United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-88/023
February 1988 ,
$EPA
Superfund
Record of Decision
Lorentz Barrel & Drum, CA
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30273-101
REPORT DOCUMENTATION
PAGE
EPA/ROD/R09-88/023
4. Tttlt and Subtitle
SUPERFUND RECORD OF DECISION
rentz Barrel & Drum, CA
smedial Action
7. Authors)
3. Recipient's Accession No.
S. Report Oete
09/25/88
8. Performing Orianizetion Rept. No.
tddress
10. Projeet/Task/Work Unit No.
11. Contract(C) or Grent(G) No.
(C)
(C)
12. Sponsoring Organization Nam* end Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
"t
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words) ~~ ' •
The 5.4-acre Lorentz Barrel & Drum (LB&D) site is located in San Jose, California,
about 0.25 mile from San Jose State University. The site lies directly above a major
source of potable ground water in the south San Francisco Bay area, with three public
water supply well fields within one mile of the site. In 1947 the Lorentz family began
a drum recycling operation on 10.5 acres of land at the site. Currently, 4.5 acres are
Capped with tar and gravel but contains stored drums, 0.75 acre includes the
Ireconditioning facilities. Drums containing residual aqueous wastes, organic solvents,
acids, oxidizers, caustic residues and oils were received for recycling. During the
early years of operation, portions of the site were also leased to other companies.
Between 1950 and 1978 a drainage ditch north of the drum processing building carried
process wastes to a large sump and other ponding areas onsite. Prior to 1968 wastes
from the sump were discharged to a storm drain system. Sometime between 1968 and 1971
the discharge was diverted to a sanitary sewer, and investigations indicate that this
discharge occurred until 1984. After this time, liquid wastes were evaporated, drummed
and disposed of as hazardous waste along with incinerator ash, residual liquids, and
sludge. Subsequent surface runoff was collected and recycled in the hot caustic drum
wash. Since 1981 several investigations have revealed soil and ground water
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Lorentz Barrel & Drum, CA
First Remedial Action
Contaminated Media: gw, soil
Key Contaminants: metals (arsenic, nickel), organics (PCBs, pesticides), VOCs (benzene,
b. Identlfiers/Open-Ended Terms PCE , TCE)
c. COSATI Field/Group
Availability Statement
(See ANSI-Z39.18)
19. Security Class (This Report)
None
20. Security Class (This Page)
None
See Instructions on Reverse
21. No. of Pages
119
22. Price
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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16. Abstract. Include a brief (200 words or lesa) factual summary of the most significant information contained in the report. If the
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17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.
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: :~H3 : - 331-5:5 (3393) OPTIONAL FORM Z72 BACK (*-77>
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JPA/ROD/R09-88/023
A>rentz Barrel & Drum, CA
Tirst Remedial Action
16. ABSTRACT (continued)
contaminated with numerous metals, organics, and PCBs. Removal of drums, stored
hazardous materials, and highly contaminated soil has been conducted at the site. This
remedial action will address the offsite contaminated shallow ground water. Onsite
contaminated soil and additional shallow and deep ground water remediation will be
addressed in a subsequent remedial action. The primary contaminants of concern affecting
soil and ground water are VOCs, including benzene, PCE and TCE, other organics including
PCBs and pesticides, and metals including arsenic and nickel.
The selected Expedited Response Action for this site includes: onsite ground water
pump and treatment using ozone/UV for organic removal and ion exchange for nickel
removal, with discharge of treated water to a local creek. The estimated present worth
cost for this remedy is $3,238,000 with annual O&M costs of $198,000.
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LORENTZ BARREL & DRUM
ENGINEERING EVALUATION/COST ANALYSIS
RECORD OF DECISION
PART 1 - DECLARATION
PART 2 - DECISION SUMMARY
PART 3 - RESPONSIVENESS SUMMARY
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0000231
LORENTZ BARREL & DRUM
ENGINEERING EVALUATION/COST ANALYSIS
RECORD OF DECISION
PART 1
DECLARATION
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0000231
RECORD OF DECISION
DECLARATION
Statutory Preference for treatment as a principal element is
met.
SITE NAME AND LOCATION
Lorentz Barrel & Drum
San Jose, California
STATEMENT OF BASIS AND PURPOSE
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0000231
o construction and operation of a groundwater treatment
system; and
o disposal of treated groundwater to the storm sewer,
from which it flows to Coyote Creek.
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and state requirements that are
applicable or relevant and appropriate to the remedial action,
and is cost effective. This remedy satisfies the statutory
preference for remedies that reduce tozicity, mobility, and/or
volume as a principal element. It also utilizes permanent
solutions to the maximum extent practicable. The applicability
of the 5-year facility review provision will be determined
after the RI/FS is completed.
. 2.1.96
Date Signature (DRA)
Signature (AA/RA)
1-2
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00002U1
Lorentz Barrel and Drum
RECORD OF DECISION
Concurrence — Superfund Program
14-1 SP
Mary Rasters / ' / Date
Remedial Project Manager
South Bay Section (T-4-5) *
Amy zimpfer / / Date
Chief
South Bay Section (T-4-5)
Phil Bobel / 'Date
Chief
Superfund Remedial Branch (T-4-A)
*/»/#
Date
ssistant Director for Superfund
Toxics and Waste Management Division (T-4)
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Lorentz Barrel and Drum
RECORD OF DECISION
Concurrence — Toxics and Management Division
0000231
Jeff Zelikson Date
Director .
Toxics and Waste Management Division
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0000231
Lorentz Barrel and Drum
RECORD OF DECISION
Concurrence — Water Management Division
Harry Seraydarian Date
birect.or
Water Management Division
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0000231
Lorentz Barrel and Drum
RECORD OF DECISION
Concurrence — Office of Policy and Management
Nora McGee (Date
Director
Office of Policy and Management
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Lorentz Barrel and Drum
RECORD OF DECISION
Concurrence — Office of Regional Counsel
7l(
.\\ tX'-^C,.
Nancy MarVel Date
Regional Counsel
Office of Regional Counsel
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0000231
Lorentz Barrel and Drum
RECORD OF DECISION
Concurrence — Air Management Division
y^Dave Howekamp
Director
Air Management Division (A-l)
ate
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0000231
LORENTZ BARREL & DRUM
ENGINEERING EVALUATION/COST ANALYSIS
RECORD OF DECISION
PART 2
DECISION SUMMARY
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0000231
LORENTZ BARREL & DRUM
ENGINEERING EVALUATION/COST ANALYSIS RECORD OF DECISION
DECISION SUMMARY
TABLE OF CONTENTS
\
SECTION PAGE
1.0 SITE LOCATION AND DESCRIPTION 1-1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.1 HISTORY OF SITE ACTIVITIES 2-1
2.2 HISTORY OF SITE INVESTIGATIONS 2-1
2.3 HISTORY OF ENFORCEMENT ACTIONS 2-2
3.0 COMMUNITY RELATIONS HISTORY 3-1
4.0 SCOPE OF RESPONSE ACTION 4-1
4.1 OBJECTIVES OF RESPONSE ACTION 4-1
4.2 RELEVANCE TO SITE REMEDIATION STRATEGY . . . 4-2
5.0 SITE CHARACTERISTICS 5-1
5.1 PREVIOUS INVESTIGATIONS 5-1
5.2 SOURCES OF CONTAMINATION 5-5
5.3 NATURE AND EXTENT OF CONTAMINATION IN THE
SHALLOW AQUIFER 5-13
5.4 HUMAN AND ENVIRONMENTAL EXPOSURE PATHWAYS . . 5-21
6.0 SUMMARY OF SITE RISKS 6-1
6.1 CONTAMINANTS OF CONCERN 6-1
6.2 EXPOSURE ASSESSMENTS 6-1
6.3 RISK CHARACTERIZATION 6-4
7.0 DOCUMENTATION OF SIGNIFICANT CHANGES 7-1
8.0 DESCRIPTION OF SHALLOW AQUIFER TREATMENT AND
DISPOSAL ALTERNATIVES 8-1
8.1 APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS 8-1
8.2 TREATMENT TECHNOLOGIES 8-4
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0000231
TABLE OF CONTENTS (Continued)
SECTION PAGE
9.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF
ALTERNATIVES 9-1
9.1 COMPARISON OF EE/CA VAND FS GUIDANCE
CRITERIA 9-1
9.2 .COMPARISON EVALUATION METHODOLOGY 9-1
9.3 COMPARISON OF ALTERNATIVES 9-5
9.4 TREATED EFFLUENT DISPOSAL 9-7
10.0 THE SELECTED REMEDY 10-1
11.0 STATUTORY DETERMINATIONS 11-1
11.1 PROTECTIVENESS OF HUMAN HEALTH AND THE
ENVIRONMENT 11-1
11.2 ATTAINMENT OF APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS 11-1
11.3 COST EFFECTIVENESS 11-1
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND
ALTERNATIVE TREATMENT TECHNOLOGIES TO
THE MAXIMUM EXTENT PRACTICABLE , 11-2
11.5 PREFERENCE FOR TREATMENT THAT REDUCES ' .
TOXICITY, MOBILITY AND VOLUME AS A
PRINCIPAL ELEMENT 11-2
12.0 REFERENCES 12-1
ii
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TABLE
0000231 '
LIST OF TABLES
PAGE
5-1 PREVIOUS INVESTIGATIONS 5-6
5-2 GROUNDWATER INVESTIGATIONS 5-12
5-3 SUMMARY OF MONITORING WELL DATA 5-14
5-4 SUMMARY OF HIGHEST DETECTED CONTAMINANT LEVELS . 5-18
5-5 RESULTS OF TRC GROUNDWATER ANALYSES 5-19
6-1 CONTAMINANTS OF CONCERN IN THE SHALLOW
GROUNDWATER AT LB&D 6-2
6-2 CANCER RISK FROM GROUNDWATER INGESTION:
WORST CASE SCENARIO 6-5
6-3 INHALATION DOSES, CANCER POTENCY ESTIMATES,
AND LIFETIME CANCER RISK FOR UNCONTROLLED
AIR STRIPPER EMISSIONS 6-6
8-1 FEDERAL AND STATE OF CALIFORNIA REGULATORY,
ADVISORY, AND ACTION LEVELS FOR ANALYTES
IN GROUNDWATER 8-2
8-2 SHALLOW GROUNDWATER CLEANUP OBJECTIVES 8-5
8-3 SUMMARY OF COSTS FOR TREATMENT ALTERNATIVES ... 8-9
9-1 TECHNOLOGY SELECTION CRITERIA 9-2
9-2 , COMPARISON OF ALTERNATIVES 9-6
10-1 ESTIMATED (-30%, +50%) COSTS FOR OZONE/UV
TREATMENT ALTERNATIVE 10-3
LIST OF FIGURES
FIGURE
1-1 SITE LOCATION MAP
1-2 GENERAL MAP OF SITE VICINITY ;
1-3 SITE FACILITIES
2-1 LOCATIONS OF PREVIOUS SOIL EXCAVATIONS . . ,
5-1 GENERAL GEOLOGIC CROSS-SECTION
5-2 FORMER MONITORING WELL LOCATIONS
5-3 APPROXIMATE EXTENT OF CONTAMINATION
6-1 CONCEPTUAL EXPOSURE MODEL - SHALLOW
GROUNDWATER CONTAMINATION . . ,
8-1 PROPOSED EXTRACTION WELL FIELDS .......
8-2 FLOW DIAGRAM FOR LIQUID PHASE GAG TREATMENT .
8-3 FLOW DIAGRAM FOR GAG/AIR STRIPPING TREATMENT
8-4 FLOW DIAGRAM FOR OZONE/UV/GAC TREATMENT
SYSTEM
Paoe
1-2
1-3
1-5
2-3
5-2
5-4
5-20
6-3
8-7
8-10
8-12
8-14
iii
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0000231
1.0 SITE LOCATION AND DESCRIPTION
The Lorentz Barrel & Drum (LBSJD) site is located at 1515 South
Tenth Street, on the southwest corner of the intersection of
East Alma Avenue and South Tenth Street in the southern portion
of the City of San Jose, Santa Clara County, California
(Figure 1-1). A land use map of the site and vicinity is shown
in Figure 1-2.
\
The residential district to the north and east of the LB&D site
includes .Spartan Field (San Jose State University football
stadium), San Jose Bees Stadium (City of San Jose), and San
Jose State University recreation fields. The closest housing
to the site consists of San Jose State University student
housing, roughly 1/4 mile north of the site.
Topography of the site is nearly level, with a slight slope
from the southwest corner to the northeast corner. The highest
elevation at the southwest corner is 106 feet and the lowest
point at the northeast corner is 102 feet above sea level.
The site is located in the southeastern corner of the San Jose
subarea as defined by The California Department of Water
Resources (DWR, 1967). This subarea is one of the most
important natural source of groundwater in the south San
Francisco Bay area ("south bay"). The deep aquifer (250 to 400
feet below ground surface) is a major source of potable
groundwater, from which it is estimated that Santa Clara Valley
extracts 107,000 acre-feet per year. Three public water supply
well fields (owned by San Jose Water Company), located at the
12th Street, Cottage Grove, and Needles Stations, are within
1 mile of the site. A San Jose State University well is
located at the Spartan Stadium.
The major surface water stream in the vicinity is Coyote
Creek. It is less than 1/2 mile from the site, toward the
northeast. Coyote Creek perennial flows are regulated by
Coyote and Anderson reservoirs, which are controlled by the
Santa Clara Valley Water District.
At the time drum processing operations started in 1947, the
site included 10 1/2 acres of land. The current site is
L-shaped and covers 5 1/4 acres of which approximately 4 1/2
acres are capped with tar and gravel. The area that is now
sealed was used for drum storage and covers sections of soil
which were discolored and possibly contaminated.
II-l-l
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0000231
Spartan
Stadium
San Jose
Muni Baseoall
Stadium
CURRDJT LBtD
LORENTZ BARREL
& DRUM SITE
FIGURE 1-1
SITE LOCATION
LORENTZ BARREL fc DRUM
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l^&H'i
V^ ':$,.'%*{**•&*>'*' -\
«^,A':§fe:y ^^' V ' \ ::r"
220O
LEGrEND
K RE5IDEMT/AL
27OO
6 COMMERCIAL
KA 56HOOL6, 6rOK.T$ COMPLEX,
O
o
FIGURE 1-2
GENERAL MAP OF SITE
VICINITY
LORENTZ BARREL ( DRUM
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0000231
The remaining 3/4 acre includes five buildings which housed the
drum reconditioning facilities. Two sumps and one open storage
bin adjacent to the facility have held liquid and sludge. The
facilities show signs of extended use with minimal upkeep, as
evidenced by eroded concrete, rusted metal structures, and
conduits in various stages of disrepair. Figure 1-3 shows the
locations of the onsite facilities.
II-1-4
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0000231
Pacific Sandblast Property
~\
EAST ALMA AVENUE
Western Pacific
Railroad Easement
M947, 0.4 acres)
Arata Prooerty
(1981, 1.34 acres)
r
e
LJ
Present Lorentz
Barrel & Drum Site
(19B8. 5.25 acres)
Norton/Phelps Property
(1950. 3.4 acres)
100
200
LEGEND
1 Treatment Facility
2 Processing Facility
•* Former location of
•* Lorentz residence
4 Incinerator
5 Shop and Bathrooma
6 Storaga Facility
7 Warehouse and Office
8 Former Sump
9 Existing Sump
Excavations
SCALE IN FEET
FIGURE 1-3
SITE FACILITIES
LORENTZ BARREL & DRUM
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0000231
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 HISTORY OF SITE ACTIVITIES
The Lorentz family started recycling drums at the site in
1947. During the early years, portions of the site were also
rented or leased to other companies. Several facilities were
in operation around 1954, including an autowrecker, a junkyard,
a roofing company, a construction company, and sandblasting
services.
Drums for' recycling were received from both private and public
sources throughout California and Nevada. Private sources
included over 800 different companies, representing chemical,
food, health care, electronics, paint, ink, and paper
industries. Public sources included military bases, research
laboratories, and county agencies. Drums arrived at the site
containing residual aqueous wastes, organic solvents, acids,
ozidizers, and oils. (Under current law, drums sent to a
recycling facility can contain no more than 1 inch of residual
material.) Lorentz Barrel & Drum (LB&D) also received
polyethylene carboys or drums containing caustic residues.
From the 1950s until some time between 1976 and 1978, a
drainage ditch (which probably drained processing waste)
existed north of the processing structure (buildings 1 and 2 in
Figure 1-3). The northeastern corner of the site had a large
sump (30 feet by 80 feet) from the 1950s through the late
1970s. Aerial photographs of the area revealed the presence of
liquids in the sump, drainage ditch, and various ponded areas
during this period of time. The sump appeared to have been
filled in with soil prior to 1980.
Research into San Jose City records has shown that prior to
1968, the waste stream from the drum recycling processes flowed
from the processing structure, through the drainage ditch, to
the large sump in the northeast corner of the site. It was
then discharged to the storm drain system. Between 1968 and
1971 the discharge was diverted to the sanitary sewer.
Previous investigations have indicated that discharge to the
sanitary sewer ceased in 1983 or 1984. After 1984, liquid
wastes were reportedly reduced in volume by evaporation,
drummed and disposed of as hazardous waste along with
incinerator ash, residual liquids, and sludge. Surface runoff
was reportedly collected and recycled in the hot caustic wash
cycle of the drum recycling process.
2.2 HISTORY OF SITE INVESTIGATIONS
Since 1981 there have been several environmental sampling
studies at the LB&D site aimed at investigating the extent and
nature of contamination. The California Department of Health
II-2-1
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0000231
Services (DHS), their consultants and various consultants to
LB&D have collected soil and groundwater samples from onsite
and offsite monitoring wells. On six occasions, groundwater or
soil samples were taken from the site. Numerous metals,
organics, and polychlorinated biphenyls (PCBs) were found above
Total Threshold Limit Concentrations (TTLC). Sampling results
from these efforts are summarized in Section 5.0 of this
Decision Summary.
\
2.3 HISTORY OF ENFORCEMENT ACTIONS
Since 1966, there have been many regulatory actions at the LB&D
site. A complete chronological list of enforcement events is
given in Appendix 8 of the Engineering Evaluation and Cost
Analysis (EE/CA) (Ebasco, May 1988).
In summary, the major enforcement episodes have been:
o 1982 - The DHS investigated soil contamination,
resulting in a Remedial Action Order in 1987.
o 1982 - The Regional Water Quality Control Board
(RWQCB) investigated groundwater contamination,
resulting in Clean Up & Abatement Order No. 86-001.
o 1984 - The United States Environmental Protection
Agency (EPA) formally proposed LB&D as a candidate for
the National Priority List.
o 1987 - The LB&D facility ceased operation due to a
temporary restraining order from DHS. The EPA assumed
the lead agency responsibility for the site
remediation.
o Since 1984, several parties have excavated known "hot
spots" of contaminated soil from the sump areas.
These include three contractors hired by LB&D, as well
as a DHS contractor (Canonie Environmental).
Excavated areas are shown in Figure 2-1.
o In December 1987, EPA initiated an Expedited Response
Action (ERA)/Operable Unit for the shallow groundwater
plume extending northward from the site. The EE/CA
recommended extraction of the groundwater, followed by
treatment and disposal to the storm sewer.
Other agencies which have cited LB&D for some type of violation
include:
o California Department of Fish & Game (CDFG);
o San Jose/Santa Clara Water Pollution Control Plant;
II-2-2
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0000231
Pacific Sandblast Property
EAST ALMA AVENUE
Arata Property
(1981. 1.34 acres)
Present Lorentz
Barrel & Drum Site
H988, 5.25 acres)
_|_ Norton/Phelps Property
(1950, 3.4 acres)
Western Pacific
Railroad Easement
(1947. 0.4 acres)
LEGEND
2|
3
4
1—84
Excavation depth 2.0 leet.
CONSERVTECH 3-85
Excavation depth 2.0 feet.
REED CORPORATION 6-85
Excavation depth ?
CAN ON IE 10-87
Eicavation depth 4-12 feet.
100
=±=
SCALE IN FEET
FIGURE 2-1
LOCATIONS OF PREVIOUS
SOIL EXCAVATIONS
LORENTZ BARREL & DRUM
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000(1201
o California Department of Occupational Safety & Health
(OSHA);
o San Jose Fire Department; and
o Santa Clara District Attorney's Office (Civil and
Criminal Proceedings).
II-2-4
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0000231
3.0 COMMUNITY RELATIONS HISTORY
A history of the community relations activities at the Lorentz
Barrel & Drum (LB&D) site, the background on community
involvement and concerns, and specific comments and responses
on the Engineering Evaluation and Cost Analysis (EE/CA) are
summarized in the Responsiveness Summary (Part 3) of this
Record of Decision (ROD). .
II-3-1
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0000231
4.0 SCOPE OF RESPONSE ACTION
4.1 OBJECTIVES OF RESPONSE ACTION
This Expedited Response Action (ERA)/Operable Unit will address
the three principal hazards posed by the contaminated shallow
aquifer. These hazards are: further migration of the plume;
potential plume discharge into Coyote Creek; and potential
contamination of the drinking-water supply (deep aquifer). The
United States Environmental Protection Agency (EPA) believes
that the .drinking water supply is potentially at risk, and
action should not be delayed until the Remedial
Investigation/Feasibility Study (RI/FS) process is completed.
4.1.1 Plume Migration
A groundwater extraction system is proposed in order to prevent
existing contamination in the shallow aquifers from migrating
deeper and farther from the site. The groundwater extraction
system will consist of a series of linear well fields. Each
row of extraction wells, pumped simultaneously, will create a
trough in the water table beyond which groundwater should not
flow. Final design of the extraction system will be based upon
data obtained during the RI (which has already been initiated)
concerning aquifer yield and water quality parameters which can
affect system hydraulics (e.g., hardness) and effluent
limitations (e.g., nickel).
4.1.2 Plume Discharge to Covote Creek
Existing data suggest that portions of the shallow aquifer are
hydraulically connected with (i.e., discharge to) Coyote
Creek. As a result, contamination in the shallow aquifer may
lead to Coyote Creek contamination, posing a threat to aquatic
life and human populations (via fish or shellfish ingestion or
dermal contact). The proposed extraction system will attempt
to retard north and northeasterly migration of the plumes
toward Coyote Creek, thus preempting such a threat.
4.1.3 Contamination of the Drinking Water Supply
The San Jose Water Company relies on water contained in the
deep aquifer underlying the contaminated aquifer.
Contamination of the deep aquifer could eventually occur as the
result of discontinuities in the 50-foot aquitard, either
natural or as created around abandoned private supply wells
located within the plume areas (see Chapter 5.0 for a more
detailed discussion of the area's groundwater regime). In
June, five San Jose Water Company municipal wells were
sampled. The analytical data are not yet available, but those
II-4-1
-------
wells will be sampled again during the RI, and results will be
presented in RI report. To date, no contamination has been
found in the San Jose Water Company municipal wells.
The proposed extraction and treatment system will remove
contaminated water from the shallow aquifer and control
continued lateral and/or vertical spreading of the plume.
These actions will greatly, reduce the possibility of
contamination of potable water supplies.
4.2 RELEVANCE TO SITE REMEDIATION STRATEGY
The remedial actions taken to date have been aimed at reducing
or stabilizing further infiltration of contaminants into the
shallow aquifer. These actions have included removal of
contaminated drums from the site/ drainage of the existing
storage tanks; removal of the heavily contaminated soil,
particularly underneath the former northeast sumps; and (in
early 1988) paving most of the site to preclude surface water
infiltration from being a continued vector of contaminant
transport into groundwater.
The proposed action will further EPA's interim remediation of
the site by retarding contaminant migration in groundwater and
removing and treating some of the water presently
contaminated. This action is referred to as ERA/Operable
Unit 1, and it is considered to be consistent with future
action expected to be implemented to permanently remediate site
conditions. While the ongoing RI/FS will include evaluation of
potential source removal (i.e., contaminated soils) the problem
is mainly one of groundwater contamination, a principal remedy
of which is groundwater pumping and treatment. The remediation
presented in this ROD is therefore relevant to and consistent
with the overall site remediation strategy.
II-4-2
-------
000('231
5.0 SITE CHARACTERISTICS
5.1 PREVIOUS INVESTIGATIONS
The Lorentz Barrel & Drum (LB&D) site has been the subject of
numerous investigations. The following discussion of regional
and site-specific hydrogeology has been adapted from a report
entitled "Technical Memorandum: Preliminary Hydrogeologic
Assessment" (CH2M Hill, November 19873), as modified by
observations and measurements made by Ebasco in a limited
sampling program performed in June 1988 and bench scale
treatability-related studies done in July/ August 1988.
5.1.1 Regional Hydroaeolooy of the Santa Clara Vallev
The LB&D site lies near the center of the Santa Clara Valley
between the Santa Cruz Mountains to the west and the Diablo
Range to the east. The Santa Clara Valley is a broad alluvial
basin trending northwesterly. The sediments are divided into
the lower Plio-Pleistocene Santa Clara Formation, which is
somewhat consolidated and has been deformed, and the upper
Quaternary alluvium, which is poorly consolidated. Both units'
consist of interbedded gravel, sand, silt, and clay, and they
cannot be reliably differentiated in well logs (CH2M Hill,
February 1987).
The San Jose subarea, in which LB&D is located, is considered
one of the most important parts of the South Bay Groundwater
Basin due to the thickness and permeability of the
water-bearing units. At least two major water-bearing units or
aquifers are believed to exist in the LB&D area, separated by a
marine clay layer or aguitard, formed during past incursions of
San Francisco Bay. The upper water-bearing unit is a shallow
aquifer zone that may be confined. Below this is an aquitard;
below the aquitard and approximately 250 feet below the surface
lies the stressed confined aquifer zone from which municipal
wells are pumped. The lateral extent of this major aquitard is
not fully known, but it seems to be present in the LB&D area.
5.1.2 Site-Specific Hydrogeolooy
Within the site, the sediments are primarily composed of fine-
grained, unconsolidated silts and clays with interbedded sand
and gravel lenses.
A generalized cross-section of the site-specific hydrogeology
is shown in Figure 5-1. Based on the information available, a
layer of clayey-silt underlies the site to a depth of about 5
feet. Beneath this is a layer of sand and gravel which ranges
from 2 to 15 feet thick. Below the sand and gravel layer is a
silty clay layer to about 70 feet below surface. This layer
II-5-1
-------
s
110- HW-I
MW-1
100-
00—
- 00-
I
III
-« TO —
in
VI
ui
O
" •«-
ui
_i
™ 50-
«0 —
JO —
JO —
MW-S
MW-4
MW-I
MW.I
FIGURE 5-1
GENERAL GEOLOGIC CROSS-
SECTION (adapted from
CH2M Hill PSAR, February 1987)
LORENTZ BARREL & DRUM
-------
0000231
contains scattered sand lenses which may or may not be
connected to the overlying sand. Below the clay layer is
another sand and gravel layer approximately 15 feet thick.
Well locations used to establish the onsite stratigraphy and
groundwater levels are shown in Figure 5-2.
Based on previous sampling by DHS and EPA, there are three
aquifers of concern at the site: a potential shallow water
table that could be affected^ by seasonal recharge; a shallow
upper aquifer; and a deep aquifer. Each of these three
aquifers are described in the following sections.
Shallow Water Table
It is possible that a seasonal shallow water table could exist
above the silty clay layer. This water table was not found by
either DHS or EPA. However, both of those previous sampling
events occurred following extended dry periods. It is possible
that a seasonal water table could form during the wet season.
If so/ then it is likely that it would be contaminated. The
RI/FS will address this potential seasonal aquifer.
Shallow Upper Aquifer
Data on the shallow upper aquifer are based on two sampling
events: one event in October 1986 by DHS; and the second during
August 1988 by EPA. The latter sampling followed 2 years of
drought. During both events, the groundwater depth was roughly
25 feet below ground surface. This places the groundwater in
the silty clay. The shallow groundwater appears to be in a
semi-confined aquifer. The August 1988 sampling showed that
the potentiometric surface of the groundwater was generally 1
to 5 feet above where the groundwater was first encountered
during drilling, indicating that the upper groundwater surface
is confined by the silty clay layer. The October 1986 sampling
by DHS showed the presence of an unsaturated zone at the 75
foot depth, which is below the shallow upper aquifer. However,
the integrity of the well that was used to identify the
unsaturated zone has been questioned by State hydrogeologists.
The presence of the unsaturated zone below the shallow upper
aquifer is therefore not conclusive.
The direction of flow in the shallow upper aquifer is generally
northward. However, the flow direction may have changed
because of the recent drought. Data collected by DHS in
October 1986 indicated a northward flow, with a groundwater
gradient of 0.0015 ft/ft. However, data collected by EPA in
August 1988 (after 2 years of drought) showed a negligible
northward gradient and a slight eastward flow. It is believed
II-5-3
-------
0000231
MW-7<
MW-6,
in
0.
Pacific Sandblast Property
EAST ALMA AVENUE
MW-4
Arata Prooertv
(1961, 1.34 acres)
* i
M£-1 / / n
MW-2
Present Lorentz
Barrel & Drum Site
(1988. 5.25 acres)
Norton.'Pheips Property
(1950. 3.4 acres)
ii
LEGEND
Monitoring well
1987 Excavations
Existing sump
100
200
SCALE IN FEET
FIGURE 5-2
FORMER MONITORING
WELL LOCATIONS
LORENTZ BARREL & DRUM
-------
0000231
that the August 1988 data are strongly affected by the drought,
and do not reflect the long-term historical or future
groundwater properties.
Slug tests to measure the characteristics of the shallow upper
aquifer were conducted by EPA during August 1988. The tests
were done using two monitoring wells that had screened sections
extending 10 feet into the 30-foot saturated zone of the
aquifer. Slug tests are considered to be accurate only to
within an order of magnitude. The slug tests indicated an
apparent aquifer transmissivity (T) of 0.22 gpm/ft and a
storitivity (S) of 0.001. Assuming that the aquifer is
homogeneous, the calculated radius of influence for a 5 gpm
extraction well would be 50 feet, with a 10 foot drawdown.
Groundwater monitoring by DHS and EPA have shown that the
shallow upper aquifer has been contaminated by the LB&D
operations. This indicates that the silty clay layer above the
shallow upper aquifer has not prevented vertical migration of
contaminants. Additional hydrogeological data will be needed
to fully design the shallow aquifer extraction system.
Deep Aquifer
Based on data collected by.DHS, the LB&D site is underlain by a
deep aquifer with an apparent water table roughly at the
100-foot depth. The deep aquifer is used 'for municipal
drinking water supplies. The groundwater flow direction in the
deep aquifer is governed by troughs created by municipal well
fields. No sampling of the deep aquifer near the LB&D site has
yet been conducted. It is therefore not yet known whether the
silty clay layer prevents vertical migration of contaminants
between the shallow upper aquifer and the deep aquifer.
Sampling of the deep aquifer will be conducted in the future
RI/FS for the LB&D site.
5.1.3 Soil and Groundwater Contamination
Previous investigations of contamination of soil and
groundwater at the LB&D site date back to 1981, as summarized
in Table 5-1. Also included in Table 5-1 are dates and
locations of soil excavations performed as partial remedial
actions. Table 5-2 summarizes the history of previous
groundwater investigations done at the site, in terms of dates,
contractors, and parameters measured.
5.2 SOURCES OF CONTAMINATION
Residues contained in the used barrels and drums accepted for
processing at the site, incineration products of those
residues, and other chemicals used to handle, store, or
recondition the drums gradually contaminated site soils and
groundwater.
II-5-5
-------
TABLE 5-1
SUMMARY OF SAMPLING ACTIVITIES TO DATE AT THE LB&D SITE
(August 1981 through July 1988)
Page 1 of 6
DATE
SAMPLED CLIENT
8-81 DHS
9-82 LB&D
10-82
SAMPLED OR
PERFORMED
BY
DHS
Associated
Labs
ANALYZED BY
DHS
Associated
Labs
ACTIVITY
25 surface soil
samples around
site
35 subsurface
soils (A few
ANALYTE,
METHOD
Metals. Purgeables (EPA
624) Organophosphorus
Pesticides (EPA 614)
Chlorinated Pesticides/
PCBs (EPA 608)
Metals, Chlorinated
Pestlcldes/PCBs
RESULTS
ABOVE TTLC
(Soil)
Cd, Cr. Pb
PCBs. DOE
Pb. N1
PCBs. ODD. DDE
RESULTS ABOVE
ACTION CRITERIA
(Groundwater)
N/A
N/A
ALSO DETECTED
(Above Background) .
Toluene. Xylenes.
Ethylbenzene, Dtazlnon,
Malathton. Ethlon. etc.
g-BHC. Heptachlor.
Heptachlor Epoxide
Cr
DDT
10-83 LBtD Feuersteln B&C
11-83 LB&D Geotechnlcal B&C
Consultants
for
Feuersteln
11-83 LB&D .Feuersteln N/A
1-84 LB&O Feuersteln B&C
sediment/liquids
from around site)
18 surface soils
along drainage
ditch
Monitoring wells
1 & 2 Installed
- soils sampled
In borewells
at 10' depth
- groundwater
from wells
1 & 2 sampled
Excavation of
soil In & around
drainage ditch
12 soil samples
taken at base of
excavation
(EPA 608)
Chlorinated Pesticides/
PCBs (EPA 608)
Metals. CN-, Phenols
Purgeables (EPA 625)
Chlorinated Pesticides/
PCBs (EPA 608)
Extractables (EPA 625)
Excavation only; no
samples taken
Chlorinated Pesticides/
PCBs (EPA 608)
PCBs. N/A
chlordane. ODD.
DDE
None
N/A
PCBs.
chlordane,
ODD. DDE. DDT
N/A
N/A
DDT
As. benzene.' Soil: Various VOCs
chloroform, (TCE. Xylenes, etc.)
PCE. TCE.
1.1-DCE Various VOCx and
semi-VOCs
N/A
None
o
o
CO
-------
TABLE 5-1 (Continued)
SUMMARY OF SAMPLING ACTIVITIES TO DATE AT THE LB&O SITE
(August 1981 through July 1988)
Page 2 of 6
DATE
SAMPLED CLIENT
1-84 LB&D
1-84 LB&D
1-84 LB&D
1-34 LB&D
3-85 DHS
SAMPLED OR
PERFORMED ANALYZED BY
BY
Feuersteln
Feuersteln B&C
Geotechnlcal B&C
Consultants
for
Feuersteln
Feuersteln B&C
DHS DHS &
McKesson
ACTIVITY
Further excava-
tion of soil In
and around
drainage ditch
1 soil sample
at base of
excavation
Monitoring Hell
3 Installed
- soil sampled
In borehole
at 10' depth
- groundwater
sampled MH-3
Monitoring wells
1. 2, 3 sampled
4 surface soils
on & off site
ANALYTE.
METHOD
Excavation only;
no samples taken
Chlorinated Pesticides/
PCBs (EPA 608)
Chlorinated Pesticides/
PCBs (EPA 608) Purgeable
Halocarbons (EPA 601)
Purgeable Halocarbons
(EPA 601)
Metals Purgeables
Chlorinated Pesticides/
RESULTS RESULTS ABOVE
ABOVE TTLC ACTION CRITERIA
(Soil) (Groundwater)
N/A N/A
None N/A
None PCBs, TCE
PCE. 1,1-DCE
N/A 1,1-DCE, 1,
2-OCE,
Dkhloro-
propane,
PCE, TCE
ODD. DDE, DDT N/A
ALSO DETECTED
(Above Background)
N/A
None
Soil: PCBs. PCE
Groundwater:
1.1.1-TCA
Freon 113.
1.1.1-TCA. 1-OCA
PCBs, PCE. Toluene.
PCBs (EPA 608) Serai -
volatlles (EPA 625)
Total Hydrocarbons
Ethylbenzene, Xylenes
o
£2
-------
TABLE 5-1 (Continued)
SUHHARY OF SAMPLING ACTIVITIES TO DATE AT THE LB&D SITE
(August 1981 through July 1988)
Page 3 of 6
DATE
SAMPLED
3-85
3-85
4-85
4-85
5-85
6-85
6-85
CLIENT
LB&O
LB&D
LB&D
LB&D
DHS
LB&D
LB&D
DHS
LB&O
SAMPLED OR
PERFORMED
BY
Feuersteln
Conservtech
Geotechnlcal
Cons.
Reed
DHS
Reed
Reed
ANALYZED BY
N/A
Associated
Associates
Labs
B&C
DHS
B&C
N/A
DHS
B&C
ACTIVITY
Excavation of
soil at 6
locations around
5 soils at base
of excavation
Monitoring
wells 4 & 5
Installed and
sampled
Monitoring wells
1 & 5 sampled
18 soil samples
taken at base of
excavation
Splits sent to
different labs
Excavation of soil
In Area 3
15 soil samples
taken around the
site, splits
ANALYTE ,
METHOD
Excavation only;
no samples taken
Metals
Purgeables (EPA-624)
Chlorinated Pesticides/
PCBs (EPA 608)
Purgeable Halocarbons
(EPA 601)
Chlorinated Pesticides/
PCBs (EPA 608) Semi-
volatiles (EPA 625)
Purgeables (EPA 624)
Pb
PCBs
N/A
Metals
Chlorinated Pesticides/
PCBs (EPA 608)
RESULTS
ABOVE TTLC
(Soil)
N/A
PCBs
N/A
N/A
PCBs
N/A
Cd. Pb. PCBs.
DDE
RESULTS ABOVE
ACTION CRITERIA ALSO DETECTED
(Groundwater) (Above Background)
N/A N/A
N/A ODD, DDE. Pb. TCE. PCE
1.2-DCE. None
1.2-DCA. PCE.
TCE
None . Freon 113
N/A Pb
N/A N/A
N/A
DleldHn,
sent to
different labs
Organophosphorus
Pesticides (EPA 614)
dtsulfoton, methyl
parathlon. ethlon.
azlnphos-methyl
o
-------
TABLE 5-1 (Continued)
SUMMARY OF SAMPLING ACTIVITIES TO DATE AT THE LB&D SITE
(August 1981 through July 1988)
Page 4 of 6
DATE
SAMPLED CLIENT
SAMPLED OR
PERFORMED
BY
ANALYZED BY
ACTIVITY
ANALYTE.
METHOD
RESULTS
ABOVE TTLC
(Soil)
RESULTS ABOVE
ACTION CRITERIA
(Groundwater)
ALSO DETECTED
(Above Background)
6-85
7-85
6-86
DHS
LB&D
DHS
LB&D
DHS
Reed
DHS
Reed
DHS
B&C
DHS
TMA (EAL)
10-86
DHS
CH2M Hill
CH2M Hill
8-87 DHS
11-87
CH2M Hill
TRC
32 soil samples
from area near
processing
facility;
Splits sent to
different labs
1 soil sample
east of main
building
Monitoring wells
6 & 7 Installed
and samples
taken from
monitoring wells
1, 2. 3. 4. 6.
and 7
Monitoring
wells 4 and
sampled
Soil-gas and
groundwater
study offsite
Chlorinated Pesticides/
PCBs (EPA 608)
Extractables (EPA 625)
Organophosphorus pesti-
cides (EPA 614)
VGA's (EPA 5020-GC/MS)
Metals
PCBs
Purgeable Halocarbons
(EPA 601)
PCBs
PCBs
N/A
Metals
Purgeables (EPA 624)
Chlorinated Pesticides/
PCBs
N/A
Volatile organic
compounds (TRC,
November 1987
N/A
N/A
N/A
1.2-Dichloro-
propane.
chlorform. TCE.
vinyl chloride.
1.1.1-TCA.
1.1-OCE.
1,2-DCE. PCE,
1,2-DCA,
PCE. 1,2-DCA
Ba
Benzene, vinyl
chloride.
1.1-DCE 1,2-DCE
1,2-Dlchloro-
propane. TCE.
1,1,2,2-PCA
chlordane.
PCBs
N/A
Parathion
None
Chloroethane,
1,1-DCA.
Bromodi-
chloromethane
Toxaphene.
phthalates
Off site plume;
TCE. TCA, Freon 113,
Vinyl chloride
O
.-"-^
-------
Late B7
Early
88
Early
88
TABLE 5-1 (Continued)
SUMMARY OF SAMPLING ACTIVITIES TO DATE AT THE LB&D SITE
(August 1981 through July 1988)
Page 5 of 6
DATE
SAMPLED
Mid-87
CLIENT
DHS
SAMPLED OR
PERFORMED
BY
Canonte
ANALYZED BY
Canonie
& Acurex
ACTIVITY
Soil sampled In
Perimeter &
ANALYTE.
METHOD
Metals
VOCs (EPA 624)
RESULTS
ABOVE TTLC
(Soil)
Cd. Cr. Pb.
RESULTS ABOVE
ACTION CRITERIA
(Groundwater)
N/A
ALSO DETECTED
(Above Background)
None
6-88
DHS
DHS
EPA
EPA
Emergency
Response
Division
EPA
Canonie
IT
E&E
EPA/E&E
N/A
Curtis &
Tomklns
Curtis &
Tomkins
EBASCO
CLP
"Hot Spot" areas
In northern
part of site
Excavation
of soil
Drum removal
etc.
Post excava-
tion soil
sampling
Incinerator
ash from barrel
on site sampled;
more facility
cleanup etc.
CHIP and SEAL
Installed on
drum storage area
Municipal Hell
sampling (RI/FS)
Semi-VOCs (EPA 625)
Organochlorlne Pestl-
cldes/PCBs (EPA 614)
Excavation only;
no samples taken
Ml. PCBs. ODD.
DDT. Xylenes.
Benzene. Ethy-
benzene. Toluene
N/A
Metals. Semi-volatile PCBs (some
Organlcs (EPA 3270) samples)
Organochlorlne •
Pestlcldes/PCBs (EPA 8080)
Volatile* (EPA 8240)
Metals Pb
Dloxlns and Furans
(EPA 8280)
N/A
N/A
N/A
Semi-Volatile organlcs
(CLP RAS)
Pestlclde/PCBs (CLP RAS)
Data not
received yet
Data not
received yet
N/A
None
High Cr. N1. Zn
Low concentrations
of heptachloro-
dlbenzo-p-dloxln.
octachlorodlbenzo-
p-dloxln, octachloro-
dlbenzo furan
Data not received yet
CJ
-------
TABLE 5-1 (Continued)
SUMMARY OF SAMPLING ACTIVITIES TO DATE AT THE LB&D SITE
(August 1981 through July 1988)
Page 6 of 6
DATE
-AMPLEO
7-88
CLIENT
EPA
SAMPLED OR
PERFORMED
BY
EBASCO
ANALYZED BY
Hlttman-
Ebasco
ACTIVITY
Groundwater
characterization
ANALYTE,
METHOD
Metals
Semi-volatile organic*
RESULTS
ABOVE TTLC
(Soil)
N/A
RESULTS ABOVE
ACTION CRITERIA
(Groundwater)
Vinyl chloride
1.1-DCA;
ALSO DETECTED
(Above Background)
Acetone 1.1-DCA;
trans- 1,2-DCE;
sampling for
treatablllty
study (RI/FS)
(EPA 601/602. 624)
Organochlorlne pesticides/
PCBs (EPA 605/608)
Phenols (EPA 606)
Phthalate esters (EPA 604)
Chemical & Physical
Properties (EPA)
01oxIns (EPA 8280)
modified)
1.2-DCP; TCE;
Benzene; PCE*
1.1,1-TCA; Toluene;
Chlorobenzene;
Ethyl benzene*
Data not yet
received (dloxlns)
ABBREVIATIONS:
B&C - Brown and Caldwell
Canonic - Canonle Environmental
CLP - Contract Laboratory Program
DHS - California Department of Health Services
E&E - Ecology & Environment
EBASCO - Ebasco Services. Incorporated
EPA - Environmental Protection Agency
Feuerstetn - Feuersteln Associates Consulting Engineers
N/A - Not Applicable
IT - IT Corporation
LB&D - Lorentz Barrel ft Drum
McKesson - McKesson Environmental
RAS - Routine Analytical Services
Reed - Reed Corporation
RI/FS - Remedial Investigation/Feasibility Study
TMA - Thermo Analystlcal, Inc.
TRC - Tracer Research Corporation
* - Results preliminary awaiting validation (Ebasco 1988)
o
o
CO
-------
TABLE 5-2
GROUNOWATER ANALYSES
Date
Sampled
11-23-83
01-20-84
03-02-84
04-04-85
04-29-85
07-86
10-02-86
06-30-88
07-16-88
Client Sampled By Analyzed By
LB&D Feuerstein ft Associates Brown ft Cal dwell Laboratory
LB&D Feuerstein ft Associates Brown ft Cal dwell laboratory
LB&D Feuerstein ft Associates Brown ft Cal dwell Laboratory
LB&D Geotechnlcal Consultants, Inc. Associated Laboratories
LBKD Reed Corporation Brown ft Cal dwell Laboratory
LB&D Reed Corporation • Thermo Analytical, Inc./
Environmental Research Group
OHS CH2M Hill, Inc. CH2M Hill Environmental
Laboratory
EPA Ebasco Services, Inc. Contract Laboratory Program
EPA Ebasco Services, Inc. Hittman-Ebasco
Analytical
Method
Unknown
EPA 624
EPA 625
EPA 601
EPA 608
EPA 601
EPA 601
EPA 624
EPA 608
EPA 624
EPA 601
Unknown
EPA 624
EPA 608
EPA 625
Unknown
CLP RAS
CLP RAS
EPA 608
EPA 604
EPA 606
EPA 601 /
602 & 624
EPA 625
EPA 200
Series
EPA
Various
Analyte/Method
Metals. CN. Phenols
Purgeables/Gas Chromatography-
Mass Spectrometry (GC-MS)
Extractables/CG-MS
Purgeable Halocarbons/GC
Chlorinated Pesticides and PCBs/GC
Purgeable Halocarbons/GC
Purgeables/GC
Semi volatile Organics/GC-MS
Chlorinated Pesticides and PCBs/GC
Purgeables
Purgeable Halocarbons/GC
Metals
Purgeables/GC-MS
Organochlorine Pesticides and
PCBs/GC
Semivolatiles Organics/GC-MS
Minerals
Semi volatile organics/GC-MS
Chlorinated Pesticides and
PCBs/GC
Pesticides/PCB
Phenol s
Ph thai ate Esters
Volatile organics
Semivolatiles
Metals
Chemical ft Physical
Properties
o
-------
000(631
5.3 NATURE AND EXTENT OF CONTAMINATION IN THE SHALLOW AQUIFER
The shallow groundwater beneath both onsite and offsite areas
is contaminated with volatile organic compounds (VOCs),
pesticides, polychlorinated biphenyls (PCBs), and some metals.
Table 5-3 summarizes results of groundwater analyses performed
to date by various consultants .to LB&D. Table 5-4 provides the
maximum contamination levels detected for selected
contaminants. No remedial actions to date have addressed
groundwater contamination. Therefore, all of these data must
be considered in assessing site contamination. Results from
Tracer Research Corporation (TRC) 1987 study are shown in
Table 5-5. The Data Quality Level (DQL) for the previous
studies was taken into consideration by the Regional Board
(1981-1986) and DHS (1986-1987) in their decisions as lead
agencies at LB&D. For this ROD, EPA has determined that the
DQL is Level 3, appropriate for preliminary engineering design.
The 1987 TRC study showed a complex pattern of water
contamination (Figure 5-3). In addition, the groundwater
samples analyzed from well MW-6 indicate that contaminants
other than VOCs have migrated offsite. The potential migration
of PCBs is of particular concern. PCBs do not migrate readily
in groundwater, but they are soluble in organic solvents (e.g.,
1,1,1-TCA and TCE) and can be transported along with those
solvents. The lack of information about the transport and
actual extent of PCB contamination is one of the major data
gaps that needs to be filled by collection and laboratory
analysis of samples from groundwater monitoring wells before
design of the treatment facility can be implemented. Samples
collected for treatability studies in summer 1988 did not have
measurable levels of PCBs, but further work needs to be done to
confirm this.
Other data gaps which will be addressed during the RI/FS before
further remedial action evaluation and design are completed
include determination of:
o the types of contaminants comprising the plume(s);
o the vertical and horizontal extent and variability of
contamination;
o the extent of actual or potential migration pathways,
such as potential conduits between aquifers; and
o the potential for vertical migration between aquifers,
via either natural or man-made discontinuities.
II-5-13
-------
TABLE 5-3
SUMMARY OF MONITORING WELL DATA
(units for analysis are specified for each category of analyte in Column 1.)
Analyte
METALS (ppb)
Arsenic
Barium
Chromium (total)
Cobalt
Molybdenum
Nickel
Vanadium
Zinc
VOLATILE ORGAN ICS (ppb)
Benzene
Chloroethane
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dlchloroethene
Trans- 1,2-Dichloroethene
Methylene Chloride
1,2-Dlchloropropane
Tetrachloroethene
1,1,2,2-Tetrachloroethane
1,1.1-Tri Chloroethane
Trlchloroethene
Vinyl Chloride
Freon 113
Carbon Disulfide
Bromodlchtoromethane
Olchlorotrif luoroethane
C6H12 Cyclic Hydrocarbon
SEMI -VOLATILE ORGANICS (ppb)
Di-n-Butyl Phthalate (f)
Butylbenzyl Phthalate (f)
Bls(2-Ethyl HexyDPhthalate (f)
Oi-n-Octyl Phthalate (f)
MU-1
B ft C (b)
11/83 3/84 4/85
3.0
0.3
43.0
—
1.0
...
...
10.0 51.0
...
12.0 9.0
9.0 10.0
—
4.0 3.0
5.0 2.0
—
30.0 33.0
59.0 54.0
—
30.0 26.0 4.0
...
—
50.0
5.0
TMA (c)
7/86
—
11.0
11.0
—
9.0
8.4
—
1.7
(e)
3.0(e)
34.0
61.0
—
—
MW-2
B 1 C (b)
11/83 3/84
4.0
0.1
33.0
...
...
—
2.0
— ...
—
— —
— —
—
— —
... ...
—
2.0 -•-
— —
—
7.0 6.0
3.0
—
6.0
TMA (c)
7/86
..j
1.4
—
—
—
—
—
—
(e)
— (e)
0.36
—
—
—
MU-3
B ft C (b)
1/84 3/84
46.0
29.0 47.0
105.0
45.0
17.0 38.0
26.0 34.0
640.0 1000.0
41.0
TMA (c)
7/86
—
29.0
40.0
18.0
22.0
91.0
—
60.0
(e)
65.0(e)
60.0
950.0
62.0
1.5
MtH
Associated
4/85
.
—
...
—
—
—
240.0
—
...
...
—
—
510.0
—
...
5100.0
TMA (c)
7/86
24.0
...
85.0
58.0
160.0
750.0
—
170.0
(e)
140. 0(e)
220.0
1100.0
1100.0
—
MU-4A (a)
CH2M Hill
10/86
—
160.0
—
60.0
—
130.0
30.0
20.0
26.0 (d)
—
...
38.0 (d)
—
90.0
430.0
26.0 (d)
89.0
...
91.0
75.0
1766.0
455.0
—
...
31.0
...
73.0
...
MU-4B (a)
CH2M Hill
10/86
—
160.0
—
50.0
20.0
120.0
30.0
20.0
26.0 (d)
—
...
41.0 (d)
—
97.0
488.0
—
92.0
...
106.0
83.0
2108.0
553.0
...
—
24.0
17.0
680.0
60.0
(a) Splits of sample collected from MU-4 (10-86)
(b) Brown ft CaIdwell
(c) Thermo Analytical, Inc.
(d) Indicates an Estimated Trace Value
(e) Co-Eluting Compounds
(f.) Phthalates are most probably laboratory contaminants
Not Detected
(blank) Not Analyzed
C.3
>-•
-------
TABLE 5-3 (continued)
SUMMARY OF MOMI TORIMG WELL DATA
(unit* for analysis are specified for each category of analyte .In Co I inn 1.)
Analyte
HETALS (ppb)
Arsenic
Barium
ChromiuM (total)
Cobalt
Molybdenum
Nickel
Vanadium
Zinc
VOLATILE ORGAN ICS (ppb)
Benzene
Chloroethane
Chloroform
1.1-Oichloroethane
1,2-Oichloroethane
1 , 1 - D i ch 1 oroethene
Trans-1,2-Dichloroethene
'Methylene Chloride
1 ,2-Dichloropropane
Tetrachloroethene
1,1,2,2-Tetrachloroethane
1,1.1-Trichloroethane
Trichloroethene
Vinyl Chloride
Freon 113
Carbon Disulfide
Bromodichloromethane
D i ch 1 orot r i f I uoroethane
C6H12 Cyclic Hydrocarbon
SEMI -VOLATILE ORGAN ICS (ppb)
Di-n-Butyl Phthalate (f)
Butylbenzyl Phthalate (f)
Bis(2-Ethyl HexyDPhthalate (f)
Dl-n-Octyl Phthalate (f)
MW-
Associated
4/85
—
—
—
4.8
...
—
...
—
23.0
—
45.0
—
—
—
5
B t C (b)
4/B5
...
MV
TMA (C)
7/86
—
9.9
35.0
8.5
49.0
120.0
...
23.0
(e)
60.0(e)
32.0
770.0
510.0
—
1-6
CH2M Hill
10/86
...
110.0
10.0
20.0
20.0
60.0
30.0
...
—
—
—
18.0 (d)
—
33.0
61.0
...
—
...
22.0 (d)
14.0 (d)
413.0
60.0
—
—
113.0
32.0
39.0
...
MU-7
TMA (c)
7/86
—
—
1.0
270.0
1.7
—
...
—
(e)
— (e)
5.2
0.5
—
—
MU-16
HITTMAN EBASCO
7/88
—
141
1.9
13
72
25
8
—
—
14
...
27
52
...
18
18
—
11
300
66
—
—
...
...
...
...
MU-16 (field duplicate)
HITTMAN EBASCO
7/88
...
128
2.4
15
71
32
8
—
0.5
16
20
29
56
...
19
19
—
12
311
72
—
...
...
—
...
...
MU-20
HITTMAN EBASCO
7/88
...
99
2.3
11
...
25-
3
—
—
3
—
86
14
...
1
...
—
34
2
8
—
—
...
...
...
...
(a)
(b)
(c)
(d)
(e)
(f )
(blank)
Splits of sample collected from MU-4 (10-86)
Brown I Ca I dwell
Thermo Analytical, Inc.
Indicates an Estimated Trace Value
Co-Eluting Compounds
Phthalates are most probably laboratory contaminants
Detected
o
o
CO
-------
TABLE 5-3 (continued)
SUMMARY OF MONITORING WEIL DATA
(units for analysis are specified for each category of anatyte In Column 1.)
Analyte
EXTRACTABLES (ppb)
Isophorone
D I methyl ethoxyethanol
>C9 Aldehyde
Docosanoic Acid
Hexadecanoic Acid
C4 Benzole Acid
>C10 Fatty Acid
MINERALS (ppm)
Calcium
Magnesium
Potassium
Sodium
Bicarbonate
Carbonate
Chloride
Nitrate
Phosphate
Sulfate
Silica
CaC03
PESTICIDES (ppb)
Chlordane
Toxaphene
POLYCHLORINATED
BYPNENVLS (ppb)
PCB 1221
PCB 1242
PCB 1254
PCB 1260
MU-1
• ft C (b)
11/83 3/84 4/85
2.0
2.0
2.0
2.0
4.0
2.0
...
...
TMA (c)
7/86
MU-2
B ft C (b)
11/83 3/84
1.0
...
...
TMA (C)
7/86
MU-3
B & C (b)
1/84 3/84
...
...
0.36
TMA (c)
7/86
MV-<
Associated
4/85
,
...
...
TMA (c)
7/86
'
NW-4A (a)
CH2M Hill
10/86
97.0
140.0
0.92
200.0
1293.0
—
79.0
83.8
24.0
24.0
0.2
1.0
2.0
1.0
0.4
MU-4B (a)
CH2M Hill
10/86
96.0
140.0
1.0
210.0
1220.0
—
78.0
82.0
26.0
26.0
0.1
2.0
3.0
— .
0.4
(a) Splits of sample collected from MU-4 (10-86)
(b) Brown ft CaIdwell
(c) Thermo Analytical, Inc.
(d) Indicates an Estimated Trace Value
(e) Co-Elutlng Compounds
(f) Phthalates are most probably laboratory contaminants
Not Detected
(blank) Not Analyzed
CJ
-------
TABLE 5-3 (continued)
SUMMARY OF MONITORING WELL DATA
(units for analysis ere specified for each category of anatyte .in Colum 1.)
Analyte
EXTRACTABLES (ppb)
Isophorone
Dlmethylethoxyethanol
>C9 Aldehyde
Docosanoic Acid.
Hexadecanoic Acid
C4 Benzole Acid
>C10 Fatty Acid
MINERALS (ppm)
Calcium
Magnesium
Potassium
Sodium
Bicarbonate
Carbonate
Chloride
Nitrate
Phosphate
Sulfate
Silica
CaC03
PESTICIDES (ppb)
.Chlordane
Toxaphene
POL YCHLORI HATED
BYPHENYLS (ppb)
PCB 1221
PCB 1242
PCB 1254
PCB 1260
MW-
Associated
4/85
...
...
5
B ft C (b)
4/85
MV
TMA (C)
7/86
1-6
CH2M Hill
10/86
73.0
110.0
1.12
290.0
1250.0
—
55.0
95.0
24.0
24.0
—
...
4.0
...
0.2
MW-7
TMA (c)
7/86
MU-16
HITTMAN EBASCO
7/88
f
70
123
...
297
83
613
—
...
...
—
—
—
MU-16 (field duplicate)
HITTMAN EBASCO
7/88
67
118
...
285
••
73
601
—
...
...
...
...
...
MU-20
HITTMAN EBASCO
7/88
123
15
1.8
659
253
870
—
...
...
—
...
...
(a) Splits of sample collected from MU-4 (10-86)
(b) Brown ft Caldwell
(c) Thermo Analytical. Inc.
(d) Indicates an Estimated Trace Value
(e) Co-Eluting Compounds
(f) Phthalates are most probably laboratory contaminants
Not Detected
(blank) Not Analyzed
o
-------
TABLE 5-«
GROUNDWATER CONTAMINATION LEVELS
DETECTED AT LORENTZ BARREL AND DRUM SITE*
0000231
Analyte
DHS Action
Criteria
References'-*
(ppb)
Highitt
Level
Dtticttd*
(PPb)
Date
HHALS
Arsenic
Barium
Chromium (toUl)
Cobilt
Molybdenum
Nickel
Vanadium
21 nc
VOLATILE ORGANIC?
B«niint
Chloroethane
Chloroform
1.1-Oichloroethane
1,2-Oichloroethane
1.1-Oiehloroethene
trans-l,2-Dichloroethene .
Dichlorome thane
1.2-01chloropropane
Tttrtchlorotthint
1,1,2.2-tetrachloroethane
1,1,1-Trichloroethane
Trichloroethene
Vinyl Chloride
Frton 113
PESTICIDES
Chlordane
Toiaphene
POLVCHLORINATED BIPHENYLS
PCBi
0.002 (2)
10.00 (3)
51.00 (3)
150.00 (1)
7,480 (3)
0.70 (1.4)
0.50 (3)
4>000.00 (3)
0.51 (3)
LOQ (4)
70.00 (1)
10.00 (4)
10.00 (4)
0.87 (3)
0.17 (3)
200.00 (4)
1.80 (3)
0.015 (3)
O.OS (4)
35.00 (2)
O.OOB (3)
4.00*
160.00*
10.00
60.00
20.00
130.00
30.00
20.00
26.00*
24.00
29.00*
85.00
270.00*
160.00*
750.00*
26.00*
170.00*
140.00*e
106.00*
220.00*
2.108.00*
1.100.00*
41.00
0.20*
2.00
6.40*
11/83
10/86
10/86
10/86
10/86
10/86
10/86
10/86
10/86
07/86
07/86
07/86
07/86
07/86
07/86
10/86
07/86
07/86
10/86
07/86
10/86
07/86
03/84
10/86
10/86
10/86
a Concentrations are shown in parts per billion (ppb) unless otherwise indicated.
b DHS Action Criteria are as defined in a March 17, 1986. memorandum from David J.
Leu, Ph.D., DHS'I Chief of Alternative Technology and Policy Development Section,
Tonic Substances Control Division, to all Section Chiefs in DHS's Tosic Substance
Control Division. Reference numbers are shown in parentheses and indicate the
source of each criterion. These sources are listed in the Reference section
following this table.
c 140.00 ppb is the sum of PCE and 1,1.2.2-tetrachloroethane concentrations.
NOTES: DHS - Department of Health Services
LOQ • Limit of Quantification
• • eiceeds DHS Action Criterion
1. Draft Health Advisories. Office of Drinking Water.
U.S. Environmental Protection Agency. Washington, D.C.
September 30. 1985
2. Ambient Water Quality Criteria Documents.
Office of Water Regulations and Standards.
U.S. Environmental Protection Agency, Washington, D.C.
October 1980. (Values adjusted for drinking water.)
3. Draft Health Effects Assessment Documents
Office of Emergency and Remedial Response
Office of Environmental Criteria and Assessment
U.S. Environmental Protection Agency
Cincinnati, Ohio. September 19B4.
4. Sanitary Engineering Branch California Department o< Health Services
Berkeley, California. 1985
+ CH2H Hill. February 1987. Preliminary Site Allotment Report. Lorenti Barrel I
Drum (IBID). Prepared for California Department »' Health Services (DHS).
II-5-18
-------
TABLE 5-5
ANALYTICAL RESULTS OF GROUNDUATER
(Tracer Research Corporation, Groundwater Investigation at Lorentz Barrel ft Drua, Novenfcer 1987)
SAMPLE
V2
U3
U4
US
W6
U7
US
W9
U10
U11
U12
U13
UU
U15
U16
U18
W19
U20
DEPTH
(feet)
27
27
20
20
26
26
20
26
26
26
26
26
25
26
24
25
26
26
DATE
11/18
11/18
11/19
11/19
11/19
11/19
11/19
11/19
11/19
11/19
11/19
11/19
11/20
11/20
11/30
11/30
11/30
11/30
FREON
113
22
3
<0.3
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
0.2
<0.02
<0.03
TRICHLOROETHANE
90
5
28
60
53
7
68
U
<0.008
4
64
60
20
69
62
33
<0.009
0.03
TRICHLOROETHENE
2600
54
30
<0.02
3
<0.02
1
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
0.8
<0.02
<0.02
<0.02
PERCHLOROETHENE
11
0.2
0.1
<0.004
<0.004
<0.004
<0.004
<0.004
<0.004
<0.004
<0.004
<0.004
<0.004
<0.004
0.1
<0.05
-------
TCA
(Approximate)
VINYL CHLORIDE
(1.0 ppt>>
TCE
(5.0 PPt>»
Spartan
Stadium
San Jose
Muni BaiaDall
Stadium
GROUND* ATE R FLOW
tORENTZ BARREL
4 DRUM SITE
o
b
500
SCALE IN FEET
1000
=d
FIGURE 5-3
APPROXIMATE EXTENT OF
GROUNDWATER CONTAMINATION
LORENTZ BARREL & DRUM
-------
0000231
5.4 HUMAN AND ENVIRONMENTAL EXPOSURE PATHWAYS
Potential exposure pathways for VOCs are ingestion, dermal
contact, and inhalation of vapors from contaminated
groundwater, as well as accidental dermal exposure or ingestion
of Coyote Creek water. Potential exposure pathways for metals
are ingestion of contaminated groundwater and dermal contact
with Coyote Creek sediments and exposed surface soils.
Potential exposure pathways for PCBs consist of ingestion and
dermal contact from contaminated groundwater and soil.
II-5-21
-------
0000231
6.0 SUMMARY OF SITE RISKS
A screening-level health risk assessment was conducted to
evaluate potential health risks related to remediation of the
LB&D site by groundwater treatment alternatives described in
Engineering Evaluation and Cost Analysis (EE/CA) (Ebasco, May
1988). Since the groundwater treatment system is designed to
remediate groundwater contamination only, the scope of this
assessment focused on drinking water-related health risks as
the primary exposure route.. However, since one of* the
treatment alternatives also - involved air emissions of the
extracted contaminants, the additional health risks associated
with these emissions were also evaluated. Because this is a
screening-level assessment, adverse health impacts were
quantified only in terms of increased risk of cancer. A much
more comprehensive analysis of health risks at the LB&D site,
including all relevant exposure pathways and an evaluation of
noncarcinogenic health risks, will be included in the Remedial
Investigation/Feasibility Study (RI/FS) risk assessment.
6.1 CONTAMINANTS OF CONCERN
Contaminants included in the assessment (i.e., contaminants of
concern) consisted of all groundwater contaminants identified
at or near the LB&D site for which the United States
Environmental Protection Agency (EPA) has developed a cancer
potency estimate. All such contaminants were assumed to be
carcinogens and were included in the analysis regardless of
frequency of detection or magnitude of concentration.
Exceptions to this rule included phthalates, dichloromethane,
cadmium, and chromium. Analytical data for phthalates and
dichloromethane contaminants strongly suggested that detection
of these contaminants was due to laboratory contamination,
therefore these contaminants were not included in the
analysis. Cadmium and chromium were also excluded since these
compounds are not considered by EPA to be carcinogenic via the
oral route of exposure. A complete list of the contaminants
included in the analysis, along with the maximum and average
concentrations observed at the LB&D site, is provided in Table
6-1.
6.2 EXPOSURE ASSESSMENT
The potential exposure pathways associated with contamination
.of the shallow groundwater are illustrated in Figure 6-1.
Figure 6-1 includes all pathways of potential significance.
However, since this was a screening-level assessment, only the
most significant exposure pathways were quantitatively
evaluated. These pathways were considered to be drinking water
and inhalation (air stripper emissions only). Quantitative
evaluation of all other pathways will be included in the RI/FS
risk assessment.
II-6-1
-------
TABLE 6-1
CONTAMINANTS OF CONCERN IN THE SHALLOW GROUNDWATER
AT LORENTZ BARREL & DRUM
Estimated
Average
Maximum Concentration
Concentrations In The Plume
Found (ug/1)1 (ug/1)
1,1 Dlchloroethene
1,1,2,2 Tetrachloroethane
1,2 DUhloroethane
Arsenic
Benzene
Chlordane
Chloroform
PCBs (total)
Tetrachloroethene
Toxaphene
Trlchloroethene
Vinyl chloride
160
106
270
4.0
26
0.2
29
6.4
140
2.0
2,108
1,100
26
28
16
0.2
6.2
0.01
8.0
0.31
17
0.10
651
155
Expected
NPDES
Discharge
Limits
(ug/1)2
5
5
1
20
0.5
0.014
5
0.065
5
0.24
5
2
Source: CH2M H111, February 1987, Preliminary Site Assessment Report,
Lorentz Barrel & Drum
Source: California Regional Water Quality Control Board, San Francisco
Bay Region, Basin Plan Review, November 1986
II-6-2
-------
CONTAMINANT
SOURCE
CONTAMINANT
RELEASE
MECHANISM
CONTAMINANT
TRANSFER
MEDIA
POTENTIAL
EXPOSURE
MEDIA
POTENTIAL
EXPOSURE
ROUTES
POTENTIAL
EXPOSURE
POINTS
Discharge In
Coyote Creek
Onsite
Soil
T
Leaching
Surface
Runoff
Shallow
Ground
Water
•Sumps Leakage
-Spillage
•Drum Leakage
•Waste Dumping
Drinking Water
Supply
Contamination
Dermal
Accidental
Ingestion
Accumulated
Ingestion
(Fish)
Dermal
Ingestion
Inhalation
Coyote
Creek
Shower Stalls
Water Faucets
Bath Tubs
FIGURE 6-1
CONCEPTUAL EXPOSURE MODEL
SHALLOW GROUNDWATER
CONTAMINATION
LORENTZ BARREL ( DRUM
-------
0000231
Although the shallow groundwater is not currently being
utilized as a drinking water source, the drinking water pathway
was considered important based on the concern that the shallow
groundwater may have a hydraulic connection with the deep
aquifer. The deep aquifer is currently an important source of
drinking water in the region. The significance of this concern
will be clarified as a result of extensive RI studies currently
being performed.
6.3 RISK CHARACTERIZATION
Daily drinking water doses of carcinogens/ EPA cancer potency
estimates/ and lifetime cancer risk estimates for each of the
groundwater carcinogens are listed in Table 6-2. Human daily
contaminant doses associated with the consumption of two liters
per day of untreated shallow LB&D groundwater for a lifetime
were calculated using the maximum groundwater concentrations
reported for each of the carcinogens. An average adult human
body weight of 70 kg was also assumed in making the dose
calculation. Lifetime cancer risk was calculated by
multiplying the daily dose of ea.ch carcinogen by the cancer
potency estimate. The total cancer risk due to consumption of
untreated drinking water was calculated to be 8.1 x 10~2,
with most of the cancer risk attributable to vinyl chloride.
One of the groundwater treatment alternatives (Alternative C)
discussed in the EE/CA (Ebasco/ May 1988) utilizes an air
stripping tower to volatilize organic contaminants from the
extracted groundwater. Use of the air stripper without a
hazardous substance control device for air emissions could
result in atmospheric emissions of chlorinated hydrocarbons,
the significance of which would be a function of concentration
and dispersion. Daily doses of carcinogens associated with the
inhalation of air stripper emissions, along with lifetime
cancer risk estimates, are listed for all volatile carcinogens
in Table 6-3. Inhalation doses were estimated assuming a daily
inhalation rate of 20 mVday, an inhalation absorption
efficiency of 100 percent, and a 70 kg body weight. Annual-
average air concentrations of the contaminants were estimated
as described in Section 5.4.3 of the EE/CA. The calculated
total cancer risk associated with the uncontrolled air stripper
emissions is 2.8 x 10~6. The calculated cancer risk exceeds
the allowable 1 x 10~6 value for uncontrolled sources, which
is established by the Bay Area Air Quality Management District
(BAAQMD). This indicates that BAAQMD would require that a
control device be installed to reduce the compound emission
rate.
II-6-4
-------
TABLE 6-2
CANCER RISK FROM GROUNDWATER INGESTION: WORST CASE SCENARIO
Maximum Detected
Groundwater
Concentration1
Compound (ug/1)
1.1-Dichloroethene
1 , 1 ,2 ,2-Tetrachl oroethane
1,2-Dichloroethane
Arsenic"
Benzene
Chlordane
Chloroform
PCBs"
Tetrachl oroethene
Toxaphene
T rich! oroethene
Vinyl Chloride
160
106
270
4.0
26
0.2
29
6.4
140
2.0
2108
1100
Estimated Dose*
(mg/kg/day)
4
4
7
1
7
5
8
1
4
5
6
3
.58 x
.00 x
.72 x
.14 x
.43 x
.72 x
.29 x
.83 x
.00 x
.71 x
.03 x
.15 x
10-3
10-3
10-3
10-4
10-4
10~6
lo-4
ID"4
10-3
10-5
10-2
10-2
Cancer Potency
(risk/mg/kg/day)
5
2
9
1
2
1
8
7
5
1
1
2
.80
.00
.10
.5 x
.90
.61
.10
.7 x
.10
.10
.10
.30
x lO'1
x lO'1
x ID'2
10-1
x 10~2
x 10°
x ID'2
10°
x ID'2
x 10°
x ID'2
x 10°
Total Risk -
Estimated Risk
Level
2.
8.
7.
1.
2.
9.
6.
1.
2.
6.
6.
7.
8.
66 x
00 x
02 x
71 x
15 x
21 x
71 x
41 x
04 x
28 x
63 x
24 x
07 x
10-3
10-4
10-4
10-5
10-5
10-6
10-5
10-3
io-«
10-5
io-<
10-2
ID'2"
1 Based on highest levels detected in site monitoring wells.
Dose calculation assumes 2 liters of water consumed daily and a 70 kg body weight consistent
with standard United States Environmental Protection Agency (EPA) risk assessment assumptions.
These are different from the Engineering Evaluation and Cost Analysis (EE/CA) (Ebasco, May
1988) Table 5-1 based on recent EPA revisions to cancer potency estimates.
I1-6-5
-------
0000231
TABLE 6-3
INHALATION DOSES, CANCER POTENCY ESTIMATES,
AND LIFETIME CANCER RISK FOR UNCONTROLLED
AIR STRIPPER EMISSIONS
Compound
Inhalation
Dose
(mg/kg/day)
Cancer Potency
Estimate
(risk/mg/kg/day)
Incremental
Lifetime
Cancer
Risk3
Chloroform
1 , 2-Dichloroethane
1 , 1-Dichloroethene
Tetrachloroethene
1,1,2,2-Tetra-
chloroethane
Trichloroethene
Vinyl Chloride
5
1
1
1
1
4
9
.0
.0
.6
.1
.8
.1
.7
Z
z
z
z
z
z
z
10
10
10
10
10
10
10
-7
-6
-6
-7
-6
o
-5
j
-6
8
3
1
1
2
2
2
.10E-02
.50E-02
. 16E+00
.70E-03
.OOE-01
.50E-02
.50E-02
4
3
1
1
3
1
2
.1
.5
.9
.8
.-5
.9
,4
z
z
z
z
z
z
a
io-8
io-8
IO"6
io-9
_ 7
10 7
_7
10 7
io-7
Total Inhalation Risk
2.8 z 10
lifetime cancer risk=cancer potency estimate z inhalation
dose
II-6-6
-------
0000231
7.0 DOCUMENTATION OF SIGNIFICANT CHANGES
There have been no significant changes in the alternatives
considered since the release of the Engineering Evaluation/Cost
Analysis (EE/CA) (Ebasco, May 1988).
II-7-1
-------
QQO(BKJ
8.0 DESCRIPTION OF SHALLOW AQUIFER TREATMENT AND DISPOSAL
ALTERNATIVES
8.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Section 121(d) of the Superfund Amendment and Reauthoriz'ation
Act of 1986 (SARA) requires the consideration of Applicable or
Relevant and Appropriate Requirements (ARARs) of environmental
laws, ordinances, regulations, and statutes in remedial
actions. In addition, SARA requires consideration of other
pertinent criteria and advisories that are not yet
promulgated. For the Lorentz Barrel & Drum (LB&D) site, ARARs
were used to examine the existing situation, possible remedial
actions, and potential impacts.
The United States Environmental Protection Agency (EPA)
"Interim Guidance on Compliance with ARARs" identifies three
separate categories of ARARs:
o ambient or chemical-specific requirements that set
health or risk-based concentration limits or ranges
for specific chemicals (e.g., Safe Drinking Water Act
Maximum Contaminant Levels);
o performance-, design-, or action-specific requirements
that regulate particular activities (e.g., the Clean
Water Act Pretreatment Standards of Discharge to
Publicly-Owned Treatment Works (POTW)); and
• o location-specific requirements (e.g., POTW discharge
requirements).
Table 8-1 identifies those Federal, State of California, and
local regulatory, advisory, and action levels applicable to the
groundwater at the LB&D site. The following presents
guidelines related to discharge of liquid and gaseous effluents:
o the guidelines on discharge of liquid effluents to
surface water bodies are provided in the Basin Plan
prepared by the California Regional Water Quality
Control Board (CRWQCB). The LB&D discharges to
surface waters must satisfy National Pollution
Discharge Elimination System (NPDES) discharge
requirements. The discharge of water extracted from
the shallow aquifer at the LB&D site to the Coyote
Creek via a storm drain will require satisfaction of
NPDES requirements;
II-8-1
-------
IMLf 8-1
fEKRAl MB SIAfE at CALIFORNIA REOUUTORT. ADVISORY. UO «CII(M IEVEIS FOR ARAIVTES II CROUMnMIER
ARAIYTE
MEIAlt
••••••
Areenlc
••rlui
ChroMluB (tot el)
Cobett
Nolybdenue
Rlckel
Venedlue
line
VOLATILE OMARin
lent en*
Chloroethen*
CMorofone
1.1-Dlchloroethene
1.2-Dlchloro«thene
1.1-Dlchleroelhcnt
Trene-1.2-Dlchloro*thene
1,2-Dlchloropropene
Tctrechloroethene
IICNEft UVU
DETECTED IN
CROUNDUATER «t
INE IUO till
ppb (•)
4.0
160.0
10.0
M.O
20.0
1)0.0
30.0
20.0
26.0 CD
. 24.0
29.0
M.O
270.0
160.0
750.0
ITOiO
UO.O
NICNCST LEVEL
DETECTED
OFFSUE
ppb (b)
.
11.0
EPA NAXIMUN
CMTAMIIMf
IEVEI (e)
P»*
to
1000
SO
5
100
s
1
EPA NAIIMJN
CONJTAIIIRANI
LEVEL GOAIS
SO
»00
120
0
0
7
70
6
0
c* on
ORIWIN
WIEI ACIION
IEVEIS (()
B*
0.70
20
6.0
«.o
WOES
OISCMICE
limit
B*
20
11
7.1(«)
n
MTU tMCf •
raw MM* it
OltCMIGE
DEOUIKMEIIIS
W*
1000
5000
1000
2600
2600
10. «|l
10. (i)
10. (1)
10. (I)
10. (1)
10. (Jl
10.0 (|)
KA11M ADVI!
ACUTE 1 DAT
(EXCtPT WEtE IOTED)
Pf*>
SO
UOO (10 OATI
1000 (10 itay)
.
233
740
2000 (k>
20,000
90 (10
0.0022
0.66
0.19
0.94
0.033
0.8
(•) ChMlecl dit* froi Bonltorlni Mil (Mpllnfl on mi imrtay effcltt (M* TibU 5-4).
(b) Choice! d«t« Itam trcetr Rttnrch wblU I* ftuly oflilt*.
(c) US EPA Nnliui ContMlnmt ll"lt (MCl)i SO CFR 46902; Rovotwr 13. 19M.
(d) US EPA PrepoMd MClOi SO C« 46936; Rovcifcer 13. 1985.
(t) drinking Mt*r Ktlon level* rtcowmdcd by the CellfemU Dtpcrtacnt of Rnltk Scrvle**. October 1987.
(I) Effluent Hal let lone for d lecher t*« te eurfeee wet*re receemiided by Cellfornle *t«lonel Meter Ouellty Control Roerd In the lee In Hen.
Depending, en elte-epeclf Ic fectere. beet evelleble technology (RAD «ey be required to further reduce concent ret lone In the dledierfe,
(t) Induetrlel Wette 0lecher** Rcguletlone for thet Aree Irlbutery to Sen Joee-Sent* Clere Meter Pollution Control Plent. loveeter 1986.
(h) Drinking Meter Reelth Advleorlee fro- US EPA Office of Drinking Meter Ouellty. Subject to Cheng*.
(I) RAIMC: Retlonet Aufclent Meter Ouellty Crlterle US EPA 4*0/5-84-001. Key 1986.
(I) PublIcly-Ouned Treetwnt Morte (POTW) Olecherg* Halt on Totel Chlorlneted Orgenlce It 10 ppb.
(k) Oreft US EPA Itoelth Advisory.
(I) Eelleafed trece velue.
(•) Interlei Unit only. Hnel Halt to be eeteMlttwd be**d jon future bloeeieye of IRIO treeted effluent.
•lenk Specei No eiletlni reoplteennt.
1986. tAlch le currently being revleed.
ROTE I
Phtholetee end dlchloroMthene nor* oaltted froa thle teble due to unrelleblllty of eupportlne dete.
(They eopeer to be leboretory or field contealnente.)
-------
fUlf 8-1
rtociu MD nun or CALIFORNIA (EOUUTORT. ADVISORY. MO ACTION LEVEL* m AMITIES n GMUMHMUI (continued)
ANAim
VOLATILE (MGMin (continued)
1.1.2.2-letrechloroethane
1.1,1-lrlchloro*th*ne
TrlcMoroethene
Vinyl Chlerld*
rrcon 111
PESTICIDES
CMordan*
Toxephene
POLKRIORINATED gYPNENHS
PCS*
NICNEST UVfl
GROUNDWATE* AT
IK IUO fltf
H* <•)
UO.O
120.0
2108.0
1100.0
41.0
0.2
2.0
6.4
DftlCIED
OMSITE
ft*> (b)
w.o
2600.0
520.0
22.0
CONTAMINANT
ICVCl (e)
PI*
200
I
2
J
CONTAMINANT
LEVEL OMlt (d)
H*
200
0
0
0
0
0
c* DNS
IMtEl ACt ION
LEVELS (•)
«*
200
5.00
2.00
18000
0.05S
DISCHARGE
UNITS (f)
H*
!.().<•)
8.0.
8.0.
DISCHARGE
REOUI*ENEN!S (f)
B*
10.0 (It
10.0 (|)
10.0 (|)
10.0 <|>
10.0 (I)
10.0
10.0 (1)
DEALT* AOVII
ACUTE 1 OAT
(EXCEPT ME«E MOTED)
W*
UOOOO (k)
2600 (10
200
cmoNic
CANCER
ppb/70kg
2.8
0.015
0.0218
0.011
EM M
NON-
CANCER
K*>
18*00
0.00*1
0.0002
O.OJ*
WOC (II
CANCER
PI*
0.17
t.T
t.r
2.0
0.000(6
o.ooon
0.000079
(•) Omilcil del* fro» •anllerlnt Mil Mptlnf on mi nnrby of (tit* UN t«bl» 5-«).
(b) Chmlctl d*U frai TrK«r Rnrarch •abll* lab (turfy offcltt.
(e) IIS EPA Nulaui ContMlrant Unit (NCl)i 50 CfR (6902; Nevntor 1]. 1985.
(d) US EPA Propntd NC16: 50 CFR 469M; Novoter 1). 1985.
(•> Orlnklnf Mttr •ellon l«v*lt rccoMicndcd by tt>« Cillfarnl* OtpuHmtHt of Nnlth Strvlcm. Octobtr 1987.
(f) Efflutnt Iliittctlani for dlidiM-tn to rartceo twttri rocunmidtil by CcllfomU Rtf lonal U»t«r Owllty Control 8oord In MM twin Pl«n, Ruvtoinr 1986. Nbldl It currently b»ln§ rev I ltd.
Depending on •Itt-tpeclllc (octori, bMt ovolloblo tcchnolofy (BAT) cvy bo required to further reduce concentration* In the dlichirfe.
(•) Induitrlol Unto BUehwte Regulotlani for thot Aroo Trlbutory to Son Jote-Sent* Clor* Witer Pollution Control Plont. No»e«t>«r 1986.
(h) Orlnklnf Itater Roolth AdvUarlc* Ira* US EPA Office of Drinking Water Outllty. Subject to Change.
(I) NAWOCI National Aslant Utter Quality Criteria US EPA **0/5-86-001. Hay 1986. (10-4 cancer rlak leveti)
(I) Publlcly-Ounad Ireitvent Uorka (POTW) DI (charge Halt on total Chlorinated Organic! la 10 ccfc.
(k) Draft US EPA Health Advlaory
(I) Satlaated trace value.
(•) SetOK detection
Blank Spec*! No editing reojulraaant.
o
•OtEs
Phttotate* and dlchloroMthana Her* oattted fro» thli table due to unreliability of •upportlng data.
(they oHiiai '° be laboratory or field contaminanti.)
-------
o reinjection of water into an aquifer is controlled by
CRWQCB and the provisions of the Safe Drinking Water
Act which require that the quality of water should at
least meet the drinking water standards prescribed by
EPA and California Department of Health Services
(DHS). In addition, the best available technology
must be used for treatment of water prior to
reinjection;
\
o the discharge of treated groundwater to POTW from the
LB&D site is prohibited by San Jose Municipal Code
Ordinance #20710, Title 15, Section 15.12.200; and
o the discharge of volatile organic compounds (VOCs)
into the atmosphere is controlled by the Bay Area Air
Quality Management District (BAAQMD). The releases
from the air stripper at the LB&D site will be subject
to toxic risk assessment as required by the Air
Pollution Control Officer's proposed Guidelines for
Risk Screening and Risk Management. The LB&D air
stripper would have to satisfy the BAAQMD licensing
requirements.
8.2 TREATMENT TECHNOLOGIES
Four alternatives were evaluated in detail in the Engineering
Evaluation and Cost Analysis (EE/CA) (Ebasco, May 1988):
Alternative A: No Action (Periodic Groundwater Monitoring);
Alternative B: Groundwater Extraction; Granular Activated
Carbon (GAC) Treatment; Disposal of
Groundwater to Storm Sewer;
Alternative C: Groundwater Extraction; GAC Guard Bed for
PCB Removal; Air Stripping; Fume
Incineration or GAC Vapor Control; GAC
Polishing Bed; Disposal of Treated
Groundwater to Storm Sewer; and
Alternative D: Groundwater Extraction; Ozone-Ultraviolet
(ozone-UV); GAC Polishing Bed; Disposal of
Groundwater to Storm Sewer.
The primary treatment technologies were chosen on the basis of
removal of organics, to the cleanup objective levels given in
Table 8-2. Subsequent to the May 1988 EE/CA, and performance
of treatability studies and additional groundwater analyses, it
was felt that nickel removal may have to be considered in order
to attain present NPDES effluent limitations. Therefore,
Ebasco has included an example of the type of treatment which
II-8-4
-------
0000231
TABLE 8-2
SHALLOW GROUNDWATER CLEANUP OBJECTIVES
Compound
1,2 Dlchloropropane
Trlchloroethane
Chloroform
1 ,2-D1chloroethane
1 ,l-D1chloroethene
Tetrachloroethene
1,1.2,2-
Tetrachloroethane
Trlchloroethene
Vinyl Chloride
Benzene
PCBs (Total)
Chlordane
Toxaphene
Arsenic
Barium
Chromium (Total)
Z1nc
Cobalt
Nickel
Minerals (pom):
Calcium
Magnesium
Potassium
Sodium
Bicarbonate
Chloride
Sulfate
Silica
pH
* «. Interim llmi
bloassays of
NP . No limit has
(1) - 0.065 ug/1 1
number 0.065
limits of al
Estimated
Contaminant
Concentrations
In Extracted
Groundwater
(ug/1)
25
42
8.0
16
26
17
28
651
155
6.2
0.31
0.01
0.1
0.2
120
3.0
5.0
13
36
Expected
NPDES
Discharge
Limit
(ug/1)
5
5
5
1
5
5
5
5
2
5
0.065
0.014
0.24
20
NP
11
58
NP
7.1*
97
140
1
210
1,293
79
84
26
7.0
Federal
MCLs
(ug/1)
. NP
NP
NP
5
7
NP
NP
NP
2
5
0
NP
5
50
1000
50 (Cr +6)
NP
NP
NP
t only. Final limit to be established based
LB&D treated effluent
been promulgated for
s the method detection
used 1n this table 1s
.
Desired
Treated
Effluent
Level
(ug/1)
5
5
5
1
5
5
5
5
1
5
0.065CD
0.014
0.24
0.23
N/A
N/A
N/A
N/A
7.1*
on future
this compound.
limit for
meant to
aroclor 1242
represent the
only. The
detection
1 the PCB aroclors combined.
II-8-5
*
-------
could be utilized for nickel treatment, in conjunction with
Alternatives B, C, and D. The need to actually utilize such
technology however is pending final determination of an
appropriate NPDES Permit effluent limitation for nickel.
Determination of this effluent limitation will include: an
evaluation of whether the source is controlled to the maximum
extent feasible; an analysis of the costs and benefits of
reducing (treating) nickel concentrations to (as low as) 7.1
ppb; and an assessment of effluent toxicity to fish and/or
invertebrates using bioassay procedures to be prescribed by the
Regional Water Quality Control Board in conjunction with EPA.
In this section, conceptual designs and order-of-magnitude
(-30%, +50%) cost estimates are given for each alternative.
For purposes of comparison, cost estimates include potential
removal of nickel by the candidate treatment technologies
described. Further, they are based on an assumed groundwater
flow rate of 100 gallons per minute (gpm). Results of EPA's
ongoing RI, which includes aquifer pump tests, will provide the
data needed to make an accurate and precise determination of
extraction rates prior to final design of the system.
8.2.1 Alternative A: No Action (Periodic Groundwater
Monitoring)
The "no action" alternative would require that no remedial or
removal actions take place at this time. Adoption of this
alternative will require monitoring of plume migration.
Based on the calculations shown in Table 6-2, the "No Action"
Alternative would fail to reduce the existing public health
risks. However, the ongoing monitoring programs that are
included in the "No Action" Alternative would provide an early
warning if the drinking water aquifer became contaminated.
8.2.2 Groundwater Extraction System
As discussed in Section 5.0, the level of current information
precludes a detailed design for the groundwater extraction
system at this time. The design of the system will be provided
in more detail after the field activities associated with the
RI are performed in October and November 1988. Final design of
the entire system will await the initial installation of
several of the extraction wells. Nevertheless, for the
purposes of the EE/CA, a conceptual design had to be selected
to establish a baseline and estimate costs. The extraction
well system conceptualized for such purposes is shown on
Figure 8-1.
II-8-6
-------
TCA PLUME
(approximate)
VINYL CHLORIDE
PLUME
TCI PLUME
PUMP
STATION
EXTRACTION
HELLS
FORCED
MAIN V 'VTREATMENT
PLANT
LORENTZ BARREL
& DRUM SITE
GROUNDWATER
FLOW
FIGURE 8-1
PROPOSED EXTRACTION
WELL FIELDS
LORENTZ BARREL & DRUM
-------
0000231
The system is designed to prevent the existing plumes from
migrating further, and to remove the existing contaminated
groundwater so it can be treated. To accomplish this, lines of
wells were considered: a pair of wells at the northeast corner
of the site, where groundwater contamination is known to be the
highest; two principal lines of wells, one at the northern end
of the TCE/vinyl chloride plume, and the other along East Alma
Avenue; and two 200-foot-wide lines of wells at • the
downgradient ends of the two smaller side plumes. The
treatment facility will be located on the LB&D site itself.
Order-of-magnitude (-30%, +50%) capital costs for the
groundwater extraction system have been estimated at $803,000.
8.2.3 Alternative B; Groundwater Removal. GAG Treatment.
Nickel Removal, Disposal to Storm Sewer
As shown in Figure 8-2, this treatment alternative consists of
the following series of processes:
o a groundwater interception system identical to that
described in Section 8.2.2;
o ion exchange water softening to prevent scale
formation. The spent resin is regenerated daily using
dilute brine. The spent brine is not a RCRA waste,
but will be disposed of appropriately;
o a GAC guard bed to remove PCBs and pesticides. The
spent GAC from the guard. bed is shipped to offsite
incineration facilities;
o a GAC main bed for VOC removal. The spent GAC from
the main bed is shipped offsite for regeneration once
per year; and
o if necessary,- an ion-exchange column for nickel
removal. The spent resin is regenerated onsite using
dilute acid. The spent regenerant solution is shipped
offsite for recycling and disposal at a licensed
hazardous waste disposal facility.
For this analysis, the influent flow rate is assumed to be
100 gpm. Approximately fifty-two million gallons per year of
groundwater would be treated.
The total estimated order of magnitude capital cost (-30%;
+50%) for this system is $1,902,000. The estimated first year
costs are $255,000. Based on an assumed 10 year project life
and a 10 percent discount rate, the present worth for the
Alternative B system is $3,469,000. Costs for all of the
alternatives are summarized on Table 8-3.
II-8-8
-------
TABLE 8-3
SUMMARY OF COSTS (-30% +50%) FOR
TREATMENT ALTERNATIVES*
•
Capital Costs
First Year
Operation and
Maintenance
Present Worth
B
GAC
1,902,000
255,000
3,469,000
Alternative
C
>GAC/Air Stripping
1,964,000
243,000
3,457,000
D
Ozone-UV/GAC
2,022,000
198,000
3,238,000
* The estimated capital and O&M costs of treating the effluent
for removal of nickel are $200,000. and $54,000/year,
respectively. These are assumed constant among alternatives.
II-8-9
-------
.Brine
Regenerant
Acid
Regenerant
Raw
Water
(100 gpm)
Water
Softening
(Ion Exchange)
Spent
Brine to
POTW
(10,000 gpd)
PCB/GAC
Guard Bed
VOC/GAC
Main Bed
Spent PCB/GAC
to Incinerator
(2,000 Ibs/yr)
Nickel
Removal*
(Ion Exchange)
Treated
Effluent to
Storm Sewer
Spent VOG/GAC
to Recycle
(50,000 Ibs/yr)
Spent
Regenerant to
Disposal
(2,000 gal/yr)
* If necessary
Figure 8-2
Flow Diagram for Liquid-Phase GAG Treatment
-------
8.2.4 Alternative C; Groundwater Removal. Air Strippina/GAC
Treatment. Nickel Removal.. Disposal to Storm Sewer
This alternative includes the following operations:
o a groundwater interception system identical to that
described in Section 8.2.2;
o ion exchange water softening to prevent scale
formation (as discussed in Alternative B, above);
o a GAC guard bed adsorption system to remove PCBs and
pesticides;
o an air stripper with a vapor phase GAC scrubber to
remove most of the VOCs;
o a liquid phase GAC system to remove unstripped VOCs;
o ion exchange nickel removal; and
o. disposal of treated effluent to a local storm sewer.
The flow diagram for this treatment system is shown in
Figure 8-3. Following water softening, a combination of three
systems will be used to remove PCBs/Pesticides and VOCs. A GAC
guard column is first used to remove PCBs/pesticides. Next, a
packed tower air stripper with a vapor-phase GAC scrubber is
used to remove the most easily stripped VOCs from the
groundwater. Finally, VOCs that are not removed by the air
stripper are removed by a downstream GAC polishing column.
Although the May 1988 EE/CA identified fume incineration as a
possible component of this alternative, recently completed
treatability studies showed that a fume incinerator was not
necessary, and that a vapor phase GAC unit would be adequate.
Finally, an ion exchange column can be used to remove nickel if
necessary.
The hydrocarbon exhaust rate from the air stripper/GAC scrubber
will be less than the 15 Ibs/day limit specified by the BAAQMD
for total emissions of smog inducing substances in the
atmosphere. These emissions will concurrently comply with the
10~6 cancer risk limit imposed by the Toxic Risk Screening
Policy of the BAAQMD.
As shown in Table 8-3, the estimated capital cost for this
alternative is $1,964,000. First year operation and
maintenance costs are estimated at $243,000. The present worth
of this alternative is $3,457,000 using a 10-year life and a 10
percent discount rate.
II-8-11
-------
Brine
Regenerant
Clean Au-
to Exhaust
Raw
Water
(lOOgpm)
Water Softening
(Ion Exchanger)
PCB/GAC
Guard Column
Spent Brine to
POTW Disposal
(10,000 gal/day)
Vapor Phase
GAC Scrubber
t
Spent GAC to
Recycling
(24,000 Ibs/yr)
Dilute Acid
Regenerant
Air
Stripper
Fan
VOC/GAC
Main Column
Nickel Removal*
(Ion Exchange)
Treated Effluent
to Storm Sewer
Spent GAC
toOffsite
Incinerator
(2,000 Ibs/yr)
Spent Regenerant
* to Recycling
(2,000 gal/yr)
Spent GAC
to Recycle
(12,000 Ibs/yr)
o
* If necessary
Figure 8-3
Flow Diagram for GAC/Air Stripping Treatment
-------
0000231
8.2.5 Alternative D; Groundwater Removal. Ozone-UV/GAC
Treatment. Nickel Removal. Disposal to Storm Sewer
The flow diagram for this treatment alternative is shown in
Figure 8-4. A combination of two technologies would be used:
first, a commercially available packaged ozone-UV system to
destroy VOCs and PCBs/pesticides; and second (if necessary), an
ion exchange column to remove .nickel. Ozone-UV treatment has
been shown to be effective for destruction of PCBs/pesticides
and VOCs such as 1,1,1-TCA, TCE, and vinyl chloride. Also,
treatability studies conducted in August 1988 determined that
GAC polishing was not necessary. Based on discussions with
equipment manufacturers, it is assumed that pretreatment for
water softening should not be needed.
Estimated capital cost for this alternative is $2,022,000
(Table 8-3). First year operation and maintenance costs are
estimated at $198,000. Assuming a 10-year life and a 10 percent
discount rate, the present worth of this alternative is
$3,238,000.
II-8-13
-------
Ozone
Generator
Acid
Regenerant
Raw Water
(100,000 gpd) ^
o
o
o
o
0
0
o
o
0
o
o
0
o
w
Nickel
Removal *
(Ion Exchange)
^ Treated
Effluent to
Storm Sewer
UV-OZONE
SYSTEM
i
t
Spent Acid
to Recycling
(2,000 gal/yr)
* If necessary
Figure 8-4
Flow Diagram for Ozone/UV Treatment System
CO
-------
0000231
9.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
9.1 COMPARISON OF ENGINEERING EVALUATION/COST ANALYSIS
AND FEASIBILITY STUDY GUIDANCE CRITERIA
The United States Environmental Protection Agency (EPA)
guidance criteria for evaluating remedial alternatives for
Engineering Evaluation and . Cost Analysis (EE/CA) and
Feasibility Studies (FS) are presented below for comparison.
FS Guidance Criteria
o Short-term effectiveness
o Long-term effectiveness
and permanence
o Reduction of toxicity,
mobility, or volume
o Implementability
o Cost
o Compliance with Applicable
or Relevant and Appropriate
Requirements (ARARs)
o Overall protection of
human health and
environment
o State acceptance
o Community acceptance
EE/CA Criteria
(non-time-criticaV)
o Technical feasibility
- Effectiveness
- Demonstrated
performance
Operation and
maintenance
requirements
- Useful life
- Environmental effects
upon operations
- Constructability
o Reasonable cost
o Institutional
considerations
- Permitting and other
factors
affecting startup
- Time to complete
- Safety
o Environmental impacts
The major differences between the EE/CA guidance and the FS
guidance are that there are no requirements to meet ARARs or to
perform a Risk Assessment in the EE/CA. As shown above, the
evaluation criteria are otherwise very similar. Since the
Lorentz Barrel & Drum (LB&D) EE/CA included consideration of
ARARs and provided preliminary risk assessments, the
alternative actions have been evaluated by all of the FS
criteria.
9.2 COMPARISON EVALUATION METHODOLOGY
The evaluation method used is based on the method under
development by United States Environmental Protection Agency
(EPA) as EE/CA guidance for non-time-critical removal actions.
This method uses a set of criteria based on technical
feasibility, cost reasonableness, institutional considerations,
and environmental impacts. Table 9-1 presents the criteria and
associated ratings.
II-9-1
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0000231
TABLE 9-1
TECHNOLOGY SELECTION CRITERIA*
Rating
Criteria Points
1. TECHNICAL FEASIBILITY
A. Effectiveness
. Destroys hazardous substances 4
. Prevents release of hazardous substances; 3
contaminants are isolated but not
eliminated
. Minimizes the release of hazardous 2
materials; adequately protects public
health and environment
. Allows or promotes release of hazardous 1
substances; ineffective.
B. Demonstrated Performance
. Proven reliable in the field under similar 4
conditions on the same waste materials;
widely demonstrated to be effective
. Proven reliable in the field under similar 3
conditions on similar waste materials
. Proven reliable, but under different 2
conditions and materials; limited
experience and reliability
C. Useful Life
. Permanent; irreversible 4
. Long-term, potentially reversible; 3
effectiveness decreases in time
with a low probability of release
. Long-term, potentially reversible with a 2
high probability for release
. Short-term solution; difficult to repair or 1
replace upon failure; temporarily mitigates
hazards; long term abilities questionable
D. . Environmental Effects Upon Operations
. Performs well under all environmental 4
conditions
. Performs well under most environmental 3
conditions
. Performs adequately under most conditions 2
. Susceptible to adverse weather conditions 1
II-9-2
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0000231
TABLE 9-1 (Continued)
TECHNOLOGY SELECTION CRITERIA*
Rating
Criteria Points
2. REASONABLE COST
This item is discussed but not scored
3. INSTITUTIONAL CONSIDERATIONS
A. Permitting and Other Factors Affecting Start-up
. No permitting or significant lead time 4
required
. Minimal lead time required (3 months) 3
. Moderate lead time required (6 months) 2
. Significant lead time required (1 year) 1
B. Time to Complete
. Can be completed within the 12-month 4
statutory limit
. Site is expected to qualify for an exemption 3
to the 12-month limit and an alternative can
be completed within a reasonable time
thereafter
. Site is expected to qualify for an exemption, 2
but requires significant time beyond the
12-month limit to complete
. Cannot be completed within the 12-month 1
statutory limit and the site is not expected
to qualify for an exemption
C. Safety
1) During Installation/Operation
. Very safe; requires no more than normal 4
safety procedures required for workers
at hazardous waste sites; no threat to
surroundings at any time
. Safe; requires few safety procedures 3
other than those normally required at
hazardous waste sites; minor threat
to adjoining residential areas may occur
. Hazardous; requires stringent safety 2
procedures to ensure worker safety; may
II-9-3
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0000231
TABLE 9-1 (Continued)
TECHNOLOGY SELECTION CRITERIA*
Rating
Criteria Points
require evacuation of homes near the site
. Very hazardous; requires remote operation 1
'and evacuation of area homes
2) Effects of Failure
. Very safe; redundant controls prevent 4
hazardous substance release
. Failure results in hazard that is less 3
than that presented by the site prior to the
removal action
. Failure results in hazard that is 2
approximately
equal to that presented by the site prior the
removal action
. Failure results in hazard greater than that 1
presented by the site prior to the removal
action
D. Other relevant institutional considerations
may be added
4. ENVIRONMENTAL IMPACTS
Positive environmental impact 4
No detrimental environmental impact 3
Minimal adverse environmental impact 2
Extreme adverse environmental impact 1
Based on guidance from EPA for the EE/CA
II-9-4
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0000231
9.3 COMPARISON OF ALTERNATIVES
Staff from EPA and Ebasco met on August 30, 1988 to discuss the
alternatives and select one for implementation. During that
meeting, GAC and ozone/UV treatability test results of July and
August 1988 were presented by the respective vendors. The
results of those tests indicate that action levels can be
achieved by either technology. Consequently, none of -the
alternatives was eliminated based solely on ability to' treat
groundwater to desired levels.
An evaluation similar to that presented in section 6 of the
EE/CA was performed. This evaluation assessed each alternative
in light of the EE/CA evaluation criteria. The results are
presented in Table 9-2. All of the treatment alternatives were
scored essentially equal. Present worth estimates are also
approximately the same, within the accuracy of the estimates
that were prepared.
Three primary distinctions can be made among the alternatives
however. These are:
o GAC systems have been proven reliable over a longer
time period than the ozone/UV system;
o the ozone/UV system provides onsite destruction of
contaminants, as opposed to transporting wastes for
offsite destruction of contaminants through
regeneration of the carbon; and
o GAC/air stripping could require additional air
emission controls in order to comply with BAAQMD
standards.
Two other water treatment considerations were identified during
the treatability testing. One involved influent treatment; the
other involved possible effluent treatment. The GAC testing
revealed a carbonate precipitate in the test column. As a
result, it was recommended that a water softening step be
included prior to the GAC options. The ozone/UV system did not
experience scaling during the treatability testing. Both
processes require further consideration of effluent
concentrations of nickel as well. This issue will be examined
through additional groundwater sampling and analyses, and
bioassays of treated effluent. If results of these studies
show that nickel removal is necessary, a treatment system such
as that described in Section 8.2.3 will be included in the
process prior to discharge of the effluent.
In consideration of all of the -factors, EPA has decided that
the best course of action is to demonstrate the ozone/UV
II-9-5
-------
TABLE 9-2
COMPARISON OF ALTERNATIVES
Alternative A
No Action
Technical Feasibility
. Effectiveness
. Demonstrated Performance
. Useful Life
. Environmental Effects
on Performance .
Subtotal Score
Institutional Considerations
. Permitting and Startup
. Time to Complete "
. Safety
Subtotal Score
Environmental Impacts
TOTAL SCORE
Estimated Costs
1
1
1
-1
4
2
2
-2
6
1
11
Alternative C
Alternative B GAC/Air
Liquid Phase Stripping/
GAC Vapor Control
.3
x 4
3
_4
14
4
4
_4
12
4
30
3
4
3
_4
14
3
4
_4
11
4
29
Alternative 0
Ozone-UV
X
4
3
3
_4
14
4
4
_4
12
4
30
Capital Cost * 1,902,000 1,964.000 2,022,000
First Year Operation and
Maintenance • 255,000 243,000 198,000
Present Worth Costs $170,000 3,469,000 3,457,000 3,238,000
•These costs will depend on:
- the number of monitoring wells;
- the frequency of monitoring; and
- which chemical analyses are chosen.
II-9-6
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0000231
technology through the Superfund Innovative Technologies
Evaluation (SITE) program. This selection was made for the
following reasons:
o the technology provides onsite destruction of
contaminants;
o a several week(s) demonstration will allow EPA to
determine the reliability of the ozone/UV system;
o it appears that ozone/UV may not require water
softening. However, the demonstration will allow EPA
to determine whether an eventual carbonate scaling
problem can be dealt with through pH adjustment rather
than water softening;
o there will be no long-term commitment of taxpayer
dollars until the testing program conclusively
demonstrates the success of the technology; and
o should ozone/UV not prove adequate based on further
testing, Alternative B (Liquid Phase GAC) provides an
adequate backup remedy.
EPA's selected remedy is described in detail in Section 10.0.
9.4 TREATED EFFLUENT DISPOSAL
Of the four treated effluent disposal options, only two are
technically and administratively feasible: discharge to the
storm sewer and Coyote Creek; and groundwater recharge by
reinjection wells. Each of the four options are described
below.
Storm Sewer/Coyote Creek - This is the least expensive and most
reliable option. It would only require that a force main be
constructed to the nearest storm drain. The California
Regional Water Quality Control Board (CRWQCB) discharge
requirements for surface water disposal would have to be
satisfied.
Groundwater Reinfection - This option is feasible. Effluent
disposal would be performed by pumping the treated effluent
back into the shallow aquifer, using a series of reinjection
wells. Because of the need for extra wells and pumps, this
option would be expensive and more subject to mechanical
problems than would the "storm sewer" option. The pretreatment
standards established by the CRWQCB would have to be
satisfied. As an alternative to using reinjection wells, there
are currently several large municipal groundwater recharge
basins within a few miles of the LB&D site. The LB&D effluent
could conceivably be pumped off site to one of those
II-9-7
-------
facilities. However, this would be impractical because it
would require construction of miles of force main through
residential areas.
Publicly Owned Treatment Works (POTW) Sanitary Sewer - This
option is not feasible. Discharge of any groundwater,
pretreated or not, to the POTW sanitary sewer is forbidden by
the San Jose Municipal Code Ordinance #20710, Title 15, Section
15.12.200.
Industrial Reuse - This option is technically feasible but it
would be expensive and impractical. The treated effluent could
conceivably be stored and used by local industries for process
water. However, it would require construction of large storage
tanks and complex water distribution piping systems. This
option would not be .practical, since there are no industries
near the LB&D site that require a large, steady volume of
process water. The disposal of the LB&D effluent would
therefore be limited by the fluctuating water needs of many
small businesses.
In summary, the most practical and least expensive alternative
for treated effluent disposal during the Expedited Response
Action (ERA)/Operable Unit is disposal to the storm
sewer/Coyote Creek. Industrial reuse and groundwater injection
will be studied in more detail during the Feasibility Study.
Any pf these options could be selected as a long-term solution
to the disposal question.
II-9-8
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0000231
10.0 THE SELECTED REMEDY
The selected remedy consists of the following items: a
groundwater extraction system; an above-ground treatment system
(ozone/UV plus nickel removal); and treated effluent disposal
to the storm sewer. As mentioned in Section 8.2, until a final
decision is reached between EPA and CRWQCB concerning
appropriate effluent limitations for nickel, it is assumed that
NPDES discharge limits will ^require nickel removal. Each of
these items are described in the following sections.
The selected remedy was chosen for the following reasons:
o the contaminated shallow groundwater will be contained
and removed, thereby minimizing the potential for
future contamination of deeper drinking water aquifers;
o the ozone/UV treatment system will treat all VOCs to
below the MCLs and NPDES discharge limits, and will
treat PCBs/pesticides to below detectable levels;
o. as discussed in Chapter 9.0, the ozone/UV treatment
system received the highest overall rating among the
alternatives, and has the lowest estimated present
worth cost; and
o the ozone/UV treatment system can be field tested for
reliability under EPA's Superfund Innovative
Technology Evaluation (SITE) program.
As discussed in Section 8.2.2, the groundwater plume will be
intercepted and collected using the extraction system shown in
Figure 8-1.
As shown in Figure 8-4, a combination of two technologies would
be used: First, a commercially available packaged ozone/UV
system to destroy VOCs and PCBs/pesticides; and second, an ion
exchange treatment system to remove nickel. Ozone/UV treatment
has been shown to be effective for destruction of PCBs/
pesticides and halogenated hydrocarbons such as 1,1,1-TCA, TCE,
and vinyl chloride.
EPA and other agencies have supported a variety of tests, which
have shown that ozone/UV treatment is effective for permanent
destruction of VOCs and PCBs/pesticides in wastewater and
groundwater. Treatability tests using LB&D groundwater were
performed in July and August 1988. These tests showed that
VOCs could be destroyed to below the NPDES discharge limits.
In 1980, at a General Electric plant in Hudson Falls, New York,
a commercial ozone/UV treatment plant was installed and
successfully operated to destroy PCBs in groundwater to below
detection levels.
II-10-1
-------
000(631
The contaminated groundwater will initially be pumped to an
equalization tank. This tank will provide roughly 30 minutes
of storage and will dampen any short-term variations in flow
rates or contaminant concentrations. A commercially-available
packaged ozone/UV treatment system will be used to destroy
PCBs/pesticides and other organic compounds. The ozone/UV
treatment method utilizes ozone's strong oxidizing capacity
with UV light's additional energy to provide considerable
amounts of free radicals and excited-state species capable of
effectively destroying the contaminants present.
Ozone is provided by an onsite generator and bubbled through
the wastewater. The ozonated wastewater is then subjected to
high intensity UV light in a packaged treatment vessel. The UV
light originates from an array of quartz-enclosed low-pressure
mercury lamps. It is assumed that ozone/UV treatment will
destroy the PCBs/pesticides, vinyl chloride, 1,1,1-TCA, and TCE
in the influents. The residence time of the water in the
ozone/UV unit is 40 minutes. The wastewater is treated using
an oxidant dosage of 75 mg/1 of ozone plus 25 mg/1 of hydrogen
peroxide. Contaminant destruction occurs inside the treatment
vessel.
EPA will be working with CRWQCB to determine NPDES limits for
nickel. If necessary, nickel can be removed using a packaged,
commercially available ion exchange system. Additional
treatability studies will be required to select the best ion
exchange resi'n. Based on discussions with resin manufacturers,
the resin will be contained in conventional columns. The spent
resin will be regenerated several times each year, using dilute
acid as the regenerant solution, and will consist of a
neutralized nickel sulfate solution. The spent solutions will
be shipped to an offsite recycling firm if further data suggest
that economical recovery of the nickel sulfate is possible. If
not, the waste will be disposed of in accordance with existing
solid and hazardous waste legislation.
The ozone/UV system will be delivered prepackaged and installed
skid-mounted. The ozone/UV treatment system, the nickel
removal columns, and all required pumps and controls will be
housed in a prefabricated building. The treatment plant site
will be fenced to prevent public access.
The estimated capital and operating costs for the extraction
and treatment systems are listed in Table 10-1. The capital
costs for the groundwater extraction system are based on Ebasco
engineering estimates. The capital and operating costs for the
treatment system are based on manufacturers' estimates.
II-10-2
-------
TABLE 10-1
ESTIMATED (-30%, +50%) COSTS FOR OZONE/UV
TREATMENT ALTERNATIVE
Capital Costs
I/Direct
Site preparation
Groundwater extraction system
Flow equalization
Ozone/UV equipment
Nickel removal system
Levels, controls (etc.)
Building
Disposal force main
$10,000
803,000
5,000
300,000
200,000
20,000
80,000
5.000
$1,423,000
2/Indirect
NPDES Permit application
Engineering Construction Management
(15% Direct costs)
Contingency (25% Direct Costs)
Total estimated Capital Costs
30,000
213,000
356.000
$599,000
$2.022.000
O&M Costs (Annual)
Operating labor
(2 days/week @ $300/day) $31,000
Ozone power/year ($0.263/1000 gals) 14,000
Hydrogen Peroxide/year
($0.125/1000 gals) 7,000
Ultraviolet power/year
($0.266/1000 gals) 14,000
Ultraviolet maintenance 16,610
(including lamp replacement
and labor)
Replacement of Nickel removal
resin ($100,000/2 years) 50,000
II-10-3
-------
TABLE 10-1 (Continued)
ESTIMATED (-30%, +50%) COSTS FOR OZONE/UV
TREATMENT ALTERNATIVE
O&M Costs (Annual) (Continued)
Processing of spent resin
reactivation ^solution
($2/gal, 2000 gals/year) 4,000
Treated effluents analysis
(I/week e$300) 16,000
Groundwater sampling
(40 wells/year $2,500/well) 20,000
System maintenance
(5% 03/UV and Nickel
removal equipment
Capital Costs) 25.000
$198.000
Present Worth (i = 10%, 10 yrs) $3.238.000
II-10-4
-------
00231
The estimated capital cost for the selected remedy is
$2,022,000. The estimated first year operating cost is
$198,000. The estimated present worth cost (assuming a 10 year
project life and a 10 percent discount) is $3,238,000.
Treated effluent will be disposed of by pumping directly to the
nearest storm sewer. The treated effluent will satisfy all of
the required NPDES discharge .standards. It is assumed that
periodic monitoring will be required to document compliance
with the pretreatment standards.
II-10-5
-------
0000231
11.0 STATUTORY DETERMINATIONS
The statutory requirements of Section 121 of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) state that the selected remedy must:
o be protective of human health and the environment;
o attain Applicable •- or Relevant and Appropriate
Requirements (ARARs);
o be cost-effective;
o utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent possible; and
o address whether the preference for treatment that
reduces toxicity, mobility, or volume as a principal
element is satisfied.
11.1 .PROTECTIVENESS OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy is protective of human health and the
environment by preventing further vertical or horizontal
migration of contaminants in the shallow aquifer and treating
the extracted groundwater prior to disposal. It also prevents
migration of contamination into the deeper drinking water
aquifer and Coyote Creek. By stopping the migration of
contaminants and treating the extracted groundwater, the
selected remedy reduces the potential threats posed by
contamination of Coyote Creek and the drinking water aquifer.
11.2 ATTAINMENT OF ARARS
The selected remedy will meet all substantive ARARs for the
shallow groundwater, as discussed in Section 8.1.
The numerical limits that apply to the shallow groundwater are
specified on Table 8-2. The results of the treatability study
will demonstrate that this remedy achieves those action limits.
11.3 COST EFFECTIVENESS
All of the treatment alternatives are essentially equal with
respect to total present worth costs. No distinction can be
made among these alternatives from the cost point of view
within the accuracy of the estimates that were prepared. All
treatment alternatives are therefore equally cost effective.
II-ll-l
-------
(W0231
The selected approach, which is to perform a demonstration of
ozone/UV through the SITE program, is especially cost
effective. It defers capital expenditures until the technology
is demonstrated over a reasonably long term. Such an approach
reduces the ultimate risk borne by the taxpayer by increasing
the level of knowledge about this technology at the LB&D site.
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
The selected remedy meets the Superfund Amendment and
Reauthorization Act of 1986 (SARA) preference for permanent
solutions to the maximum extent practicable. It is expected to
remove the contaminants from the groundwater and to effectively
destroy them or convert them into harmless substances posing no
threat to human health and the environment.
11.5 PREFERENCE FOR TREATMENT THAT REDUCES TOXICITY, MOBILITY,
AND VOLUME AS A PRINCIPAL ELEMENT
The selected remedy focuses on treatment of the contaminated
shallow groundwater to specified action levels. This treatment
technology is expected to reduce the toxicity of the
contaminants by rendering them harmless. Mobility is reduced
by use of the selected groundwater extraction system,
preventing the further spread of the plumes. Also, by
extracting and treating the shallow grpundwater, it is likely
that the volumes of the plumes will be reduced.
II-11-2
-------
0000231
12.0 REFERENCES
California, State of. Department of Water Resources (DWR).
August 1967. Evaluation of Groundwater Resources: South Bay
Geology. DWR Bulletin #118-1, Appendix A.
Canonie Environmental. August 1987. Draft Report, Remedial
Action Plan. Submitted to Fairchild Semiconductor Corporation,
San Jose Facility. Project No. 82-012.
CH2M Hill. February 1987. Preliminary Site Assessment Report.
Lorentz Barrel & Drum (LB&D). Prepared for California
Department of Health Services (DHS) Contract No. 84-84540,
Task 2-5-2.0-P21039.
. November 1987a. Technical Memorandum: Preliminary
Hydrogeological Assessment. LB&D. Prepared for DHS Contract
No. 84-84540, Task 2-5-4.0-P21039.
. November 1987b. Technical Memorandum: Soil Gas
Survey. LB&D. Prepared for DHS Contract No. 84-84540,
Task 2-5-4.0-P21039.
. November 1987c. Technical Memorandum: Well
Canvass, Volume I. LB&D. Prepared for DHS Contract
No. 84-84540, Task 2-5-4.0-P21039.
. November 1987d. Technical Memorandum: Treatment
Alternative. LB&D. Prepared for DHS Contract No. 84-84540,
Task 2-5-4.0-P21039.
Ebasco Services, Inc. May 1988. Engineering Evaluation and
Cost Analysis for a Shallow Groundwater Collection and
Treatment System, LB&D. Prepared for United States
Environmental Protection Agency (EPA) under the REM III
Contract No. 68-01-7250, EPA Work Assignment No. 203-9L64.
Freeze, R.A. and J.A. Cherry. 1979. Groundwater. Prentice-
Hall, Inc.
Plunkett, E.R. 1976. Handbook of Industrial Toxicology.
Chemical Publishing Company, New York.
Prengle, H.W. and C.E. Mauk. 1978. New Technology: Ozone/UV
Chemical Oxidation Wastewater Process for Metal Complexes,
Organic Species and Disinfection. The American Institute of
Chemical Engineers Symposium Series, 74 228-243.
Sitting, M. 1981. Handbook of Toxic and Hazardous Chemicals.
Noyes Publications, Park Ridge, New Jersey.
II-12-1
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0000231
Stenzel, M. and U. Gupta. December 1985. Treatment of
Contaminated Groundwater with Granular Activated Carbon and Air
Stripping. JAPCA. 35(12), 1304-1309.
Tracer Research Corporation. November 1987. Groundwater
Investigation at Lorentz Barrel & Drum. Submitted to CH2M Hill,
Turner, D.B. 1970. Workbook of-Atmospheric Dispersion
Estimates. Prepared for EPA. x
United States Environmental Protection Agency. April 1980.
Carbon Adsorption Isotherms for Removal of Toxic Compounds from
Water Supplies. EPA/600/8-80-023. PB-80-197320.
. 1985. Chemical, Physical, and Biological
Properties of Compounds Present at Hazardous Waste Sites:
Final Report. Office of Solid Waste and Emergency Response,
Washington, D.C.
. 1986. Superfund Public Health Evaluation Manual
EPA/540/1-80/060. Office of Emergency and Remedial Response
Washington, D.C.
March 1987. Data Quality Objectives for Remedial
Response Activities; EPA/540/G-87/003 (OSWER Directive
9355.0-7B).
II-12-2
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0000231
LORENTZ BARREL & DRUM
ENGINEERING EVALUATION/COST ANALYSIS
RECORD OF DECISION
PART 3
RESPONSIVENESS SUMMARY
-------
0000*0
1.0 INTRODUCTION
From June 1, 1988 through June 30, 1988, the United States
Environmental Protection Agency (EPA) sponsored a public
comment period on EPA's Draft Engineering Evaluation and Cost
Analysis (EE/CA) for the shallow groundwater contamination at
the Lorentz Barrel & Drum (LB&D) Superfund site in San Jose,
California. Region IX has . determined that the EE/CA is
substantively equivalent to a fast track operable unit
feasibility study. The EE/CA evaluates four alternatives for
addressing shallow groundwater contamination at the LB&D site.
Each alternative contains a component for the removal and
treatment of the contaminated groundwater, which lies
approximately 40 feet below the ground surface, and the
disposal of the treated water. The purpose of the public
comment period was to give interested parties the opportunity
to comment on the EE/CA.
The EE/CA is a study that examines various ways that the
contamination problem in the shallow aquifer can be addressed
while a remedy for the remainder of the site is being
developed. The purpose of the EE/CA is to select a remedy for
the shallow groundwater contamination that is protective of
human health and the environment, attains Federal and state
Applicable or Relevant and Appropriate Requirements (ARARs),
and is cost-effective. Because the full extent of the
contamination at the LB&D site is not yet known, EPA has chosen
to accelerate the remediation process by addressing the shallow
groundwater contamination as a separate unit. Remedial
alternatives for the other contaminated media at the site will
be examined in a separate site Feasibility Study (FS) Report,
which will be issued in late 1989.
A Responsiveness Summary is required under EPA Superfund
regulations for the purpose of providing both EPA and the
interested public with a review and summary of community
concerns about the site .and comments on the EE/CA. In addition
to summarizing citizen concerns and questions, the
Responsiveness Summary presents EPA's responses to those
concerns.
The Responsiveness Summary for the EE/CA conducted at the LB&D
site is divided into three sections:
Background on Community Involvement and Concerns. This section
provides a brief history of community interest in and concerns
about the LB&D site.
Overview of the LB&D EE/CA. This section provides a brief
history of the LB&D site, summarizes the contents of the Draft
EE/CA, and identifies EPAs preferred alternatives.
• III-l-l
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0000231
Summary of Comments Received and EPA Responses. This section
categorizes and summarizes written and oral comments received
during the public comment period and provides EPA's responses
to these comments.
Appendix A contains an index and copies of the pages from the
public hearing transcript that contain the specific comments
made.
III-1-2
-------
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Lorentz Barrel & Drum (LB&D) site, one of the many sites in
the South San Francisco Bay area affected by groundwater
contamination, has been highly visible in the local press and
among citizens living in the vicinity of the site since a
contamination problem was identified in 1980. Concerns have
been registered with the California Regional Water Quality
Control Board (CRWQCB), City, Council representatives and other
local agencies on a regular basis, and indicate that the
community has been concerned primarily with the potential
effects of the shallow groundwater contamination on its
drinking water.
Moreover, residents of the area for the most part have not
distinguished between the shallow and deeper aquifers. They
believe that contamination at any level would affect the safety
of their drinking water supply. Agency representatives have
sought to assure residents that the deeper aquifer supplies
residents with their drinking water and that, to date, there is
no evidence to indicate contamination in the deeper aquifers.
Between 1980, when California Division of Occupational Safety
and Health (OSHA) informed the California Department of Health
Services (DHS) of potential hazardous material problems at the
LB&D site, and 1987, when technical progress initiated more
contact between the agencies and community members, few
community relations activities were conducted at the site.
However, investigations, sampling efforts, and remedial actions
were conducted jointly by DHS, the CRWQCB, and the United
States Environmental Protection Agency (EPA) when the
responsible party refused to comply with cleanup regulations.
As a result of the multi-agency participation during this time,
some community members raised the concern that the
responsibility for problems at the site had been shifted among
the agencies so much that no one agency had been exercising
adequate leadership.
In 1987, community involvement increased significantly when DHS
released a Preliminary Site Assessment for public review, held
an agency briefing to present a status report on the LB&D site
investigations, published a series of fact sheets and updates
detailing technical progress at the site, and drafted a
Community Relations Plan (CRP) for the site. The CRP is based
on interviews conducted by the DHS with community members,
elected officials, and agency representatives. It summarizes
past community concerns and discusses current and potential
issues in the community related to the site.
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0000231
In June 1987, DHS held a public meeting to provide the
community with information regarding the site investigation and
Preliminary Site Assessment Report. Over 100 community members
attended the meeting. Several attendees expressed
dissatisfaction with the length of time that the agency was
taking to investigate and cleanup the site. They also
expressed their concerns about the status of the drinking water
in the area and the effects that water might have on fruit and
vegetable gardens near the vsite. On September 3, 1987, DHS
held another public meeting (with roughly 100 attendees) to
discuss the proposed actions for drum and sump removal. The
public expressed dissatisfaction with the format of the
meeting, claiming that it did not provide an appropriate forum
for public involvement. In response to this concern, DHS
hosted an informal community open house on November 18, 1987 to
answer community questions, especially those related to health
issues.
On December 1, 1987, EPA was designated as the lead agency
responsible for site investigation and cleanup. DHS and EPA
distributed a joint fact sheet in February informing the public
that responsibility for the site had been transferred. On
February 25, 1988, a public meeting was held to discuss the
changes in responsibility for the site cleanup. Approximately
25 people attended this meeting.
Since EPA became involved at the site, it has conducted a
Limited Sampling Program, taking soil and water samples from
private fruit gardens, community gardens, a local grocery
store, and nearby Coyote Creek. EPA prepared and distributed a
fact sheet in June 1988 explaining the Engineering Evaluation
and Cost Analysis (EE/CA) and detailing the remedial
alternatives proposed for the shallow groundwater contamination
problem. A public meeting, attended by roughly 30 people, was
held on June 15, 1988 to discuss the- proposed remedial
alternatives and to give community members an opportunity to
comment formally on these alternatives. Results from the
produce and creek sampling and a presentation of opportunities
for community involvement also were presented. A few community
members at the meeting stated that they were generally pleased
with EPA's approach to community relations activities at the
site.
The following list summarizes concerns raised during interviews
conducted in DHS's preparation of the April 1987 CRP and in
community meetings.
o Groundwater Quality - The primary concern at the LB&D
site is the.quality of the groundwater supply and the
potential for contamination to move to the deeper
aquifers, which supply residents with a portion of
their drinking water. Many residents fear the
potential short- and long-term health effects from
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0000231
contamination. Some community members fear the
possibility of contamination spreading to food
•products, because some of the active wells serve food
processing facilities. Other residents .living near
the site have expressed concern about the potential
for contamination to affect private fruit and
vegetable gardens, as well as public gardens.
Residents also have .expressed concern that inactive
wells could allow .. contaminants to leach into the
deeper aquifer. Some community members affiliated
with San Jose State University are concerned about the
'effects of the contamination on a University
recreational area. Drinking water for the
recreational facility is provided by a university
owned well which is screened in the deeper drinking
water aquifer below 200 feet and located within 1 mile
of the site.
o Need for Frequent Monitoring - Some community members
believe that frequent groundwater monitoring is
necessary to characterize the extent of contamination
at the site accurately. These individuals believe
that frequent monitoring would enable EPA to identify
the spread of the contamination plume in a timely
manner.
o Duration of Investigation - Some citizens criticized
the government agencies for spending too much time and
money on investigations without achieving any tangible
results.
o Inefficiency of Agency Involvement - Prior to the
increase in community relations efforts in 1987, some
community members expressed frustration that their
concerns regarding the safety of drinking water near
the site had not been adequately addressed by the
agencies involved. Local media attention emphasized
the extent of the problem and minimized discussion
about agency activity.
The San Jose Mercury News and the Spartan Daily, the San Jose
State University newspaper, have presented most of the coverage
on the shallow groundwater contamination at the LB&D site.
Generally, the level of media coverage has corresponded to
technical progress made at the site and the occurrence of
public meetings and agency briefings. Media coverage
concerning the site was particularly active during August 1987,
as a result of the death of Mr. Ernest Lorentz, owner of LB&D,
who had been placed in custody by the Santa Clara County
District Attorney for . his refusal to comply with cleanup
requirements of the site.
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0000231
The following is a list of community relations activities
conducted to date by DHS and EPA at the LB&D Superfund site.
February 10, 1987
April 1987
June 1987
June 24, 1987
August 1987
September 3, 1987
October 1987
November 1987
November 18, 1987
December 1, 1987
DHS presents status report on site
investigation at an agency briefing. Those
present included representatives from: EPA,
DHS, Santa Clara County Health Department,
Santa Clara County Executive's Office, Santa
Clara Valley Water District, Bay Area Air
Quality Management District (BAAQMD), San
Jose City Manager's Office, San Jose
Attorney's Office, San Jose Planning
Department, San Jose Office of Environmental
Management, and the San Jose Fire Department.
DHS drafts CRP based on interviews that DHS
conducted with community members and agency
representatives regarding activities at the
site.
DHS distributes the first fact sheet
explaining technical progress and the
February 1987 release of the Preliminary
Site Assessment Report.
DHS holds a public meeting to explain the
Preliminary Site Assessment Report and
technical progress made at the site to date.
DHS distributes an update explaining
planned removal actions at the site.
the
DHS holds a public meeting to discuss the
proposed removal actions.
DHS distributes an update on the proposed
transportation route for the removal actions.
DHS distributes an update informing the
public that EPA will be taking the lead as
the agency responsible for further
investigation and cleanup.
DHS holds an open house/public forum for
community members to question or comment on
activities at the site.
EPA becomes the lead agency responsible for
site investigation and cleanup.
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0000231
February 1988
February 25, 1988
March 1988
May 1988
June 1988
June 15, 1988
June 30, 1988
EPA and DHS publish a joint fact sheet that
explains the transfer of agency
responsibility. The fact sheet also
explains EPA's plan to pave most of the site
to prevent surface water runoff and leaching.
EPA and DHS hold a public meeting to explain
the transfer of lead agency, EPA's role in
the Superfund process, recent paving
activities, and EPA's plans for further
activities.
EPA distributes letters to some residents
requesting permission to sample private
fruit and vegetable gardens.
EPA conducts Limited Sampling Program
testing water and soil samples from private
gardens, community gardens, and Coyote Creek.
EPA distributes a fact sheet summarizing the
EE/CA for shallow groundwater contamination.
EPA holds a community meeting to discuss the
EE/CA and EPA's proposed cleanup solution,
and to accept public comments on the
proposed alternatives.
EPA conducts municipal well sampling program
testing water from area drinking water wells.
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0000201
3.0 OVERVIEW OF THE LORENTZ BARREL & DRUM ENGINEERING
EVALUATION AND COST ANALYSIS
The contemplated Expedited Response Action (ERA)/Operable Unit
is a shallow groundwater collection and treatment system. The
objective of the Engineering Evaluation and Cost Analysis
(EE/CA) was to consider various potential removal action
options for this system, screen them, evaluate specific options
in greater detail, and compare those that appear to offer the
greatest benefits. Figure 3-1 diagrams the general EE/CA
process.
In the EE/CA, the potential technologies under consideration
were judged on their ability to achieve compliance with
identified clean-up standards. The San Jose publicly-owned
treatment works (POTW) acceptance criteria were also included
in the action-specific review. The situation-specific nature of
the threat was reviewed to evaluate whether the need to protect
public health and the environment required more stringent
requirements than the ARAR's.
The .EE/CA first reviewed the site characterization. After
formulation of removal action objectives which arose from
review of the site characterization various technologies were
considered and initially screened against the prescribed ERA
evaluation criteria. The screened technologies that survived
were used to develop various ERA alternatives as combinations
of technologies. These alternatives were evaluated, additional
data requirements were identified, and a limited sensitivity
analysis was performed as part of the comparison of
implementation costs for the alternatives.
III-3-1
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IDENTIFY
SITE
PROBLEMS
IDENTIFY
GENERAL
RESPONSE
OBJECTIVES
IDENTIFY
TECHNOLOGIES AND
PROCESS OPTIONS
SCREEN PROCESS OPTIONS
PUBLIC HEALTH PROTECTION
TIMELINESS
TECHNICAL FEASIBILITY
INSTITUTIONAL ACCEPTABILITY
DEVELOP ALTERNATIVES
BY COMBINING
PROCESS OPTIONS
EVALUATE AND
COMPARE ALTERNATIVES
COMPLIANCE WITH ARAR'S
REASONABLE COST
ENVIRONMENTAL EFFECTS
INSTITUTIONAL ACCEPTABILITY
SELECT
TENTATIVE
ALTERNATIVE
EXAMINE
COST
SENSITIVITY
FOR TENTATIVE
ALTERNATIVE
o
FIGURE 3-1
ENGINEERING EVALUATION/COST
ANALYSIS PROCESS
LORENTZ BARREL & DRUM
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0000231
4.0 SUMMARY OF COMMENTS RECEIVED AND THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY RESPONSES
4.1 COMMENTS FROM THE JUNE 15, 1988 PUBLIC MEETING
1. Comment:
One community member asked whether, after the water is
treated, and assuming that the flow rates are
sufficiently low, evaporation could be considered as a
disposal alternative. [10]
United States Environmental Protection Agency (EPA)
Response:
The assumed flows for the Expedited Response Action
(ERA)/Operable Unit (100 gallons per minute (gpm)) are
too large for effective use of an evaporation pond.
The required amounts of land are not available in the
site vicinity. As a result, evaporation ponds were
not considered viable for the ERA. During the
Remedial Investigation (RI) and the operation of the
ERA groundwater extraction system, more information on
groundwater flows and potential pumping rates will be
developed. Evaporation ponds will be considered in
the Feasibility Study (FS) as a long-term disposal
option.
2. Comment:
Another community member, referring to the potentially
large-scale plumbing effort necessary to transport
contaminated water from the wells to the treatment
plant, asked whether the construction activity could
be kept to a level that would be tolerable -to the
neighborhood. [11]
EPA Response:
The piping associated with the extraction well system
will be similar to that for a local water supply
system. Construction of the required pipelines will
involve digging 5-foot trenches at appropriate
locations. As with any public works construction
project, it will be planned to minimize disturbance in
the residential areas. After this temporary
disturbance, the water transmission system will be
hidden from view.
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0000231
3. Comment:
A representative of the Silicon Valley Toxics
Coalition asked what cleanup goals EPA was following
in its evaluation of cleanup technologies, and urged
EPA to consider an approach that combines the
California Regional Water Quality Control Board's
(CRWQCB) policy of "nondegradation" with the -"best
available technology" approach. He also asked that,
if EPA does a comparative cost estimate on these
approaches the community be allowed to comment on
'those results. [12]
EPA Response:
Prior to discharge, the groundwater will be treated to
meet the most stringent of any of the applicable
regulations. The treatment system incorporates the
"best available technology" for removal of organic
compounds and trace metals. The CRWQCB requires that
the treated effluent contain no detectable pesticides
or PCBs. The CRWQCB discharge limits are designed to
ensure that the treated effluent will cause no
degradation of Coyote Creek.
4. Comment:
That same comraenter, referring to the air stripping/
fume incinerator alternative, asked that EPA use the
best available technology guidelines to treat the air
emissions from the fume incinerator. He also
suggested that the level of treatment attained by
incineration should exceed the guidelines set by the
Air Board. [13]
EPA Response:
As described in Section 6.0 of the Decision Summary,
the risk presented by the air emissions from the air
stripper is the result of the volatile organic
hydrocarbons (VOCs) stripped from the groundwater.
There are two ways to remove these compounds from the
air: fume incineration; or granular activated carbon
(GAC). However, EPA is concerned about GAC's
effectiveness in removing vinyl chloride. As a
result, gas-fired incineration was tentatively
selected as the Best Available Technology for reducing
these emissions. As stated in Section 6.0 (and
presented in more detail in Section 5.4.3 of the
III-4-2
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0000231
EE/CA), the Bay Area Air Quality Management District
(BAAQMD) has set a criterion of an allowable cancer
risk of 1 x 10"6. The calculated risk from the
uncontrolled emissions (before use of the fume
incinerator) is 2.8 x 10~6, which is only slightly
above the BAAQMD limit of 1.0 x 10~6. The
destruction efficiency of a fume incinerator could
reduce the cancer risk well below the BAAQMD
guidelines. However since the EE/CA was written, the
effectiveness of GAG for removal of VOC vapors has
been evaluated by treatability tests during the summer
-of 1988. Results of these studies indicated that GAC
would effectively remove VOC vapors to below BAAQMD
limits, thus rendering use of a fume incinerator
unnecessary.
5. Comment:
The community group representative also asked whether
EPA could consider reinjection of the water into the
shallow aquifer as an alternative to disposal. [14]
EPA Response:
A discussion of the groundwater reinjection option, as
it compares with other disposal options, is presented
in Section 9.4 of the Decision Summary. There are
several different ways to reinject the treated
effluents. For example, it could be reinjected either
upstream or downstream of the contaminated zone. Each
different method has its own advantages and
disadvantages. Groundwater reinjection, as well as
the effects of extraction on the shallow aquifer, will
be evaluated in detail during the RI/FS process.
Based on the current level of knowledge and cost
considerations, it was not selected for the ERA. It
may or may not be selected for the long-term remedial
action chosen as a result of the RI/FS.
6. Comment:
One community member asked if tests had been conducted
to determine whether contaminated groundwater is
rising to the surface and evaporating off, which, she
said, would be potentially harmful to people who use
the track and tennis courts on a regular basis. She
also asked what kind of tests had been conducted west
of the designated plume. [15]
III-4-3
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0000231
EPA Response:
Soil gas sampling has been performed on site in a
westerly direction/ and was used to define the
boundary of the small western TCA plume. (See Figure
5-3 of the Decision Summary.) Additionally, the
health risk assessment to be performed during the
RI/FS process will evaluate the vapor inhalation
pathway for exposure to humans. This assessment will
model volatilization from the plume and diffusion
•through the soil and into the atmosphere. It will
then evaluate the predicted ambient concentrations of
chemicals in light of known or expected vapor
inhalation risks. The objective of this study is to
estimate risks associated with this potential pathway
before and during implementation of remedial actions.
Results of this evaluation will be made available to
the public during the RI/FS.
7. Comment:
One community member asked which government body is
responsible for recovering costs from those
potentially responsible parties who sent drums to the
Lorentz Barrel & Drum (LB&D) site. [16] He asked
whether EPA knew the names of these companies and
whether; if they were contacted, the companies had
been willing to inform EPA of the contents of the
barrels. [16] He also asked whether the tags
attached to the barrels provided any information on
the barrels' contents. [17]
EPA Response:
Both EPA and DHS plan to cost recover. EPA has a list
of approximately 800 potential responsible parties who
utilized the LB&D recycling plant. EPA is in the
process of refining and prioritizing this list and
plans to contact companies, in a phased approach.
There is very little information on barrel contents on
the tags.
8. Comment:
One community member asked why the "no-action*
alternative cost $170,000.
III-4-4
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EPA Response:
The no-action alternative requires continuing
monitoring of plume migration. The cost is associated
with the installation of several monitoring wells, and
periodic sampling and analytical work related to
long-term monitoring requirements.
9. Comment:
One community member said he feared that test wells
and borings could potentially contribute to the spread
of aquifer contamination. [18]
EPA Response:
Properly designed and constructed wells will not cause
cross-aquifer contamination. When a well is
constructed, a casing is placed outside the well
pipe. After the well pipe is installed, the space
between the well pipe and the casing is filled with
grout. The casing is then removed. The well is
screened (i.e., where the water flows into the well)
only 10 to 20 feet in one of the aquifers. With a
properly constructed and installed well, no
cross-contamination occurs.
10. Comment:
One community member, asserting that neighboring
businesses use chemicals similar to those found at the
LB&D site, asked why the LB&D property has been
targeted for cleanup over other areas in the City. He
recommended that EPA simply, pave over the site as a
. parking lot, with a gravel base and a top layer of
concrete. [19]
EPA Response:
Lorentz Barrel & Drum was targeted for cleanup because
of noncompliance with hazardous waste management
regulations. There are several Superfund sites in the
South Bay, as well as sites under state orders
requiring cleanup actions. If additional information
is gathered indicating other sources of potential
chemical contamination in areas near the Lorentz site,
those sources will be investigated. Investigations of
this sort may result in a site being added to the
federal or state Superfund list. Paving over the
Lorentz site will not result ' in cleaning up the
groundwater contamination plume which, has migrated
III-4-5
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0000231
offsite. The potential threat that exists to public
health and the environment would not be alleviated by
this alternative.
11. Comment:
One community member questioned why spent carbon
solids could not be .incinerated at a location on the
LB&D site rather than at an incineration facility in
Texas.[20]
EPA Response:
It would be very difficult and expensive to obtain a
licensed mobile hazardous waste incinerator to come to
the site to incinerate such a small amount of GAG.
Mobilization costs are a major component of overall
mobile incineration costs. On a per-ton basis, the
resulting costs would be prohibitive.
12. Comment:
That same commenter, referring to the proposed
treatment alternatives, asked that EPA consider more
closely: the pollution caused by natural gas during
incineration; the number of British thermal units
(Btu) per hour dispersed into the air following
incineration; Bay Area standards set for pollution in
the air; and the possibility of simply using
evaporation treatment on the water. [22]
EPA Response:
From AP-42 (an . EPA compilation of air pollutant
emission factors), the following pollutant emissions
can be expected from a natural gas incinerator.
Emissions in Emissions in
lb/106 cu ft lb/106 Btu
Particulate 1 to 5 0.001 to 0.005
Sulfur dioxide 0.6 0.0006
Nitrogen oxides 100 to 140 ' 0.1 to 0.14
Carbon monoxide 20 to 40 0.02 to 0.04
VOCs - methane 2.7 to 3 0.0027 to 0.003
- nonmethane 2.8 to 5.3 0.0028 to 0.0053
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0000231
At a rate of 32,000 Btu/min, or 1.92 x 10~6 Btu/hr,
the AP-42 estimated emissions from the burning of
natural gas are:
Estimated Emissions
in Ib/hr
Particulate 0.0019 to 0.0096
Sulfur dioxide v 0.0012
Nitrogen oxides 0.192 to 0.269
Carbon monoxide 0.038 to 0.077
VOCs - methane 0.0052 to 0.0058
- nonmethane 0.0054 to 0.0102
All of the energy consumed in the incinerator
would be released to the atmosphere, either
through the flue gas or radiant heat loss from
the incinerator and its peripherals.
Bay area standards for carcinogenic emissions are
addressed in the risk assessment (Section 6.0 of
the Decision Summary). None of the pollutant
emissions listed in the table would exceed the
BAAQMD limit of 15 Ib/day.
The use of evaporation for treated groundwater is
addressed in the answer to question 1 in this
section.
Results of treatability studies have shown that
the incinerator should not be necessary.
13. Comment:
One community member said that the "No action"
alternative should be considered more seriously as
being in the public's best interest at this time. [22a]
EPA Response:
The "no action" alternative was not selected for this
ERA because it would do nothing to alleviate threat
that the shallow groundwater poses to the deeper
drinking water aquifer. The "no action" alternative
will be considered during the RI/FS.
14. Comment:
One representative of a community organization wanted
to know the nature of the emissions coming out of the
old incinerator that operated on the site. He also
wanted to know the composition of the ash that is
still on the ground. Finally, he wanted to know if
III-4-7
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0900231
EPA is going to take shallow soil samples downwind of
the site to determine if there is any metals
contamination. [23]
EPA Response:
Based on current knowledge/ EPA does not know what .the
emissions from the onsite incinerator were. EPA has
already sampled ash from the incinerator. The samples
contained minimal organic contaminants, at
concentrations far below EPA's cleanup limits.
However, the samples contained high concentrations of
lead and zinc. As part of the RI, additional samples
of the ash will be taken and analyzed to determine its
composition. Shallow soil samples will also be taken
around the incinerator's location and analyzed to
determine if there is metals contamination present.
If the results of these analyses are positive,
additional samples will be taken (concentrically from
the source) in order to assure that the area of
contamination is fully defined. A detailed
description of planned RI sampling activities is
contained in the RI Field Sampling and Analysis Plan
(FSAP), which was published in June 1988.
15. Comment:
One community member, referring to the Fort Detrick,
Maryland studies on the epidemiological effects of
airborne bacteria, asked what contaminants might be
released from an onsite air stripper. [24]
EPA Response:
The contaminated groundwater at the site is not
expected to contain any harmful bacteria. This, in
conjunction with adequate equipment maintenance,
suggests that release of airborne bacteria from an air
stripper operation would be very unprobable if this
alternative had been chosen. As pointed out in
Sections 9 and 10 of the ROD, however, this
alternative was not selected by EPA following
treatability studies.
16. Comment:
That same commenter, referring to the ozone-
ultraviolet (ozone-UV) and GAC treatment alternative,
suggested that "reactive ion etching* would be a more
effective treatment technology because this technology
utilizes more radicals and, therefore, has a faster
III-4-8
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0900231
reaction time and is not dependent on an ultraviolet
light source. This commenter also questioned how the
natural gas and electrical facilities would be
impacted if the ozone/UV treatment alternative were
chosen. Specifically, he expressed concern about
potential power shortages affecting the local
community and industries. [25]
EPA Response:
EPA is not familiar with the term "reactive ion
etching." The commentor is possibly referring to
ozone-peroxide oxidation, which uses free radicals to
decompose organic compounds. EPA has investigated
ozone-UV treatment, which is known to be more
effective than ozone-peroxide treatment. The treat-
ability studies will determine whether ozone-UV is the
best technology. If it is, the vendor of the
treatment system will be responsible for generating
the ozone on site.
Remedial activities will not use enough natural gas or
electric energy to have any adverse affects on service
to the community.
17. Comment:
One commenter, referring to EPA's plan to conduct well
surveys, suggested instead that the site be isolated
from the existing aquifers using a dolomite pump to
isolate the clay soil from the sandy soil — much like
a slurry wall. [26]
EPA Response:
At the time the Engineering Evaluation and Cost
Analysis (EE/CA) was finalized, there was not enough
information available to determine whether or not
slurry walls, or any other containment technology,
would be effective. As a result, containment was not
considered viable for the ERA. Additionally, the
Superfund Amendment and Reauthorization Act of 1986
(SARA) favors the implementation of remedies that
permanently treat the contamination, as opposed to
remedies that merely contain it. However, a
significant amount of new information will be
generated during the RI. That new information will
allow containment technologies to be considered during
the FS.
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0000231
5.0 RESPONSES TO COMMENTS FROM SILICON VALLEY TOXICS COALITION
LETTER OF JUNE 30. 1988
The Silicon Valley Toxics Coalition (SVTC) letter of June 30,
1988 is reproduced as Exhibit 1. The questions have been
numbered and the responses in this section relate to those
numbers.
1. As part of the Phase I Field Investigation of the Remedial
Investigation (RI), a well survey will be performed. After
these wells have been identified, an assessment will be
made, regarding whether they could serve as vertical
conduits between the shallow and deeper, aquifers.
„ Appropriate action to prevent cross aquifer contamination
will be taken. Section 4.1.3.5 of the Final Work Plan
provides more details on this survey.
The concern of vertical cross contamination between
aquifers is addressed in question 9 (pg III-4-4) of the
nrevimifi section.
2.
previous section.
3. The Field Sampling and Analysis Plan (FSAP) for the RI/
finalized in August of 1988, presents a detailed
explanation of all sampling and analytical work that will
be performed during the RI. Sample locations are shown on
Figures 3-10 through 3-15 of the FSAP. The monitoring
wells will include several locations similar to those
proposed by the SVTC.
4. The groundwater extraction system is presented in Section
8.2.2 of the Decision Summary. As stated in that section,
the conceptual design prepared for the Engineering
Evaluation and Cost Analysis (EE/CA) was based on limited
information. The final design will be based on information
gathered during the field investigation of the RI, through
October 1988. The final number of wells will be determined
at that time.
5. Several points should be made in responding to this
question. First, if the treated water was reinjected into
the same aquifer (i.e., shallow aquifer) from which it was
drawn, it would probably not be used as drinking water.
(Potable water supply wells utilize the deep aquifer.)
However, if water was reinjected at all, it would need to
be of a quality which is in compliance with state and
federal regulations. Bench-scale treatability studies
performed in July/August, 1988 indicated that treated
effluent can meet Maximum Contaminant Levels (MCLs)
established under the Safe Drinking Water Act, as well as
DHS drinking water action levels. Further studies will be
performed, however, to ensure attainment of these levels.
Specifically, an onsite pilot-scale demonstration of
III-5-1
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the treatment alternative recommended in the ROD is being
planned by EPA Region IX in conjunction with EPA's
Superfund Innovative Technologies Evaluation (SITE)
program. Results will confirm whether the treatment
technology can attain stipulated water quality standards.
6. As stated in the answer to question 5 (pg III-4-3) in the
previous section/ the available information indicates that
reinjection of the treated effluent would be less reliable
and more expensive than discharge to the storm sewer and
Coyote Creek. The effluent will be treated to below all
regulatory limits. Each of the treatment alternatives
investigated in the EE/CA incorporate backup systems to
ensure that no untreated water is accidently discharged to
the creek.
7. As stated above/ reinjection will be considered in the
RI/FS. The SVTC's "Percolation Ditch Plan" will be
considered as one of the reinjection options.
III-5-2
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S^con
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EXHIBIT 1
0000231
vey
Toxics
Coalition
7^0 North First Street.
Sffond Floor
San lose. California 95112
(406) 267-6707
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0000231
Mary Masters -2- 30 June 1988
Comments:
I think it is necessary to keep the treated water as close to the
site as possible and not have possible contamination in other areas
of the valley. The alternative to placing treated water into
Coyote Creek seems to be a means of giving the water to people
downstream.
Attached is an idea I hope can be useful in the cleanup procedure.
XI. Percolation ditch plan
Treating the pollution as close to the site as possible after
pumping the water out, and then letting it percolate back into
the ground, will hopefully flush the contaminants out of the
soil.
The positive aspects of this plan are that the water is recycled
and kept near the site.
Drilling monitoring wells beyond the pumping wells will aid
in keeping track of any escaping contaminants into the deep
aquifter.
The percolation ditch is "V" shaped and perforated for strength
and faster percolation, respectively.
Thanks for your consideration.
Sincerely,
Bruce Beale Ted Smith
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0900231
6.0 RESPONSES TO COMMENTS FROM REED CORPORATION LETTER OF
JUNE 30. 1988
The Reed Corporation letter of June 30, 1988 is reproduced as
Exhibit 2. The questions are numbered, and the responses in
this section refer to those numbers.
1. The shallow aquifer is not in use as a drinking water (or
bathing) source at the current time. However, the
Superfund Public Health Evaluation Manual, which provides
guidance in assessing risks, requires the United States
Environmental Protection Agency (EPA) to consider the
ingestion, dermal, and inhalation pathways anyway. It is
possible that some development may occur in the future, and
this development could expose the public to risks from
contaminated groundwater through the stated pathways.
2. The desired cleanup level for arsenic for use during the
Expedited Response Action (ERA) is 0.23 parts per billion
(ppb) (230 parts per trillion (ppt)) (see Table 8-2 of the
Decision Summary). This represents an estimated cancer
risk of 10~4. Since the treated groundwater will be
discharged to a surface water body during the ERA, the
cleanup requirements were derived by comparing National
Pollution Discharge Elimination System (NPDES) limits with
the 10~4 cancer risk level. The more stringent level was
then selected.
3. The levels reported on in Table 2-3 of the Engineering
Evaluation and Cost Analysis (EE/CA) (Table 5-3 of the
Decision Summary) are merely summaries of older data
published by other contractors. In the case of barium,
Table 8-2 of the Decision Summary shows that there is no
desired cleanup level.
4. Please see the response to question 1 in this section.
5. 6.4 ppb represents the total of all types of poly-
chlorinated biphenyls (PCBs) (1221, 1242, etc.) from well
MW-4B in Table 2-3 of the EE/CA (Table 5-3 of the Decision
Summary). While it is true that several of the more highly
chlorinated PCB compounds have solubilities less than 6.4
ppb, the Handbook of Environmental Data on Organic
Chemicals (2nd Edition, Van Nostrand Reinhold Company, New
York, 1983) provides the following solubilities for the
specific PCB compounds found at the Lorentz Barrel & Drum
(LB&D) site:
III-6-1
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Solubility at 24°C
Compound (PPD)
PCB 1221 590
PCS 1242 100
PCB 1254 57
PCB 1260 80
6. Superfund contractors are required in many cases by EPA to
use certain methods to monitor quality control (QC)
available only at EPA specified contract labs. In
determining groundwater quality to identify contaminant
plumes/ for example, EPA would not allow the use of 2 to
3-year-old data taken by private contractors and analyzed
outside the contract lab program. The statement in the
EE/CA does not indicate that the work was poorly done; it
merely indicates that it can only be used to a certain
extent (i.e., to show the presence of contamination) and
that more monitoring is required.
7. The purpose of the EE/CA is to establish the need for the
ERA. It did not include a detailed investigation into the
presence of upgradient sources. Such an investigation will
be part of the Remedial Investigation (RI).
8. The purpose of the order of magnitude cost estimates was to
assess feasibility only. The estimates incorporated the
assumptions stated in the EE/CA. The RI will define the
location of the plume in more detail.
9.. The concern is based on the current level of information
about the aquitard. The writer seems to agree in the
second paragraph of his letter, that "the relationship
between the upper and lower aquifer is not well known."
Since this is the case, EPA did not want to risk the lower
aquifer because of a lack of information.
10. According to the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) and the
Superfund Amendment and Reauthorization Act of 1986 (SARA),
the source of the vinyl chloride in the groundwater is only
important as it relates to the potential to cleanup a
source area and the potential for the government to recover
cost from a potentially responsible party. If the
groundwater is contaminated, it must be addressed. The RI
field program will locate whatever sources remain on site.
With regard to the other comment on health risks, please
see the answer to question 1 of this section.
III-6-2
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0000231
11. The risk levels shown on Table 5-1 of the EE/CA are based
on a preliminary risk assessment. A more detailed and
complete' risk assessment will be prepared as part of the-
RI/Feasibility Study (FS). Also/ see the answer to
question 1 of this section.
12. Please see the discussion in Section 8.2.2 of the Decision
Summary. A significant amount of additional work will be
performed before the groundwater extraction system is
finally designed. Please see the answer to question 5 in
Section 4.0 of this Responsiveness Summary for a discussion
of groundwater reinjection. As stated in the EE/CA, these
costs are based on Ebasco Services, Incorporated experience
and related RI/FS work in the region.
13. Please see the discussion in Section 5.4.3 of the EE/CA
which shows that Bay Area Air Quality Management District
(BAAQMD) requirements lead to the conclusion that the fume
incinerator is necessary. As stated on page 5-24 of the
EE/CA (May, 1988), a granular activated carbon (GAC) system
for the off gas. was not selected because of some concern
that it might ' not be effective in absorbing vinyl
chloride. However, as a result of treatability studies
undertaken in July/August 1988, the capability of a vapor
phase GAC to cost-effectively remove vinyl chloride has
been established. In view of this finding, fume
incineration is no longer considered to be a necessary
component of the vapor control system.
14. The LB&D site has been proposed for inclusion on the
National Priorities List (NPL). The question of the
relative risk of LB&D as compared with other Silicon Valley
sites was addressed when the site was proposed in 1984.
III-6-3
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EXHIBIT 2
OOOOJ»31
REED CORPORATION
Kiivliuiiiiiimlul Kii
2140 ShuUuck Avenue. Suite 504
Berkeley. CA 94704
(4 IS) 524-0450
•r,,,,o in lonn Mobile (415) SCO-U25
June jo, 1980 Telecopy (4J5) 232-3796
U.S.E.P.A.
215 Fremont Street (t-1-3) CONFIRMING COPY
San Francisco, CA 94105 ORIGINAL SENT BY
TELECOPY ON 6/30/88
ATTN: Ms. Gail Louis
Community Relations Coordinator
Subject: Comments on the EE/CA for the Lorentz Superfund Site
Dear Ms. Louis:
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0000331
Ms. Gail Louis
June 30, 1988
page 2
not appear to be realistic concerns with respect to public
health.
Specific concerns of regarding other contaminants are as follows:
o Arsenic - while the Department of Health Service (DOHS)
has an action level of 2.0 parts per trillion in
the California Administrative Code Title 22
drinking water standards (64435 Table 2)
show that the maximum contaminant level (MCL) is
0.05 ppro or 50,000 parts per trillion. The MCL
would appear to be a more realistic goal for
discharge to non-potable water such as would occur
in the Lorentz matter.
o Barium - The reported levels of 160 ppb of barium from the
C112MH111 reports appear to be above the solubility
of barium in this ground water. Equilibrium would
be approximately 100 ppb or less in the presence
of sulfates. Additionally, the Title 22 standard
for barium is 1000 ppb, which would appear to be a
more realistic human health concern level.
o Vinyl Chloride - The EBASCO report states that the MCL for
Vinyl Chloride is 1 ppb; USEPA MCL is 2 ppb
effective 12/31/88. In any case the concerns over
actual health hazards from the reported, levels of
vinyl chloride appear to be overstated due to the
fact that the ground water is not used for
drinking and the highly volatile nature of vinyl
chloride which would cause it to be readily
out-gassed during any normal usage of the water.
o PCB - The level of 6.4 ppb of PCB does not appear in Table
2-3 of the EBASCO report. The highest level shown
is 4.0 ppb. These results appear to be higher
than '-would normally be anticipated for PCB
solubility in water.
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Ms. Gail Louis
June 30, 1988
page 3
p. 2-24 2.4.2 Analytical Data Review
Monitoring Well Analyses
I take strong exception to the statements that "The quality of
the ground water analyses from investigations prior to the CH2M
Hill study is poorly known, because sampling activities were
minimally documented. Original lab reports for the work done by
Associated Laboratories and Brown and Caldwell are not available
at this time, and the results were transcribed from handwritten
notes and faded photocopies.1* I personally transmitted via
facsimile copies of information requested by Ms. Robin Scott of
EBASCO in January 1988. At that time I informed ner tnat copies
of all lab data sheets were available at the DOHS or RHQCB files,
and that I assumed that she had ready access to this information.
X never heard back from Ms. Scott, and therefore assumed that she
got what she wanted. Additionally, all appropriate documentation
of sampling was submitted to the RWQCB and all information was
available from the files of the LorentT consultants with minimal
additional effort from EBASCO.
p. 2-27 2.4.3 Extent of Shallow Aquifer Ground Water
Contamination
Reference is made to Figures 2-6a and 2-6e show contamination
VOC starting substantially to the south of the Lprentz site near
the area of the bus (private) maintenance facility (see Figures
2-6d and 2-6e specifically). No mention of upgradient
contamination is made, why is that and to what source is this
likely due to?
p. 2-33 2.4.4 Contaminant Extent Data Caps
It is indicated that the extent of the plume must be determined
before a final treatment system design can be completed. How can
a meaningful cost estimate be developed without knowledge of the
extent of the plume? How does one assume the length of the plume
(i.e. the distance of pipelines to return to the site) or the
number of wells without this information, and why hasn't this
information been determined in the work completed over the last
two years by DOHS and EPA?
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0000231
Ms. Gail Louis
June 30, 1988
page 4
p. 2-33 2.5.2 Potential Impacts
The premise that the contaminated plume will reach potable
drinking water is weak and quite implausible given the local
hydrogeological conditions. To assume that there is sufficient
VOC material present in the ground water where the highest
concentration of total VOCs is less that 4 ppm (MW-4 TMA 7/86) is
frankly ludicrous. There are dozens of sites in the Silicon
Valley where 50 times this levels of VOC materials are present in
the ground water. Additionally, in the 40 years of Lorentz
operation there has never been any indication of any potential or
actual deep aquifer contamination.
p. 5-3 5.2 Alternative A: Mo Action (Periodic Ground Hater
Monitoring)
Reference is made to Table 5-1 regarding relative risk, however,
closer review of Table 5-1 would indicate that essentially all of
the risk is related to Vinyl Chloride which most likely being
produced naturally by biological processes in the soil from
materials released to the ground water by someone in the a'rea.
Vinyl Chloride accounts for 7.24*10-2 of 7.83*10-2 (or 92 percent
of the estimated risk). Clearly, this conditions dramatically
overstates the relative health risk of the non-potable ground
water in this area.
I strongly disagree with the assumptions made in this section.
First, no single sample was utilized for this comparison. It
appears to make little sense to add up the highest data from
unrelated samples (spatial and time variations in all samples).
Second, the assumption that the very deep drinking water would be
contaminated to the same degree as the shallow aquifer is silly.
Clearly, by simple dispersion dilution of the water would occur
and substantial adsorption of these materials would occur during
the vertical movement of these materials in the unsaturated zone
between the shallow and deep aquifer.
Third, because the water has nearly 2000 ppm of TDS it is not
logical that one would ever drink any of this shallow ground
water or that anyone would ever drink the estimate 51,100 liters
per life time used in this estimate (nearly 14,000 gallons).
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0000231
Ms. Gail Louis
June 30, 1988
page 5
Fourth, no existing public health risks have been identified or •
pathway quantified even.though a comment is made to this effect
in the text.
p. 5-5 5.3 Alternative B: Ground Water Removal; GAC Treatment
Disposal to Storm Sewer
Zt is indicated that no pumping tests have been completed and
that this would be required prior to final design. Why hasn't
this been done to date? Our analysis indicates that 50 gpm or so
is likely to be the maximum flow available from the site with a
reasonable number of wells (less than 10). How was the number of
80 wells derived without the pump test data?
It does not appear that the data support the requirement for the
80 wells shown on Figure 5-1 nor does hydrogeological or chemical
data support the relative spacing of the wells with the exception
of the approximate location of the plume in the northerly
direction (recall that EBASCO previously stated that the extent
of the plume was unknown). It is very unlikely that the wells
will produce anything near to the five gpm assumed.
On p. 4-9 the concept of ground water reinjection was discarded;
however, closer review may indeed indicate that this is the only
effective alternative from the hydrogeolgical standpoint.
Several costs in Table 5-3 appear to be quite high. The cost of
well installation per foot is approximately $125 (based on
summing $55,500+126,000+107,000+163,000 and dividing by 80*45
feet • 3,600 feet). No well diameter information is given in the
report. Assuming that four inch wells were constructed a cost pf
one half of this amount would be more typical.
Additionally, the cost of $252,000 for 80 wells results in a
cost of over $3,000 for a pump and installation. My experience
indicates that $2,000 is more typical. No cost is shown for
electrical installation and no information is presented on the
cost per foot of pipe trench.
The parameters for the design of the GAC units appear to be
within standard ranges.
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