EPA Superfund
Record of Decision:
United Heckathorn Site,
Richmond, CA,
10/26/1994
PB95-964501
EPA/ROD/R09-95/121
November 1994
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RECORD OF DECISION
United Heckathorn Superfund Site
Richmond, California
EPA ID#CAD981436363
PART I - DECLARATION
Statement of Basis and Purpose
This Record of Decision ("ROD") presents the selected remedial action for the United
Heckathorn Superfund Jite ("the Site") in Richmond, California. This document was developed in
accordance with the Comprehensive Environmental Response, Compensation and Liability Act of
1980, ("CERCLA"), as amended by the Superfund Amendments and Reauthorization Act of 1986
("SARA"), 42 U.S.C. §§9601 et seq., and, to the extent practicable, in accordance with the
National Oil and Hazardous Substances Pollution Contingency Plan ("NCP"), 40 C.F.R. Part 300,
and the laws of the State of California. This decision is based on the Administrative Record for the
Site. The administrative record index identifies the documents upon which the selection of the
remedial action is based.
Assessment of the Site
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of the Remedy
The United Heckathorn Superfund Site in Richmond, California, was used to formulate
pesticides from approximately 1947 to 1966. Soils at the Site and sediments in Richmond Harbor
were contaminated with various chlorinated pesticides, primarily DDT, as a result of these pesticide
formulation activities. At the time of Site listing in 1990, a visible deposit of pesticide residue
containing up to 100% DDT was present on the Lauritzen Channel embankment. Several response
actions have already been taken to cleanup the most contaminated upland areas of the Site,
including the embankment. Under EPA Removal Order 90-22, a group of Potentially Responsible
Parties (PRPs) excavated the embankment deposit and transported it offsite to a permitted disposal
facility. During subsequent actions through 1993 pursuant to the removal order, all known
additional upland soil deposits containing high levels of pesticides were removed, as were piles of
contaminated soils generated in earlier actions.
The final remedy addresses remaining hazardous substances, primarily in the marine
environment. The major components of the selected remedy include:
Dredging of all soft bay mud from the Lauritzen Channel and Parr Canal, with offsite
disposal of dredged material.
Placement of clean material after dredging.
Construction of a cap around the former Heckathorn facility to prevent erosion.
A deed restriction limiting use of the property at the former Heckathorn facility location to
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non-residential uses.
Marine monitoring to verify the effectiveness of the remedy.
Statutory Determinations
The selected remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate ("ARARs") to
the remedial action, and is cost effective. The selected remedy uses engineering controls and
institutional controls to address remaining hazardous substances at the Site. Concentrated wastes
at the upland portion of the Site were addressed by previous removal actions.
Because this remedy will result in hazardous substances remaining onsite, a review will be
conducted within five years after the commencement of remedial action, and every five years
thereafter, to ensure that the remedy continues to provide adequate protection of human health and
the environment.
Felicia^Marcus -J^ Date
Regional Administrator
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PART II - DECISION SUMMARY
United Heckathorn Superfund Site
Richmond, California
1. Site Name. Location, and Description.
The United Heckathorn Site is located in Richmond Harbor, on the east side of San
Francisco Bay (Figures 1 and 2) in Contra Costa County, California. The location of the former
United Heckathorn facility (Figure 3) is currently being used as a marine shipping terminal operated
by the Levin Richmond Terminal Corporation (LRTC). The area of contamination at the Site includes
the northern five acres of the terminal and marine sediments in harbor channels including the
Lauritzen, which is immediately adjacent to the location of the former Heckathorn facility, the Santa
Fe, the Parr Canal, and the Inner Harbor Channel.
The upland area of the Site is currently fenced and occupied. Current and expected future
zoning of the upland area of the Site permits only industrial use. Land use restrictions selected as
part of the Site remedy will also permit only nonresidential, industrial or commercial uses in the
future.
2. Site History and Enforcement Activities.
The upland area of the Site is currently owned by Levin Enterprises, Inc. The Site was used
from approximately 1947 to 1966 by several operators, including the R.J. Prentiss Company,
Heckathorn and Company, United Heckathorn, United Chemetrics, and Chemwest Incorporated
(hereafter collectively referred to as "United Heckathorn") to formulate and package pesticides. No
chemicals were manufactured onsite.
Documents from the 1950s and 1960s indicate that approximately 95% of Heckathom's
operations entailed processing the pesticide, DDT. The processing activities included mixing,
blending, grinding, and packaging. Various solvents, including xylenes, were used to dissolve DDT
and other pesticides into liquid formulations. Powder formulations were also prepared.
United Heckathorn employees apparently routinely washed out equipment containing
pesticide residues. The wash water was permitted to either run through drains that discharged to
the Lauritzen Channel, or to seep into the ground adjacent to the Site (Levine-Fricke, 1990). Later,
settling tanks were used to recover pesticide residues from wash water; however, overflow and
leakage from these tanks also occurred. In addition, accidental spills, leaks, and releases also
occurred during the processing of liquid and dry pesticide formulations, which were conducted both
inside and outside the United Heckathorn buildings.
In 1960, the San Francisco Bay Regional Water Quality Control Board (SFBRWQCB)
inspected the facility and cited United Heckathorn for the release of DDT-laden wastewater into the
Lauritzen Channel. In 1965, California Department of Fish and Game staff identified a discharge of
wastewater overflow into the Lauritzen Channel and leakage from the pesticide settling tanks.
Pesticide processing activities at the Site ended in approximately 1966. Between 1966 and
1970, the United Heckathorn facility buildings were demolished and cleared from the Site. In the
1970s, the Site was apparently used primarily for bulk material storage. In 1981, the Levin Metals
Corporation purchased the property from the Parr-Richmond Terminal Company and has been
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operating the Site since that time as a bulk shipping facility.
In 1980, the United Heckathorn Site was inspected and sampled by CDHS as part of the
Abandoned Sites Project. Chlorinated pesticides and metals were detected in soil samples, and the
area was designated a state Superfund Site in March 1982. EPA listed the United Heckathorn Site
on the CERCLA National Priorities List (NPL) in March 1990, and took over as lead agency in August
1990.
Interim response actions were conducted from 1982 to 1993 in the upland and embankment
areas of the United Heckathorn Site. As early as 1982, contaminated soil, asphalt, and concrete
from the United Heckathorn Site were excavated by the current landowner and moved to a nearby
lot adjacent to the Parr Canal. These materials were subsequently transported to several hazardous
waste disposal facilities. In 1983, soils containing high levels of pesticides were removed by the
current landowner during routine maintenance and extension of onsite railroad lines. A 6-in. to 8-in.
layer of gravel was placed over the surface of the Site, including a 6-in. layer of ballast rock over
the Lauritzen Channel embankment and selected areas of high DDT concentrations. In 1986, during
excavation for the construction of a train scale, high levels of pesticides were detected and
approximately 60 cubic yards (yd3) of soil were removed by the current landowner.
In November 1990, pursuant to EPA Removal Order 90-22, approximately 1500 yd3 of soil
and visible pesticide residue containing up to 100% DDT were excavated by several PRPs (Levin,
Montrose, Parr, Shell, and Stauffer) from the Lauritzen Channel embankment. This excavation was
taken back to the foundation of the former Heckathorn building 1, where a pesticide deposit
approximately 3 ft thick was revealed beneath the foundation. Samples of this deposit contained
approximately 30% DDT. An additional 1800 yd3 of pesticide residue and contaminated soil were
excavated by the same PRPs from this area in April 1991. The excavated material and stockpiles
that had been placed onsite in the 1980s were hauled offsite by truck to permitted hazardous waste
disposal facilities. A final soil removal action was completed in May 1993 by the same PRPs as
well as Prentiss and Sherwin Williams. Assuming that the embankment deposit contained 30%
DDT, over 99% of the mass of pesticides has been removed from the upland portion of the Site
since 1990.
Marine sediment has not been the subject of prior removal actions or otherwise been
remediated. However, as shown on Figure 3, the southeastern area of the Lauritzen Channel was.
last dredged for berth maintenance in 1985.
3. Highlights of Community Participation.
Six fact sheets have been released describing activities at the Site. In July, 1994 EPA
released a proposed plan and the Administrative Record for the Site. Site documents were made
available at the agency Superfund Records Center and at the Richmond Public Library, and a public
notice was published allowing 30 days for public comment on the Proposed Plan. A public meeting
was held on August 2, 1994 to describe the proposed remedy and receive comments. The public
comment period was then extended an additional 30 days at the request of PRPs. Three persons
made comments at the public meeting, and six written comments on the proposed plan were
received during the comment period. Responses to all significant comments received during this
period are contained in the attached "Analysis of Public Comments." The decision for this Site is
based upon the Administrative Record.
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4. Scope and Role of Remedial Actions.
The remedial actions selected in this Record of Decision are expected to be the final
response actions performed at the Site. As described in the Site history above, significant interim
response measures were performed at the Site in the past. These removal actions addressed the
principal threats at the upland portion of the Site.
The selected remedy addresses the contaminants remaining in sediments at the Site, as well
as the low levels of contaminants remaining in soils at the Site.
5. Site Characteristics.
The nature and extent of contamination at the United Heckathorn Site has been delineated
by the combination of state-ordered Site investigations which occurred prior to NPL listing, and
EPA's subsequent Remedial Investigation (Battelle, 1994). As discussed above, large deposits of
extremely high levels of pesticides remained in upland soils after United Heckathorn ceased
operations in 1966. These have been the subject of extensive excavation and removal actions over
the past three years.
A soils database representing current Site conditions was compiled in EPA's Human Health
Risk Assessment (ICF Technology, 1994) from the previous Site studies and removal action reports.
A conservative estimate of the remaining mean Site soil concentrations of the primary Contaminants
of Concern (COCs), DDT (total) and dieldrin, are 64 and 5.7 milligrams per kilogram (mg/kg),
respectively. These estimates are conservative because the soils database includes the large
number of additional samples which were taken to delineate the hot-spot areas for the removal
actions. The actual mean Site concentrations are likely to be lower.
DDT at levels exceeding 1 mg/kg in upland soils extends over the upland portion of the Site
as shown in Figure 4. The total mass of these upland soils is approximately 95,000 tons
(Levine-Fricke, 1993). Confirmation sampling performed during the excavations of the most
contaminated soil areas indicated that the concentrations drop to nondetectable levels in the
younger bay mud immediately below the upland soils, demonstrating that the homogeneous silty-
clay bay mud underlying the Site is an effective barrier to downward migration of Site chemicals.
Due to the Site's proximity to San Francisco Bay, the shallow groundwater at the Site is
naturally saline and is not a source of drinking water under state or federal law.
In 1992, EPA performed a screening assessment of offsite soils (ICF Technology, 1994) in
order to determine whether the historic operations of United Heckathorn could have released
pesticides into the air in sufficient quantities to cause current levels of concern in nearby off-site
residential soils. Sampling locations were chosen along Cutting Boulevard and immediately north of
Highway 580, because the meteorological analysis for EPA's 1988 air monitoring program indicated
that the strongest prevailing winds at the Site blow due north. The sampling program was therefore
deliberately biased to target the area which would have had the highest levels of pesticides, had
Heckathorn caused contamination. All off-site soil sampling results were well within acceptable
levels for protection of human health.
The results of the Rl of marine sediment, however, indicate that the occurrence of
pesticides at the Site, particularly the Contaminants of Concern, DDT and dieldrin, is more
widespread and at concentrations orders of magnitude higher relative to San Francisco Bay
background levels than other detected contaminants. The area! and vertical distribution of marine
contamination is summarized below.
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Vertical core segments and channel edge grab samples were analyzed for chlorinated
pesticides to delineate the area! and vertical extent of marine contamination. Results indicated that
significant pesticide contamination was limited to the soft geologically recent "younger bay mud";
samples from the hard underlying "older bay mud" generally contained only traces of pesticides.
Figure 5 presents the average total DDT concentration in the younger bay mud in the inner
Richmond Harbor. It is significant to note that the concentration contours on this figure must be
presented on a log scale in order to depict the gradient of six orders of magnitude between the
Lauritzen Channel and Point Potrero. The maximum and median total DDT and maximum dieldrin
concentrations throughout the study area are also shown.
Pesticide concentrations were highest in the Lauritzen Channel, and decreased with
increasing distance from the former United Heckathorn Site, clearly indicating that Heckathorn was
the source of contamination. The highest total DDT concentration of 633,000 micrograms per
kilogram (//g/kg) dry wt was measured in a sample from 1 ft to 3 ft below the mudline in the center
of the channel. Pesticide concentrations of greater than 100,000 //g/kg were detected in sediment
from the northern and western portions of the channel. The median total DDT concentration was
approximately 47,000 //g/kg at the head of the Lauritzen Channel, which has not been dredged in a
number of years. The median concentration of total DDT decreased to about 14,000 //g/kg in the
western, undredged portion of the channel, and to 1500 //g/kg in the dredged portion of the channel
near the Levin terminal. Dieldrin concentrations were lower (maximum concentration of
16,000 //g/kg), but exhibited the same spatial trend in relative concentration.
Total DDT concentrations in sediment decreased by at least two orders of magnitude from
the Lauritzen Channel to the Santa Fe Channel. The median concentration of total DDT in the
younger bay mud was 110 //g/kg in the upper Santa Fe Channel and 210 //g/kg in the federally
maintained portion of the channel. DDT and dieldrin concentrations were higher in the federally
maintained portion of the Santa Fe Channel, which includes the area downstream of the Lauritzen
Channel. Total DDT and dieldrin concentrations decreased by another order of magnitude from the
Santa Fe Channel to the Inner Harbor Channel. The median total DDT concentration was 60 //g/kg
in the upper Inner Harbor Channel, and 10 //g/kg in the lower Inner Harbor Channel. The maximum
total DDT concentration near Point Potrero was 19 //g/kg, which is approximately equal to the
median DDT concentration for the periphery of San Francisco Bay, excluding the Lauritzen Channel
(Longetal., 1988).
Pesticide concentrations in Parr Canal sediment were lower than those measured in the
Lauritzen Channel but greater than those measured in Santa Fe or Inner Harbor Channels. The
maximum and median total DDT concentrations measured in Parr Canal sediment were 4080 //g/kg
and 840 //g/kg, respectively. The maximum dieldrin concentration was 170 //g/kg. The Parr Canal
is significantly narrower than it was in the 1940's, due to filling which (based on aerial
photographs) occurred sometime between 1958 and 1968. Some of the material used to fill the
canal may have been dredged from the harbor, possibly explaining the elevated levels of pesticides
in Parr Canal sediments.
Grab samples collected from channel edges throughout the study area showed the same
spatial trend in pesticide concentrations as the core samples. The total DDT concentrations in
channel edge samples were consistent with the median concentration measured in core samples
from that area.
Contaminant concentrations in the younger bay mud were generally not well stratified. In
the shallow portions of the Lauritzen Channel, contaminant concentrations increased, and then
decreased with increasing depth. The most highly contaminated sediment was generally found from
1 ft to 5 ft below the mudline. In the Santa Fe Channel, the most contaminated sediment was
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found down-channel of the mouth of the Lauritzen Channel in the surface sediment, and just
up-channel of the mouth in deeper sediment. Contaminant concentrations were generally higher in
deeper sediment in the Inner Harbor Channel. Analysis of the volumes of contaminated sediments
and the average concentrations in harbor channels indicates that 98% of the mass of DDT in harbor
sediments is confined to the Lauritzen Channel.
Selected core samples collected during the marine Rl were analyzed for polynuclear aromatic
hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), metals, and butyltins. In general, sediment
from the upper Lauritzen Channel and Parr Canal had higher concentrations of PAHs, PCBs, and
metals than sediment from the Santa Fe and Inner Harbor Channels. This is probably because the
larger channels have been routinely dredged for navigation, whereas the northern Lauritzen and Parr
have not. Only the pesticides, DDT and dieldrin, are consistently found in sediments and biota at
levels orders of magnitude higher than the regional background levels.
6. Applicable or Relevant and Appropriate Requirements (ARARs)
Federal and state environmental laws which have been determined to be ARARs for the
remedy are summarized below. Chemical-specific ARARs are discussed first, followed by other
requirements.
Surface Waters: ARARs for surface water include EPA's ambient water quality criteria for DDT and
dieldrin. These are the primary basis for the Site remediation goals.
EPA Ambient Water Quality Criteria. Section 304 of the Clean Water Act required EPA to
publish criteria for water quality that accurately reflect the latest scientific knowledge on the kind
and extent of all identifiable effects on health and welfare, including effects on plankton, fish, shell-
fish, wildlife, and plant life, which may be expected from the presence of pollutants in any body of
water, based on the substances' whole-water concentration. The ambient water quality criteria for
DDT and dieldrin were published in October 1980. The human health values have been updated
since the original criteria publications in 1980 to reflect revised carcinogenic potency values from
EPA's Integrated Risk Information System (IRIS) database (see Final Rule, 40 CFR Part 131, 57 FR
60848, December 22, 1992).
The derivation of EPA's ambient water quality criteria is discussed at length in the ecological
assessment (EPA, 1994). Criteria for the protection of saltwater aquatic life are, for most
pollutants, based upon toxic effects data for water-column organisms. However, for DDT and its
metabolites, which bioaccumulate to high levels and may cause toxicity to organisms at higher
trophic levels, it was determined that more restrictive criteria were necessary to protect fish-eating
birds. The chronic marine aquatic life criterion is 1 ng/L (10'° g/l, EPA 1980, EPA 440/5-80-0381).
The water quality criterion for the protection of human health from the consumption from the
bioaccumulation of DDT in fish is 0.59 ng/l, based on achieving a 1 X 10"6 lifetime excess cancer
risk level.
The chronic marine aquatic life criterion for dieldrin of 1.9 ng/l is also residue-based, and
was set at the level which would result in the achievement of the Food and Drug Administration's
(FDA) action level in fish oil after bioaccumulation (EPA 1980, EPA 440/5-80-019]). This criterion
is protective of sensitive aquatic organisms. The water quality criterion for the protection of human
health from the consumption from the bioaccumulation of dieldrin in fish is 0.14 ng/l, based on
achieving a 1 X 10* lifetime excess cancer risk level. The EPA aquatic life and human health water
quality criteria for DDT and dieldrin are listed in Table 1.
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TABLE 1. EPA Ambient Water Quality Criteria
Chemicals
DDTW
Dieldrin
Saltwater Aquatic Life
(ng/L)
24-hour average
1.0
1.9
Human Health
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EPA's Ambient Water Quality Criteria were specifically developed to protect beneficial uses such as
these.
Porter-Cologne Water Quality Act. San Francisco Bav Regional Basin Plan, and Fish and
Game Code. The release of hazardous substances to surface waters is controlled under the
Porter-Cologne Water Quality Control Act and implementing regulations, and the state Fish and
Game Code §5650.
Beneficial uses of surface waters were designated in the Water Quality Control Plan for the
San Francisco Basin (the Basin Plan) adopted by the Regional Water Quality Control Board
(SFBRWQCB, 1986). The Basin Plan designates the following beneficial uses of Central San
Francisco Bay, which includes the waters at the Site:
Industrial Service Supply
Industrial Process Supply
Navigation
Water Contact Recreation
Non-contact Water Recreation
Commercial and Sport Fishing
Wildlife Habitat
Preservation of Rare and Endangered Species
Fish Migration
Fish Spawning
Shellfish Harvesting
Estuarine Habitat
The Basin Plan also contains the following narrative objective:
"All waters shall be maintained free of toxic substances in concentrations that are lethal to
or that produce detrimental responses in aquatic organisms. Detrimental responses include,
but are not limited to, decreased growth rate and decreased reproductive success of
resident or indicator species and/or significant alterations in population or community
ecology or receiving water biota. Other relevant biological measures will be considered by
the Regional Board in evaluating compliance with this objective. Additionally, effects on
human health due to bioconcentration will be considered."
Resolution 68-16: Statement of Policy with Respect to Maintaining High Quality of Waters in
California. The State Water Resources Control Board adopted Resolution 68-16 on October 28,
1968. The Basin Plan, discussed above, states: "Whenever the existing quality of water is better
than the quality of water established herein as objectives, such existing water quality shall be
maintained unless otherwise provided by State Water Resources Control Boars Resolution 68-16."
The SFBRWQCB has identified Resolution 68-16 as a potential ARAR for the United Heckathorn
Site. While EPA does not agree that Resolution 68-16 is an ARAR, EPA and the State agree that
achieving the water quality criteria identified above would meet the requirements of 68-16
regardless of whether or not it is an ARAR.
Soils and Sediments
No chemical-specific ARARs were identified as remedial goals for soils or sediments at the
Site. Based on the results of the ecological assessment, mean sediment levels were calculated to
prevent violations of the ARARs for surface waters, and to meet the National Academy of Sciences
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(NAS) action level for DDT in fish to ensure protection of fish-eating birds, including endangered
species (see discussion below).
California Code of Regulations. Title 22. The state of California has developed
chemical-specific regulatory criteria for the identification of hazardous and extremely hazardous
wastes, based on Total Threshold Limit Concentration OTLC) and Soluble Threshold Limit
Concentration (STLC) values (California Code of Regulations, Title 22, Sections 66699 and 66723).
Any waste containing a substance at a concentration equal to or exceeding a listed TTLC is
classified as a hazardous waste by the California Department of Toxic Substances Control (DTSC).
Extremely hazardous wastes are also classified by DTSC using TTLCs. STLCs are related to the
Waste Extraction Test (WET), also described in Title 22. Any waste which produces an extract in
the WET test the concentration of which exceeds an STLC, is classified as a hazardous waste by
DTSC. The TTLCs and STLCs for the major COCs at the Site, DDT and dieldrin, are listed in Table
2.
TABLE 2. State of California Hazardous Waste Limits
Chemicals
DDT, ODD, DDE
Dieldrin
TTLC
(mg/kg wet wt)
1.0
8.0
STLC
(mg/kg wet wt)
0.1
0.8
All materials known to contain concentrations of substances exceeding the limits which
classify extremely hazardous wastes have been removed from the Site. Based on the results of
previous investigations and the marine Rl, approximately 95,000 tons of soils in the upland area of
the Site and approximately 65,000 yd3 of sediments in the Lauritzen Channel and Parr Canal exceed
the California TTLC for DDT. No sediments outside these channels exceed the levels listed in Table
2. Although the TTLCs and STLCs do not represent cleanup levels, soils and sediments with
chemical concentrations higher than the TTLCs or STLCs would be classified as hazardous under
California law if they were dredged or excavated at the Site.
EPA has developed chemical-specific criteria for the identification of hazardous waste under
the Resource Conservation and Recovery Act (RCRA). For the COCs at this Site, the criteria are not
concentration-based, but are instead based on the source of the constituents (40 CFR 261.33).
Product spills, for example, are RCRA-regulated, but generally releases of chemicals contained in
process waste streams are not (40 CFR 261.33(d)(comment)). Based on a review of historical
documents, the presence of COCs in marine sediments and remaining soils appears to be due to
releases contained in waste streams from United Heckathorn's processes. Therefore, EPA has
determined that the contaminated soils and marine sediments are not hazardous wastes regulated
under RCRA.
Groundwater. There are no chemical-specific ARARs for the concentration of COCs in Site
groundwater. Previous investigations found that salinity levels exceed federal (40 CFR 144.3) and
state (SWRCB Resolution No. 88-63) limits for underground sources of drinking water.
Consequently, the shallow groundwater at the Site is not considered a potential source of drinking
water as defined under state and federal law.
The water quality criteria for surface waters discussed above do not apply to groundwater,
although they might provide a basis for developing remediation goals in groundwater if there was a
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complete pathway by which contaminants in groundwater caused violations of the criteria in
surface water. However, as discussed in the previous chapter, an analysis of groundwater
transport to the bay was made in 1986 as part of the initial state-ordered Site investigation.
Although extremely high levels of pesticides were present in soils at that time, there were only
sporadic detections of low levels of pesticides in groundwater samples, and modeling indicated that
this potential pathway would not cause violations of state surface water quality objectives. Based
on this analysis, groundwater monitoring was not required in subsequent state-ordered Site
investigations. Subsequently, all highly contaminated soils containing approximately 99% of the
mass of pesticides were removed from Site soils, further reducing any potential threat.
Air. There are no chemical-specific ARARs, such as National Ambient Air Quality Standards
(NAAQS) or National Emission Standards for Hazardous Air Pollutants (NESHAPS), for the
concentrations of Site COCs in the air. Air monitoring was performed at the Site prior to the
removal of extremely high levels of exposed pesticides from Site soils. Even under those
conditions, the concentrations in onsite and off site air were well below levels of concern.
Fish and Shellfish. There are no chemical-specific ARARs for the concentration of COCs in fish and
shellfish. The NAS saltwater action levels are TBCs, which provide an additional level of protection
to fish-eating birds beyond the level that is the basis of the surface water ARARs for aquatic life.
The FDA action levels for the marketability of fish and shellfish are also TBCs for protecting human
health, but they are much less stringent than the levels that would be achieved by meeting the
surface water ARARs discussed above.
The NAS and National Academy of Engineering published recommendations in 1972 for
pollutant residues in compoSites of 25 or more whole fish of any species within the same size range
as those consumed by any bird or mammal in the marine environment (EPA-R3-73-033,
March 1973). The document cites studies demonstrating DDE induced shell thinning in mallards,
American kestrels, Japanese quail and ring doves, and an inverse relationship between shell
thickness and concentrations of DDE in eggs of wild populations of herring gulls, double-crested
cormorants, great blue herons, white pelicans, brown pelicans, and peregrine falcons. The
document concludes that a wet weight tissue range of 0.1 mg/kg to 0.5 mg/kg (100 //g/kg to 500
//g/kg) is "evidently higher than one which would permit successful reproduction of several fish-
eating and raptorial birds." The criterion for DDT is 50 pg/kg, which is one-third the level which
was the basis for the EPA water quality criteria discussed above.
Since the US Fish and Wildlife Service raised concerns that the EPA criteria for DDT might
not be stringent enough for the protection of fish-eating birds, and an endangered species (the
brown pelican) has been observed feeding at the Site, the NAS action level was retained as a TBC
to help determine the protectiveness of remediation (see 55 FR 8745).
Other Requirements
Endangered Species Act. The Endangered Species Act of 1973, 16 USC §1531 et sea..
requires the conservation of species of fish, wildlife and plants that are threatened with extinction.
Compliance with the act at Superfund Sites requires the identification of any threatened or
endangered species or of its critical habitat that would be affected by a proposed remedial action.
The U.S. Fish and Wildlife Service (FWS), which is the federal trustee for the protection of
migratory birds, provided a list of endangered species that are known to nest in central or northern
San Francisco Bay, or are likely to feed regularly in the immediate vicinity of Richmond Harbor
(Table 3). Among these, the California brown pelican has been observed by EPA personnel feeding
in all channels in Richmond Harbor, including the most contaminated waterways.
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The FWS raised the concern that the tissue residue basis (0.15 mg/kg DDT in prey) of the
surface water ARARs resulted in reproductive levels in pelicans that were still 10% to 30% below
the levels needed to maintain a stable population, described in the 1976 study used to set the
criteria. It should be emphasized, however, that the reproductive effects occurred when
contamination was widespread in the birds' range, and that the contamination in Richmond Harbor
is restricted to a small area. Nevertheless, the selected remedy is expected to also achieve the NAS
saltwater action level for DDT in fish (0.05 mg/kg), which was identified as a TBC for determining
the protectiveness of remediation.
TABLE 3. Endangered Species
Common Name
Brown Pelican
Bald Eagle
Peregrine Falcon
Clapper Rail
Least Tern
Nests In SF or San
Pablo Bays
Y
Y
Y
Feeds In/Around
Richmond Harbor
Y
Y
Y
Prey
Fishtol
Omni.0"
Bird'61
Invert.""
Fish
(a) Fish: consumes primarily fish.
(b) Bird: consumes primarily birds.
(c) Omni.: diet usually omnivorous/scavenger.
(d) Invert.: consumes primarily small- to medium-sized invertebrates.
California Endangered Species Act. The goal of the California Endangered Species Act
(California Fish and Game Code §2050) is to conserve, protect, restore and enhance any
endangered or threatened species and its habitat. Among the birds likely to nest or feed in the area,
most of those that are listed as endangered or threatened by the state are also listed federally. The
one exception is the California black rail, a state threatened species.
CDFG submitted the names of two potentially-affected plant species, both of which are
listed as rare and have distributions in the north Bay and delta. They are Mason's lilaeopsis, a
minute, turf-forming perennial plant in the carrot family, and soft bird's-beak, a sparingly-branched,
semi-parasitic herbaceous annual plant in the figwort family. The known distribution of Mason's
lilaeopsis, which is found on saturated clay soils regularly inundated by waves and tidal action,
appears to be limited to the bay delta. Soft bird's-beak occurs in the coastal salt marshes and
brackish marshes of northern San Francisco and Suisun Bays.
The surface water ARARs discussed previously are five orders of magnitude more stringent
than the levels necessary to protect aquatic plants. None of the potential remedies wpuld involve
destruction of rare plants or their habitat.
Coastal Zone Management Act (CZMA). Section 307(c)(1) of the CZMA requires that federal
agencies conducting or supporting activities directly affecting the coastal zone conduct or support
those activities in a manner that is consistent with approved state coastal zone management
programs. All remedial alternatives analyzed would affect the coastal zone. Under CERCLA Section
121 (e), 42 U.S.C. § 9621 (e), onsite activities are not subject to administrative review or permitting
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processes, but they must be consistent with the substantive requirements of the coastal zone
management plan. The approved coastal zone management program for San Francisco Bay includes
the McAteer-Petris Act and the San Francisco Bay Plan, and is administered by Bay Conservation
and Development Commission (BCDC).
The McAteer-Petris Act and the Bay Plan were developed primarily to halt uncontrolled
development and filling of the bay. Their broad goals include reducing bay fill and disposal of
dredged materials in the bay, and maintaining water quality and the ecological integrity of the bay.
Generally, filling of the bay is allowable only when public benefits exceed public detriment from the
loss of water areas, the filling is for a water-oriented use, and there is no alternative upland location
available.
Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act. Section
404 of the Clean Water Act and Section 10 of the Rivers and Harbor Act, 42 U.S.C § 1344,
regulates dredging and filling in waters of the United States. Several of the remedial alternatives
analyzed include dredging contaminated sediments. Some of the potential disposal options include
filling in waters of the United States. The United States Army Corps of Engineers (USACE) usually
issues permits to conduct the above activities; however, since the actions analyzed would all occur
onsite, permits would not be required pursuant to Section 121(e) of CERCLA, although the
substantive requirements of the laws would still have to be met.
The determination of the acceptability of fill in waters of the United States is made under
the Clean Water Act Section 404(b)(1) guidelines, which were promulgated in 40 CFR Part 230.
The discharge of dredged or fill material is prohibited if there is a practicable alternative to the
proposed discharge that would have less impact on the ecosystem, so long as the alternative does
not have other significant adverse environmental consequences.
California Hazardous Waste Control Law. California's hazardous waste facility closure
requirements, 22 California Code of Regulations, Chapters 14 and 15, "Closure and Post Closure,"
are not ARARs with respect to the upland portions of the United Heckathorn Site because it is
neither a hazardous waste facility nor a landfill. Some of the remedial alternatives analyzed would
involve the consolidation and onsite containment of contaminated sediment. In the analysis of
alternatives, operational requirements found in Title 22 of the California Code of Regulations are
discussed, including limited long-term management, Site and cover maintenance, and institutional
controls, including land use restrictions.
7. Summary of Site Risks and Remediation Levels.
Risk assessments were conducted by EPA to evaluate the threat to human health and the
environment posed by contamination from the United Heckathorn Site. Results of these
assessments and the final remediation levels established to address Site risks are summarized
below.
Human Health Risk Assessment. The Baseline Human Health Risk Assessment for the Site
was performed by ICF Technology Inc. for EPA (ICF Technology, 1994). The results indicate that
among the various potential exposure pathways for Site contaminants, only the consumption of fish
poses risks that are above EPA's acceptable risk range.
COCs at the Site were selected for evaluation in the risk assessment using the Site soil and
sediment data collected by HLA (1986), Levine-Fricke (1990, 1991, 1993), and Weston (1993).
The COCs selected for onsite soils were DDT (and metabolites), dieldrin, aldrin, endrin, and lead. Of
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these, DDT and dieldrin are the most prevalent contaminants and are the primary contributors to
risk. COCs selected for sediments were DDT and dieldrin.
Six exposure pathways were identified as potential concerns at the Site, as follows:
/
• ingestion and dermal adsorption of chemicals in onsite surface soils by workers at the Site;
• inhalation of fugitive dust from surface soils by onsite workers;
• ingestion and dermal adsorption of chemicals in onsite surface and subsurface soils by
temporary construction workers at the Site;
• inhalation of fugitive dust from soils by temporary construction workers at the Site;
• incidental ingestion and dermal adsorption of chemicals in offsite soils by nearby residents,
and;
• ingestion of contaminants in fish and shellfish from the Lauritzen, Santa Fe, and Inner
Richmond Harbor Channels by fishermen and their families.
The onsite exposure pathways assume that the Site will continue to be used for commercial
or industrial uses in the future. This is in accordance with the Bay Conservation and Development
Commission's (BCDC) San Francisco Bay Plan which designates the area for port priority or water-
related industry use, and the City of Richmond's M-3 (heavy industry) zoning of the Site and
surrounding properties.
The six potential exposure pathways were evaluated according to EPA guidance, which uses
conservative estimates of chemical toxicity and exposure, and cumulative risk from the addition of
pathways. Chemical concentrations used in the risk assessment included both average and either
Reasonable Maximum Estimates (RME) of Site concentrations or maximum measured values. EPA
baseline human health risk assessments intentionally present conservative (i.e. health-protective)
estimates of Site risks. Actual risks are likely to be lower and may in fact be zero.
The assessments for onsite worker exposure and offsite residential exposure are more
conservative than usual because the soils databases in both cases were influenced toward higher
values. The onsite soils database was skewed by the high number of samples taken to delineate
the hot-spot excavation areas. Offsite soil screening samples were intentionally taken only in the
immediate downwind area, which would have had the highest concentration had contamination
occurred.
The cumulative risks calculated for the onsite soil exposure scenarios indicate that the
removal actions that have occurred to date have reduced upland Site concentrations of chlorinated
pesticides to acceptable levels. The highest RME cancer risk calculated for the various onsite
upland worker scenarios (ingestion, dermal adsorption and inhalation of fugitive dusts from surface
soils by a permanent worker) is 1 x10"4, and the maximum Hazard Index (HI) for noncarcinogenic
effects is 1. More probable estimates for the same exposure scenario are 2x10"6 and < 1. Risks for
other onsite worker scenarios are lower. Since the onsite soils database is skewed to produce
conservative results and EPA's acceptable risk range is 10"4 to 10"6, onsite risks associated with
chlorinated pesticides are acceptable.
Onsite risks for occupational exposure to lead were evaluated using EPA's 500 mg/kg to
1000 mg/kg acceptable range for residential exposure, and the state of California's draft procedure
for the assessment of adult exposure to lead in soil. Mean onsite lead levels are below 500 mg/kg,
and the RME lead concentration results in a 95th percentile adult blood lead level below the target
concentration of 10 micrograms per deciliter (jjgldL) using the state's draft procedures. Therefore,
onsite lead levels are acceptable.
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Offsite residential risks for COCs in nearby soils were evaluated using the maximum values
obtained in EPA's soil screening survey and conservative exposure assumptions, including childhood
exposure. All results were well within the acceptable risk range for carcinogenic effects and below
an HI of 1 for noncarcinogenic effects, (i.e., the maximum values measured were below a Hazard
Index of 1 for noncarcinogenic effects, and below a lifetime excess cancer risk level of 10*4 for
carcinogenic effects).
Risks to fishermen and their families who consume fish caught in the inner Richmond Harbor
were evaluated using information from two sources: fish tissue data generated as part of EPA's
ecological assessment of the Site, and community interviews with individuals who fish or are
familiar with fishing practices in Richmond Harbor. The community interviews confirmed that
fishing occurs regularly in Richmond Harbor, particularly at a Site in the Inner Harbor Channel near
the Parr Canal that has unrestricted access. Although it could not be determined from the limited
interviews performed whether fishing at subsistence rates occurs in the harbor, it is clear that the
fishermen are from poor, minority communities, and that the fish are caught for consumption.
Fishing in the Lauritzen Channel is restricted because it is surrounded by fenced industrial facilities,
and fishing from boats is discouraged by warning signs in English, Spanish, Vietnamese and
Laotian, posted under a 1986 order of the CDHS. Baseline risk assessments, however, assume that
institutional controls, such as fences and posting, will be ineffective or not maintained. In fact, a
person was photographed fishing from an industrial facility on the Lauritzen Channel during the EPA
field sampling for the ecological assessment.
The results of the risk calculations indicate that the risks from long-term consumption of
either whole fish or fillets of fish caught in the Lauritzen Channel are unacceptable. Using the
exposure scenario which is the basis of EPA's water quality criteria for fish consumption, the
lifetime excess cancer risk associated with Site COCs is above 10'3 for consumption of whole fish,
and above 10"4 for fillets. In the Santa Fe and Richmond Inner Harbor Channels, lifetime excess
cancer risks are within the acceptable range using the same exposure scenario. If consumption
were to occur at subsistence rates, the associated risks would be approximately 10 fold higher.
The proposed remedy is expected to achieve protective levels for contaminants of concern under
either exposure scenario.
On April 7, 1994, the California Department of Toxic Substances Control issued an advisory
against consuming any resident bottom fish, such as white croaker, from anywhere in the Inner
Richmond Harbor. The State's advisory was based on levels of contaminants found in fish
purchased from resident fishermen at the Parr Canal area. These fish were larger than those in
EPA's studies and had slightly higher contaminant levels. The primary risk associated with the
consumption of fish caught outside the Lauritzen Channel is due to contamination with
polychlorinated biphenyls (PCBs), although the State would have issued the advisory based upon
DDT and dieldrin contamination alone. The source of PCBs is unknown. PCBs are not related to
the United Heckathorn Site, and may be present in fish throughout the bay. PCB levels in Richmond
Harbor sediments are not elevated relative to typical levels in the bay.
Ecological Assessment. The Ecological Risk Assessment for the United Heckathorn Site was
performed by EPA (EPA, 1994). The operations of United Heckathorn from 1947 to 1966 resulted
in the release of DDT and other pesticides to and from the shoreline of the Lauritzen Channel and to
San Francisco Bay. Today, in the waters of Richmond Harbor near the former plant, high levels of
DDT and dieldrin remain in marine sediments. DDT and dieldrin bioaccumulate in marine organisms
to the highest levels found in the state of California.
The goals of EPA's ecological assessment were to assess the threats posed to the
environment by the contaminants released from United Heckathorn and to determine cleanup levels
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protective of the beneficial uses of San Francisco Bay.
The waters of Richmond Harbor are part of San Francisco Bay, the West Coast's largest
estuary. The estuary sustains a complex ecosystem containing thousands of species of fish,
invertebrates, birds, mammals, insects, amphibians, plants and other life, as well as nearly half the
waterfowl and shorebirds migrating along the Pacific flyway. Fish-eating birds, including
cormorants, grebes, loons, kingfishers, and California brown pelicans (an endangered species) feed
in the most contaminated channels at the Site.
The initial components of EPA's ecological assessment included a review of previous studies
in the area. Highlights of this review included the findings that sediment concentrations of DDT are
elevated to acutely toxic levels in the Lauritzen Channel and decline by over four orders of
magnitude to near background levels in the vicinity of Point Potrero. DDT and dieldrin
concentrations are extremely elevated in transplanted mussels and resident invertebrates in the
Lauritzen Channel and decline by two orders of magnitude in the Inner Richmond Harbor Channel.
Fish caught in the Lauritzen Channel in 1986 contained extremely high levels of DDT, which were
comparable to the levels measured in 1960. Finally, a study of migratory waterfowl in San
Francisco Bay found that only those which wintered in Richmond Harbor significantly accumulated
metabolites of DDT. Although other chemicals are present in Richmond Harbor, they are not
consistently found at levels notably above background or above levels that are likely to cause
toxicity, in marked contrast to DDT and dieldrin, which are many orders of magnitude above
background and were selected as the COCs for the study.
The next preliminary phase of the study was a review of the available standards, criteria,
and scientific literature regarding ecological impacts of the COCs to determine as far as possible the
contaminant levels in various media that could adversely impact sensitive organisms. This review
indicated the ecological receptors likely to be the most sensitive and helped guide the selection of
field and laboratory studies. EPA's ambient water quality criteria for DDT and dieldrin were
identified as applicable to the Site. The marine chronic criteria for DDT (1 nanogram per liter, ng/L)
is based upon preventing bioaccumulation in fish to levels harmful to sensitive marine birds.
The major phase of the study involved field and laboratory measurements of contaminant
concentrations in various media and the performance of standard benthic tests for determining
impacts from contaminated sediments. Most of the field samples were taken in October 1991.
Additional fish and shellfish samples were taken in April 1992. The studies included bulk sediment
toxicity testing, benthic community analyses, bioaccumulation testing, and chemical analyses in
sediments, surface waters, and tissues of benthic organisms and fish and shellfish collected in
trawls. An additional goal of these studies was the determination of the relationship between
sediment contaminant concentrations and the concentrations in other media so that a sediment
cleanup concentration could be determined which would result in the attainment of water quality
criteria and protective contaminant levels in fish and shellfish tissues.
The results of the studies are summarized below. The total DDT levels measured in surface
water from the Lauritzen, Santa Fe and lower Richmond Inner Harbor Channels were 50 ng/L,
9 ng/L, and 1 ng/L, respectively. The dieldrin concentrations were 18 ng/L, 2 ng/L, and
nondetectable, respectively. These results indicate that the water quality criteria are violated in the
Lauritzen and Santa Fe Channels, but are achieved (within the uncertainly of the analysis) or not
detectable in the lower Inner Harbor Channel. Analysis of water-to-sediment ratios indicates that
the Lauritzen is a source of contamination to the other channels.
Sediment concentrations of total DDT declined from over 50 mg/kg in the Lauritzen Channel
to 12 fjQ/kg near Point Potrero. Dieldrin concentrations declined from 570 //g/kg in the Lauritzen to
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nondetectable levels in the Inner Harbor Channel. These results are consistent with those of
previous researchers, and with the more extensive Rl of marine sediments (White et. al 1994).
In 28-day bioaccumulation tests using Macoma nasuta, tissue levels of DDT over 50 mg/kg
(dry wt) and 1.5 mg/kg dieldrin were obtained using Lauritzen Channel sediments. Tissue levels
declined to 80 //g/kg DDT and undetectable levels of dieldrin using sediments from the vicinity of
Point Potrero. These results are consistent with those of previous researchers. Further studies
revealed that the tissue concentrations obtained at 28 days were approximately half those obtained
after a 90-day exposure. Tissue residues of DDT and dieldrin measured in field-collected benthic
infauna were as high as 46 mg/kg and 2.5 mg/kg (dry wt), respectively, in the Lauritzen Channel.
Concentrations dropped by about two orders of magnitude in the Inner Harbor Channel.
Tissue residues of DDT and dieldrin measured in mussels (Mytilus spj were 2.6 mg/kg and
97 //g/kg (wet wt) in the Lauritzen Channel, and declined to 40 //g/kg and 5 //g/kg in the lower
Richmond Inner Harbor Channel. These results are consistent with those of the State Mussel Watch
program. Tissue levels in the lower Inner Harbor Channel are higher than would be predicted from
the underlying sediment concentration, again indicating that there is water-column transport of
pesticides from the Lauritzen to less contaminated areas.
Tissue residues of DDT measured in whole fish (shiner perch) were over 10 mg/kg in the
Lauritzen Channel, roughly 1 mg/kg in the Santa Fe Channel, and roughly 0.1 mg/kg in the
Richmond Inner Harbor Channel. Dieldrin levels were roughly 0.6 mg/kg, 0.04 mg/kg, and
0.002 mg/kg in the respective channels. The contaminant concentrations in fish from the Lauritzen
Channel are in the same range as those measured in the 1960s, and exceed the levels that may
cause adverse impacts to sensitive predatory birds by orders of magnitude. A sensitive bird, which
had no other source of DDT in its diet and which consumed more than 0.5% to 1.5% of its diet
from the Lauritzen Channel, could be adversely affected. These concentrations may also cause
direct toxic impacts such as reduced fry survival in fish. The results for the Santa Fe Channel are
an order of magnitude lower, but still exceed levels that may cause adverse impacts to sensitive
fish-eating birds. A sensitive bird that consumed more than 5% to 15% of its diet from the Santa
Fe Channel might be adversely affected.
Sediment toxicity tests using the amphipod, Eohaustorius estuarius, indicated significant
acute toxicity in sediments from the Lauritzen Channel. Sediments from the Santa Fe Channel
displayed lower but significant toxicity relative to the amphipod's native Yaquina Bay, Oregon,
sediment, but were not significantly different from those in the Inner Harbor Channel or other San
Francisco Bay locations. DDT was determined to be the primary cause of toxicity in the Lauritzen
Channel.
Additional toxicity tests conducted during the Rl using the amphipod Rhepoxynius abronius
confirmed the acute toxicity of Lauritzen Channel sediments. In four of five Lauritzen Channel
composite samples, there was no survival of test organisms, an extremely rare occurrence
indicating severe toxicity. Amphipod survival in samples beginning at the southern end of the
Lauritzen Channel and proceeding out the harbor was not significantly different than survival in the
San Francisco Bay fine-grained sediment control, indicating that the toxicity is confined to the
Lauritzen.
An analysis of benthic infauna indicated that amphipod abundance (with the exception of
the pollutant-tolerant Grandidierella japonica] was inversely related to DDT concentration. The
minimum benthic ecological effects concentration was determined to be 100 //g DDT/g organic
carbon (equivalent to 1.9 mg/kg, dry wt, at 1.9% organic carbon).
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Overall, the results indicate that the gross contaminant levels in the lauritzen Channel
threaten a variety of ecological receptors at various trophic levels, including benthic and water-
column organisms and fish-eating birds. Effects are likely to be much less severe in the Santa Fe
Channel, although the contaminant levels in fish are significantly higher than the levels that may
threaten sensitive fish-eating birds. In the Richmond Inner Harbor Channel, the DDT levels in fish
(100 //g/kg) are between the level that is the basis of EPA's chronic marine water quality criteria
intended to protect marine birds (150 //g/kg), and the National Academy of Sciences (NAS)
recommendation (50 //g/kg) for protecting marine birds. It is clear from the results above that the
most sensitive ecological receptors to sediment organochlorines in Richmond Harbor are likely to be
fish-eating marine birds.
The only contaminated medium for which applicable regulatory criteria were identified is
surface water. Nonregulatory or surrogate criteria were also identified for fish and shellfish tissues
and sediments. Fortunately, surface water concentrations were found to be quite consistent during
different tidal cycles and seasons in each of the three channels sampled. In addition, the
concentrations measured in the water column and the concentrations measured in whole fish were
found to agree remarkably with the concentrations predicted by the applicable EPA marine chronic
water quality criteria. This demonstrates that total DDT present in surface waters is bioavailable,
and that it accumulates as predicted by the applicable marine chronic criteria.
The analysis of surface water pesticide concentrations in the three channels indicates that
the concentrations in the Santa Fe and Richmond Inner Harbor Channels are likely elevated by
approximately one order of magnitude over the concentrations that would result from the respective
local sediment concentrations, due to the flux of contaminated water from the Lauritzen Channel.
This indicates that remediation of the Lauritzen would have beneficial effects throughout the Inner
Harbor.
Site Remediation Goals. The final goal of the ecological assessment was to provide
sufficient information to develop Site remediation goals for contaminated marine sediments
containing the COCs, DDT and dieldrin, which would be protective of the environment and human
health. The DDT and dieldrin water quality criteria are near or below the levels which can be
quantified by the best laboratories. Protective levels in sediments are much more readily
measureable, particularly for DDT. Although DDT and dieldrin co-occur, the DDT concentration is
generally 10 to 100 times higher, and DDT was detected in sediment samples over a wider area.
Sediment remediation goals, which are expected to attain protective levels for both contaminants,
have therefore been established based on DDT concentration.
As indicated above, it was determined that the minimum ecological effects concentration for
benthic organisms was 100 //g DDT/g of organic carbon, which is equivalent to 1,900 //g/kg (dry
wt) at 1.9% organic carbon. Sediment concentrations exceeding this value might cause local
chronic adverse impacts to benthic organisms. EPA has reviewed data for other DDT-contaminated
Sites, and found a similar threshold for benthic effects. Sediments in the Lauritzen Channel and
Parr Canal exceed this level. The maximum concentrations outside these channels are below this
level.
The EPA marine chronic water quality criteria of 1 ng/L DDT is likely to be achieved if the
average channel sediment concentration is below 1,000 //g/kg DDT (dry wt); and the human health
criteria of 0.6 ng/L is likely to be achieved if the average sediment concentration is below 590 //g/kg
DDT.
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TABLE 4. Remediation Levels
Final Remediation Levels
Medium
Surface
Water
Sediment
Chemical
DDT
Dieldrin
DDT
Level
0.59 ng/l
0.14 ng/l
Avg: 590 ^g/kg
Basis
EPA AWQC
Ecological
Assessment
Cancer Risk Level
1 X 10*
1 X10-6
1 X 10*
The average sediment concentrations in the Lauritzen Channel and Parr Canal exceed the
590 i/g/kg DDT level, while the average concentrations in the Santa Fe and Inner Harbor Channels
are below the level. Therefore the remediation of sediments will be limited to the Lauritzen Channel
and Parr Canal. Although the concentrations of pesticides in upland soils are acceptable for human
exposure, they exceed the protective levels for sediments in the adjacent channels, indicating that
erosion of upland soils and stormwater runoff to the marine environment should be prevented.
The NAS action level for the concentration of DDT in fish to protect fish-eating birds is not
an ARAR but was identified as a TBC to assist in determining the protectiveness of remediation.
The NAS action level is likely to be achieved if the average channel DDT sediment concentration is
below 420 fjg/kg. Since the average concentrations of DDT in the Santa Fe and Inner Harbor
Channels are below this level, cleanup of sediments in the Lauritzen Channel and Parr Canal is
expected to result in achievement of the NAS action level.
8. Description of Alternatives.
The environmental media requiring remediation are soft marine sediments (young bay muds)
in the Lauritzen Channel and Parr Canal. Contamination is confined to softer younger bay mud, and
has not migrated into the underlying older bay mud. The volume of contaminated sediment in the
Lauritzen Channel and Parr Canal is approximately 65,000 yd3. Remediation of this sediment is
expected to result in achievement of the remedial action goals. In addition, erosion of upland soils'
containing DDT at concentrations exceeding the final remediation level for sediments must be
prevented. No action will be taken in other areas in Richmond Harbor, such as the Santa Fe
Channel and Inner Harbor Channel, because sediment levels are below the remediation levels
established above.
The action alternatives presented below all include dredging of contaminated sediments and
paving of upland soils on the northern half of the Levin Richmond Terminal. The principal difference
among these alternatives is in the location chosen for disposal of dredged sediments. In addition,
the "no action" alternative has been retained as a baseline for comparison with the other
alternatives, as required by the National Contingency Plan, 40 C.F.R. § 300.430(e)(6>. The four
alternatives are summarized below:
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Alternative 1: no action
Alternative 2: confined disposal of marine sediment in the Port of Richmond's Point Potrero
graving docks, and capping of upland areas
Alternative 3: confined disposal of marine sediment in the Lauritzen Channel, and capping
of upland areas
Alternative 4: offsite disposal of marine sediment by rail, and capping of upland areas.
With the exception of "no action," all of the alternatives have been developed to meet the
remedial action goals. In addition to the components listed above, each action alternative includes
environmental monitoring to evaluate the effectiveness of the remedy, and institutional measures to
limit future Site uses to those considered in the human health risk assessment.
Common Elements
Elements which are common to two or more alternatives, including dredging, monitoring,
paving of upland areas, and institutional controls, are discussed below.
Dredging. Alternatives 2 through 4 would involve dredging of the younger bay mud from
the Lauritzen Channel and Parr Canal. The total volume of these sediments is estimated to be
65,000 yd3, although if Alternative 2 were selected, some of the most contaminated sediments
would remain in place in the Lauritzen Channel within a Confined Disposal Facility (CDF). In areas
to be dredged, all soft sediments down to the hard older bay mud contact would be removed.
Silt curtains would be erected across the mouths of the channels prior to dredging to
prevent transport of sediment disturbed by the dredging process out of the excavation area. In
addition, control measures would be implemented to prevent or minimize the runoff or return of
sediment back to the excavation areas. The surface water ARARs for the concentrations of COCs
are not currently achieved, and would not be expected to be achieved in the Lauritzen Channel and
Parr Canal during the dredging phase of remediation at the Site. The surface water ARARs are
remedial action goals which are expected to be achieved after the dredging is completed.
Two sunken barges, one small tank, and other debris (see Figure 3) would have to be
removed from the Lauritzen Channel prior to dredging under Alternatives 2 through 4. In one of the
configurations of Alternative 3, a CDF would be constructed in the northern end of the channel,
allowing one barge and the small tank to remain in place. Samples of sediment taken by EPA divers
from inside the barge and tank indicated that they are not sources of contamination.
Monitoring. In order to determine the effectiveness of the remedial action, a post-remedial
monitoring program would be required. Monitoring would be expected to occur annually for at least
five years or until it was demonstrated that the remediation goals had been achieved, and could
continue at longer intervals (e.g., once every five years) for an additional period of time. The
monitoring program would also be implemented as part of the "no action" alternative.'
The post-remedial monitoring program would include surface water and biological monitoring
components. Periodic collection and analysis of surface water samples would determine compliance
with EPA ambient water quality criteria, which are ARARs. Bioaccumulation could be monitored
through the periodic deployment and subsequent collection and analysis of mussels, as is done in
the State Mussel Watch program. Mussels provide the most consistent, readily obtainable
biological data. These data can be compared to the historic State Mussel Watch bioaccumulation
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database for Richmond Harbor to confirm reductions in tissue residues. Sampling locations to
confirm the effectiveness of the remedy would be in the Lauritzen, Santa Fe and Richmond Inner
Harbor Channels. Additional sampling might be required based on the remedy selected. For
example, if confined disposal at the Port of Richmond's graving docks were selected, an additional
monitoring station would be established outside the facility.
Capping of Upland Area. The results of the human health risk assessment indicate that the
removal actions performed at the Site between 1990 and 1993 reduced contaminant concentrations
in upland soils to levels that are acceptable for current and expected future commercial or industrial
uses. Nevertheless, roughly 95,000 tons of soils over a large area of the Site exceed the much
lower remedial action goal for marine sediments. Therefore, a remediation goal of erosion
prevention was established for upland soils. The northern half of the Levin Richmond Terminal,
which is where the United Heckathorn facility was located and where concentrations exceed 1
mg/kg DDT, is currently unpaved. Each of the action alternatives includes paving this area with
asphalt. The area of the upland asphalt cap is shown in Figure 6. The cost of capping this area
was estimated in the FS performed by Levine-Fricke (1991). The estimate of $400,000 includes a
20% contingency. This cost is included in the estimates generated for each remedial alternative
except "no action."
Institutional Controls. The human health risk assessment concluded that the concentrations
of COCs in upland soils at the Levin Richmond Terminal had been reduced to acceptable levels for
current and expected future industrial uses. This is consistent with the San Francisco Bay Plan
under which the area is zoned for port priority or water-related industrial use. In order to provide an
additional measure of assurance that the Site could not be converted to other use, such as
residential, without further study and possibly further remediation, a deed restriction on the property
will be included as part of Alternatives 2 through 4.
The Lauritzen Channel is currently posted with signs warning fishermen that fish and
shellfish may be contaminated with DDT and other pesticides. These signs will remain in place until
post-remedial monitoring confirms that concentrations of the COCs have been reduced to
acceptable levels.
Alternative 1: No Action with Monitoring. The NCP requires the analysis of no action as an
alternative (40 CFR 300.43Q(e)(6)). Under no action, no further remediation would be conducted at
the Site, although the monitoring program would still be performed to evaluate the effects of the
remaining contamination. The existing institutional controls would remain in place.
The no action alternative does not meet either of the two threshold criteria described below
(overall protection of human health and the environment, and compliance with ARARs). Because
the threshold criteria are not met, this alternative is not eligible for selection.
Alternative 2: Dredging with Containment at the Point Potrero Graving Docks. The major
components of this alternative are dredging approximately 65,000 yd3 of contaminated sediment
from the Lauritzen Channel and Parr Canal, and disposing of the sediment in a CDF constructed at
the Port of Richmond's graving docks.
The graving docks are located at Point Potrero, at the southern end of the Richmond Inner
Harbor Channel, approximately one mile from the location of the former United Heckathorn facility
(see Figure 2). A sediment containment facility constructed at the graving docks could be
determined to be "onsite" under the definition of the NCP, which includes all locations within the
areal extent of contamination and all suitable areas in very close proximity necessary for
implementation of the response action (40 CFR 300.5).
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Graving docks are concrete box structures used to drydock ships. The Point Potrero graving
docks were built during World War II and, due to their relatively small size, are obsolete for modern
vessels. The Port of Richmond suggested that the graving docks be analyzed as a potential disposal
Site for contaminated sediments because they have the capacity to effectively contain very large
volumes. Depending on the configuration and number of basins used, the facility could contain
between 89,000 yd3 and 500,000 yd3 of sediment. The facility would not be simply a disposal
Site, but would be constructed so that it would be suitable for use as a marine shipping terminal.
Use of the graving docks would not be offered by the Port of Richmond for disposal alone. The
Port has analyzed a number of alternative configurations which would accommodate varying
volumes of dredged material and provide the Port an additional berth or pier of at least 600 ft. The
Port's cost estimates for each of the various configurations include the costs of preparing the basins
to receive dredged material, and the costs of enhancing the facility for Port use.
The configuration chosen for analysis would entail filling Basin 1 with approximately 65,000
yd3 of sediment dredged from the Lauritzen Channel and Parr Canal, and 24,000 yd3 of additional
material to produce a total of 89,000 yd3. This is the lowest cost configuration which would
provide sufficient volume to contain sediments dredged from the Lauritzen Channel and Parr Canal.
Prior to receiving sediment. Basin 1 would be inspected and repaired if necessary, and then sealed
with a concrete bulkhead. Wick drains would be installed for dewatering. The pier between Basins
2 and 3 would be removed, and Basin 3 would be lengthened from 500 ft to 750 ft, creating a new
berth for large ships.
Dredged sediment would be barged to the drydock and deposited by mechanical means in
order to minimize entrainment of water. It is estimated that consolidation of the sediment within
the basin would take a minimum of four years. If hydraulic dredging were used, consolidation
would probably take longer. The average concentration of DDT in the sediment would be 30 mg/kg
wet wt. Based on the results of the treatability testing performed during the marine Rl, it is
expected that treatment by filtration and carbon adsorption would be required before effluent
produced by dewatering could be discharged from the basin to the bay. Although a Waste
Discharge Permit would not be required under CERCLA, substantive requirements would have to be
achieved, including toxicity limits and compliance with numeric water quality criteria. A possible
alternative would be to discharge effluent to a sanitary sewer under permit from the local agency.
Discharges to the sewer system would be "offsite" and require permitting.
In addition to the actions described above, this alternative would include the post-remedial
monitoring program, removal of the sunken barges and other debris from the Lauritzen Channel,
asphalt paving of the northern half of the Levin Richmond Terminal, and institutional controls. The
estimated cost of this alternative included roughly $700,000 to prepare Basin 1 and close it after
filling, and roughly $1.8 million to remove the pier between Basins 2 and 3, and lengthen Basin 3 to
produce a 750-ft berth. Annual overhead and maintenance costs include evaluation and repair of
the graving docks, operation and maintenance of an effluent treatment system for dewatering
sediment, and post-remediation monitoring. The total estimated cost for this alternative is $5.6
million. This estimate does not include the costs, which could be substantial, of obtaining an
agreement among various parties regarding the use of the facility and future liability. In addition,
state and federal agencies have indicated that they might seek mitigation to compensate for the fill
associated with this alternative. The costs of mitigation would also significantly increase the total
cost of this alternative.
This alternative would be expected to meet the remedial action goals defined in Table 4 and
provide effective long-term protection of human health and the environment. It is unclear, however,
whether it would comply with ARARs related to bay fill unless an upland alternative were
unavailable. Dredging would cause short-term impacts within the excavation areas. Because the
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-23-
dredged sediment would be classified as hazardous waste pursuant to State of California
regulations, this alternative would require agreements between a number of government and private
parties regarding long-term liability and operations and maintenance, limiting its implementability.
Alternative 3: Dredging with Containment at Lauritzen Canal. The major, components of this
alternative would be dredging between 44,000 yd3 and 52,000 yd3 of contaminated sediment from
the Lauritzen Channel and Parr Canal, and depositing it in a CDF constructed within the Lauritzen
Channel. Two variations of CDFs were analyzed for this alternative based on alternatives developed
by Levine-Fricke (1991). The first consists of a steel sheetpile wall approximately 1300 ft long
constructed along the eastern shoreline of the channel. The sheetpile wall would be tied to anchors
placed in the soil at the Levin Richmond Terminal. This configuration does not interfere with either
the storm drain at the northern end of the channel, or with properties across the channel from
Levin.
The second variation of a CDF in the Lauritzen would consist of a rock dam across the
northern end of the Lauritzen Channel. Advantages of this configuration are that it would minimize
the dredging of the most contaminated sediments in the channel; the barge, tank, and debris in the
northern end of the channel could remain in place; it would require less maintenance than a steel
sheetpile wall; and it would be less costly to construct.
Dredged sediment could be deposited in the CDF by mechanical means, or by hydraulic
dredging. Consolidation of the sediment within the basin would take several years. The average
concentration of DDT in the sediment would be 30 mg/kg wet wt. Based on the results of the
treatability testing performed during the marine Rl, it is expected that treatment by filtration and
carbon adsorption would be required before effluent produced by dewatering could be discharged
from the basin to the bay. Although under CERCLA a Waste Discharge Permit need not be
obtained, substantive requirements would have to be achieved, including toxicity limits and
compliance with numeric water quality criteria. A possible alternative would be to discharge
effluent to a sanitary sewer under permit from the local agency. Discharges to the sewer system in
this case would be "offsite" and require permitting.
In addition to the actions described above, this alternative would include the post-remedial
monitoring program, asphalt paving of the northern half of the Levin Richmond Terminal, removal of
at least one sunken barge from the Lauritzen Channel, and institutional controls. Annual overhead
and maintenance costs include evaluation and repair of the CDF, operation and maintenance of an
effluent treatment system for dewatering sediment; and post-remediation monitoring. The cost of
dredging the sediment for this alternative would be slightly lower than the costs described for the
previous alternative since some of the sediment would remain in place and transportation would not
be required. The estimated cost range is $13 million for the sheet-pile wall variation and $4.3
million for the rock dam. In addition, state and federal agencies and the Port of Richmond have
indicated that they might seek mitigation to compensate for the fill associated with this alternative.
The cost of mitigation would also significantly increase the total cost of this alternative.
This alternative would be expected to meet the remedial action goals defined in Table 4 and
provide effective long-term protection of human health and the environment. It is unclear, however,
whether it would comply with ARARs related to bay fill unless an upland alternative were
unavailable. This alternative would require the least amount of dredging, which would minimize
short-term impacts within the excavation areas. The rock dam variation of this alternative would
have an impact on adjacent property owners, which could hinder implementability. In addition,
because the dredged sediment would be classified as hazardous waste pursuant to State of
California regulations, this alternative would require agreements between a number of government
and private parties regarding long term liability and operations and maintenance, limiting the
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-24-
implementability of this alternative.
Alternative 4: Dredging with Offsite Disposal. The major components of this alternative are
dredging approximately 65,000 yd3 of contaminated sediment from the Lauritzen Channel and Pan-
Canal, and transportation of the sediment by rail to a permitted offsite disposal facility. Transport
by rail offers several significant advantages. The Levin Richmond Terminal is a rail facility with lines
running the length of the shoreline of the Lauritzen Channel. Since dredging can produce very large
volumes of sediment very quickly, the limiting factor in removing sediment from the Site would be
the time required to load it for transport. Watertight rail cars would be used to prevent releases
during transportation. A rail car can carry 100 tons, and a single train can transport approximately
8000 tons. It is estimated that the entire project could be accomplished in about two months.
In addition to the actions described above, this alternative would include the post-remedial
monitoring program, asphalt paving of the northern half of the Levin Richmond Terminal, removal of
barges and debris from the Lauritzen Channel, and institutional controls. The estimated cost for this
alternative is $7.3 million. Since the sediments would be transported offsite to a permitted disposal
facility, long-term operations and maintenance costs are only those associated with the monitoring
program and maintenance of the asphalt paving at the Site. The estimated disposal cost for this
alternative includes transportation by rail and was provided by the East Carbon Development
Corporation, a facility in eastern Utah which is permitted to receive non-RCRA wastes.
This alternative would be expected to meet the remedial action goals defined in Table 4,
provide effective long-term protection of human health and the environment, and comply with all
ARARs. Dredging would cause short-term impacts within the excavation areas. Disposal of
sediments at an offsite facility would require no bay fill, and would minimize long-term maintenance
costs and liabilities. Offsite disposal by rail appears to be implementable at a reasonable cost.
9. Summary of Comparative Analysis of Alternatives.
The alternatives were analyzed using the nine criteria of the NCP (see 40 CFR
300.430(f)(5)(i)). The comparative analysis with respect to each criteria is summarized below.
Overall, it was determined that Alternative 4, Dredging with Off-Site Disposal provides the best
balance among the alternatives with respect to the evaluation criteria.
Overall Protection of Human Health and the Environment: All of the alternatives except "no action"
are expected to provide adequate protection of human health and the environment. The risks
associated with the COCs are due to their current location in or near the aquatic environment.
Alternatives 2 and 3 would achieve protection by isolating the contaminants from the aquatic
environment in onsite confined disposal facilities which would require perpetual maintenance to
ensure that contaminants were not re-released to the marine environment. Alternative 4 would
achieve protection by transporting contaminants offsite.
Compliance with ARARs: The "no action" alternative would not result in compliance with ARARs.
Alternative 2, confinement in the Port of Richmond's graving docks, relies on the dual purpose of
the remedy to create a port facility in order to achieve consistency with the CZMA and compliance
with the Clean Water Act. Alternative 3, confinement in the Lauritzen Channel, would probably not
be consistent with the CZMA or the Clean Water Act unless it was determined that there was no
practicable alternative. Alternative 4, offsite disposal, complies with all ARARs, and appears to be
practicable.
Long-term Effectiveness and Permanence: Alternatives 2 through 4 are all expected to provide
adequate long-term effectiveness and permanence. Concrete vaults and shoreline CDFs have been
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-25-
used successfully at other Sites to contain contaminated sediments, although they require perpetual
maintenance. Alternative 4, offsite disposal, provides the highest degree of permanence because
the contaminated sediments would be stored far from the aquatic environment. Although the
contaminated sediment presents an unacceptable threat to human health and the environment
because of its current location which allows exposure to marine organisms and biomagnification in
the food chain, the expected average concentration after dredging of approximately 30 mg/kg is
well within the acceptable range for direct human exposure, and would not present a direct threat
when contained in a disposal facility.
Reduction of Toxicitv. Mobility, or Volume through Treatment: None of the alternatives employs
treatment. Alternatives 2 through 4 meet the expectation of the NCP for containment of high
volumes of waste which have relatively low contaminant concentrations. Based on the process
screening conducted in the FS, treatment of the COCs in Site sediments would not be practicable.
Site upland soils which contained extremely high levels of contaminants were addressed in previous
removal actions.
Short-term Effectiveness: None of the alternatives would be expected to cause short-term risks to
the community. The risks to workers are expected to be primarily those associated with
construction, transportation, dredging, and solids handling. All of the dredging alternatives would
cause short-term impacts within the excavation areas, and would remove the existing benthic
communities from the bottoms of the Lauritzen Channel and Parr Canal. However, it is expected
that the channel bottoms would be recolonized by more diverse populations. Alternative 4, offsite
disposal, would achieve protection in the shortest amount of time.
Implementabilitv: Alternative 4 is the most readily implementable. It would require the least amount
of onsite construction and preparation, and should have no administrative impediments. Alternative
2, consolidation at the Port of Richmond's graving docks, would require a complex agreement
between the City of Richmond and other parties regarding ownership, operations, and liability.
Alternative 3, consolidation in a CDF in the Lauritzen Channel, would likely encounter state
opposition, and could require agreements among adjacent property owners regarding loss of
shoreline and access, as well as agreements with PRPs and several government agencies, including
the City of Richmond, DTSC and EPA.
Cost: The estimated costs for all of the alternatives are comparable. The cost for Alternative 4,
offsite disposal, while not the lowest, is the most certain. The estimated costs for Alternative 2, •
confinement at the Port of Richmond's graving docks, and Alternative 3, confinement at the
Lauritzen Channel, would be more likely to change given the need for agreements among parties
regarding ownership, maintenance and liability for facilities containing wastes exceeding state
hazardous levels. The costs for construction, dewatering, effluent disposal, and hazardous waste
storage are also less certain than the offsite transportation and disposal costs. In addition, the cost
estimates for alternatives 2 and 3 did not include possibly significant costs for mitigation of bay fill,
which had been proposed by state and local agencies.
State Acceptance: The Department of Toxic Substances Control of Cal-EPA, which is the lead state
agency for oversight at this Superfund Site, agrees with the selected remedy. In addition, the San
Francisco Bay Regional Water Quality Control Board and the San Francisco Bay Conservation and
Development Commission also agree with the selected remedy.
Community Acceptance: Based on the comments received during the Proposed Plan comment
period, it is evident that the selected remedy is acceptable to the community. No comments were
received from the community opposing the selected remedy or supporting other alternatives.
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10. Selected Remedy.
The selected alternative is dredging with off-site disposal. Components of the selected
remedy include:
Dredging of all soft bay mud from the Lauritzen Channel and Parr Canal, with off-site
disposal by rail of dredged material.
Placement of clean sediment after dredging.
Capping of areas around the former Heckathorn facility, shown in Figure 6.
A deed restriction or notice limiting use of the Levin-Richmond terminal to the current
industrial classification.
Marine monitoring to determine the effectiveness of the remedy.
The remedy will involve dredging of the younger bay mud from the Lauritzen Channel and
Parr Canal. The total volume of these sediments is estimated to be 65,000 yd3. In areas to be
dredged, all soft sediments down to the hard older bay mud contact would be removed. Two
sunken barges, one small tank, and other debris (see Figure 3) would be removed from the Lauritzen
Channel prior to dredging. In limited areas dredging may be impractical or of limited effectiveness in
removing all contaminated sediments because of obstructions such as rip-rap and capping may be
required.
Silt curtains will be erected across the mouths of the channels prior to dredging to prevent
transport of sediment disturbed by the dredging process out of the excavation area. Dredged
material will either be loaded directly onto rail cars or stockpiled on a barge or on land to facilitate
loading. Excess water, if any, produced during dredging and initial handling will be returned to the
dredging area inside the silt curtains. However, control measures, such as physical separation or
filtration, will be implemented to prevent or minimize the runoff or return of sediment back to the
excavation areas. The surface water ARARs for the concentrations of COCs are not currently
achieved, and would not be expected to be achieved in the Lauritzen Channel and Parr Canal during
the remediation. The surface water ARARs are remedial action goals which are expected to be
achieved after the remediation is complete.
The dredged material will be transported by rail to a permitted land disposal facility which
meets the requirements of the CERCLA offsite policy. The expected average concentration of
approximately 30 mg/kg, is well within the acceptable range for direct human exposure, and will not
present a long-term threat at a disposal facility. Monitoring of surface water and biota will occur for
at least five years or until it is demonstrated that the remediation goals have been achieved, and
could continue for a longer period of time. To promote the return of flora and fauna to the dredged
areas, a 1/2 foot layer of clean material will be placed after dredging. The material will not
significantly alter the existing bathymetry or impede navigation. The estimated cost for the selected
remedy is $7 million.
The selected remedy provides overall protection of human health and the environment,
complies with ARARs, and provides the best overall balance of alternatives under the nine selection
criteria of the NCP.
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11. Statutory Determinations
The selected remedy is protective of human health and the environment, complies with
ARARs, and is cost effective. The principal threats at the Site were addressed by removal actions.
Because this remedy will result in hazardous materials remaining onsite, a review will be conducted
five years after the commencement of remedial action, and every five years thereafter, to ensure
that the remedy continues to provide adequate protection of human health and the environment.
12. Documentation of Significant Changes.
The proposed plan for the Site was released for public comment in July, 1994. The
proposed plan identified alternative 4, dredging with offsite disposal as the preferred alternative.
EPA reviewed all written and oral comments submitted during the comment period. Upon review of
these comments, EPA determined that no significant changes to the remedy, as it was originally
identified in the proposed plan, were necessary.
During the proposed plan comment period, the National Oceanic and Atmospheric
Administration and the U.S. Fish and Wildlife Service recommended that a layer of clean material be
placed in the channels after dredging for restoration. The material would promote the return of
habitat and fauna to the dredged areas. The proposed plan included the placement of clean fill in
limited areas. The final remedy includes placement of a 1/2 foot layer of clean material after
dredging in the Lauritzen Channel and Parr Canal. The cost of placing clean material, which would
apply to all alternatives except "no action," was not included in the estimates contained in the FS or
proposed plan. The estimated cost is $200,000, which increases the total estimated cost from
$6.8 million in the proposed plan to $7 million for the final remedy.
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San Rafael
Richmond
Study
Area
Saifsafito
Berkeley
ngel Island
Oakland
Golden Gate
Bridge
San
Francisco
Pacific Ocean
San Francisco Bay
0 2.5 5
Scale in Nautical Miles
122°20' W
Figure 1. Site location map.
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LAURITZEM
CHANNEL
APPROXIMATE SQUNPARY
OF THt fORMEft
HECKATHORN
PARfr
CANAL
. INNER
HARBOR
CHANNEL
RICHMOND
INNER HARBOR
BASIN
500 1000
FEET
Figure 2. Map of Richmond Harbor.
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6
CO
Former Building
Complex
1,461.500 E
Approximate[AreaioJ; :/
1085 Dredging- • •/'• •
o>
CO
O
JS
o>
a
n
CO
a?
3
O)
Coordinates are Galifornla Coordinate System Zone III, NAD 1927 >' "^
-------
FORMER
ELECTRICAL
BSTATION A
SOUTH FOURTH STREET
EXCAVATION
AREA (1990-1991)
o.
a
a
'•5
a>
a>
8
Q>
(A
§
'+3
1
0)
o
o
o
0)
T3
0>
a
€
TJ
(Q
"a
From 12/22/93 letter from Levine-Fricke to EPA.
O)
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-32-
Upper Lauriizen Channel
Max DDT 633.000
Median DDT 47.000
MaxDieldrin 16.000
Undreded Area. Laurit7.cn Channel
Max DDT 192.000
Median DDT 14,000
Max Dieldrin 7000
Dredged Area. Lauritzen Channel
Max DDT 121,000
Median DDT 1500
Max Dieldrin 500
Upper Santa Fe Channel
Max DDT 740
Median DDT 110
Max Dieldrin 30
Parr Canal
Max DDT 4080
Median DDT 840
MaxDieldrin 170
Federal Santa Fe Channel
Max DDT 1090
Median DDT 210
Max Dieldrin 40
Unper Inner''Harbor Channel
Max DDT 220
Median DDT 60
Max Dieldrin 5
TOTAL DDT
(ug/kg dry wt)
Lower Inner Harbor Channel
Max DDT 80
Median DDT 10
Max Dieldrin 3
> 100.000
10.000 • 100.000
1.000-10.000
100-1.000
10-100
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BULM MATERIAL LOADING
STORAGE AREA
Modified from Levine-Fricke 1991a.
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