, MOC UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
D ATE: 9 MAY 1985
SFUND RECORDS CTR
subject: Record of Decision for a Remedial Action 1940-00076
for the Jibboom Junkyard Superfund Site
from: Harry Seraydarian
Director, Toxics and Waste Management Division (T-1)
TO: Judith E. Ayres
Regional Administrator (RA)
A Record of Decision to select a remedial action (RA) for
the Jibboom Junkyard site is attached for your signature. Also
attached are briefing documents describing the selection process
and the basis for our determination that excavation and offsite.
disposal is the most cost-effective remedial alternative for the
site.
As you know, EPA Headquarters recently delegated the
authority to sign certain Records of Decision for remedial actions
from the Assistant Administrator for Solid Waste and Emergency
Response to the Regional Administrator. Upon your signature,
the U.S. Army Corps of Engineers will be given authorization to
begin design of the RA. We expect construction to begin within 4
months and to have the project completed by the end of the year.
Based on the Feasibility Study, I request that you sign the
Record of Decision selecting excavation and offsite disposal as
the cost-effective remedial action for the Jibboom Junkyard site.
I am available to discuss this matter in more detail if you have
any questions concerning the attached Record of Decision package.
Attachment
EPA Form 1320*6 (Rev. 3-76}
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Record of Decision
Remedial Alternative Selection
SITE; Jibboom Junkyard, Sacramento, California
DOCUMENTS REVIEWED
My decision is based primarily on the following documents
describing the analysis of cost-effectiveness of remedial
alternatives for the Jibboom Junkyard:
- Study entitled "Draft Feasibility Study, Jibboom Junkyard,
Sacramento, California," February, 1985.
- Summary of Remedial Alternative Selection.
- Community Relations Responsiveness Summary.
DESCRIPTION OF SELECTED REMEDY
- Excavation and removal of contaminated soils to a
RCRA-approved offsite. Class 1, hazardous waste 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
excavation and offsite disposal of contaminated soils at the
Jibboom Junkyard is a cost-effective remedy adequate to protect
public health, welfare, and the environment. The State of
California has been consulted and fully supports the approved
remedy.
I have also determined that this action is appropriate when
balanced against the availability of Trust Fund monies for use at
other sites. In addition, the offsite transport and secure
disposition of contaminated soils is more cost-effective than
other remedial actions, and is necessary to protect public health,
welfare and the environment.
8s~
Date
ator
U. S. EPA Region 9
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Record of Decision
Concurrence Page
Site: Jibboom Junkyard, Sacramento, California
The attached Record of Decision package for the Jibboom
Junkyard, Sacramento, California has been reviewed and I concur
with the contents.
« 9 HAY 1905
Date
Date
shM
/ Datfe
Karl R. Morthole
Regional Counsel
farry Seraydarian
Director, Toxics and Waste
Management Division
Q ¦
Frank M. Covingtc
Directorr Water Man^jement
Division
Date
(f.
flijL
David P. j|b^ekamp
Director, Air Management Division
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SUMMARY OF REMEDIAL ACTION SELECTION
JIBBOOM JUNKYARD
Sacramento, California
SITE LOCATION AND DESCRIPTION
The Jibboom Junkyard site is located in Sacramento,
California on the east bank of the Sacramento River (see Figure
1). The site is approximately 2000 feet downstream from the
confluence of the American and Sacramento Rivers. The nine
acre site is the former location of the Associated Metals
Company salvage yard. The majority of the site, 6.7 acres, is
now covered by Interstate 5 and the adjacent Jibboom Street.
The remaining portion of the site, 2.3 acres, is a relatively
flat open field, with one cluster of trees and no other surface
structures or other objects present.
The site lies within the 100 year floodplain of the
Sacramento River. However, a California Department of Water
Resources, Sacramento River Flood Control Project levee helps
to protect the site from potential flooding.
Situated in an industrial part of town, the site is
approximately 4,000 feet from Old Sacramento, a historic downtown
area, and approximately 6,000 feet from the State Capitol Building.
At the northern edge of the site is an abandoned Pacific Gas
and Electric Company (PG&E) steam electric power generating station
that was constructed in 1912. Several motels are located to the
north of the site along Jibboom Street. The closest of these motels
is 400 feet from the site. A water intake structure is located
400 feet northwest of the site and 100 feet west of the levee
bank of the Sacramento River. This intake supplies water to the
City of Sacramento Filtration Plant. This water filtration
plant provides water for up to 50 percent of the city's population,
approximately 145,000 people in downtown, western, and southern
Sacramento. The filtration plant itself is 550 feet east of the
uncovered portion of the site.
Four hundred feet south and east of the site is a heavily
industrialized area that has been in operation since the 1860' s.
Along the western edge of the site, on top of the levee, is a
heavily used bike path constructed in 1983 as part of the
Sacramento and American River Bikeway.
There are no homes in the vicinity of the site. The only
known residents in the area are members of a family who reside
in a motel at the northern edge of the site.
Groundwater beneath the site is used for industrial
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purposes only. There are no potable or agricultural uses.of
the groundwater in the area. The water is hydraulically connected
to the Sacramento River. The river serves as-a hydraulic
connection, and presumably a barrier, to the potable groundwater
that is on the western side of the Sacramento River. The
groundwater beneath the site rises to within five feet of the
ground surface for up to six months of the year. Flow direction
is presumed to fluctuate biannually according to the river stage.
Surface water over the covered portions of the site are
collected in ditches on both sides of the freeway. This water
is then pumped into the American River. Surface water from
the remaining areas of the site either percolates into the
ground or evaporates.
SITE HISTORY
The site is named for an unofficial landfill that was
operated between the 1930's and the early 1970's along Jibboom
Street to the north of the actual site. The nine acre site which
was ranked for the National Priorities List (NPL) is defined by
the boundaries of the operations at the now defunct Associated
Metals Company yard.
In 1863, Southern Pacific Transportation Company (SP) began
operations at a 200 acre yard approximately 400 feet southeast of
the site. This facility is a major locomotive overhaul facility
for SP, and has historically handled large amounts of solvents,
paints, sand blasting wastes (including wastes containing lead),
petroleum, oils, and lubricants. In response to regulatory agency
concern regarding the disposal of some of these materials, SP has
begun an extensive soil and groundwater monitoring program.
In 1912, PG&E constructed a steam electric power generating
station north of the site. The station consisted of the main power
generating building, three 12,000 barrel oil aboveground storage
tanks on concrete pads with retaining walls, and two 200 barrel
underground storage tanks. In 1957, PG&E ceased operations at
this plant. By 1967, the three aboveground storage tanks had been
dismantled and removed. The now historic PG&E building and the
two underground storage tanks remain in place.
Sometime prior to 1928, the City of Sacramento constructed
a water filtration plant 150 feet due east of where the site would
be located. This plant mixes treated water from the American and
Sacramento Rivers to supply all 290,000 residents of Sacramento.
A 1928 aerial photograph indicates that tfye Jibboom site was
still wooded. By 1946, the original Jibboom Street alignment had
been paved and the entire site had been cleared of trees. Disposal
activities at the site were not evident.
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In 1950 or 1951, the property south of the power plant was
purchased by the Associated Metals Company. The property was
used for a metal salvage operation from this time until 1965.
All grades of metal were salvaged, including railroad cars,
army tanks, batteries, and some transformers. Although no
inventories or records of operations at the yard are known to
exist, a former employee indicated that there was on-site disposal
of scrap metal as well as some direct discharge of transformer
oils to the ground. Transformers were not frequently scrapped.
This employee, who was the yard foreman, and historical aerial
photographs, have been the only sources of information regarding
releases of hazardous materials at the Associated Metals yard.
In 1965, the State of California Department of Transportation
purchased all of the Associated Metals Company property for
easement and construction of 1-5. No soils were removed, but
the site was graded during freeway construction. By 1967, Jibboom
Street was realigned to the present location.
Between 1981 and 1985, EPA and the State of California
Department of Health Services (DOHS) performed extensive on and
offsite surface and subsurface soil sampling. In 1984, DOHS
constructed a fence around the site. There have been no other
response or enforcement activities to date.
CURRENT SITE STATUS
Results of the seven EPA and DOHS sampling efforts indicates
that there is extensive lead, zinc, and copper contamination
onsite. Most of this contamination is limited to the top one
foot of soil, and no offsite contamination has been detected.
Subsurface contamination above background levels was only
detected at four locations. PCB's were detected in the top foot
of soil throughout the site, however, the levels detected did
not exceed the state or federal criteria for the definition of a
hazardous substance, 50 ppm PCB's.
Lead is a Resource Conservation and Recovery Act of 1976
(RCRA) Appendix VIII listed compound, hence its presence at any
concentration above background identifies the material as hazardous
According to the Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA) Section 101, any soil containing
lead at greater than background concentrations is also a CERCLA
hazardous substance. Lead zinc, and copper have all been detected
at concentrations greater than the California Assessment Manual
(CAM) criteria for the definition of a hazardous material, which
are, for total metal concentrations (Total Threshold Limit
Concentration, or TTLC) 1000 ppm, 5000 ppm, and 2500 ppm
respectively. Federal action levels or criteria do not exist
for zinc or copper.
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In the top foot of soil, total lead was found at
concentrations up to 13,600 ppm, total zinc at concentrations up
to 19,700 ppm, and total copper at concentrations up to 3450 ppm.
Of the four subsurface locations that were contaminated above
background or state action levels, two were contaminated to ten
feet, one was contaminated to six feet, and one was contaminated
to five feet. For these four locations, total lead was found at
concentrations up to 1,200 ppm (at five feet), total zinc at
concentrations up to 18,200 ppm (at five feet), and total copper
at concentrations up to 6310 ppm (at five feet).
In 1985, the DOHS conducted surface soil sampling to evaluate
the leachability of the metals in the soil. The state tested
surface soils where contamination was known to be greatest according
to the state's California Assessment Manual (CAM) Soluble Total
Limit Concentration (STLC) test. This test is used to determine
the leachability of a substance given worst case environmental
conditions. The criteria for defining a material as hazardous
when using this test is 5 ppm for lead, 250 ppm for zinc, and 25
ppm for copper. [A comparable, but not identical, federal test
is the RCRA Extraction Procedure (EP) Toxicity test, by which a
material is defined as a RCRA hazardous waste if lead leaches at
greater than 5 ppm. RCRA EP Toxicity criteria do not exist for
zinc or copper.3 Test results indicated that lead was leaching
at concentrations of up to 164 ppm, which is 32 times the state
and federal criteria. Zinc and copper, which leached at
concentrations of up to 356 ppm and 65 ppm respectively, also
exceeded the state criteria for identifying a hazardous material.
Data from the Endangerment Assessment chapter of the
Feasiblity Study showed that direct contact with contaminated
soils at this site could be a health hazard. This is the
only known potential health threat posed by the site. Using
conservative ingestion rate and risk models, and assuming
residential use of the site, increased cancer risks of between
1 x 10~5 an(j i x io~3 from the ingestion of PCB contaminated
soil could be expected. It should be noted that these
potentially unacceptable health risks are associated with PCB
concentrations in soil which are below federal or state criteria
for defining a hazardous substance. Using the same soil ingestion
rate models results in exceedance of the federal Acceptable
Daily Intake for lead, which is 0.1 mg/day. While lead is not a
carcinogen, its consumption by young children has been linked
to neurobiological defects, such as learning disabilities and
behavioral problems. As exposure levels increase, reproductive
effects, such as stillbirths, occur and severe, often irreversible
damage develops in the blood forming system, the nervous system,
the heart and blood vessels, kidney, and liver.
At the present time, a fence restricts site access. However,
this fence is often in disrepair due to vandalism. In the past,
truck drivers have used the open area to the north of the site
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At the present time, a fence restricts site access. However,
this fence is often in disrepair due to vandalism. In the past,
truck drivers have used the open area to the north of the site
for parking. Trucks are often parked along side of the fence,
in areas where the greatest damage appears to be located.
Transients have historically used the PG&E building for refuge
and continue to do so. These transients are subject to exposure
to the contamination at the site. Should the EPA choose
no action for this site, a large number of people, including
the motel's residents, motel guests, bicylists who use the levee,
and the aforementioned truck drivers and transients, would be at
risk of direct contact with soils contaminated with unsafe levels
of lead and PCB's.
Because this site is one of the last remaining parcels of
undeveloped land along the Sacramento River, it is likely that
the site would continue to receive active use by the public under
the no action scenario.
ENFORCEMENT
All of the contamination at this site appears to be the
result of activities by the Associated Metals Company. The
company is now defunct and all of its principals have deceased.
California Secretary of State records indicate that neither
Associated Metals Company nor Associated Iron and Metals, the
only known alias of Associated Metals Company, were ever
incorporated in the State of California. There are no known or
suspected potential responsible parties at this site.
While the State of California and the City of Sacramento
currently own all of the land at the site, they were not owners
or operators of the site at the time of disposal. Therefore,
according to CERCLA Section 104(c)(3), the state is only liable
for 10% of the remedial action costs. It is recommended that
Trust Fund monies be used to fund the other 90% of the remedial
action costs.
ALTERNATIVES EVALUATION
Off-site migration of contaminants is not known to be
occurring, therefore, all of the alternatives evaluated for this
site are defined as source control measures.
Two objectives were developed for the remedial actions under
consideration at this site. In order to protect human health,
limiting potential exposure to soils contaminated with lead
above 500 mg/kg was the initial objective. This action level
is consistent with cleanup objectives at other federal and
state Superfund sites involving soils contaminated with lead.
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By cleaning up all contaminated soils above 500 ppm lead, potential
exposure to all known PCB contamination would also be eliminated.
This action level, which was developed for the Feasibilty Study,
is not in compliance with RCRA closure requirements for landfills
and surface impoundments. Final closure of landfills and surface
impoundments, requires cleanup of lead, a RCRA Appendix VIII
listed compound, to background levels. Because none of the five
exceptions for selecting a remedial action which is not in compliance
with all applicable federal laws exists at this site, as specified
in the Proposed National Oil and Hazardous Substances Pollution
Contigency Plan of February 12, 1985 (Proposed NCP) 40 CFR Part
300.68 (i), a cleanup objective of controlling exposure to lead
at greater than 200 ppm, the background level, was developed for
this Record of Decision.
A secondary objective is to prevent any potential future
groundwater contamination. Although groundwater is not currently
used as a potable water supply, this objective is consistent
with RCRA landfill and surface impoundment closure requirements,
EPA's policy of protection for Class 2 groundwater as identified
in EPA's Ground Water Protection Strategy, with California
Administrative Code (CAC) Title 23, Subchapter 15 Discharges of
Wastes to Land requirements, and with the State of California
Regional Water Quality Control Board (RWQCB) concerns.
In order to meet these two cleanup objectives, the following
general response actions were developed and evaluated:
° No action
° Containment—capping or encapsulation
° Removal—excavate contaminated soils and dispose of at a
RCRA approved offsite Class 1 hazardous waste facility
° Onsite Treatment—incineration, solidification, biological
treatment, and chemical treatment
° Offsite treatment—incineration, biological treatment, and
chemical treatment
° In situ treatment—soil flushing and neutralization
° Restrict site access and future land use without treatment
or remova1
Three levels of screening were performed on the remedial
action alternatives. First, an initial technology screening
was performed to eliminate inapplicable, infeasible, or
unreliable technologies. Next, an initial alternative screening,
according to the National Oil and Hazardous Substances Contigency
Plan of July 16, 1982 (NCP) 40 CFR Part 300.68(h) was performed.
Finally, a detailed alternative evaluation, according to the NCP
40 CFR Part 300.68(i) was performed.
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INITIAL TECHNOLOGY SCREENING
The general response actions were screened on the basis of
engineering judgment and qualitative comparisons. This screening
was performed to eliminate inapplicable, infeasible, or unreliable
technologies.
All of the remedial technologies associated with treatment
were eliminated. This included onsite treatment, offsite treatment,
and in situ treatment.
"Incineration, Biological Treatment, and Chemical Treatment—
Incineration, biological treatment, and chemical treatment are
technologies which could be implemented onsite or offsite. None
of these three treatment technologies are feasible when dealing
with soils contaminated with heavy metals. Heavy metals are
only moderately reduced during incineration, and volume reduction
would be relatively low. Biological treatment could result in
heavy metals uptake, but the resulting sludge would contain these
metals. Nutrient and substrate provisions would be very difficult.
Chemical treatment for metals removal in soils has not been demon-
strated to be technically or economically feasible.
"Solidification-Solidification would not isolate contaminants
from the environment or direct contact unless combined with
containment. This would effectively be the same as capping or
encapsulation with the added cost of solidifying the waste,
therefore, it was eliminated from further consideration.
"In Situ Treatment—In situ soil flushing using water or
an acidic solution would be difficult to implement, would have
to be operated for an extended period of time, and would increase
the level of contaminants in lower soils and in the groundwater.
An extraction system would be needed to recover and treat
contaminated groundwater. Land use would be restricted during
operation of this technology. This alternative would be very
difficult and complex to implement and the possibility of
successful treatment without leaving contaminated groundwater
or contamination in lower soils is relatively small. Therefore,
soil flushing was eliminated from further consideration.
In situ treatment by neutralization would not meet the site
objectives unless combined with containment. This would effectively
be the same as capping or encapsulation with the added cost and
difficulty of neutralizing the waste; therefore, this treatment
technology was also eliminated from further consideration.
Upon completion of the initial technology screening, the
following alternatives remained:
° No action.
° Restrict site access and future land use.
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Cap areas where lead concentrations exceed 500 mg/kg
using clay, a flexible membrane, or asphaltic cover.
Control surface water as needed and revegetate capped
areas except for the asphalt cap.
Excavate soils where lead concentrations exceed 500 mg/kg
and dispose of soils at an EPA approved Class I facility.
° Encapsulate soils where lead concentrations exceed 500 mg/kg.
INITIAL ALTERNATIVE SCREENING
Before the remaining alternatives were developed in detail,
an initial alternative screening, according to the NCP, 40 CFR
Part 300.68(h), was conducted. Alternatives that posed a
significant adverse environmental impact, that did not adequately
protect the environment, public health or public welfare, were
not feasible, were not applicable, were not reliable, or that
cost significantly more than other alternatives without providing
significantly greater environmental or public health benefits
were eliminated.
At this time, alternatives were screened for application to
the eastern, 6.7 acre, portion of the site which is covered by
1-5 and Jibboom Street. Because of the high cost of performing
remedial actions under the covered portion of the site and the
minimal environmental and public health benefits that would be
realized, no alternatives were developed. All potential
alternatives would cost an order of magnitude greater than
those developed for the covered portion of the site. Historical
records and discussions with a previous foreman at the yard
indicated that mostly storage and little waste disposal occurred
in the eastern portion of the site. Furthermore, construction
details and discussions with the Engineer-in-Charge of contruction
of 1-5 and Jibboom Street indicated that soils from the Associated
Metals yard were not removed during roadway construction. These
road surfaces, with up to two inches of asphalt and concrete,
extensive drainage systems, vegetated side slopes, and regular
long term maintenance are effective caps for sites containing
inorganic wastes, such as are present at Jibboom. Also of
significance are the results of an ongoing groundwater monitoring
program at a nearby facility which indicates that because of
the river's influence on the water table, groundwater beneath
the freeway portion of the site is up to 3.5 feet lower than
beneath the western portion of the site. Therefore, groundwater
is unlikely to submerge any contaminants that might be present
at depth. In summary, the costs of performing remedial actions
far outweigh the minimal environmental and public health benefits
that could be achieved by performing any remedial actions.
Hence, per the NCP, 40 CFR Part 300.68(h), alternatives were
not developed for the covered portion of the site.
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The remaining alternatives were developed for application
to the uncovered 2.3 acre portion of the site and a partially
contaminated 0.4 acre parcel of land to the north of the site.
DOHS and RWQCB concur with the focused scope of response actions
for this site.
According to the Proposed NCP, 40 CFR Part 300.68(f),
alternatives must be developed which fall into five catagories.
These catagories, and the alternatives that are in each catagory,
are shown in Table 1. No alternative was developed which exceeds
applicable or relevant federal public health or environmental
standards since none could reasonably be developed.
The following alternatives were eliminated according to the
NCP, 40 CFR Part 300.68(h):
° No action—The no-action alternative would allow any type
of future use of the site, including residential, and would do
nothing to prevent site access. Therefore, direct contact
with contaminated soils by the public would remain a risk. As
described in the Endangerment Assessment chapter of the Feasibility
Study, such potential exposure is an unacceptable public health
risk. However, while this alternative does not meet the objectives
developed for this site, it was carried through the detailed
alternative evaluation as a baseline comparison.
° Restrict site access and future land use—While
implementation of this alternative could meet the immediate
public health objective for this site (reducing the potential
for direct contact with contaminated soils), it would do nothing
to protect groundwater. Furthermore, according to DOHS, which
installed and maintains the present fence, continuous maintenance
is a problem. The fence is often in disrepair. This may be due
to the historical usage of the site by transients and commercial
truckers. Sufficient data do not exist to estimate acute exposure
risks for site intruders. However, an analysis of chronic exposure
levels indicates that living on the site for as little as 10
percent of a lifetime may result in exposure exceeding recommended
levels. Protection of public health cannot be demonstrated by
implementation of this alternative; hence it was eliminated from
further consideration.
DETAILED ALTERNATIVE EVALUATION
The remaining alternatives were analyzed in detail according
to the NCP, 40 CFR Part 300.68(i). Alternatives were evaluated in
terms of cost, technical concerns, public health concerns, and
environmental impacts. The following discussions describe this
detailed analysis.
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Table 1
JIBBOOM JUNKYARD REMEDIAL ACTION ALTERNATIVES
ALTERNATIVES REQUIRED TO
BE DEVELOPED*
ALTERNATIVES DEVELOPED
CAPPING
REMOVAL
ENCAPSULATION
NO ACTION
1. Offsite disposal at a RCRA
approved facility
2. Fully compliant with all
applicable or relevant
standards, guidance, and
advisories
/
3. Exceeds all applicable or
relevant standards, guidance,
and advisories
4. Meets all CERCLA goals but is
not fully compliant
5. No action
* per proposed NCP 40 CFR Part 300.68 (f) of February 12, 1985 and Guidance
Document for Feasibility Studies Under CERCLA of February 1, 1985
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° Capping—Capping the site with clay, asphalt, and a flexible
membrane liner were all considered. For each of these sub-
alternatives, the site would be graded and runoff collector ditches
along the sides of the site would be constructed. For the asphalt
and membrane caps, various fill material would be placed between
site soils and the cap. Clean soil would be then placed on top of
the cap with each sub-alternative. The soil would be hydroseeded
to help establish vegetation.
Capping the site would cost between $299,000 and $385,000,
depending on the type of material used. While this alternative
would be effective in preventing direct contact with contaminated
soils, it relies on proper long-term operation and maintenance
(O&M) for continued protection. This alternative would prevent
further groundwater contamination from water percolating downwards
through the contaminated soil column, but it would do nothing
to prevent the water table from rising into the contaminated
soils from below. Hence, metals could still leach into the
groundwater and offsite migration of contaminants could occur.
Capping, therefore, only meets one of the site objectives.
Capping does not comply with relevant or applicable federal and
state laws (see CONSISTENCY WITH ENVIRONMENTAL LAWS section).
Capping is a proven and reliable technology which has
been used at many other hazardous waste sites. Construction
time is estimated to be three months. Potential health and
safety concerns related to construction activities could be
addressed by implementation of proper construction practices
and stringent health and safety requirements.
° Excavation and offsite disposal—Soils with lead
concentrations above 200 mg/kg would be excavated and disposed
of offsite at a RCRA approved Class 1 hazardous waste facility.
The site would then be sampled to determine if more excavation
was required. The site would then be graded to existing
conditions with clean soil. This soil would be hydroseeded to
establish vegetation.
Excavating the contaminants for disposal at a RCRA approved
Class 1 hazardous waste disposal facility would cost $1,460,000.
A disposal facility in Benicia, California that is acceptable to
the EPA Region 9 RCRA/CERCLA Workgroup has been chosen as the
waste disposal site. Implementation of this alternative would
provide permanent, reliable, protection of public health and
groundwater with no reliance on proper O&M. This alternative
meets both site objectives and complies with all relevant and
applicable federal and state laws (see CONSISTENCY WITH
ENVIRONMENTAL LAWS section).
Excavation and offsite removal is a proven and reliable
technology which has been used at many other hazardous waste
sites. Construction time is estimated to be two months with
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no major on-site safety concerns that could not be addressed
by proper contruction practices. Application of stringent
health and safety requirements would help prevent potential
health risks during offsite transportation of the contaminated
soils.
° Encapsulation—Encapsulation would require that all
contaminated soils be excavated and stockpiled elsewhere on site.
Clean fill would be placed in the ground and graded to create
a uniformly sloping cell with the bottom at the current ground
surface. A double liner of clay and a flexible membrane and a
leachate collection system would be placed on the exposed ground
surface, the contaminated soil would then be placed on top of the
leachate collection system. Another flexible membrane liner would
be placed over the soil and would be completely sealed with the
bottom liner. A gas vent system would be incorporated with the
top liner. Clean soil would be placed over the top of the cell
and hydroseeded to establish vegetation.
Encapsulation of contaminated soils would cost $1,200,000.
Encapsulation would prevent all potential exposure to
contaminants at the site and would help prevent potential
groundwater contamination. Like capping, however, this
alternative relies on proper long-term O&M to ensure its
effectiveness. O&M could be difficult to perform since half
the cap would be buried under the contaminants. The useful
life of this alternative is approximately 30 years, at which
time the entire encapsulation system would have to be replaced.
The cost of replacing the flexible membrane liner is not included
in the cost of this alternative since the operable unit is likely
to last somewhat longer than thirty years due to the lack of
highly acidic or basic fluids at the site. This alternative would
meet both of the site specific objectives and would comply with
all relevant or applicable federal and state laws (see CONSISTENCY
WITH ENVIRONMENTAL LAWS section).
Encapsulation is a proven and reliable technology which has
been used at many other hazardous waste sites. Construction,
which would take approximately four months, would be the
most difficult for this alternative. Safety and health
concerns are greatest with this alternative since contaminated
material would have to be excavated, stored on site, then
replaced into the on-site containment cell. These potential
health and safety concerns could be addressed by implementation
of proper construction practices and stringent health and
safety requirements.
° No action—There are no costs associated with the no
action alternative. However, this alternative would not prevent
direct contact with contaminants nor would it prevent potential
groundwater contamination. This alternative, which does not
meet either of the site specific objectives, is not in compliance
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with applicable federal and state laws (see CONSISTENCY WITH
ENVIRONMENTAL LAWS section).
Table 2 summarizes the technical, environmental, public
health, O&M, and cost concerns for these four remaining
alternatives.
COMMUNITY RELATIONS
There has been relatively little community concern with this
site. Of the fourteen comments received on the Draft Feasibility
Study, eight were from state or local agencies, four were from or
for private developers, one was from a company which owns land
adjacent to the site, and one was from a citzens" action group.
Ten of the comments expressed a preferance for excavation and
offsite disposal of the contaminants, two commentors did not
express an opinion on any of the alternatives, one commentor
suggested another alternative, and one commentor expressed a
preference for no action.
There is no residential property in the vicinity of the site.
The only people known to reside near the site inhabit an adjacent
motel and have expressed satisfaction with regulatory agency
responses to date.
CONSISTENCY WITH ENVIRONMENTAL LAWS
Although operations at this site ceased prior to
November 19, 1980, site conditions are such that the Resource
Conservation and Recovery Act of 1976 (RCRA) is a relevant
regulation. Specifically, RCRA Subtitle C, 40 CFR Part
264 and 265 contain closure requirements for landfills and
surface impoundments, as well as groundwater monitoring
requirements that would apply to this site except for the legal
technicality of the trigger date identified in RCRA Subtitle C,
Section 3005(e). Under RCRA, the site could not be left in its
current state without some form of remedial action. In order
to comply fully with all relevant or applicable portions of
RCRA, immobilization of the contaminants must be assured: any
offsite migration of contaminants would be unacceptable. Only
encapsulation or offsite removal can assure that contaminants
will not migrate offsite. Neither capping nor no action can
prevent groundwater from rising into the contaminated zone and
leaching the metals into the groundwater: capping and no action
do not fully comply with RCRA.
RCRA Part 264 and 265 would also apply to encapsulation
since any onsite redisposal of contaminants would require
compliance with the double-liner requirements for new landfill
cells. The encapsulation alternative has been designed to be
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Table 2
SUMMARY DP EVALUATION Or RfMEOIAL ALTDtNATIVXS
Alternative/Total Coat
0(M
Requirements
Public Health Concerns
Bivlronaental Concerns
Technical Concerns
1A Capping with flexible $350,000
aeabrsne
IB Capping with clay $299,000
IC Capping with asphalt $385,000
Perpetual
Useful lit*
of 1A is 30
years, IB
is IS years
Ellalnates direct contact with
contaalnated soils.
Potential (or exposure during
construction.
Continued potential (or groundwater contamina-
tion (roa the water table rising Into the
eontaalnants. Restricts (uture land us* sod
would potential ljr reduce nearby property
values.
Short-ten construct loo-related adverse
iepacts would include teaporary loss o(
vegetation (wlldlKe habitat), loss o(
wildlife (peraanent (or asphalt cspt, air
pollution, noise pollution, congestion, and
temporary disruption o( businesses. Many of
these Impacts could be aitlgated using proper
construction aetbods.
Proven technology
Belies en hilv*« long
tam OH for acntia-
aad ettectivemes.
1 Reaoval and disposal to $1,460,000
BP area
Hone
Ellalnates direct contact witb
contaalnated soils.
Poteottal (or exposure during
construction.
No restriction on (uture land use.
Short-tara construction-related adverse
lapacts would Include teaporary loss o(
vegetation (wlldlKe habitat), and loss o(
wlldlKe. Potential adverse lsvacts of air
pollution, noise pollutioa, congestion, and
teaporary disruption of businesses could also
occur In offslte areas as oontaalnants are
being transported to the disposal alt*. Many
o( these lapacts could be aitlgated using
proper construction activities.
hmo technology
3 Encapsulation
$1/200,000
Perpetual
Most diff.
to perform
proper O+M
Oaeful Ufa
is 30 years.
Ellalnates direct contact with
contealnated soils.
Fotentlsl (or exposure during
construction.
Restricts (uture lend use and would
potentially reduce nearby property values.
Short-tara construction-related advara* lapacts
would Include teaporary loss of vegetation
(wlldlKe habitat), loss of wlldlKe (peraa-
nent (or asphalt cap), air pollution, noise
pollution, congestion, and teaporary disruption
of businesses. Many of these lapacts oould be
aitigsted using proper construction Methods.
Proven technology
Relies on piL\jer long
tain O+M tor oencia-
ued effectiveness.
Itoet difficult and
imylanr to casuun.
< Mo action
Hone
Continued potential for direct
contact with contaalnated soils
onstt*.
Does not reduce potential (or future algratlon
of eontaalnants to groundwater, surface water,
or released to the air.
*Total costs Include present worth of OtM costs based on a 30-year period.
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-13-
compliant with these RCRA requirements.
The groundwater under the site is considered Class II
groundwater under the EPA Ground Water Protection Strategy (GWPS).
Such a classification indicates that the water is a current or
potential source of drinking water or has other beneficial uses.
The water beneath this site is not currently a potable water source,
yet it is being used for industrial purposes. According to the
GWPS, the goal of remedial actions for this site should be to
maintain drinking water quality or background levels. The capping
alternative, which prevents surface water from percolating
down through the contaminated soils into the groundwater, does
nothing to prevent groundwater from rising up into areas with
contaminated soils. The capping and no action alternatives do
not, therefore, comply with the GWPS. The encapsulating and
removal alternatives, which eliminate the potential for
contaminants to migrate into the groundwater, are fully
compliant with the GWPS.
Any applicable Occupational Safety and Health Administration
requirements will be addressed during the detailed design phase of
the selected alternative. Department of Transportation Hazardous
Material Transport Rules will be complied with during the offsite
transportation of hazardous materials for the removal alternative.
The Toxic Substances Control Act of 1976 (TSCA) would not
apply to this site since PCB's are not present at concentrations
greater the 50 ppm, the concentration at which a substance is
defined as a hazardous material and at which TSCA regulations
begin to apply.
No other relevant or applicable federal laws, regulations,
requirements, advisories, or guidances are known that might pertain
to the remedial actions which were evaluated for this site.
The primary state laws which apply to this site are Title 22
and Title 23 of the California Administrative Code (CAC). Title 22
contains the California Assessment Manual criteria for defining a
hazardous material (see CURRENT SITE STATUS). Regulations
regarding the storage, treatment, transportation, and handling of
hazardous material are also contained in this portion of the CAC.
The recently adopted Chapter 3, Subchapter 15 of CAC Title 23
is applicable to this site. Subchapter 15 specifies minimum
standards for siting and management of landfills and waste piles.
Although variances can be obtained, wastes at sites like Jibboom
must be seperated from the uppermost aquifer by a minimum of 20
feet of clay permeable to less than 10~7 cm/sec. At the discretion
of the state, groundwater monitoring may also be required. Removal
and encapsulation fully comply with these regulations. Variances
would be required if capping or no action were chosen. However,
DOHS and RWQCB have indicated that a variance would probably not
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-14-
be available for this site given the leachability of the
contaminants and the depth to groundwater.
According to the Proposed NCP, 40 CFR Part 300.68 (i)f
remedial actions must comply with all relevant and applicable
federal laws and regulations unless one of five exceptions
apply. None of those five exceptions apply to this site.
This guidance also specifies that state standards shall be
used in determining the appropriate remedial action.
RECOMMENDED ALTERNATIVE
The recommended alternative is excavation and offsite
disposal at a RCRA approved Class 1 hazardous waste disposal
facility for all soils contaminated with lead above 200 ppm.
This action will address all public health concerns by eliminating
the potential for direct contact with soils contaminated by
lead and PCB's. No other contaminants are known to exist at
the site in levels which may present a threat to human health.
Removal will ensure protection of groundwater by removing
those contaminants that could potentially migrate into the
groundwater. This alternative complies with all relevant or
applicable federal and state laws, standards, and guidance.
Excavation and offsite removal is consistent with the cost-
effectiveness requirement of the NCP, 40 CFR Part 300.68(j).
Unlike capping, removal will ensure protection of the environment.
Sampling in March 1985 showed that copper, lead, and zinc are
leachable at up to 33 times the federal and state criteria for
defining a hazardous waste. Therefore, capping and no action,
which permit groundwater to come into contact with the deepest
contaminants at the site, may not provide adequate protection
of groundwater beneath the site.
Encapsulation also complies with all applicable or relevant
laws, and can provide a degree of protection equal to removal.
Encapsulation costs slightly more than removal. However, because
the cost estimates developed for the Record of Decision are
order of magnitude estimates and have an accuracy of +50, -30
percent, the removal and encapsulation alternatives should be
compared as if the cost of implementation were equal. Because
of several drawbacks with the encapsulation alternative, as
explained below, excavation and offsite disposal is the
recommended alternative.
Encapsulation relies on proper O&M to provide continued
human health and environmental protection. The contaminants of
concern present at this site, lead and PCB's, are very stable
and are unlikely to break down for long periods of time. These
contaminants are likely to remain at the site long after the
required 30 years of O&M is over. Burrowing rodents, extensive
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-15-
site use, and natural degradation are all factors that can
reasonably be anticipated to contribute to top or bottom liner
failure once required O&M is completed.
Complete replacement of the encapsulation alternative will be
required every 30 years, the projected useful life of the flexible
membrane materials. This replacement is unlikely to occur after
the required 30 years of O&M is over and, as described above, the
site is likely to still present a threat to human health and
the environment.
Most commentors consider encapsulation (as well as capping
and no action) unacceptable. There is a great deal of interest in
developing the site and there is a very high probability that such
development will require soil borings and construction into
subsurface soils. Any development would therefore require the
capping or encapsulation alternatives to be completely dismantled.
If development were to proceed, contaminated soils would require
offsite disposal, or construction of another on site encapsulation
cell, space permitting. If EPA choose encapsulation, and onsite
development were to occur, redundant remedial actions would
be performed.
Encapsulation is also the most difficult alternative to
implement. There are not many qualified contractors with
experience in installing flexible membranes, as would be required
for the top and bottom liners. The leachate collection system,
the gas vent system, and the completely enclosed nature of this
encapsulation unit are all aspects of this technology which make
this alternative very complex and difficult to install correctly.
Because of the considerations described above, removal,
which effectively costs the same as encapsulation to implement,
is determined to be the cost-effective remedy for this site.
OPERATION AND MAINTENANCE (O&M)
There are no O&M requirements for the recommended alternative
O&M activities for the other alternatives consists of surface vege
tation maintenance to prevent erosion and repair of the cap if
erosion occurs. The asphalt cap would not be vegetated, yet it
would have to be checked for cracks and would require a major
overlay approximately every 15 years. The flexible membrane cap
and the encapsulation with flexible membrane alternatives have
useful lives of approximimately 30 years. At that time the
entire cap system will require replacement. The capping
alternatives may require installation of a fence and monitoring
wells.
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-16-
SCHEDULE
° Approve Remedial Action (sign ROD)
° Enter Interagency Agreement with
Corps of Engineers for Remedial Design
° Award State Superfund Contract for
Remedial Design and Remedial Construction
° Enter Interagency Agreement with
Corps of Engineers for Remedial Action
° Complete Remedial Design
° Start Remedial Action Construction
° Complete Remedial Action Construction
° Delete Site from National Priorities List
May 9, 1985
May 9, 1985
June 21, 1985
June 21, 1985
August 6, 1985
October 1, 1985
December 3, 198 5
June 3, 1986
FUTURE ACTIONS
Once this Record of Decision is signed, EPA will enter into
an Interagency Agreement with the Corps of Engineers for design
of the selected remedial action. Negotiations with the state
will then begin on the State Superfund Contract. Prior to the
completion of the design of the selected remedial action/ at the
time when an accurate cost estimate is available, EPA will
enter into an Interagency Agreement with the Corps of Engineers
for construction of the remedial action. Construction is
expected to take approximately two months. Within six months
of the completion of construction activities, the site is
expected to be deleted from the National Priorities List.
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COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
JIBBOOM JUNKYARD
Sacramento, California
INTRODUCTION
The purpose of this responsiveness summary is to document
the following items for the public record: (1) the concerns
and issues raised by private citizens and governmental agen-
cies during the remedial planning process, (2) comments
raised and questions asked during the comment period on the
feasibility study, and (3) the response of EPA to these com-
ments and concerns.
COMMUNITY RELATIONS ACTIVITIES
The following community relations activities were undertaken
to inform interested parties of the feasibility study pro-
cess and solicit their comments:
April 1984: Interviews were conducted with local and
state agencies, elected officials, an adjacent property
owner, and former employees of the metal salvaging
operation previously on the site. The purpose of the
interviews was to identify the concerns of interested
parties for use in preparing the community relations
plan.
June 1984 to February 1985: During the preparation of
the Feasibility Study, contact was maintained with the
Department of Health and Services (DOHS) and with the
Regional Water Quality Control Board (RWQCB). Remedial
action alternatives and water quality issues were
discussed.
January 24, 1985: Letters were sent to interested par-
ties, notifying them of the upcoming availability of
the Feasibility Study, the public comment period, and
the two locations where copies of the Feasibility Study
would be available for review.
January 31, 1985: A public notice was placed in the
Sacramento Bee announcing the upcoming availability of
the Feasibility Study, the public comment period, and
the two locations where the Feasibility Study could be
reviewed.
February 13, 1985: An executive summary of the Feasi-
bility Study was sent to interested parties summarizing
the major findings in the report.
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-2-
February 14, 1985, to March 7, 1985: Public comment
period on the Draft Feasibility Study. Fourteen
comment letters or phone calls were received regarding
the feasibility study.
March 8 to March 13, 1985: Phone calls were initiated
by EPA to individuals and agencies that were expected
to be interested in the Feasibility Study but from whom
EPA had not yet received comments.
A public meeting to discuss the Feasibility Study was not
held because during the interviews in April 1984 the level
of interest in the site was found to be relatively low.
Other community relations techniques were judged to be more
appropriate in disseminating information and soliciting
comments.
CONCERNS RAISED PRIOR TO THE
FEASIBILITY STUDY COMMENT PERIOD
The comments and concerns received prior to the feasibility
study comment period consisted of those raised during the
interviews held in April 1984. These are summarized below.
WATER QUALITY
Comment: Several interviewees were concerned about current
or potential contamination of the groundwater under the site
or contamination of the Sacramento River adjacent to the
site. This was of particular concern because a Sacramento
city water intake is located near the site.
Response: EPA and the state have concluded that past
groundwater contamination, the subsequent contamination of
the Sacramento River, and the City potable water supply were
unlikely because:
o The soil column below 5 feet is relatively free of
contaminants, indicating groundwater contamination
to date is unlikely to have occurred.
o The large amount of flushing (from river water) in
the area, combined with low levels of subsurface
soils contamination, reduces the possibility that
significant groundwater contamination has occurred
in the past or that contaminants are still present
in the groundwater.
o Many other industrial locations in the area are
potential contributors to groundwater pollution,
which would make it difficult to attribute exist-
ing contamination to the site.
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-3-
o Groundwater testing by a nearby facility shows
that there has been no significant contamination
by copper, lead, or zinc, the contaminants of con-
cern at the Jibbooro site.
o The City of Sacramento water filtration plant reg-
ularly tests its water and has not found any ele-
vated metals concentrations in the water taken
from the Sacramento River.
o EPA will consider the potential impact of any
remedial action on the groundwater and surface
water in the area,
FUTURE DEVELOPMENT
Comment: Several people were also concerned about whether
the site would be suitable for future development. They
considered the site to be valuable for private development
because it is highly visible, is accessible, is near the
Sacramento historic district, and is located on the water-
front. There are several development proposals for the
site, and some of the interviewees were concerned that reme-
dial action at the site might preclude future development.
Response: The Feasibility Study addressed these concerns by
assessing the effects of each remedial action alternative on
the development potential of the site. Alternative 2 (exca-
vation and offsite disposal of contaminated soils) was found
to be the only alternative that would not limit future
development of the site, and EPA has recommended this alter-
native as the final remedial action alternative.
JUSTIFICATION FOR REMEDIAL ACTION
Comment: Some people felt the site does not present a great
enough hazard to justify the time and money being spent on
it and that these resources could better be spent on other
environmental problems considered to be more serious.
Response: This issue was also raised during the comment
period for the feasibility study. Measured values of con-
taminants onsite show that the site poses a potential public
health threat. Therefore, there is a justification for con-
sidering a remedial action at the site.
CONCERNS RAISED DURING THE COMMENT PERIOD
AND EPA RESPONSES
The comment period on the Draft Feasibility S,tudy began Feb-
ruary 14, 1985, and ended March 7, 1985, Fourteen people or
agencies made comments; a list of those who commented is
attached.
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-4-
The comments made are summarized below; copies of the com-
ment letters and phone conversation records are attached.
The comments received are categorized below by subject and
followed by a response. Ten of the people or agencies who
commented made only one comment, which was that they pre-
ferred the excavation and offsite removal alternative.
Three people commented on water quality issues, and three
people commented on issues related to soil contamination.
One commentor suggested another remedial action alternative.
COMMENTS CONCERNING THE SELECTED REMEDIAL ACTION ALTERNATIVE
1. Comment/Question: Ten commentors supported the recom-
mended alternative: Excavation and removal. This is
the only alternative that would prevent migration of
contaminants from the site, protect public health,
allow future development of the property, and preserve
adjacent property values.
Response: EPA is recommending Alternative 2, excava-
tion and removal offsite, for the final remedial action
at the site.
2. Comment/Question; One commentor suggested that com-
mercial development on the site be allowed in the
future under the condition that the developer cover the
site with a concrete base, foundation, building, or
parking lot. This would serve the same function that a
cap would, and it would be less expensive than the exca-
vation and removal or the capping alternative. If there
is no immediate interest in developing the site, the
site could be paved or otherwise prepared for future
development with a surface that would serve as a cap in
the short term and a surface over which development
could occur in the future.
Response: There is no way for EPA to evaluate poten-
tial future development at the site without a descrip-
tion of the alternative and associated costs. If a
developer were to make a proposal with the necessary
information, then the alternative could be evaluated.
Furthermore, a cap does not address potential submer-
sion of highly leachable contaminants from groundwater
rising through near-surface levels.
COMMENTS CONCERNING WATER QUALITY
3. Comment/Question; The selected remedial action should
ensure that any surface water drainage from the site
does not flow toward 1-5. This is a concern because of
the possibility for surface water infiltration through
-------
-5-
buried contaminated soil under the freeway embankment
and frontage road.
Response: EPA agrees. Stormwater controls will be
identified during the design of the remedial action.
The recommended alternative (excavation and removal) as
well as the other two alternatives (capping and encapsu-
lation) would include measures to divert stormwater
runoff to the Sacramento River rather than inland toward
the freeway.
4. Comment/Question: If the contaminated soil on the 2.3
acres is not removed, protection against any lateral
migration of contaminants toward the freeway should be
addressed.
Response: EPA agrees. The excavation and removal
alternative will address this concern. In addition
encapsulation would also prevent potential lateral
migration of contaminants. This would be accomplished
by complete isolation of contaminants from the sur-
rounding environment including any water that could
serve as the transport mechanism for lateral migration.
Capping and no action will not protect against lateral
migration of groundwater contamination. This has been
considered in our determination of the recommended
alternative.
5. Comment/Question; Soluble Threshold Limit Concentra-
tions (STLC) measurements are needed to determine the
threat to groundwater from the observed soil contamina-
tion. Such sampling could be concentrated in locations
where Total Threshold Limit Concentrations (TTLC's)
exceed California Assessment Manual (CAM) levels, pri-
marily in Area 2.
Response: EPA agrees. Soil samples were taken at the
site in February 1985 and analyzed for STLC values in
March 1985.
COMMENTS CONCERNING SOIL CONTAMINATION
6. Comment/Question; Background soil samples should be
taken at another location that is on the same side of
the freeway and a similar distance from the freeway as
the site. These samples might indicate if part of the
surface soil lead contamination could be caused by auto
emissions or if other inherent "background" conditions
exist near the site.
Response: Surface and subsurface soil samples were
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-6-
taken on the east side of the freeway (same side as the
site) , an equal distance front the freeway as the site.
These are surface soil samples No. 1 through No. 5,
collected in April, 1983, and subsurface soil samples
No. 42 through No. 51, collected in June, 1983. These
samples show metals concentrations similar to those
found on both sides of the levee, which are considered
to represent true background values. Hence, elevated
metals concentrations at the site, including the sur-
face lead concentrations, appear to be caused by the
previous operations at the site, and not from vehicle
emissions.
7. Comment/Question: Were surface soil samples taken from
the areas between the frontage roads and the freeway
lanes on both sides of the freeway? If these soils are
contaminated, remedial action should be proposed to
protect motorists and engineering workers who might
come into contact with these soils.
Response: No, these areas were not sampled. The area
to the east of the freeway is outside of the fence that
demarked the extent of operations at Associated Metals
and is currently under clean fill and a vegetative cover.
The fill and vegetative cover have been installed as
part of the freeway and receive regular maintenance. A
review of historical information also indicates that
the area between the freeway and the frontage road to
the west of the freeway was mostly used for storage and
not for actual salvaging. Hence, soil contamination is
not expected to be significant. Portions of this area
were also covered with clean fill at the time of the
freeway and frontage road construction.
COMMENTS CONCERNING THE COVERED PORTION OF THE SITE
8. Comment/Question: The water table could rise and come
in contact with contaminated soil that is beneath the
freeway, the freeway embankments, and frontage roads.
It might therefore be necessary to monitor groundwater
quality in the area.
Response: See response to Comment No. 10.
9. Comment/Question; Why are no remedial action measures
being considered for contamination that might lie be-
neath the freeway?
Response; See response to Comment No. 10.
10. Comment/Question; It seems inconsistent, to discuss the
excavation and removal option for the 5.1-acre parcel
-------
-7-
wheri the material beneath Interstate 5 is accepted as
being sufficiently contained by the "cap" that the free-
way provides.
Response: Contamination under the freeway is unlikely
to be significant. EPA has reviewed historical docu-
mentation and found that most areas of the site which
are under the freeway and Jibboom Street were either
outside of the fenced area of Associated Metals, which
demarked the extent of disposal activities, or were
areas which were used only for storage of items await-
ing salvaging. Very little salvaging appears to have
been conducted in the covered portions of the site.
According to current engineering standards, the freeway
and frontage roads are satisfactory hazardous waste
caps. A review of construction details and discussions
with the engineer in charge of construction indicates
that all technical requirements of a cap for a hazard-
ous waste site containing inorganic contaminants have
been met. Up to 20 feet of clean fill was placed over
the ground surface, up to 2 inches of concrete and
asphalt were placed on top of the fill, the side slopes
were planted with vegetative cover for erosion control,
and drainage control ditches were installed which carry
all surface water offsite for ultimate discharge into
the American River. The road surfaces, vegetative cover,
and drainage control ditches all receive regular main-
tenance. The freeway and frontage road will, therefore
prevent direct contact with any potentially contaminated
soils and will prevent migration of any contaminants by
downward percolation of groundwater.
While the covered portions of the site are unlikely to
be extensively contaminated, and they are effectively
capped, EPA did consider additional remedial measures.
EPA performed analysis which showed that the costs of
performing any additional remedial work would be exhor-
bitant and the incremental benefits would be slight.
EPA concluded that additional remedial actions for the
covered portions of the site were unnecessary and that
the cost and difficulty of performing such actions
would far outweigh any potential benefits.
OTHER COMMENTS
11. Comment/Question: The concentrations of PCB in the
soil may not justify remedial action, and the cancer
risk estimates on pages 3-7 through 3-9 of the Feasi-
bility Study are overstated.
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-8-
Response: EPA agrees that the PCB concentrations may
not warrant remedial action. Remedial action at this
site is based entirely on concentrations of lead in the
soil.
PCB is currently classified category 2B by the Interna-
tional Agency for Research on Cancer, which means that
there is limited evidence that the chemical is a carcin-
ogen. The cancer potency from the EPA Carcinogen
Assessment Group (which is a 95 percent upper bound
estimate) is 4.34 kg-day/mg, which is the estimate that
was used in the Feasibility Study. The potential lower
bound risk associated with exposure to PCB's is zero.
The risk assessment approach used in the report is con-
sistent with the approach used at other CERCLA sites
and with the EPA carcingenicity guidelines (49 Federal
Register 46294). As noted in the guidelines, there are
major uncertainties in the extrapolations from animal
data to humans and from high dose to low dose. As has
been noted with other chemicals, different groups of
scientists can derive different cancer potencies for
the same chemical. These differences may occur because
of differences in assumptions and the type of analysis
performed on the animal data. The inherent uncertainty
in carcinogen risk estimation can lead to more than one
valid approach.
A relative risk perspective is provided by the approach
used for the Jibboom Junkyard assessment. Because a
consistent methodology is applied, the EPA can compare
the risks estimated to be associated with exposure
scenarios at this site to other CERCLA sites to assist
in making a remedial action decision for Jibboom. Further-
more, it is important to note that the remedial actions
proposed for Jibboom have been based, primarily, on the
lead concentrations in soil rather than the PCB concen-
trations. Complete removal of PCB's was an added benefit
of the lead cleanup objective.
12. Comment/Question; A representative of a community
group who was contacted by phone feels that the site
does not belong in the National Priorities List because
there is no significant contamination offsite. He feels
that the Aerojet site and the Sacramento city landfill
present more serious problems than the site.
Response: Data from the Endangerment Assessment chapter
of the Feasibility Study indicates that the site poses
a potential health threat via direct contact with con-
taminated soils. This site, therefore,,requires some
kind of response action. Many other sites may also
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-9-
require response actions. Currently, the Aerojet site,
which is on the National Priorities List, and the
Sacramento city landfill, are the focus of regulatory
agency concerns.
13. Comment/Question; The Reclamation Board of the Cali-
fornia Department of Water Resources requires that all
projects that might affect the structural or functional
integrity of the flood control levee adjacent to the
site be reviewed and approved by the Reclamation Board
before such projects are begun.
Response; Based on the conceptual design of the removal
alternative, it is not anticipated that removing con-
taminated soil from the site will affect the structural
or functional integrity of the levee. However, during
the design of the remedial action alternative, EPA will
contact the Reclamation Board to discuss the effect of
the recommended alternative on the levee.
EDITORIAL COMMENTS
The following changes should be made to the text of the fea-
sibility study.
14. The acreages of Areas 1 and 2 given on page 2-1 are
reversed.
15. The word "virtually" can be taken out of the following
statement on page 2-4: "These results show that vir-
tually all surface metals contamination exceeding CAM
TTLC levels is limited to Areas 1 and 2." No metal
concentrations exceeding TTLC levels were found in
Area 3.
REMAINING CONCERNS
There are no remaining concerns known with regard to the
recommended remedial action. Any concerns that do arise
will be addressed by continued community relations.
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-10-
LIST OF COMMENTORS
State Agencies
California Department of Transportation, March 5, 1985
California Regional Water Quality Control Board, March 3,
1985
California Department of Water Resources, March 7, 1985
California Department of General Services, March 7, 1985
California Department of Parks and Recreation, March 18,
1985
California Department of Health Services, April 9, 1985
City Departments
Sacramento Department of Planning and Development, March 14,
1985
Sacramento Department of Public Works, March 13, 1985
Others
Pacific Gas and Electric, March 11, 1985
Sacramento Toxic Coalition, March 8, 1985 (phone conversation)
Ives Corporation, March 13, 1985 (phone conversation)
Brown, Nolan and Nickerson, Attorneys at Law, March 7, 1985
George Hampton, March 7, 1985
Marcus Millichap Investment Real Estate Brokers, March 6,
1985
-------
STA7E OF CALIFORNIA-BUSINESS, TRANSPORTATION AND HOUSING AGENCY
GEORGE DEUKMEJIAN, Governor
DEPARTMENT OF TRANSPORTATION
OFFICE OF DIRECTOR
1120 N STREET
SACRAMENTO, CALIFORNIA 95814
{916)445-4495 —
March 5, 1985
Mr. Nick Morgan
EPA (T-4-3)
215 Fremont Street
San Francisco, CA 94105
Dear Mr. Morgan:
We have reviewed the U.S. Environmental Protection Agency's (EPA)
report entitled "Feasibility Study, Jibboom Junkyard, Sacramento,
California" and offer the following comments for your
con si derati on:
Area Adjacent to I-5/Frontage Road (2.3 Acres)
The cleanup action selected by EPA should ensure that any surface
drainage from the 2.3 acre contaminated site does not flow .
toward 1-5. This will reduce potential surface infiltration
through buried surface contaminated soil under the frontage road
and freeway embankment.
If the contaminated soil on the 2.3 acres is not removed,
protection against any lateral migration of contaminants toward
the freeway should be addressed.
The report is unclear as to whether surface soils in the areas
between the two frontage roads and the northbound and southbound
lanes were analyzed for contamination. If these soils are
contaminated, a remedial action should be proposed to protect both the
traveling public who may temporarily stop as well as highway workers who
may be in the area.
Area Buried Under 1-5 and Frontage Roads (6.3 Acres)
Essentially, the embankment and surface pavements provide for a
degree of groundwater protection by limiting vertical
infiltration. It obviously protects the public from contact with
the contaminated soil. Future land use is further restricted
because of the transportation system.
-------
y
Mr. Nick Morgan
Page 2 _
March 6, 1985
t
The water table could rise and come in contact with any
contaminated soil that is beneath the freeway embankment and
adjacent frontage roads. Therefore, it may be necessary for EPA
to monitor groundwater to verify groundwater quality.
Thank you for the opportunity to comment and for your keeping us
i nformed.
W. E. SCHAEFER
Deputy Director
Project Development
-------
RECORD OF
COMMUNICATION
0 PHONE CAUL QDISCUSSION Q FIELD TRIP (^CONFERENCE
~ OTHER (SPECIFY)
(Record of item checked above)
TO:
Charles McKinley
RWQCB
916-322-9094.
FROM:
Nick Morgan
EPA T-4-3
DATE
Mar 15, 1985
TIME
4:00 pm
SUBJECT
Monitoring Requirements at Jibboom *
SUMMARY OF COMMUNICATION
1. RWQCB will not require monitoring of gw under the freeway if we
implement any of the alternatives listed in the Draft FS.
2. RWQCB will probably not require gw monitoring of the 2.3 exposed
acres if we cap or encapsulate, but a final decision will not be
made on this matter until STLC results are reviewed.
3. GW monitoring is not being required under the freeway because
A. There is limited surface area for contaminants to percolate
through to the underlying water.
B. Most of the area is paved.
C. There are no potable uses of the gw in the area.
D. There are many other potential sources of contamination in
the area.
4. By EPA choosing removal for the final remedial action at this site,
we are effectively addressing the 2 concerns that the RWQCB raised in
thier comment letter of March 4, 1985.
5. RWQCB is satisfied with the removal alternative.
INFORMATION COPIES
TO:
EPA Form 13004 (7*72) "Eplicei era hq form »ioo-i which may be used until supply is exhausted.
-------
STATE OF CALIFORNIA
GEORGE DEUKMEJIAN. Governor
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD-
CENTRAL VALLEY REGION
3201 S STREET
SACRAMENTO. CALIFORNIA 95816-7090
PHONE: (916(445-0270 '
RECElv'-v
u.s. e;>;.
REGION 9
COMM. CDi'.t;
I
4 March 1985
£5 MAR-7 A1039
Mr. Nick Morgan
U.S. Environmental Protection Agency
Region 9 (T-4-3)
215 Fremont Street
San Francisco, CA 94105
FEASIBILITY STUDY, JIBBOOM JUNKYARD
I have reviewed the subject study and have the following comments regarding fur-
ther investigation at the site:
1. Soluble Threshold Limit Concentrations (STLC) measurements are needed to
determine the threat to ground water from the observed soil contamination,-
Such sampling could be concentrated in locations where TTLC's exceed CAM
levels, primarily in Area 2.
2. Background soil samples, taken on the same side of U.S. Highway 5 and a
similar distance from the freeway, may be helpful to indicate if part of
the surface lead source could be auto emissions, or if other inherent "back-
ground" conditions exist near the site.
The above information would assist in the evaluation of the threat to ground
water quality and aid in the selection of adequate remedial measures. If you
have any questions, please call me at (916) 322-9094.
Area Engineer
CBM:jec
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STATE OF CALIFORNIA-RESOURCES AGENCY
GEORGE OEUKMEJ1AN, Governor
DEPARTMENT OF WATER RESOURCES
THE RECLAMATION BOARD
1416 — 9»h S»i»«t, Room 455-6
Socrom»nto, CA 95814
(916) 445-9454
MAR 7 1985
"85 MAR-8 A11:10
f
Mr. Nick Morgan
U. S. Environmental Protection Agency
215 Fremont Street
San Francisco, CA 94105
Dear Mr. Morgan;
Staff for The Reclamation Board has been notified of the pro-
posed superfund project - draft feasibility study on the
Jibboom Junkyard Clean-up Project {SCH 84041617), and has the
following comments.
The Jibboom Junkyard is located adjacent to the Sacramento
River and the Sacramento River Flood Control Project levee
which in this location protects a large urban area includ-
ing downtown Sacramento.
The flood control project is under the Board's jurisdiction
and the Board requires that all plans for construction or
other modifications that may affect the structural or func-
tional integrity of the flood control project be reviewed
and approved by the Board before start of work. Staff will
be glad to assist you in evaluating the potential effects of
the clean-up project on the levee.
For additional information about the Board's standards and
regulations as well as its application procedures for Approval
of Plans, contact Mr. Ted Allen, Encroachment Control Section,
Department of Water Resources, 1416 Ninth Street, Room 455-8,
Sacramento, CA 95814, telephone (916) 445-9225.
Please include the Board on your mailing list for the Jibboom
Junkyard Clean-up Project.
General Manager
cc: Ms. Peggy Osborn
State Clearinghouse
1400 Tenth Street, Room 121
Sacramento, CA 95814
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STATE OF CALIFORNIA—STATE AND CONSUMER SERVICES AGENCY
GEORGE DEUKMEJIAN, Governor
DEPARTMENT OF GENERAL SERVICES
OFFICE OF REAL ESTATE SERVICES
650 Howe Avenue
Sacramento, CA 95825-4699
(916) 920-7576 —
March 7, 1985
Mr. Nick Morgan
EPA T-4-3
215 Fremont Street
San Francisco, CA 94105
Dear Mr. Morgan:
OLD SACRAMENTO PG&E STEAM PLANT
SSL-293
We have received and reviewed the Draft Feasibility Study for the Jibboom
Junkyard dated February 1985.
We are 1n favor of the Implementation of Alternative No. 2 to excavate and
dispose of the contaminated soils at an off-site land fill. The reasons we
are supportive of Alternative No. 2 are:
1. The site 1s a highly developable and valuable site.
2. The property 1s located near the City of Sacramento's water source.
3. The location 1s adjacent to a highly populated metropolitan downtown
area.
In our opinion, we feel capping the site would not be a solution that would
suffice 1n correcting the existing situation. We feel there is a definite
need to eliminate alf present, as well as future, contamination on this
property.
Considering the close proximity to the Sacramento water source, 1t 1s so
Important to the environment of the Sacramento community that the site not
be capped as 1t does not ensure against potential future water supply con-
tamination. In addition, capping the site will adversely affect the future
land use, diminish the property value and create tremendous problems 1n the
area.
Encapsulating the soils would cost nearly the same as removal, take twice as
much time to implement and could cause future problems as the contaminants
would still remain on the property even though encapsulated.
We do not see how capping will really eliminate the problem and, conse-
quently, we feel both capping and encapsulating are poor alternatives.
Your consideration and efforts In Implementing a complete removal of the
contaminants from the site are sincerely appreciated. If I can supply you
with additional supportive justification for Alternative No. 2, please feel
free to contact me or Paula McGranahan of my staff at the above address or
phone number.
Chief Land Agent
FRM:PPM:dt:A-l.45
-------
SlATE of CAllfORNIA—THE RESOURCES AGENCY
GEORGE DEUKMEJlAN, Governor
DEPARTMENT OF PARKS AND RECREATION
P.O. BOX 2390
SACRAMENTO M811
(916) 324-9067
MAR 1 81985
*85 19
Mr. Nick Morgan
EPA (T-4-3)
215 Fremont Street
San Francisco, CA 94105
Dear Mr. Morgan:
Our Department has reviewed the report entitled, "Draft Feasibility Study,
Jibboom Junkyard, Sacramento, California," which develops and evaluates
a number of remedial action alternatives for the cleanup of toxic wastes
on this site. As you know, most of this property is owned by our Department
and is part of Old Sacramento State Historic Park. Enclosed is a map of
our ownership for your information.
It is the opinion of this Department that Alternative 2, excavation and
removal of contaminated soils, is the most appropriate measure for cleanup.
It is further recommended that the Environmental Protection Agency take
action to accomplish the necessary work at the earliest possible time.
Our position is based upon what we feel is in the greatest ultimate public
interest. Access to and development of the Sacramento waterfront has been
increasing dramatically in recent years and is expected to continue.
The City of Sacramento has developed a public bike path on the levee
immediately adjacent to the site which is heavily used. In addition, this
area along the river is a very popular location for use by fishermen.
Public use has also been increasing due to recent nearby hotel developments
and new residential developments just to the north of tcwn. All of these
uses are expected to continue regardless of the future development of the
remainder of the site, which is -uncertain at this time. Development could
occur which may intensify the probability of public contact with contaminated
soils. Although groundwater contamination does not appear to be a major
concern at this time, the potential for harm to visitors to Old Sacramento
State Historic Park and to all inhabitants of this, the State Capitol,
is not worth taking the risk. We should use this opportunity to remove
as much of the contaminants as possible before build-out of this area
prohibits this opportunity in the future.
The reason I say future development is uncertain is because all of our
ownership north of the "I" Street Bridge has been declared surplus to our
need. This involves approximately 9 acres all together. Legislation was
passed in 1982 which authorizes the exchange or sale of the property
(Chapter 1266, Statutes of 1982). Our intent is to dispose of most of
-------
Mr. Nick Morgan
Page 2
the property through a public sale. An appraisal is currently being
prepared by the Department of General Services, Office of Real Estate
Services. They are proceeding under the assumption that the site will
be clear of toxic waste contamination. It is anticipated that they will
be in a position to receive bids on the property by early May. As you
can see, we would be very interested in learning of your specific schedule
as well as method of cleanup as soon as possible. Alternative 2 would
also be the most desirable for the purpose of disposing of the property
since it imposes the least amount of restrictions to future use.
Thank you for this opportunity to corrment on the study. The contact person
from our Department is Mr. Jim Quayle. He may be reached at (916) 445-9299
or at the address shewn above.
Sincerely,
Wn. ^S-r"T3riner
Director
Enclosure
-------
STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY
GEORGE DEUKMEJIAN, Governor
DEPARTMENT OF HEALTH SERVICES
714/744 P STREET
SACRAMENTO, CA 95814
(916) 324-2443
RECEiV >.
U.-5.
REGiO1: ¦
CQMK Ci>".
APR 0 9 1985 .g5 12 AH -05
»
Keith Takata
Chief, Superfund Programs Branch
U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, CA 94105
Dear Mr. Takata:
We have reviewed the draft feasibility study for the Jibboom Junkyard
located in Sacramento. Our comments are included herein. Overall the
study is thorough, covering the feasible alternatives.
The Department recommends and supports either one of the Number 2
alternatives - excavation and redisposal of the contaminated soil at
an approved hazardous waste landfill. All other agencies and
interested parties who have contacted the Department concerning the
site have recommended this alternative highly.
Based on the Department's interpretation of the results of the
sampling program, it may not be necessary to excavate as great a
quantity as indicated in your contractor's cost estimates. Further,
as you know the contaminated material may need to be taken to a double
lined landfill in accordance with recent EPA policy requirements.
Available facilities must be identified prior to the initiation of
cleanup.
Discussions have been held with the Central Valley Regional Hater
Quality Control Board concerning the installation of groundwater
monitoring wells. Since the sampling program has shewn that the
contaminated material is mostly all contained in the upper one foot of
soil neither the Department nor the Regional Water Quality Control
Board believe that monitoring wells will be necessary if the
excavation and removal alternative is chosen as the cleanup
alternative. Accordingly, we would not support the installation of
such wells.
Enclosed are the results of the additional testing of sanqples from the
Jibboom Junkyard site for the Soluble Threshold Limit Concentrations
(STLC) for lead, copper, and zinc. The concentrations exceed the
levels which are considered hazardous by the Department.
-------
Keith Takata
-2-
A£#? 0-9 m
We are available to assist you where possible in the initiation of
an expeditious cleanup of the Jibboom Junkyard site. For further
assistance, please contact me at (916) 324-2443 or Mike Golden at
(916) 324-2426.
S incerely,
Thomas E. Bailey, Chiei
Program Management Section
Toxic Substances Control Division
Enclosure
cc: James Allen
Jack DelConte
-------
CITY OF SACRAMENTO
CALIFORNIA
RECEiVZn
U.S. £FA
RtGlC'H r,
COH;'!
*
'OCT urn i .j V/ITt HALL
0J IV.,. lb P&lsfi; Street - 95814
(916) 449-5704
City Haul
Office Or The
City Manager
March 15, 1985
Nick Morgan
E.P.A. (T-4-3)
215 Fremont Street
San Francisco, CA 94105
RE: "FEASIBILITY STUDY, JIBB00M JUNKYARD SACRAMENTO, CALIFORNIA"
Dear Mr. Morgan:
This letter is to serve as the City's official comment on the above
entitled report. Several City departments have reviewed and offered
comments concerning the alternatives identified by your agency to mitigate
the soil contamination on the subject site.
Of the four alternatives discussed in your report only Number 2 is viewed
as acceptable to the City since this alternative would eliminate human
contact with hazardous materials and entirely prevent the potential of
ground water contamination in the future. Additionally, this alternative
greatly enhances the future potential uses of the property for urban
purposes.
I am attaching copies of responses from two City departments which provide
a more detailed review of alternatives included in your study.
Please refer any questions that you may have on the City's position on
this matter to this office. Thank you for your assistance on this matter.
Attachments
cc: Walter J. Slipe, City Manager
Mac Mailes, Director of Planning & Community Development
Mel Johnson, Director of Planning & Development
Bill Powell, Fire Chief
Christine Olsen, Public Information Officer
Dick Troy, State Parks
Andy Plescia, Acting Executive Director, SHRA
-------
CITY OF SACRAMENTO
DEPARTMENT OF PLANNING AND DEVELOPMENT
927 10th Street Sacramento, Ca 95814
March 14, 1965
CITY
MAR 141985 LJ
Administration
Room 200 449-5571
Building Inspections
Room 100 449-5716
Planning
Room 300 449-5604
TO: Solon Wisham, Jr. Assistant City Manager
FROM: Mac Mailes, Director of Planning and DevelOj
SUBJECT: DRAFT FEASIBILITY STUDY - JIBBOOM JUNKYAR!
This hazardous site is in a location of obvious concern. The site is exposed
to wind and rain, enabling off-site migration of toxic wastes. Relatively
unencumbered accessibility creates nuisance, and increases the public health
threat.
As a solution to the problems at the Jibboom Junkyard site, environmental
staff supports the excavation and removal of the contaminated soils with soil
replacement, regrading, and revegetation. Of the four cleanup alternatives
proposed in the draft study, Alternative Two is the only measure that will
accomplish these goals. The following is a brief assessment of each of the
four measures:
ALTERNATIVE ONE: CAP CONTAMINATED AREA
The EPA study indicates that this method would eliminate human contact
with the contaminates and reduce the infiltration of water into the
soils. This method offers no assurances that the clay or synthetic cap
will not later be permeated or breached either by natural forces or by
development of the site. Operation and maintenance would be required
indefinitely with this alternative, thereby probably significantly
increasing the total estimated cost. New federal regulations would
require the installation of a double artificial lining with a leachate
collection and monitoring system, should this method be chosen. The
added cost of complying with these new regulations does not appear to be
a part of the feasibility cost estimate for Alternative One.
ALTERNATIVE TWO: EXCAVATE CONTAMINATED SOILS
The EPA study indicates that this method would eliminate human contact
with the hazardous materials, and entirely prevent the potential for
groundwater contamination. This method fully mitigates the problem. All
toxic wastes are removed and future use of the site would not be a
potential public health hazard. There would be no associated operation
and maintenance costs.
-------
Environmental staff strongly supports this alternative because it
provides complete protection to the public from water, air, and land
contamination.
ALTERNATIVE THREE: ENCAPSULATE CONTAMINATED SOIL
The EPA study indicates that this method would have the same effects as
Alternative One. This method lacks the same comprehensive and permanent
public protection as Alternative One.
ALTERNATIVE FOUR: NO ACTION
This alternative does not address the public health and safety threat
that has been identified at the Jibboom Junkyard site, nor does it
accomplish the goals of the EPA remedial action plan.
Environmental staff does not support this alternative because inaction
would continue to expose the City's water source to potentially dangerous
contamination. This water serves more than 275,000 City residents. In
addition, public exposure to airborne and earth-laced toxic elements
would continue.
Only Alternative Two provides a complete, comprehensive, permanent, cost-
effective, environmentally cognizant solution to this situation. Alternatives
One and Three are band-aid remedies that offer no long term guarantee for
protection of the City's water source, and may eventually be more expensive
than implementing Alternative Two today. Alternative Four is simply
unacceptable.
cc: Marty Van Duyn
CI if Carstens
-------
feufiU. .
CITY OF SACRAMENTO
DEPARTMENT OF PUBLIC WORKS
DIVISION OF WATER AND
SEWERS
March 13, 1985
MEMORANDUM
TO; Solon Wisham, Jr., Assistant City Manager
SUBJECT: ALTERNATIVE MITIGATION MEASURES - JlBBOONV JUNKYARD
Per your directive to Mel Johnson dated March 11, 1985, I have
been Instructed to comment on the alternative mitigation measures
presented In the Draft Feasibility Study performed for the U.S.
EPA by the consulting engineering firm CH2M Hill.
The Draft Feasibility Study eliminated two alternatives during
the screening process. These were the no-act I on alternative
and the restriction of future land use and site access. The
City should concur with the elimination of these alternatives.
The remaining alternatives to mitigate the adverse effects of
the presence of unacceptable levels of hazardous chemicals In
the soil at the site Include:
A. Capping the contaminated area.
B. Encapsulating the contaminated area.
C. Excavation and removal of contaminated soils.
The City's concerns in recommending the selected alternative
are: 1. Protection of future groundwater and surface water
quality. 2. Protection of the health of our citizens In this
high use corridor. 3• The preservation of unrestricted future
use of the property. k. Preservation of property values in
the area.
A. The Capping Alternative. (CH2M Hill Alt. 1)
This alternative consists of capping the contaminated area with
either a flexible membrane, fine clay, or asphalt at a cost
of between $363,000 - $468,000. The City should ask that this
alternative be rejected. If this alternative were adopted,
the material would be left in place with no guarantees that
future groundwater contamination would not occur. This alternative
OFFICE
I-AKHY I. COM/YKSH
Division Mana$*er
1301 3STH AVENUE
SACRAMENTO. CA 95822 20! 1
©161449 S226
-------
Solon Vtshara, Jr.
—2-
rta rch. 13, 19&5
would require extensive future monitoring and maintenance costs.
Future land use would be restricted and nearby property values
could be negatively Impacted, Clearly this alternative Is unacc-
eptable—
B. The Encapsulation Alternative (CH2M Hill Alt. 3) t
This alternative consists of excavating the contaminated soil,
temporarily stockpiling It while the site would be prepared
with clean fill and graded, placing a flexible membrane, replacing
the excavated contaminated soil on the membrane, and wrapping
the membrane around the layer of contaminated soil completely
encapsulating It. This alternative would cost $1,097,000 including
30 year present worth 0 6 M costs. This alternative Is unacceptable
to the City for the same reasons as was the capping alternative,
in addition, the reliability of such a flexible membrane Is
unclear. Burrowing rodents have rendered such systems useless
in many documented Instances.
C. The Excavation - Removal Alternative (CH2M Hill Alt. 2)
This alternative consists of exeat i ng all contaminated soil
at the site and transporting It to a class f landfill site for
disposal. The costs are estimated to be between $1,089,000
and $1,593.000 depending on the location of the disposal site.
This is the only alternative which will acceptably protect the
City's Interests In preserving water quality and the future
unrestricted use of the area. Although it will result in temporary
adverse Impacts associated with the project, selection of this
alternative will Insure that the property values In the area
will not decline. Staff has contacted toxic waste speciali s ts .
with the State of California Department of Health Services and
they have also stated that the only acceptable mitigation measure
for the Jibboon Junkyard Site Is the excavation alternative.
It is strongly recommended that the City's comments to the U.S.
Environmental Protection Agency reflect the position that the
only acceptable mitigation measure presented In the Draft Feasibility
Study on the Jibboon Junkyard Is the excavation alternative.
Thank you for the opportunity to comment on this matter.
Assistant Superintendent - Water Production Facilities
cc: Me 1 Johnson, Director of Public Works
-------
PACIFIC
GAS AND ELECTRIC COMIPANY
77 BEALE STREET . SAN FRANCISCO, CALIFORNIA 94106 • (415) 972-2733 . TWX 910-372-6587
H. M. HOWE
CHIEF SITING ENGINEER March 11, 1985
Mr. Nick Morgan
U.S. Environmental Protection Agency
Region IX (T-4-3)
215 Fremont Street
San Francisco, CA 94105
Dear Mr. Morgan:
Comments on "Draft Feasibility Study,
Jibboom Junkyard, Sacramento, California"
PGandE's comments on the "Draft Feasibility Study, Jibboom
Junkyard, Sacramento, California," are given below. Although the
EPA announcement regarding the availability of the study
requested that comments be postmarked by March 7, 1985, it is our
understanding from a March 7th telephone conversation between Ms.
K. L. Uhlir of PGandE and Ms. Patricia Post of EPA that it would
be acceptable for us to deliver our comments to EPA on March 11,
1985. We appreciate this accomodation and hope that our comments
prove valuable.
Our comments on the draft report are:
1. Acreages given on page 2-1; The acreages of Areas 1 and 2
given on page 2-1 should be reversed.
2. Statement about metal contamination on page 2-4; Since there
were no metal concentrations exceeding TTLC levels in Area 3, the
word "virtually" should be deleted from this sentence on page
2-4: "These results show that virtually all surface metals
contamination exceeding CAM TTLC levels is limited to Areas 1 and
7 "
3. Public health assessment for PCB's (page 2-4; 3-4 through
3-10Ti" The authors conclude that the presence of copper, lead,
zinc and polychlorinated biphenyls, in their respective
concentrations, pose a hazard to human health (pages 2-4 and
3-9). We agree that, based on current regulatory guidelines and
limits, the soils contaminated with those metals constitute
hazardous waste and may pose a health hazard. However, the
concentrations of PCB alone may not justify remedial action.
We believe the cancer risk estimates for PCB's (pages 3-7 through
3-9) are overstated. These estimates were based on the high end
-------
Mr. Nick Morgan
-2-
March 11, 198£
(median to maximum) of PCB concentrations in the soil and on "the ¦>
upper boundary of risk associated with a given exposure" (page '
3-7). Thus, the range of risk estimates reflects only the upper
bounds of risk associated with worst case scenarios. A
corresponding lower range of risk estimates should be included in
describing the actual hazards from PCB soil contamination at the
site.
As an additional note in this area, we believe the cancer
estimates in the Jibboom study are inaccurately represented as
absolute values. Attached is a report summarizing various risk
extrapolations for PCB's using different risk models and applied
by various federal agencies. The report discusses the relative
strengths and weaknesses of various models and clearly indicated
the relative, not absolute, value models and clearly indicates
the relative, not absolute, value of risk estimates. A
comparison of the Jibboom data and that of the Food and Drug
Administration (FDA) and Office of Technology Assessment(OTA)
(see Table 8, page 42 in the attached federal report and Table
3-3, page 3-8 of the Jibboom report) reveals that for the
equivalent extra lifetime cancer risk, the dosages given by FDA
and OTA are approximately 10 times and 700 times higher than the
PCB dosage in the Jibboom report. The OTA risk assessment was
based on the most conservative one-hit model (see Table 7, page
41 in the attached report). This comparison of data and risk
models underscores the fact that while risk estimates are
valuable to an extent, they should not and cannot be represented
as absolute values. The application of different risk models to
the same data set can dramatically affect the conclusions
reached.
4. Remedial action alternatives (Chapter 5); It seems
inconsistent to discuss the removal of all or part of the 5.1
Ac parcel when the material beneath the Interstate 5 freeway
is accepted as being contained. There is one additional remedial
action alternative which should be considered. This option would
be to require that the area be used for commercial development
with stipulation that the site be covered with a concrete base or
foundation (that is, a building or parking lot). Superfund
monies would then be conserved for other projects.
Alternatively, to eliminate any potential immediate exposure to
the contaminants on the site, the site could be covered as soon
as possible, with the associated costs included in the value of
the property when it is sold. The draft report indicates that
there are interests in developing the site (page 6-8).
-------
*
. , .. -.3- March 11, 1985
Mr. Nick Morgan J
If you have any questions on these comments, please contact Ms,
K. L. Uhlir at (415) 972-6911).
Sincerely,
//
i
-------
RECORD OF
COMMUNICATION
Qphonecau. ~DISCUSSION ~FIELOTWP ~CONFERENCE
~ other (SPECIFY)
(Record of item checked above) j
TO:
John Stoll
Sacramento Toxics Coalition
916-482-9162
FROM:
Nick Morgan
EPA T-4-3
DATE
March 8, 1985
TIME
10:00 am
SUBJECT .
Jitbocm FS Comments
SUMMARY OF COMMUNICATION
1. I called to see if the SIC had any ccrrments on the Jibbocm FS since the public
cement period had just closed.
2. John had met with Patti Post in Congressman Iseribergs office sometime last year and
at that time John gave his feelings on Jibbocm. STC still feels that this site
does not belong on the NFL and is not worth the time and effort that we are putting
into it. John would much rather see our time and effort put into the Aerojet site.
3.
4.
Because there is no signifigant contamination at the site or any off site contamina-
tion, the STC is not too concerned about the site. I stated that I disagreed and
that I felt the levels of metals at the site, in the 10,000 ppm range, was
signifigant contamination. He agreed and stated that he was defining signifigant
as meaning off site contamination.
STC feels that the city landfill is probably worse than the Jibbocm site.
5. EPA should not expect any written cements from the STC.
INFORMATION COPIES
TO:
EPA Farm 13004 (7-72) *£pucei epa ho form »»oo-» which mav be used until iupplv is exhausted.
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RECORD OF
COMMUNICATION
0 PHONE CALL {^DISCUSSION ~ FIELD TRIP QCONFERENCE
~ OTHER (SPECIFY)
(Record of item checked above)
TO:
Everett Hemphill
Ives Corporation (President)
602/855-7902
FROM:
Nick Morgan
T-4-3
DATE
Mar 13, 1985
TIME
10:00
SUBJECT
JIBBOQM JUNKYARD FEASIBILITY STODY
SUMMARY OF COMMUNICATION ————
1. Everett is very interested in developing the site. His firm has invested several
hundred thousand dollars and several years in getting together a development plan
for the site. His plan includes; one overnight $45 m steamboat (four day cruise
to S.F.) , one $15 in day trip steamboat, marina, narrow gauge steam train to Old
Sac, 16 story parking strucyure & office building, 30+ story Hilton, an additional
parking structure, and seme kind on mountain scene screen. He considers this
information confidential and I should not share this info with others.
2. I described the findings of the FS; metals contamination throughout site to between
six inches and one foot. PCB's belcw action levels. Contamination to 5 of 10 feet
at three locations. For final RA. we are looking at no action, capping, encapsulatior,
and removal, with the latter costing between 1.1 and 1.6 million dollars.
3. Everett stated that his firm is strongly in favor of removal. Uiis is especially
a concern, since he intends to develop the site and if we were to cap or encapsulate,
he would just have to pay for removal of the cap and then go ahead and excavate the
contaminated material anyway. Therefore, it would be wasteful to spend the effort
for capping the site when the contaminants will just be removed in a short while
anyway.
4. Everett had an estimate of approx $500,000 for the removal based of the DCHS
estimate. I informed him that we used a higher disposal cost than the DCHS estimate
(we used $90-95/ cu yd) and that disposal costs were variable based on situations
at the time of disposal. However, it is likely that removal would cost closer to
the DCHS estimate if a private party were to do the work. For Everett, the only
cost to do the cleanup himself would be the additional cost of trucking and
disposing of the wastes in a Class 1 facility/ since he would already have to do
major earth moving in order to develop the site.
5. Everett met with Patti Post (T-l) several years back and thought he would be inclu-
ded in he FS mailing and public comment period. Since Patti failied to inform him
of the ocxrment period, and he is out of stata, could I send him acopy of the FS ?
I said I would considering the circumstances, but that this was not the standard
procedure, given the limited number of copies available.
6. Everett will be out to make a presentation to state and other officials in about
45 days. He will get in touch with me then to invite me to the presentation.
7. Mailing address is: P.O. Box 708
Lake Havasu City, AZ 86403
information copies
TO:
EPA F*rm 1300^ (7»72) «epl*cm era ho form b»oo.s which may »e used until supply is exhausted.
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THE OFFICES OF
BROWN, NOLAN & NICKERSON
ATTORNEYS AT LAW
STEVEN W. BROWN
THORPE E. NOLAN
WILLIAM J. NICKERSON. JR.
542 SANTA FE DRIVE
ENCINITAS. CA. 92024
(619)942-8205
or '
(619)753-8944
R.EASE REPLY TO:
ENCINITAS
7742 HERSCHEL AVE.
SUITE J
LA JOLLA CA. 92037
(619)456-1290
FILE NO.
TELEX: 140414 TOT
March 7, 1985
Mr. Nick Morgan
EPA T-4-3
215 Freemont Street
San Francisco, CA 94105
RE: Cleanup of former PG&E Property in
Old Sacramento, California
Dear Mr. Morgan:
This office represents a developer with interest in
acquiring the above referenced property (which has
been the subject of a recent EPA feasibility study).
We have only today received a summary of your agency's
report from the State of California along with a cover
letter advising that the public comment period ends
today.
This letter is being written in the hopes that you
will receive it despite the official deadline. As
should be apparent, we have hardly had the time to
respond earlier.
After review of the summary, it is our opinion that
any activity short of excavation and removal of the
contaminated soils will negatively affect the
marketability of the land in question. From a
developer's perspective, should a proposed project
require shoring, pilings, etc., nothing less than
excavation today will make sense. Merely capping
the site will pass on the excavation costs to the
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prospective developers and effectively rule out -those
who cannot make those added costs "pencil out". In
other _words, the site will only be saleable to those
developers not needing to pierce the cap. Furthermore,
if the capping "solution" is selected, there will
always remain an adverse public opinion towards the
area. Will the containment not filter into the water
table anyway? Will the public want to live above
or patronize any establishment standing on top of
a capped toxic waste? Can a developer make a viable
project in the face of such negatives? Surely not.
We urge you, therefore, to take the only sensible
solution: remove the contaminants!
We thank you in advance for your consideration of
our comment.
, Sincerely,
Steven W. Brown
dlb
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March 6, 1985
'85 MAR 18 A11:21
Mr. Nick Morgan
E.P.A.
215 Fremont Street
San Francisco, California 94105
Dear Mr. Morgan:
We are interested in developing a project on the former PG & E Steam
Plant site in Old Sacramento. It has come to our attention that con-
taminated soils on the land could pose a danger to human life.
We strongly recommend the removal of this contaminated soil to an
off-site land fill area. Capping with clay or asphalt is a cover-up
solution a developer may be likely to disturb.
As potential owners of this property we wish to be reassured that
future soil contamination will not occur. We appreciate your con-
sideration of this serious problem and hope you will keep us updated
of your decision.
Thank you,
George C. Hampton
GCH/gd
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MarcusfyMillichap
t
Investment
Real Estate Brokers
March 6, 1985
1500 River Park Drive
Sacramento California 95815
916 929 1900
Mr. Nick Morgan
E.P.A.
215 Fremont Street
San Francisco, California 94105
Dear Mr. Morgan:
This letter concerns the property located at the former
PG & E Steam Plant in Old Sacramento. As potential
owners of the property we need to be assured that future
ground water contamination and PCBs' in the soil will
be taken care of in a way that there will be no future
complications at a later date.
We strongly recommend removal of the contaminated soils,
and that they be disposed of at an off-site land fill area.
We feel that capping the site is a cosmetic solution
which future complications can arise if a developer were
to disturb the cap. We want to be assured that the
site we are seriously considering will not pose a threat
or hazard to human health.
Looking forward to hearing from you regarding your decision
on what alternatives you have chosen in this serious matter.
Sincerely,
MARCUS & MILLICHAP, INC. OF SACRAMENTO
Walter R. Helm
WRH/ks
Palo Alto
San Francisco
Sacramento
Wnucron
Denver
Phoenix
Dallas
Beverly Hills
San Diego
Newport Beach
Seattle
Encino
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
D*TE 3 OCT ]yb$
subject Amendment to the Jibboom Junkyard Record of Decision -
ACTION MEMORANDUM
from Harry 'Seraydarian
Director, Toxics and Waste Management Division
to Judith Ayres
Regional Administrator
Attached for your approval is an Amendment to the Jibboom
Junkyard Record of Decision which revises the cleanup level for
lead in soil. On May 9, 1985, you signed a Record of Decision
for the Jibboom Junkyard site which set the cleanup level for
lead at 200 mg/kg, the level we determined to represent the
background concentration. This amendment changes the remedial
action cleanup level of lead in soil from 200 mg/kg to 500 mg/kg.
At the time the Record of Decision was signed, we were
operating under Headquarters guidance that required cleanup to
background levels at all sites involving excavation and offsite
disposal of contaminated soils. On July 8, 1985, Headquarters
issued new guidance which allowed cleanup action levels to
exceed background where EPA could demonstrate that the residual
contamination poses no threat to public health or the environment.
This amendment reflects this recent interpretation of the
Landfill and Surface Impoundment Closure Requirements of the
Resource Conservation and Recovery Act of 1984 (RCRA) 40 C.F.R.
Part 264.111, as approved by the Acting Assistant Administrator
for Solid Waste and Emergency Response and the Office of General
Counsel.
The proposed action level of 500 mg/kg of lead in soil is
sufficient to protect human health and the environment and is
fully supported by the State of California and the Office of
Regional Counsel. In addition, the 500 mg/kg cleanup level is
the level we had intended to use prior to the guidance requiring
cleanup to background, and is the level included in the Feasibility
Study Report which was fully presented to the public during a
three week public comment period. Implementation of this new
action level will result in a cost savings of $ 433,000.
Disapprove
Date
/o.y.er"
Attachment
EPA Form 1320-6 (Rev. 3-76)
I
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AMENDMENT TO THE JIBBOOM JUNKYARD RECORD OF DECISION
Date: October 4, 1985
On February 13, 1985, the Draft Feasibility Study for the
Jibboom Junkyard Superfund site, Sacramento, California was
distributed to two information repositories. The Executive
Summary from the report was sent to all interested parties the
same day. The next day, February 14, 1985, the official three
week public comment period on the Feasibility Study was commenced.
The report stated that one of the site-specific objectives of
the remedial action was to "limit human exposure to lead [in
soil] to no more than 500 mg/kg." The 500 mg/kg action level
was based on protection of public health and the environment,
action levels at other Superfund sites, the insignificant cost
difference for eliminating exposure to lead in soil at either
500 mg/kg or 1000 mg/kg (the State of California criteria for
defining a hazardous waste), and the potential to eliminate
exposure to all known polychlorinated biphenyls (PCB's) at the
site. None of the fourteen comments made on the study discussed
this site-specific action level.
In April 10, 1985 Region 9 was informed by the Office of
Solid Waste and Emergency Response that "clean closure" of a
Superfund site according to the Landfill and Surface Impoundment
Closure Requirements of the Resource Conservation and Recovery
Act as amended in 1984 (RCRA).- 40 C-F.R. Part 264.1 1 1 would
require removal of all contaminants above background concentra-
tions. Consequently,- the Record of Decision was revised to
reflect this new interpretation of a relevant regulation. The
Record of Decision which was approved by the Regional Administrator
on May 9, 1985 authorized removal and off-site disposal of all
soil contaminated with lead at greater than 200 mg/kg (background)
at a cost of $1,460,000.
On June 19, 1985 the Acting Assistant Administrator for
Solid Waste and Emergency Response was briefed on the Region 6
Crystal Chemical Superfund site. During the briefing, it was
decided that contamination at some level greater than background
levels could be left behind without the requirement for capping
or other closure/postclosure measures. This meant that
"clean closure", per 40 C.F.R. Part 264.111, could be achieved
by removing all contaminants from a site that may pose a threat
to human health or the environment through any route of exposure,
such as ground water, surface water, or direct contact. This
decision, concurred on by the Office of General Counsel and
the Office of Solid Waste, was documented in a July 8, 1985
memorandum from John J. Stanton, Director of the CERCLA
Enforcement Division, OWPE, to David Buente, Chief of the
Environmental Enforcement Section, Department of Justice.
This amendment to the May 9, 1985 Record of Decision
revises one of the site-specific remedial action objectives
for lead in soil from 200 mg/kgf the background levelr to
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500 mg/kg. This action level is sufficient to prevent any
contamination from posing a threat to human health or the
environment, as recommended by the Centers for Disease Control
on November 15, 1984, and as determined by the site-specific
engineering analysis performed for the Jibboom Junkyard
Feasibility Study. This action level is also consistent with
the action level presented to the public for comment in the
Feasibility Study. The State of California Department of
Health Services and Regional Water Quality Control Board fully
support this proposed change to the lead in soil action level.
This change in the lead action level will require that
4,800 cubic yards of contaminated soil be excavated and removed,
including two locations below the surface layer of contamination
one at ten feet, and one at five feet. Based on cleanup to the
background level, 200 mg/kg, 7,200 cubic yards of contaminated
soil, including four subsurface locations, would have required
excavation and removal. The total cost savings of this change
in the lead cleanup level is estimated to be $433,000.
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