RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE: McColl Site, Fullerton, California
DOCUMENTS REVIEWED
I have reviewed the following documents describing the
analysis of cost-effectiveness of remedial alternatives for the
McColl site:
McColl Site Remedial Investigation
Environmental Assessment of the Remedial Action
Alternatives for the McColl Site, Fullerton,
Cal if orni a
Cost-Effectiveness Evaluation of Remedial Action
Alternatives for the McColl Site, Fullerton,
California
Review-of Feasibility Study at the McColl Site,
Fullerton, California, CH2M Hill
Summary of Remedial Alternative Selection
DESCRIPTION OF SELECTED REMEDY
All waste will be excavated and disposed of at an approved
RCRA disposal facility. Any hazardous soil up to a depth of one
foot below the waste will be removed to a RCRA disposal facility.
DECLARATIONS
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CFR Part 300), I have determined that the
excavation and redisposal alternative at the McColl site is a
cost-effective remedy and provides adequate protection of public
health, welfare, and the environment. The State of California
has been consulted and agrees with the approved remedy.
-------
-2-
I have also determined that the action being taken is
appropriate when balanced against the availability of Trust Fund
monies for use at other sites. In addition, the off-site transport
and redisposal is more cost-effective than other remedial action,
and is necessary to protect public health, welfare, or the
environment.
bee pi . inomas
Assistant Administrator
Office of Solid Waste and Emergency Response
V- / n /(t
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
MCCOLL SITE
Fullerton, California
I. SITE LOCATION AND DESCRIPTION
The McColl site is located approximately 20 miles southeast
of Los Angeles in Fullerton, Orange County, California. The site
is south of Rosecrans Avenue and west of Sunny Ridge Drive. The
site is divided into two parcels: the 7-acre Ramparts parcel to
the east and the 3.5-acre Los,-Coyotes parcel to the west. Homes
border the Ramparts site to the east and south. This residential
area of approximately 1,200 people contains homes directly ad3acent
to the site. The Los Coyotes parcel underlies the Los Coyotes
Country Club Golf Course. There are six sumps on each parcel
containing an estimated 85,000 cubic yards of waste (Figure 1).
This site is located in an earthquake zone 4, denoting the highest
level of earthquake activity.
II . SITE HISTORY
The site was created as a disposal area for acid sludge
wastes from the production of high octane aviation fuel during
World War II. In 1942, Eli McColl had 12 pits constructed in
what was then a rural area of Orange County. North of the site
were oil fields; a hog^ farm operated to the south; and the area
to the southeast was devoted to agriculture. Mr. McColl arranged
to haul away acid wastes of refiners producing high octane fuel
in the area. From 1942 to 1946, these wastes were dumped in the
McColl sumps.
*
Following the war, Mr. McColl wanted to improve the property
by covering the sumps so that the land could be developed for
other future uses. At that time drilling muds from oil production
activities in the area were plentiful. He received the necessary
local permits and arranged with several oil companies to dispose
of drilling muds. From 1951 to 1962 drilling muds were deposited
on-site, mainly in the lower Ramparts sumps. The acid sludge
and drilling mud combination was not stable; the drilling muds
sank into, and combined with the sludge.
In 1957 , the Los Coyotes Golf Course and Country ClujD was
constructed over the western six sumps. In the 1960's, developers
began to build homes in this area of Orange County. In the mid-
19701 s, homes were built immediately adjacent to the eastern and
southern borders of the Ramparts parcel. In July 1978, Orange
County received the first complaint of odors from McCol'd area
res idents.
-------
r Lyui t; i. uxciyxtuii oj_ rnjxjuxx dii.u
-------
-2-
In November 1980, the EPA Field Investigation Team (FIT)
conducted a background investigation of the McColl site which
identified potential responsible parties based on the types of
waste in the sumps. In December 1981, EPA, the State, local
agencies, and four oil companies (Shell, Union, ARCO, and Texaco)
signed a memorandum of agreement to study the McColl site.
On-site work commenced in March 1982 and a final report was
received in November. This remedial investigation was funded
by the oil companies, which contributed $800,000, and the
State of California which contributed $150,000.
In September 1982 the same participants entered into a
memorandum of agreement to conduct a feasibility study. This
feasibility study was funded by the State at a cost of $350,000.
In addition, Shell Oil Co. funded a pilot excavation project
which took place during May 1983, and demonstrated that excavation
was feasible without great inconvenience to area residents. The
feasibility study began in October 1982, and a final report was
published in June 1983. Based on this study, the State selected
excavation and redisposal of the waste and contaminated soil as
the cost-effective alternative. They immediately contracted
for the design of an excavation and redisposal project. The
project was opened for bidding on October 17, 1983; bids were
received by December 2, 1983; and a contractor will be selected
by the State in April or May 1984.
III. CURRENT SITE STATUS
contaminated sou at tne site. me waste is cnaracterized by
low pH (as low as 0.7), high sulfur content, and high organic
content. Levels of benzene, sulfur dioxide and tetrahydrothiophene
were found in the waste and soil. Gases produced from the material
include benzene, sulfur dioxide (SO2), hydrogen sulfide (H2S),
and various odorous hydrocarbons. In addition, arsenic has been
found in one of the lower Ramparts sumps. The major pathways
for exposure are through direct contact and inhalation.
The data indicate the corrosivity of the waste, and that pH
is less.acidic (higher) in the soil than in the waste. Direct
contact with the highly acidic material can cause burns to eyes
and skin. The State has applied a temporary cover of synthetic
material and soil to the Ramparts portion of the site. While
this has temporarily mitigated some of the threat, waste seeping
to the surface, especially on the golf course, continues to
create a direct-contact hazard.
There are
waste and
-------
-3-
The main ground water body at the McColl site is 150 to 250
feet below the land surface. Perched water at 15 to 42 feet has
been found underlying'the Ramparts site. However, this perched
zone is not used and no connection to the regional aquifer has
been demonstrated. Ground water flow is generally to the south.
The perched ground water has been sampled by the State, and
shows very low pH, and high sulfates and arsenic. These constituents
may be attributable to the waste deposited on-site. However,
water samples of the regional aquifer from one ground water
monitoring well and four city wells south of the site, show
neutral pH and no elevated levels of contaminants that could be
traced to the site.
The State analyzed soil samples below the waste to a depth
of over 100 feet in two cores. Soil below the waste showed a pH
greater than 2. Trace amounts of metals and sulfur-containing
compounds were found in the soils. However, these are not in
concentrations that would pose harm to the public or the
environment. If the waste is properly controlled to prevent
future leaching, there should be little or no threat of ground
water contamination from the site.
Arsenic in most areas of the McColl site does not exceed
background levels. However, surface sampling from one of the
Ramparts sumps revealed an arsenic concentration of 10,100 ppm.
Arsenic enters the body primarily by ingestion or inhalation.
The California Department of Health Services has estimated
that ingestion of a few grams of arsenic-contaminated soil at
concentrations found on a portion of the McColl site (10,100
ppm) could produce acute poisoning, especially in children.
Arsenic in concentrations of 0.35 mg/1 has been measured in
storm water runoff from the site. This is seven times the Federal
drinking water standard of 0.05 mg/1. However, since runoff
does not enter any drinking water supplies, this is not presently
a health threat.
The most obvious problem from the McColl site are its odors
and toxic air emissions. Sulfur-containing hydrocarbons are
emitted from the site at levels detectable to the residents.
Because odors prompt public complaints, air samples have been
analyzed for odorous compounds such as SC>2 and tetrahydrothiophene.
The following table indicates the concentrations of gases that
have been measured from the site.
-------
-4-
Contami nants
Undisturbed
(On-site)
Disturbed Disturbed
(On-site) (Community)
S02
Benzene
2500 ppb
42,000 ppb 170 ppb
thousands up to 1000 ppm
of ppm
The State Department of Health Services conducted a health
survey of the McColl site from July 1981 to March 1982. The
symptoms reported by area residents (headaches, nausea, dizziness
and respiratory irritation) increased with the proximity of the
residence to the site. These- symptoms could be attributed to
the types of air emissions coming from the site.
Ambient levels of benzene in the McColl area are no higher
than benzene levels in other parts of the Los Angeles Basin.
However, the potential for exposure exists should the site or the
cap be disturbed. Chronic benzene poisoning is manifested by
symptoms such as fatigue, headache, dizziness and loss of appetite.
Sulfur dioxide (SO2) gas is emitted from the McColl site,
especially during site disturbance. This gas classified is an
eye and respiratory irritant in low concentrations (6-12 ppm)
and can be fatal in high concentrations. In combination with
other air pollutants, such as particulate matter and ozone,
SC>2 has caused an increase in the death rate during smog incidents.
As expected, the elderly and those with heart and lung disease
are more susceptible. Orange County has not reached attainment
with National Ambient Air Quality Standards for particulate
matter and ozone, although it is in attainment with SO2 standards.
In sum, the major pathways for exposure are air and direct
contact. Disturbance of the site can cause the release of benzene
and SO2 in high concentrations. Although the site has been
fenced, children are attracted to the area to search for golf
balls. The fence has not deterred this activity. The temporary
cover applied by the State to the Ramparts parcel has reduced
the danger from direct contact and air emissions. However, the
cover is only a temporary measure. Waste seeping to the surface,
especially on the golf course, still creates a hazard.
IV. ENFORCEMENT
In 1980, EPA sent RCRA section 3007 letters to seven potenti-
ally responsible parties (PRP's). In 1981, further section 3007
letters were sent to nine PRP's requesting additional information.
As a result of that effort, a Participants Committee was formed
of EPA, the State, local agencies and PRP's. Under this Committee's
oversight the remedial investigation and feasibility study were
conducted. On July 22, 1983, 16 additional section 104/3007
letters were sent in an attempt to identify other PRP's. Notice
letters were sent to eight PRP's on August 12, 1983.
-------
-5-
In June 1983, a negotiating committee (composed of EPA, the
State, local agencies, several oil companies, and landowners) was
formed to discuss implementation of the feasibility study recom-
mendation. During the initial meetings, the committee agreed to
an additional effort to locate other PRP's. In addition, it was
agreed that no dollar offer could be made until the State refined
the cost of the project during design. The State's final design
was made public in October 1983. On November 8, 1983, the PRP's
made a tentative settlement offer of $10 million, less than 50
percent of the estimated total#cost of the cleanup. EPA and
DOHS jointly rejected that offer.
In addition, EPA and DOHS clarified their position on the
amount of an offer necessary to allow negotiations to continue
(no less than 80 percent of the total cleanup cost) and on
settlement issues raised by the PRP's. This position was conveyed
to the PRP's at a meeting on January 31, 1984. The PRP's were
informed that negotiations would be terminated on March 8, 1984,
unless significant progress was being made. On February 16,
1984, the PRP's submitted a written offer of $15 million. EPA
and DOHS are currently evaluating that offer.
At the same time, EPA, the State, and PRP's have met to
discuss language for a proposed consent decree. Although there
has been progress toward settlement, Region 9 is preparing a
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) section 106 order to be issued to the PRP's
should settlement not be reached. It is anticipated that the
order will be issued in early May giving the PRP's an opportunity
to respond before the cooperative agreement is awarded.
V. STATE'S COST-EFFECTIVENESS EVALUATION
A. Background
EPA and the State investigated the site and sent Resource
Conservation and Recovery Act (RCRA) section 3007 letters in
late 1980, prior to the passage of CERCLA in December 1980. An
initial meeting with PRP's and other interested parties was held
in April 1981. From that point, the State took the lead in the
remedial action with EPA remaining as a member of the Participants
Committee. In December 1981, the Participants Committee entered
into a memorandum of agreement for remedial investigation of the
site. The remedial investigation commenced in March 1982, at
the same time as the National Contingency Plan revisions for
Superfund were proposed. After completion of the remedial
investigation, the Participants entered into another memorandum
of agreement to conduct a feasibility study. The feasibility
study recommended excavation to be the cost-effective alternative
for cleaning up the site.
-------
-6-
In June 1983, when the final feasibility study report was
published, the State considered the need for Federal Superfund
money to fund the cleanup. At that time, EPA asked CH2M Hill to
review the State's feasibility study to determine compliance
with the NCP.
Concurrent with our review of the State's feasibility study,
the State contracted for design of the excavation and redisposal
alternative. The design was completed by Black and Veatch and
the project was opened for bidding on October 17, 1983. Bids
were received December 2, 1983; but a contract has not yet been
awarded.
Throughout the process of remedial investigation, feasibility
study and design, the State held numerous public meetings and
sent letters and bulletins to the McColl area residents to keep
them informed of activities at the site. EPA remained a member
of the Participants Committee and reviewed all remedial investiga-
tion and feasibility study documents produced by the State.
During the feasibility study, 82 potential technologies for
site cleanup were considered. These technologies fall into the
following categories: excavation/waste handling, emission control
during remedial alternative, long-term emission control, treat-
ment of solids/semi-solids, treatment of liquids/runoff, in situ
treatment/pretreatment, redisposal, transportation, surface
water control, containment, recov.ery/recycle/reuse, and dust
control. Using the State's selection criteria, technologies
were assessed to eliminate those not appropriate for the McColl
site: applicability to the McColl site; ability to meet DOHS
cleanup criteria; environmental, health, and safety impacts;
time and/or cost .requirements; usefulness with intermingled
wastes; technology status; reliability and implementabi1ity; and
usefulness as part of a system of technologies.
In the State's evaluation, technologies that were applicable
to the McColl situation were incorporated in the development of
six remedial alternatives (three involving containment and three
involving removal). These six alternatives were further refined
to one containment scenario and one removal scenario. A combination
of containment of waste on one parcel and removal of wastes on
another was also considered. Thus, three alternatives were
evaluated in detail.
Before the State evaluated the cost-effectiveness criteria,
the State considered any environmental impacts imposed by the
remedial alternatives. All three alternatives were considered
by--the State to have long-term positive impacts. The containment
alternative had the greatest long-term potential risk of failure
and also the lowest short-term impact for community exposure.
While the potential for short-term community exposure was greatest
with the excavation alternative, the potential for long-term
impacts was to be eliminated.
-------
-7-
There were three phases to the State's cost-effectiveness
determination. The initial rating was conducted in April 1983.
Alternatives of containment, excavation and a combination were
developed for the following variables: 2-hour and 8-hour round
trip to disposal site; 2 feet, 5 feet and 10 feet excavation of
soil below the waste.
B. Evaluation of Alternatives
Based on this initial cost-effectiveness rating, the
State eliminated the Combination Alternative as least cost-effective
because the effectiveness ratios for this alternative were lower
than the excavation and containment cases that would best mitigate
-the hazard. Excavation and redisposal appeared to be the
cost-effective alternative. To verify that excavation without
undue community impacts was feasible, a pilot excavation project
was undertaken. After the pilot project demonstrated that excavation
was safe, the designs of Alternatives containment and excavation
and redisposal were slightly modified and the alternatives were
again rated for cost-effectiveness.
For this second evaluation, a short schedule was evaluated
and costs estimated for each alternative. Minor cost revisions
were incorporated for both alternatives. In addition, disposal
and transportation costs, the cost of the excavation enclosure,
and the cost of the foams based on information gathered during
the test excavation were evaluated. The evaluation committee
found that excavation was cost-ef-f ect ive.
The State's final cost-effectiveness rating was completed
in June 1983. The effectiveness scores did not change from the
May version, but costs were refined based on new estimates. The
major change in cost was the addition of construction management
costs. These items were not included in earlier estimates.
The State selected excavation and redisposal as the cost-
effective alternative.
VI. CH?M HILL'S REVIEW OF STATE-CONDUCTED FEASIBILITY STUDY
CH2M Hill was tasked by EPA to evaluate the remedial
investigation and feasibility study managed by the State. Part
of their task was the review of the State's assumptions and the
development of independent cost estimates. CH2M Hill concluded
that the process followed by the State to screen alternatives
and relate effectiveness to cost is consistent with the NCP.
The State's study thoroughly characterizes the site and the
waste. Danger to public health via direct contact and air
emissions is documented.
-------
TABLE 3-8. COMPARISON OF AVERAGE CHEMICAL COMPOSITIONS BETWEEN SAMPLE TYPES
N. Matrix
\ Class
W4
M2
to
M4
S2
S3
S4
Number of
N. Samples
Variable N.
n=8
n=l
n=l
o=3
n = l
n=l
n=4
Carbon, X
16
" 34
1.6
25
0.16
0.19
1.1
Hydrogon, %
3.7
7.3
1.8
4.8
0.70
2.0
1.7
Oxygen, X
23
24
15
17
3.6
16
14
Nitrogen, %
0.17
0.20
0.10
0.17
0.10
0.10
0.11
Sulfur, X
9.5
8.7
0.24
7.5
0.73 ,
0.27
1.2
Chlorine, X
0.12
0.10
0.10
0.13
0.11
• 0.10
0.10
Asli, %
48
10.
79
35
90.
80.
80.
BTU/lb
2900
7580
175
5700
100
100
650
Volatile matter, X
44
77
23
56
11
22
20
Total fixe^ carjjpn. _ X . _
13
0.00
9.9
0.00
0.00
1.7
Density, g/cra
1.1
0.96
1.7
0.95
1.5
1.4
TTTj
pU, pll units
- o : <#"¦
0.90
7.0
1.2
3.6
3.9
6.0
Conductivity, uraho/cm
88100
60000
35000
79000
8000
4900
8900
-------
Type
S _
K
D
W
>,
u
e
l
SI
Ml
01
wi
0)
<->
sa
*wi
2
S2
K2
D2
W2
m
c
3
3
S3
M3
D3
• W3
4
S4
M4
D4
W4
Type
S - Soil/Sand - Material from the sice that appears Co be
background soil, sand, overburden, etc. Ho visible signs or" contamination
from che wastes.
M - Soil/Waste Mixture - Material that looks like a mixture of
soil and waste. Visible signs of waste. Waste material can be black
asphalclc (liquid or solid), white powder, dry black/brown dusty powder,
or other non-sediment material.
D - Drilling Mud Waste - Grey/brown, mud-like material. Drilling,
ciud usually is a thick sludge with a wee appearance.
W - Black Asohaltic Waste - Black waste material that can have a
variety of consistencies.
Consistency
1 - Liquid - Light fluids with a low weight percent solids char-
acter (i.e., perched groundwater).
2 - Low Viscosity Sludge - Fluid sludge material that flows easily.
Liquid tar is included at this consistency class (i.e., molasses-type}.
3 - High Viscosity Sludge - Very high weight percent solids char-
acter. Will not support weight (i.e., oatmeal-type consistency).
4 - Solid - Structural integrity like chat of background soil.
Figure 3-1. Matrix Class System.
-------
However, CH2M Hill determined that the extent of the
problem at the site has not been fully defined in two respects.
The first is ground water contamination. Only one downgradient
well exists for this site. Though limited sample data from this
well indicate that it is not contaminated, insufficient data
exist to conclude that the waste has not yet contaminated the
ground water. The State has undertaken a study to investigate
the ground water. However, the existence of contaminated ground
water would not alter the selection of the source control remedy.
The second area of concerh to CH2M Hill was the extent of
soil excavation required using the State's cleanup criteria.
Very limited data have been collected on the extent of soil
contamination. The State bored five cores in five different
sumps. A total of 11 samples from varying depths were analyzed
for volatiles, base/neutrals, priority pollutant metals, and pH.
Substances such as tetrahydrothiophenes, cycloparaffins, and
organic sulfides were measured in the ppm range. Heavy metals
and phenols were also detected. In calculating the total density
of waste, CH2M Hill recommended that the density figure used
by the State (0.88 tons/yd^) be revised upward to 1.35 tons/cubic
yard, based on an assumption that the State's analysis was based
on estimates rather than empirical data.
CH2M Hill subsequently reexamined its recommendations in
light of density measurements of the soil and wastes conducted
by Radian. They concluded that the weighted average of the
waste was 1.04 grams per cubic centimeter. This is equivalent
to the 0.88 tons/cubic yards (see attached Radian summary of
density analysis). CH2M Hill confirmed this estimate. Therefore,
based on these data, EPA accepts the density figure used by the
State. r
VII. EPA'S COST-EFFECTIVENESS EVALUATION
EPA decided, based on the findings of CH2M Hill, that an
independent cost-effectivess evaluation was necessary. Cost
estimates developed by the State's contractor and CH2M Hill were
evaluated. Based on the cleanup criteria described below, EPA
redefined the scope of the excavation and redisposal alternative.
In addition, EPA also developed alternatives for upgraded containment
(designed to protect against earthquake damage) and a RCRA on-site
facility. EPA cost estimates for four key alternatives (see
Table 1). The four alternatives are: 1) containment, 2) upgraded
containment, 3) excavation and redisposal, and 4) a RCRA on-site
disposal facility.
-------
-9-
A. Cleanup Criteria
Because there is no evidence that hazardous substances have
migrated from the site except via the air pathway, a source
control remedial action as described in the NCP is the appropriate
cleanup method. These criteria address both short-term and
long-term protection of public health and the environment.
1. Water
a. Ground Water,
° minimize standing water
b. Surface Water
0 short-term criteria for benzene, toluene, xylene,
arsenic, sulfates and pH
° over the long-term, no run-off from the site may
contain satistically significant levels of any
constituents attributed solely to the site
above background levels.
2. Air '
a. Odor: The South Coast Air Quality Management
District (SCAQMD) has developed an odor monitoring
plan for the McColl site. During the cleanup
distinct, easily noticeable odors will not be
allowed beyond the site perimeter. Over the
long-term, faint.odors will be allowed directly
over the site, but no detectable odor is allowed
beyond the site perimeter. A SCAQMD inspector
' will assess odor intensities during cleanup.
• b. SO2: 24-hour, 1-hour and 5-minute standards
have been set. The 24-hour standard is the
same as EPA's 24-hour National Ambient Air
Quality Standard. The 1-hour 'and 5-minute
standards are approximately half of similar
standards set by the Puget Sound Air Pollution
Control Agency (one of the few regulatory
agencies with similar standards). Because the
Orange County area is nonattainment for particulate
matter and ozone, and because the health effect
of SO2 is exacerbated in combination with
particulate matter and ozone, stringent standards
are'warranted. The long-term standard requires
no statistically significant SO2 concentration
increase across the site.
-------
-10-
c. Benzene: The fence-line standard is 2 ppm under
the most stable (or worst case) meteorological
conditions - no wind and low solar radiation.
The standard provides protection below the
one-in-one-million cancer risk level.
d. Soil and Waste: Excavation or containment of
waste and all obviously contaminated soil up to
one foot below the sump.
The State's cleanup criteria used during development of the
feasibility study were far more stringent regarding soil removal
than those detailed above, if literally applied. These criteria
included: removal of all soils with pH less than or equal to 2,
and all soil with arsenic at or above hazardous concentrations.
Soils meeting California definitions of hazardous waste were
also to be removed, as well as soils with chemical concentrations
above those specified in the California Assessment Manual.
Soil sampling below the sumps indicate there is minimal
contamination of soils^ extending approximately 50 to 70 feet
below the sumps. These contaminants have migrated approximately
one to two feet per year and are not expected to pose a threat to
the ground water. TheStates's remedial investigation showed a
distinct break between ,the waste and underlying soils. Excavation
of the wastes would remove 99 percent of all site contaminants.
Soil removal under the,sumps would not provide additional protection.
EPA's cleanup criteria have been presented to the State. The
State has agreed that these criteria are acceptable.
B. Description of Alternatives
1. No-Action Alternative
Selection of the no-action alternative is not acceptable
for several reasons. First, there is the threat of emissions to
residences adjacent to the McColl site. The entire community has
been subjected to odors primarily from¦uncovered wastes in the
lower Ramparts area. Significant potential exists for air
contaminant emissions (e.g., SO2 and benzene) during site
disturbances. A health effects study conducted by the State
indicated that proximity to the site was linked to adverse responses
of the residents.
Direct contact is the second concern at the site.
Waste materials have seeped to the surface in the Los Coyotes and
Ramparts areas. Arsenic has been found at high concentrations
(up to 10,000 ppm) which can cause acute poisoning. Also direct
contact with the acidic waste can cause eye and skin burns.
-------
-11-
The third area of concern is the long-term threat of ground
water contamination. Should the site be left in its current
condition, contaminant migration would continue, at the rate of
approximately one foot per year.
Each of these threats would be compounded as a result of
seismic activity. Disruption of the waste material resulting
from an earthquake could cause substantial emissions of benzene,
SC>2 and other hazardous constituents.
2. Containment Alternative
The State developed the containment alternative which left
the waste and contaminated material in place on both portions of
the site (Ramparts and Los Coyotes). Containment walls of acid
and sulfate resistant concrete would be placed around both areas
of the site. Reinforced concrete would be put in the "downhill"
portion of the walls for structural integrity and seismic protection.
The remaining portions of the structure would be standard slurry
construction. Emissions control during trenching would include:
mechanical collection and dispersion, foams, sprays and deodorants.
A cover would prevent rain infiltration, surface run-off, and
would contain gaseous emissions. A gas collection system would
be installed below the cover in a gravel bed and emissions captured
with a treatment system. The containment system would not tie
into an impervious layer.
A monitoring system would be installed to monitor air quality
during construction. A seismic monitoring system would also be
installed and water quality,monitoring would be conducted at the
rate of four samples per year per well.
*•
All trenching materials and contaminated overburden would
be removed and sent to a Class II-l landfill. The total to be
removed is estimated to be 20,650 cubic yards. The synthetic
cover would be overlaid by sand and top soil and seeded. Below
these, two layers of construction fabric, a layer of gravel would
be installed. The reinforced concrete would have an average
depth of 45 feet and-would be 3 feet wide. The slurry wall would
have an average depth of 40 feet and be 1.5 feet wide. A synthetic
membrane would be installed as an additional barrier to the
reinforced wall.
In evaluation of the seismic risk to the containment alterna-
tive, the State's consultant predicted that the construction of
the walls buried in place would not result in collapse in the
event of an earthquake. However, displacement or separation of
the walls could occur, resulting in some release of materials
near the surace. In steeply sloping areas, small scale slumping
and near surface rotational displacement could also take place.
The State's consultant stated that it would be unlikely that
large scale slumping or large scale releases of waste would
occur.
-------
-12-
3. Upgraded Containment Alternative
As a result of the threat of an earthquake at the site, EPA
developed an upgraded containment option to approach the same
protection afforded by excavation and redisposal off-site. The
upgraded containment remedy would be improved in two respects.
First, a second liner would be placed in the cap to increase the
reliability of the gas control system. Should there be a failure,
the second liner would capture emissions. The cost of this
component is $360,000.
The wall of the containment system would not tie into an
impervious layer. Therefore, a ground water control system,
comprised of six wells, approximately. 80 feet deep, also would
be added to the upgraded containment remedyto prevent migration
below the cut-off walls. The wells would pump ground water
whenever necessary to insure that the contained waste was not
saturated. The possibility of future migration of waste would
be further minimized. The protection and reliability of upgraded
containment closely approaches that of excavation and redisposal.
However, reliability of the system nonetheless would be less
because of the inability to predict the itensity and effects of
seismic activity.
4. Excavation and Redisposal Alternative
The State also developed the "excavation and redisposal"
alternative, involving removal of*all waste and obviously
contaminated material from both parcels. Waste includes the
black or dark-covered tar-like asphaltic material disposed in
the 12 pits, and obviously contaminated material up to one foot
below the sumps.
The quantities of waste material in the sumps to be excavated
are estimated to be 85.,000 cubic yards. Berm materials between
the sumps to be excavated are estimated to be 25,000 cubic yards.
Contaminated overburden to be excavated are estimated to be
21,000 cubic yards. Clean overburden of 13,650 cubic yards
would be excavated and then replaced on-site. The one foot^of
soil to be excavated below the sumps is estimated to total 8,000
cubic yards. Redisposal of waste is to take place at a RCRA
Class I facility. The site would be regraded with soil available
on-site.
Emissions will be monitored during excavation and will be
controlled using foams, sprays and mechanical collection.
5. RCRA Qn-Site Disposal
The RCRA on-site disposal alternative entails the excavation
and temporary storage of waste material and contaminated soil.
Lined disposal cells would then be constructed and the wastes
and soils placed into the cells. The cap over the cells would be
lined and a gas collection system installed.
-------
-13-
C. Evaluation of Costs
The net present value of the original containment option
developed by the State is estimated by EPA to be $17,392,000.
The upgraded containment, which is considered to provide protection
approaching that of excavation and redisposal has a present value
cost of $18,937,000 compared to that of excavation and redisposal
of $18,306,000.
Cost estimates for the excavation and redisposal option are
more highly refined than figures for the remaining options due to
the completion of design and bidding of that design by the State.
Cost estimates tor the remaining three options have varying
degrees of refinement as reflected in the range estimates on
Table 1.
The State's containment option costs are expected to reflect
the reliability of a feasibility study estimate. The upgraded
containment option shows additional costs for ground water
protection and adding the cost of a double liner to the cap.
These cost estimates have similar reliability to the State's
containment option. The estimates for a RCRA on-site facility
are far less refined because the original State feasibility
study did not'consider this option. Further analysis would be
required to refine this estimate.
The EPA confidence level is highest for the cost estimates
developed for the excavation and redisposal alternative. Should
containment be selected, wider cost variations would be expected.
D. Evaluation of Effectiveness
The effectiveness of the four alternatives is discussed below.
1. During Construction
a. Containment
Construction of the containment structure would entail
trenching and removal of a limited amount of hazardous material
prior to installation of the barrier walls, liner and cap. A
very limited amount of air emissions would be expected and control
of these emissions would occur by the use of foams. No exposure
of the adjacent community would be expected.
A shorter construction time compared to excavation and
redisposal is anticipated due to the more limited scope of the
work. However, time for design and procurement would add
considerably (i.e., 9-12 months) to the anticipated schedule.
EPA estimates that actual construction would not commence before
early 1985.
-------
COSTS Of PROPOSED REMEDIES AT MCCOLL
Design:
Oversight:
Radian:
State:
Site Preparation:
Cleamp Costs:
Double Cap:
Ground Water Control:
Total Capital Costs:
O&M:
Annual:
Present VaLue:
Total Present Value:
Containuent
750,000
930,000
120,000
-0-
1/
13,355,000
15,155,000
237,0UU
2,237,0(J0
17,392,000
Upgraded Containment
750,000
930,000
120,000
-0-
Excavation and Redisposal
336,000
1,500,000
120,000
731,000
RCRA On-Site Disposal
750,000
1,000,000
120,000
731,000
3/
13,355
000
15,543,000
19,722,000
360
000
500
000
2/
tons
unit ptice
subtotal
Excavation
Overburden
13,650-
X 5.00
68,250
-'Wast.e & SoiX~)
130,620
15.10
1,972,362
$2,028
14.85
475,616
2,516,228
tons
miles unit price
subtotal
Transportation
Waste-
130,620
190 0.146
3,623,399
Soil
32,028
190 0.138
839,774
On-Site
13,650
2.50
34,125
4,497,298
tons
unit price
subtotal
Redisposal
Waste (liquid)
1,500
15.48
23,220
(solid)
130,620
15.48
2,021,998
Soil (liquid)
"2,000
12.10
24,200
(solid)
32,028
12.10
387,539
2,456,957
Other
6,073,000
16,015
,000
18,230,000
22,323,000
310,
000
20,000
406,000
2,922
000
76,000
3,825,000
Ranges:
-10%
+35%
15,653,000
23,479,000
-10%
+ 35%
17,043,000
25,565,000
-10%
+20%
16,475,000
21,967,000
-35% 16,996,000
+75% 45,759,000
1
-------
Source of these estimates is CH^M Hill evaluation oŁ Radian feasibility study estimate.
Sources ot these figures ace the Radian feasibility study and bid documents to the State.
Source of these rough estimates is CH2M Hill.
-------
-14-
b. Upgraded Containment
To afford increased protection to the containment option,
EPA considered two additional components to the State's containment
remedy. A second liner would be installed and a ground water
interceptor system would be installed around the site. EPA
expects that these additional components would extend the schedule
for construction by at least two months.
The remaining advantages and disadvantages during the
construction period are identical to those discussed above for
the State's containment option.
c. Excavation and Redisposal
This alternative entails excavation, handling, transportation
and redisposal of 85,000 cubic yards.of waste material. Substantial
emissions are expected to result during this operation. The State
has designed an extensive program for emissions control, using
foams, special enclosures, and monitoring systems. In addition,
large quantities of contaminated overburden and soil would be
removed from the site. A lesser degree of air emissions are
expected from these materials.
A higher temporary risk of exposure to the residents, compared
to the containment alternative, would be anticipated for this
alternative due to the large quantities of waste to be removed.
Construction of this alternative would be expected to extend
to 19-20 months. However, design and procurement for this alterna-
tive have already been completed by the State.
r
d. RCRA Qn-Site Disposal
This alternative would require excavation followed by
short-term storage of wastes and contaminated materials, during
liner installation. The advantages and disadvantages during
contruction are similar to the excavation and redisposal option
with a few exceptions. An increased risk of exposure to the
adjacent community would result because waste would be stored
above ground on-site, remaining until installation of the liner
is complete.
EPA estimates that construction time would extend 4-6 months
beyond that estimated for excavation and redisposal. No design
or procurement for this alternative has been developed.
-------
-15-
2. Post Construction
a. Contai nment
Waste materials would remain on-site permanently. Barrier
walls would not be tied to an impervious layer. Vertical migration
of some contaminants at low levels has occurred to a depth of
50-100 feet. Although installation of the cap would be expected
to limit migration and the barrier walls would be expected to
prevent any horizontal migration, they would not stop all verticial
migration cf contamination. Minimal risk to this aquifer would
occur with selection of this option.
A gas collection system would be installed below the cap to
collect gases below the waste. This system would be connected to
a caustic scrubber and carbon absorption unit above the cap.
Seismic activity could, disrupt the unit causing mechanical failure,
liner or containment wall failure, or failure of the collection
system. Gaseous emissions could occur as a result of these
failures. The community adjacent to the site would immediately
be exposed to these toxic emissions.
The design life of the containment structure is approximately
30 years. Without significant seismic activity, an evaluation of
this structure at the end of this period would be conducted and
major renovation of the structure may be required. With seismic
activity, damage to the structure could cause repairs of varying
extents. Repair of small cracks are estimated to cost $50,000.
Although unlikely, major failure could cost up to $9,000,000 to
r epai r.
Land use post-construction of the containment alternative would
be restricted to passive uses (e.g. golf course).
b. Upgraded Containment
The addition of a second liner to the cap would be expected
to provide further protection against possible gas emissions.
This would not, however, prevent all such migration. The gas
collection system would be the same as that envisioned under the
original containment option. However, the possible disruption
and gas escape caused by seismic activity would be more limited
by the second liner. Disruption of the scrubber system, however,
would remain the same as that detailed above. The additional
ground water interceptor system would, however, avoid ground
water contact with contaminants in the soil, providing a much
higher level of protection.
Risks to the barrier walls from seismic activity would also
be the same as discussed in the basic containment option.
-------
-16-
c. Excavation and Redisposal
Removal of all waste and obviously contaminated materials
afford the highest level of protection to the adjacent community.
More than 99 percent of the waste would be removed in this option
leaving minimally contaminated soils.
The likelihood of significant migration of contaminants
toward the ground water aquifer is minimized by the removal of >
the source of such contaminants.
With this option, the threat of direct contact or exposure
to gaseous emissions would be eliminated. In addition, seismic
activity would not increase the threat of exposure to emissions
or direct contact with this option.
The likely redisposal facility is located in a zone with
lower levels of seismic activity than the zone in which McColl
is located.
d. RCRA On-Site Disposal
The RCRA on-site facility would be expected to present a
much lower risk of vertical and horizontal migration of contaminants
to the aquifer because of the placement of a double synthetic
liner below the wastes. The installation of a leachate collection
system would also provide additional protection to the possible
migration of contaminants to the ground water. Some periodic
evaluation of the synthetic liners integrity might prove necessary.
Seismic activity affecting the functioning of a gas collection
and treatment syst„em would be expected to be the same as the
effects detailed in the containment option discussion.
VI. COMMUNITY RELATIONS
A. Background
The State has taken the lead on community relations throughout
this project. It developed a process for relaying information
to the public in early 1982 when the remedial investigation began.
Using census data and door-to-door canvassing, a mailing list of
approximately 950 area residents was developed. The State notified
these residents by letter and bulletin of meetings, and also of
any upcoming activities at the site. DOHS chaired the numerous
public meetings. Local newspapers were notified of meetings at
the same time as area residents. While the State did not place
formal "public notice" advertisements in the papers, the papers
frequently ran articles announcing the upcoming meetings.
-------
-17-
The first meeting was held February 4, 1982, to inform the
residents that an agreement had been reached with the oil companies
for remedial investigation of the site. In March 1982 a Residents'
Committee was formed of area residents who wanted more involvement
than the general public. This committee met several times with
the State independently of the general public meetings.
At each phase of the project DOHS held a public meeting to
inform the residents of progress (e.g. to discuss remedial
investigation, health studies, give general status). Meetings
were on the record. At each meeting the public was given the
opportunity to make oral and written comments. The early meetings
were held at the Fullerton Main Library. On February 24, 1983,
the meeting location changed to Parks Junior High School. At
this meeting three remedial alternatives were presented and
described to the approximately 200 residents in attendance.
The State informed the public that it would determine the
cost-effective remedy following evaluation of public comment.
On April 7, 1983, the State met with the residents to inform
them that it had selected excavation as cost-effective. At the
same time the residents were informed that a test excavation
would be conducted during May to ensure that DOHS emissions
control criteria could be met. The final meeting on this phase
of the project was held June 2 when the results of the test
excavation were discussed.
At every meeting the public was encouraged to comment on
the State's planned activities. Under the State's procedures
copies of each report developed during the feasibility study
were sent to two local libraries (the Fullerton Main and Hunt
Branch) at the same time the documents were submitted to DOHS
and EPA. *
Articles published in the Daily News Tribune and the Daily
Star Progress following the June 2, 1983, public meeting described
the residents' reaction to the State's announcement. The
overwhelming community consensus was an endorsement of the
excavation alternative. No written comments were received by
the State. State Community Relations staff telephoned individual
members of the community advisory committee to solicit written
comments. Members contacted stated that they felt the public's
oral comments in favor of excavation were clearly stated during
the public meeting. The residents primary concern was focused on
removal of the waste to eliminate the threat of hazardous emissions.
No concern was expressed regarding removal of the soil.
-------
-18-
B. Responsiveness Summary
All meetings were recorded. These records and newspaper
articles clearly indicate that the public favors excavation.
Because no written comments on the alternatives were received,
no formal summary is required.
VIII. CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
There are two environmental regulations with which the
McColl cleanup is required to comply: Clean Air Act and Resource
Conservation and Recovery Act-'(RCRA).
As required by the Clean Air Act, EPA has promulgated National
Ambient Air Quality Standards for criteria pollutants such as
SO2, particulate matter, and ozone. Primary standards are designed
to protect the public health. Secondary standards are designed
to protect the public welfare. Under the Clean Air Act, States
have the authority to set standards which are stricter than
national standards. The State of California in conjunction with
the South Coast Air Quality Management District, has set ambient
air standards for SO2 that must be met during the McColl excavation.
The excavation has been designed to use foams and a containment
structure to ensure that the standards are met. However, should
the standards be exceeded, excavation could be delayed.
Authority to implement RCRA has been delegated to the State
of California with the exception of permitting for surface
impoundments, incineration and land disposal. Since the State
is acting as the generator during cleanup, they will comply with
their own regulations. RCRA generator standards will apply to
the excavation. Tjie State will comply with all regulations,
including manifesting, recordkeeping, and reporting.
IX. RECOMMENDED ATERNATIVE
Section 104 (c) (4) of CERCLA states that EPA shall select
the most "cost-effective" remedy. In addition, Section 101(24)
of CERCLA states that off-site transport of hazardous substances
is not appropriate unless it is "more cost-effective than other
remedial actions" oŁ "necessary to protect public health or
welfare or the environment from a present or potential risk
which may be created by further exposure to the continued presence
of such substances." These provisions are explained futher in
the National Contingency Plan. See sections 300.68(j) and
300 .70(c).
EPA has carefully reviewed the State's cost-effectiveness
evaluation and the CH2M Hill review of the State's feasibility
study, as discussed above. Based on EPA's independent cost-
effectiveness evaluation, excavation and redisposal is the most
cost-effective remedy.
-------
-19-
Both containment options provide greater protection of
public health during construction. However, the excavation and
redisposal alternative' provide the highest degree of protection
after construction.
Estimates of the cost of containment range from $15,653,000
to $23,479,000; excavation costs range from $18,306,000 to
$21,967,200. Costs estimated for an upgraded containment
alternative range from $18,937,000 to $25,565,000. For comparison,
costs for a containment facility designed to comply with RCRA
range from $16,996,000 to $45,759,000.
The upgraded containment option is rejected because it is
six percent more expensive than excavation and redisposal and does
not provide the same level of long-term protection as excavation.
Similarly, the RCRA on-site alternative is significantly more
expensive than excavation and similarly provides the long-term
protection of upgraded containment. In this case, EPA's evaluation
indicated that excavation is cost-effective for the following
reasons.
1. Although there is no evidence of an earthquake fault
directly under the site, the Fullerton area is in the highest
risk earthquake zone in California (Zone 4) as designated by
the Uniform Building Codes. While the precise degree of risk is
unclear, there is some risk of public exposure to hazardous
substances, especially gases, should an earthquake disturb the
containment system. Because the community is adjacent to the
site, exposure would be rapid and without attention. The likely
redisposal site (Casmalia) is in a lower risk earthquake zone
(Zone 3).
2. The containment system is not tied to an impervious layer
beneath the site. Thus, the potential for ground water contami-
nation from leachate from the site remains. Available data indicate
that several constituents from the waste have migrated approximately
50 feet or more below the land surface. While the concentration
found at these depths are not hazardous, their presence indicates
the vertical mobility of the waste.
3. The public has been informed of the short-term risks of
excavation, and it supports the selection of excavation. The
containment alternative would not have a high level of acceptance,
because it would be difficult to guarantee such a system against
possible failure. The State supports excavation, has designed
the remedy, accepted bids for the cleanup, and is ready to award
the cleanup contract.
-------
-20-
All of the alternatives evaluated in detail were designed to
be protective of health, welfare and the environment. The EPA
therefore rejected the.highest cost alternatives — an on-site
RCRA disposal facility and upgraded containment. Although the
basic containment option was slightly less expensive than
excavation, EPA's evaluation concluded that the long-term risks
of containment and the long-term benefits of excavation justify
the small cost differences (4 percent) between containment and
excavation. The State, and EPA staff recommend the selection of
excavation and redisposal as the cost-effective remedy. Total
capital costs are expected to be $21,500,000, which includes a 20
percent construction contingency.
------- |