United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/RO9-89/041
September 1989
&EPA Superfund
Record of Decision:
Beckman Instruments, CA
-------
5»272-10t .
REPORT DOCUMENTATION
_ PAGE
1. REPORT NO.
EPA/ROD/R09-89/041
3. Recipient* AccMdon No.
4. Title and Subtitle
.SUPERFUND RECORD OF DECISION
Instruments (Porterville) , CA
Remedial Action - Final.
i. Report D*tD
09/26/89
7. Author)*)
8. Performing Orgmiadoh Rept No.
9. Performing Orgiinintlon Nun* end
ia Pro|ecta*»k/Worti Unit No.
11. Contnct(C)orGrant(G)No.
(C)
(G)
12. Sponsoring Organization Name end Addree*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report* Period Covered
800/000
14.
15. Supplementary Note*
16. Abtlrict (Limit: 200 word*)
The Beckman Instruments (Porterville) site, which includes the Beckman plant and
surrounding study area, is in the city of Porterville, California. The 12-acre Beckman
plant has manufactured electronic instrument assemblies and circuit boards since 1967.
Wastewater from industrial processes including electroplating and degreasing, contains
>ent halogenated solvents, inorganic and acid solutions, salts, metal-laden solutions,
plating bath sludges. From 1974 to 1983, wastewater was discharged to an onsite
lar evaporation pond; however, since 1983, wastewater has been treated onsite. Ground
water in the vicinity of the pond was used for domestic and agricultural purposes until
1983 when ground water was found to be contaminated. Beckman subsequently closed the
pond, provided alternate water supplies to approximately 300 residents in the area, and
began ground water pumping and treatment using air stripping in 1985. Additionally, soil
beneath the former pond as well as near a former pesticide operation area are known to be
contaminated with elevated levels of lead. The primary contaminants of concern affecting
the soil and ground water are VOCs including TCE, and metals including lead.
The selected remedial action for this site includes excavation and offsite disposal of
lead-contaminated soil; continued operation of the ground water pumping and treatment
system for the upper aquifer; pumping and treatment of ground water from upper aquitard
and lower aquifer using air stripping; offsite (Continued on next page)
17. Document Anilyci* a. Descriptor*
Record of Decision - Beckman Instruments (Porterville), CA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (TCE), metals (lead)
b. Identifiera/Open-Ended Term*
COSATI Held/Group
Availability Statement
19. Security On* (Thl* Report)
None
20, Security d*M (Thto Pige)
None
21. No. ol Page*
74
22. Price
(See ANSI-Z3».1S)
S*w Instruction* on Avwnw
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-3S)
t of ConwiiBr C9
-------
16. Abstract (Continued)
EPA/ROD/R09-89/041
Instruments (Porterville) , CA
discharge of all treated water into infiltration basins or irrigation canals; and ground
water monitoring. The estimated present worth cost for the selected remedy is
$4,740,000. This estimate does not include costs for continued operation of the existing
pumping and treatment system.
-------
BECXMAN INSTRUMENTS SITE
PORTERVILLE, CALIFORNIA
RECORD OF DECISION
United States Environmental Protection Agency
Region IX — San Francisco, California
,. - September 1989
-------
RECORD OF DECISION
TABLE OF CONTENTS
Section Page
DECLARATION 1
I. SITE LOCATION AND DESCRIPTION 4
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
IV. SCOPfe AND ROLE OF OPERABLE UNIT RESPONSE ACTION 7
V. SITE CHARACTERISTICS 7
VI. SUMMARY OF SITE RISK 10
VII. DESCRIPTION OF ALTERNATIVES 14
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 16
IX. THE SELECTED REMEDY 21
X. STATUTORY DETERMINATIONS 23
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 23
ATTACHMENTS
Administrative Record Index
Response Summary
List of Tables
Table
1 Maxianufc. Contaminant Concentrations in Groundwater
-•?-.
2 Constfltftnts Detected above Background Levels
in Si«r*3oil
3 Toxicity Values for Beckman Site Contaminants
4 Clean Up Goals and Water Quality Criteria
-------
RECORD OF DECISION
DECLARATION STATEMENT
Site Name
Beckman Instrument^ site
Site Location
Porterville, California
Statement of Basis and Purpose
This decision document presents the selected remedy for
contaminated groundwater and soil 'at the Beckman Instruments
Site. The document was developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) , and to the extent
practicable, the. National Contingency Plan (NCP; 40 CFR Part
300). This decision is based on the Record of Decision for this
site. The attached index (Attachment 1) identifies the items on
which the selection of the remedial action is based.
Description of Selected Remedy
The selected remedy for the Beckman Instruments site
addresses groundwater contaminated with volatile organic
chemicals (VOCs) and soils contaminated with lead. This action
represents the final remedial action to remove contaminants from
groundwater and to control movement of lead in soils.
Groundwater contamination was first addressed in 1985 when
Beckman Instruments instituted a groundwater pump and treat
program to control contaminant movement and to remove and treat
contaminated groundwater. The selected remedy includes a
continuation and expansion of this pump and treat program, plus
other elements.
The major elements .of the selected groundwater and soil
remedy include:
o Groundwater Extraction, Treatment, and Discharge. This
action involves pumping contaminated groundwater from the upper
and lower «4Kifers and the aquitard separating the two aquifers.
The extract**- groundwater would be treated by air stripping to
remove volatile organic compounds (VOCs). Treated water would be
disposed of into infiltration basins to recharge groundwater.
Treated water could also be used for irrigation purposes.
o Groundwater monitoring. Groundwater monitoring shall be
conducted consistent with provisions under the Resource
Conservation and Recovery Act, Section 264, to ensure that
contaminants which exceed cleanup requirements are not released
into the environment.
-------
RECORD OF DECISION
TABLE OP CONTENTS (eont.)
List of Figures
Figure
1 Location of Site Study.Area
2 Distribution of 1,,1-DCE in the Upper Aquifer
3 Extent of Contamination,in the Upper Aquitard
4 Extent of Contaminants .in Lower Aquifer
5 Location of the Soil Stain Area
-------
o Soil Excavation and Disposal. Soil contaminated with lead
above 200 ppm will be excavated and disposed of off-site in a
disposal facility which meets RCRA and CERCLA requirements.
Additional sampling to better define the contamination exceeding
soil cleanup levels will be performed in the design phase.
The selected remedy is the final remedy for the Beckman
Site. The remedial action will remove contaminants from the
groundwater, reducing the threat to public health and allowing
the aquifer to return to beneficial uses. Soil excavation and
offsite disposal will eliminate any health threat and prevent
movement of contaminants when the soil mass is properly contained
in an approved landfill.
The selected remedy will protect groundwater resources,
prevent migration of contaminated soil, and eliminate direct
contact risks. The selected remedy will ensure the long-term
protection of public health and the environment through removal
or containment of toxic chemicals. Treatment (air stripping)
will be used to remove contaminants. The present worth cost of
the selected remedy is estimated at $4,740,000. This estimate
does not include costs for the existing pump and treat system.
-------
Declaration Statement
Consistent with CERCLA as amended by SARA, and to the extent
practicable, the National Contingency Plan, I have determined
that the selected remedy for the Beckman Instruments Site meets
the remedy standards in CERCLA Section 121, 42 U.S.C Section
9621, by being protective of public health and the environment.
I have determined that the selected remedy attains Federal and
State requirements that are legally applicable to the hazardous
substances or are relevant and appropriate under circumstances of
release, and is cost effective. The selected remedy utilizes
permanent solutions to the maximum extent practicable for this
site. Treatment, using air stripping, will remove contaminants
from the groundwater. The selected remedy will reduce volume,
mobility, and toxicity of contaminated soils to the maximum
extent practicable.
As the remedial action for treatment of groundwater in the
lower aquifer below the site is expected to take 15 to 25 years
to complete, a review of the remedial action will be conducted
every 5 years after commencement to ensure that the remedy
continues to provide adequate protection of public health and the
environment, and to assess the feasibility 'of meeting cleanup
goals, particularly in the aquitard.
Date M)aniel W. McGovern
Regional Administrator
EPA Region IX
-------
RECORD OF DECISION
Beckman instruments sit*
Decisiop
I. SITE NAME. LOCATION AND DESCRIPTION
The Beckman Instruments Site, which includes the Beckman
plant and surrounding study area, is located near the southern
limit of the city of Porterville, California. Porterville is
located in Tulare County about 25 miles southeast of Visalia on
the eastern fringe of California's Central Valley. . The Beckman
plant is located at 167 West Poplar Avenue and occupies
approximately 12 acres of a 94.33 acre parcel of land owned by
Beckman. The site study area is generally bounded by the Tula
River to the north, - ant property to the east, Poplar ditch to
the south and Newcorc; Drive on the west (Figure 1) . Land use
within the study area includes residential, field crop, orchard,
grazing land, Tule River floodway, commercial, industrial, and
vacant land. The study area contained 473 residents in 1980.
The Beckman plant consists of 7 buildings used to
manufacture and repair electronic equipment, house chemicals and
supplies, house the wastewater treatment plant, and to house
maintenance equipment. The facility also contains a tank farm,
drum storage area, and former waste handling areas.
This decision document, the final remedy for this site,
addresses three response actions for the site.
1. Upper aquifer groundwater contaminated with VOCs.
2. Lower aquifer and aquitard groundwater contaminated with
VOCs.
3. Soils contaminated with lead.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The BecJoaan plant has manufactured electronic instrument
assemblies»^ subassemblies, and printed circuit boards at the
Porterville^facility since 1967. Industrial processes have
included electroplating and degreasing. Waste streams from these
processes have included spent halogenated solvents, inorganic and
acid solutions, salts, metal-laden solutions and plating bath
sludges. Between 1967 and 1974, wastewater was discharged to the
City of Porterville sewer system. From 1974 to 1983, waste
streams were discharged to an on-site solar evaporation pond.
Wastes may have also been placed in other areas near the plant.
Since 1983, wastes streams have been treated on-site.
-------
' BecJonan initiated groundwater monitoring in the vicinity .of
the solar pond in 1982. Plant chemicals were first discovered in
groundwater below the solar pond and in domestic wells
downgradient of the plant in 1983. The pond was closed in 1983.'
Prior to discovery of chemicals in the groundwater in 1983,
groundwater below the site area was used for domestic and
agricultural purposes. After discovery of chemicals, Beckman
provided alternative water supplies to approximately 300
residences in the study area. As an additional groundwater
protection measure, 8 private wells which were completed in the
upper and lower aquifers were sealed or replaced with wells
screened in the lower aquifer to prevent further spread of
contamination.
With the Discovery of contamination in groundwater, Beckman
was directed by the California Department of Health Services
(DHS) and the California Regional Water Quality Control Board
(RWQCB) to determine the extent of groundwater contamination. By
June of 1985, VOCs had migrated westward 9,000 feet downgradient
of the site. Between 1983 and December 1988 Beckman installed 63
piezometers, 70 fully penetrating wells, 10 partially penetrating
wells, and 2 cluster wells in the upper aquifer. Beckman also
installed 20 wells into the lower aquifer and 15
containment/reclamation wells to extract groundwater for
treatment. Beckman began treatment, via air stripping, of
extracted groundwater in July 1985 to contain western migration
of the plume, control water level gradients in the upper aquifer,
and reclaim upper aquifer groundwater. A second containment and
reclamation system began pumping in the eastern portion of the
site area in July 1987.
In March 1985, the California Department of Health Services
placed the site on California's Superfund State Priority Ranking
List pursuant to Section 25356 of the California Health and
Safety Code. On October 9, ,1985, EPA received an official
request by California DHS to assume the lead role in overseeing
remedial studies and cleanup activities at the Beckman
Instruments Site. The site was added to the Federal Superfund
National Priorities List (NPL) by the EPA in the Federal Register
notice in Volume 51, No. Ill, Tuesday, June 10, 1986.
Interim Remedial Measures
Beckm«j£ has made alternate water supplies available to
approximatooraoo residences in the study area. Beckman has also
located an^abandoned wells which were acting as conduits and
contributing to the migration of contaminants from the upper
aquifer to the aquitard and lover aquifer. In the summer of
1985, Beckman commenced operation of a system to contain the
westward migration of contaminants in the groundwater of the
upper aquifer. The western containment/reclamation system
consists of 11 extraction wells which pump groundwater to an air
stripping tower for treatment. Treated groundwater is used for
local irrigation or is placed in infiltration basins near the
Tule River pursuant to RWQCB Waste Discharge Requirements
-------
-------
(«85-067) and NPDES permit #CA0081663. The air releases from the
western treatment tower have been permitted by the Tulare County
Air Pollution Control District (TCAPCD) under permit
#3679-0102-0785-01. In addition, Beckman has prepared a risk
assessment on the air releases which has been reviewed by the
TCAPCD and EPA. Although the site is located within a non-
attainment area, the air releases are below levels specified in
EPA national policy.
A second containment/reclamation system was put into
operation in July, 1987. This eastern system comprises 4 wells
and an air stripping tower located on the plant site. This
treated water is used for irrigation or is placed in infiltration
basins located northeast of the plant site. • This second system
is operated under RWQCB Waste Discharge Requirements (#87-105).
The air releases have been permitted by the TCAPCD in permit
#3679-0202-0787-01.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
All requirements for public participation as specified in
Section 113 (k) (2) (B) (i-v) of CERCLA were satisfied during the
remedial action process for the development of the Record of
Decision. '. . •
A Remedial Investigation (RI) report describing the extent
of contamination within the Beckman Site study area was prepared
by a consultant to Beckman and submitted to EPA in December 1988.
A Feasibility Study (FS) report was released for public review in
March 1989. The Proposed Cleanup Plan on the remedial action was
released in June 1989. These documents were made available to
the public in the Administrative Record File and information
repository maintained in the EPA Docket Room in Region IX. Fact
sheets, RI and FS reports and related documents, and the Proposed
Plan were placed in the reference section of the Porterville
Library at 41 West Thurman Avenue. Documents pertinent to the
remedial action will remain at these locations for public review
during the course of the remedial action. Fact sheets and the
Proposed Plan have also been mailed to persons on EPA's Beckman
Instruments Site mailing list, which contains members of the
general public, elected officials, and Beckman Instruments.
The NotEbCMj of Availability of the FS Report and the Proposed
Plan was pwttriphed in the Porterville Recorder and the Visalia
Times on JOB* 12, 1989. The Proposed Plan was presented at a
Public Meeting held in the Porterville City Council Chambers on
June 22, 1989. At this meeting representatives of EPA discussed
the Proposed Plan, answered questions about the site and the
proposed remedial alternatives, and received oral comments on the
Proposed Plan. The Public Comment Period began on June 12, 1989
and was originally scheduled to end on July 11, 1989. The Public
Comment Period was extended by one additional week via a July 11,
1989 notice in the Porterville Recorder and Visalia Times. This
resulted in a public comment period of 37 days. Comments
-------
received at the public meeting and during the Public Comment
Period are recorded and addressed in the Responsiveness Summary,
an Attachment to this Record of Decision.
IV. SCOPE AND ROLE OF OPERABLE U
During the' course of the remedial investigation, three areas of
the site were identified that pose a threat to public health and
the environment. These three areas are:
1. Upper aquifer, contaminated with VOCs.
2. Lower Aquifer and Upper Aquitard, also contaminated with
VOCs.
3. Soils contaminated with lead.
Beckman has instituted a program of extraction and treatment
of contaminated groundwater in the upper aquifer which is
expected to take less than 2 years to complete. A similar pump
and treat program is proposed to remedy the lower aquifer and
aquitard, but current projections estimate that this may not be
accomplished for 15 to 25 years. The soil rertedy will take less'
than 1 year to accomplish. Recognizing the similarity in
treatment options for both aquifers and the benefits of using the
same treatment unit for water pumped from either aquifer, EPA
elected not to separate these actions into operable units. As
the soil remedy can be readily accomplished, EPA also elected not
to make this action an operable unit. This Record of Decision
therefore addresses remediation of all three areas as one action,
and is considered the final remedy for this site.
V. SITE CHARACTERISTICS
The site is located on the eastern fringe of the Central
Valley in California. The Tule River enters the Central Valley
from the mountains and foothills to the east, approximately three
miles east of Porterville. The Tule river flows past the site,
forming the northern boundary of the study area. The City of
Porterville and the study area are situated on a broad alluvial
fan of jthe Tule River. Much of this fan forms a relatively flat
alluviajl plfin, characterized by surfaces of low topographic
relief whidt rarely exceed 10 feet of elevation change, except in
the vicinitjt*f the river.
Data collected during the remedial investigation indicated
the existence of a multilayer aquifer system beneath and
downgradient of the plant. The aquifer system is comprised of an
"upper aquifer", *»upper aquitard", and "lower aquifer", based on
order of occurrence of the units below ground surface and the
hydraulic characteristics of the units. In addition to these
units of interest at the site, a regional aquitard exists below
the lower aquifer. For this reason, the aquitard of interest at
this site is referred to as the "upper" aquitard. These units
-------
TABLE 1
MAXIMUM CONTAMINANT CONCENTRATIONS IN GROUNDH&TER
(•aerograms per liter)
Site
Contaminant
1,1,1-TCA
1,1-DCE
Freon 113
1,1-DCA
TCE
September
Upper
Aquifer
18.0
11.0
16.0
2.1
0.5
1988
Upper
Aquitard
230.0
400.0
240.0
3.8
18.0
Lower
Aquifer
2.7
17.0
16.0
6.1
26.0
March/May
Upper
Aquifer
March
8.3
7.7
5.6
2.0
NO
1989
Upper
Aquitard
May
270.0
460.0
310.0
3.4
8.7
Lower
Aquifer
May
44.0
80.0
16.0
5.8
17.0
ND • Not Detected
-------
are the uppermost portion of a westward thickening wedge of
sediments of continental origin, including both fluvial and
lacustrine sediments derived from the Sierra Nevada mountain
range.
Water quality data have been collected at the site since
1983.. Five primary contaminants have been identified in
groundwater at the Beckman site. These •volatile organic
compounds include 1,1,1 Trichloroethane (1,1,1-TCA), 1,1
Dichloroethylene (1>1-DCE), Freon 113, 1,1 Dichlorqethane (1,1-
DCA), and Trichloroethylene (TCE). Other contaminants, such as
1,2 Dichloroethane and Benzene, have been sporadically detected
in groundwater in and surrounding the site.
Upper Aquifer .«
The upper aquifer is comprised of silt, sand, gravel and
cobbles and underlies the study area to depths of up to 75 feet
below" land surface. The average hydraulic conductivity of the
upper aquifer is approximately 3,600 gallons per day per square
foot (gpd/sq ft). The upper aquifer is unconfined, with depth to
groundwater ranging between 10 to 33 feet below ground surface
(in September, 1988). >
Groundwater elevations in the upper aquifer fluctuate due to
varying amounts of recharge from precipitation and surface water
sources and due to groundwater pumpage associated with seasonal
groundwater use in the vicinity of the site. During the .period
from 1985 to 1988 groundwater levels have declined primarily due
to reduced surface water availability and increased agricultural
pumpage in the area.
Groundwater flow direction, flow gradients, and flow rates
in the upper aquifer are factors which determine the direction of
movement of VOCs in the groundwater. These factors are
influenced by recharge from surface water sources and by the
operation of the two containment/reclamation wellfields.
Throughout the RI/FS, the flow direction in the upper aquifer was
to the west.
Contaminants apparently entered the upper.aquifer in the
vicinity of the solar evaporation pond and migrated to the west.
The maximum concentrations of contaminants detected in September,
1988 and in Karen/May, 1989 in monitor or containment/reclamation
wells are pAi«nted in Table 1. The area over which contaminants
have been detected has been greatly reduced since the initiation
of the extraction and treatment systems at Beckman. The
approximate area (as of September, 1988) containing contamination
at concentrations higher than the State or Federal Maximum
Contaminant Levels (MCLs) or State Action Levels (SALs) listed in
Table 1 is shown in Figure 2. Figure 2 illustrates the extent of
contamination of the chemical 1,1,-DCS, since all other
contaminants in the upper aquifer are present at concentrations
less than the cleanup goals.
8
-------
Upper Aouitard
The upper aquitard is comprised of a fine-grained sequence
of silt, clayey silt, and sandy clay. The upper aquitard retards
movement of water between the upper and lower aquifers and ranges
from 10 to 60 feet in thickness. The aquitard is thinner and
more coarse-grained in the area of the Beckman plant, and
thickens and'becomes more fine-grained to the west of the plant.
Water level elevations within the upper aquitard and the
differences in water levels between the upper and lower aqxiifers
suggest that the upper aquifer provides recharge to the upper
aquitard in the area. The upper aquitard, in turn, recharges the
lower aquifer.
Concentrations of contaminants have been detected in five
upper aquitard piezometer sets located'near the plant,'and one
upper aquitard piezometer set located near Jaye Street as of
September, 1988. The aquitard has much higher concentrations of
contaminants than the upper aquifer. Contaminants have
infiltrated the aquitard primarily as a result of downward
migration from the upper aquifer. In some locations, existing
wells which penetrated both the upper aquifer and aquitard (and
lower aquifer) may have contributed to the downward migration of
contaminants. The maximum concentrations of contaminants in the
upper aquitard as of September, 1988 and March/May, 1989 are
shown in Table 1. Contaminants have been detected in the
aquitard over an area of approximately 160 acres. This area of
contamination is located from just west of the plant buildings to
an area west of Jaye street as shown in Figure 3. The western
extent of contamination in the aquitard has not been completely
defined. Groundwater extraction and treatment has not yet begun
in the upper aquitard.
Lower Aquifer
The lower aquifer comprises a sequence of sand and gravel
with silt and clay interbeds. The top of the lower aquifer lies
70 to 130 feet below ground surface and the aquifer is
approximately 100 feet thick. The average horizontal hydraulic
conductivity of the lower aquifer isiapproximately 55 gpd/sq ft.
Groundvater in the lower aquifer occurs under confined
conditions, - and the flow is generally to the west-southwest.
Groundwater "fievations in the lower aquifer fluctuate in response
to both locsjfr and regional groundwater pumping, and to changes in
recharge. Groundwater levels have declined recently, primarily
due to the increased agricultural pumping in the area. These
declines are consistent with region-wide trends in the Tule
Groundwater Basin.
Contaminants have been detected in the lower aquifer in the
vicinity of the plant (where the1 aquitard is relatively thin and
coarse-grained) and in locations where domestic veils were
previously open to both the upper and lower aquifers (where the
-------
•III Mil 1C
"Q*
• €U«tt« MU.
-•. X-MIVC-I «•« M-M I
•MMXM (MM Mr«tM»>* CIMIO
• • *««flMi* *fMr*«fl«t« M«MtM •!
• tM CtM'l* Mil M>. (WiCIf*
—e-
I CMIM
•••MM MflOl*
»'C. ••»• •••'lit C«tlC>«>
C« ••->*. <•••. ••«••«• MM(
I.I-OKHLOMOCTHYUNC
UPTf(» AOUIFCft
MMKH IM*
y
Fioune t
-------
upper aquifer was contaminated). Contaminants have apparently
reached the lower aquifer through these open wells and by
downward migration through the aquitard. Contaminants in the
aquitard are continuing to "leak" into the lower aquifer. The
maximum concentrations of contaminants detected in lower aquifer
wells as of September, 1988 and March/May, 1989 are shown in
Table 1. The area containing the highest concentrations of
contaminants in these units is just to the west of the Beckman
plant as shown in Figure 4. Groundwater extraction and treatment
has not yet begun in the lower aquifer.
Soils
Four potential soil contaminant source areas were identified
and studied during the remedial investigation. These include the
"soil stain" area, the former pesticide operation area, the
depression area, and the former solar pond area. The soil stain
area is located adjacent to one of the plant buildings and at one
time a blue stain could be seen in the area, presumably from
disposing of copper-containing wastes. The runoff retention basin
was investigated as a potential source area in the Remedial
Investigation (RI) and was concluded that this area is not a
potential source. Approximately 130 soil samples were taken in
the four potential source areas. Fifteen inorganic and seven
organic compounds were detected above background levels at those
locations (Table 2).
Only lead was present at levels considered to be a health
concern. Six samples showed levels of lead between background
and 40 ppm, the level identified as a cleanup goal in the
Feasibility Study (FS) . One sample showed lead at 40.8 ppm and
one sample showed lead at 1280 ppm. Based on this information,
the FS estimated the total volume of lead-contaminated soil at
740 cubic yards. The outline of the "soil stain area" which
contains the lead contaminated soil is shown in Figure 5.
Further sampling will be necessary to more precisely define the
area of contamination which exceeds the cleanup goals of 200 ppm
lead in soils which has been established in this Record of
Decision.
VI. SUMMARY OF SITE RISK
EPA policy and guidance provides that the potential risk to
human healfEh and the environment be evaluated under the
"no-action*"" scenario. This site scenario assumes the
unrestricted access to site contaminants (including soils and
groundwater) and that all the on-going treatment and/or
mitigation measures are terminated immediately. Evaluation of
the "no-action" scenario is a requirement of the National
Contingency Plan (NCP), 40 CFR Section 300.68 (e) and (f), to
represent a baseline condition. In addition, as stated in the
proposed NCP (December 21, 1988) in Section 300.430, "the lead
agency shall conduct a site-specific baseline risk assessment to
characterize the current and potential threats to human health
10
-------
EXPLANATION
A ACM UPPER AOUITARD
PCZOMETERSET
M-DCEup/l
AO-7
«o.a>
""»'
CE.TricMDRMltiylww
o0fivflDGNi9 Ifi mh^fonrwus
ltor.
*>-.
139.81
ote: VANM rapras«il
f conowtff•DOM hooi
* ^i^fc^J» Lbd^^A^^BK
•acn Demon.
BECKMAN INSTRUMENTS, INC.
Pori«rvfll«. California
1,1-DCC AND TCE
UPPER AOUITARO
MAY 1919
FIOUMI
3
-------
TABLE 2
CONSTITUENTS DETECTED ABOVE BACKGROUND LEVELS IN SITE SOIL
(milligrams per kilogram)
Inorganics Maximum Concentration Organics pajri^m Concentration
Arsenic 19.6 Aroclor-1254 1.7
Cadmium 1.4 Benzo(b)fluoranthene 0.24
Total Chromium 152.0 DDT 0.36
Copper 670.0 DDE 0.55
Cyanide 0.66 ODD 0.37
Fluoride 74.0 Pyrene 0.20
Lead 1,280.0 4-Methyl-2-Pentanone 0.07
Manganese 472.0 Toluene 0.013
Mercury 0.49 Total Xylenes 0.025
Molybedenum 1.4
Nickel 14.1
Silver 1.0
Sodium 980.0
Tin , 478.0
Zinc 460.0
M
-------
AL-20
IMOI
(NDI
L-M*
INDI
INDI
BECKMAN INSTRUMENTS. INC.
for«cr»MUD CilllornU
^TXPLANATIOH
A L3 LOWER AQUIFER
MONITOR WELL
NO-NolDrt«cl«d
1,1-OCE -1,1-DioMoRMlhylww
TCE - TrichbnMlhylMW
Concwilrations h mterograms.
1,1-OCE AND TCE
LOWER AQUIFER
MAY ItSt
-------
parking
D
SOIL STAIN AREA
r
-tenner aolar
•vapor •! Ion pond
L
J
BUILDING t
a
INFILTRATION BASINS
D
BUILDING 7
B«ekm«i Instrument* Inc.
LOCATION OF SOIL STAIN AREA
Figure
•
-------
TABLE 3
TOXICITY VALUES FOR BECKMAN SITE CGNEMUNANTS1
Site
Contaminant
1,1,1-TCE
1,1-DCE
TCE
1,1-DCA
1 All data fron
CPF - Cancer Potency
CAS No.
71-5S-6
75-35-4
79-01-6
75-34-3
Oral Inhalation
CPF WOE CPF WOE
_ _ _ • _
0.6 C 1.16 C
0.011 B2 0.0046 B2
- — — —
Oral
AIC
0.54
0.009
0.543
0.12
Inhalation
AIC
6.30
0.00025
0.000039
0.138
the Ehdangennent Assessment for the Beckman Instruments site.
Factor, expressed
as (mg/kg/day)"1
WOE - Weight of Evidence
AIC - Acceptable Chronic Intake
-------
and the environment. The results of the baseline risk assessment
will help establish acceptable exposure levels for use in
developing remedial alternatives in the FS".
EPA prepared an Endangerment Assessment (EA), also called a
Risk Assessment, to evaluate risks which may be posed by the "no
action" scenario (document #212 in the Administrative Record).
Because on-going treatment systems have been operating at the
site since 1985, a true "no-action" scenario is impossible to
determine. For this reason, August, 1986 was chosen as the date
which would simulate the no action scenario. It was assumed that
the pump and treat system was shut off and contaminants were
allowed to migrate downgradient as would occur if no remediation
had 'been taking place. The EA follows the procedures required by
the Superfund Public Health Evaluation Manual.
The Endangerment Assessment process consists of several
'steps. The first step is contaminant identification. This EA
identified a number of compounds that, because of their, toxicity
or other health risks, ,are identified as contaminants of concern
for the site. At this site, VOCs in groundwater and lead in
soils are the main compounds of interest. These chemicals and
their maximum concentrations are presented in Table 1. v
The second step in the Endangerment Assessment process is to
identify the fate and transport of the contaminants identified in
step one to assess the pathways of human or environmental
exposure. The primary contaminants of concern are VOCs in
groundwater (both upper and lower aquifers) and lead in soils.
The identified exposure pathways for groundwater include
ingestion (of contaminated groundwater, fish, beef and crops),
inhalation (due to showering and other household activities) and
dermal contact. It must be noted that these pathways are only
applicable to the no-action scenario. Since the treatment
systems have been operating in the upper aquifer, no
contamination has reached the Tule River and domestic use of the
groundwater ceased in 1985 when Beckman connected affected
households to a public water supply. Thus, ingestion of fish,
beef and crops and groundwater would pose a risk only if the
no-action alternative were selected.
The exposure pathways for lead-contaminated soil include
dermal contact and inhalation of contaminated dust.
%r
The EA^eoncluded that the exposure scenarios presenting the
highest risk under the no action alternative were direct
consumption of contaminated groundwater and inhalation of
contaminants volatilized from water while showering.
The third step of the EA is the Toxicity assessment.
Chemicals present at this site include both carcinogens and
non-carcinogens. Two contaminants are of concern based on their
potential ability to cause cancer: TCE is a Group B2 agent,
Probable Human Carcinogen, and 1,1-DCE is a Group C agent,
Possible Human Carcinogen. These classifications are based on
11
-------
the strength of scientific evidence that these agents may be
carcinogenic. For TCE, there is sufficient evidence of
carcinogenicity in animals and inadequate evidence the compound
is carcinogenic in humans. For 1,1-DCE, there is only limited
evidence the compound is carcinogenic in animals and the
available evidence on humans is inadequate. Chemicals which have
been proven to cause cancer in humans are classified as Group A
agents, Known Human Carcinogens. Cancer Potency Factors (CPFs)
have been developed by EPA's Carcinogenic Assessment Group (CAG)
for estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic Chemicals (see Table 3 for
toxicity information). CPFs which are expressed in units of
mg/kg-day are multiplied by the estimated intake of a potential
carcinogen in mg/kg/day to provide an upper bound estimate of the
excess lifetime cancer risk associated with exposure at that
intake level. The term "upper bound" reflects the conservative
estimate of the risks calculated 'from the CPF. Use of this
approach makes underestimation of the actual cancer risks highly
unlikely. Cancer potency factors are derived from the results of
human epidemiological studies or chronic animal bioassays to
which animal-to-human extrapolation and uncertainty factors have
been applied.
Several non-carcinogenic chemicals have been identified to
be chemicals of concern at this site. Reference doses (RFDs)
have been developed by EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting
non-carcinogenic effects. The reference dose is an estimate,
with an uncertainty of perhaps an order of magnitude, of a
lifetime daily exposure for the entire population (including
sensitive individuals) that is expected to be without appreciable
risk of deleterious effects. Estimated intake of chemicals from
environmental media (e.g./ the amount of a chemical ingested from
contaminated drinking water ) can be compared to the RFD. RFDs
are derived from human epidemiological studies or animal studies
to which uncertainty factors have been applied (e.g., to account
for the use of animal data to predict effect on humans) . These
uncertainty factors help ensure that the RFDs will not
underestimate the potential for adverse non-carcinogenic effects
to occur.
i"
The last step in the Endangerment Assessment process is the
Risk Characterization. At this point the information from the
proceeding B&tps is combined to determine if an excess health
risk is promit at the site. Excess lifetime cancer risks are
determined by multiplying the intake level with the cancer
potency factors. These risks are probabilities that are
generally expressed in scientific notation (e.g., 1x10-6). An
excess lifetime cancer risk of 1x10-6 indicates that, as a
plausible upper-bound, an individual has a one in one million
chance of developing cancer as a result of site exposure to a
carcinogen over a seventy year lifetime under the specific
exposure conditions at a site.
12
-------
The EA estimated that the lifetime cancer risk to the
maximally exposed individual who drinks and showers with water
from the upper aquifer (containing concentrations of carcinogens
present in August, 1986) is approximately 6 chances in 10,000 or
6x10-4.' Because the pump and treatment system has been operating
since August, 1986 to decrease1 the concentrations of carcinogens
in the groundwater, the associated risks are decreasing.
Drinking and showering are the exposure pathways which are
associated with excess risk (greater than 10-6). This cancer
risk is primarily from DCE (a- class C carcinogen). The EA also
estimated that lifetime cancer risk due to drinking and showering
with water from the lower aquifer was about 1.6 chances in 1000
or 1.6x10-3 based on the August, 1986 concentration levels. The
aquitard was not used in risk calculations because it is not a
productive aquifer and is not expected to provide a significant
source of ,groundwater to -domestic wells. However, it is of
concern to EPA as a continuing source of contamination. Actual
current risks are essentially zero as contaminated groundwater is
not currently being used for domestic purposes.
Potential concern for non-carcinogenic effect of a single
contaminant in a single medium is expressed as a hazard quotient
(HQ) • (or the ratio of the • estimated intake derived from the
contaminant concentrations in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated.
The HI provides a useful reference point for gauging the
potential significance of multiple contaminants exposures within
a single medium or across media. If the ratio exceeds 1 for any
chemical, for any route of exposure, there is presumed to be a
risk of non-carcinogenic effects at that exposure point.
The EA concluded the exposure route which has a potential
for producing non-carcinogenic effects is showering with
DCE-contaminated water at the highest concentrations found in the
upper aquifer as of August, 1986. The HI for this chemical via
this route is 5.24. All oral and inhalation doses ,for DCA, 1,1,1
TCA and TCE do not present a risk of non-carcinogenic effects for
the exp9sure scenarios evaluated in the EA.
Lead in soil was also identified as a site chemical of
concern that^poses a threat to public health and the environment.
A soil leadrconcentration of 1,280 mg/kg was detected. Lead
contaminat«JF"»oil poses a health risk through direct contact,
inhalation, Ihd ingestion routes of exposure. EPA has determined
that lead soil concentrations exceeding 200 mg/kg pose a
significant health threat to children and other segments of the
human population, and thus has been selected as the cleanup level
for lead in soils. Prevention of direct contact and elimination
of dust production is a primary remedial objective for
contaminated soils.
13
-------
VII. DESCRIPTION OF ALTERNATIVES
To facilitate the detailed analysis of alternatives, the
site was separated into three areas for temedial purposes. These
three areas are: (1) upper aquifer; (2) lover aquifer and upper
aquitard; and (3) lead-contaminated soils. The remedial
alternatives for these three areas are described below.
Upper Aquifer Remedial Alternatives
Five alternatives were evaluated for groundwater
contamination in the upper aquifer. These include no action
(alternative G-l) ; institutional controls (alternative G-2) ;
groundwater collection, air stripping treatment, and discharge
(alternative G-3a) ; grpundwater collection, carbon adsorption
treatment, and discharge (alternative G-3c) ; and, groundwater
collection, carbon adsorption treatment and reinjection
(alternative G-4) .
i
The no action alternative (G-l) represents baseline
conditions against which other alternatives are compared. Under
no action, unrestricted access would be allowed to the upper
aquifer and the existing pump and treatment . system would be
terminated.
Alternative G-2 (institutional controls) would consist of
continued monitoring of groundwater quality and restricting
access through controls on pumping and new well installation.
Existing containment and treatment would cease.
Alternative G-3 (collection, treatment, and discharge)
consists of a combination of pumping wells to collect
groundwater, treatment of groundwater to remove volatiles, and
discharge to existing infiltration basins or irrigated fields.
The existing extraction wellfield would be used to collect
groundwater. Treatment would be either through air stripping or
carbon adsorption. The air stripping alternative is identified
as alternative G-3a and the carbon adsorption option as G-3c.
Alternative G-4 (collection, treatment and reinjection)
would consist of collection, treatment and recharge of treated
water using the existing extraction wellfield, carbon adsorption
treatment, qnd recharge through injection wells.
Lower Aquifer and Upper Aquitard
Six remedial alternatives were evaluated for the lower
aquifer and upper aquitard. These include the no action
(alternative LG-1) ; institutional controls (alternative LG-2) ;
extraction, treatment, and recharge of upper aquitard only
(LG-3) ; extraction, treatment, and recharge of lower aquifer
only (LG-4) ; combined extraction, treatment, and recharge of
upper aquitard and lower aquifer (LG-5) ; and, upper aquitard
in-situ bioremediation (alternative LG-6) .
14
-------
The no action alternative (LG-1) represents the baseline
conditions against which the other alternatives are compared.
Under no action unrestricted access to the aquitard and lower
aquifer will exist and no attempts to remove or contain the
contaminated aquifer will be made.
Alternative LG-2 (institutional controls) would include
continued monitoring of groundwater quality, installation of
additional monitoring wells, and preventing access to
contaminated groundwater through restrictions on pumping and well
installation.
Alternative LG-3 (upper aquitard extraction, treatment, and
discharge) would involve installation of an extraction wellfield
with wells screened into the upper aquitard, treating extracted
groundwater in the existing air stripping system, and discharging
the treated water into the existing infiltration basins or
irrigated fields. Alternative LG-3 involves remediation of the
upper aquitard only.
Alternative LG-4 (lower aquifer extraction, treatment, and
discharge) would involve installation of an extraction wellfield
with wells screened in the lower aquifer, treating extracted
groundwater in the existing air stripping system.,, and discharging
the treated water into the existing infiltration basins or
irrigated fields. Alternative LG-4 involves remediation of the
lower aquifer only.
Alternative LG-5 (lower aquifer and upper aquitard
extraction, treatment, and discharge) would involve installation
of extraction wells screened into both the upper aquitard and
lower aquifer, treating extracted groundwater in the existing air
stripping system, and discharging the treated water into the
existing infiltration basins or irrigated fields.
Alternative LG-6 (in-situ bioremediation) consists c-
in-situ aerobic bioremediation of the aquitard and would include
an injection system, an extraction system, and a surface
treatment facility.
Soil Remediation
Three MMdial action alternatives were developed for the
lead-conta^jpited soil. These include no action (alternative
S-l) ; excaiQfeion and disposal (alternative S-3); and excavation,
treatment, and disposal (alternative S-4).
The no action alternative (S-l) forms the basis against
which the other alternatives are compared. Under no action, no
remedial action would occur and unrestricted access to
contaminated soils would be allowed.
15
-------
Alternative S-3 (excavation and disposal) would consist of
excavation and offsite disposal at a hazardous waste facility of
contaminated soil. No treatment to reduce toxicity, mobility, or
volume would be performed.
Alternative S-4 (excavation, treatment, and disposal) would
consist of excavation, on-site treatment, followed by offsite
disposal at an appropriate facility. Treatment would consist of
cement solidification or silicate-based stabilization.
Treatability tests would be performed during the remedial design
to determine the most appropriate treatment. The treated soil
could then go through waste characterization and delisting which
could allow its disposal as non-hazardous.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section presents a comparison of alternatives using
nine component criteria. These criteria, which are listed below,
are derived from Section 300.68(h)(2) of the National Contingency
Plan; CERCLA Sections 121(b) and 121(c).
\
1. Protection of human health and the environment
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
3. Reduction of toxicity, mobility, or volume
4. Long-term effectiveness and permanence
.5. Short-term effectiveness
6. Implementability
7. Cost
8. State Acceptance
9. Community Acceptance
Under Section 121 of CERCLA, as amended by the Superfund
Amendments and Reauthorization Act (SARA), the basic cleanup
objective is to chose a remedy that is protective of public
health and the environment, that is cost effective, and utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable. Section 121(d) also requires that
remedial actions comply with ARARs. ARARs for this site have
been identified in the Administrative Record (Document 178) and
are discus**! in Section 1.5 of the Feasibility Study. In
particular, mSLm under the Safe Drinking Water Act are considered
ARARs for tBA site and have been selected as cleanup goals (see
Section on The Selected Remedy). Other significant ARARs include
requirements under the Resource Conservation and Recovery Act and
State requirements under the Air Resources Act, California Safe
Drinking Water act and Porter Cologne Water Quality Act.
Upper Aquifer Remedial Action Alternatives
The no action alternative (G-l) would provide no protection
of human health or the environment and would not employ treatment
to reduce toxicity, mobility, or volume. Contaminants would
continue to move in the environment and would disperse and
degrade using natural mechanisms. Because the existing pump and
16
-------
treatment system would cease to operate, the volume of
contaminated media would increase while advection and dispersion
occurred. The no action alternative would not comply with ARARS.
The alternative offers no short-term effectiveness, but because
natural advection and dispersion of contaminants will reduce
groundwater concentrations to MCLs in an estimated 1 to 2 years,
the alternative does offer limited long-term effectiveness. The
no action alternative could be easily implemented, it does not
involve implementation of a technology, and would be of minimal
cost. The alternative would probably not be acceptable to the
state or the community, and would not meet the four statutory
determination of a CERCLA remedy.
Implementation of institutional controls and continued
groundwater monitoring (alternative G-2) would provide some
protection to public health and the environment because access to
contaminated groundwater would be limited. Like the no action
alternative, contaminants would be allowed to naturally disperse.
However the alternative would not employ treatment to reduc^
toxicity, mobility, or volume. Alternative G-2 would not comply
with ARARs. The alternative offers short-term effectiveness only
through the effectiveness of enforcement of the institutional
controls. It does not meet the criteria of performance or long
term effectiveness. Like the no action alternative,
concentrations of contaminants in groundwater would achieve MCL
goals in 1 to 2 years. Alternative G-2 is perceived to be more
acceptable to the State and Community than the no action
alternative, but is also perceived to be less acceptable compared
to continuation of the present pump and treatment system.
Present worth cost for continued monitoring until MCLs are
achieved is approximately $594,000.
Continuation of the existing pump and treatment system using
air stripping to remove contaminants from extracted groundwater
(alternative G-3a) would be protective of public health and the
environment through removal and dispersion control of
contaminated groundvater. The alternative offers short and long
term effectiveness because it is estimated to take less than 1
year for contamination levels to achieve MCL goals. The
alternative J* readily implement able through use of the existing
pump and txjMbMnt system. Although air stripping vill treat
groundwater m reduce volume of contaminated water, air stripping
is a media transfer process (water to air) and contaminants are
not destroyed. This treatment process has the potential for
exposure to site chemicals through inhalation of contaminated
air, but all applicable air quality criteria relating to voc
emissions will be met. The present air-stripping treatment
system has been permitted by the Tulare County Air Pollution
Control District (TCAPCO). Although this is a non-attainment
area, the current air emissions for the site meet EPA national
policy levels of 15 pounds per day or less. The alternative will
address all ARARs for the site. Present worth cost to achieve
MCL goals is $571,000. Alternative (G-3) is perceived to be more
acceptable to the State and local community than the no action
alternative.
17
-------
Alternative G-3c would employ activated carbon to remove
VOCs from extracted groundwater. Alternative G-3c would offer
greater public health protectiveness than G-3a because VOCs would
not be released into the air. Treatment using carbon adsorption
would further reduce mobility and volume of contaminated media. ,
The alternative would take approximately 1 year to achieve MCLs
in the contaminated upper aquifer. Alternative G3-c would have
higher costs than G3-a due to the need to handle, reprocess, or
dispose of the carbon adsorption media. Present worth costs are
estimated at $1,186,000. The alternative would comply with all
ARARs and would be readily implementable. The alternative is
perceived to be acceptable to the State and local community.
Lower Aouifer/Aquitard Remedial Alternatives
The no action alternative (LG-1) would offer no protection
to public health and the environment. It would not be effective
in reducing mobility or volume of contamination and it would take
an estimated 200 years for natural dispersal and degradation
mechanisms to reduce aquifer/aquitard concentrations to below'
MCLs. The no action alternative would not comply with ARARs.
The alternative is implementable and would be of minimal cost.
The alternative is not likely to be acceptable to the State or
local Community, and would not meet the four statutory criteria »
for a CERCLA remedy.
The institutional control alternative (LG-2) would offer
some protection to public health, but effectiveness would be
related to the effectiveness of the controls. Because the
alternative relies on natural dispersal and degradation
mechanisms to achieve MCLs, institutional controls would need to
be enforced for more than 200 years. Implementation of
institutional controls for 200 years has never been tested or
proven for a waste disposal site, therefore implementability is
unknown. The alternative does not employ a technology to reduce
toxicity, mobility, or volume of contamination. Volume of
contaminated media would increase as the VOCs continued to move
unabated in the aquifer. The alternative would not comply with
ARARs. The alternative is believed to be unacceptable to the
State and local community.
Alternative LG-3 (upper aquitard extraction, treatment, and
discharge) would consist of extracting and treating water removed
from the upper itqui tard in the existing air stripping unit. This
alternative addresses the upper aquitard which is the source of
contamination fbr the lower aquifer, but would not be effective
in remediating the lower aquifer which is a drinking water
source. The alternative offers minimal short-term public health
protection for the lower aquifer because the lower aquifer would
remain contaminated for 100 to 150 years. Long-term
effectiveness would be achieved only through natural processes.
The alternative would reduce mobility and volume of contaminated
media in the aquitard, but with the exception of source control,
it would not be effective for the lower aquifer. Treatment via
air stripping is a media transfer process and contaminants would
18
-------
not be directly destroyed through treatment, it is expected that
the TCAPCD would permit these air releases. ARARs would be
achieved for the aquitard only. Present worth costs for this
alternative are estimated at $4,178,000. The alternative is
implementable through available groundwater recovery technologies
and the existing air stripping system. Treated water would be
discharged to the on-site infiltration basins and/or used for
local agricultural irrigation. State and community acceptance is
perceived to be low due to the length of time the lower aquifer
would remain contaminated.
Alternative LG-4 (lower aquifer extraction, treatment, and
discharge) consists of extraction and treatment of lower aquifer
groundwater using the existing air stripping system. Treated
water would be discharged to the on-site infiltration basins
and/or used for local irrigation. The alternative addresses the
lower aquifer which is a drinking water source, but would not
remedy the aquitard, which is the source of contamination for the
lower aqujifer. The alternative would offer some protection of
public health through containment of the plume. Short-term
effectiveness would be dependent on plume control and prevention
of access to the contaminated portion of the aquifer. Long-term*
effectiveness is estimated to be achieved in 30 to 40 years when
contaminant concentrations in the aquifer are predicted to be
reduced to MCLs. The alternative would control movement and
contain the volume of contaminated groundwater. Treatment via
air stripping is a media transfer process and contaminants would
not be destroyed by direct treatment. It is expected that the
TCAPCO would permit the air releases. ARARs would be addressed
by alternative LG-4. Present worth cost for alternative LG-4 is
estimated at $3,344,000. The alternative is perceived to be less
acceptable to the State and community than alternative LG-5 which
would produce reduced remediation time due to concurrent lower
aguifer/aquitard remediation.
Alternative LG-5 (concurrent upper aquitard/lower aquifer
extraction, treatment, and discharge) is a combination of
alternatives LG-3 and LG-4. This alternative offers greater
public health protection through control of the source and
contaminant plume. The alternative is estimated to achieve MCLs
in the lower aquifer in approximately 25 years and would be
effective in the long term. Short-term effectiveness would be
related to o&Otrol of emissions from the air stripping system and
control of Tccess to the aquifer. The alternative is easily
implemented using available groundwater extraction technology and
could use the existing air stripping system. The treated water
would be discharged to the infiltration basins and/or used for
irrigation. The alternative would effectively reduce mobility and
volume of contaminated media. Treatment would be a media
transfer process and contaminants would not be directly
destroyed. It is expected that the TCAPCO would permit the air
releases. Present worth cost is estimated at $3,928,000. The
alternative is perceived to be acceptable to the State and local
community.
19
-------
Alternative LG-6 (in-situ bioremediation) would consist oi
aerobic bioremediation of contaminated portions of the aquitard.
The alternative would require treatability studies and it is not
known whether it could be implementable. The alternative would
be effective for the aquitard, and would address the aquifer only
through reduction of release of VOCs into the lower aquifer. The
time period of remediation is not known, but the remedy may take
up to 100 years to achieve ARARs in the lower aquifer.
Short-term effectiveness would be related to the ability to
prevent access to the lower aquifer. The alternative could
result in reduction of toxicity, mobility, and volume of
contaminated groundwater. Costs for implementation are unknown.
Due to the uncertainties associated with the alternative, the
alternative is not perceived to be acceptable to the State and
the local community.
Soils Remedial Alternatives
Alternative S-l (no action) 'would allow unrestricted access
bo the area with soil contamination and therefore offers no
public health protection. Because contamination would remain
indefinitely, the no action alternative would not be effective in
the short or long terms. No action would not employ treatment to
reduce toxicity, mobility, or volume. The alternative is readily
implementable and costs would be minimal. The alternative is
perceived to be unacceptable to the State and local community.
Alternative S-3 (excavation and off-site disposal) would be
easily implemented, provide immediate (short term) protection of
public health, and provide long-term effectiveness for the site.
The alternative would comply with ARARs including the Land Ban
Restrictions. Since disposal occurred prior to November, 1980,
the lead-contaminated soil would not be considered a listed RCRA
waste, however, it may be a characteristic waste. It will be
determined during remedial design whether or not the lead
contaminated soil is a characteristic waste. If it is determined
to be a RCRA waste, then Land Ban would be considered an ARAR and
would be complied with. The alternative would not employ
treatment to reduce toxicity, mobility, or volume, and the
contamination problem would be transferred to a landfill
facility. The coat for alternative S-3 is estimated at $241,054,
which coae* primarily from the landfill disposal fee of 740 cubic
yards of e^ataainated soil estimated in the FS. Beckman has
stated th4t£this is a worst case estimate, and that the actual
volume of Contaminated soils may be much less. The remedy is
perceived to be acceptable to the State and the community.
Alternative S-4 (excavation, treatment, and off-site
disposal) would provide the same public health protectiveness and
effectiveness as Alternative S-3 for the site. The use of
stabilization as a treatment, however, provides additional
protection for the landfill receiving the stabilized soil mass.
The stabilized soil mass may be able to be reclassified as
non-hazardous allowing disposal at a non-hazardous waste
facility. Treatment would reduce contaminant mobility, but the
20
-------
volume of contaminated soil would be expected to increase by 30%
to 50%. The alternative is easily iraplementable. Cost is
estimated at $291,554, which is approximately $50,000 more than
Alternative S-3 due to treatment costs. The cost of this remedy
is based on estimates in the FS which may overestimate the volume
of contaminated soil. The remedy is perceived to be acceptable
to the State and local community.
IX. THE 5RLRCTEP'REMEDY
Upper Aquifer
i«
The selected remedy for the upper aquifer is alternative
G-3. This alternative consists of continuation of the existing
Sectarian extraction, treatment, and discharge systems. The system
has been treating groundwater since 1985 and has been shown to be
effective in reducing contamination levels in the upper aquifer.
The alternative offers significant short-tern public health
protectiveness, is estimated to take less than one year to reduce
contaminant levels to MCLs, and will be a permanent solution for
the upper aquifer. The alternative is cost-effective because the
treatment system is already in place. Permits for the current
discharge of treated water and air emission have already been
obtained, although these permits will have to be reviewed upon
initiation of treatment for the lower aquifer and aquitard.
Completion of the selected remedy will allow unrestricted access
to the upper aquifer. The selected remedy complies with SARA's
preference for treatment as the principle remedy.
Upper Aquitard/Lower Aquifer
The selected remedy for the upper aquitard/lower aquifer is
alternative LG-5, concurrent aquitard/lower aquifer extraction,
treatment, and discharge. The alternative would involve
installation of extraction wells and treatment of extracted water
in an air treatment unit. It is expected that the existing air
treatment units will be used, although the existing permits may
have to be reviewed and modified. The alternative addresses the
source of contamination and the affected aquifer. It is
recognized tlut pumping in the the aquitard may be limited,
particularly^west of the Bee km an plant due to the relatively
impermeable ria~ture of the aquitard in this area. The location of
pumping wells and extraction rates will be determined during
remedial design. This alternative is expected to achieve public
health protection in the least amount of time (about 25 years)
and would take advantage of current systems thus making it
readily implementable. When complete, the alternative offers a
permanent solution for the site. The alternative is cost
effective when compared to alternatives that will take up to 100
years to accomplish. Completion of the remedy will allow
unrestricted use of the lower aquifer. The selected remedy
complies with SARA'S preference for treatment.
21
-------
TABLE 4
CLEAN UP GOALS AND WATER QUALITY CRITERIA
(micrograms per liter)
Site
Contaminant
1,1, 1-TCA
1,1-DCE
Freon 113
1,1-DCA
TCE
Clean Up Federal Maximum State Maximum State Action
Goals Contaminant Level Contaminant Level Level
200
6
1,200
5
5 .
200
7
NA
NA
5
200
6
*1,200
*5
5
200
6
1200
5
5
*Proposed California State MCL.
-------
Soils
The selected remedy for the lead-contaminated soils is
alternative S-3. This alternative involves excavation of
contaminated soils and offsite disposal of the excavated soils.
The alternative is 'a permanent solution for the site, allowing
unrestricted access to the area of contamination after
remediation. Significant public health protection would be
achieved. Alternative S-3 was chosen as the remedy for soils
based on further review of available data and public comment.
Beckman has stated that the estimate of soil volumes in the FS
represent a "worst case" scenario and it is expected that the
actual volumes of soil and concentrations of lead in soils to be
much less than stated in the FS. Based on this information,
treatment is not expected to be as cost-effective. In addition,
the benefits of treatment (reduction in mobility) is not expected
to offset the volumetric increase in contaminated material,
particularly since the concentrations of lead are expected to be
relatively low [less than or equal to 1280 ppm]. Although the
preference for treatment as a principle component of the remedy
would not be satisfied, these factors have led EPA to choose
alternative S-3 as the selected remedy. This alternative is
cost-effective. In the event that additional information \
collected during sampling in the Remedial Design suggests that' ,
the original volume estimates are correct and/or concentrations.
of contaminants are much greater than originally expected, this
decision will be reevaluated, as treatment may be the most
appropriate remedy in that case.
Cleanup Goals
EPA has selected federal Maximum Contaminant Limits (MCLs)
as the cleanup goals for the groundwater in the upper and lower
aquifer. Where State MCLs are more stringent, EPA has selected
State MCLs, as in the case of 1,1-DCE. For those chemicals which
do not have State or Federal MCLs established, as in the case of
Freon 113 and 1,1-DCA, EPA has selected State action levels as
the cleanup goals. The selection of MCLs as cleanup goals is
consistent with the National Contingency Plan and EPA policy. The
cleanup goals are presented in Table 4.
The aquitard underlying the Beckman site is recognized to be
a variable unit ranging from relatively impermeable clays to the
west of the plant and grading to much coarser and relatively more
permeable siltSC. sands and clays in the vicinity of the Beckman
plant. The aqtfltard is recognized to be a source of contaminants
in the study area. In the vicinity of the Beckman plant, the
aquitard nay also be capable of supplying water to wells and thus
may be available for human consumption and irrigation.
Therefore, the objective is to remedy the aquitard to prevent
migration into the lover aquifer and to prevent consumption of
contaminated aquitard waters which may present an endangerment to
public health and the environment. The remedy specified in this
Record of Decision is pumping and treating of all three units, to
the extent practicable. The cleanup goals specified are MCLs for
22
-------
3H contaminants identified as compounds of concern. It is
recognized that cleanup goals may not be able to be achieved in
the more impermeable zones of the aquitard and that some
combination of institutional controls may need to be implemented
in the future. This decision will be Reviewed after the remedy
nas been in place five years to determine the feasibility of
cleaning up the aquitard to MCLs.
For lead-contaminated soils, EPA has selected a cleanup
level of 200 ppm to protect public health and the environment.
v_ STATUTORY DETERMINATIONS
The selected remedy will comply with all ARARs and, to the
extent practicable, the requirements of Section 121 of CERCLA.
The remedy will be protective, of public health and the
environment through removal and containment of a significant
quantity of contaminated media. Implementation of the remedy
will not pose unacceptable short-term risks.
i
The selected remedy will meet all ARARs for VOC release,
dust emissions, and land disposal. The selected remedy is cost
effective and makes maximum use of existing treatment systems.
The remedy offers the greatest site area health protection at
moderate cost. Risk reduction through the other alternatives was
either significantly less than the selected remedies, .or was
achieved at significantly higher cost.
The selected remedy will result in permanent solutions for
the site, allowing site groundwater to be returned to productive
use. Contaminated soil will be excavated and removed to an
offsite facility where long-term management can be properly
achieved.
The selected remedies for groundwater meet statutory
preferences for treatment as the principle remedy. Air stripping
will remove VOCs from groundwater allowing productive use of the
treated water and will achieve a reduction of toxicity, mobility
or volume of contaminants in the groundwater.
For any soils taken off-site, long-term maintenance of the
disposal facility will be a requirement for the contaminated
soils. Tr«*t»«nt will probably not be required for
lead-contaninat6B soils, as the small volume and relatively low
levels of contamination do not make treatment a cost-effective
component of this remedy.
XI. DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Beckman Instruments Site was
released in June 1989. The Proposed Plan identified pumping,
reatment, and disposal of treated water to infiltration basins
the selected remedies for the upper aquifer and the upber
23
-------
aquitard/lower aquifer. The Proposed Plan also identified soil
excavation, stabilization, and off-site disposal for lead
contaminated soils. EPA has reviewed all comments submitted
verbally and in writing during the public comment period and has
decided to change a portion of the remedy as described in the
Proposed Plan. EPA has decided that selection of Remedial
alternative S-3, (excavation and off-site disposal) would be the
most appropriate alternative for remediation of contaminated
soils. The reason for this decision is that it appears that the
volume of contaminated soil estimated in the FS is significantly
high. This is due to the fact that the FS based the cleanup
level on 40 ppro lead and this Record of Decision is selecting 200
ppm as the cleanup goal. In fact, a much smaller volume of s'oil
may be contaminated above 200 ppm. Only one soil sample (at 1280
ppm lead) showed contamination above this cleanup level. Lead
contamination in soils above 1000 ppm is considered to be
hazardous waste in the State of California, below this level it
is a "designated" waste. By treating the soils with a silicate
based cement additive, the volume of soils would increase by 30
to 50 percent. Due to the relatively low concentrations expected
to be found, it was determined that the stabilization (reduction
in mobility) was not sufficient to warrant this volumetric^
increase. Limited additional sampling will be required to confirm
the extent of contaminated areas. In the event that
concentrations of lead significantly higher than 1000 ppm and/or
vo.lumes of contaminated soil as described in the FS are
discovered, and treatment may be included the most appropriate
alternative in that case.
EPA has also reviewed the groundwater cleanup goals
identified in the Proposed Plan for achievement of the remedial
action. In the Proposed Plan EPA identified 0.5 ug/L as the
cleanup goal for any of the VOCs detected in the lower or upper
aquifers. However, after consideration of the public comments
received, and after review of the protectiveness afforded by a
0.5 ug/L level and the protectiveness afforded by MCLs for each
individual VOC, EPA has elected to change the cleanup goals for
each VOC to its respective State and/or Federal >MCL. Cleanup
goals for each of the VOCs are shown on Table 4. EPA has
determined that clean up of both aquifers to MCLs will provide
adequate protection to public health and the environment and
therefore is Baking this change in this Decision Document.
24
-------
BECKKAN INSTRUMENTS
PORTERVILLE, CALIFORNIA
RESPONSE SUMMARY
A. OVERVIEW
EPA issued a Proposed Plan for the Beckman Instruments
Superfund site on June 12, 1989, initiating a 37 day public
comment period. The Proposed Plan described EPA's preferred
alternative for groundvater and soil contamination remedies at
this site. The Proposed Plan was issued in the form of a fact
sheet that was mailed to Porterville community members and lo-
cal leaders on June 8, 1989. EPA's preferred alternative, as
described in the Proposed Plan, involved excavation, treat-
ment and disposal of lead-contaminated soils and pumping,
treatment (using air stripping) and discharge of contaminated
groundwater. The treated groundwater would be used for ir-
rigation or returned to the upper aquifer via infiltration
basins. The Proposed Plan addressed groundwater contamination
in the upper and lower a.quifers and the intervening aquitard.
i
EPA held a public mfee'ting on June 22, 1989 at the Porter-
ville City Hall to discuss the Proposed Plan. The meeting was
well attended and generated many questions and formal com-
ments. EPA also received many written comments during the
public comment period. Judging from the written and oral com-
ments EPA received, the majority of community members and lo-
cal government leaders who responded generally agree with the
recommended methods of addressing the remaining contamination
problems at the Beckman site. However, these commentors dis-
agreed with EPA's proposed clean-up goals for the site's
groundwater units as well as EPA's Endangerment Assessment,
which assessed Site risks under the "No-Action" remedial al-
ternative.
Most commentors said that they believed the clean-up
goals, set more stringent than drinking water standards, were
unrealistic, unnecessary and unfair to Beckman. Many commen-
tors questioned the benefits to be gained by achieving more
stringent cleen-up goals. These commentors also emphasized
the economic Juurdahips the Porterville community could endure
as it retained~~the "contaminated" stigma throughout the 15-25
years needed to achieve these clean-up goals. The impacts
cited most often included the perception by consumers that
produce and animal products from the area might be unsafe to
consume and the disincentive created to industries considering
moving to the Porterville area.
-------
Most conunentors cited fairness as a key issue to be con-
sidered by EPA in dealing with Beckman whom they perceive to
be an active, responsible corporate citizen. Several commen-
tors also questioned EPA's credibility in light of some con-
troversial aspects of EPA's Endangerment Assessment.
The comments received by EPA during the public comment
period have been addressed in this summary. This summary con-
tains the following sections:
o Background on Community Involvement
o Summary of Comments Received During the Public Comment
Period and EPA's Responses
o ' Remaining Concerns
o Attachment: Community Relations Activities at Beckman
Instruments
B. BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Beckman Instruments site began
during the summer of 1983. The community first learned of the
contamination problem through media coverage of a joint press
conference held by Beckman, the Regional Water Quality Control
Board (Regional Board or RWQCB) and the California Department
of Health Services (DHS). This press conference described the
groundwater and residential water well contamination dis-
covered by Sectarian's sampling and analysis program. Residents
in areas affected by the contamination were also contacted
directly by mail by both DHS and Beckman. Some of these resi-
dents received the initial news of the contamination with
widespread concern. In August 1983, some neighborhood members
organized a meeting of property owners and residents to dis-
cuss common concerns. This meeting led to the formation of a
group, dubbed the "Freon Flats Action Committee" (FFAC), whose
goals were to learn more about site contamination and its con-
sequences and to influence government decision-makers regard-
ing the actions that should be taken to address the problem.
The FFAC met frequently during the latter half of 1983. The
FFAC met less frequently following connection of affected
households,to the Porterville city water system which was com-
pleted by Qtcember 1983. Active community interest in the Be-
ckman sitfltjpontinued to wane though increased briefly follow-
ing the June 1984 discovery of contamination affecting addi-
tional residential areas. These residents were then provided
with bottled water and city water connections. As a result,
active community, interest has remained relatively low through
the present time.
Major concerns expressed by community members over the
past six (6) years have included concerns regarding:
-------
o Potential Spread of Contamination - The threat of future
contamination of private and city water wells; had the source
of contamination really been stopped?
o Health Affects Related to Contamination of Private Wells
- especially the dangers to sensitive populations such as
young children and older residents; risks associated with con-
suming produce or animal products that ingest the contaminated
groundwater.
o, Impact on Porterville Economy - The negative image and
fear created by the "contaminated" stigma and its impact on
the city's ability to attract new industries and promote its
agricultural products.
o Positive Attitude Toward Beckman - widespread community
belief that Beckman was a good corporate citizen and had done
an excellent job of addressing its groundwater contamination
problems; concern that if clean-up methods became too costly,
Beckman might close its Porterville plant which would be a
tremendous loss to the city. \
EPA has sought to address these and other Porterville
community concerns by doing the following:
Presenting information to community members regarding the
status of Beckman Superfund activities - EPA prepared a Com-
munity Relations Plan which described all planned community
out-reach activities. EPA attempted to keep the community in-
formed by preparing and distributing two (2) fact sheets and
one (1) fact sheet update. EPA also established a local
repository at the Porterville City Library for site-related
materials for public review.
Provided opportunities for two—way communication between
EPA and the community - EPA distributed fact sheets which en-
couraged community members to ask questions and make comments
by calling EPA's toll-free telephone number. EPA conducted
meetings in early June, 1989 with civic leaders and a public
meeting oa June 22, 1989 to answer questions and receive the
communitwii comments regarding EPA's Proposed Plan for ad-
dressing !•• remaining site contamination.
The public, comment period for the Beckman Instruments
site was held from June 12, 1989 through July 18, 1989. The
public comment period was originally scheduled to close on
July 11, 1989 but was extended one week by EPA in response to
requests received from Beckman and others. During the public
comment period, EPA received a total of forty (40) comments
regarding the draft Feasibility Study (FS) and EPA's Proposed
-------
Plan for cleaning up the remaining site contamination. EPA
received nine (9) verbal comments at the public meeting held
in the Porterville City Hall on June 22, 1989, and thirty-one
(,31) written comments thereafter. Two (2) comments were
received after the close of the formal public comment period
and are included in this Response Summary as well. Five (5)
commentors submitted both verbal and written comments. Com-'
ments raised during the public comment period are summarized
below and are categorized by relevant topics.
REMEDIAL ALTERNATIVE PREFERENCES
i
Relatively few of the comments received during the public*
comment period,dealt with the choice of specific remedial al-
ternatives. Of the comments that were received in this
category, most addressed concerns regarding EPA's preferred
alternatives for addressing contamination of the soils and the
aquitard/lower aquifer.
Upper Aquifer
1. California Department of Health Services, Toxic Substance
Control Division (DHS) expressed general concurrence with
EPA's proposed approach for addressing site contamination and
stated that they consider the proposed actions to be protec-
tive of human health and the environment. DHS also had other
specific comments which will be addressed later in the sum-
mary. The Regional Water Quality Control Board (RWQCB or
Board) also expressed concurrence on selection of alternative
G-3(a).
EPA Response; EPA agrees with and acknowledges the com-
ments.
2. Beckman Instruments (Beckman) and the Tulare County
Department of Environmental Health (DEH) concurred with EPA's
proposal! to continue using the existing pump, treat and dis-
charge technology (including air stripping) to address the
remaining contamination in the upper aquifer. Beckman and DEH
commented that this technology has proven itself to be a tech-
nically s^ud and effective treatment method. DEH also em-
phasized t&it the necessary components are in place and that
the community im familiar with this treatment method and has
confidence in it.
EPA Response; EPA agrees with and acknowledges the com-
ments .
3. Two (2) residents commented that they fully agree with
EPA's Proposed Plan for Beckman. They stated that they were
very concerned regarding the spread of contamination in the
lower aquifer toward them. They said it was unfortunate that
-------
more people who live in the unincorporated area around the
project were either unaware or unwilling to attend the public
meeting.
EPA Response! EPA agrees with and acknowledges tbe com-
ment.
4. Beckman stated that EPA's Proposed Plan lacks a descrip-
tion of the specific criteria to be used to determine when, the
remedial action has been completed. Beckman proposed a
criterion that would call for them to continue operating the
. pump and treat system for six (6) months after the concentra-
tion of 1,1 Dichloroethylene (DCE) in the upper aquifer drops
to or below the selected clean-up goals. Monitoring of
selected wells would then continue for a one-year period
thereafter. If DCE concentrations remain at or below selected
clean-up goals during that monitoring year, then remediation
would be considered complete.
EPA Responset The purpose of the Proposed Plan is to
provide a short summary of the remedial alternatives evaluated
in the Feasibility study for a particular site and to present
EPA's preferred alternative for site remediation. The\
detailed criteria will be determined by EPA following discus-
sions with Beckman.
Soils
1. Beckman disagreed with EPA's proposal to address lead-
contaminated soil at the site. Beckman said that excavation
and treatment of this soil was unnecessary. Beckman cited the
relatively small volume of soil affected and that EPA's plans
are based on the result of one (1) soil sample out of about
200 samples taken. Beckman sited the fact that this one
sample was taken at a depth of 1 1/2 feet below the surface in
an area already designated by the City of Porterville as a fu-
ture road site. Beckman said that all of these factors con-
tribute to posing a low risk of human exposure and therefore
; don't warrant EPA's proposed excavation, treatment and dis-
posal plans.
EPA Response* KPA's Proposed Plan was based .on the
results of the Feasibility Study/ prepared by Beekman. The PS
estimate4^|>at approximately 740 cubic yards of soil were con-
taainate4titteve 40 ppm, the level assumed in the F8 to be the
clean-up9^1. BPA has acknowledged that the volume of soil
contaminate* above 200 ppm (the cleanup goal set in this ROD)
may be much less than estimated in the F8. EPA has therefore
selected, conditional upon information determined during
remedial design, remedial alternative 8-3, Excavation and off-
site disposal for remediation of soil contaminated with lead
in excess of 200 ppm.
2. Tulare County OEH commented t.iat they concur with EPA's
proposal to excavate and dispose of Beckman's lead-
contaminated soil. OEH said, however, that it didn't find
-------
sufficient justification to require soil treatment prior to
disposal. DEH believes the health threat posed by these soils
to be minimal. DEH said they were uncertain whether the
solidified material could be determined to be non-hazardous
and, therefore, be disposed of in a Tulare County landfill.
DEH stated that the treated material1 would remain a
"designated waste" and DEH has not determined how to treat
these classes of wastes.
EPA Response; EPA acknowledges the comment and has
selected remedial alternative 8-3, Excavation and offsite dis-
posal as the remedial action.
3. The RWQCB stated that the constituents detected above
background levels do not pose a threat to water quality and
that Alternative S-4, excavation, treatment, and off site dis-
posal is an acceptable alternative.
EPA Response! EPA acknowledges the comment.
Aouitard/Lower Aquifer
i
1. Beckman, Tulare County DEH and Congressman Pashayan com-
mented that they believe insufficient data exists to select a
remedy or clean-up goal for the aquitard/lower aquifer. DEH
said "the data appears scant to warrant committing to a sig-
nificant course of action". DEH believes the missing data
could be obtained relatively quickly and could provide a
clearer understanding of the extent of contamination in these
zones. Congressmen Pashayan added that while Congress is con-
cerned about expeditious completion of Superfund clean-ups,
their primary concern is the overall quality of the work and
assuring appropriate and cost-effective remedies.
Beckman stated that the missing information is critical
to adequately prescribe clean-up methods and goals. Beckman
said that implementation of EPA's proposed remedy without suf-
ficient data could ultimately prevent removal of aquifer con-
taminants or vastly increase the time necessary to remove
them. Beckman cited important missing data which included
better definition of the areal extent ofiaquifer contaminants,
the hydraulic relationships between the) two aquifers and the
aquitard,^an evaluation of potential upgradient sources of
contamination and the extent to which aquifer contaminants can
be stored, transmitted or released in response to pumping in
these aquifers and the aquitard. Beckman stated that, follow-
ing further study, EPA's Maximum Contaminant Levels (MCLs)
would presumably be the appropriate clean-up goal for the
lower aquifer but this determination could only be made at the
completion of further work.
EPA Response! SPA recognises that additional work will
be required to develop detailed design parameters regarding
the remedial action for the aquitaird and lower aquifer. EPA
disagrees that implementation of ,'EPA's proposed remedy may
-------
preclude effective implementation of a general remedial action
for these units. Of the technologies evaluated in the FS,
pumping and treating ground water (pump and treat), no action
and institutional controls were the three technologies
believed to be feasible at this time. Neither the no action
nor the institutional control alternatives are acceptable to
EPA, the State Water Quality Control Board and the state
Department of Health Services. These alternatives require
controlling risks to public health and the environment for
several hundred years and they do not comply with Applicable
or Relevant and Appropriate Requirements (ARARs). Thus, the
only feasible technology at this time appears to be pump and
treat. EPA acknowledges that the effectiveness of the
remedial action in removing contaminants to cleanup goals is
not fully known. The effectiveness of any pump and treat sys-
tem (except hydrologically ideal systems) can only be deter-
mined .after the operation of such a system.
2. The RWQCB has stated that Alternative LG-5 is an accept-
able approach. However, the RWQCB has recommended that
cleanup goals be established for the aquitard as well because
the Board staff "...believe that the aquitard is a potential*
source of water" and that "Waters in the aquitard are waters
of the state."
EPA Response; EPA agrees with the Board's conclusions
regarding establishing.clean up goals for the aquitard. EPA
will be discussing this issue with Board staff.
TECHNICAL QUESTIONS/CONCERNS REGARDING REMEDIAL ALTERNATIVES
Most of the comments received during the public comment
period addressed concerns in this category, specifically EPA's
proposed clean-up goals for groundwater and EPA's Endangerment
Assessment (£A).
Proposed Groundvater Clean-up Goals
1. Many commentors expressed the belief that EPA's proposed
clean-up goal of .5 ppb for all of the groundwater con-
taminant* at the site is unrealistic, inappropriate and un-
necessary to protect public health. They stated that the ap-
propriate*ffft«an-up goals should be MCLs. This comment was ex-
pressed iJlVofUi form or another by most of the commentors in-
cluding Beckman, Porterville's Mayor and Chamber of Commerce,
California State Assemblyman Bill Jones, California State
Senator Rose Ann Vuich, Tulare County Supervisor Gary Reed,
Porterville Civic Development Foundation, TAKARE, Rees Inc.,
Bank of the Sierra, .Congressman Charles Pashayan Jr., and
eighteen (18) local residents. Mayor Ensslin said that the .5
ppb clean-up goal requirement was unrealistic and could take
15-25 years to accomplish.. Sectarian, as well as Assemblyman
Jones and Senator Vuich, s£id that MCLs are fully protective
-------
of human health and the environment as stated in EPA's own
guidance documents. Senator Vuich also said that MCLs incor-
porate an adequate margin of health safety.
EPA Response; EPA has considered these comments and is
selecting MCLs as the clean-up goals for this site.
2. Beckraan commented that MCLs are the appropriate clean-up
goals at this site especially considering the fact that EPA's
Maximum Contaminant Level Goal (MCLG) for the Beckman in-
dicator chemical (1,1-DCE) is the same as the MCL for that
substance. Beckman considered it is unnecessary to set a
clean-up goal lower than EPA's MCLG when the MCLG, by its
definition, is the level of the chemical at which EPA has
determined it poses no known or anticipated adverse health ef-
fect and allows an adequate margin of safety.
EPA Response; EPA has considered these comments and is
selecting MCLs as clean-up goals for this site.
3. Supervisor Reed urged EPA to adopt clean-up methodologies
and criteria that will assure health and environmental protec-
tion while still allowing a measure of reasonableness. Super-
visor Reed said he did not feel obligated to force the limits
of technology nor does he consider a totally risk-free society
attainable.
EPA Response; EPA has considered these comments and
believes that selection of MCLs as clean-up goals provides
adequate protection to public health and the environment.
4. Tulare County DEH commented that it believed EPA's
proposed clean-up goals were extremely conservative. DEH sup-
ported setting clean-up goals at MCLs or possibly 10% lower.
OEM questioned whether the aquitard sediments would release
enough of the contaminants to ever get down to the .5 ppb
level in the aquitard and aquifers.
EPA Response; • EPA has considered these comments and is
selecting MCLs as clean-up goals. The effectiveness of the
pump and treat system will be reviewed within five years.
5. Senator Vuich said she would be supportive of clean-up
goals more stringent then MCLs (possibly as low as .5 ppb) if
research existed that demonstrated significant health benefits
due to the lower concentrations. DEH commented that it
believes thejyidditional health benefits to be realized due to
the .5 ppb cgjpftn-up goal vs. MCLs to be more theoretical than
actual.
EPA Response! EPA has considered these comments and is
selecting MCLs as olean-up goals for this site.
6. Several residents commented to the effect that drinking
water standards (MCLs) were sufficient until there was proof
of health damage. Several residents voiced the belief that if
MCLs are good enough for drinking water and that the city or a
8
-------
water company- can pipe water to them at MCLs, then it should '
be good enough for the groundwater where, as one person said,
"Mother Nature is continually working on it".
EPA Response; EPA has considered these comments and is
selecting MCLs as the clean-up goals for this site.
7. DHS commented that it understood 1,2-DCA was also present
near the facility. DHS observed that the California MCL
(CMCL) for 1,2-DCA is .5 ppto and, as such, they would concur
with EPA's proposed clean-up goal. DHS stated, however, that
if the presence of 1,2-DCA is found to be insignificant or ap-
pears isolated, EPA may want to "review" its proposed clean-up
goal.
EPA Response; Although 1,2 OCA has not been selected as
a contaminant of concern/ it has been detected sporadically at
the BecJcman site. The source of this contaminant is unknown/
however/ and additional investigation will be required to
determine the source such that clean-up goals can be estab-
lished at the source.
8. DHS commented that if contaminants remain in the aquitard
after cleaning up the upper and lower aquifers, the aquitard
may act as a source of continued groundwater contamination.
DHS .suggested that clean-up goals be applied to the aquitard
as -well as the upper and lower aquifers. The RWQCB has made a
similar comment.
EPA Response; EPA agrees with the comment. Clean-up
goals will be applied to all units which are potential drink-
ing water sources. The effectiveness of pump and treat tech-
nology in removing contaminants to MCLs will be reviewed
within five years.
9. The RWQCB recommended that clean up limits be set at
least as low as the federal and state drinking water stan-
dards, however they state that final clean up limits be deter-
mined after "...consideration of the cost of achieving each
additional increment of cleanup below drinking water standards
and the benefit to the environment of that increment." They
further recommend that "...the upper aquifer be remediated
below drinking water standards until it can be demonstrated by
Beckman Instruments that benefit to the environment no longer
justifies the •conomics of additional cleanup' efforts."
EPJL-fiAifisVffci "A has considered these comments . EPA is
selecting MCLs>^nr clean up goals for this site.
Bndanaerment
1. Beckman, Tulare County DEH, and several individuals com-
mented to criticize the Endangerment Assessment (EA) for the
site prepared by EPA and its contractor. These commentors '
generally said that the EA is seriously flawed and should be
revised. Most commentors said that the materials relied upon
in the EA are factually outdated (i.e. the assumed 1986 shut-
-------
down of existing pump and treatment systems) and grossly un-
realistic. Several commentors noted that this very admission
is stated in.the EA itself.
EPA Response? The Endangarment Assessment prepared for this
site follows the procedures and methods specified in the su-
perfund Public Health Evaluation Manual. EPA is required by
the National Contingency Plan (NCP) Section 300.68 (e) t (f)
to evaluate the risks to public health and the environment un-
der a "no action" scenario. Because interim remedial action
had already begun at this site, .it vas necessary to select a
date at which it vas assumed that all on-going treatment sys-
tems were terminated and unrestricted access to contaminated
groundwater vas possible. This date vas agreed to by Beckman
as August, 1986. The risks developed in the Endangerment As-
sessment (EA) were therefore maximum risks which could be ex-
perienced in the event the current system vas terminated. As
the public is aware/ this system has not been terminated (for
the upper aquifer), thus the risk scenarios developed in the
EA were not a reflection of actual conditions. Rovever it was
necessary to develop these risk scenarios to be consistent
•with national EPA policy and guidance.
2. Tulare County DEH commented that the concept of using a
risk assessment (here called the EA) analysis is well founded
and they strongly support the concept and its objectives. DEH
felt the Beckm'an EA did not provide worthy support or jus-
tification to either the concept or the objectives. DEH
stated that the rationale for developing a "worst case"
scenario and establishing requirements on that basis is defen-
sible and provides for selecting conservative standards or
criteria. OEH said that the EA for the Beckman site does not
present a credible "worst case", nor does it evidence serious
scientific review. DEH observes that "the EA appears to be
primarily a compendium of bits of information with implied
significance but without discernible support bases. It ap-
pears that the report was compiled from cursory literature
selections and lacked review by health professionals." DEH
recommended the EA be reviewed and reconsidered by health
professionals.
| TJFA BtilfllHi The EA vas prepared following EPA Super-
funjd Public BMlth Evaluation Manual procedures. The EA vas
reviewed by tealth professionals including internal reviev by
Labat-Andersoji personnel (EPA's contractor vho developed this
EA), EPA Headquarters and Region 9 toxicology staff and by the
Agency for Toxic Substances Disease Registry (AT8OR). All of
these; professionals are either medical doctors or PhD
toxicologists. See also response to comment nusJ»er 1.
3. Beckman commented that the EA erroneously treated 1,1-DCE
as a carcinogen. Beckman observed that this was contrary to
many other official statements by EPA. Beckman cites, in ad-
10
-------
dition to studies, EPA's work plan for the Sectarian site which
states on page 2-32 that ". . .,EPA considers the data insuf-
ficient to classify DCE as carcinogenic."
EPA Response; EPA has determined 1,1 DCE to be a Class C
carcinogen and has developed a Cancer Potency Factor (CPP) for
this chemical. The Superfund office at EPA (the Office of
Solid waste and Emergency Response) has developed a policy to
treat all carcinogens, regardless of class/ as carcinogens and
recommends including them in calculations to determine cumula-
tive risks for a particular Superfuad site.
4. Sectarian also comments that it believes its Risk Assess-
ment is valid and1 sound. Beckman questions why its Risk As-
sessment, which was included with its draft Feasibility Study
(FS) for the site was disavowed by EPA without an explanation.
Beckman comments that EPA's FS Addendum fails to discuss
EPA's basis for disregarding Beckman's findings and that Be-
ckman followed the Public Health Evaluation Manual in prepar-
ing its Risk Assessment.
EPA Response; EPA has determined that the Beckman risk
Assessment does not follow the procedures in the Superfund
Public Health Evaluation Manual because not all exposure path-
ways were considered. For example/ no inhalation or dermal
exposure routes were considered although these routes are a
major concern when dealing with volatile organic chemicals
(VOCs).
•
5. Dr. James Lessinger commented that he has called the
"company that put this (EA) together" to verify and get addi-
tional information regarding materials cited in the EA and has
not had his phone calls returned. He states that he called
specifically to get a list of the references that were ex-
tracted from TOX-LINE and MED-LINE searches as stated in the
EA.
EPA Response; The EA was released by the Environmental
Protection Agency. Any additional information can be obtained
by contacting Carolyn Thompson at EPA's Regional Office in San
Francisco, CA.
OTHER IMPACff
Beck«l^r has commented that EPA, in formulating its
Proposed PMv for the Becknan site, has failed to evaluate the
additional implications of setting clean-up goals less than
MCLs including the economic impacts on the community and the
precedential effect on other Superfund and state lead sites.
Economic Impacts
1. Porterville's Mayor and Chamber of Commerce as well as
Supervisor Reed/ Senator Vuich, the Bank of Sierra and at
least six (6) other residents commented on the negative
11
-------
economic impact to the Porterville community that would be
caused by EPA's' Proposed Plan, in particular its proposed
groundwater clean-up goals. Most commentors said that the
length of time necessary to achieve these'clean-up goals as
well as the negative image associated with a community with
groundwater contamination problems would cause residents and
businesses in and around Porterville to suffer enormous and
unnecessary economic hardships. In describing this negative
image, several commentors, including Mayor Ensslin, Supervisor
Reed, Senator Vuich and Beckman, described how Porterville's
efforts to attract new industry and development to its En-
terprise Zone would suffer due to the expressed reluctance of
industries to move to a community or area branded as con-
taminated. Also described was the potential for negative im-
pact on the sales of produce and animal products from the area
because of fear that these products may be "unsafe" due to ex-
posure to the contaminated groundwater. Several commentors
also said that land values and the marketability of land for
development would be hurt due to the stigma of being con-
taminated and the long term uncertainty of when, if ever, the
land would actually be completely cleaned 'up. \
EPA Response; The purpose of remedial action is to en-
sure that contamination from the Beckman site is removed from
groundwater and soil. Beckman has estimated that the upper
aquifer will reach MCL standards vithin a year. The soil con-
tamination can be removed in less than one year. Thus, these
resources will be restored to full beneficial uses. The lover
aquifer and aquitard will take considerably longer to remedy.
However/ as most have commented/ Beckman has taken respon-
sibility for the site.
2. Supervisor Reed said that he was concerned EPA's approach
created a disproportionate focus on the remaining small
problem which might convey an inappropriate image of the com-
munity. He urged EPA to balance its printed material in the
same fashion as its oral presentations at the June 22, 1989
public meeting in Porterville.
EPA Resoonset BP.A acknowledges the comment.
3. Beckman, as well as several residents, commented on the
need to redefine the areal extent of site boundaries. These
commentors/ agreed that it was unfair and unnecessary to have
large ar«M of land vithin the original Beckman study area
remain uikmr a "cloud of contamination" for the 15-25 years
necessary to achieve the clean-up goals. These commentors
feel this is especially.inappropriate given the dramatic size
reduction of the contamination plume in the upper aquifer due
to the operation of Beckman's pump and treat system. These
commentors want EPA to clearly delineate which areas are con-
taminated and which are not and to remove these non-
contaminated areas from the study area.
12
-------
EPA Response; Until the site as a whole is determined to
be free of contaminants, EPA will continue to monitor the
remedial action. As portions of the site are cleaned up, EPA
may chose to issue fact sheets describing this progress to
date. These fact sheets are purely informative and are not a
warranty nor are they to be considered as a release of any
Kind.
4. Several comnentors said that it was unfair to "tie up"
(essentially "freezing") people's land for 15 - 25 years to
attain unnecessary and possibly unattainable clean-up goals.
These commentors also objected to having to keep their land
available for access by sampling and testing personnel for an
indeterminate length of time.
EPA Response; EPA understands the inconvenience of con-
tinued access for testing purposes. However, the mission of
EPA is to determine the extent of any contamination and
whether a threat or potential threat to public health and the
environment exists. To this end, EPA must continue to oversee
the remedial action progress. Once an area is determined to
meet cleanup goals, the applicable oversight schedule may be
reduced. Future facts sheets vill describe these changes.
i
5. Beckman suggested creating separate operable units to ad-
dress the different contaminant problems. Beckman suggested
that the upper aquifer be removed from the National Priorities
List (NPL) once its clean-up goal had been achieved.
EPA Response; EPA has determined that the most efficient
way to address this site is to implement concurrent remedial
actions for each affected media.
Precedential Effects
1. Beckman, as veil as Senator Vuich and a resident, com-
mented on the potential precedential impact of EPA's proposed
clean-up goals at the Beckman site. Beckman cited the ques-
tion EPA will face regarding the applicability of these
clean-up goals vs. MCLs to other sites around the country, in-
cluding those sites on federally owned or operated facilities.
EPA KesDonset SPA acknowledges these comments. EPA has
selected MCLS mm clean-up goals.
2. Becjfean also said that EPA's proposed clean-up goals
would place a cloud over the adequacy of MCLs as drinking
water standards by implying that MCLs and MCLGs are not really
fully protective of public health.
EPA Eespoasei EPA does not believe that the protective-
nees of MCLs ox WCLQm are questioned when cleanup goals are
••tablisaed at lower levels. Superfund sites oftea have a
complex mixture of chemicals requiring oleaaup levels more
•triageat than MCLs due to the additive nature of oareiaogenic
rick. EPA, however, has elected to establish MCLs as clean-up
9oal8 at this site.
13
-------
3. Beckman also commented that rejection of MCLs as clean-up
goals calls into question the adequacy of remedy selection at
other sites where MCLs have already been selected, including
state lead sites.
BPA R«spona«t Bach Superfund site is unique and must be
evaluated individually. See response to comment 12.
PUBLIC PARTICIPATION PROCESS
Beckman, as well as several local residents, submitted
comments regarding either the amount of time available to them
during the public comment period to review EPA's Proposed Plan
and^related documents and prepare comments or the availability
of public notice regarding site activities, in particular the
scheduling of the public meeting and the public comment
period.
Public Comment Period
1. Beckman states that they have been denied a reasonable
opportunity to prepare and submit written and oral comments on
EPA's Proposed Plan and related site materials as required by
SARA/CERCLA. Beckman cites several examples including that
the site's Administrative Record wasn't available to it until
four (4) days after the start of the public comment period,
and that EPA has fai'led to respond to Beckman's FOIA requests
for additional materials.
EPA Response: The Administrative Record for the sit* has
been available at the Porterville Public Library since Novem-
ber 30, 1988. EPA updated the information on June 19, 1989.
EPA will again update the Administrative Record to make it
complete after the issuance of this Record of Decision. EPA
has responded to the Freedom of Information Act request (FOIA)
submitted by Latham and Watkins, attorneys for Beckman. Al-
though a response was not issued until after the close of the
public comment period, it must be noted that the public com-
ment period is intended to be limited to comment on the
remedial alternatives contained in and described in the
Proposed Plan, the TB Addendum and Beckman's FS.
2. Beckman expresses its appreciation to EPA for the one-
week extensioorof the public comment period but states that it
needed an additional thirty (30) days to conduct a thorough
analysis of EPA's Proposed Plan and Administrative Record and
prepare extensive comments.
EPA Responset EPA believes that the public comment
period provided ample opportunity to comment on the remedial
alternatives described in the Proposed Plan and in Beckman1s
F8. BPA provided more time than is required under the current
or proposed National Contingency Plan (NCP).
14
-------
3. Beckman also describes information missing from the Ad-
ministrative Record which it believes should be included.
This material includes all correspondence between EPA and Be-
ckman and all correspondence between Beckman and others
regarding the site where EPA received copies of the materials.
Beckman also submitted additional documents with its written
comments that were used in preparing its comments for inclu-
sion in the Adainistrative Record.
EPA Response; Beckman should contact EPA with the infor-
mation it believes ia missing fro* the Administrative Record.
EPA vill review this information and place the appropriate
material in the Record.
Public Notice
1. One (1) resident who lives in the vicinity of the site
commented that he was concerned that his neighbors were un-
aware of the spread of the contamination plume in the lower
aquifer toward them and the dangers it represents. This resi-
dent also fully supported EPA's Proposed Plan. One (1) corn-
mentor also said that some residents have the naive belief
that Beckman, the local government and the EPA will not allow'
the Beckman contamination to harm their, water supply.
EPA Response: Implementation of the remedial action
specified in this ROD vill ensure that the plume of contamina-
tion in the lover aquifer vill not spread and that vater sup-
plies outside the zone of contamination are safe for all pur-
poses.
2. Two (2) commentors said that they learned about the con-
tamination problem from their neighbors and didn't receive
EPA's "packet" (fact sheet) in the mail and believed that only
a few people did.
EPA Response: EPA mailed over 1100 fact sheets to resi-
dents of the Porterville community; 92 vere mailed from EPA's
mailing list and over 1000 vere mailed to residents in the
site vicinity according to sip code. EPA also issued several
press releases describing the material available at the public
library. EPA apologiies to those residents vho did not
receive fact sheets and hopes that all interested individuals
had a chajkc* tct provide their comments.
15
-------
OTHER CONCERNS
. other concerns commented on include the need to be fair
to Beckman in prescribing clean-up goals, BPA's credibility
with Porterville's community members, health concerns and re-
quests for water well testing.
Fairness
1. This issue was second only to the question of appropriate
clean-up goals in drawing comments from Porterville community
members. Mayor Ensslin, Supervisor Reed, Assemblyman Jones,
Dr. Lessinger along with eleven (11) residents spoke to the
need for EPA to be fair to Beckman in prescribing clean-up
goals.
Most commentors including Mayor Ensslin and Assemblyman
Jones said that Beckaan had done an outstanding (exemplary,
"world class") job in addressing its contamination problems,
and that they should not be taken advantage of. They cited
Beckman's early pro-active response to the discovery of
groundwater contamination and the installation of'its pump and
treat systems which halted the spread and reduced the extent
of contaminated groundwater. They observed that Beckman com-
mitted substantial resources to the problem many years earlier
than it would have been required to do so under the Superfund
program. These commentors cited the millions of dollars Be-
ckman has spent in responsibly addressing the contamination
problems, including providing bottled water and city water
hookups to affected households and said that it was unfair to
require Beckman to spend many more millions of dollars and
years of work to accomplish unrealistic and unnecessary
clean-up levels. These commentors generally urged EPA to, as
one commentor at the public meeting expressed, "set reasonable
standards and get off their backs"!
EPA Raaoonset SPA sets clean-up goal* to protect public
health and the environment. EPA agrees that Beckaaa has been
responsible in addressing the contamination caused by their
operation*.
2. Several JfcpsMntors mentioned that in setting what appears
to be grossljgjpfair and unnecessary clean-up goals for the
Beckman site^nttKA appears to be punishing a company who has
acted as a responsible corporate citizen and has pro-actively
and effectively addressed its contamination problems. In es-
sence, "punishing them for doing a good job". Supervisor Reed
observed that he was aware of the need for specific processes
to be required in prescribing how government agencies carry
out their responsibilities and deal with the public but ob-
served that, absent some ability to be flexible and provide
16
-------
alternative provisions for cooperative, good-citizen com-
panies, these mandated processes can seem unfair and create
confusion and concern among a community's citizens.
EPA Response; see response to comment number l.
3. Several commentors stated that Beckman can be relied on
to accomplish any reasonable clean-up activity and should be
allowed to continue and complete their existing clean-up plan.
EPA Response; EPA believes that Beckman will be coopera-
tive in reaching a final clean-up agreement for this site.
Part of the remedial action will be to continue their existing
pump and treat system for the upper aquifer.
4. One (1) resident wrote to say that if Beckman has to meet
the .5 ppb clean-up goal then the city and all water companies
should have to meet the same requirements.
EPA Response: As discussed in an earlier response/ all
Superfund sites are unique and evaluated individually. Public
water supply systems have to meet standards set under the
Clean Water Act, most notably MCLs. As noted earlier, EPA is
selecting MCLs as clean-up goals for this site.
5. The Porterville Chamber of Commerce expressed concern
that it appeared that Porterville was being singled out for a
clean-up process that goes far beyond the norm.
EPA Response; EPA establishes clean-up goals to protect
public health and the environment. in this case/ EPA has
selected MCLS as clean-up goals after reviewing all the infor-
mation and considering public comment.
EPA's Credibility
1. One resident expressed concern that EPA's proposed
clean-up levels at BecJonan appear to be driven by outside in-
fluences, specifically congressional dissatisfaction with EPA
or EPA's recent involvement in the Alar controversy. This
coramentor suggested that EPA was attempting t'o look good by
zealously setting very conservative clean-up levels at detec-
tion' "limits.
EPA Response* BPA'a clean-up proposal is consistent with
EPA regulations, policy and guidance.
2. A resident suggested that EPA is so geared up to confront
uncooperative-companies that it is unprepared to deal with a
company who started clean-up before EPA got involved and has
made "doing the job right" a corporate priority. This same
commentor also suggested that since it rarely/ if ever/ hap-
pens that EPA has declared a site clean, that EPA is simply
not prepared to say when "it" is finished.
EPA Response! SPA deals with all companies on an equal
basis. The criteria for determining when the site has been
cleaned up will be discussed between Beckman and EPA in upcom-
ing negotiations.
17
-------
*3. One individual commented that EPA "ambushed it
credibility" with the materials in the Endangerment AssessmT"?
as well as on other issues. He stated that he "can't believo
a thing they say".
EPA Response; EPA acknowledges tit* coma oat.
Health Concerns
1. Three (3) residents commented about general health con-
cerns, they had for themselves and their families regarding
past and potentially future consumption of contaminated
groundwater. One (1) commentor stated that her husband had
died of cancer and another commented on the "scum awful taste"
of her well water currently.
EPA Response: EPA acknowledges the comments. The site
contaminants are tasteless in the concentrations found at this
site, however the commentor could have the well tested.
2. One (1) commentor said that although they have been
hooked up to the city water system for her house, she uses
well water to irrigate her garden and was concerned about the
health risks posed by eating the garden vegetables.
EPA Response; in the EA conducted for this site, the
maximum plausible risk associated with eating contaminated
produce would be 8.8X10-6 or 8.8 chances in one million. This
is well within EPA's risk range of 10-4 to 10-7. It is ex-
pected that the potential risk to this commentor to be much
less than what was estimated in the EA, however EPA would be
willing to discuss this further with the commentor.
3. Five (5) commentors requested that their wells be tested
for the presence of contaminants. One of the commentors was
the woman whose husband had died of cancer. One commentor
stated that she had requested veil testing before and had been
told it would be done but it had never happened.
EPA Response; EPA has been requested to test residential
wells south and southwest of the Beckman plant. Although the
data currently gathered do not suggest that contamination has
spread that far, EPA has contacted all these commentors and
will be testing their veils in the near future.
1. One (1) ~*eosjMJitor expressed anger that she hadn't
received any monetary settlement from Beckman because she
didn't know how to file for it. She observed that others on
her street had received such settlements.
EPA Response: EPA suggests that this commentor contact
private legal counsel for advice on how to proceed.
18
-------
D. REMAINING CONCERNS
EPA is currently not aware of any issues or concerns that
have not been addressed during the RI/FS and remedial planning
activities.
19
-------
ATTACHMENT
COMMUNITY RELATIONS ACTIVITIES
AT BECKMAN INSTRUMENTS
Community relations activities conducted at Beckman Instru-
ments to date have included:
o Joint press conference to announce early sampling results
held by Regional Board, OHS and Beckman (Summer 1983) . „
o EPA conducted community interviews with local leaders and
community members (October 1986).
o EPA established an information repository at the Porter-
ville City Library.
V
o EPA prepared and distributed a fact sheet on the
availability of the RI/FS work plan for review (March 1987).
o EPA prepared and distributed a fact sheet update #1 to
announce the Regional Board's proposed waste discharge re-
quirements for Beckman's proposed groundwater extraction,
treatment and discharge system (May 1987).
o EPA prepared a Community Relations Plan (August 1987)
o EPA prepared and distributed a fact sheet describing the
availability of the draft Feasibility Study and EPA's Proposed
Plan for public review and comment (June 1989).
o EPA conducted a briefing with Porterville's local leaders
to explain EPA's Proposed Plan for the Beckman site (June
1989).
o EPA conducted a public meeting and public comment period
to explain its Proposed Plan, answer questions and receive the
community*»-comments (June/July 1989).
20
------- |