before we get started, I just have a few items
18 to pass on.
19 In the back -- just outside the doors is the table
20 where we have a sign-in roster, and we would appreciate your
21 signing in so that we can keep track of who comes to these
22 meetings and it also helps us update our mailing list.
23 In addition, at the far end of that table there is
24 another sign-in roster, and that one is for a special work
25 group that has been proposed to look at the final use of the
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1 land after the waste pits are cleaned up. We call that
2 end-use work group, and anyone who's interested in being a
3 part of that, please sign there and we'll be contacting you
4 when that group is formed.
5 Translation in Spanish is being provided tonight by
6 Maria Victoria Perez. Anyone who would prefer to hear this
7 meeting -.n Spanish is welcome to come up to the front, where
8 translation is being provided.
9 On that back table that I referenced are a number
10 of documents that you will find useful. Some of them are,
11 the proposed plan that was mailed out to everyone on our
12 mailing list; that's about 1,900 people.
13 And in addition, there's a second fact sheet that
14 speaks specifically to one part of the proposed plan which is
15 soil vap- -- soil vapor extraction. So those two fact sheets
16 may be something that you folks want to pick up.
17 There are some materials there from the Del Amo
18 Action Committee, on the table as well, some red flyers and
19 couple of other --
20 MS. BABICH: Newsletter.
21 MR. COOPER: And a newsletter. Thanks.
22 There's also a copy of the agenda out there, and a
23 copy of some of the slides you'll be seeing later.
24 There are two other documents that you won't
25 normally see in a regular community meeting. One of them is
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1 a speaker request form.
2 If you have an interest in making a public comment
3 this evening, I would ask that you get a copy of this form
4 and fill it out while our speaker is making his presentation,
5 and give them to me; and then during the second half of this
6 meeting, I'll call your name and you can come up and make
7 your public comment.
8 If you would prefer to write down the public
9 comment and simply mail it to us, there is this form. And on
10 the back it's already addressed to EPA. You just need to
11 fold it in half and put a stamp on it, and we can receive
12 your input that way, your feedback that way.
13 You'll notice, to your right that there is a video
14 recorder that's running. That's for the internal use of the
15 EPA; that's for training purposes. That's how we keep track
16 of how our meetings go, and how we learn.
17 If anyone is uncomfortable with us filming them as
18 they're speaking, or during some part of the meeting, we're
19 happy to turn it off. It's not a formal part of this meeting
20 at all; it's just for internal EPA use.
21 At this time, is there anyone who does have a
22 concern about us running our video machine?
23 Thanks.
24 Finally, I wanted to point out that in the --in
25 the lobby area there are a number of posters, and those
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1 pesters show some of the things that we're going to be
2 talking about this evening. They show examples of the
3 different alternatives that we have --we were looking at as
4 we decided which part of rhe plan --or what to propose as a
5 method for cleaning up this site.
6 Some of the posters show another site in Fullerton,
7 California, called the McCall Site, where they are doing a
8 certain kind of clean-up activity; and those might be of some
9 interest to you, too.
10 Also, the rest rooms, for anyone who needs rest
11 rooms, are out the door and directly on the opposite side;
12 there's a men, a women's. There's a drinking fountain.
13 There is a telephone just outside the front door, and there
14 are additional facilities through the gate -- through this
15 courtyard through the gate and off in another building.
16 There's also some refreshments there. There's some pop
17 machines in one of the buildings, again, through the gate.
18 So, with that in mind, I'd like-to quickly move
19 through our very short agenda.
20 Can everyone hear me if I step away from the mike?
21 No?
22 MR. SPEAKER: No. We can barely hear you with it.
23 MR. COOPER: You can barely hear me with it. Okay.
24 Can everyone hear me now?
25 Okay. I'll just speak up.
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1 We have a very short agenda this evening.
2 Principally we're here to provide a review of the
3 alternatives that EPA looked at, provide a
4 question-and-answer period where you can ask us some
5 clarifying questions about what did we mean about what we
6 explain.
7 And then we'd like to stop the meeting, set things
8 up a little differently, move a microphone out front, and
9 then start receiving your public comments. The majority of
10 this period is the formal time when we receive your comments
11 on our proposal for taking care of the --of the Del Amo
12 Pits,- so we want to make sure that most of the time is spent
13 doing that, and not making a presentation.
14 With that, I'd like to just quickly introduce the
15 people from the Environmental Protection Agency who are here
16 this morning.
17 Dante Rodriguez and Jeff Dhont are the two project
18 managers for the Del Amo site. And the gentleman who is just
19 about to sit down, so catch him before he drops, is
20 Michael Montgomery, who is -- who is section chief that
21 includes the Del Amo site, among others.
22 Also with us tonight is Bill Nelson for -- and he
23 is with the Agency for Toxic Substances and Disease Registry.
24 And he is available after the meeting -- thank you for
25 standing up,? Bill -- he's available after the meeting to talk
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1 to you about any of the health-related issues that his agency
2 works with.
3 With that quick introduction I'd like to turn the
4 meeting over to Dante Rodriguez, whc will review the elements
5 of the proposed plan.
6 MR. RODRIGUEZ: Good evening.
7 My name is Dante Rodriguez. For those of you who
8 were at the December public meeting, you'll remember me as
9 the new project manager. I've been working on the Del Amo
10 Pits project for a little over three months now.
11 . What I want to talk to you tonight about is four
12 things.
13 One is, I want to describe to you what is the
14 Superfund process, the process that the U.S. Government has
15 for cleaning up the worst toxic waste sites. Second, I
16 wanted to talk to you about the way we screen clean-up
17 technologies for the site; and then, third, what the clean-up
18 alternatives that we are considering are." And then finally,
19 which alternative EPA prefers and why.
20 The Del Amo Pit Superfund Site is located in the
21 area that's currently commercial businesses, north of
22 204th Street. 204th Street is approximately here; the area
23 just north of that is currently a number of businesses and we
24 call that the Del Amo Facility. Within this area, there is a
25 small portion down here, just on the other side of Del Amo
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1 Boulevard alley, that we call "the pits."
2 Now, earlier on, this area was used for synthetic
3 rubber manufacturing. The area was owned by the
4 United States Government and operated by a number of
5 different companies, including Shell Oil and Dow Chemical.
6 This is a picture of the facility north of
7 204th Street, which is here. Vermont Street is here. This
8 whole area used to be this big refinery processing area. The
9 pits are located right in this area here.
10 This is a close-up of the pits area. Throughout
11 the 1950s there were a number of open pits in this area where
12 waste sludge was dumped. There were also three evaporation
13 ponds that hazardous waste was put into.
14 Currently this area has been found to be
15 contaminated with a number of hazardous substances, including
16 benzene, which is a known human carcinogen, a substance that
17 causes cancer.
18 Today the waste pits area is covered and is just a
19 grassy area within an enclosed fenced area. Beneath the soil
20 lie the sludge pits and the remains from the evaporation
21 ponds. The sludge has leaked some of its chemicals down
22 further into the ground until it hits the water, the
23 groundwater that's underground about 70 feet deep.
24 What we're going to be talking about today is how
25 to address the contaminated soil, and not the groundwater.
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1 The groundwater will be the subject of a future clean-up
2 process and decision.
3 In 1980 the United States Government passed a law
4 that allowed us to go and clean up the nation's worst
5 hazardous waste sites. In this law it spelled out a process
€ that EPA was to use in investigating, selecting clean-ups and
7 conducting clean-ups at sites.
8 This process starts when a site is discovered, and
9 inspected and assessed tc determine if it's hazardous or not.
10 Following that, a very detailed investigation is made,
11 investigating the environmental conditions and the
12 contamination in this site, and then determining what
13 feasible ways there are to address the site, to come up with
14 a remedy to having a remedial clean-up.
15 Once this information is gathered, the EPA can then
16 propose a plan for clean-up which must examine a rumber of
17 different clean-up alternatives and compare them to each
18 other. This information is then made public for people like
19 you, communities of anybody who's interested, to review this
20 information and tell us what they think.
21 Once all that information is taken into account,
22 EPA makes the official clean-up decision, called a Record of
23 Decision, and then we can design and build the remedy.
24 Right now we are in the phase of collecting public
25 comments.
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1 There's five alternatives that we ended up with;
2 but when we started this investigation in and study, there
3 were at least 24 different technologies that we assessed, to
4 try to find the most workable ones. And these technologies
5 were screened out, and there was a number of them, including
6 a technology that was -- folks had asked about in December
7 called bioremediation. That was one of the technologies that
8 was investigated initially and screened through.
9 In the end there were five alternatives that it all
10 boiled down to. I'm going to just describe those to you.
11 The first alternative is to do nothing and leave it
12 like it is. We're required in the law to always consider
13 this alternative. If nothing was done, the site would remain
14 as it looks right now. There's currently a fence around it,
15 soil and grass, but that's it.
16 The second alternative is called institutional
17 control, access control. Basically, it would mean just
18 trying to keep the people away from it. This would include
19 putting up a new fence, and drilling wells that we can
20 monitor -- continue monitoring the groundwater with.
21 During construction of this type of a remedy, you
22 would probably see drill rigs similar to this doing work.
23 Monitoring wells aren't visible from the surface after
24 they're installed. They usually just have a cover on them,
25 like a manhole cover or smaller, and they extend down into
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1 the water.
2 The third alternative goes a step further. We call
3 this the cap alternative. During construction of a cap --
4 and a cap --we call these caps RCRA caps, R-C-R-A. It
5 stands for the Resource Conservation Recovery Act. It's a
6 federal law that currently regulates the production and
7 disposal of hazardous waste, and this law defines what ways
8 these caps are to be constructed and how they're to behave.
9 They typically consist of a number of layers that seal off
10 the waste beneath and seal water from the surface from
11 getting down into the waste.
12 During construction of such a cap, you will
13 typically see a number of earth-moving equipment and large
14 bulldozers, and one of the components that they would be
15 installing is a liner, which is constructed out of a high
16 density plastic designed to last a long time. Underneath
17 this cap liner, typically, is a number of other layers of
18 clay soil that's compacted so that it also helps seal
19 contaminants below and seal water off from above.
20 Once a cap like this is constructed, there's a
21 number of uses that can be done on the surface, including
22 landscaping, parks and that kind of thing.
23 But I want to point out that there's a number of
24 layers in these caps, soil, the high density liner, clay, and
25 a number of collection layers that will collect water that
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11
1 rains down on the surface and directs the water off in a
2 drainage. And it would also collect any vapors that come up
3 off of the waste. It can collect those vapors in pipes, and
4 then direct all those to a treatment system for those vapors
5 that will clean the contamination out of that air before it's
6 released.
7 The fourth remedy alternative goes a step further
8 than that. We call this the soil vapor extraction and cap
9 alternative.
10 In addition to the cap, we will be drilling some
11 special wells. When they're installed these wells serve a
12 special purpose. What they do are --is basically, act as
13 vacuum wells. These wells are proposed to be drilled in at
14 an angle so that they go underneath the waste and suck the
15 contamination from beneath the waste and above the
16 groundwater.
17 These vapor wells basically create an airflow under
18 the ground, that moves air through the soil and picks up
19 contamination that can be transported through that air; and a
20 number of the most serious contaminants that we deal with,
21 including benzene, are chemicals like that that can be picked
22 up in these vapor extraction wells.
23 Once these vapors are sucked out, they are all
24 piped together into a treatment system that will remove the
25 contamination from that airflow and then release the clean
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1 air out.
2 The fifth clean-up alternative goes a step further
3 than that, and it is the complete excavation and incineration
4 alternative.
5 What this alternative does is digs cut all the
6 sludge waste. This would have to be taking place within an
7 enclosed tent that won't let any air in or out. The reason
8 for this is that, when the sludge comes into contact with the
9 air, it emits a lot of very hazardous vapors, very poisonous
10 gases.
11 For that reason, the workers within the enclosure
12 who are digging the material out would need to be wearing
13 these special suits with their own air supply, similar to
14 astronauts' moon suits.
15 There's going to be a continual flow of air being
16 pumped in and then pumped out of this, and the air will have
17 to undergo a high degree of treatment to clean the
18 contamination out of it before it's then released clean, up
19 into the air.
20 This project would take approximately five years of
21 the digging process.
22 Once the stuff is dug out, it would be trucked or
23 shipped to a hazardous waste incinerator, for which are none
24 in California and it would likely go to another state.
25 After such an alternative is completed, the soil
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1 vapor extraction wells would continue to suck out any
2 remaining vapors in the soil beneath the former pits.
3 Of these five alternatives, the alternative that
4 the EPA prefers was determined by comparing these
5 - alternatives to each other according to very standard
6 criteria that's given to us in the law.
7 There were seven of these criteria. One is
8 protection of human health and the environment. Another is
9 short-term effectiveness; how safe is it while it's being
10 built and processed. Third is the reduction of toxic mass
11 through treatment. Fourth is compliance with regulations and
12 laws that exist about those hazardous substances. Fifth is
13 implementability: can we do it; is it possible to do this
14 process. Six is cost. And seven is long-term effectiveness:
15 will this last.
16 The remedy that EPA prefers is number four, the one
17 that has a cap and soil vapor extraction.
18 The first act -- the first remedy doesn't do
19 anything and does not protect human health and the
20 environment. Neither does number two, the institutional
21 control, access control; this does nothing to keep the
22 contamination from moving down into the groundwater or moving
23 up and emitting into the air.
24 The third alternative, the cap, does prevent
25 contamination, the vapors from coming up into the air;
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1 however, it does not stop them from going down into the
2 groundwa t e r.
3 Institutional controls with the cap and soil vapor
4 extraction will do that protection of groundwater because
5 it'll be sucking out the vapors beneath the pits before it
6 can get down into the groundwater, at least significantly
7 reducing the movement into the groundwater.
8 The fifth alternative is protective in the long run
9 because the waste will be removed, excavated and eliminated.
10 However, in the short term while it's being dug out, it's
11 very dangerous because of the amount of time that it would
12 take, and the fact that it has to be done within an enclosure
13 for all that time. Trying not to emit any vapors, having any
14 of that escape, could be a very difficult thing and,
15 actually, has never successfully been done on this large of a
16 scale. In addition, this fifth one is also ten times more
17 costly than the next protective remedy.
18 So I've told you how we screened through these
19 technologies and came up with our proposed five remedies, and
20 which protective remedy we are preferring and why.
21 Now we want to hear from you and what you think.
22 And I'm going to turn it back over to Dave.
23 VSR. COOPER: Thanks, Dante.
24 What I'd like to do is -- if someone could get the
25 lights back there; thank you very much.
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1 I'd like to take a short break. We want to remove
2 some of this material, set up a microphone so the folks can
3 come up to make their public comments. So if people want to
4 stand up and stretch --
5 MR. DHONT: Going to do questions first?
6 MR. COOPER: Oh, excuse me. That's right. I'm sorry.
7 Were there any questions, clarifications about
8 specific things that Dante has talked about?
9 Sir?
10 MR. SPEAKER: Yes. Is the -- these alternatives include
11 addressing the soil in the homes on 204th Street that have
12 been fenced off?
13 MR. RODRIGUEZ: No, this is only the pits -- the waste
14 that's in the pits and the soil that's around the pits
15 themselves.
16 MR. SPEAKER: Is there presently any plan to -- or any
17 process -- well, tell me what -- where that process is to
18 address the homes themselves that were fenced off.
19 MR. RODRIGUEZ: The homes that were fenced off on
20 204th Street was part of a emergency removal action, which
21 happened independently from the clean-up of the pits area.
22 That was put on hold while discussions took place with the
23 community regarding buy-out.
24 MR. COOPER: Sir, in the back.
25 MR. SPEAKER: Yes. Should we go with number five, how
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1 deep will you dig to remove?
2 MR. RODRIGUEZ: The -- the sludge pits, I believe, go
3 about as deep as 30 feet deep.
4 MR. SPEAKER: And the contamination that is spreading
5 past that?
6 MR. RODRIGUEZ: And the contamination that's spread
7 further down than that will be gotten with vapor extraction
8 wells.
9 MR. SPEAKER: Has -- has the contamination spread
10 laterally at all? I've seen some -- some test wells where
11 the ... is -- used to be directly behind or in between the
12 houses and the pits. Has any lateral detections?
13 MR. DHONT: It has spread laterally, but not beyond the
14 pit bounds.
15 MR. RODRIGUEZ: Somewhat. I believe, from -- from the
16 last report that I have looked at it, it had gone from the
17 sludge pits themselves laterally somewhat, about as far as
18 the fence line. So those areas would be sucked with the
19 vapor extraction, if they -- depending on how much was there.
20 If we've found enough -- that it was still a concern, then,
21 yes.
22 MR. SPEAKER: ... at what depth?
23 MR. RODRIGUEZ: Down -- all the way down to 70 feet, to
24 groundwater.
25 MR. SPEAKER: That's -- that's where the lateral
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1 detection is?
2 MR. RODRIGUEZ: The -- the detection would stop when --
3 once you get to groundwater.
4 MR. SPEAKER: Right. Because I remember seeing an EPA
5 chart showing a benzene plume that goes all the way over to
6 Orange Boulevard.
7 MR. RODRIGUEZ: Yeah. Once the benzene hits the
8 groundwater, it moves within the groundwater; and that would
9 be a subject of the groundwater clean-up remedy, which is
10 different than just the soil. So it --
11 MR. SPEAKER: Benzene ..., correct?
12 MR. RODRIGUEZ: Correct.
13 MR. SPEAKER: So it is possible that the benzene,
14 depending on whether the soil conditions are -- are right are
15 not; if the soil conditions are dry, the benzene can
16 literally volatilize and come up over the course of that
17 70 feet?
18 MR. DHONT: Actually, the -- the -- '
19 MR. COOPER: Jeff, why don't you use the mike.
20 MR. RODRIGUEZ: Yeah. He's the groundwater specialist
21 here.
22 MR. DHONT: Yeah. Actually, it can volatilize off of
23 the groundwater, but it does not volatilize to a very great
24 degree. It stays within three feet, five feet of the
25 groundwater table; so the groundwater is far, far below the
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1 surface and the -- there is really no threat to people on the
2 surface from benzene in grcundwater.
3 In addition, there was soil gas sampling done along
4 the -- between the houses and the pits at shallower depths,
5 to ascertain whether lateral migration of vapors was making
6 it at a -- at a lesser depth, closer to the -- you know,
7 the -- the homes.
8 MR. SPEAKER: ... deeper than 20 feet, because it ...
9 MR. DHONT: Well, it would -- that would be roughly in
10 the --in that realm would be where you would be concerned
11 about vapors moving into homes. In the soil gas -- that
12 sampling indicated there was not vapors moving into homes out
13 of the pits.
14 MR. COOPER: Sir, in the back.
15 MR. SPEAKER: Yeah. What conditions, in terms of the
16 movement of toxics, toxins or hazardous material -- what
17 conditions will continue to exist after the proposed remedy?
18 In other words, I understand that the cap and the
19 soil and extraction will do something, but what will continue
20 to happen? In other words, will anything spread or will it
21 all eventually be remediated?
22 MR. RODRIGUEZ: The plan tries to contain it all and
23 stop it from spreading in any direction.
24 MS. SPEAKER: How long will that containment last?
25 MR. RODRIGUEZ: As long as it needs to; as long as the
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1 waste is still there and it's still a threat.
2 MS. SPEAKER: So a cap has no life -- has a life of
3 infinity?
4 MR. RODRIGUEZ: Indefinite, right.
5 MS. SPEAKER: I thought they were only good for like
6 50 years.
7 MR. RODRIGUEZ: Well, if something needs to be replaced,
8 an individual part can be replaced and continued on.
9 MS. SPEAKER: How many contaminants will those vapor
10 extraction things accommodate? I mean, how much of the
11 hazardous material vaporizes and how much of it stays in the
12 soil?
13 MR. RODRIGUEZ: The question was, how much of the
14 contamination vaporizes and can be gotten with the -- with
15 the vapor extraction wells.
16 The answer is, there is a whole class of the
17 contaminants, called the volatile organic contaminants; and
18 by -- by a percentage -- I'm not positive "exactly what
19 percentage they make up, but what they do make up is the bulk
20 of what moves. So basically, all of the things that are very
21 mobile and will be moving up or down, will be gotten.
22 MS. SPEAKER: And whatever doesn't move, remains.
23 MR. RODRIGUEZ: Remains, right.
24 MS. SPEAKER: Yeah.
25 MR. COOPER: Sir?
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1 MR. SPEAKER: You mentioned on your alternative
2 number four would take approximately five years -- or nc, no,
3 the extraction -- I'm sorry, the complete extraction comes to
4 five years for clean-up.
5 What time length are we looking at for alternative
6 number four, for -- for a complete clean-up?
7 MR. RODRIGUEZ: The vapor extraction wells would remain.
8 MR. SPEAKER: Right. Now, the toxins in the soil, I
9 mean, what time lengths we looking at to -- to clean up the
10 toxins in the soil, as well as --
11 ANOTHER MR. SPEAKER: . . . where does the toxic waste go,
12 the toxic waste go?
13 MR. SPEAKER: It sounds like somebody's been drinking
14 the toxic waste.
15 Excuse me, sir.
16 Approximately how long are we looking at?
17 MR. RODRIGUEZ: Well, as long as the sludge is there, it
18 will continue to emit vapors down and up. " And it will
19 continue to do that, and, thus, the soil vapor extraction
20 will continue to sit there and then collect them as they come
21 down.
22 MR. SPEAKER: Are -- are we looking at 20 years,
23 25 years, 30 years, until the vapors subside? I mean, how
24 long will --
25 MR. RODRIGUEZ: Indefinitely.
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1 MR. SPEAKER: Oh, okay. So there -- there is no real
2 clean-up here; it's just a kind of --
3 MR. RODRIGUEZ: It's a contain- --
4 MR. SPEAKER: -- kind of like --
5 MR. RODRIGUEZ: It's a contain- --
6 MR. SPEAKER: -- trying to put a Band-aid over a sore
7 kind of thing.
8 MR. RODRIGUEZ: A containment.
9 MR. SPEAKER: Okay. Okay. Thank you.
10 MR. COOPER: Sir, in the back.
11 MR. SPEAKER: I'd like to go with that number five. You
12 know, I been in the neighborhood all my life, and it seems
13 like we're just getting pushed around. Nothing ever gets
14 done.
15 Dig it out, get rid of it.
16 MR. COOPER: Sir, that also might be something you'd
17 want to repeat when we get to the public comment period, the
18 second half of this meeting.
19 MR. SPEAKER: Whether it take five years or two years,
20 whatever, ...
21 MS. BABICH: Dante -- or, I'm sorry, Dhont, Jeff Dhont,
22 what is it that keeps the benzene on the groundwaters from
23 volatilizing more than a few feet?
24 MR. DHONT: Well, it's -- it's somewhat of a complex
25 technical situation. But the -- the benzene, once it gets
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1 into the groundwater, is dissolved; and it's dissolved in the
2 groundwater and it's moving with the groundwater.
3 And, yes, the ground -- the dissolved
4 concentrations are very high, but it -- you know, the bulk of
5 the benzene will be staying in the water. Some of it will
6 volatilize, but then it goes up into the soil column a short
7 distance above the water. And there isn't -- there really
8 isn't anything to -- to drive it back up; so it will go a
9 certain distance.
10 And you do see that. If you -- if you sample down,
11 you know, all the way to the water table, you will see high
12 contamination at the top, and then it will tend to sort of
13 peter out, and then you'll see higher contamination again
14 right down at the water table, which is sort of what we call
15 the halo effect.
16 If the --if the concentrations in the groundwater
17 are high enough, and you -- and you will see that, but it --
18 it's -- there is -- there's just no -- it's not enough
19 benzene to drive it all the way up to the surface.
20 MS. BABICH: Well, as you're probably --
21 MR. DHONT: The soil stops it, in essence.
22 MS. BABICH: -- very well aware of in clay soils, a lot
23 of times in our neighborhood, we have large cracks; and what
24 would happen if one of these cracks reached down there pretty
25 far? Wouldn't that be just the perfect pathway for this soil
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1 gas to escape from?
2 MR. DHONT: Again, you'd have to have -- you'd still
3 need a lot of, a lot of benzene coming off the groundwater to
4 drive it that -- that far. But it is also very highly
5 unlikely that you have any -- while you do have some
6 cracks -- wide cracks, you have clay cracks that extend
7 anywhere near that far down.
8 MS. BABICH: 60 feet?
9 MR. DHONT: 55, 60 feet, 70 feet, yeah.
10 MR. COOPER: There was a gentlemen -- there was a
11 gentleman in the front who raised his hand earlier and I
12 didn't -- I didn't catch him, and then he went into the back.
13 Sir, could you -- did you have your hand up?
14 Well, there was a gentleman in the back. Sir?
15 MR. SPEAKER: Yes. Is volatilized benzene lighter than
16 air or heavier than air?
17 MR. RODRIGUEZ: Jeff?
18 MR. DHONT: It's heavier.
19 MR. SPEAKER: It is.
20 MR. DHONT: Yeah.
21 MR. SPEAKER: Okay. And another question about the --
22 MR. DHONT: It's lighter than water. If you have pure
23 benzene, it will float on water.
24 MR. SPEAKER: So it's floating on ... water ...?
25 MR. DHONT: There -- there are locations on the side
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1 where you can --if you have pure benzene right at the
2 source, £.nd the pits is not one of them, you can get benzene
3 floating on the water.
4 But the groundwater contamination that I have been
5 discussing is dissolved; so I'm drawing a distinction
6 between -- let's -- if, for instance, have salad oil and
7 water, they don't mix really; you just have two separate
8 layers, but a certain amount of it does dissolve in the
9 water. Okay.
10 Now, what we're seeing at the pits and out -- going
11 out from the pits in the groundwater is the dissolved part,
12 in this case.
13 MR. SPEAKER: ... You're -- you're speaking as if the
14 level of the groundwater never changes. But it does, in
15 fact, change regularly.
16 MR. DHONT: Yeah. The groundwater table, in fact, over
17 a long period of time, has been rising. But it -- it's risen
18 on the order of -- I'd -- I'd have to look it up but, you
19 know, five feet or ten feet or something like that, and
20 that's over the last couple decades.
21 It also does fluctuate on a seasonal basis, but
22 that -- those are very small fluctuations. So you have to,
23 you know, imagine again the distance from me to the rest
24 rooms, and then imagine, you know, water moving, fluctuations
25 between me and the front row. Okay?
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1 So that is going on but there's still a very great
2 distance between that groundwater and the surface of the
3 ground.
4 MR. SPEAKER: ... depth of the groundwater, say, over
5 the last ... years?
6 MR. DHONT: I'd have to look it up. I imagine -- it's
7 probably in the neighborhood of 55 feet.
8 MR. SPEAKER: I would like to have the fact, if you
9 could find that?
10 MR. DHONT: Sure.
11 MR. COOPER: Sir, you had a question.
12 MR. SPEAKER: Yeah. You said there was an excavation
13 done on a smaller scale, considering the number five option.
14 What are the circumstances and -- what is the
15 probability of a leak of some kind during the five years it
16 would take if option five was chosen?
17 MR. RODRIGUEZ: The other site that I'm familiar with
18 where there was a small sealer excavation was at the McCall
19 site in Fullerton, California, and they did it as a trial
20 excavation, to see if it was practical and see what problems
21 they would run into when they were doing that.
22 They concluded from that report that it was --it
23 was very problematic maintaining that sealed atmosphere for
24 any extended period of time. And I don't know what the
25 actual probability of having that breached would be.
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1 MR. SPEAKER: It's kind of a difficult question, I
2 guess, but it would seem important if you could -- if you
3 could do option number five and prevent the escape of any of
4 the toxins -- toxic substances, then that would be -- if not:
5 for the cost, that would be the way to go.
6 MR. COOPER: There was a woman -- yes, ma'am, please.
7 MS. SPEAKER: What's the justification for the ...
8 standard for the soil vapor extraction falling, the
9 groundwater concentration? Once a given level has been
10 established, why should the standard drop? I mean,
11 cleaning -- if you're at the beginning, saying that
12 acceptance of the ... is X, why would you raise that level at
13 the time?
14 MR. DHONT: I don't understand it.
15 MR. RODRIGUEZ: Why would -- the question was why would
16 you change a clean-up standard --
17 MS. SPEAKER: Performance standard.
18 MR. RODRIGUEZ: -- once you set it?
19 MS. SPEAKER: Right.
20 MR. DHONT: Oh.
21 MS. SPEAKER: If a given percentage is set, why would
22 that change? What's the justification for that?
23 MR. DHONT: You're referring -- have you been -- did you
24 read the supplemental --
25 MS. SPEAKER: Yes.
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1 MR. DHONT: Okay. You're referring to a changing
2 standard --
3 MS. SPEAKER: Correct.
4 MR. DHONT: Okay. I can explain that.
5 Really, what we're doing with this soil vapor
6 extraction system -- there's many different sources in this
7 whole area that are contributing to groundwater. The pits
8 are just one of them, okay?
9 So this is a remedy that, you know, in addition to
10 protecting things going up into the air, we're trying to
11 eliminate one of those sources to the groundwater.
12 Now, one of the issues that comes up is that the
13 groundwater currently is contaminated -- very, very heavily
14 contaminated. So there is, say, at least 400,000 or 500,000
15 parts per billion dissolved benzene directly under the pits
16 or up to those levels. Okay? Again, I'm talking about the
17 groundwater, okay?
18 Now, so one of the issues that comes up is, we need
19 to look at how clean we can ever get that groundwater. Okay?
20 And if the answer -- for the groundwater, it may -- it may
21 literally be impracticable; it may be impossible for us to do
22 anything with the immediate groundwater other than contain
23 it.
24 Now, we think in -- and this is sort of a -- for
25 another meeting, but we think there are things we can do with
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1 the bulk of the far outside groundwater, but immediately
2 under the pits, there may not be something we can do with
3 that.
4 So the question is, how much do we need to clean up
5 that soil to protect the groundwater that's already extremely
6 contaminated. And the -- what we came up is, we used some
7 calculations to help us estimate, given a certain level in
8 the soil, how much would -- could that increase the
9 groundwater concentration.
10 And what we wanted to make sure was that that --
11 whatever was left in the soil after soil vapor extraction,
12 could not impact the current groundwater contamination by
13 more than a very small amount, relative to what that
14 concentration was. Okay?
15 I know that's kind of complicated but --
16 MR. SPEAKER: In other words, this should have started
17 30 years ago?
18 MR. DHONT: Yeah. Well, EPA wasn't here 30 years ago.
19 MS. SPEAKER: ... justification --
20 MR. DHONT: Yeah.
21 MS. SPEAKER: -- for -- what the rationale is for to be
22 able to accomplish something, why would you accomplish less
23 than that?
24 MR. DHONT: Well, the -- really what it boils down to
25 is, if you're going to -- for instance, if I have 450,000 in
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1 the groundwater, and I -- and I'm saying, "Okay, we're going
2 to limit that to no more than an additional 50," which
3 compared to 400,000 is -- is nothing, if it would take -- if
4 the --
5 MS. SPEAKER: A lot more than zero.
6 MR. DHONT: Oh, sure, it is. But zero and 50 are
7 essentially the same when you're looking at 400,000.
8 So -- but if we manage to get 400,000 down to some
9 lower number, then -- then the soil would have to be
10 respectively even more clean to keep it commensurate. So,
11 yes, it's not zero; that's true.
12 MR. COOPER: Sir, ...
13 MS. SPEAKER: Which --
14 MR. COOPER: I'm sorry, ma'am. ...
15 MS. SPEAKER: Which aquifer is it you're speaking of?
16 And are there any perched aquifers on this property?
17 MR. DHONT: Per se there's not a perched aquifer, no.
18 There are several aquifers under the site. The
19 first groundwater in this area is what we call the Upper
20 Bellflower; and underneath that we call it -- is what we call
21 the B sand. The water table occurs, in some cases in one --
22 in the B sand, some cases in the --in the Upper Bellflower.
23 MS. SPEAKER: And what are the purposes of those
24 aquifers for ...?
25 MR. DHONT: They -- they are listed by the state as
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1 potential drinking water supplies, as are most aquifers in
2 the area, but they are currently not used for any purpose,
3 and nc one is drinking any of the water from the site.
4 MR. COOPER: Sir, in the back.
5 MR. SPEAKER: Yeah. Well, my question is, if -- if we
6 go with alternative nur±>er four, if the EPA decides to go
7 with that, can the EPA guarantee that this is going to be
8 absolutely safe for the neighborhood, for the surrounding
9 neighborhood, or can there be any malfunctions in the system?
:0 Can there bed leaks in the system? Can that be detected if
11 there are any?
12 MR. RODRIGUEZ: The question was about guarantees that a
13 alternative four, cap and soil vapor extraction system, would
14 work to protect the community. And as best as technically
15 possible, yes, EPA is guaranteeing that this is going to be
16 safe for people.
17 Now, are there going to be problems? Is something
18 going to break down? That always happens;'but as long as,
19. you know, EPA is there to take care of it and come back,
20 or -- or to stay or some of these tasks with maintaining this
21 system in a safe, operable way, then, yes, there will always
22 be somebody to come back and fix anything that happens to go
23 wrong.
24 MR. SPEAKER: It seems to me that with alternative
25 number four, we're still taking chances, that -- that we're
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1 going to have ... It seems to me that that is still beyond a
2 certainty.
3 MR. COOPER: I understand.
4 There was a gentleman up front and then the one in
5 the corner.
6 MR. SPEAKER: Yeah. I have a two-part question.
7 When this lady back here was mentioning the water,
8 this gentleman kept referring to as vapor extraction to clean
9 up the soil, which brings me back to my first question: Is
10 it's cleaning up the soil, how long will it take to
11 completely clean up that soil?
12 He kept mentioning, "Well, the vapor extraction
13 will clean the soil." So how many years are we looking at,
14 for a cleaner soil, at least below state and federal
15 standards for safety?
16 And the second part of the question is, I see that
17 your -- the capping is approximately $9 million. Now, if
18 this is forever, does this include maintenance? If not, how
19 often does maintenance occur, and what kind of price are we
20 looking at, over and above the original 9 million for
21 capping?
22 MR. DHONT: The quick answer to the second part of the
23 question is it does contain -- it is based on a present-worth
24 analysis, so it does look at operation and maintenance over
25 the lifetime of the cap. And, of course, there's a -- you
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1 know, a depreciation, you know, in that amount as time goes
2 on, due to the time value of money. So that is factored into
3 the cost.
4 In terms of soil vapor extraction and protecting
5 groundwater, realize that what EPA --
6 MR. SPEAKER: Well, no, no, not the groundwater. She
7 was talking about groundwater, and you kept saying as the
8 soil vapor extraction will clean the soil, it will eliminate
9 contamination of the groundwater.
10 What I'm asking is, the term "clean up the soil,"
11 what do you mean by that? If this is a forever process, and
12 we're looking at a contaminated parcel --
13 MR. DHONT: Right.
14 MR. SPEAKER: -- how can you possibly clean this up?
15 MR. DHONT: Okay. You have to -~ you have to imagine --
16 when we say "clean up," we don't mean to zero. What we're
17 saying is that -- according to the proposed plan, if you read
18 it, you'll see there are specific standards we are setting.
19 We're saying that you have -- they have to get -- through the
20 soil vapor extraction they have to get that zone down to
21 those levels.
22 The thing is is, in principal, anyway, there will
23 be more contamination coming out of the pits the whole time;
24 so this SV system will be continually fighting to keep what's
25 coming out balanced with what's being extracted.
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1 MR. SPEAKER: It's an endless circle; as --
2 MR. DHONT: It is --
3 MR. SPEAKER: -- contamination is extracted, more
4 contamination --
5 MR. DHONT: More is coming down, but -- but the
6 system --
7 MR. SPEAKER: -- ... the ground, so it's a continuous
8 circle will never --
9 MR. DHONT: That's right. It is a containment --
10 MR. SPEAKER: ... right?
11 MR. DHONT: -- it is a containment approach, that's
12 correct. You are -- so we -- by cleaning the soil, we mean
13 we're reducing the soil concentrations to a point. And they
14 will clean up to that point, to the point where the threat to
15 groundwater is essentially insignificant.
16 MR. SPEAKER: ... groundwater --
17 MR. DHONT: But they still have to keep running -- you
18 know, your question seems to indicate, "Well, how long before
19 we turn it off?" Well, we don't turn it off --
20 MR. SPEAKER: Well, no, not turn it off.
21 MR. DHONT: Yeah.
22 MR. SPEAKER: I was wondering about the term "clean up."
23 And I read in here ... that there's a proposed plan to build
24 a park on top of this waste dump.
25 Now, since we're in California and we're very
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1 susceptible tc earthquakes, what's the chance of us having
2 some sort of an earthquake that will break this cap, and
3 allowing the -- what is it, sulfur hydrogen gas? Hydrogen
4 sulfide gas to be released in -- into the air.
5 Now, we're -- now there's a park on top of it, so
6 the kids are in the park playing, we nave an earthquake,
7 boom, here corss all this contaminated mess.
8 MR. RODRIGUEZ: Yeah. So the question was the
9 probability of an earthquake damaging the cap and allowing
10 things to come up.
11 MR. SPEAKER: Right. Safety to -- to the citizens --
12 MR. RODRIGUEZ: Right.
13 MR. SPEAKER: -- if that occurs, I mean, how long would
14 it take to remediate the situation, to get an emergency crew
15 out there and to cap it off?
16 MR. RODRIGUEZ: Now, it's -- the probability of an
17 earthquake happening in any particular place is just that; a
18 probability.
19 We haven't done any analysis for the probability of
20 earthquake in this particular area, so I couldn't say what
21 the probability of an earthquake is, although I -- what we
22 could say is what we expect the performance of our cap, as we
23 design it, to be in case of a certain amount of earthquake.
24 MR. SPEAKER: Right, right.
25 MR. DHONT: Yeah. And what -- what can be done is, when
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1 we're designing it, design for, you know, earth movement or
2 whatever kind of shaking occurs during the earthquake, up to
3 the maximum credible earthquake, similar to the way that they
4 design a freeway. They look at, what is the -- how much
5 possible shaking could there be and how do we think our
6 system's going to respond to that.
7 And that can be taken into account when we design.
8 But as far as, if something does happen that then releases
9 them, you know, what is the time for emergency response, was
10 the other part of your question?
11 MR. SPEAKER: Right.
12 MR. RODRIGUEZ: And both the EPA, the state and
13 sometimes the County have emergency-response people that are
14 able to respond immediately to those types of accidents.
15 MR. SPEAKER: In other words, the long and short of it
16 is, is capping is good for business?
17 MR. SPEAKER: Well, has there ever been a failure with
18 the cap, that EPA has capped on these different land sites?
19 Have you ever experienced any kind of a failure?
20 MR. RODRIGUEZ: That I don't know. I'm not familiar
21 with examples across the country.
22 MR. SPEAKER: How long have you been capping?
23 A VOICE: How much time --
24 A VOICE: ... a long time?
25 MR.: RODRIGUEZ: Yeah. The capping technologies that
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1 were laid out in the --in the law that I was telling you
2 about, the law was passed around 1980. So --
3 MR. SPEAKER: When was the first cap built?
4 MR. RODRIGUEZ: Don'z know.
5 MR. SPEAKER: How long -- what kind of a performance
6 record do you have here?
7 MR. RODRIGUEZ: Yeah, I don't -- I'm not --
8 MR. SPEAKER: ... --
9 MR. DHONT: The cap -- cap has been -- since RCRA was
10 passed --
11 MR. SPEAKER: ... for example, the cap may not hold up
12 very well in an earthquake.
13 MR. DHONT: -- since RCRA was passed in 1976 there's
14 been a number of caps across the country. We're not av.-are of
15 caps failing.
16 In this particular instance, you know, number one,
17 there can be monitoring. Number two, even if there were
18 failures of one form or another, you understand what we --
19 what's on the site right now, which is just dirt, you know,
20 there's been monitoring which indicates extremely low, if
21 any, emissions from that facility. So if -- from the pit.
22 So if there were some -- you know, the cap can
23 handle ... --
24 MR. SPEAKER: You're doing the wells ... you're doing
25 the wells that will allow the -- the contaminants, the
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1 vapors, to release if there was damage to the cap.
2 MR. DHONT: I mean, the design of the cap is designed
3 such that --
4 MR. COOPER: Excuse me. Jeff, why don't you use the
5 mike because I have a feeling this is starting to get lower
6 and lower and the people aren't ...
7 MR. DHONT: The caps are designed so -- if there's wells
8 through the cap, they're designed for -- with those sorts of
9 things in mind. So if there is a problem with gas movement
10 in a well or something like that, those sorts of things are
11 accounted for in design.
12 And there are times when you do have to drill holes
13 through a cap; but -- for wells or what have you, but
14 those -- number one, you try to minimize them; number two,
15 you design for that -- those sorts of problems.
16 MR. COOPER: Michael, I think you've had your hand up
17 for about a half an hour.
18 MR. SPEAKER: Yes, I have a two-part'question.
19 The first part is, you said you've got benzene
20 that's still going to be leaking down from the pits; then
21 you've got the halo above the groundwater level.
22 Will the soil vapor extraction system tend to pull
23 the halo up; in other words, it might, in fact, cause more of
24 the benzene out of the water into the halo, then up the ...
25 Will that soil vapor extraction system affect the
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1 halo at all? Would that feed into it and have to be
2 processed and cleaned up . . . ?
3 MR. DHONT: The attempt in the design of the soil vapor
4 extraction system would be to minimize that. Obviously, if
5 you're operating system, you're trying to clean soil. If
6 you're sucking more stuff off the water, you're just sort of
7 defeating ycur purpose. So to the extent that that can be
8 avoided, we will do that.
9 The -- although there may be some halo that, you
10 know --at the upper fringes of it that do get drawn in, but
11 if that's the case, that halo would be immediately sucked
12 into the system.
13 MR. SPEAKER: Okay. And my second -- the second
14 question is this. In your decision-making process you
15 started at "do nothing"; no, that doesn't work. You went
16 down to two, you went down to three, you went down to some
17 four.
18 At some point you looked at five, and there were
19 conditions that argued for five and there were conditions
20 that argued against five, and where you -- your best decision
21 was four.
22 What I'd like to hear a little bit is, what were --
23 what was that discussion like on the border line between five
24 and ten. What was driving you toward five and what drove you
25 back toward four?
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1 MR. RODRIGUEZ: The main things between four and five
2 was safety during the process of excavating in five, and the
3 cost, it being ten times more expensive than four. Those
4 were the two main things.
5 MR. COOPER: Just as a -- as a point of interest here,
6 we have this room from 7:00 until 9:00.
7 It's a little bit past 8 o'clock, and I know that
8 there are a number of questions that people still have to
9 answer -- or to ask, to get answers; but I'd like to keep in
10 mind that the primary purpose of this meeting was to hear
11 your concerns about the proposed plan formally, so that we
12 could report them as part of the Record of Decision that
13 eventually gets made.
14 So as long as you're comfortable continuing on in
15 this vein, that's fine with us; we're happy to answer your
16 questions. But we want to make sure that everyone who wants
17 to make a formal comment -- and some of the things that have
18 been said here to me seem like formal comments about what
19 we've proposed --we want to make sure that there is time for
20 those folks to do that before the end of the meeting. So I
21 just want to -- I want to toss that out.
22 I -- this hand's been up for quite a while I think.
23 MS. SPEAKER: My question goes back to the earthquakes.
24 I'd like to know if there is a cap that's anywhere between 10
25 and 20 years old along the California coast where our fault
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1 lines follow?
2 MR. RODRIGUEZ: What was it that ...
3 MS. SPEAKER: Yeah. Do you have aged cap?
4 MR. RODRIGUEZ: I'd have to -- I'd have to research that
5 for you.
6 MS. SPEAKER.: I don't believe so. I couldn't find one.
7 And I know even at my own home in this area, I have
8 a four-foot slab in the front of my house and the last
9 earthquake cracked it, okay? So right there tells me, we
10 weren't even close -- the earthquake was in Northridge. If
11 there is an earthquake in this area, how do you see, ... the
12 cap. ***.. .?
13 MR. RODRIGUEZ: Well, to address the question of the
14 cracking that she experienced in her concrete floor, as
15 opposed to the effects of a similar earthquake on a cap, the
16 answer I would give to that is that the cap is made with a
17 lot of earthen materials, instead of solid asphalts or
18 concrete.
19 With concrete, if it's shifted enough it'll just
20 crack and -- and break and show that crack.
21 If you have clay and gravel and that kind of
22 material in your cap, if that, you know, shifts any, it'll
23 move but then it'll be resettling into itself. Clay can be
24 like clay like Play-Doh, and that kind of thing.
25 The part of your cap that's not the earthen
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1 material that's the plastic liner, you know, since it's
2 plastic, it has some give and stretch that concrete wouldn't.
3 So it has a better chance of moving and withstanding earth
4 movements that a concrete slab wouldn't.
5 MS. SPEAKER: What type of --
6 MR. DHONT: Let me just add one thing to that, too, is
7 that -- is that, really, operation and maintenance of a cap,
8 once a cap is constructed, there -- the operation and
9 maintenance period on that cap is active. And it is assumed
10 that if there are any breaks in the cap or any compromise to
11 that cap, that it would be repaired.
12 So the cap is not just placed and then -- and then
13 left. As with all the EPA remedies, there is an operation
14 and maintenance period.
15 MR. COOPER: There's a gentleman in the back who had his
16 hand up quite a while, and, sir, I'm sorry I missed you.
17 Sir, in the back. You had your hand up and I missed you
18 earlier.
19 MR. SPEAKER: How deep is this contamination?
20 MR. RODRIGUEZ: Is the what?
21 MR. SPEAKER: How deep is the contamination? What are
22 we talking about in depth? 500 feet?
23 MR. RODRIGUEZ: No, no, no. It's -- it goes as deep as
24 about 30 feet in the sludge form, and then in the
25 groundwater, the stuff that leaks down into the groundwater,
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1 it gets deeper than that down in the water.
2 And how deep is the --
3 MR. COOPER: Jeff?
4 MR. DHONT: How deep is what?
5 MR. RODRIGUEZ: -- deep is contamination in the
6 groundwater.
7 MR. SPEAKER: If you're talking about the ... three days
8 ... remove all that ... all the expenses involved ...
9 MR. SPEAKER: (Inaudible.)
10 MR. COOPER: That sounds like something you definitely
11 want to say during the public comment part of this, sir. I
12 mean --
13 MR. SPEAKER: What's the big discussion? Why not dig
14 out that cancer and get rid of it and it's over with. No
15 more cap.
16 MR. COOPER: Sir, the gentleman standing in the --in
17 the doorway, you've had your hand up for a long time.
18 MR. SPEAKER: Yes. I had a couple of things I wanted to
19 comment about, what this fellow was asking.
20 Has anybody even bothered to look into fault lines
21 or anything like that in our area, or was earthquake totally
22 ignored?
23 MR. RODRIGUEZ: Yeah. For that I'd have to look back to
24 the --to the reports that I've read; but I seem to remember
25 the initial study of the environmental area said that there
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1 was no fault line running through the pits area. But I'd
2 have to double check on that to give you a better answer.
3 MR. SPEAKER: What . . . ?
4 MR. DHONT: For sure.
5 MR. SPEAKER: ... if we have a major earthquake ... it
6 rocks and rolls ... something else.
7 This RCRA cap, when are we going to see the final
8 detail of how it's constructed? Because I've been asking for
9 this information for -- ever since you guys started, and I
10 haven't seen anything yet.
11 MR. RODRIGUEZ: So the question is the details about the
12 design of the RCRA cap.
13 My projection about our process is that once I
14 finished taking all public comments and we make the official
15 decision, we're going to seek to get the design going through
16 the companies that were -- had dumped the stuff there. And I
17 think a -- an optimistic negotiation time to get an agreement
18 with them to do the work would be perhaps"six months after
19 that. So my projection is that the design would be starting,
20 maybe as early as this fall.
21 MR. SPEAKER: You want us to go along with something
22 that you haven't even designed yet?
23 MR. RODRIGUEZ: We haven't designed it yet, right.
24 MR. SPEAKER: Right. You're asking us to say --
25 MR. SPEAKER:
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1 MR. SPEAKER: -- okay. That doesn't make any sense
2 whatsoever. I mean, let's put the horse in front in front of
3 the cart.
4 MR. COOPER: Ma'am, way in the back.
5 MS. SPEAKER: You've answered a number of questions ...
6 MR. SPEAKER: ... to earthquakes, and --
7 MS. SPEAKER: (Inaudible.)
8 MR. SPEAKER: No, but was it even considered. That was
9 the question.
10 MS. SPEAKER: (Inaudible.)
11 MR. DHONT: It's recognized that it is an earthquake
12 area. There -- there are no faults running right under the
13 site. It was recognized that there are earthquakes in this
14 area.
15 The point is, the cap can be designed to withstand
16 earthquakes, and if -- again, if there were any breach of
17 the --of the cap, then those -- that maintenance would be
18 performed.
19 And, no, we have not designed it yet. In the
20 Superfund process, we select a remedy. The actual full-blown
21 design occurs after the remedy is selected.
22 But these RCRA caps have been designed and -- and
23 they're -- they're a variety of different designs, but
24 we're -- we're telling you what the cap would be --
25 MR. SPEAKER: ... on page 5 the basic structure.
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1 MR. DHONT: That is the basic structure, yes.
2 MR. SPEAKER: ... But the basic structure of the cap
3 drawing on page 5, . . . ?
4 MR. COOPER: Ma'am.
5 MR. MONTGOMERY: I actually -- I have some examples of
6 the types of materials that would be used in these cap
7 systems, and people interested in looking at them after
8 the ...
9 MR. COOPER: Okay. That was Mike Montgomery. He'll be
10 available afterwards to show some of the material that's
11 used.
12 Ma'am, you had your hand up.
13 MS. SPEAKER: Yes. I grew up here in this area, I did
14 go ... and my family still lives there. And we are told the
15 homes are ... in the -- south of 204. But I'm just
16 wondering, when they get to that, how dangerous that is
17 for ...
18 MR. DHONT: Are you referring to areas --
19 MS. SPEAKER: (Inaudible.)
20 MR. DHONT: Yeah. There's two investigations we're
21 planning to do, and I can tell you this briefly. And in
22 interest of time I'd -- I'd like, if you -- we -- I can talk
23 to you more about it afterwards, but we want to make sure
24 people have an opportunity for comment.
25 There are two investigations that we are currently
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1 planning for. We'd like to begin them chis year, if
2 possible, pending funding constraints and what have you. But
3 the first is along the Kenwood Avenue, where there was a
4 former drainage pathway from the Montrose site; and the
5 second is the general neighborhood where about -- rhe issue
6 of aerial dispersion of DDT from Montrose.
7 Currently we do not have any indication that either
8 of those is an immediate health threat; but we are checking
9 it out. We are checking it out.
10 MR. COOPER: Sir, with the -- with the fact sheet in
11 your hand.
12 MR. SPEAKER: I have a problem with putting money . . .
13 It seems to me that -- that between number four and number
14 five a big issue is the cost involved in it. ... the cost
15 between four and five.
16 And I can see how . . . have people working . . . but
17 looking at a long-term, 20, 30, 50-year situation, what do
18 you guys consider less hazardous to workers who are going to
19 be working at this site, or long-term in the neighborhood?
20 ... the cost issue ... I don't think ... that should be an
21 issue. I mean, the health and safety, that should be the
22 main ...
23 MR. RODRIGUEZ: Yes. The question was the long-term
24 effectiveness of four versus five. And five because it
25 removes the waste, after that whole removal and the
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1 incineration process is done, five, because the waste
2 wouldn't be there anymore, would be more safe in the long run
3 because it's not there anymore.
4 MR. COOPER: Ma'am.
5 MR. SPEAKER: ... If you have another decision-maker,
6 what's he going to propose ... Sacramento ... But why would
7 you even consider four?
8 MR. RODRIGUEZ: Because we do have to consider cost, and
9 we do have to consider the short-term safety during the
10 construction.
11 MR. DHONT: And it is safe.
12 MR. SPEAKER: Don't you also consider the cost of
13 medical bills of people that are living there while all these
14 toxics are going on? I mean, you add up all the major
15 medical bills of the people in the neighborhood, versus your
16 hundred billion dollars to clean it up, it's still going to
17 balance out. But you've got a whole lot of us people with
18 cancer and et cetera, et cetera.
19 MR. RODRIGUEZ: So the question was, is medical bills
20 factored into it during the comparison of the cost of the
21 alternatives? And the answer is no, we don't do that.
22 MR. SPEAKER: Yeah, I know. You ought to.
23 MR. COOPER: Ma'am.
24 MS. SPEAKER: Was there ever an alternative six which
25 involved removing the contaminated soil? And if not, why
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1 not? Just strictly ... if that was considered at all, what
2 were the costs if that was done?
3 MR. RODRIGUEZ: The question was removal of soil.
4 When I was talking about the screening of the
5 initial technologies, about 24 of them, one of them was the
6 excavation of soil, and then various other things happening
7 to it. And off the top of my head I don't remer±>er what that
8 cost was of the excavation of the soil.
9 But I do remember that the volume of soil is very
10 much greater than the volume of the sludge.
11 MR. DHONT: And it's much deeper.
12 MR. SPEAKER: As far as your criteria, is part of the
13 criteria, isn't it also, community acceptance?
14 MR. RODRIGUEZ: Right.
15 I talked about the first seven criteria that we
16 used to come up with the alternatives to date; and the eighth
17 and ninth criteria are what we're doing right now, is
18 community input, community thoughts and comments on the
19 remedies. That's the eighth.
20 And the ninth is the State of California acceptance
21 of the remedy and which they prefer. So that's what we're
22 doing now is having the meetings, seeking --
23 MR. SPEAKER: Well, in order to get my acceptance, I'm
24 going to need to see some kind of -- of plan or design, which
25 isn't going to get started until after we accept?
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1 MR. RODRIGUEZ: Right.
2 MR. SPEAKER: Somehow that doesn't sit well with me. I
3 don't know about my neighbors. Most of them are pretty
4 smart, though.
5 MR. RODRIGUEZ: Okay.
6 MR. COOPER: If there were no other clarifying
7 questions, specifically about what was presented as these are
8 what the five alternatives were and this is our proposal, in
9 the interest of time, perhaps we could take a short break,
10 allow us to set up and then take your formal comments,
11 including many that you've already made, if you wouldn't mind
12 making them again to make sure that we get them very clearly.
13 And before I -- before I ask you to leave, I'd like
14 you to again consider going out and signing in, if you
15 haven't signed in already. And remind you about the end-use
16 work group that EPA is coordinating at the request of the
17 Del Amo Action Committee; that sign-in roster is to the far
18 end of the table.
19 If you wish to speak and make a formal oral comment
20 this evening, there are cards out front; please sign them and
21 just hand them to me. And if you prefer to make your comment
22 in writing, there are comment forms out there that are
23 already addressed to EPA which you can simply fill out at
24 your leisure.
25 The formal comment period began on December 16th
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1 and ends on February 13th. That was a 60-day comment period.
2 So if -- if you'll just give us a few minutes.
3 MS. BABICH: Before you guys break, I know a lot of you
4 are tired and you want to go home.
5 But I do have some comments that I've been waiting
6 to make and hopefully you'll get some of the knowledge and
7 some of the stuff that the Committee, had to go through over
8 the last couple of years to try and get to this point. And I
9 think that if you leave before you hear them, you might miss
10 out on some important information.
11 So I'll make it as brief as possible, but I hope
12 that you'll stick around.
13 MR. COOPER: Again, the rest rooms are out the door and
14 directly across the lobby.
15
16 (Recess.)
17
18 MR. COOPER: Let's all take our seats. We'll be
19 starting the second part of tonight's meeting.
20 When I opened the meeting this evening, I said that
21 this is a -- a special kind of meeting. It's a time when we
22 go to the public and ask for their comments about our
23 proposed plan in a more formal fashion, and this part of the
24 meeting is that more formal part.
25 I said that this is a special kind of meeting.
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1 It's a time when we go to the public and ask for their
2 comments about our proposed plan in a more formal fashion,
3 .and this part of the meeting is that more formal part.
4 To my right is Lee St. James. And you'll notice
5 that she has a machine over there and it's -- it's going to
6 record the public comments and those will be transcribed into
7 a document that we have as a record of this meeting.
8 The comments that you give us this evening formally
9 by speaking or in writing with the document that is back on
10 the tables, those -- those comments are put together in what
11 we call a responsiveness summary where we summarize all of
12 the comments and issues that were raised by the public
13 regarding the way we plan to take care of the waste at the
14 Del Amo Pits.
15 In order for this to work most effectively, we at
16 EPA will be listening through this part except where we need
17 to clarify what -- what you've said. If there's something
18 that's said that we don't quite understand, we may ask "What
19 did you mean by this?" or "What did you mean by that?"
20 But essentially this is your time to talk, this is
21 our time to listen. And so what I'll do is I'll ask one
22 person at a time to come up to the microphone and share with
23 us their comments, their issues, their concerns about what
24 we've proposed to do today.
25 I would ask as a ground rule that we respect
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1 whoever is at the mike and that the person come up, tell us
2 very clearly their name so that for the record we can keep
3 track of who said what and then just -- just tell us what you
4 think.
5 With that in mind, the first speaker is
6 Cynthia Babich.
7 MS. BABICH: First of all, I really appreciate everybody
8 coming here tonight. I know that these meetings aren't the
9 best opportunity for most of you who have worked all through
10 the day.
11 I'll try and make it as brief as possible, but this
12 is a very complicated situation that we're dealing with here
13 in the community, and I have taken the time to chose my words
14 very carefully. Normally, I don't read but I will read my
15 comments because I do want to make sure that they're
16 understood clearly and that there's no question on what we're
17 saying here.
18 I'm Cynthia Babich, and I'm the-director of the
19 Del Amo Action Committee, which is the community group that's
20 gotten involved here in this community due to health concerns
21 mainly. And through that involvement we're learned quite a
22 bit, and some of that I want to share with you tonight.
23 What I will tell you tonight comes two-and-a-half
24 years after researching, watching and participating with
25 State and Federal agencies working on our Superfund Site.
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1 This is a projection of what needs to be done at
2 the waste pits in the short term and in the long term. We
3 must state to these agencies and corporations what our needs
4 are, but this must be stated in the form of demand to be
5 heard clearly.
6 We are committed to following through with the work
7 that has been started by the Del Amo Action Committee. The
8 Del Amo Action Committee knows that this community supports
9 its efforts, but agencies, responsible parties and our
10 political representatives need to know this as well.
11 There are representatives here tonight of all of
12 those who have a stake in this community's future in one way
13 or another. We have been negotiating over a year now with
14 many of these stakeholders on the 204 Street buyout issues.
15 Although we may hate in our hearts for the
16 destruction many industries have caused, we do not and should
17 not hate the messenger. All warriors know the importance of
18 knowing their enemies.
19 Mr. Chuck Paine and Mr. Larry Bone is here tonight,
20 and I'd like you to please raise your hand. These are some
21 of the people responding to the problems here, and they have
22 been working very hard to come to some kind of agreement on
23 issues raised by this committee.
24 We certainly do not agree on many things, and they
25 only know if they have been successful at putting themselves
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1 into our shoes, but I can tell you that they have tried very
2 hard to understand.
3 There are many problems across our nation, and if
4 we cannot even begin to talk to each other about how to solve
5 them, then we are truly doomed.
6 The EPA as well has risen to the challenge on many
7 occa5ior.s and they have failed [sic] on some others. I am
8 telling you this so you can understand that this committee's
9 anger is not at the individual trying to make some sense of
10 this horrible situation; it is with the federal and corporate
11 policies that must be changed. This committee is tired of
12 cheap talk and we are gearing for action.
13 We have come here tonight to talk about the EPA's
14 proposals for remediating. Some think that means cleaning up
15 the Del Amo Waste Pits. It's not what remediation is to me.
16 We will talk about current conditions and future
17 conditions. We already know from previous meetings what has
18 occurred in the past to this community: exposure to toxic
19 chemicals from the waste pits and the Montrose facility as
20 well.
21 Most of us are in the mid- to low-income range.
22 Historically, it has been found that lower income communities
23 have much more than their share of toxic problems.
24 There is a trend unfolding across the country about
25 communities just like ours. Some feel the reason for this is
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1 that lower income communities are so involved in making ends
2 meet that they may not even notice that they have these added
3 dangers in their community.
4 The attitude which has caused this problem and
5 which we as a nation have been facing is called environmental
6 racism. We are engaged in a struggle for environmental
7 justice.
8 Many communities have been standing up, educating
9 themselves and fighting hard for what is theirs, should have
10 been theirs and will be theirs in the future. We cannot
11 change the past, the present we may alter, but the future we
12 hope to forge for ourselves.
13 The future of this community is very important.
14 Many of us at this time with the knowledge of toxic exposure
15 in the past and present in this community don't hold out a
16 lot of hope for most adults. Our quality of life has been
17 diminished, extensively in some cases.
18 We now look at the situation with brave hearts and
19 optimistic minds. When we look at our children, we wonder
20 what the quality of life will be for them in the future.
21 This is what we have to make sure remains protected.
22 A little boy 204 Street asked me the other day
23 where I lived, and I told him in San Pedro. I was lucky
24 enough to have been under the EPA's temporary relocation, but
25 feel torn between my community, which I dearly love, and fear
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1 of my life from continued exposure. The air is fresher where
2 I live at now, but I do not feel connected to this new
3 community.
4 I was goir.g to ask this little boy where he lived,
5 but I was afraid he might tell me, or afraid of what I might
6 have to tell him about where he lives.
7 That little boy and many other children in our
8 neighborhood represent our future. It would be disgraceful
9 to condemn them to the same feelings we now have about those
10 who have blatantly dumped on this community. We are owed
11 something for our suffering, we are owed self respect and we
12 are owed a future, which today remains uncertain.
13 When we look at the remedies for the waste pits,
14 containment or excavation, many of us from the beginning have
15 felt it should be cleaned up. We didn't put it here, we
16 didn't ask for it to be put in this community, and this
17 community was here before the Del Amo facility.
18 What many of us have come to understand is that it
19 can't be cleaned up. Trying to clean it up with current
20 technology would be mean risking our health again and risking
21 the health of the working because this stuff is so toxic, it
22 can kill people at high levels immediately, like the levels
23 that are currently in the waste pits.
24 What happens after toxins are dug up, if it can be
25 done successfully? We have read options from the EPA and it
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1 sounds as if it could be done at a cost of over $100 million.
2 What happens then?
3 It gets shipped, trucked or railed to another
4 community just like ours or to a burial site like in Nevada
5 or Arizona where they'11 dig another hole and bury it. Maybe
6 this time they'll have some concrete liner or some other kind
7 of protective measure. But it's still not being taken care
8 of, it's not being cleaned up.
9 Or if it's too toxic to bury again, this other
10 community that's like ours will more than likely have an
11 incinerator. In this incinerator, they will burn the
12 contaminated material. This will expose the community to the
13 residual burnoff. They will be exposed as well to the many
14 dangers of an accident while all these shipments are coming
15 in.
16 The Del Amo Action Committee stands in solidarity
17 with those communities, and although we don't want our toxic
18 problem, we certainly don't want to ship it off to another
19 community and cause them the same grief that we've had to
20 endure.
21 So then what is the answer? We look to our current
22 situation and we know from the limited studies that have been
23 done to date that what we have been exposed to in the past is
24 very bad.
25 We know that for at least two summers, toxic ooze
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1 has seeped up from the ground from the waste pits. The dirt
2 cover over the waste pits, which has been placed -- been in
3 place for over a decade, has worn thin, blown away in the
4 wind, and been washed away by rains.
5 We are being exposed currently. When you smell
6 rotten eggs in the area, that's hydrogen sulfide, H2S, a
7 deadly chemical that can kill you.
8 Why are we smelling it in our neighborhood? H2S is
9 one of the chemicals in the waste pits and this
10 neighborhood's closest source. We need to be protected from
11 the oozes that are occurring, from the vapors we are smelling
12 and from the eroding cap r.hat was never up to par to begin
13 with. We need to make sure this is capped as soon as
14 possible.
15 Option four, containment, which has been proposed
16 by the EPA has a venting system to burn off vapors that will
17 be volitizing [sic] off the waste pits. When past air
18 samplings were done, we were told no chemicals in the air
19 were coming from the waste pits, yet they are going to be
20 venting these vapors that will be building up under the
21 plastic liners of the cap and burn them off near the eastern
22 boundary of the waste pit area somewhere.
23 That sounds like chemicals do evaporate into our
24 air space from the waste pits.
25 Option No. 4 will also be implementing groundwater
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1 extraction. The waste pits are continually adding toxins
2 into the groundwater so future contamination to the
3 groundwater would have to be stopped at the source. These
4 pump extraction wells will be located between the waste pits
5 and the communities. They will be pumping groundwater until
6 the site is cleaned, which may be never.
7 What the committee has asked the EPA to help us do
8 is look into bioremediation options for this site.
9 Bioremediation is when organisms are introduced into a
10 contaminated environment and encouraged to feed off the
11 contamination. The more they feed, the more they reproduce
12 and the less contamination is left behind.
13 This is the committee's only hope for a clean
14 future. This is the legacy we have to leave to this
15 community and our children.
16 Will we ever be able to walk away from this, look
17 back and think we have done anything at all besides leave the
18 problem for another generation and another generation and
19 another generation?
20 We live in fear of Superfund Sites in our
21 neighborhood. We not only have one, we have two. How can we
22 have a good quality of life when our minds have been
23 poisoned?
24 A healthy mentality is very important. It helps
25 shape one's self-confidence and encourages us to stand up for
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1 ourselves by speaking out and seeking the information needed
2 to become an involved citizen.
3 We do not want to condemn our children and this
4 community to deal with the knowledge that they have deadly
5 contamination just a cap away from causing them h-\rm once
6 again.
7 . What does this teach our children? Are they not
8 good enough or important enough to live in a healthy, clean
9 environment that they don't have to worry about? Or does it
10 make them feel that they are not as important as other
11 children not dealing with this toxic neighborhood?
12 Some corporations and agencies have tried to pull
13 the wool over some of us adults as to the extent of the
14 contamination, but our children seem to know the difference.
15 They are being alerted about the environment and its dangers
16 and the dangers that have been caused and posed by the
17 industrial revolution.
18 They are trying to find ways to-secure their own
19 future. They will turn to us some day and ask us why we
20 didn't do anything. Those of you working for the
21 corporations and government entities responsible for this
22 mess and the agencies involved in the remediation can bet
23 your children will turn to you some day and ask the same
24 questions.
25 What will be the answer? "We did the best with
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1 what resources we had at the time"? "We fought real hard to
2 make sure that current exposure would be stopped"? "We stood
3 behind a cap because we did not want to send our waste to
4 other communities"?
5 Science is not advanced enough at this time to
6 clean up the many messes all over the country. More research
7 needs to be done, more research into bioremediation of this
8 particular type of contamination.
9 Some bioremediation studies have been done in 1991.
10 These studies were not very conclusive, and in 1991 it was a
11 long time ago and a lot has changed in the scientific world
12 since then.
13 Along with Option No. 4, we want resources set
14 aside for grants into bioremediation technologies. This will
15 provide funding for research on how and which organisms to
16 introduce so that one day maybe 50 or 100 years from now
17 nothing living in this neighborhood or in the near vicinity
18 will live with the threat of a Superfund Site.
19 We have all seen how the government can shut down
20 and Superfund's existence is questionable. What if there was
21 no EPA? Our site in the future could represent a now defunct
22 and failed system with nothing to stop the eroding and
23 leaching contaminants into our community once again.
24 Can we turn to our children in the future and tell
25 them that we did the best we could with what we had at the
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1 time and we stand behind the decisions we n;ade? Or will they
2 turn to us and say we didn't stand up for justice.
3 Although we did complain a little, shout a few
4 times, but ultimately we let people die. This is what will
5 happen. People have died from these toxins in the past, they
6 are dying today, and if nothing is done to see that this
7 contamination is removed, they will die in the future.
8 This is our neighborhood and this is our quality of
9 life we are talking about. The agencies out here are
10 required by law to listen to us. They know we are the people
11 who have to live with the decisions that they will ultimately
12 make for this community.
13 We have been told that the cleanup will cost
14 $100 million or more. A cap on the other hand approximately
15 costs $10 million. The estimated life span of a cap is
16 30 years, maybe longer. We're talking about replacing
17 something every 30 or 50 years. This is not a permanent
18 solution.
19 We need a solid future in this neighborhood. We
20 need to keep fighting for solutions. The money that is not
21 being spent on this clean up is a large amount. There is a
22 big difference between 10- and $100 million dollars to some
23 of us is more than we can imagine, although I can tell you
24 that $1 million would go a long ways towards solving the
25 problems in the future through bioremediation, as well as
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1 other sites with similar contamination.
2 Some day this community could again be as beautiful
3 as before the toxins came. Its residents will once again
4 feel comfortable with where they live. The children can say,
5 "We live in a community that once was contaminated with toxic
6 poison, but our community is evolving, learning and educating
7 and helping others understand that things can change."
8 Industries that have made mistakes in the past can
9 start going back to change the things that have occurred and
10 they can make a difference as well. It has begun to happen
11 here already with the many stakeholders joining in the buyout
12 discussions. But we must continue.
13 If the involved agencies, political representatives
14 and stakeholders will not stand beside this community and
15 push for bioremediation grants that need to be made
16 available, then truly you are not doing a service to this
17 community.
18 Please help us bring justice to- this community.
19 Stand tall beside us. Know that you are making changes not
20 only for the future of this community, but for the future of
21 all kinds of communities around the country.
22 If the world was only a few feet in diameter
23 floating above a field somewhere, people would come from
24 everywhere to marvel at it. People would walk around it,
25 marveling at its big pools of water, little pools and the
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1 water flowing between the pools.
2 People would marvel at the bumps on it and the
3 holes in it and they would marvel at the very thin layer of
4 gas surroundin; it and the water suspended in that gas. The
5 people would marvel at all the creatures walking arcund the
6 face of the ball and the creates in the water.
7 The people woulc declare it precious because it was
8 the only one and they woi-ld protect it so chat it would not
9 be hurt. The ball would be the greatest wonder known and
10 . people would come to behold it, to be healed, to gain
11 knowledge, to know beauty and to wonder how it could be.
12 People would love it and defend it with their lives
13 because they would know somehow that their lives, their own
14 roundness would be nothing without it.
15 Please use this meeting to once again voice your
16 concerns about car toxic environment, even if you are angry.
17 Freedom of speech is a powerful tool and we need to use it.
18 We need to -- the help of the PRPs as well. If they do not
19 want to put money aside for research, they will pressure this
20 proposal and our fight will be harder.
21 Mr. Paine and Mr. Bone, I ask you to continue to
22 try to understand our needs and help us achieve the goals we
23 have spoken of here tonight so that one day we may all be
24 proud of a job well done.
25 Please stand beside the Del Amo Action Committee
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1 and let these stakeholders know that there is no mistake that
2 our community is united and we will fight to continue to
3 achieve justice in this community. Thank you very much.
4 MR. COOPER: Thank you. Kim Simpson, please.
5 MR. SIMPSON: Hello. Can everybody hear me back there?
6 My name is Kim Simpson, and, excuse me, I represent
7 Simpson Environmental Research, a research and development
8 company that has been researching the advance of
9 environmental studies for the last 27 years.
10 This is the first opportunity I've had to address
11 the EPA on this Del Amo site. And for the EPA and for the
12 community also, I would like to propose my solution to the
13 Del Amo site.
14 Simpson Environmental Research has cleaned up toxic
15 waste dumps all through California. We have worked for the
16 Federal Environmental Research --or Federal EPA, I'm sorry,
17 and the California EPA. We have cleaned up the Azusa waste
18 site, Irwindale waste site and the San Gabriel Superfund
19 site; we have cleaned all those up.
20 We can remediate that property; not cover it up but
21 remediate it, actually take the carcinogens out of the soil
22 to below state and federal standards for not only industrial
23 use, but all the way down to residential use.
24 We can do this without breaking the topsoil of the
25 surface and releasing the hydrogen sulfide gases, which is
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1 one of the most -- one -- your biggest concern for
2 excavation, is it not, the release of the hydrogen sulfide
3 gases.
4 Now, if they were to be released on excavation,
5 they can obviously be released through a fault in the cap
6 site. Their price to put a cap.over the site is
7 approximately $9 million.
8 I propose that our company can come in and
9 remediate that site for under $4 million with an*up-front fee
10 of less than $500,000 and we are prepared to give the EPA and
11 the city a free show-and-tell under controlled situations,
12 take us to the site, show us the small parcel of land you
13 would like remediated and we will do it absolutely free to
14 show you that this not a con or a trick-and-pony show.
15 This is a brand new technology. You were talking
16 on microbiology or micro remediation, bioremediation which is
17 the use of microbes. That is very successful as far as a
18 natural remediation is concerned.
19 The problem with microbes is that it takes an
20 extremely long time for them to work and they only work in a
21 very short window. It cannot be too hot or too cold, too wet
22 or too dry. And the soil has to be completely oxygenated at
23 all times, so it is still a fairly expensive process.
24 This process that I propose is the process of
25 molecular remediation. We do not take care of the symptoms.
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1 We take care of the actual problems, which in this case are
2 your hydrocarbon and carbon hydrogen lines.
3 We remediate completely volatile organic compounds,
4 semi-volatile organic -- organic compounds. We remediate
5 benzene, which I've heard so many times tonight. We actually
6 mediate it down to nondetectable levels. We also remediate
7 lead, arsenic and a multitude of other metals and
8 contaminants.
9 Our record is available for anybody who would wish
10 to contact to see what we have done. We have an extensive
11 list of sites we have remediated, and in the last
12 three months the Federal EPA contacted our company to bid on
13 the remediation of New York Harbor.
14 They have tested our remediation, they believe in
15 it, and they are currently using it. So I ask the public,
16 please, before any decision is made, please at least consider
17 to remediate the land before you put the Band-aid over it.
18 Thank you very much.
19 MR. SPEAKER: How long?
20 MR. SIMPSON: I'm sorry. Excavation you said would take
21 five years, the capping is indefinite. We will completely
22 remediate that site within six months, six months. That is a
23 guarantee.
24 Our up-front cost, as I promised, is less than
25 $500,000. And we will design a contract that states that no
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1 other money is to be paid to us until the EPA receives their
2 test levels back and we come in below the -- excuse me - -
3 I've got extremely dry mouth up here, I'm sorry -- below the
4 levels that you deem necessary. Thank you.
5 MS. BABICH: I have some questions.
6 MR. SIMPSON: Yes, ma'am.
7 MS. BABICH: Scrry. I'll be real quick.
8 MR. SIMPSON: Yes, ma'am.
9 MS. BABICH: Hov did you come upon this meeting tonight?
10 MR. SIMPSON: Through America On Line.. AOL. It's taken
11 me quite a long time to decipher how the EPA puts information
12 on the AOL, but through approximately four months of research
13 and working in AOL, America On Line, we have found where we
14 can finally get in here and put our proposals in before any
15 decisions are made.
16 MS. BABICH: I'd like to know if the EPA has any
17 comments on -- this quite sounds, you know, like some pretty
18 good razzle-dazzle here. I'm ready to buy.
19 So what do you guys think?
20 MS. SPEAKER: I like it.
21 MS. BABICH: How come this is just coming up now, and is
22 this something that can be put in perspective here for the
23 community.
24 MR. MONTGOMERY: I mean, this is actually a comment
25 period. I mean, I think I'd like to talk with you
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1 afterwards. I -- you didn't -- you didn't make it clear as
2 to whether or not your particular technology would require
3 excavation.
4 MR. SIMPSON: Absolutely not. Our technology does not
5 require disturbing the landfill at all. We work in a -- a
6 medium of percolation. We put our product in a water truck,
7 we saturate the land, let it percolate down, and for the
8 levels of deep contamination, we use the wells that have
9 already been dug.
10 MR. DHONT: Are you aware that we're not dealing with
11 soils here but a monolithic and viscus and non- -- relatively
12 non-porous set of waste that would not accept percolation.
13 MR. SIMPSON: We're dealing with contamination of the
14 soil.
15 MR. DHONT: We're not dealing with soil here, sir.
16 MR. SIMPSON: We will clean up the contaminated waste
17 and the sludge. We have done it. I have a list here of
18 places we have done it for. Again, the San Gabriel Superfund
19 Site in '93.
20 MR. DHONT: Sir, all superfund sites are different.
21 This is a site with --
22 MR. SIMPSON: I've researched, I've found out --
23 MR. DHONT: -- with waste --
24 MR. SIMPSON: -- what the contaminants are, sir. I
25 would not be here if I thought I was wasting my time.
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1 MR. DHONT: If we had a monolithic -- if we had soil in
2 this instance, we might be proposing a very different remedy.
3 We do not have soil.
4 MR. SIMPSON: I would not be here if I did not think we
5 could remediate this situation. Again, I reiterate, we do
6 not expect to be paid other than the up-front money until the
7 control levels have been met.
8 And once again I reiterate we are willing to give a
9 free show to the EPA, controlled. You show us the land you
10 want remediated. We won't do the whole site. We'll give you
11 up to eight, nine cubic yards.
12 You control the situation; you control the test
13 site; we'll do it for you for absolutely nothing. And if I
14 thought I was wasting my time, I would not be offering this
15 for free.
16 Thank you very much, gentlemen. Thank you for your
17 patience and time.
18 MR. COOPER: Again, in the interest of time for everyone
19 who has waited to -- to be able to speak, the next person on
20 the list is Chuck Paine. You're welcome to just use the --
21 the microphone there if you'd like. Or you can come up here.
22 MS. BABICH: He has to come up here, too. He doesn't
23 want his back turned to people. He doesn't trust us that
24 much.
25 MR. PAINE: I'll try to be brief.
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1 My name is Chuck Paine. I work for Shell Chemicals
2 Health Safety and Environmental organization. I'm also the
3 project coordinator for the Del Amo site respondents.
4 The proposed plan that the EPA has- issued and we've
5 been discussing today is comprehensive, it's informative, and
6 I believe balanced. The amount of -- the -- it's the result
7 of a significant amount of effort on the part of the agency
8 to try to move forward a solution at the Del Amo site.
9 The Del Amo respondents stand ready to work with
10 the EPA to further define, develop and implement a cost
11 effective remedy that is protective of human health and the
12 environment as easily may -- implement it and maintain.
13 We also stand ready to continue to work with the
14 community in -- in working towards a future land use that is
15 truly of benefit to the community.
16 When we look at the -- the alternatives that have
17 been presented, Alternative 4 is desirable over excavation.
18 When you look at the cap and the SVE, the-cap will cut off
19 emissions, cut off dust, and effectively cut off any kind of
20 contact with the waste, solve vapor extraction, will be
21 protective of groundwater.
22 I do give support and thanks to the EPA for the
23 effort that they have done here, and look forward to working
24 with everybody in the future. Thanks.
25 MR. COOPER: Robert Evans, whichever mike you would like
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1 to use.
2 MR. EVANS: Nobody else is using it.
3 MR. COOPER: Okay.
4 MR. EVANS: I don't really need a mike.
5 Yes. I do not agree with covering up, but I also
6 don't agree with excavating, because I know if they excavate,
7 it will put everyone that lives in my neighborhood at risk.
8 And what was jus- offered somehow seems too good to
9 be true. I would definitely like to be there when you do
10 this just for my own peace of mind.
11 I would like for the EPA to investigate your
12 method, Mr. Simpson, of how to do this remediation without
13 disturbing the soil and digging it up and neutralizing it. I
14 do not believe at all that it should be left alone.
15 I would like to know if you can address the
16 groundwater problem, and that would be definitely something
17 to pursue, I think.
18 I would like to thank Cindy for your hard-hitting
19 action because without it, well, we'd all be rotting in toxic
20 waste.
21 So that's all I got to say. Thank you everybody.
22 MR. COOPER: I have the strong feeling that there are
23 others who would like to come forward and make public
24 comments. That was the list that I had, so if anyone else --
25 I think, Dunian [ph] , you had some comments you wanted to
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1 make, and you'll probably want to use my mike. Okay. Fine.
2 MS. PONCE: I would like to thank Cynthia, the PRPs, and
3 the EPA and the whole community for sticking together for
4 this whole three years that we've been working on this toxic
5 problem.
6 I would also like to remind the agencies that the
7 problem doesn't end at half of 204 Street; that we are
8 working hard towards negotiation of buyout of half of -- of
9 half of the neighborhood of 204th Street. But that is not
10 the end.
11 And we do hope the rest of the community to be out
12 because there are other toxic problems, and we're only
13 addressing a small portion of the problems on the
14 neighborhood. And there is a lot --a lot of more people
15 that is going to be left behind suffering and being
16 contaminated, arid we'd like to see them out as well.
17 So I just wanted to remind everybody not to forget
18 that, that there is another half of the neighborhood that
19 needs to be worked on and we're not going to forget them.
20 MR. COOPER: Was there someone else?
21 I'd like to again remind folks that the -- the
22 period for public comment runs through the 13th of February,
23 and so thoughts that might occur to you later, questions that
24 you may have later, you're certainly welcome to contact
25 either Dante Rodriguez or Jeff Dhont or myself, David Cooper.
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1 We'd be happy to work with you to answer any
2 questions that you have or you can just -- you can mail your
3 comments in.
4 Just as a final note, for those people who did not
5 sign it, we would appreciate knowing who attended so we can
6 keep track of that. And you're certainly welcome to any of
7 the material.
8 And, again, the end use work group that the Del Amo
9 Action Committee has asked EPA to coordinate, that's the
10 sign-in roster at the far end of the table.
11 MS. BABICH: With the red writing on it.
12 MR. COOPER: With the red writing on it.
13 MR. DHONT: David, we'll be available for questions.
14 MR. COOPER: And all of the EPA folks will be available
15 for questions after this meeting.
16 I also want to remind you that Bill Nelson of ATSDR
17 will be available to discuss any of the health issues and
18 concerns that you folks have, and he'll be sitting at the
19 table just outside the doors.
20 Mike, did you have a comment? You look midway
21 through a thought.
22 Ma'am?
23 MS. SPEAKER: I have a comment. Mike just said no, he
24 didn't. But I think it would be a good idea since he does
25 have samples of what cap material does look like, so the
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1 people that do not know what it looks like ... they should
2 know that he does have a couple of samples of all the types.
3 MR. COOPER: The re- -- the reminder is that
4 Mike Montgomery, who's holding up the yellow envelope, has
5 actual samples of some of the material that could be used in
6 a construction of a multi-layer cap for the Del Amo Waste
7 Pits, so you may want to talk to him about that.
8 MS. BABICH: Can you explain the process for an
9 extension on the comment period in case some people feel like
10 they need to do more research.
11 MR. COOPER: You provide to -- the question was an
12 extension to the comment period, if more time is needed to
13 review the documents that are available, particularly -- and
14 I should mention this.
15 There are two libraries that contain the full
16 administrative record for -- which was the basis of the
17 proposal that you heard tonight. That's the Torrance Library
18 that's in this complex area, as well as the -- the Carson
19 Library. So if you have additional questions beyond what is
20 answered in the --in the fact sheet, you're certainly
21 welcome to go there and -- and review the material in
22 general.
23 Anyway, the -- the process would be to simply
24 submit a letter to EPA making a request and explaining why.
25 That letter should be addressed to Dante Rodriguez, and for
Fox Reporting, Inc.
(213) 688-9464
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1 those folks who wan- Dante's address, if you will pick up one
2 of the comment forms that look like this, Dante's address is
3 or. the back as part of the -- the reply. So that -- that's
4 what you need to do.
5 If there are no other comments at this time, I'd
6 like to say thank you, all of you. There's -- there's almost
7 80 people I think that I counted here tonight. Thank you all
8 for coming and staying through the -- through this entire
9 process. We appreciate your comments.
10 Many of you are very, very well thought out and
11 very good comments and questions about our proposal. We
12 certainly have a lot to think about and we hope to talk to
13 you again about this. Thank you.
14 MS. BABICH: Thanks for coming.
15
16 (Proceedings concluded.)
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Fox Reporting, Inc.
(213) 688-9464
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1
2
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4 CERTIFICATION
5
6 I, MARIE FOX, do hereby certify that the foregoing
7 26 pages comprise a true and correct transcription of the
8 taped proceedings had in the matter of EPA Del Amo Proposed
9 Superfund Site, at the EPA Public Meeting held Wednesday,
10 January 29, 1997.
11 I hereby certify that I have caused said
12 proceedings to be transcribed and that the foregoing is a
13 full, true and correct transcript of said proceedings; that I
14 am neither counsel for nor related to any party to said
15 hearing, nor in anywise interested in the outcome thereof.
16 Dated this 10th day of March, 1997.
17
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20 ,
Transcriber
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Fox Reporting, Inc.
(213) 688-9464
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FROM'OMNIFfiX
TO:
415 744 2180
SEP 5. 1997 i:36Pf1 8243 P. 02
SFUND RECORDS CTR
0639-01335
4
CaltZEA
Dijjfintent of
Toxic Substances
Control
245 West Broadway.
Suite 350
Long Beach. CA
90802-4444
September 5, 1997
Mr. John Kemmerer, Branch Chief
Site Cleanup Branch
U.S. Environmental Protection Agency
Region IX
Mail Code SFD-7
75 Hawthorne Street
San Francisco, California 94105
Dear Mr. Kemmerer,
RECORD OF DECISION, DEL AMO SITE, WASTE PIT AREA
The Department of Toxic Substances Control (DTSC) hae
reviewed the Record of Decision (ROD) and Response Summary
for the Del Amo Waste Pit Operable Unit. Our review reveals
that DTSC's comments of December 11, 1996, to the
Feasibility Study Report, and the State Applicable or
Relevant and Appropriate Requirements (ARARs) have been
adequately addressed. However, due to the unique nature of
splitting the Del Amo site into several operable units some
state ARARs have been deferred until subsequent RODs for
those operable units are completed.
DTSC concurs with U.S. Environmental Protection
Agency's selected remedy Number 4, a Resource Conservation
Recovery Act (RCRA) equivalent cap and a Soil Vapor
Extraction System. The RCRA cap consists of multiple
layers, including a vegetative cover, a marker bed, a
drainage layer, a low-permeability layer, a gas collection
layer, and a grading layer. The Soil Vapor Extraction
System will be applied to the soil under the pits, with soil
gas monitoring probes surrounding the pits.
If you have any questions regarding this letter please
contact Mr. Haissam Salloum, at (562) 590-4916.
Sincerely,
Pete Wilson
Governor
James M. Strock
Secrilaryfor
Environmental
Protection
Nennet V. Alvarez, Branch Chief
Site Mitigation Cleanup Operations
Southern California Branch B
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the waste pits and is currently present in the vadose zone soils.
The major components of the selected remedy for this action include:
- Placement of a RCRA-equivalent cap over the Waste Pits Area as described in this
ROD and associated soil gas monitoring;
- Installation of surface water controls to prevent ponding of water on the cap and to
prevent runoff onto adjacent properties;
- Installation and operation of a soil vapor extraction system (SVE) beneath the Waste
Pits Area to achieve the interim soil remediation standards established in this ROD;
- Installation of security fencing around the treatment units associated with the cap and
SVE systems;
- Implementation of deed restrictions prohibiting future residential use of the Waste Pit
Area and prohibiting any future use of the Waste Pits Area that could threaten the
integrity of the RCRA equivalent cap;
- Long-term operation and maintenance of all of the above and related components of
the remedy selected in this ROD.
1.5 Statutory Determinations
The selected remedy is protective of human health and the environment, complies with
federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum extent practicable. Components
of the selected final remedy satisfy the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining on-Site above health-based
levels, a review will be conducted at least once every five years after commencement of the remedial action
to ensure that the remedy continues to provide adequate protection of public health or welfare or the
environment.
1.6 Signature
Keith A. Takata, Director DATE
Superfund Division
U.S. Environmental Protection Aeencv. Reeion IX
u.a. B/r/\
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