SEMS-RM DOCID # 100021608
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September 2020
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%Pro^° EPA Superfund
Record of Decision
for
Montrose Superfund Site
Dense Non-Aqueous Phase Liquid
Operable Unit
EPA ID: CAD008242711
Montrose Superfund Site
Los Angeles, California
U.S. Environmental Protection Agency
Region IX
San Francisco, California
September 2020
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TABLE OF CONTENTS
1.0 PART 1: THE DECLARATION 1
1.1 SITE NAME AND LOCATION 1
1.2 STATEMENT OF BASIS AND PURPOSE 1
1.3 ASSESSMENT OF THE SITES 5
1.4 DESCRIPTION OF THE REMEDY 5
1.5 STATUTORY DETERMINATIONS 6
1.6 ROD DATA CERTIFICATION CHECKLIST 6
1.7 AUTHORIZING SIGNATURE 7
2.0 PART 2: DECISION SUMMARY 8
2.1 SITE NAME, LOCATION, AND DESCRIPTION 8
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 8
2.2.1 Summary of Previous Site Investigations 10
2.3 COMMUNITY PARTICIPATION 15
2.4 SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 18
2.5 SITE CHARACTERISTICS 20
2.5.1 Conceptual Site Model 20
2.5.2 Physiographic and Surface Water Features 22
2.5.3 Regional Hydrogeology 22
2.5.4 Site-Specific Hydrogeologic Setting 25
2.6 NATURE AND EXTENT OF DNAPL CONTAMINATION 32
2.6.1 DNAPL Composition and Physical Properties 32
2.6.2 Lateral and Vertical Extent of DNAPL 34
2.6.3 DNAPL Distribution, Thickness, and Mass Estimates 38
2.7 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES 42
2.7.1 Land Use and Utilities 42
2.7.2 Groundwater Use and Potential Threat to Water Supply 45
2.8 SUMMARY OF SITE RISKS 49
2.9 REMEDIAL ACTION OBJECTIVES AND REMEDIATION GOALS 49
2.9.1 Remedial Action Objectives 50
2.10 DESCRIPTION OF REMEDIAL ALTERNATIVES 51
2.10.1 Alternative 1 - No Action 53
2.10.2 Alternative 2 - ICs 53
2.10.3 Alternative 3 - ICs and SVE (Unsaturated Zone) 54
2.10.4 Alternative 4A—ICs, SVE (Unsaturated Zone), and HD with Untreated
Water Injection 59
2.10.5 Alternative 4B-ICs, SVE (Unsaturated Zone), and HD with Treated
Water Injection 61
2.10.6 Alternative 5A - ICs, SVE (Unsaturated Zone), and Steam Injection for
Focused Treatment Area with Hot Floor 63
2.10.7 Alternative 5B - ICs, SVE (Unsaturated Zone), and Steam Injection for
Entire DNAPL Area with Hot Floor 66
2.10.8 Alternative 6A—ICs, SVE (Unsaturated Zone), and ERH for Focused
Treatment Area without Hot Floor 70
2.10.9 Alternative 6B—ICs, SVE (Unsaturated Zone), and ERH for Entire
DNAPL Area without Hot Floor 75
2.11 COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES 78
2.11.1 Overall Protection of Human Health and the Environment 83
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2.11.2 Compliance with ARARs 83
2.11.3 Long-Term Effectiveness and Permanence 83
2.11.4 Reduction of Toxicity, Mobility, and/or Volume of Hazardous
Constituents through Treatment 84
2.11.5 Short-Term Effectiveness 85
2.11.6 Implementability 85
2.11.7 Cost 86
2.11.8 State Acceptance 89
2.11.9 Community Acceptance 89
2.12 PRINCIPAL THREAT WASTE 90
2.13 SELECTED REMEDY 91
2.13.1 Summary of Rationale for Selected Remedy 91
2.13.2 Detailed Description of Selected Remedy 93
2.14 EXPECTED OUTCOME OF THE SELECTED REMEDY 95
2.15 ST.VIT TORY DETERMINATIONS 95
2.15.1 Protection of Human Health and the Environment 96
2.15.2 Compliance with ARARs 96
2.15.3 Cost-Effectiveness 96
2.15.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable 97
2.15.5 Preference for Treatment as a Principal Element 97
2.15.6 Five-Year Review Requirements 97
2.16 DOCUMENTATION OF SIGNIFICANT CHANGES 98
3.0 PART 3: RESPONSIVENESS SUMMARY 99
3.1 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES 99
3.2 WORKS CITED 117
APPENDIX A ADMINISTRATIVE RECORD INDEX FOR 01-3 - DNAPL 119
APPENDIX B TRANSCRIPT FROM EPA PUBLIC MEETING ON NOVEMBER 8, 2014 155
APPENDIX C WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
232
APPENDIX D DETAILED COSTS FOR THE SELECTED REMEDY 280
APPENDIX E ARARS FOR THE SELECTED REMEDY 363
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LIST OF FIGURES
Figure 1-1 Site Location Map 2
Figure 1-2 Vicinity Map 3
Figure 1-3 Montrose and Del Amo Superfund Sites Operable Units 4
Figure 2-1 Historical Site Features Combined Pre and Post 1953 11
Figure 2-2 Well and Cross Section Locatin Map 12
Figure 2-3 Regional Hydrogeologic Features 23
Figure 2-4 Stratigraphic Column 24
Figure 2-5 Cross Section A-A 26
Figure 2-6 Cross Section B-B 27
Figure 2-7 Cross Section C-C 28
Figure 2-8 Groundwater Elevation Map Upper Bellflower Aquitard - Oct. 2006 30
Figure 2-9 Groundwater Elevation Map Bellflower Sand - Oct. 2006 31
Figure 2-10 DNAPL Extent in the Unsaturated UBA 0-60 36
Figure 2-11 DNAPL Extent in the Saturated UBA 60-105 37
Figure 2-12 Maximum DNAPL Concentration Saturated UBA 39
Figure 2-13 Liberal DNAPL Thickness Saturated UBA 41
Figure 2-14 Present Property Features Update Final 2-19-20 43
Figure 2-15 Aerial Photo Montrose Superfund Site 2010 44
Figure 2-16 Well Locations 47
Figure 2-17 Destroyed Wells 48
Figure 2-18 Conceptual SVE Wells PVS 55
Figure 2-19 Conceptual SVE PFD 56
Figure 2-20 Conceptual SVE Wells UBA PD 57
Figure 2-21 Focused Treatment Area 71
Figure 2-22 UBA Conceptual ERH Remedy Well Pattern Focused Treatment Area 72
Figure 2-23 Conceptual ERH Remedy PFD 73
Figure 2-24 Low Energy Alt Cost Summary 87
Figure 2-25 High Energy Alt Cost Summary 88
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LIST OF TABLES
2-1 Physical Properties of Montrose DNAPL 33
2-2 DNAPL Occurrence Guidelines 34
2-3 Remedial Alternative Component Summary 52
2-4 Alternative 2 - Institutional Controls Cost Summary 54
2-5 Alternative 3 - Institutional Controls and Soil Vapor Extraction (Unsaturated
Zone) Cost Summary 59
2-6 Alternative 4A—Hydraulic Displacement with Untreated Water Injection Cost Summary 61
2-7 Alternative 4B —Hydraulic Displacement with Treated Water Injection Cost
Summary 62
2-8 Alternative 5A— Steam Injection, Focused Treatment Area Cost Summary 66
2-9 Alternative 5B—Steam Injection, Entire Treatment Area Cost Summary 69
2-10 Alternative 6A—Electrical Resistance Heating, Focused Treatment Area Cost
Summary 75
2-11 Alternative 6B—Electrical Resistance Heating, Entire Treatment Area Cost
Summary 78
2-12 Comparative Analysis of Remedial Alternatives 81
IV
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ACRONYMS AND ABBREVIATIONS
°c
degrees Celsius
l-ig/L
micrograms per liter
AOC
Administrative Order on Consent
ARAR
applicable or relevant and appropriate requirement
BFS
Bellflower Sand
bgs
below ground surface
Cal-EPA
California Environmental Protection Agency
CCR
California Code of Regulations
CDWR
California Department of Water Resources
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
CERCLIS
Comprehensive Environmental Response, Compensation, and Liability Information
System
CFR
Code of Federal Regulations
CIP
Community Involvement Plant
cP
centipoise
CPA
central processing area (of the former Montrose plant)
CVOC
chlorinated volatile organic constituent
DAAC
Del Amo Action Committee
DCN
Document Control Number
DDT
dichlorodiphenyltrichloroethane
DNAPL
dense non-aqueous phase liquid
DTSC
California Department of Toxic Substances Control
dyn/cm
dynes per centimeter
EPA
U.S. Environmental Protection Agency
ERH
electrical resistance heating
FLUTe™
Flexible Liner Underground Technologies
FS
feasibility study
ft/ft
foot per foot
ft/day
feet per day
ft2
square feet
g/cc
grams per cubic centimeter
GAC
granular activated carbon
g/kg
grams per kilogram
gpm
gallons per minute
H+A
Hargis + Associates, Inc.
HAZOP
hazard and operability study
HD
hydraulic displacement
HI
hazard index
JCI
Jones Chemical Industries, Inc.
kWh
kilowatt hour(s)
LADWP
Los Angeles Department of Water and Power
lb
pound(s)
LBA
Lower Bellflower Aquitard
LGAC
liquid-phase granular activated carbon
MACP
Monitoring and Aquifer Compliance Plan
MBFC
Middle Bellflower C Sand
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MCL
maximum contaminant level
mg/kg
milligrams per kilogram
Montrose
Montrose Chemical Corporation of California
NAPL
Non-aqueous phase liquid
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NPL
National Priorities List
NPV
net present value
NRRB
National Remedy Review Board
O&M
operation and maintenance
OU
operable unit
OVA
organic vapor analyzer
pCBSA
para-chlorobenzene sulfonic acid
PD
Playa Deposits
Ppmv
parts per million by volume
PRP
potentially responsible party
PVS
Palos Verdes Sands
RA
remedial alternative
RAO
remedial action objective
RCRA
Resource Conservation and Recovery Act
RI
remedial investigation
ROD
Record of Decision
RWQCB
California Regional Water Quality Control Board
SARA
Superfund Amendments and Reauthorization Act of 1986
scfm
standard cubic feet per minute
Site
Montrose Chemical Superfund Site
SVE
soil vapor extraction
TAG
Technical Assistance Grant
TASC
Technical Assistance Services for Communities
TBC
to-be-considered (criterion)
TCE
trichloroethene
TI
technical impracticability
UBA
Upper Bellflower Aquitard
UPRR
Union Pacific Railroad
U.S.C.
United States Code
VGAC
vapor-phase granular activated carbon
VOC
volatile organic compound
WRD
Water Replenishment District of Southern California
VI
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1.0
PART 1: THE DECLARATION
1.1
SITE NAME AND LOCATION
Montrose Chemical Superfund Site (Montrose Superfund Site)
20201 South Normandie Avenue
Los Angeles, California
Los Angeles County, California (Figure 1-1)
Comprehensive Environmental Response, Compensation, and Liability Information System
(CERCLIS) Identification Number: CAD008242711
Dense Non-Aqueous Phase Liquid (DNAPL OU)
This final Record of Decision (ROD) addresses the dense non-aqueous phase liquid (DNAPL)
contamination in soil and soil gas for Operable Unit (OU) 3 DNAPL (the DNAPL OU), which is
one of eight OUs at the Montrose Chemical Corporation Superfund Site (Montrose Superfund
Site, or Site). The DNAPL OU is defined as the portion of the Site on which DNAPL from the
Montrose Chemical Corporation of California (Montrose) plant property, located at 20201 South
Normandie Avenue in Los Angeles, California, has come to be located.
The Montrose Superfund Site occupies approximately 18 acres within the Harbor Gateway area
of the City of Los Angeles, including the 13-acre former Montrose plant property, the adjacent
5-acre Jones Chemicals, Inc. (JCI) property, and other areas impacted by the former plant
operations. The Harbor Gateway area is located east of the City of Torrance, California and south
of the City of Gardena (Figures 1-1, 1-2). The Site was listed on the National Priorities List (NPL)
on October 4, 1989.
DNAPL from the Montrose Superfund Site impacts the contaminated groundwater plume from
both the Montrose and Del Amo Facility Superfund Sites, which is being addressed by the remedy
selected for the Groundwater OU in the Record of Decision for Dual Site Groundwater Operable
Unit, Montrose Chemical and Del Amo Superfund Sites, Volume I: Declaration and Decision
Summary (the OU-3 Dual Site Groundwater ROD), dated March 1999 (EPA, 1999). The Del
Amo Facility Superfund Site, a former 280-acre synthetic rubber manufacturing plant, is located
east of the former Montrose plant property (Figure 1-3).
This decision document presents the U.S. Environmental Protection Agency's (EPA) selected
remedy for the DNAPL OU at the Montrose Superfund Site in Los Angeles, California, which was
chosen in accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the Administrative Record for this
Site (Appendix A).
1.2
STATEMENT OF BASIS AND PURPOSE
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SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 1-1
Site Location Map i ,L s
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California <•„ (Kt t
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Legend:
Location of Current Montrose Property
Boundary (Surveyed August, 2001)
City of Torrance from LADPW, 2004
City of Los Angeles/Harbor Gateway
Unincorporated Los Angeles County
-- Selected Industrial Areas
Flood Control / Storm Water Channel
References:
Parcel Boundary Information from Los Angeles,
CA, Department of Public Works, On—line GIS
database, copyright 2006. Montrose Chemical
Corporation Boundary Survey conducted August
13, 2001 by Dulin—Boynton Land Surveyors.
Montrose Chemical Corp. and Hargis +
Associates, map dated September, 2004.
Satellite/Aerial Photos Reference:
Urban Areas Georeferenced Satellite Imagery,
March 29. 2004.
TerraServer Georeferenced Imagery, June 2003.
Not a Surveyed Map, Site Features, Streets and
Boundary locations are approximate.
&
NORTH
500
1,000 FEET
SCALE: 1"= 1.000'
Montrose Chemical Corporation
Montrose Superfund Site
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
EARTH TECH | AECOM
Figure 1-2
Vicinity Map
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
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isez.
Figure 1 -3: Montrose and Del Amo Superfund Sites Operable Units
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
186th St
Los Angeles County
Palos Verdes
Peninsula
Palos Verdes
Shelf
Los Angeles
Harbor
Pacific
Ocean
Former Del Amo Facility
Former Montrose
Plant Property
Waste Pits Area
JCI Jones Chemical Inc
Kenwood
Ditch
To Palos
Verdes Shelf
Kenwood
Legend
Torrance Lateral
Drain
Torrance Blvd
Del Amo OU-1 (Soil and NAPL)
Del Amo OU-2 (Waste Pits)
Montrose OU-1 (Soils)
Montrose OU-2/OU-6 (Stormwater Pathway)
Montrose OU-3D (Montrose DNAPL)
Montrose OU-4 (Kenwood)
Montrose OU-5 (Palos Verdes Shelf)
Montrose OU-7 (Jones Chemical)
Montrose and Del Amo OU--3G
(Dual Site Groundwater)
Note: OU = Operable Unit
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The State of California, acting through the Department of Toxic Substances Control (DTSC),
concurs with the remedy selected in this document. EPA and DTSC have agreed that DTSC will
be the lead agency for the State and will represent all State stakeholders, including the Water
Replenishment District of Southern California (WRD) and California Regional Water Quality
Control Board (RWQCB).
1.3 ASSESSMENT OF THE SITES
Releases of chemical contaminants from the former dichlorodiphenyltrichloroethane (DDT)
pesticide manufacturing plant operated by Montrose, including but not limited to chlorobenzene
and DDT, have resulted in widespread contamination of soil and groundwater with hazardous
substances. Some of these hazardous substances are present below the ground surface either as
dissolved in water, adsorbed to soils, or in the form of DNAPL, which is considered a continuous
source of contamination to groundwater. The response action selected in this ROD is necessary to
protect the public health or the environment from actual or threatened releases of hazardous
substances into the environment.
1.4 DESCRIPTION OF THE REMEDY
The selected remedy and its major components are summarized in this section. This remedy is
necessary to protect public health or welfare or the environment from actual or threatened releases
of hazardous substances and pollutants or contaminants into the environment. The remedy will
remove hazardous substances from the Site, thereby reducing risk and limiting the potential for
migration of mobile DNAPL. Collectively, these actions are intended to limit exposure for human
and/or ecological receptors. Implementation of the remedial actions selected by this ROD shall
meet the description and all specifications and requirements as provided in this section, and the
accompanying Decision Summary.
Alternative 6A (Electrical Resistance Heating [ERH], Focused Treatment Area), outlined in Final
DNAPL Feasibility Study, Montrose Superfund Site (the DNAPL FS), dated September 2013
(AECOM, 2013), is the selected remedy to address DNAPL OU at the Montrose Superfund Site.
This alternative is premised on the application of ERH within a focused area of the Site where
mobile DNAPL is known to be present. The selected remedy includes the following components:
• In-situ (in place) thermal treatment by ERH - Treatment of a focused treatment area of over
approximately 26,000 square feet (ft2) in the saturated Upper Bellflower Aquitard (UBA).
Conceptually, the ERH system will target treatment over the full thickness of the saturated
UBA, from 60 to 105 feet below ground surface (bgs). The estimated volume treated by
ERH is approximately 43,400 cubic yards. This heating technology will primarily remove
chlorobenzene from the DNAPL, leaving DDT as a precipitated solid in the subsurface.
Chlorobenzene is a threat to groundwater resources, and its removal will minimize the
potential for future DNAPL migration to impact groundwater, which remains the primary
objective for the selected remedy. DDT is relatively insoluble in water and does not pose
a significant threat to groundwater resources. Heated soil vapors will be extracted from the
subsurface by vapor extraction wells; condensed fluids will be conveyed to a central
treatment system via an aboveground piping network and treated onsite. Following
extraction and conveyance to a central treatment system, vapors will be cooled to condense
moisture before treatment. Soil vapors will then be passed through the treatment system
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for removal or destruction of VOCs prior to discharge to the atmosphere. A steam re-
generable carbon/resin system is the preferred option for the vapor treatment.
• Soil vapor extraction (SVE) in the unsaturated zone - SVE to extract and treat VOCs from
permeable unsaturated soils would be implemented in the unsaturated zone between
approximately 10 and 60 feet bgs; more than 400,000 pounds of chlorobenzene are
estimated to be present within this target treatment area. The conceptual design of the SVE
system would include a series of extraction wells positioned throughout the VOC- and
DNAPL-impacted unsaturated zone. The spacing between wells would be based on pilot
test observations. Because subsurface conditions exhibited different flow properties in pilot
testing, two sets of wells would be installed: one set of wells for extraction from the low-
permeability PD, and one set of wells for extraction from the high- permeability
unsaturated sands.
• A land use covenant (deed restriction) - A land use covenant will restrict future activities
at the former Montrose plant property for industrial use only and will place limits on
construction, excavation, and/or drilling activities.
1.5 STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal
and State requirements that are applicable or relevant and appropriate to the remedy, except where
such requirements have been waived (i.e., within the TI Waiver Zone), is cost-effective, and
utilizes permanent solutions and alternative treatment technology to the maximum extent
practicable. The waiver of certain ARARs is justified due to the technical impracticability, analysis
prepared for the 1999 ROD. The selected remedy also satisfies the statutory preference for
treatment as a principal element of the remedy to reduce the toxicity, mobility, or volume of
hazardous substances, pollutants, or contaminants in both the saturated and unsaturated zones.
The selected remedy will result in hazardous substances, pollutants, or contaminants remaining
onsite above levels that would allow for unlimited use and unrestricted exposure. Therefore, a
statutory review (a CERCLA Five-Year Review) will be conducted within five years after
initiation of remedial action, and every five years thereafter, to ensure that the remedy is, or will
be, protective of human health and the environment. The first Five-Year Review for the
Groundwater OU occurred in 2015. The first Five-Year Review to include the DNAPL OU will
be in 2025.
1.6 ROD DATA CERTIFICATION CHECKLIST
The following information is included in Part II: Decision Summary of this ROD (additional
information can be found in the Administrative Record file and the Administrative Record Index
for the DNAPL OU, which is included in Appendix A of this ROD):
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1
Chemicals of concern and their respective concentrations, and distribution
of mobile DNAPL
Section 2.6
2
Baseline risk represented by the chemicals of concern
Section 2.8
3
Cleanup levels established for chemicals of concern and the basis for these
levels
Section 2.9.2
4
How source materials constituting principal threats are addressed
Section 2.12
5
Current and reasonably anticipated future land use assumptions and
current and potential future beneficial uses of groundw ater used in the
baseline risk assessment
Section 2.7
6
Potential land and groundwater use that will be available at the site as a
result of the Selected Remedy
Section 2.14
7
Estimated capital. O&M, and total present value costs, discount rate, and
the number of years over which the remedy cost estimates are pro jected
Sections 2.10.8
and 2.13
8
Key factors that led to selecting the remedy
Section 2.13
This ROD was prepared consistent with guidance published by EPA for preparation of RODs
(EPA, 1999).
1.7 AUTHORIZING SIGNATURE
This ROD documents the selected final remedy for the DNAPL OU of the Montrose Chemical
Corporation Site. The remedy was selected by EPA with the concurrence of the California
Department of Toxic Substances Control. The Assistant Director of the Superfund Division,
Region IX, has been delegated the authority to approve this ROD.
DAM A Digitally signed by
L-ZrAI Nr\ DANA BARTON
BARTON
Dana Barton Date
Assistant Director, Superfund Division
California Site Cleanup Branch
U.S. Environmental Protection Agency Region IX
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2.0
PART 2: DECISION SUMMARY
2.1
SITE NAME, LOCATION, AND DESCRIPTION
Montrose manufactured the technical grade of the pesticide DDT from 1947 until 1982 at a plant
located at 20201 South Normandie Avenue, in the Harbor Gateway area of the City of Los Angeles,
California, east of the City of Torrance, California (Figure 1-1). The Harbor Gateway area is a
narrow, half-mile-wide strip of the City of Los Angeles that extends south from Los Angeles
proper and provides the city a contiguous jurisdiction to Los Angeles Harbor (Figure 1-2).
The former Montrose plant property lies on the west side of South Normandie Avenue, between
Del Amo Boulevard on the south and Francisco Street (extended) on the north. The former
Montrose plant property boundaries are illustrated on Figures 1-2 and 1-3. The areas surrounding
the former Montrose plant property contain portions of Unincorporated Los Angeles County and
the cities of Los Angeles and Torrance, California. The plant was dismantled and demolished by
1983, and the plant property was graded and covered with an asphalt cap. The Montrose Superfund
Site occupies approximately 18 acres within the Harbor Gateway area of the City of Los Angeles,
including the 13-acre former Montrose plant property, the adjacent 5-acre JCI property, and other
areas impacted by the former plant operations.
The CERCLIS Identification Number is CAD008242711. The lead agency overseeing the Site
cleanup is EPA, supported by California state agencies led by DTSC. The District Court for the
Central District of California has already considered certain issues relating to liability for the
groundwater contamination emanating from the Montrose Superfund Site and issued an Order on
Summary Judgment (Order Granting United States' Motion for Partial Summary Judgment, April
24, 2000, as amended by Joint Stipulation and Order, July 18, 2000) (ECF Nos. 1922 and 2100).
In these Orders, the Court concluded that Montrose, Atkemix Thirty-Seven, Inc. (corporate
predecessor of Settling Defendant Stauffer Management Company LLC), and Aventis
CropScience USA, Inc. (corporate predecessor of Settling Defendant Bayer CropScience Inc.) are
jointly and severally liable for all costs of removal or remedial action incurred by the United States
or DTSC with respect to the former Montrose Plant Property and certain property referred to in
the orders as the "Stauffer Property" and currently owned by Settling Defendant Stauffer
Management Company LLC.
Montrose Chemical Corporation operated a technical grade DDT pesticide manufacturing plant at
20201 South Normandie Avenue in Los Angeles, California from 1947 to 1982. During its 35
years of operation, the Montrose plant released hazardous substances into the surrounding
environment, including surface soil and subsurface soil, stormwater drainage ditches and sewers,
sanitary sewers, and via migration these releases impacted groundwater and ultimately the Pacific
Ocean. Contaminants, including chlorobenzene, entered the ground within the Montrose plant
property by way of leaks from valves and clogged lines, and other elements of the DDT
manufacturing process.
Soil beneath the Montrose plant property contains DNAPL, which consists of a mixture of
approximately 50 percent chlorobenzene and 50 percent DDT. Less than one percent of the
2.2
SITE HISTORY AND ENFORCEMENT ACTIVITIES
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DNAPL is composed of other VOCs, including methyl ethyl ketone, chloroform, 1,4-
dichlorobenzene, and para-chlorobenzene sulfonic acid (pCBSA). DDT is a crystalline solid and
is not soluble in water, but is soluble in chlorobenzene. Because the DDT component of the
DNAPL has a tendency to precipitate, some areas may have a reduced concentration of DDT in
the DNAPL, resulting some free chlorobenzene and some DDT that has precipitated out as a solid
in the subsurface. DNAPL acts as an ongoing source in the UBA that continues to contaminate
groundwater as it migrates underground. The chlorobenzene groundwater plume is present in
multiple aquifer units and extends for more than 1.5 miles downgradient of the former Montrose
plant property (Figure 1-3). The chlorobenzene plume is commingled with a benzene plume
originating from the Del Amo Superfund Site (EPA CERCLIS identification number
CAD029544731), which is a former 280-acre synthetic rubber manufacturing plant, located east
of the Montrose Superfund Site (Figure 1-3). As described in Section 1, the remedy selected for
the DNAPL OU by this ROD is interrelated to the OU-3 Dual Site Groundwater remedy, which
addresses the commingled groundwater plume from the Montrose and Del Amo Superfund Sites.
In 1982, EPA conducted an inspection of the Montrose plant property and determined that DDT
was present in surface drainages leading from the property. In 1983, EPA and the RWQCB issued
an enforcement order to Montrose, requiring them to cease and desist their discharge of hazardous
wastes to the storm drain and surface water drainages. On October 15, 1984, the Montrose
Superfund Site was proposed for the NPL. The Site was listed on the NPL on October 4, 1989.
Montrose demolished the former plant and graded the Site in 1984 and 1985 without prior approval
from EPA. Montrose covered the entire plant property with an asphalt cap, except for an area in
the southeastern corner. EPA issued a unilateral administrative order to Montrose on February 19,
1988 requiring Montrose to cover the uncovered southeastern portion of the plant property with
asphalt (EPA Docket No. 88-10), and Montrose ultimately complied with the order.
On October 28, 1985, Montrose and EPA entered into an Administrative Order on Consent (AOC)
(EPA Docket No. 85-04), which obligated Montrose to perform a remedial investigation (RI) and
a feasibility study (FS) of the entire Montrose Superfund Site. This AOC was subsequently
amended twice, once in 1987 and again in 1989. In response to the AOC, Montrose performed the
RI and generated a draft RI report; however, Montrose did not address EPA's comments on this
document. In January 1998, pursuant to the provisions of the AOC, EPA completed the RI report
using EPA staff and contractor resources.
Montrose submitted a draft version of the DNAPL FS to EPA in September 1999 (Hargis +
Associates, Inc. [H+A], 1999). EPA subsequently requested that additional investigation be
conducted to further characterize the nature and extent of DNAPL at the Site and to evaluate
candidate technologies through laboratory and field pilot studies. Montrose conducted additional
DNAPL-related testing at the Site from 2003 through 2009 and submitted a revised draft version
of the DNAPL FS to EPA on April 21, 2009. EPA commented on the revised draft version of the
DNAPL FS in a letter dated January 27, 2010 (EPA, 2010a), and Montrose responded to EPA
comments in letters dated April 27, 2010 and April 28, 2010 (AECOM, 2010; Latham & Watkins,
2010). Multiple technical and legal issues required resolution, and a series of reconciliation
meetings and conference calls were held between September 2010 and February 2011 to address
these issues. Montrose submitted the Final DNAPL FS to EPA on September 27, 2013 (AECOM,
2013).
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As outlined in Section 1, the OU-3 Dual Site Groundwater remedy, selected by EPA in the OU-3
Dual Site Groundwater ROD (EPA, 1999), addresses groundwater contamination from both the
Montrose and Del Amo Superfund Sites. The OU-3 Dual Site Groundwater remedy is interrelated
with the DNAPL OU remedy, and therefore its enforcement history is briefly described here. In
2012, EPA entered into a Partial Consent Decree with Montrose and three other parties for the
construction of a groundwater treatment system for the Groundwater OU. Montrose started
construction of the treatment system, which treats extracted groundwater, in 2013. Operational
testing of the system occurred in 2015, but the system did not operate properly. The treatment
system was redesigned and portions reconstructed. As documented in the Groundwater Treatment
Plan Update, Montrose and Del Amo Superfund Sites, dated October 2019, Montrose started
continuous operations of the extraction and treatment system at low pumping rates in February
2019 (EPA, 2019). The OU-3 Dual Site Groundwater remedy also requires long-term containment
of groundwater contamination in the TI Waiver Zone.
On August 6, 2020, the United States and DTSC lodged the Operation and Maintenance Consent
Decree for the chlorobenzene groundwater plume remedy for the groundwater operable unit. If
the United States moves to enter this Consent Decree after evaluating the public comments, and if
it is approved and entered by the court, then the responsible parties will be required to implement
the chlorobenzene groundwater plume remedy pursuant to the OU-3 Dual Site Groundwater
remedy (EPA, 1999).
2.2.1 Summary of Previous Site Investigations
The Montrose Superfund Site and surrounding properties have been the subject of numerous
studies and investigations to delineate the nature and extent of site-related contaminants. A
chronological summary of studies pertinent to DNAPL and VOC characterization activities
performed since 1987, the year DNAPL was first detected at the Site, is provided below.
1988/1989
• Detailed lithologic logging and soil, groundwater, and DNAPL sampling and analyses at,
and in the vicinity of, the former central processing area (CPA) (Figure 2-1) to depths of 130
feet bgs (H+A, 2004a).
• A focused field investigation to determine the chemical and physical characteristics of
DNAPL and the rate of DNAPL accumulation in monitoring well MW-2 (Figure 2-2) (H+A,
1999).
• Design, construction, and testing of extraction well UBT-1 and observation wells UBT-2 and
UBT-3 in the DNAPL-impacted area (Figure 2-2) (H+A, 1999).
• Design, construction, and sampling of Bellflower Sand (BFS) monitoring well BF-9 adjacent
to monitoring well MW-2 (Figure 2-2) (EPA, 1998a).
1991
• Design, construction, and testing of pilot extraction well UBE-1 for 28 days (Figure 2-
2)(H+A, 1992).
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SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-1
Historical Site Features (Combined Pre and Post 1953) ^
DNAPL OU Record of Decision
U.S. EPA Region IX .SB/
Montrose Superfund Site, Los Angeles, California
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EXPLANATION
S305/S3QSA
SOIL BORING
MW-2
e MONITOR WELL
PSB-7
SONIC BORING
DP—10
O DIRECT PUSH BORING
UBE-2
EXTRACTION WELL
UBI-01
A INJECTION WELL
PROPERTY BOUNDARY
A A* CROSS SECTION LOCATION
SOURCE: HARGIS+ASSOCIATES, 2004b
FEET
MONTROSE CHEMICAL CORPORATION
OF CALIFORNIA
TORRANCE, CALIFORNIA
HARGIS + ASSOCIATES, INC.
3/08
RPT NO,e57.04B 410-6614 A
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-2
Well and Cross Section Location Map Operable
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
i \
Cssy
\ • j
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1998/1999
• Collection and analysis of DNAPL samples for physical properties and chemical composition
to support evaluation of DNAPL remedial technologies and process options as part of the
DNAPL FS (H+A, 1999).
2003/2004
• DNAPL reconnaissance, including drilling and sampling of 60 borings, to further define the
extent and distribution of DNAPL on-property in the UBA (H+A, 2004b).
• Short- and long-term SVE pilot tests within the former CPA and from all three unsaturated
zone layers, including Playa Deposits (PD), Palos Verdes Sands (PVS), and UBA (Earth
Tech, 2004a).
• Soil gas survey at the former Montrose plant property at 33 locations from three different
depth intervals, including 5, 15, and 35 feet bgs (Earth Tech, 2004c).
2004/2005
• Design, construction, and extraction testing of groundwater/DNAPL at wells UBE1, UBE2,
UBE3, UBE4, and UBT1 over a 329-day period (Figure 2-2) (H+A, 2007b, 2008e).
• Supplemental soil investigation, including drilling and soil sampling of 152 borings. This
work included 10 borings drilled to 90 feet bgs within the saturated UBA and logged for the
presence of DNAPL (AECOM, 2011c; H+A, 2006a).
2006
• Measurements of DNAPL boiling point as detailed in an August 2006 report (H+A, 2006b).
• Measurements of DNAPL physical properties at temperatures ranging from 10 to 90 degrees
Celsius (°C), and a bench-scale, one-dimensional steam column test (Davis, 2006).
2007 to 2009
• Depth-discrete groundwater and soil sampling from the BFS to evaluate the possible presence
of DNAPL (H+A, 2008a, 2008b).
• Two-dimensional testing to evaluate the mobility of DNAPL during steam flushing, including
physical properties testing of saturated UBA soils and DNAPL (Earth Tech, 2007a, 2007b,
2008a).
• Physical properties testing of the DNAPL at temperatures between 20°C and 120°C was
conducted in December 2008. The steam-flushing experiments were conducted in 2008 and
2009, and results of experiment Runs 1 and 2 were provided to EPA in March and August
2009 (University of Toronto, 2009). A comprehensive summary report of the steam-flushing
experiments was submitted to EPA in December 2011 (AECOM, 201 lb).
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• Two-dimensional ERH laboratory experiments terminated. Despite significant efforts,
attempts to conduct two-dimensional ERH laboratory experiments were terminated due to
mechanical failure of the test cell under pressure (Queen's University, 2009).
• Computer modeling of hydraulic displacement (HD) alternatives forDNAPL (H+A, 2009a,
2009b).
• Evaluation of containment zone timeframes for DNAPL remedial alternatives (H+A, 2008c,
2009c). Evaluation of candidate focused treatment areas for thermal DNAPL remedial
alternatives (Earth Tech, 2008b).
• Installation of one additional well, UBE-5, adjacent to soil boring SSB-12, and monitoring
for passive DNAPL accumulation (Figure 2-2) (Earth Tech, 2008d). A short-term extraction
test, conducted at UBE-5 in December 2008, confirmed the presence of mobile DNAPL at
this location (Earth Tech, 2009).
2011 to 2013
• Revised DNAPL Feasibility Study (AECOM, 2011a.) was submitted to EPA. Several
meetings were held between Montrose, EPA, DTSC and RWQCB to discuss the document
and path forward.
• EPA presented the FS to the National Remedy Review Board in November 2012.
Recommendations and the response from Region IX were published (EPA, 2013a & 2013b).
• Draft Final FS (AECOM, 2013) submitted including recommendations from the NRRB.
2014 to 2016
• EPA approves the DNAPL FS (EPA, 2014a) and publishes the Proposed Plan (EPA, 2014b).
• EPA hosts DNAPL workshops for the community and the Proposed Plan Public Meeting takes
place. A transcript of this meeting is included in Appendix B.
• In 2016 various documents from the community are submitted to EPA regarding technology
screenings and concerns about vapor intrusion. Also, in 2016 Montrose proposes an ERH
Pilot Study.
2017
• Montrose, during the annual groundwater monitoring event, finds DNAPL in well CMW-002.
Montrose also starts a DNAPL Purging and Recovery Test for CW-002 (Group Delta, 2017).
2018-2019
• Pilot Study - Montrose successfully concluded an ERH pilot study at the end of April 2019.
Using ERH, more than 26,600 pounds of VOCs were removed from the subsurface of (and
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properly disposed of) the former Montrose plant property. In addition, chlorobenzene
concentrations in the confirmation soil samples were found to be significantly below the
concentrations equivalent to the residual DNAPL saturation, which indicates that no mobile
DNAPL remained within the pilot test treatment area following completion of treatment.
(TRS, 2019).
Additional Investigations
• Additional ongoing investigation as part of the Groundwater OU - Semiannual gauging and
purging of accumulated DNAPL from on-property wells screened in the saturated UB A. This
activity has occurred at varying frequencies from 1988 through the present time.
• Nearby investigation - Reconnaissance DNAPL investigation at the JCI property, including
drilling of six deep soil borings to between 90 and 100 feet bgs. Field work conducted in
2010 was reported in 2011.
2.3 COMMUNITY PARTICIPATION
Congress made community involvement an important part of the Superfund process when the
program was established by CERCLA of 1980; the role of community involvement was further
strengthened in the SARA. EPA has a long history of community involvement on the Montrose
and Del Amo Superfund Sites that began in the mid-1980s. EPA issued a Community Relations
Plan (later referred to as a Community Involvement Plan or CIP) in July of 1985 (EPA Document
Control Number [DCN] 0639-00482) (EPA, 1985), and EPA updated it in November of 1996
(EPA DCN 0639-02277) (EPA, 1996) and April of 2010 (EPA, 2010b). These plans were issued
in accordance with EPA guidelines to facilitate community involvement with respect to the
Superfund process associated with the Montrose and Del Amo Sites. The plans have guided EPA's
community involvement at the two Sites over more than three decades. EPA finalized the latest
CIPin June 2020 (EPA, 2020).
In 1993, DDT-contaminated fill was found in residential yards along 204^ Street immediately
adjacent to the former Del Amo waste pits. Consequently, EPA conducted a comprehensive
residential yard soil investigation and cleanup. In 1994, a group of community members formed
the Del Amo Action Committee (DAAC). DAAC crusaded for permanent relocation of the entire
204^ Street block area (120 homes). Over time, DAAC took up the broader issues of health
concerns and possible contamination throughout the wider neighborhood.
Beginning in 1983, EPA has maintained a postal mailing list of household and business entities
residing near the Sites and people who have shown interest in the Sites over time. EPA uses this
postal mailing list to issue fact sheets or postcards, addressing various actions and investigations
underway. These fact sheets and postcards encourage the public to approach EPA with any
concerns and comments they may have. More recently, EPA has developed an email list to also
pass along more timely and detailed information. EPA still uses the postal mailing list to distribute
material and information (i.e., the email list does not replace the postal mailing list).
EPA has held public meetings and invited public comments for the Montrose Superfund Site, as
required by CERCLA. In addition, EPA has also held many additional public meetings, technical
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workshops, and community involvement activities to better understand and address community
concerns, as well as obtain appropriate feedback regarding ongoing activities.
EPA has also worked directly with and supported DAAC. For many years, EPA awarded DAAC
with a Technical Assistance Grant (TAG). EPA's TAG program was created by SARA to provide
funding for non-profit, community groups to contract their own technical advisors to interpret and
explain technical reports, site conditions, and EPA's proposed cleanup proposals and decisions.
Between 2012 and 2015, EPA provided DAAC with access to independent technical consulting
services through the Superfund Technical Assistance Services for Communities (TASC) program.
The national TASC program provides independent assistance through an EPA contract.
Throughout the remedy selection process for the Montrose DNAPL OU, EPA has provided several
opportunities for participation from the community and interested stakeholders. EPA has
specifically worked with, supported, and involved the DAAC. Below is a list of these public
involvement opportunities:
• In August 2012, the EPA TASC program supported a workshop on DNAPL. In December
2012, DAAC issued a fact sheet on DNAPL working with EPA's TASC program.
• In 2012, EPA provided DAAC an additional opportunity to include comments in the proposed
remedy submittal package for the National Remedy Review Board (NRRB). This submittal
package included the draft FS. DAAC provided comments to the NRRB in September 2012
under EPA's TASC program.
• In early 2013, EPA worked with DTSC on the FS to address concerns raised by DAAC. EPA
also worked to respond to the NRRB recommendations and shared the response to the NRRB
recommendations with DAAC.
• In September 2013, Montrose issued a revised DNAPL FS. This revision addressed many
comments from DAAC (which included comments from TASC) and the NRRB. EPA
approved this version of the DNAPL FS in January 2014. In March and April of 2014, EPA
met with DAAC to discuss the DNAPL FS, as well as the NRRB recommendations and Region
IX's response to the NRRB recommendations. In April 2014, EPA sent DAAC a response to
DNAPL FS comments.
• In September 2014, EPA published the Proposed Plan for the DNAPL Operable Unit,
Montrose Superfund Site (the Proposed Plan) (EPA, 2014) available to the public. The public
notice of the Proposed Plan was published in the Daily Breeze on September 8, 2014, and EPA
mailed the Proposed Plan to all entities included on the mailing list. EPA initially provided a
74-day comment period (longer than the standard 30-day).
• From October through December of 2014, the EPA TASC program worked with DAAC to
respond to the Proposed Plan. Working with TASC, DAAC issued a fact sheet, hosted a
DNAPL community workshop, and participated in the EPA DNAPL Workshop as well as the
EPA Proposed Plan public meeting.
• On October 19, 2014, EPA participated in the DAAC DNAPL community workshop
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sponsored by EPA's TASC program. This workshop facilitated one-on-one dialog with experts
in the field regarding site characterization and multiple investigations to define the DNAPL.
On October 27, 2014, EPA hosted a DNAPL Workshop in advance of the Proposed Plan public
meeting. The workshop provided community members a bilingual interactive discussion of the
proposed remedy, site contaminants, potential health impacts, and treatment technologies
suitable for remediation of DNAPL at the Site. Approximately, 14 people attended the EPA
DNAPL Workshop. Personnel from DTSC and WRD joined EPA during this meeting.
On November 8, 2014, EPA held a Proposed Plan public meeting to present clean up remedial
alternatives for the DNAPL OU and invite public comments. EPA received minimal comments
that directly related to the DNAPL OU. Eight residents provided formal comments verbally
during the public meeting. The transcript of this meeting can be found in the DNAPL
Administrative Record (also in Appendix B).
On February 13, 2015, EPA closed the public comment period. Altogether, EPA extended the
public comment period from 74 days to five months in order to give the public additional time
to submit oral or written comments. On that day, EPA received comments from DAAC.
On August 13, 2015, EPA participated in a DAAC stakeholder meeting about the Montrose
and Del Amo Superfund Sites. One of the agenda items included a brief discussion of a
DNAPL technology screen that DAAC wished to do with TASC support.
From May 2015 through January 2016, the EPA TASC program supported DAAC to develop
a technology screening review for the DNAPL OU. EPA prioritized the facilitation of the
technology screening discussions between DAAC, TASC, and EPA. The purpose of the
technology screening review was to evaluate any existing DNAPL treatment options that are
relevant for the Site. TASC developed a 24-page Montrose DNAPL Technology Screening:
Meeting Materials Technical Memo. This document included a technical summary, a list of
potential DNAPL technology types to include in a technology screening, and a draft
technology screening matrix to support a future meeting.
On February 8, 2016, EPA held a teleconference call with DAAC, DTSC, WRD, and RWQCB.
The goal of the call was to discuss technologies that exist and are relevant for the DNAPL OU,
the evaluations EPA performed on those existing and relevant technologies, and a proposed
pilot study of the ERH technology. The pilot study was conducted to evaluate the effectiveness
of the preferred alternative identified in the Proposed Plan, and to address the concerns from
DAAC in regard to protecting the nearby community from the migration of contaminants off
property. During this call, DAAC continued to raise concerns about the preferred alternative
for the DNAPL OU and the need for close monitoring during future remedy implementation.
On February 19, 2016, EPA sent an email to summarize that discussion and underscore EPA's
confidence that having a closely monitored pilot study will ensure that ERH will properly
address the DNAPL OU without posing any risk to the nearby community.
On April 12, 2016, EPA received final comments from DAAC regarding the Proposed Plan.
These comments included the TASC products mentioned above. DAAC's comments and
submitted supporting material can be found in Appendix C of this ROD.
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• Since 2016, EPA has published at least one fact sheet per year and hosts two "Open House"
meetings per year. During these meetings and in these fact sheets, we have kept the community
informed about the DNAPL OU.
EPA's responses to comments received on the Proposed Plan are provided in Part 3 of this ROD.
Oral comments from the Proposed Plan public meeting were recorded via a court transcriber, and
that transcript is included in Appendix B on the ROD. Written comments received by EPA are
included in Appendix C. Written comments were received during the comment period from the
following stakeholders: DAAC, Montrose, Sierra Club, EPA TASC technical advisors, DTSC, and
WRD.
EPA maintains information repositories near Superfund sites which contains documents, reports,
and letters about site cleanup activities, in addition to the administrative records. The Proposed
Plan and the DNAPL FS can be found in the Montrose DNAPL OU administrative record file
online at http://www.epa.gov/superfund/montrose or in the following information repositories:
Carson Public Library EPA's Regional Records Center
151 East Carson Street 75 Hawthorne St., Room 3110
Carson, CA 90745 San Francisco, CA 94105
(310) 830-0901 (415)947-8717
Katy Geissert Civic Center Library 3301
Torrance Boulevard
Torrance, CA 90503
(310) 618-5959
2.4 SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
As with many Superfund sites, the problems at the Montrose Superfund Site are complex. As a
result, EPA has organized the work into eight OUs. The eight OUs are described below.
• OU-1 - On- and Near-Property Soils. OU-1 consists of the study of site-related contamination
in shallow soils (less than 10 feet below ground) and soil gas. The boundaries of OU-1 include
the former Montrose plant property, as well as neighboring properties located immediately to
the north, east, and south. OU-1 is in the investigation stage (a human health risk assessment
and feasibility study are currently being prepared), and EPA has not yet selected a remedy for
this OU.
• OU-2 - Current Stormwater Pathway. OU-2 consists of the study of site-related
contamination in the Kenwood Drain (which replaced the Kenwood Ditch in 1973), Torrance
Lateral, Dominguez Channel, and the Consolidated Slip (within the Port of Los Angeles). These
drainages are locations where rainfall runoff may have carried contaminants from the former
Montrose plant property. The Torrance Lateral is a fenced, concrete-lined open drainage sewer
that flows eastward until it merges with the Dominguez Channel. OU-2 is in the remedial
investigation stage, and EPA has not yet selected a remedy for this OU.
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OU-3G - Dual Site Groundwater. OU-3G consists of the study and cleanup of the
groundwater contamination originating from both the Montrose and Del Amo Superfund Sites,
as well as from additional sources. The groundwater contamination from the Montrose and Del
Amo Superfund Sites has commingled, and EPA refers to this plume as the Dual Site
Groundwater OU. EPA oversees work on the contaminated groundwater (and associated vapor
intrusion pathway) at both Sites concurrently. The groundwater plume extends more than 1.3
miles from the former Montrose plant and Del Amo properties, where it originated, and occurs
in up to six interconnected hydrostratigraphic units. The Dual Site Groundwater OU consists
of groundwater impacted by wastes spilled on the Del Amo and Montrose Superfund Sites that
has leached into the groundwater. Dissolved contaminants from the two sites have mixed and
migrated within the groundwater, toward the southeast. The OU-3 Dual Site Groundwater ROD
selected the remedy for this OU, and the Dual Site Groundwater OU is in the remedial action
stage (i.e., the extraction and treatment system is in place and operating).
OU-3D - DNAPL. DNAPL OU consists of the study and cleanup of a highly concentrated mass
of chlorobenzene in the form of DNAPL located in the subsurface (deeper than 10 feet below
ground surface) of the former Montrose plant property. Chlorobenzene is one of the main
ingredients used to make DDT. Excess chlorobenzene from the historic DDT manufacturing
process has slowly migrated down through the soil and is now trapped in spaces between the
soil particles in the form of DNAPL. The DNAPL chlorobenzene mass is a current source of
the chlorobenzene groundwater contamination. It takes only a small amount of dissolved
chlorobenzene for the groundwater to be extremely toxic and unsafe for drinking. Removing
the mobile DNAPL from the ground will make the groundwater cleanup (see OU-3G, Dual-Site
Groundwater) successful and efficient. The DNAPL OU consists of liquid wastes including
chlorobenzene and dissolved DDT that were released to the ground, to drainage ditches, and to
an unlined pond, and have seeped into subsurface soils on the former Montrose plant property.
Mobile DNAPL is heavier than water and tends to migrate downward, where it may contaminate
groundwater and drinking water aquifers. This ROD selects the final remedy for the DNAPL
OU. The role of the remedial action for the DNAPL OU is to support the current remedy for the
Dual Site Groundwater OU and the future remedy for OU-1, by removing mobile DNAPL mass
to limit the migration of DNAPL outside the TI Waiver Zone.
OU-4 - Historical Stormwater Pathway - North. OU-4 consisted of the study and removal of
DDT-contamination in shallow soil of residential properties along the west side of Kenwood
Avenue, north of Torrance Boulevard. In 2000, EPA found that soil in some of the residential
yards on the west side of Kenwood Avenue contained DDT at levels that posed an unacceptable
health risk to residents. This DDT-contaminated soil is the result of Montrose releasing
contaminated surface water into the historical Kenwood Ditch. From 2001 to 2002, EPA
removed shallow soils contaminated with DDT and restored the yards. A second removal action
was completed in 2008. The removal actions for this OU are complete and no further action is
required.
OU-5 - Palos Verdes Shelf. OU-5 consists of the study, removal, and management of site-
related contamination, including DDT from Montrose, in the sediment off the Palos Verdes
Peninsula in the Pacific Ocean. OU-5 is addressed separately, with its own CIP and separate
EPA staff contacts. For more information on fish advisories, visit: http://www.pvsfish.org.
OU-6 - Historic Stormwater Pathway - South. OU-6 consists of the study and removal of
DDT-contaminated soil along the historical Kenwood Ditch, south of Torrance Boulevard. This
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OU also includes portions of the industrial property at 20846 South Normandie Avenue (the
former Ecology Control Industries, Inc [ECI] property). This area also includes subsurface
portions of the backyards of seven residential homes immediately east of the former ECI
property. EPA is also investigating the historic stormwater pathway between ECI and the
Torrance Lateral. OU-6 is in the remedial investigation stage, and EPA has not yet selected a
remedy for this OU.
• OU-7 - Jones Chemical Inc. OU-7 consists of the study of site-related contamination in soil,
soil gas, and groundwater on or near the JCI property. JCI owns and operates an industrial
chemical supply plant located at 1401 Del Amo Boulevard in Torrance, California, immediately
south of the former Montrose plant property. Operations at the JCI property included
repackaging, warehousing, and distribution of inorganic chemicals used mostly in the treatment
of drinking water, as well as waste and wastewater treatment. Environmental investigations are
currently in progress to define the areas where contaminants may have been released into soils
and groundwater from historical operations. OU-7 is in the remedial investigation stage, and
EPA has not yet selected a remedy for this OU.
2.5 SITE CHARACTERISTICS
The Montrose Superfund Site includes the 13-acre former Montrose plant property, the adjacent 5-
acre JCI property, and other areas impacted by the former plant operations. The plant was
dismantled and demolished by 1983, and the former Montrose plant property was graded and
covered with an asphalt cap. The former Montrose plant property does not include any areas of
archaeological or historical importance.
The former Montrose plant property is bounded by the Union Pacific Railroad (UPRR) right-of-
way and South Normandie Avenue to the east, the JCI property and a right-of-way owned by the
Los Angeles Department of Water and Power (LADWP) to the south, the former Boeing Realty
Corporation to the north, and Frito-Lay (food processing facility) to the west (Figure 1-2). The
former Farmer Brothers Coffee Company property is located south of the LADWP right-of- way.
2.5.1 Conceptual Site Model
The Conceptual Site Model (CSM) identifies potential chemical sources, release mechanisms,
impacted media, transport mechanisms, exposure routes, and potential receptors. The CSM for the
Montrose Site is complex, as potential exposures to contamination in various subsurface media are
managed under different OUs. As described in Section 2.4 above, the role of the remedial action for
the DNAPL OU is to support the remedy for the Dual Site Groundwater OU and the future OU-1
remedy, by removing mobile DNAPL mass to limit the migration of DNAPL outside the TI Waiver
Zone. Residual DNAPL is immobile and does not pose a risk to receptors. The following paragraphs
explain the CSM.
Potential Chemical Sources
The primary sources of the chemicals found in the DNAPL beneath the former Montrose plant
property are aboveground storage tanks and former DDT manufacturing operations in the former
CPA, where chlorobenzene was used to manufacture technical grade DDT. The DNAPL is
comprised primarily of chlorobenzene and DDT, with less than one percent made up of other VOCs.
The nature and extent of the DNAPL is described in Section 2.6 below.
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Chlorobenzene is the most prevalent VOC detected in soil and groundwater at the site and comprises
roughly fifty percent of the DNAPL. Based on the historical operations at the former Montrose plant
property, and the chlorobenzene distribution determined through sampling, the sources of the
dissolved phase chlorobenzene appear to reside beneath the former CPA, where chlorobenzene was
stored, processed, and disposed. The former Montrose plant has been decommissioned and the surface
facilities that resulted in contaminant leaks to soil and groundwater have been removed; however,
DNAPL and soil contamination underneath the former CPA remain a source of chlorobenzene to
groundwater.
Release Mechanisms
Contaminants used at the former plant were released within the former Montrose plant property
through spills, leaks from valves and clogged lines, and other elements of the DDT manufacturing
process. Released contaminants migrated both laterally and vertically in the subsurface.
Impacted Media
Releases from the former Montrose plant property impacted underlying soil and groundwater media.
When mobile DNAPL comes into contact with groundwater, chlorobenzene dissolves from the
mobile DNAPL. DDT in DNAPL, which has a lower solubility than chlorobenzene, is expected to
precipitate out of DNAPL and sorb onto the soil particles. Therefore, mobile DNAPL remains an
ongoing source of groundwater and soil contamination.
Transport Mechanisms
Contamination from the DNAPL is transported either into the groundwater via infiltration and
leaching, or upward to soil and the surface via volatilization. As mentioned above, DNAPL at the
Site consists of about 50 percent DDT and 50 percent chlorobenzene. Chlorobenzene can volatilize
from solids or liquids into soil gas and the atmosphere. Chlorobenzene is also soluble in water and
dissolves from DNAPL when it contacts groundwater to form a plume of contaminated groundwater.
DDT is not volatile and not soluble in water. Because it is not volatile, DDT does not pose a risk of
VI. Also, DDT does not mix and/or travel with groundwater; therefore, the chlorobenzene plume in
groundwater includes little to no DDT. The dissolved chlorobenzene plume is being addressed by
the OU-3 Dual Site Groundwater remedy. Soil and soil gas contamination in shallow soils (0 - 10 ft
bgs) will be addressed by the OU1 soil remedy. The remedy selected for the DNAPL OU is focused
on supporting the remedy for the Dual Site Groundwater OU and the future OU-1 remedy by
removing mobile DNAPL mass to limit the migration of mobile DNAPL to areas outside the TI
Waiver Zone (that is, contain groundwater contamination).
Exposure Routes
The exposure route refers to the method by which a chemical may enter the human body or
environmental receptors. Human receptors can be exposed through inhalation of soil particulates or
vapor; ingestion of soil particulates, water, or DNAPL; and dermal contact with contaminated soil,
water, or DNAPL. Soil particulates and vapors transported into the breathing space can expose
potential receptors through the inhalation route. Contaminants sorbed onto soil that are inhaled by a
receptor can also be ingested. Contaminants dissolved in water can be swallowed. Contaminants
sorbed onto soil could contact and be absorbed into a receptor's bare skin. Similarly, such
contaminants that directly contact the receptor's skin can also enter the receptor's mouth and be
ingested when the receptor touches the hands to the mouth. Contaminants dissolved in water can
also be absorbed into a receptor's bare skin.
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Potential Receptors
Receptors are humans, animals, or plants that are potentially exposed to the contaminants.
There are currently no people living on the former Montrose plant property, and current zoning is
restricted to commercial/industrial land use. The Site is covered with asphalt, which prevents
potential receptors from being exposed to the DNAPL. Shallow soil and soil gas contamination will
be addressed under OU-1.
Exposure Pathways
An exposure pathway consists of the route and mechanisms by which a chemical reaches a receptor.
A complete exposure pathway occurs where a continuous link exists between the contaminant
source, release mechanism, transport medium, exposure route, and potential receptor(s). Currently,
there are no completed exposure pathways for DNAPL beneath the Montrose Site.
2.5.2 Physiographic and Surface Water Features
The former Montrose plant property is located on the Torrance Plain, which is a portion of the Los
Angeles Coastal Plain as shown on Figure 2-3 (California Department of Water Resources [CDWR],
1961). The Torrance Plain is a marine plain that historically was poorly drained and only bisected
by local streams. Former wetlands or floodplains are not known to exist at the former Montrose plant
property.
2.5.3 Regional Hydrogeology
The Site is located in the groundwater basin known as the West Coast Basin (Figure 2-3).
Groundwater in the West Coast Basin occurs in aquifers of varying water quality and usage.
Hydrostratigraphic units beneath the former Montrose plant property include unsaturated playa
deposits and Palos Verdes Sands, as well as aquitards and aquifers of varying compositions and
water-yielding properties. These units, in order of occurrence from the ground surface to deeper
units, are shown on Figure 2-4 and include the following:
• Playa deposits (PD)
• Palos Verdes Sands (PVS)
• Upper Bellflower Aquitard (UBA)
• Bellflower Sand (BFS)
• Lower Bellflower Aquitard (LB A)
• Gage Aquifer
• Gage/Lynwood Aquitard
• Lynwood Aquifer
• Lynwood/Silverado Aquitard
• Silverado Aquifer
The principal municipal water supply aquifers include the Gage, Lynwood, and Silverado
aquifers (CDWR, 1961).
22
-------
I ^-TOS ANGELES
1/
I Los Angeles
Of MALIIU'
point
50 FATHOMS"
I VHJTT'Cj
tw sceuweo,
Central J Qosln
ton?™* frw
HW*gsA\
• CfrCM,
*C3QJi:>0\
S»tACM^
SQUTOJf
PLAIN
~OWT fUM*
EXPLANATION
£ MONTROSE PROPERTY
BOUNDARY BETWEEN PHYSIOGRAPHIC
FEATURES (DOTTED WHERE APPROXIMATE
OR POORLY DEFINED)
BOUNDARY OF GROUNDWATER BASIN
BOUNDARY OF FOREBAY AND WHITTIER AREA
AXIS OF SUBMARINE CANYON
SOURCE: CDWR, 1961
MONTROSE CHEMICAL CORPORATION
TORRANCE, CALIFORNIA
3/08
RPT no 85 7.04B 410-5815
SOURCE: Revised DNAPL l-easibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-3
Regional Hydrogeologic Features Operable
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California '%
23
-------
MONTROSE Rl
(2)
HYDROGEOLOGIC
UNIT
CO
UNSATURATED
UPPER
BELLFLOWER
AQUITARD
BELLFLOWER
SAND
LOWER
BELLFLOWER
AQUITARD
GAGE
AQUIFER
GAGE/
LYNWOOD
AQUITARD
LYNWOOD
AQUIFER
LYNWOOD
SILVERADO
AQUITARD
SILVERADO
AQUIFER
AVERAGE
THICKNESS
(ft)
60
40
45
30
60
20
36
208
>240
BASE ELEV.
RANGE
(ft/msl)
-12 TO -20
-20 TO -90
-70 TO -110
-85 TO -140
-155 TO -190
-170 TO -230
-240
-440
NOT
REACHED
(3)
DEL AMO STUDY AREA Rl
HYDROSTRATIGRAPHIC
UNIT
UPPER
BELLFLOWER
AQUITARD
B-SAND
MUD
MIDDLE
BELLFLOWER
AQUITARD
C-SAND
LOWER
BELLFLOWER
AQUITARD
GAGE
AQUIFER
GAGE/
LYNWOOD
AQUITARD
EXPLANATION
ft = FEET
msl = MEAN SEA LEVEL
~ = WATER TABLE
SOURCES:
(1) CDWR BULLETIN 104, 1961 AND POLAND ET AL. 1959
(2) ENVIRONMENTAL PROTECTION AGENCY, 1998
I3I DAMES & MOORE. 1998
| 3/08 | RPT N0.857.04BI 640-0136
Figure 2-4
Stratigraphic Column
DNAPL OU Record of Decision
U.S. EPA Region IX
^2011)633'b'1'^ s'udy' Montrose Superfund site Montrose Superfund Site, Los Angeles, California
24
-------
2.5.4 Site-Specific Hydrogeologic Setting
Because DNAPL occurrence at the former Montrose plant property appears to be mostly limited
to the PD, the PVS, the UBA, and potentially the BFS, the description of hydrostratigraphy
presented below is limited to these units. Cross sections illustrating the hydrostratigraphy beneath
the former Montrose plant property are shown on Figures 2-5 through 2-7. Figure 2-2 shows the
cross-section locations.
2.5.4.1 Umaturated Zone
The unsaturated zone beneath the former Montrose plant property occurs from the ground surface
to approximately 40 to 60 feet bgs, and includes artificial fill, the PD, the PVS, and the unsaturated
portion of the UBA. These units are described below:
• Artificial fill occurs from approximately the ground surface to 4 feet bgs and is primarily
composed of highly plastic dark brown clayey silt, silty clay, or clay. The artificial fill contains
some construction debris, such as concrete, brick, gravel, and wood. Within the buried
concrete trenches and pits that were part of the former plant, the artificial fill is thicker and is
present to approximately 15 feet bgs.
• The PD occurs from approximately 4 to 25 feet bgs and is primarily composed of medium
brown, moist, dense silts, with some sand and clay. Soils in the PD exhibit a relatively low
horizontal permeability to air and have a moderate moisture content.
• The PVS is primarily composed of light yellowish brown to light olive brown, well-sorted
sand, and generally is encountered from approximately 25 to 45 feet bgs. Thin well- cemented
fossiliferous sand is encountered at the base of the PVS.
• The unsaturated UBA extends from approximately 45 feet bgs to groundwater, which occurs
at approximately 40 to 60 feet bgs, and has continued to rise in recent years. Where
groundwater occurs shallower than 45 feet bgs, there is effectively no unsaturated UBA. Soil
within the unsaturated UBA is heterogeneous with varying layers of sands and low-
permeability silts/clays. The upper portion of the unsaturated UBA exhibits the highest
permeability to air in the unsaturated zone. The lower portion of the UBA exhibits a low
horizontal permeability to air.
2.5.4.2 Water Table Aquifer or Saturated UBA
The water table aquifer beneath the former Montrose plant property occurs in the UBA. The
saturated UBA extends from the water table, at 40 to 60 feet bgs, to a depth of approximately 105
feet bgs (Figure 2-5). Historically, the water table has been considerably deeper due to the
groundwater basin being over-pumped (EPA, 1998a). Following adjudication of the groundwater
basin in the 1960s, which limited groundwater pumping and operation of injection barriers along
the coast, water levels throughout the basin have been gradually recovering. Groundwater levels
may continue to rise in the future, which may result in an increase in the saturated thickness of the
UBA and a decrease in the portion of the UBA that comprises the unsaturated zone.
The saturated UBA is heterogeneous and interbedded with layers of fine-grained sand, silty sand,
and silt, with lesser amounts of fine to medium sand and occasional clayey intervals. Overall, the
sediments that make up the saturated UBA are interbedded, are variable in thickness, and display
varying degrees of lateral continuity (Figures 2-5 through 2-7). There appears to be a gradual
easterly dip in the lower portion of the UBA (Figure 2-5), which may result in down-dip migration
25
-------
50—
45
40
35
30
25 H
20
UJ
W 15
10
s
V)
z
fi 5
LLI
U.
z"
o
UJ
-10-
-15
-20
-25
-30
-35-
-40
-45
-50
NW
UBM SSB-10
PSB-T
UBI-2
TSB-5
1FPER BELLFLOWEH
AQUITARD
EXPLANATION
[3 FILL J SANDY SILT
SAND | SILT
[j] SILTY SAND [J CLAY
~ CLAYEY SAND ^ gHEUS
xtm OVA READING IN PPM
CONCENTRATION OF
CHLOR06EN2ENE AND DDT
IN MG/KG
• DNAPL PRESENT
DNAPL POSSIBLY PRESENT
BASIS OF DETERMINATION OF
DNAPL PRESENCE
VISUAL
1 t—5
UBOMIQRtMWYSm
APPROXIMATE GROUNDWATER
SURFACE (-14.75 FEET MSL) BASED
ON JANUARY2004 MEASUREMENTS
£3l-
4T01
VERTICAL
EXAGGERATION
CASING
HORIZONTAL
SCALE WELL SCREEN
(tax)
£ « SUWF-
FILTER PACK
GROUT
BASKET
NOTES
DDT = DICHLORODIPHENYLTRJCHLOROETHANE
DNAPL - DENSE NONAQUEOUS PHASE UQUID
MC8 = CHLOROBENZENE
MG/KG « MILUGRAMS PER KILOGRAM
MSL ¦ MEAN SEA LEVEL
OVA - ORGANIC VAPOR ANALYZER
PPM ¦ PARTS PER MILLION
RIBBON - HYDROPHOBIC DYE^PREGNATED
FABRIC
SOURCE HARGiS + ASSOCIATES, 2004b
MONTROSE CHEMICAL CORPORATION
OF CALIFORNIA
TORRANCE, CALIFORNIA
HARGIS + ASSOCIATES, INC.
03/07
i f)GJ _fl_SS7_0*S«Ucn> ¦ A^20M_M«n*
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7,2011).
Figure 2-5
Cross Section A-A'
DNAPL OU Record of Decision P* \
U.S. EPA Region IX SB/
Montrose Superfund Site, Los Angeles, California
26
-------
50-
45
40
35
30 —
25
20
15
10
5
0
-5-
LU
>
y
2
w
z
a
5
In
K
0
fe -10
1
uJ -15
-20—
-25
-30-!
-35-
-45-'
-50
N
TSB-1G
7T
f
PSB-4
TSB-2 SSB-2
1
en.
i.n
)ii -
I
394
-"t
« -
EK&-™
J
if
-------
50—
40
35
30-
25
20
15-
10-
$ H
1LI
5 •
?-=
"" -10—i
tn
K! -is—j
z"
o -20
t
[£J -25-
LU
-30
-3&J
-40—1
-45-J
-SO-;
-55—1
-60
-65-j
-70-
-75
-80
sw
PSB-17
SSB-14
ARTIFICIAL FILL
J
RECENT PLAYA
DEPOSITS
RALOS VERDES
SAND
UPPER
BELL FLOWER
AQUfTARD
in
S101/101A
li
MW-2 UBT-1 UBE"°1 UBT-03
S-301/A/B S-305
. o-Mcri
LBS-ODt-T
940
07-wO-
420 J
J
OJW
SJSO-MB
S-
li/
4
SS8-3
BF-09
|fr,
1 I
5
BELLFLOWER
SAND
NE
EXPLANATION
[3 FIU. []]]| SANDY SILT
SAND W SILT
Pjj SIL7Y SAND ' ClAY
~ CLAYEY SAND ^ SHELLS
3.1« OVA READING IN PPM
CONCENTRATION OF
B-oorJ" CHLOROBENZENE AND DDT
IN MG/KG
• DNAPL PRESENT
DNAPL POSSIBLY PRESENT
BASIS OF DETERMINATION OF
DNAPL PRESENCE
- VISUAL
OVfcftEAOINO
- LABORATORY ANALYSIS
APPROXIMATE GROUNDWATER
SURFACE (-14.76 FEET MSL) BASED
ON JANUARY 2004 MEASUREMENTS
luff-
uiw"
>
3 TO 1
VERTICAL
EXAGGERATION
CASING
HORIZONTAL
SCALE WELL SCREEN
(feet)
is » SUMP
SEAL
FILTER PACK
GROUT
BASKET
NOTES
DDT = DICHLORODIPHENYLTRICHLOROETHANE
DNAPL =» DENSE NONAQUEOUS PHASE LIQUID
MC8 = CHLOROBENZENE
MG/KG = MILLIGRAMS PER KILOGRAM
MSL » MEAN SEA LEVEL
OVA - ORGANIC VAPOR ANALYZER
PPM » PARTS PER MILLION
RIBBON = HYDROPHOBIC DYE-IMPREGNATED
FABRIC
SOURCE: HARGIS+ ASSOCIATES, 2004b
MONTROSE CHEMICAL CORPORATION
OF CALIFORNIA
TORRANCE, CALIFORNIA
HARGIS+ASSOCIATES, INC.
03/07
Fie_1_S_SS7_qn«««!S»i_C • C_JOO»_l««i_19.COH
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-7
Cross Section C-C'
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
<^t0SX
uSSy
28
-------
of DNAPL within this unit.
The groundwater flow direction in the UBA is primarily to the south and southeast, but varies
locally. The horizontal hydraulic gradient measured within and downgradient of the Montrose
plant property ranges from 0.0004 to 0.002 foot per foot (ft/ft) (Figure 2-8). The horizontal
hydraulic conductivity of the UBA was estimated to vary between approximately 1 and 20 feet per
day (ft/day) based on field testing and groundwater modeling.
2.5.4.3 Bellflower Sand (BFS)
The BFS underlies the UBA and occurs from approximately 105 to 130 feet bgs. The BFS
comprises an interval of nearly continuous sand that coarsens with depth. The upper half of the
unit typically consists of fine sand, while the lower portion typically consists of fine- tomedium-
or fine- to coarse-grained sand. While DNAPL has not been directly observed in wells and soil
borings in the BFS, the concentrations of chlorobenzene and pCBSA, a specific by-product of
DDT synthesis, increase with depth within the BFS. These observations suggest the potential
presence of DNAPL in this unit (H+A, 2008a, 2008b; EPA, 2008). East of the Montrose plant
property, the base of the BFS dips approximately two degrees from horizontal and is generally
oriented in an easterly direction. However, there is some uncertainty in the orientation of the BFS
bed dip. The importance of this issue is that mobile DNAPL, if present in the BFS, can migrate in
the down-dip direction under gravity, which could be different from the predominated groundwater
flow direction.
The groundwater flow direction in the BFS in the vicinity of the Site is to the southeast. The
horizontal hydraulic gradient in the BFS ranges from approximately 0.0004 to 0.0007 ft/ft (Figure
2-9). The horizontal hydraulic gradient within the BFS beneath the former Montrose plant property
is somewhat steeper, averaging about 0.001 ft/ft. The regional direction of groundwater flow in
the BFS has been about the same since 1987 (H+A, 2007a). There is currently a downward vertical
gradient between the UBA and the BFS. The magnitude of the vertical gradient is greater in the
area southeast of the former Montrose plant property and tends to decrease to the west.
Within the former CPA, the downward vertical gradient is approximately 0.014 ft/ft, which is 7 to
14 times higher than the corresponding horizontal gradient in this portion of the former Montrose
plant property. Based on the pilot testing and groundwater modeling, the large-scale average
hydraulic conductivity for the BFS in the vicinity of the former CPA is approximately 250 ft/day.
29
-------
KNOX STREET
•PACCA^jdQHTY
204-th STREET
TORRANPF iateral
TORRANCE BLVD
TORRANCE LATERAL
CARSON STREET
MW-31
©
EXPLANATION
UPPER BELLFLOWER AOUITARD
MONITOR WELL
-12.01 WATER LEVEL ELEVATION
FEET MEAN SEA LEVEL
NM NOT MEASURED
NOT CONTOURED
* WATER LEVEL POTENTIALLY EFFECTED
BY FLOATING FREE PRODUCT
_12 ?
CONTOUR UNE OF EQUAL WATER
LEVEL ELEVATION IN FEET BELOW
MEAN SEA LEVEL;
DASHED WHERE APPROXIMATE,
QUERIED WHERE INFERRED.
DIRECTION OF GROUNDWATER FLOW
SOURCE: HARGIS + ASSOCIATES, 2007a
MONTROSE CHEMICAL CORPORATION
TORRANCE, CALIFORNIA
H HARGIS + ASSOCIATES, INC.
3/08
RPT NO.857.04B 220-1909 A
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-8
Groundwater Elevation Map Upper Bellflower Aquitard, October 2006
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
2 \
[sgii
30
-------
KNOX STREET
•WCC^KHTY
204th STREET
TORRANnr IATERAL
TORRANCE BLVD
TORRANCE LATERAL
14.95
CARSON STREET
EXPLANATION
BF—12
0
BELLFLOWER SAND MONITOR WELL
-14.32 WATER LEVEL ELEVATION
FEET MEAN SEA LEVEL
NU NOT MEASURED
( ) NOT CONTOURED
-12 ?
CONTOUR LINE OF EQUAL WATER
LEVEL ELEVATION IN FEET BELOW
MEAN SEA LEVEL;
DASHED WHERE APPROXIMATE,
QUERIED WHERE INFERRED.
DIRECTION OF GROUNDWATER FLOW
SOURCE: HARGIS + ASSOCIATES, 2007a
MONTROSE CHEMICAL CORPORATION
TORRANCE, CALIFORNIA
H HARGIS + ASSOCIATES, INC
3/08
RPT NO.857.04B 220-1910 A
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-9
Groundwater Elevation Map BellflowerSand, October 2006
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
31
-------
2.6
NATURE AND EXTENT OF DNAPL CONTAMINATION
This section describes the nature and extent of DNAPL contamination. DNAPL composition and
physical properties are discussed in Section 2.6.1. The lateral and vertical extent of DNAPL is
discussed in Section 2.6.2. DNAPL distribution, apparent thickness, and mass estimates are
discussed in Section 2.6.3.
2.6.1 DNAPL Composition and Physical Properties
Beneath the former CPA, DNAPL is composed of approximately 50 percent chlorobenzene (a
VOC) and 50 percent DDT (a non-volatile pesticide) by weight. A small fraction (less than 1
percent by weight) of the DNAPL is composed of other VOCs including methyl ethyl ketone (0.5
percent by weight in one sample), chloroform (0.1 to 0.4 percent by weight in four samples), 1,4-
dichlorobenzene (0.1 to 0.2 percent by weight in five samples), and pCBSA (0.07 to 0.14 percent
by weight in five samples).
Physical properties of the DNAPL (density, viscosity, interfacial tension, and boiling point) were
evaluated during previous studies conducted in 1998 (H+A, 1999) and 2006 (Davis, 2006; H+A,
2006b). The results of the physical properties analysis are summarized in Table 2-1, and discussed
below.
Density. At 20°C, DNAPL density measured 1.25 g/cc, which is approximately 25 percent higher
than that of water. In the saturated zone, the DNAPL will experience a net downward gravitational
force relative to water, causing it to move vertically downward through permeable soil layers and
to accumulate above low-permeability silts or clays (also called capillary barriers).
Viscosity. At 20°C, DNAPL viscosity measured 2.5 cP, a value roughly 2.5 times higher than that
of water. The significance of this physical property is that the flow of mobile DNAPL through
saturated soils will be 2.5 times slower than the flow of water under equivalent hydraulic
conditions and saturations.
Interfacial Tension. Fluid interfacial tension dictates the capillary forces that must be overcome
in order to mobilize a fluid through a soil matrix. Low interfacial tension properties are indicative
of fluids that can readily migrate in porous media. Conversely, fluids with high interfacial tension
require larger forces to promote migration in a comparable soil profile. The interfacial tension of
the Montrose DNAPL/water is 13 to 15 dyn/cm, which is considered low to moderate in
comparison with other common DNAPLs.
Boiling Point. The boiling point of pure chlorobenzene at 1 atmosphere is 132°C, which is well
above the boiling point of pure water (100°C). However, in the presence of groundwater at
atmospheric pressure, the boiling point of a chlorobenzene/water mixture is 92°C at 1 atmosphere.
The resulting boiling point of the combined fluids is below the boiling point of pure water and
pure chlorobenzene and is known as the co-boiling point. The phenomenon, based on Dalton's
Law, allows for boiling of two fluids at their interface at temperatures that are lower than the
boiling point of either fluid. The co-boiling principle is fundamental to thermal remediation
projects for VOCs and allows boiling of the DNAPL, at the interface, in advance of groundwater
boiling.
32
-------
Table 2-1: Physical Properties of Montrose DNAPL
Montrose Superfund Site, Torrance, California
Physical Property
Test
Temperature
Result
Year -Author
Density
o
o
O
1.228 to 1.239 g/cc
2006 - Davis
22 °C
1.241 to 1.252 g/cc
1998-H+A
VO
o
o
O
1.155 to 1.157 g/cc
2006 - Davis
Viscosity
o
o
o
3.4 to 3.5 cP
2006 - Davis
22 °C
2.5 to 2.8 cP
1998-H+A
C\
o
o
O
1.8 to 2.0 cP
2006 - Davis
Interfacial Tension,
DNAPL- Groundwater
o
o
o
11.1 to 11.5 dyn/cm
2006 - Davis
22 °C
13.0 to 15.0 dyn/cm
1998-H+A
VO
o
o
O
10.6 to 11.8 dyn/cm
2006 - Davis
Boiling Point - DNAPL
only
Various
Initial: 128 °C
Final: 359 °C
2006 - H+A
Co-Boiling Point -
2
DNAPL/Groundwater mixture
Various
Initial: 96 °C
Final: 115 °C
2006 - H+A
Notes:
The boiling point increases as the chlorobenzene component of the DNAPL boils off, eventually reaching a maximum
temperature when the DNAPL was likely composed solely of DDT.
2
Initially, the DNAPL boiled off more rapidly than the water. After capture of approximately half the DNAPL, when
the chlorobenzene component boiled off, the water began to boil off more rapidly than the DNAPL, steadily increasing
to a maximum temperature.
°C - degrees Celsius cP - centipoise
DNAPL - dense non-aqueous phase liquid dyn/cm - dynes percentimeter
g/cc - grams per cubic centimeter
DNAPL-Water Capillary Pressure Curve. DNAPL-water capillary pressure curves provide a
measure of DNAPL saturation at varying capillary pressures, and provide an indication of DNAPL
mobility in the saturated zone. Drainage and imbibition capillary pressure curves for the Montrose
DNAPL were measured for a core sample collected from the saturated UBA as part of the 2-
dimensional thermal remediation bench-scale testing (Earth Tech, 2008a). DNAPL, soil, and
groundwater samples were used to conduct the capillary pressure measurements. For the drainage
curve, DNAPL displaces water in a saturated core at increasing capillary pressures. The drainage
curve ended with a maximum DNAPL saturation of 50.7 percent. For the imbibition curve, water
displaces DNAPL at varying capillary pressures, and the curve ended with a minimum DNAPL
saturation of 18.9 percent. The significance of this value is that the lowest achievable residual
DNAPL saturation from this soil type through a remediation strategy that relied on water
displacement would be 18.9 percent, provided that the pore space was initially saturated to at least
50.7 percent. While the soil type sampled is reasonably representative of the sand layers within
the saturated UBA, soil samples with smaller pore throats, such as those present in silts and clays,
will generally exhibit lower residual DNAPL saturations due to the fact that less DNAPL migrates
into the pores of silts. DNAPL-water capillary pressure curves were obtained for additional soil
and silt samples during the installation of monitoring points for the ERH pilot study performed in
2019. These curves showed an average residual DNAPL saturation of 27.1% in sands, and 15.8%
33
-------
in silts. Thus, average residual saturation of chlorobenzene in sands is equivalent to approximately
27,900 milligrams per kilogram (mg/kg), and in silts the average residual saturation is
approximately 17,000 mg/kg. Thus, chlorobenzene concentration less than these concentrations
would indicate that the chlorobenzene is not mobile.
2.6.2 Lateral and Vertical Extent of DNAPL
The lateral and vertical extent of DNAPL was determined based on the following (H+A, 2004b):
1. Visual inspection
2. Staining on a hydrophobic dye-impregnated fabric (Flexible Liner Underground
Technologies [FLUTe™] ribbon)
3. Laboratory analysis of discrete soil samples
4. Organic vapor analyzer (OVA) field soil headspace measurements
These four lines of evidence provide information related to the definite and possible presence of
DNAPL in the subsurface. The guidelines listed in Table 2-2 were used to evaluate the four lines
of evidence for assessing DNAPL occurrence.
Table 2-2: DNAPL Occurrence Guidelines
Montrose Super fund Site, Torrance, California
Method
DNAPL
Not Present
DNAPL
Possibly Present
DNAPL
Definitely Present
Primary
Visual
Not Visible
Not Visible
Oily Sheen
FLUTe™
Ribbon
No Staining
No Staining
Ribbon Staining
Secondary
Laboratory
Results'
<180 mg/kg
chlorobenzene
or <60 mg/kg Total DDT
180 to 1,000 mg/kg
chlorobenzene
or 60 to 1,000 mg/kg
Total DDT
>1,000 mg/kg
chlorobenzene
or >1,000 mg/kg
Total DDT
OVA readings'
<1,500 ppmv
1,500 to 10,000 ppmv
>10,000 ppmv
Notes:
1 The rationale for the criteria for laboratory results and OVA readings is presented in H+A, 2004b.
> greater than
< less than DDT dichlorodiphenyltrichloroethane
DNAPL dense non-aqueous phase liquid
FLUTe™ Flexible Liner Underground Technologies
mg/kg milligrams per kilogram
OVA organic vapor analyzer
Ppmv parts per million volume
2.6.2.1 Estimated Lateral Extent of DNAPL
The area directly beneath and adjacent to the former CPA at the former Montrose plant property
has the most DNAPL in both the unsaturated zone and the saturated UBA; however, the lateral
extent of DNAPL is significantly greater in the saturated zone than in the unsaturated zone. The
34
-------
lateral extent of DNAPL occurs fully within the TI Waiver Zone established by EPA as part of the
OU-3 Dual Site Groundwater ROD (EPA, 1999).
In the unsaturated zone (0 to 60 feet bgs), the extent of DNAPL is estimated to be approximately
57,000 ft2; and the possible extent of DNAPL is estimated to be approximately 79,000 ft2 (Figure
2-10). In addition, two isolated small areas located in the unsaturated zone at the southeast corner
of the former Montrose plant property were found to have chlorobenzene/total DDT concentrations
meeting the criteria for possible DNAPL.
In the saturated UBA (60 to 105 feet bgs), the definite extent of DNAPL is estimated over an area
of approximately 150,000 ft2 as shown on Figure 2-11. As shown on this figure, DNAPL extends
east of the former CPA, presumably due to DNAPL migration along the top of low-permeability
silt layers that dip to the east. The possible extent of DNAPL in the saturated UBA is estimated to
be 160,000 ft2.
2.6.2.2 Estimated Vertical Extent of DNAPL
DNAPL has been definitively detected from a minimum of 7 feet bgs in the unsaturated zone to
a maximum of 101.5 feet bgs in the saturated UBA (H+A, 1999, 2004b). The predominant
DNAPL-impacted zone is the saturated portion of the UBA at depths ranging from
approximately 75 to 95 feet bgs (H+A, 2004b). The majority of the observed DNAPL appears
to be perched on low-permeability silt layers throughout the UBA (Figures 2-5 through 2-7).
2.6.2.3 Potential Presence of DNAPL in BFS
While DNAPL was not directly observed in the BFS, its likely presence in this
hydrostratigraphic unit could be inferred based on the following lines of evidence:
• Elevated chlorobenzene concentrations (over 70,000 micrograms per liter [|ig/L]) in
groundwater; concentrations in groundwater at the base of the BFS are approximately
20 percent of the chlorobenzene solubility limit.
• Presence of DDT in the BFS (at a depth of 126.5 feet bgs) at a concentration of 130
mg/kg may be related to the past or present occurrence of DNAPL.
• An increasing concentration trend from top to bottom of the BFS in wells BF-4 and
BF-9, and soil boring BFSB1 was observed.
• Dissolved chlorobenzene concentrations observed north and upgradient of the former
Montrose plant property at wells BF-35, and CMW001 may be indicative of DNAPL
migration within the BFS.
• DNAPL distribution, thickness, and mass estimates, approximately 1.7 gallons of
DNAPL have been recovered from upgradient well CMW002, which is to the north of
the Montrose property, starting in 2017. Due to the construction of this well, it is not
known if the DNAPL migrated down the well bore or laterally within the BFS (Group
Delta, 2017).
35
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EXPLANATION
• MUD ROTARY BORING DRILLED TO 2003
O DIRECT PUSH BORING DRILLED 2003
• SONIC BORING DRILLED 2003-2005
o MONITOR WELL
® EXTRACTION WELL
A INJECTION WELL
— DEFINITE DNAPL EXTENT IN UNSATURATED UBA
POSSIBLE EXTENT IN UNSATURATED UBA
SOURCE: HARGIS + ASSOCIATES, 2006a
MONTROSE CHEMICAL CORPORATION
TORRANCE, CALIFORNIA
HARGIS+ASSOCIATES, INC
H yd rogeo logy/Engineering
11-11
RPT NO.857.04b 410-6615 A
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-10
DNAPL Extent in the Unsaturated UBA (0-60 feet bgs)
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
36
2 \
ISB
PHD**'
-------
EXPLANATION
• MUD ROTARY BORING DRILLED PRIOR TO 2003
O DIRECT PUSH BORING DRILLED 2003
• SONIC BORING DRILLED 2003-2005
e MONITOR WELL
® EXTRACTION WELL
A INJECTION WELL
— DEFINITE DNAPL EXTENT IN SATURATED UBA
POSSIBLE DNAPL EXTENT IN THE SATURATED UBA
SOURCE: HARGIS + ASSOCIATES, 2006a
MONTROSE CHEMICAL CORPORATION
TORRANCE, CALIFORNIA
HARGIS+ASSOCIATES, INC
Hydro geology/Engineering
11-11
RPT NO.857.04b 410-6616 A
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-11
DNAPL Extent in the Saturated UBA (60-105 feet bgs)
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
37
i \
-------
However, the amount of DNAPL, if present in the BFS, is likely to be significantly less than the
mass estimated in the UBA.
2.6.3 DNAPL Distribution, Thickness, and Mass Estimates
2.6.3.1 DNAPL Distribution and Area of Mobile DNAPL
The sum of the chlorobenzene and total DDT concentrations in saturated soils, where DNAPL
is encountered, is collectively referred to as the "DNAPL concentration." DNAPL
concentrations detected in the saturated UBA are shown on Figure 2-12, and summarized as
follows:
• The highest DNAPL concentration within the former CPA exceeds 50,000 mg/kg.
• Southeast of the former CPA an elevated DNAPL concentration (103,000 mg/kg) was
reported at SSB-12.
• Moderate DNAPL concentrations, greater than 10,000 mg/kg, occur over the southern
portion of the former CPA and east of the former CPA.
• Low DNAPL concentrations (below 1,000 mg/kg) were reported at DP-1, 2, 4, and 8,
located immediately east of wells UBT-1 through UBT-3.
• The areas represented by possible DNAPL all have low DNAPL concentrations (below
1,000 mg/kg).
Because only a limited number of DNAPL-impacted soil samples were collected for laboratory
analysis, significant uncertainty remains in the distribution of DNAPL saturation in the subsurface.
Physical properties testing showed an average residual DNAPL saturation of 27.1% in sands, and
15.8% in silts. Thus, average residual saturation of chlorobenzene in sands is equivalent to
approximately 27,900 milligrams per kilogram (mg/kg), and in silts the average residual saturation
is approximately 17,000 mg/kg. Therefore, DNAPL is assumed to be potentially mobile in areas
where the chlorobenzene concentration exceeds 27,900 mg/kg in sands or 17,000 mg/kg in silts.
As shown on Figure 2-12, an area of approximately 26,000 ft2 is estimated to contain DNAPL in
concentrations that are potentially mobile at the Site, which corresponds to chlorobenzene
concentrations indicative of mobile DNAPL. This area is referred to as the "Focused Treatment
Area" in the remedial alternatives. Additional DNAPL characterization data may need to be
collected to better define/confirm the area of mobile DNAPL to the north under the building.
38
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Legend:
llllllllllllllllllllllllll
~
LADWP
S204 •
MW002 0
PSB—7 #
DP-10O
UBE-2(8)
••
UBI-01A
1,000
10,000
50,000
[21,000]
, Location of Current Montrose Property
Boundary
¦ Parcel Boundary / Right-of-Way
Surveyed Fence Line
Existing Railroad Tracks
Existing Building
Los Angeles Department of Water and Power
Soil Boring Location
Monitoring Well Location
Sonic Boring Location
Direct Push Boring Location
Extraction Well Location
Existing DNAPL Recovery Location
Injection Well Location
Entire Possible DNAPL Impacted Area
1,000 mg/kg DNAPL Concentration
(MCB + Total DDT)
10,000 mg/kg DNAPL Concentration
(MCB + lotar DDT)
50,000 mg/kg DNAPL Concentration
(MCB + Total DDT)
MCB + Total DDT mg/kg
References:
1.
Parcel Boundary Information from Los Angeles,
CA, Department of Public Works, On—line Arclnfo
GIS data set, 2004. Montrose Chemical Corporation
Boundary Survey conducted August 13, 2001 by
Dulin—Boynton Land Surveyors.
Satellite/Aerial Photos Reference:
Urban Areas Georeferenced Satellite Imagery,
March 29, 2004.
3. Source: Earth Tech, 2008b
2.
A
NORTH
0 60 120 FEET
SCALE: 1"- 120'
Montrose Chemical Corporation
Date: 04-09
Project No.
103649
Montrose Superfund Site
EARTH TECH AECOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-12
Maximum DNAPL Concentration, Saturated UBA
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
i \
I SBU
39
-------
2.6.3.2 DNAPL Thickness
The thickness of DNAPL was estimated by Montrose based on visual observations and FLUTe™
ribbon staining. Based on the analysis completed by Montrose, the DNAPL thickness varies from
0.25 foot to 14.15 feet (H+A, 2008b, 2008c). The estimated thickness of DNAPL is shown on
Figure 2-13. The greatest thicknesses of DNAPL are within the former CPA near the former
wastewater pond at UBT-1 through UBT-3, west of the former wastewater pond at PSB-9, and at
the former raw materials storage area near PSB-5. DNAPL thickness east of the former CPA is
estimated to be less than or equal to 2 feet.
EPA used an alternate approach to estimate DNAPL thickness based on the reported concentration
of DNAPL in soil samples and the capillary properties of the soil (CH2M HILL, 2010). In this
analysis, nine soil samples collected from boring 2DSB-1 in February 2008 were analyzed for
air/water capillary pressures. The reported van Genuchten parameters were then used to estimate
the vertical height of DNAPL required to produce the reported concentrations of DNAPL in soil.
Thickness measurements prepared by Montrose and EPA were subsequently integrated into the
calculation of DNAPL mass in the subsurface as described in the following section.
2.6.3.3 Estimated DNAPL Mass
The DNAPL mass present in the saturated UBA was estimated using the area of DNAPL- impacts
to soil, estimated DNAPL thicknesses, DNAPL concentration measurements, and soil bulk
density, as described below. Since DNAPL thickness was estimated by Montrose and EPA using
two different methods, two mass estimates are summarized in this section
Montrose Estimate. Montrose estimated the mass of DNAPL in the saturated UBA using the
following equation:
DNAPL Mass = Area x Thickness x Concentration x Wet Bulk Density
Using the measured density of the Montrose DNAPL at 22°C (1.25 g/cc), the estimated mass of
DNAPL within the saturated UBA is approximately 796,100 pounds (H+A, 2008b). This mass
estimate is based on the lateral and vertical area of DNAPL-impacts, DNAPL concentrations,
DNAPL thickness estimates, and the average wet bulk density of saturated UBA soil.
EPA Estimate. EPA estimated DNAPL-phase chlorobenzene mass based on the analytical results
of soil samples collected during the DNAPL Reconnaissance Investigation (H+A, 2004b) and
physical property results of soil samples collected from boring 2DSB-1 in February 2008.
EPA averaged the mass integrals within each of the concentration contours shown on Figure 2-12
and multiplied by the area of the contours to obtain the estimated chlorobenzene mass. Consistent
with the Montrose DNAPL composition, the mass of DNAPL was determined by doubling the
chlorobenzene mass estimate. The EPA estimate of DNAPL mass at the Site is approximately
900,000 pounds (CH2M HILL, 2010).
40
-------
Legend:
Location of Current Montrose Property
Boundary
Parcel Boundary / Right-of-Way
——— Surveyed Fence Line
iiiiiiiiiiiiiiiiiiiiiiiiii Existing Railroad Tracks
I I Existing Building
LADWP Los Angeles Department of Water and Power
S204 • Soil Boring Location
MW0020 Monitoring Well Location
PSB-7 • Sonic Boring Location
DP-10O Direct Push Boring Location
UBE—2(8) Extraction Well Location
0# Existing DNAPL Recovery Location
UBI-01A Injection Well Location
Entire Possible DNAPL Impacted Area
1 DNAPL Definite Thickness in Feet
[1.60] DNAPL Thickness in Feet
References:
1. Parcel Boundary Information from Los Angeles,
CA, Department of Public Works, On-line Arclnfo
GIS data set, 2004. Montrose Chemical Corporation
Boundary Survey conducted August 13, 2001 by
Dulin-Boynton Land Surveyors.
2. Satellite/Aerial Photos Reference:
Urban Areas Georeferenced Satellite Imagery,
March 29, 2004.
3. Source: H+A, 2008a
A
NORTH
0 60 120 FEET
SCALE: 1"- 120'
Montrose Chemical Corporation
Date: 04-09
Project No.
103649
Montrose Superfund Site
EARTH TECH
AECOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-13
Liberal DNAPL Thickness, Saturated UBA
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
sr«»
s A \
uasy
41
-------
In addition to total DNAPL mass (residual and mobile), both Montrose and EPA estimated the
mass of mobile DNAPL by assuming a residual DNAPL saturation of 18.9 percent, consistent with
the results of physical properties testing. Additionally, the EPA estimate of DNAPL mass in the
Focused Treatment Area assumes an area of approximately 30,500 ft2, which is slightly higher
than the area of 26,000 ft2 defined by the assumed 18.9% residual DNAPL saturation. (AECOM,
2013.) The estimates of DNAPL mass for the various treatment scenarios are summarized below.
Montrose and EPA DNAPL Mass Estimates
Treatment Area
DNAPL Mass (pounds)
Montrose
Estimate
EPA Estimate
Entire DNAPL-
Impacted Area
796,100
900,000
Focused Treatment
Area
473,600
780,000
Mobile DNAPL
221,800
340,000
Given the inherent uncertainty associated with the DNAPL distribution, these two DNAPL mass
estimates are generally consistent.
2.7 CIIRRE^NT AND POTENTIAL FUTURE SITE AND RESOURCE USES
2.7.1 Land Use and Utilities
2.7.1.1 Former Montrose Plant Property
The former Montrose plant property is currently vacant. The Site is mostly undeveloped and
unoccupied, with the exception of the groundwater treatment plant that is part of the OU-3 Dual
Site groundwater remedy, which is located on the former Montrose plant property. In 1985, the
former Montrose plant property was regraded and covered with asphalt to prevent exposure to
underlying shallow soils containing DDT. During regrading activities, concrete foundations and
footings were either left in place, buried in debris pits and trenches, or crushed and used as
aggregate beneath the asphalt cover.
Two large raised building pads and a total of six temporary soil and debris containment cells are
located at the former Montrose plant property (Figure 2-14). The cells were constructed by EPA
to temporarily contain DDT-impacted soils and debris excavated from the historical stormwater
pathway located along Kenwood Avenue, southeast of the former Montrose plant property. In
addition, Montrose relocated DDT-impacted soil in the vicinity of the groundwater treatment plant
and placed the soil under a new low-permeability asphalt cover under EPA oversight. This soil
was excavated for the groundwater treatment plant construction (e.g., pipeline, utility corridor,
facility footprint, etc.). The soils and debris contained in the cells will ultimately be incorporated
into the soils remedy for Montrose Superfund Site OU-1. Until that time, the soil cells will remain
in place and will be inspected regularly to ensure effective containment of the soil and debris.
Additionally, a storage container is located at the former Montrose plant property for onsite storage
of field equipment and supplies. An aerial photograph of the former Montrose plant property is
shown on Figure 2-15.
42
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6MTD TEL COND PAC TEL-
FRANCISCO ST.
DISTRICT 5 INTERCEPTOR
JOINT OUTFALL D
GLJ Holdings
Property *
SITE
ENTRANCE-
GUARD SHACK
WATER
SERVICE
LINE
SOIL CELL
MOBILE
STORAGE
UNIT
DRUM
PAD
DEBRIS
x CELI/,
BUILDING
PAD B
BUILDING
PAD A
Treatment
Plant
BUILDING
PAD B
Jones Chemical
Electrical
Substation
Electrical Substation
LADWP Right-of-Way
DRIVEWAY
Western Waste
ALLEY
204th STREET
Legend:
LADWP
Location of Current Montrose Property
Boundary
Parcel Boundary / Right-of-V\foy
Surveyed Fence Line
Existing Railroad Tracks
Former Railroad Tracks
Existing Building
Los Angeles Department of Water and Power
Utility Trench
References:
1. Parcel Boundary Information from Los Angeles,
CA, Department of Public Works, Online Arclnfo
GIS data set, 2004. Montrose Chemical Corporation
Boundary Survey conducted August 13, 2001 by
Dulin-Boynton Land Surveyors.
2. Satellite/Aerial Photos Reference:
Urban Areas Georeferenced Satellite Imagery,
March 29, 2004.
TerraServer Georefernced Imagery, 2003
A
NORTH
100 200 FEET
SCALE: 1"= 200'
Montrose Chemical Corporation
Date: 12-11
Project No.
60212541
Montrose Superfund Site
AECOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011) & Google Earth 2/19/2020
Figure 2-14
Present Property Features
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
?' A \
I®*
43
-------
GLJ Holdings
Property
&
3
5
Building
Pad B
¦ Mobile
Storage Unit
Montrose
Superfund Site
Electrical
Substation
Li®
Jones Chemical \ y
Building
Pad B
lWHHIWHimHIHmWHlS
i»mppwiW*Miiiiii in
tMlllllllllllllllllllllllllllllllllllllllllllllllllllllll'HW^1"^
Electrical Substation
DRIVEWAY
LADWP Right-of-Way
Legend:
( Location of Current Montrose Property
Boundary
Parcel Boundary / Right-of-Way
— Surveyed Fence Line
iniiHiiiHiiiiiiiimiii Existing Railroad Tracks
1 I Existing Site Features
LADWP Los Angeles Department of Water and Power
References:
Parcel Boundary Information from Los Angeles, CA,
Department of Public Works, On-line CIS data set,
Copyright 2006. Montrose Chemical Corporation
Boundary Survey conducted August 13, 2001 by
Dulin—Boynton Land Surveyors.
Satellite/Aerial Photos Reference: Urban Areas
Georeferenced Satellite Imagery, March 29, 2004.
Bing Maps Image of 20201 S. Normandie Ave.,
Torrance, California 90502
http: //www.binq.com/maps
accessed: December 4, 2011
1.
2.
A
NORTH
60 120 FEET
Montrose Chemical Corporation
Date: 12-11
Project No.
60212541
Montrose Superfund Site
AICOAi
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-15
Aerial Photo Montrose Superfund Site 2010 o^t0
DNAPL OU Record of Decision / \
U.S. EPA Region IX sez;
Montrose Superfund Site, Los Angeles, California "%
44
-------
Water service is available at the former Montrose plant property through a metered line located at
the northeast corner of the former Montrose plant property. Electrical and telephone services are
not currently available at the former Montrose plant property. Several abandoned underground
sewer mains and lateral connections owned by the Sanitation Districts of Los Angeles County are
located near and beneath the former Montrose plant property. These lines were historically used
in conveyance of Montrose process wastewater. Two active sewer mains, the District 5 Interceptor
and the Joint Outfall D, run north to south beneath the eastern portion of the former Montrose plant
property (Figure 2-14). The District 5 Interceptor is located approximately 50 feet west of the
eastern property boundary. Joint Outfall D is located approximately 30 feet west of the eastern
property boundary.
In a 2004 study conducted by EPA (EPA, 2004), it was concluded that the most likely reuse
scenario for the former Montrose plant property would be industrial land use, which is consistent
with current zoning, surrounding property use, and the Harbor Gateway Community General Plan
(City of Los Angeles, 1996).
Under EPA oversight, Montrose designed, built, and is currently operating the groundwater
extraction and treatment system as part of the OU-3 Dual Site Groundwater remedy. In 2013,
under EPA oversight, Montrose began constructing the groundwater treatment system, which
includes groundwater extraction and injection wells and a groundwater treatment plant located on
the former Montrose plant property at 20201 South Normandie Avenue. Operational testing of the
system occurred in 2015, but the system was determined to be not operating properly. The
treatment system was redesigned and portions reconstructed. Montrose started continuous
operation of the extraction and treatment system at low pumping rates in February 2019 (EPA,
2019).
2.7.1.2 Adjacent/Surrounding Land Use
As mentioned previously, the former Montrose plant property is bounded by the UPRR right-of-
way and South Normandie Avenue to the east, the JCI property and a right-of-way owned by
LADWP to the south, the former Boeing Realty Corporation property to the north, and Frito- Lay,
Inc., to the west (Figure 1-2). The former Farmer Brothers property is located south of the LADWP
right-of-way. The land use up to approximately 1 mile north and east of the former Montrose plant
property, and approximately 1/2 mile west, is zoned for industrial and commercial use. The area
east of the former Montrose plant property is occupied by manufacturing and commercial facilities.
The area to the west is occupied by manufacturing and an oil refinery. Land uses south and
southeast of the former Montrose plant property are mixed manufacturing, commercial, and
residential. Residential areas are located at distances of about 800 to 1,000 feet from the former
CPA.
2.7.2 Groundwater Use and Potential Threat to Water Supply
2.7.2.1 Groundwater Use
The State of California designates all water-bearing hydrostratigraphic units beneath the Montrose
Superfund Site (including units beneath the former Montrose plant property) as having potential
potable beneficial use (that is, they are a potential source of drinking water). Therefore, EPA
considers drinking water standards (maximum contaminant levels, or MCLs) to be relevant and
45
-------
appropriate requirements for in-situ cleanup of groundwater in this area (Section 9 of the OU-3
Dual Site Groundwater ROD [EPA, 1999]). As discussed previously, EPA issued a TI Waiver
for attainment of drinking water standards in the immediate vicinity of the DNAPL beneath and
adj acent to the former Montrose plant property. This created a TI Waiver Zone where groundwater
contamination within the area is not required to be restored to drinking water standards. The plume
of dissolved contaminants in groundwater outside the TI Waiver Zone, however, must be restored
to drinking water standards as described in the OU-3 Dual Site Groundwater ROD (EPA, 1999).
There are currently no known municipal or private potable production wells in use within the area
of contaminated groundwater at the Montrose Superfund Site. The nearest municipal supply wells
are about 1/2 to 1 mile downgradient of the current leading edge of groundwater contamination
related to the Montrose Superfund Site. These wells are screened primarily in the Silverado
aquifer, although some are screened in the Lynwood aquifer. These deeper aquifers are not
currently impacted by groundwater contamination. Wells within a 2-mile radius of the Montrose
Superfund Site are shown on Figures 2-16 and 2-17.
2.7.2.2 Potential Threat to Public Water Supply
Site investigation data indicate the majority of DNAPL resides in the UBA. However, recent data suggest
that DNAPL may have also migrated into the BFS. Mobile DNAPL migration into the deeper
aquifers will cause a further increase in the concentration of dissolved contaminants such as
chlorobenzene or pCBSA, and may cause further spreading of dissolved contaminant plumes
laterally and vertically. Groundwater contamination from the DNAPL source may continue to
move both laterally outward and vertically downward, and eventually reach locations where it
could be drawn into potable water wells. As dissolved contamination migrate, less of the
groundwater resource can be used in the future. The laws and policies of the State of California
are generally focused on protecting potential future beneficial uses of groundwater, even where it
is not currently used. In addition, the NCP requires that EPA consider future potential groundwater
uses in making decisions on remedial actions for groundwater. Without groundwater
contamination related to the Montrose Superfund Site, deeper groundwater aquifers beneath this
area (the Gage, Lynwood, and Silverado aquifers) would be of sufficient water quality and
production to make them strong candidates for sources of drinking water.
The groundwater remedy required by the OU-3 Dual Site Groundwater ROD (EPA, 1999) is being
developed to contain the dissolved contamination originating from the DNAPL source and to
remediate groundwater to the in-situ groundwater standards outside the TI Waiver Zone. The OU-
3 Dual Site groundwater remedy is performed under a different OU and is not the subject of this
document. However, the remedial action for the DNAPL OU is required by the Groundwater OU
ROD to support the remedy for the Dual Site Groundwater OU and the future OU-1 remedy, by
removing mobile DNAPL mass to limit the migration of DNAPL to areas outside the TI Waiver
Zone.
46
-------
\
MADRID PM—3 .CLUSTER
4S/14W—2N1
4SX14W-2N2
~ 4S714W-2N3
4S/14W-2N4
766A
ORRANCE
#4)
\
\
\
%
\
\
STUDY AREA
~
CARSON STREET
DOMINGUEZ 219-
(4S/13W—17D3)
4S/14W—14J1
\ TORRANCE #7
(4S^14W-14K.
#
\
)
TORRANCE #8
(4S/14W—14J2)
CARSON—2 CLUSTER
4S/13W-18K1
4S/13W-18K2
4S/13W-18K3
4S/13W-18K4
4S/13W-18K5
~
\
DOMINGUEZ 279-D1
~
835E
4S/14W-14K2
EXPLANATION
MUNICIPAL PUBLIC WATER SUPPLY WELL
OBSERVATION OR TEST WELL
WELL NUMBERING SYSTEM USED BY LOS ANGELES COUNTY
DEPARTMENT OF PUBLIC WORKS (LACDPW), FORMERLY
LOS ANGELES COUNTY FLOOD CONTROL DISTRICT (LACFCD)
WELL NUMBERING SYSTEM USED BY THE STATE OF
CALIFORNIA, DEPARTMENT OF WATER RESOURCES
NOTE: DOES NOT INCLUDE MONITOR OR DESTROYED WELLS.
4,000
MONTROSE CHEMICAL CORPORATION
OF CALIFORNIA
TORRANCE, CALIFORNIA
HARGI5+ASSOCIATES/1N C.
H ydrogeol ogy/En g in eerin g
03/04
PREP BY GTC REV BV MAP RPT NO. 85/.17 410-4554 A
SOURCE: Montrose Production Well Survey Report (Hargis + Associates, 2004).
Figure 2-16
Well Locations
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
#/
% p„0^
47
-------
SAN DIEGO FRWV
STUDY AREA
794C,
794B
794A (
INTERNATIONAL
UGHT
METALS
TOCO
INDUSTRIES-
CAPITOL
METALS
B24A
FORMER
FARMER
BROTHERS
204th STREET
TORRANCE LATERAt.
TORRANCE BLVD
785D
785A
TORRANCE LATERAL
CARSON STREET
BQ6A
797A
827D
798H
EXPLANATION
• MUNICIPAL PUBLIC WATER SUPPLY WELL
¦ INDUSTRIAL SUPPLY WELL
~ DOMESTIC WELL
O IRRIGATION WELL
~ OBSERVATION OR TEST WELL
A WELL OF UNKNOWN USE
785A WELL NUMBERING SYSTEM USED BY LOS ANGELES COUNTY
DEPARTMENT OF PUBLIC WORKS (LACDPW), FORMERLY
LOS ANGELES COUNTY FLOOD CONTROL DISTRICT (LACFCD)
4-S/14W—14K2 WELL NUMBERING SYSTEM USED BY THE STATE OF
CALIFORNIA, DEPARTMENT OF WATER RESOURCES
o
DESTROYED WELLS
PRESUMED ABANDONED OR DESTROYED WELLS
NOTE: DOES NOT INCLUDE MONITOR OR DESTROYED WELLS
LESS THAN 50 FEET DEEP.
MONTROSE CHEMICAL CORPORATION
OF CALIFORNIA
TORRANCE, CALIFORNIA
HARGIS+ASSOCIATE5/ INC
H ydrog eol ogy/ En g in eerin g
03/04
PREP by RAN REV by MAP RPT NO. 857.17 410-4551 A
SOURCE: Montrose Production Well Survey Report (Hargis + Associates, 2004).
Figure 2-17
Destroyed Wells
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
48
I w/
-------
2.8
SUMMARY OF SITE RISKS
Based on the land and groundwater uses described above, DNAPL at the Montrose Superfund Site
does not currently pose a direct exposure risk to human or ecological receptors. Institutional
controls (ICs) will ensure that human receptors do not come into contact with DNAPL in the
subsurface and OU-1 will address soil and soil gas contamination within the top 10 ft of soil
beneath the Montrose Site.
However, mobile DNAPL is the principal threat at the Montrose Superfund Site because it
continues to dissolve into the groundwater, and serves as a long-term source of chlorobenzene and,
to a lesser degree, other contaminants to groundwater and soil vapor. The groundwater remedy for
the Dual Site Groundwater OU is designed to contain and remediate the dissolved plume.
However, mobile DNAPL present at the former Montrose plant property may continue to migrate
laterally and vertically within the subsurface under gravitational forces. This includes migration
outside the TI Waiver Zone and to deeper drinking water aquifers, which could impact the
performance and protectiveness of the OU-3 Dual Site Groundwater remedy. If DNAPL migrates
to areas outside of the TI Waiver Zone, it would provide a continuous source of chlorobenzene to
groundwater, which could jeopardize restoration of groundwater outside of the TI Waiver Zone.
The dissolution of DNAPL may cause further migration of dissolved groundwater contamination
into deeper aquifers and, possibly, toward potable water supply wells. Mobile DNAPL also may
cause additional volatilization of VOCs from the DNAPL into soil vapor, which could result in
risk from the vapor intrusion pathway.
Basis for Action
The primary basis for undertaking this action at the Site is the threat to the groundwater resource
underlying the Site. Mobile DNAPL poses as a source of contamination to the groundwater. The
remedy selected in this document is focused on the removal of mobile DNAPL to ensure protection
of human health and the environment by supporting the success of the OU-3 Dual Site
Groundwater remedy and future OU-1 remedy.
The response action selected in this ROD is necessary to protect the public health or welfare or the
environment from actual or threatened releases of hazardous substances into the environment.
2.9 REMEDIAL ACTION OBJECTIVES AND REMEDIATION GOALS
As discussed in previous sections, a significant mass of DNAPL is present beneath the former
Montrose plant property. While the DNAPL provides no immediate risk to human and ecological
receptors, mobile DNAPL remains a threat to groundwater. Site-related contaminants may readily
migrate through unsaturated soil, and DNAPL beneath the water table will remain as an ongoing
source of dissolved- and vapor-phase contaminants. Therefore, removing subsurface mobile
DNAPL is a critical component in preserving the groundwater resource and ensuring protection of
human health and the environment by supporting the success of the OU-3 Dual Site Groundwater
remedy and the future OU-1 remedy. While the RAOs for the DNAPL OU remedy discussed in
this document rely on the long-term containment of contaminated groundwater under the OU-3
Dual Site Groundwater remedy, groundwater containment is not a part of the remedial action for
the DNAPL OU.
49
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In the OU-3 Dual Site Groundwater ROD, EPA recognized that "it will not be practicable to
remove enough (virtually all) DNAPL so as to attain drinking water standards in the immediate
vicinity of the DNAPL" (EPA, 1999). For this reason, EPA waived the requirement to attain
cleanup levels for groundwater located beneath the former Montrose plant property and
subsequently established a TI Waiver Zone encompassing the DNAPL-impacted soil and
groundwater. Specifically, in establishing the TI Wavier Zone, the OU-3 Dual Site Groundwater
ROD waived the following ARARs relating to drinking water standards due to technical
impracticability:
1.Federal Primary Drinking Water Standards (40 CFR Part 141)
2.California ARARs:
a. California Primary Drinking Water Standards (22 CCR Sections 64431 and 64444)
b.California Secondary Drinking Water Standards (22 CCR Section 64449)
c.California Notification Levels (Health and Safety Code Section 116455)
ARARs and to be considered (TBC) criteria were evaluated during the DNAPL FS. The ARARs
for the selected remedy are listed in Appendix E. The RAOs and remediation goals for the DNAPL
OU remedy are discussed below.
2.9.1 Remedial Action Objectives
The goals of the remedial action for the DNAPL OU are to remove mobile DNAPL within the TI
Waiver Zone to reduce DNAPL mass, minimize potential DNAPL mobility, and prevent further
migration of DNAPL in the subsurface. The removal of mobile DNAPL will result in protection
of human health and the environment through the support of the OU-3 Dual Site Groundwater
remedy and the future OU-1 remedy and will decrease the uncertainty associated with the success
of the OU-3 Dual Site Groundwater remedy. Given these considerations, the RAOs for the DNAPL
OU are specified in terms of DNAPL mobility and mass reduction, since mobile DNAPL mass
which could migrate outside of the containment area poses a greater threat to human health and
the environment than DNAPL that is immobile. The remediation endpoint is premised on reducing
DNAPL saturation below the threshold where it may be mobilized by gravity or hydraulic
displacement.
The RAOs for the DNAPL OU are as follows:
1. Prevent human exposure to DNAPL constituents (via ingestion, inhalation, or dermal contact)
that would pose an unacceptable health risk to on- or off-property receptors under industrial
land uses of the former Montrose plant property and adjacent properties.
2. To the extent practicable, limit uncontrolled lateral and vertical migration of mobile DNAPL
under industrial land use and hydraulic conditions in groundwater.
3. Increase the probability of achieving and maintaining containment of dissolved-phase
contamination to the extent practicable, as required by the existing OU-3 Dual Site
Groundwater ROD, for the time period that such containment remains necessary.
4. Reduce mobile DNAPL mass to the extent practicable.
5. To the extent practicable, reduce the potential for recontamination of aquifers that have been
restored by the groundwater remedial actions, as required by the OU-3 Dual Site Groundwater
ROD, in the event containment should fail.
50
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6. To the extent practicable, reduce the dissolved-phase concentrations within the containment
zone over time.
For the site-specific conditions, analytical testing indicated that a DNAPL saturation greater than
27 percent in sands or 15.8 percent in silts may be considered mobile. Because DNAPL at the
Montrose Superfund Site is composed of approximately 50 percent DDT and 50 percent
chlorobenzene, chlorobenzene concentrations above 27,900 mg/kg in sand and 17,000 mg/kg in
silts may represent mobile DNAPL and are considered to be a remediation goal for the DNAPL
OU remedy.
A performance verification program will be implemented to assess whether remediation goals of
removing mobile DNAPL are met by the selected remedy.This program will include soil
verification sampling to verify that chlorobenzene concentrations have been reduced to, or below,
residual saturations. For the SVE system, risk-based cleanup goals will be used for residual VOCs
in soils. The SVE system will be optimized during operations to ensure air flow throughout the
treatment area, and rebound testing will be performed. Confirmation soil borings will be collected
and aid in the determination of SVE completion. The VOC mass removal rate, and the cost-benefit
of continuing SVE operations also will be considered. Specific measurements of temperature
throughout the treatment area, power density, and specific time at co-boiling temperature, were
successfully used during the ERH Pilot Study and will be used as part of the performance
verification for the Focused Treatment Area remediation (TRS, 2019).
The performance monitoring program will also be designed to assess potential adverse impacts of
the remedy on groundwater quality. For example, ERH may increase the potential for vertical
DNAPL migration during remedy implementation, and therefore monitoring for chlorobenzene
concentrations below the treatment zone (in the BFS) will be included in the performance
monitoring. Other monitoring parameters will also be evaluated and included in the performance
monitoring program, as appropriate. Dissolved-phase groundwater contaminants migrating from
the thermal treatment area will be captured by the groundwater extraction and treatment system
under the OU-3 Dual Site Groundwater remedy. Details regarding performance monitoring will
be provided in the remedial action process.
2.10 DESCRIPTION OF REMEDIAL ALTERNATIVES
A total of nine remedial alternatives were developed to address DNAPL at the Montrose Site.
Table 2-3 lists the alternatives and DNAPL treatment technologies associated with each and a
description of each alternative is provided in Sections 2.10.1 through 2.10.9 below. The nine
alternatives are:
• Alternative 1 - No Action
• Alternative 2 - ICs
• Alternative 3 - ICs and SVE (Unsaturated Zone)
• Alternative 4A - ICs, SVE (Unsaturated Zone), and HD with Untreated Water Injection
• Alternative 4B - ICs, SVE (Unsaturated Zone), and HD with Treated Water Injection
• Alternative 5A - ICs, SVE (Unsaturated Zone), and Steam Injection for Focused Treatment
51
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Area with Hot Floor
• Alternative 5B - ICs, SVE (Unsaturated Zone), and Steam Injection for Entire DNAPL Area
with Hot Floor
• Alternative 6A - ICs, SVE (Unsaturated Zone), and ERH for Focused Treatment Area without
Hot Floor
• Alternative 6B - ICs, SVE (Unsaturated Zone), and ERH for Entire DNAPL Area without Hot
Floor
Table 2-3: Remedial Alternative Component Summary
Montrose Superfund Site, Torrance California
Remedial
Alternative/Technology
Institutional
Controls
SVE
Unsaturated Zone
o
n
HD with Treatment
Steam Injection
Focused Treatment
Steam Injection
Entire DNAPL
ERH
Focused Treatment
ERH
Entire DNAPL Area
Alternative 1—No Action
Alternative 2—ICs
X
Alternative 3—ICs and SVE
(Unsaturated Zone)
X
X
Alternative 4A—ICs, SVE
(Unsaturated Zone), and HD with
Untreated Water Injection
X
X
X
Alternative 4B—ICs, SVE
(Unsaturated Zone), and HD with
Treated Water Injection
X
X
X
Alternative 5A—ICs, SVE
(Unsaturated Zone), and Steam
Injection for Focused Treatment Area
with Hot Floor
X
X
X
Alternative 5B—ICs, SVE
(Unsaturated Zone), and Steam
Injection for Entire DNAPL Area with
Hot Floor
X
X
X
Alternative 6A—ICs, SVE
(Unsaturated Zone), and ERH for
Focused Treatment Area without Hot
Floor
X
X
X
Alternative 6B—ICs, SVE
(Unsaturated Zone), and ERH for
Entire DNAPL Area without Hot Floor
X
X
X
HD - Hydraulic Displacement
ERH - Electrical Resistance Heating
SVE - Soil Vapor Extraction
52
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As mentioned previously, hydraulic containment within the TI Waiver Zone is a component of the
OU-3 Dual Site Groundwater remedy. Thus, it is not a component of the DNAPL OU remedy
selected in this document. The DNAPL FS developed by Montrose (AECOM, 2013), however,
includes the cost of hydraulic containment for all DNAPL remedial alternatives considered.
Therefore, the estimated cost of hydraulic containment must be excluded from the total remedy
costs presented in the DNAPL FS. Hydraulic containment is not a component of any of the nine
remedial alternatives for the DNAPL OU and is not discussed or further considered in this
document.
Two general response actions limiting groundwater use have been selected as part of the OU-3
Dual Site Groundwater remedy and will be implemented regardless of which remedial alternative
is selected for the DNAPL OU:
1. Limitations on groundwater and Site use will be implemented in the form of deed restrictions
to prevent exposure to groundwater impacted by DNAPL constituents, specifically
chlorobenzene.
2. Groundwater monitoring will be implemented as part of the groundwater remedy and will
document the effectiveness of the hydraulic containment program.
The components and costs of candidate remedial alternatives for DNAPL are summarized in the
following sections.
2.10.1 Alternative 1 - No Action
Under this alternative, no action would be taken to reduce DNAPL mass or mobility, or to comply
with the DNAPL RAOs, other than those actions required by the OU-3 Dual Site Groundwater
remedy and the future OU-1 remedy. The No Action Alternative is required by the NCP to provide
a baseline for comparison of the costs and benefits of other alternatives.
Cost. By definition, there is no cost associated with the No Action Alternative.
2.10.2 Alternative 2 - ICs
This remedial alternative includes the following element:
• A land use covenant (deed restriction) would be established to prevent access to DNAPL-
impacted soils and restrict future activities at the former Montrose plant property for industrial use
only. This would include limitations on construction, excavation, and drilling activities. Site access
is currently restricted by perimeter fencing and warning signs. These access restrictions would
remain in place and continue to be monitored as part of an annual site inspection and maintenance
program to ensure restrictions are in place and functioning. ICs for DNAPL would be limited to
DNAPL-impacted areas including the former Montrose plant property.
ICs are also a component of Alternatives 3 through 6a, so the ICs described here are also applicable
to these other remedial alternatives.
Duration. ICs would remain in place as long as contamination preventing unrestricted use is
present at the Site.
Performance Monitoring and Verification. Annual site inspection and maintenance would be
conducted to ensure ICs are in place and functioning as intended.
53
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Cost. Estimated capital and operations cost for this alternative are summarized in Table 2-4.
Table 2-4: Alternative 2—ICs Cost Summary
Montrose Super fund Site, Torrance, California
Activity
Cost
(NPV)1
Deed Restriction and Sign Installation - On Property
$ 110,577
Deed Restriction Renewal Fence/Signage Maintenance
$ 4,623
Deed Restriction Renewal Fence/Signage Maintenance (year 3 to 30)
$ 1,542
Net Present Value at 30 Years '
$ 116,742
Note:
The net present value (NPV) calculation is based on a discount rate of 4 percent.
2.10.3 Alternative 3 - ICs and SVE (Unsaturated Zone)
This remedial alternative includes the following:
• ICs as described above in Section 2.10.2 for Alternative 2.
• SVE to extract and treat VOCs from permeable unsaturated soils would be implemented in the
unsaturated zone between approximately 10 and 60 feet bgs; more than 400,000 pounds of
chlorobenzene are estimated to be present within this target treatment area. The conceptual
design of the SVE system would include a series of extraction wells positioned throughout the
VOC- and DNAPL-impacted unsaturated zone. The spacing between wells is based on pilot
test observations. Because subsurface conditions exhibited different flow properties in pilot
testing, two sets of wells would be installed: one set of wells for extraction from the low-
permeability PD, and one set of wells for extraction from the high- permeability unsaturated
sands (Figures 2-18 and 2-19). Alternative 3 assumes that 23 SVE wells would be required for
DNAPL treatment and VOC removal from the unsaturated zone. The SVE wells are assumed
to be screened over a discrete interval of 25 to 45 feet bgs for permeable sands, and over
intervals of 10 to 25 and 45 to 60 feet bgs for lower-permeability soils in the unsaturated
portion of the UBA. An aboveground piping network would connect the SVE wells to an ex-
situ extraction and treatment system located at the former Montrose plant property.
Soil vapor would be extracted using a blower; the estimated total SVE flow rate would be
approximately 1,500 standard cubic feet per minute (scfm). Suspended particulates would be
filtered, and entrained moisture would be separated or condensed. Soil vapors would then be
passed to a treatment system for removal or destruction of the VOC contaminants prior to
atmospheric discharge. Figure 2- 20 provides a process flow diagram of the conceptual SVE
system. Three different soil vapor treatment process options were retained for analysis,
including:
-Disposable granular activated carbon (GAC)/resin;
-Steam-regenerable GAC/resin; and
54
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Legend:
Location of Current Montrose Property
Boundary
Parcel Boundary / Right-of-Way
¦—¦— Surveyed Fence Line
iiiiiiiiiiiiiiiiiiiiiiiiii Existing Railroad Tracks
iiiiiiiiiiiiiiiiiiiiiiiiii Former Railroad Tracks
I I Existing Building
LADWP Los Angeles Department of Water and Power
Soil Boring Location
Monitoring Well Location
Maximum MCB Isoconcentration in
Soil Contour Interval 10-100 mg/kg
Maximum MCB Isoconcentration in
Soil Contour Interval 100-1000 mg/kg
Maximum MCB Isoconcentration in
Soil Contour Interval 1000-10,000 mg/kg
Maximum MCB Isoconcentration in,
Soil Contour Interval >10,000 mg/kg
DNAPL Present
d, DNAPL Present in Vadose Zone
Boring Location
O SVE Pilot Test Well Location
+ Pilot Test Monitoring Point Location
/ \ Radius of Influence (103 Ft.)
I •"-1 Palos. Verdes.Sands
y
(Number of Wells = 7)
References:
1.
2.
3.
4.
Parcel Boundary Information from Los Angeles,
CA, Department of Public Works, Online Arclnfo
GIS data set, 2004. Montrose Chemical Corporation
Boundary Survey conducted August 13, 2001 by
Dulin—Boynton Land Surveyors.
Satellite/Aerial Photos Reference:
Urban Areas Georeferenced Satellite Imagery,
March 29, 2004.
DNAPL Present Contour from Hargis & Assoc., Inc,.
Technical Memorandum Addendum 2 to the Results
of DNAPL Reconnaissance Investigation, Montrose
Site, Torrance, CA to the EPA dated February 20, 2008.
Source: AECOM, 2011; Earth Tech, 2008j; Earth
Tech, 2007b; Earth Tech, 2008g; Earth Tech,
2004a; EPA, 1998; H+A, 2004b; H+A, 2006a;
H+A, 2008b
l\
NORTH
60 120 FEET
SCALE; 1"- 120'
Montrose Chemical Corporation
Date: 12-11
Project No.
60212541
Montrose Superfund Site
AICOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-18
Conceptual SVE Wells, Palos Verdes Sands,
Radius of Influence: 103 Feet
DNAPL OU Record of Decision
U. S. EPA Region IX \ \N|/V J
Montrose Superfund Site, Los Angeles, California % PK0^
55
-------
Legend:
Location of Current Montrose Property
Boundary
Parcel Boundary / Rtght-of-Way
¦ Surveyed Fence Line
iiiiiiiiiiiiiiiiiiiiiiiiii Existing Railroad Tracks
iiiiiiiiiiiiiiiiiiiiiiiiii Former Railroad Tracks
I I Existing Building
LADWP Los Angeles Department of Water and Power
Soil Boring Location
Monitoring Well Location
Maximum MCB Isoconcentration in
Soil Contour Interval 10-100 mg/kg
Maximum MCB Isoconcentration in ,
Soil Contour Interval 100-1000 mg/kg
Maximum MCB Isoconcentration in
Soil Contour Interval 1000-10,000 mg/kg
Maximum MCB Isoconcentration in,
Soil Contour Interval >10,000 mg/kg
DNAPL Present
DNAPL Present in Vadose Zone
Boring Location
O SVE Pilot Test Well Location
+ Pilot Test Monitoring Point Location
^ Radius of Influence J52 Ft.)
Unsaturated Upper Bellflower Aquitard and
Playa Deposits (Number of Wells = 16)
References:
1. Parcel Boundary Information from Los Angeles,
CA, Department of Public Works, Online Arclnfo
GIS data set, 2004. Montrose Chemical Corporation
Boundary Survey conducted August 13, 2001 by
Dulin—Boynton Land Surveyors.
2. Satellite/Aerial Photos Reference:
Urban Areas Georeferenced Satellite Imagery,
March 29, 2004.
3. DNAPL Present Contour from Hargis & Assoc., Inc..
Technical Memorandum Addendum 2 to the Results
of DNAPL Reconnaissance Investigation, Montrose
Site, Torrance, CA to the EPA dated February 20, 2008.
4. Source: AECOM, 2011; Earth Tech, 2008J; Earth
Tech, 2007b; Earth Tech, 2008g; Earth Tech,
2004a; EPA, 1998; H+A, 2004b; H+A, 2006a;
H+A, 2008b
A
NORTH
0 60 120 FEET
SCALE: 1"- 120'
Montrose Chemical Corporation
Date: 12-11
Project No.
60212541
Montrose Superfund Site
AICOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-19
Conceptual SVE Wells, Upper Bellflower Aquitard
and Playa Deposits, Radius of Influence 52 Feet
DNAPL OU - Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
^tDS%
# o \
\ SBZ/
Kay
56
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Legend:
PID PHOTO IONIZATION DETECTOR
TRANSFER PUMP
MOISTURE
SEPARATOR
(700 SCFM EXTRACTED
VAPOR, 7 WELLS)
ORIFICE
PLATE
POSITIVE DISPLACEMENT
VACUUM BLOWER
25 FEET
45 FEET
TYPICAL
PALOS VERDES SANDS
SVE WELL
(800 SCFM EXTRACTED
VAPOR, 16 WELLS)
10 FEET
25 FEET
45 FEET
60 FEET
VENT TO
ATMOSPHERE
PID
Notes:
SCFM
VGAC
STANDARD CUBIC FEET PER
VAPOR-PHASE GRANULAR
ACTIVATED CARBON
PLAYA DEPOSITS SCREENED WHERE SILTY
SANDS ARE PRESENT
DISCHARGE
STACK
TO GROUNDWATER
TREATMENT SYSTEM
FOR PROCESSING
AND RE-INJECTION
TYPICAL
UPPER BELLFLOWER AQUITARD
AND PLAYA DEPOSITS
SVE WELL
Montrose Chemical Corporation
Date: 12-11
Montrose Superfund Site
Project No.
60212541
AECOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-20
Conceptual Soil Vapor Extraction Process Flow Diagram
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
$ A \
las;
57
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-Thermal oxidation with acid-gas scrubbing.
Both of the GAC/resin-type process options remove VOC contaminants from the vapor stream via
adsorption. The thermal oxidation process option destroys VOC contaminants at elevated
temperatures, converting them to carbon dioxide, water vapor, and acid gas. The acid gas is
subsequently quenched, and pH neutralized prior to discharge. The specific vapor treatment
method will be selected during the future remedial action process.
Duration. SVE operations would continue for a period of approximately three to five years until
VOC concentrations in soil gas decline to low asymptotic levels. This duration of SVE operations
reflects approximately 5,000 pore volumes of soil vapor flushing within the treatment area. Given
the lower-permeability nature of some unsaturated soils at the Site, the presence of DNAPL, the
proximity of groundwater in the unsaturated UBA, and the relatively low vapor pressure of
chlorobenzene, it is expected that SVE operations will require more time to achieve the cleanup
goals than is typically required by SVE projects.
• Year 1 = Design
• Year 2 = Construction
• Years 3-6 = O&M (four years)
• Year 7 = Verification, rebound testing and potential Decommissioning/Abandonment
ICs would remain in place as long as contamination preventing unrestricted use is present at the
Site, as discussed in Section 2.10.2 for Alternative 2.
Performance Monitoring and Verification. A series of soil vapor monitoring points and/or wells
would be used to monitor the performance of the SVE system between and surrounding the
extraction wells. In order to monitor the vacuum influence within each of the three distinct
unsaturated zone layers, three nested monitoring points would be constructed at each location
within a single borehole. The points would be used to monitor vacuum influences both laterally
within the extraction wellfield, and vertically within each of the three unsaturated soil layers. The
monitoring points will demonstrate vacuum influence throughout the target treatment area,
including along the northern property boundary where VOCs in soil gas were detected at
concentrations exceeding industrial screening levels.
The concentration of VOCs in soil gas within the monitoring points also would be tested routinely
to demonstrate a reduction in VOC concentrations over time. To confirm the reduction in adsorbed
VOC concentrations, soil borings would be drilled and samples collected to verify the
effectiveness of the SVE remedy in the unsaturated zone. Residual VOC concentrations in soil
would be compared to risk-based cleanup goals. Residual VOCs from the low-permeability PD
and underlying groundwater surface will slowly volatilize into soil gas during SVE operations,
even though these VOC sources are not the objective of the SVE remedial action. Therefore, the
decision criteria for terminating SVE operations in the unsaturated zone would be based on the
adsorbed concentration of VOCs remaining in soil, the vertical concentration trend in the target
treatment zone, the VOC mass removal rate, and the cost-benefit of continuing SVE operations.
The decision criteria for termination of SVE will be specified in the remedial action process.
Cost. The estimated cost for SVE in the unsaturated zone under Alternative 3 (i.e., not coupled
with in-situ thermal treatment of the saturated UBA) is summarized in Table 2-5.
58
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Table 2-5: Alternative 3—ICs and SVE (Unsaturated Zone) Cost Summary
Montrose Superfund Site, Torrance, California
Activity
Cost (NPV)1
Institutional Controls
$ 192,229
Design
$ 186,538
Well Construction
$1,340,719
Wellfield Equipment Installation
Treatment Equipment Installation
Construction Management
Operation and Maintenance - Year 3 (1 of 4 years)
$ 1,102,661
Operation and Maintenance - Year 4 (2 of 4 years)
$713,323
Operation and Maintenance - Year 5 (3 of 4 years)
$ 575,585
Operation and Maintenance - Year 6 (4 of 4 years)
$ 489,724
Well Abandonment
$221,731
Demobilization
Total NPV at Seven Years'
$4,822,510
Note:
1 The NPV calculation is based on a discount rate of 4 percent.
2.10.4 Alternative 4A—ICs, SVE (Unsaturated Zone), and HD with Untreated Water
Injection
This remedial alternative includes the following:
• ICs as described in Section 2.10.2 for Alternative 2.
• SVE as described in Section 2.10.3 for Alternative 3.
• HD, where groundwater is simultaneously extracted and injected to induce hydraulic gradients
to mobilize DNAPL towards extraction wells, would be implemented over an area of 26,000
ft2 within the saturated UBA where mobile DNAPL is believed to be present. This treatment
area was estimated based on the known occurrence of mobile DNAPL in source area wells and
chlorobenzene concentrations in saturated UBA soils exceeding 27,900 mg/kg in sands or
17,000 mg/kg in silts. As previously discussed in Section 2.6.3, DNAPL saturations of
approximately 27 percent or more in sands and 15.8 percent in silts are required for DNAPL
to be mobile.
The extraction and injection wells would be positioned in a five-spot type pattern, with four
extraction wells surrounding one injection well. Around the perimeter of the treatment area,
additional injection wells would be positioned to hydraulically flush mobile DNAPL inward,
toward the recovery wells. A conceptual HD well pattern using a 50-foot well spacing includes
23 extraction wells and 46 injection wells (including the area near soil boring SSB-12).
Injection wells also would be placed around the periphery of the focused treatment area.
Injection wells are prone to fouling; therefore, the ratio of injection wells to extraction wells
59
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was conceptually established as 2:1. Spare injection wells were incorporated into the well
pattern on the upgradient side of the mobile DNAPL extent to maintain the hydraulic gradients
mobilizing DNAPL towards extraction wells. As injection wells become fouled, they would
be redeveloped while the spare injection wells would be activated.
Because HD is a displacement technology, five hydraulic containment wells would be used to
hydraulically contain displaced groundwater and increase the certainty that an HD alternative
would not adversely impact systems operated as part of the OU-3 Dual Site Groundwater
remedy for hydraulic containment of the TI Wavier Zone. These wells would be located on
the downgradient side of the DNAPL extent to prevent the downgradient migration of DNAPL
and would be spaced approximately 80 feet apart. The wells would be screened across the
DNAPL-impacted interval ranging from approximately 60 to 100 feet bgs. The wells would
be constructed with a 5-foot sump at the bottom for DNAPL or solids accumulation.
Groundwater would be extracted at a rate of approximately 7 to 10 gallons per minute (gpm)
per extraction well using electric submersible pumps, and transferred via an aboveground
piping network to a gravity separator for DNAPL removal. Separated water would be filtered
to remove suspended solids and then reinjected without further treatment. Dissolved-phase
contaminants present in extracted groundwater would not be removed prior to reinjection. A
combined groundwater extraction and reinjection rate of approximately 150 gpm is likely
under this alternative. DNAPL accumulated in the extraction wells will be removed using low-
flow pneumatic bladder pumps and combined with DNAPL recovered in groundwater from
the gravity separator. Separated DNAPL would be transferred to the collection tank for
subsequent offsite disposal; separated groundwater would be transferred to the
groundwater/DNAPL separator for subsequent filtration and reinjection. Separated DNAPL
would be transported for offsite disposal every 90 days or less.
Duration. The duration of the HD component of the remedial alternative is assumed to be eight
years total based on the following schedule of activities:
• Year 1 = Design
• Year 2 = Construction
• Years 3-7 = O&M (five years)
• Year 8 = Verification and Decommissioning/Abandonment
ICs would remain in place as long as contamination preventing unrestricted use is present at the
Site, as discussed in Section 2.10.2 for Alternative 2. The duration of the SVE component of the
remedial alternative is assumed to be seven years, as presented in Section 2.10.3 for Alternative 3.
Performance Monitoring and Verification. The HD remedy would include a monitoring
program to evaluate remedy effectiveness. The program would include a series of monitoring wells
located throughout the HD wellfield. The monitoring wells would be gauged routinely to
demonstrate hydraulic influence from the extraction/injection wells and the absence of stagnation
zones. The monitoring wells also would be gauged for the presence of DNAPL accumulation.
The rate of DNAPL recovery from each extraction well would be monitored; once DNAPL
recovery rates had declined to zero or asymptotic levels, the HD system would be turned off.
Following system shutdown, a series of soil verification borings would be drilled at the midpoint
between the extraction and injection wells to test for residual chlorobenzene and DNAPL.
60
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Chlorobenzene concentrations would be compared against residual saturations to evaluate the
mobility of residual chlorobenzene concentrations in the saturated zone. If residual saturations
below this value are not achieved, then mobile DNAPL remains and the system would be restarted.
For costing purposes, a total of 10 soil verification borings are assumed for this remedial
alternative.
Cost. The estimated capital and operations cost for HD of DNAPL is summarized in Table 2-6.
Table 2-6: Alternative 4A—ICs, SVE (Unsaturated Zone), and HD with Untreated Water
Injection Cost Summary
Activity
Cost
(NPV)1
Institutional Controls
$ 192,229
SVE
$4,630,281
Design
$518,389
Well Construction
$ 3,235,449
Wellfield Equipment Installation
DNAPL Collection Equipment Installation
Construction Management
Operation and Maintenance - Year 3 (1 of 5 years)
$691,858
Operation and Maintenance - Year 4 (2 of 5 years)
$ 624,459
Operation and Maintenance - Year 5 (3 of 5 years)
$ 580,865
Operation and Maintenance - Year 6 (4 of 5 years)
$ 553,207
Operation and Maintenance - Year 7 (5 of 5 years)
$ 527,766
Well Abandonment
$ 533,797
Demobilization
Total NPV at Eight Years'
$ 12,088,300
Note:
1 The NPV calculation is based on a discount rate of 4 percent.
2.10.5 Alternative 4B-ICs, SVE (Unsaturated Zone), and HD with Treated Water
Injection
This remedial alternative includes the following:
• ICs as described in Section 2.10.2 for Alternative 2.
• SVE as described in Section 2.10.3 for Alternative 3.
• HD would be implemented within the saturated UBA to remove mobile DNAPL as described
in Section 2.10.4 for Alternative 4A, except groundwater would be treated prior to reinjection.
Following extraction and DNAPL separation and filtering, groundwater would be treated
onsite using a combination of liquid-phase GAC (LGAC) adsorption to remove chlorobenzene
and other VOCs and an oxidation technology to remove pCBSA. As required by the Dual Site
61
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Groundwater remedy (EPA, 1999), the removal of pCBSA would be necessary prior to
injection. As additional treatment technology (the oxidation technology) is required because
chlorobenzene and pCBSA cannot be treated with the same technologies. In preparation of the
FS, treatment efficacy of pCBSA was successfully demonstrated using HiPOx, a proprietary
oxidation technology using ozone and hydrogen peroxide. The effectiveness of the two
technologies proposed by this remedial alternative was previously demonstrated in treating the
primary dissolved contaminants present in site groundwater (Earth Tech, 2004b, 2008c).
Duration. The duration of the HD component of the remedial alternative is assumed to be eight
years total based on the following schedule of activities:
• Year 1 = Design
• Year 2 = Construction
• Years 3-7 = O&M (five years)
• Year 8 = Verification and Decommissioning/Abandonment
ICs would remain in place as long as contamination preventing unrestricted use is present at the
Site, as discussed in Section 2.10.2 for Alternative 2. The duration of the SVE component of the
remedial alternative is assumed to be seven years, as presented in Section 2.10.3 for Alternative 3.
Performance Monitoring and Verification. Performance of this alternative would be verified as
outlined above in Section 2.10.4 for Alternative 4A.
Cost. The estimated capital and operations cost for HD of DNAPL with treated water reinjection
is summarized in Table 2-7.
Table 2-7: Alternative 4B—ICs, SVE (Unsaturated Zone), and HD with Treated Water
Injection Cost Summary
Montrose Superfund Site, Torrance, California
Activity
Cost (NPV)1
Institutional Controls
$ 192,229
SVE
$4,630,281
Design
$ 650,000
Well Construction
$4,184,234
Wellfield Equipment Installation
DNAPL Collection Equipment Installation
Construction Management
Operation and Maintenance - Year 3 (1 of 5 years)
$2,182,117
Operation and Maintenance - Year 4 (2 of 5 years)
$2,084,310
Operation and Maintenance - Year 5 (3 of 5 years)
$ 1,994,082
Operation and Maintenance - Year 6 (4 of 5 years)
$ 1,907,817
Operation and Maintenance - Year 7 (5 of 5 years)
$ 1,832,831
62
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Well Abandonment
$611,387
Demobilization
Total NPV at Eight Years'
$ 20,269,288
Note:
1 The NPV calculation is based on a discount rate of 4 percent.
2.10.6 Alternative 5A - ICs, SVE (Unsaturated Zone), and Steam Injection for Focused
Treatment Area with Hot Floor
Under this remedial alternative, steam injection, which is the process of injecting pressurized steam
into the subsurface to displace and/or vaporize contaminants for recovery by multiphase extraction,
would be implemented within the saturated UBA over a Focused Treatment Area (Figure 2-21) to
thermally treat both residual and mobile DNAPL. The Focused Treatment Area is an area of
approximately 26,000 ft2 estimated to contain all areas of mobile DNAPL. The Focused Treatment
Area represents approximately 16 percent of the entire DNAPL-impacted area, but contains
between approximately 60 and 87 percent of the estimated DNAPL mass in the saturated UBA.
This remedial alternative includes the following:
• ICs as described in Section 2.10.2 for Alternative 2.
• SVE for the unsaturated PD and PVS as described in Section 2.10.3 for Alternative 3. In
addition, SVE would be implemented in the unsaturated UBA and used to recover steam and
volatilized VOCs as a component of the steam injection alternative, as described below.
• Steam injection would be implemented over the Focused Treatment Area of approximately
26,000 ft2. Steam injection and multiphase extraction wells (groundwater, DNAPL, and soil
vapors) would be installed throughout the Focused Treatment Area in either a five-spot or
seven-spot pattern. A 5-spot pattern is composed of four multiphase extraction wells, in a
square pattern, surrounding one steam injection well. A 7-spot pattern is composed of six
multiphase extraction wells, in a hexagonal pattern, surrounding one steam injection well.
System wells were assumed to be spaced 42 feet apart in a five-spot pattern. This configuration
corresponds to 14 steam injection wells and 27 multiphase extraction wells in the Focused
Treatment Area. Because the perimeter of the Focused Treatment Area is still within the entire
DNAPL-impacted area, the outer wells of the pattern would be extraction wells in order to
recover any contaminants displaced away from the Focused Treatment Area by steam
injection.
To address preferential steam flow through the highest-permeability soil layers, the system
design includes three independent injection wells at each location to control the amount of
steam delivered to each of the three intervals, as needed. Multiphase extraction wells will be
constructed using 6-inch-diameter casing and screened over the entire treatment zone of 45 to
105 feet bgs (both unsaturated and saturated UBA). A thermal barrier or "hot floor" would be
63
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implemented within the underlying BFS to mitigate the potential risk of downward DNAPL
mobilization imposed by steam injection. By heating beneath the known depth of DNAPL
occurrence, a hot floor will be created at the base of the treatment zone to prevent vertical
migration. This approach also affords an additional benefit in recovering contaminants
(potentially DNAPL) from the top portion of the BFS. The conceptual design for the hot floor
includes 20 steam injection wells and 9 multiphase extraction wells spaced 60 feet apart in a
seven-spot pattern. The wells would be screened from 110 to 115 feet bgs, and steam would
be injected into the hot floor at least 30 days in advance of heating the UBA. With a treatment
interval from 60 to 105 feet bgs, the target treatment volume for this alternative would be
43,400 cubic yards within the saturated UBA.
Displaced groundwater and DNAPL, steam and heated soil vapors would be extracted from
the subsurface and treated onsite. Soil vapors would be extracted at a rate of approximately
750 scfm using two liquid-ring vacuum blowers; extracted vapor would be cooled to condense
the steam before being delivered to the vapor treatment system. The soil vapor treatment
process options were evaluated in the DNAPL FS, but steam-regenerable carbon/resin was
considered the most applicable vapor treatment option, because the steam boiler is already
required to create steam for injection and chlorobenzene can be efficiently removed by GAC.
Groundwater and steam condensate would be extracted at a rate of approximately 75 gpm from
the multiphase wells during system operation. Extracted and condensed liquid would be treated
by a combination of GAC to remove chlorobenzene and other VOCs, and HiPOx to destroy
pCBSA through chemical oxidation processes. Reinjection of the treated water is not
fundamental to the steam injection remedy and may serve to cool the subsurface, which may
reduce the efficacy of the steam injections or reduce the temperatures of the hot floor. For this
reason, treated groundwater would be transferred to the groundwater treatment system
associated with the OU-3 Dual Site Groundwater remedy for subsequent reinjection into the
BFS and Gage aquifers.
Achieving the desired remedial objectives for this RA is predicated on the energy input to the
treatment zone. Two operating scenarios were evaluated during FS preparation: (1) low-energy
input that assumed the injection of 2.5 pore volumes of steam into the UBA, and (2) high-
energy input injection of 6 pore volumes into the UBA. Under the high-energy input, more
contamination would likely be treated within the operational timeframe, but the costs would
be increased due to the additional energy requirements.
Duration. The duration of the heating portion of this remedial alternative is estimated to be 12
months in the saturated UBA and 15 months for the hot floor, which must start prior to heating of
the saturated UBA. The duration of the thermal treatment component of this remedial alternative
is four years total under the low-energy scenario based on the following schedule of activities:
• Year 1 = Design
• Year 2 = Construction/Hot Floor Pre-Heat
• Year 3 = O&M (one year under the low-energy scenario)
• Year 4 = Verification, Rebound Testing, and Decommissioning/Abandonment
The duration of the thermal treatment component of this remedial alternative is five years total
under the high-energy scenario based on the following schedule of activities:
• Year 1 = Design
64
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• Year 2 = Construction/Hot Floor Pre-Heat
• Years 3-4 = O&M (two years under the high-energy scenario)
• Year 5 = Verification, Rebound Testing, and Decommissioning/Abandonment
ICs would remain in place as long as contamination preventing unrestricted use is present at the
Site, as discussed in Section 2.10.2 for Alternative 2. The duration of the SVE component of the
remedial alternative is assumed to be seven years, as presented in Section 2.10.3 for Alternative 3.
Performance Monitoring and Verification. Approximately 14 temperature monitoring points
would be installed throughout the Focused Treatment Area to monitor subsurface heating both
laterally and vertically. At each temperature monitoring point, thermocouples would be positioned
every 5 vertical feet from approximately 25 to 115 feet bgs to monitor temperatures both above
the treatment interval and below and within the hot floor. The key objective of thermal monitoring
is to document and record the achievement of target temperatures in the treatment interval. In
addition to subsurface temperature, the energy input and the chlorobenzene mass removal rate
would be used as a guide for determining when to conduct the soil verification sampling.
Achieving residual saturations of chlorobenzene would be expected to occur sometime after the
peak mass removal rate but before the removal rate declines to a low asymptotic level.
After the chlorobenzene mass removal rate declines to low levels and the target temperature goal
has been demonstrated, soil verification sampling would be conducted to determine if mobile
DNAPL was effectively reduced in the treatment zone below residual saturations. Residual
saturations of 27 percent or greater for sands and 15.8 percent for silts are representative of mobile
DNAPL, so residual saturations of less than that would indicate no mobile DNAPL remains. Under
this approach, 10 soil verification borings would be drilled at the midpoint between steam injection
and multiphase extraction wells. If the temperature goal was not achieved in some areas, one or
more of the verification borings would be relocated to coincide with those areas. A minimum of
six soil samples would be collected from each boring to provide sufficient post-remediation
characterization to support statistical analysis. Analyses would include VOCs by EPA Method
8260B and testing for DNAPL saturations/mobility. Sampling results would be compared against
residual saturations to ensure that remaining DNAPL is not mobile.
Cost. The estimated capital and operation costs associated with implementation of steam injection
in the Focused Treatment Area are summarized in Table 2-8.
Costs were estimated for the high- and low-energy scenarios. Since steam injection also includes
a hot floor, costs were developed for high and low steam injection associated with the hot floor
development.
The unsaturated UBA SVE system and steam injection share similar infrastructure and ex-situ
treatment requirements. Therefore, SVE costs were reduced to reflect cost savings due to combined
operation of the steam injection and SVE systems. Since the operations timeframe is tied to the
amount of energy input in the form of steam, a range of capital and operation costs for unsaturated
zone SVE was developed for the low- and high-energy scenarios developed under this remedial
alternative.
65
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Table 2-8: Alternative 5A—ICs, SVE (Unsaturated Zone), and Steam Injection for
Focused Treatment Area with Hot Floor Cost Summary
Montrose Superfund Site, Torrance, California
Activity
Low-Energy Input Cost
(NPV)1
High-Energy Input Cost
(NPV)1
Steam Injection Approach
2.5 UBA Pore Volumes and
3 Hot Floor Pore Volumes
6 UBA Pore Volumes and
7 Hot Floor Pore Volumes
Institutional Controls
$ 192,229
$192,229
SVE2
$ 2,521,673
$2,311,104
Focused Treatment Design
$ 1,243,389
$ 1,243,389
Well Construction
$ 10,788,157
$ 10,782,238
Wellfield Equipment Installation
Activity
Low-Energy Input Cost
(NPV)1
High-Energy Input Cost
(NPV)1
Instrumentation and Controls Installation
Treatment Equipment Installation
Construction Management
Hot Floor Pre-Heat
Focused Treatment Operation and Maintenance
- Year 3 (1 of 1 year for low-energy scenario;
1 of 2 years for high-energy scenario)
$ 7,800,504
$ 8,432,146
Focused Treatment Operation and Maintenance
- Year 4 (2 of 2 years high-energy scenario)
-
$ 8,062,699
Well Abandonment
$ 1,504,136
$ 1,446,284
Demobilization
Total NPV at Four (low-energy
scenario)/Five (high-energy scenario)
Years'
$ 24,050,088
$ 32,470,089
Notes:
1 The NPV calculation is based on a discount rate of 4 percent.
^ The estimated cost for SVE was significantly reduced due to concurrent implementation and operation of thermal treatment via
steam injection and SVE systems.
2.10.7 Alternative 5B - ICs, SVE (Unsaturated Zone), and Steam Injection for Entire
DNAPL Area with Hot Floor
Under this remedial alternative, steam injection would be implemented within the saturated UBA
over the entire DNAPL-impacted area to thermally treat both residual and mobile DNAPL. This
remedial alternative includes the following:
• ICs as described in Section 2.10.2 for Alternative 2.
• SVE as described in Section 2.10.3 for Alternative 3 with the addition of SVE implemented
in the unsaturated UBA and used to recover steam and volatilized VOCs as a described in
Section 2.10.6 for Alternative 5A.
• Steam injection would occur over an area of 160,000 ft2, which is the entire DNAPL-
impacted area in the UBA. Steam injection would be implemented in the same manner as
66
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described for the Focused Treatment Area (Section 2.10.6), except that the target treatment
volume would be considerably larger.
Assuming a target treatment area of 160,000 ft2, and a treatment interval from 60 to 105 feet
bgs, approximately 267,000 cubic yards within the saturated UBA would be treated under this
alternative. Steam injection and multiphase extraction wells would be installed throughout the
entire DNAPL-impacted area using the same well pattern and spacing indicated for the focused
treatment area. Assuming a five-spot pattern with 42-foot well spacing, a total of 61 steam
injection and 53 multiphase extraction wells would be required. A hot floor also would be
integrated for the entire treatment area.
The conceptual design for the hot floor includes 55 steam injection wells and 22 multiphase
extraction wells spaced 60 feet apart in a seven-spot pattern. The actual number of system wells
would be determined following completion of pilot testing as discussed below.
Steam and heated soil vapors would be extracted from the multiphase wells for onsite
treatment. Soil vapors would be extracted at a rate of approximately 2,000 scfm using three
liquid-ring vacuum blowers; extracted vapor would be cooled to condense the steam before
being delivered to the vapor treatment system. Groundwater and steam condensate would be
extracted at a rate of approximately 200 gpm from the multiphase wells and treated onsite, as
described in Section 2.10.6 for Alternative 5A. Treated groundwater would be transferred to
the groundwater treatment system associated with the OU-3 Dual Site Groundwater remedy
for reinjection into the BFS and Gage aquifers.
Because the proposed treatment area and volume are significant, a pilot test would be
implemented in advance of full-scale steam injection to confirm design parameters and
assumptions required for implementation and operation of a full-scale system. Upon
completion of pilot testing, full-scale treatment of the entire DNAPL-impacted area would be
2
initiated. The pilot test would thermally treat an area of approximately 11,000 ft and 18,300
cubic yards within the saturated UBA, would use a five-spot pattern with 42-foot well spacing,
and would include 3 steam injection and 8 multiphase extraction wells.
Similar to Alternative 5A, achieving the desired remedial objectives for this remedial
alternative is predicated on the duration of thermal treatment system operation and the
corresponding energy input to the treatment zone. Two operating scenarios were evaluated:
(l)low-energy input that assumed the injection of 2.5 pore volumes of steam into the UBA,
and (2) high-energy input injection of 6 pore volumes into the UBA.
Duration. The duration of the heating portion over the entire DNAPL-impacted area is estimated
to be 24 months. The duration of the thermal treatment component this remedial alternative is
seven years total for the low-energy scenario based on the following schedule of activities:
• Year 1 = Design/Pilot Test Construction
• Year 2 = Pilot Testing
• Year 3 = Full Scale Design
• Year 4 = Full Scale Construction/Hot Floor Pre-Heat
• Years 5-6 = O&M (two years)
• Year 7 = Verification and Decommissioning/Abandonment
67
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The duration of the thermal treatment component this remedial alternative is nine years total for the
high-energy scenario based on the following schedule of activities:
• Year 1 = Design/Pilot Test Construction
• Year 2 = Pilot Testing
• Year 3 = Full Scale Design
• Year 4 = Full Scale Construction/Hot Floor Pre-Heat
• Years 5-8 = O&M (four years)
• Year 9 = Verification and Decommissioning/Abandonment
ICs would remain in place as long as contamination preventing unrestricted use is present at the
Site, as discussed in Section 2.10.2 for Alternative 2. The duration of the SVE component of the
remedial alternative is assumed to be seven years, as presented in Section 2.10.3 for Alternative 3.
Performance Monitoring and Verification. Approximately 70 temperature monitoring points
would be installed throughout the DNAPL treatment zone to monitor subsurface heating both
laterally and vertically. Thermal remediation soil verification sampling would be conducted in the
same manner as described in Section 2.10.6 for Alternative 5A, except that 20 borings would be
drilled across the entire DNAPL-impacted area instead of only the Focused Treatment Area. To
ensure treatment of the mobile DNAPL, 10 borings would be advanced within the Focused
Treatment Area (one boring per 2,600 ft2) to target the areas of mobile DNAPL; the remaining 10
borings would be advanced outside the Focused Treatment Area where only residual DNAPL is
believed to occur (one boring per 13,400 ft2). Analyses would include VOCs by EPA Method
8260B. Sampling results would be compared against residual saturations to ensure that remaining
DNAPL is not mobile. Based on physical properties testing discussed in Section 2.6.3, DNAPL
saturations of 18.9 percent or more are required for the DNAPL to be mobile.
Cost. To capture the range of potential costs associated with energy input to the entire treatment
area, two cost scenarios were considered for the entire treatment area steam injection, including
the low-energy scenario of 2.5 pore volumes and the high-energy scenario of 6 pore volumes.
Since steam injection also includes a hot floor, similar scenarios for minimum and maximum steam
injection into the BFS were also established.
As described in Section 2.10.6 for Alternative 5A, the unsaturated UBA SVE system and steam
injection share similar infrastructure and ex-situ treatment requirements. Therefore, SVE costs
were reduced for both low- and high-energy scenarios compared to those for the SVE and HD
alternatives. The estimated capital and operation costs associated with implementation of steam
injection in the entire treatment area are summarized in Table 2-9.
68
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Table 2-9: Alternative 5B—ICs, SVE (Unsaturated Zone), and Steam Injection for
Entire DNAPL Area Cost Summary
Montrose Super fund Site, Torrance California
Activity
Low-Energy Input
Cost (NPV)1
High-Energy Input
Cost
(NPV)1
Steam Injection Approach
2.5 UBA Pore Volumes
and 3 Hot Floor Pore
Volumes
6 UBA Pore
Volumes and 7 Hot
Floor Pore Volumes
Institutional Controls
$ 192,229
$ 192,229
SVE2
$ 1,439,564
$ 1,231,679
Pre-Design
$ 2,253,454
$ 2,253,454
Pilot Test Well Construction
Pilot Test Wellfield Equipment Installation
Pilot Test Instrumentation and Controls Installation
Pilot Test Implementation
$ 2,802,649
$ 2,939,857
Full-Scale Design HAZOP Preparation,
and Permitting
$ 1,173,602
$ 1,173,602
Full-Scale Well Construction
$ 19,361,940
$ 19,361,940
Full-Scale Wellfield Equipment Installation
Full-Scale Instrumentation and Controls Installation
Full-Scale Treatment Equipment Installation
Construction Management
Hot Floor Pre-Heat
Annual Operation and Maintenance - Year 5 (1 of 2
years for low-energy scenario; 1 of 4 years for high-
energy scenario)
$ 13,537,631
$ 14,526,749
Annual Operation and Maintenance - Year 6 (2 of 2
years for low-energy scenario; 2 of 4 years for high-
energy scenario)
$ 12,841,213
$ 13,790,769
Annual Operation and Maintenance - Year 7 (3 of
4 years for high-energy scenario)
$ 13,260,355
Annual Operation and Maintenance - Year 8 (4 of
4 years for high-energy scenario)
$ 12,751,745
Well Abandonment
$ 2,901,269
$ 2,682,386
Demobilization and Project Close-Out
Total NPV at Seven (low-energy
scenario)/Nine (high-energy scenario) Years
$ 56,503,551
$ 84,164,765
Notes:
The NPV calculation is based on a discount rate of 4 percent.
2 The estimated cost for SVE was significantly reduced vs. HD alternatives because the unsaturated UBA SVE system and steam
injection share similar infrastructure and ex situ treatment requirements.
69
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2.10.8 Alternative 6A—ICs, SVE (Unsaturated Zone), and ERH for Focused Treatment
Area without Hot Floor
Under this remedial alternative, ERH, which uses an electric current sent between electrodes to
heat the soil and vaporize chlorobenzene DNAPL via electrical resistance, would be implemented
within the saturated UB A over the Focused Treatment Area of 26,000 ft2. The basis of the Focused
Treatment Area extent is the same as described in Section 2.10.6 for Alternative 5A. Alternative
6A includes the following:
• ICs as described for Alternative 2.
• SVE as described for Alternative 3 with the addition of SVE implemented in the unsaturated
UBA and used to recover volatilized VOCs as described for Alternative 5A.
• Thermal treatment using ERH would be implemented in the Focused Treatment Area of
approximately 26,000 ft2. Conceptually, ERH will target the full thickness of the UBA, from
60 to 105 feet bgs, with the target treatment volume of approximately 43,400 cubic yards. A
total of 87 ERH electrodes would be installed throughout the Focused Treatment Area on a 21-
foot spacing and in an offset linear pattern (21-foot equilateral triangles). Each row of ERH
electrodes would extend to or slightly beyond the edge of the Focused Treatment Area as
shown on Figure 2-22. A total of 57 vapor extraction wells also would be spaced in a similar
pattern, but on a 27-foot spacing. The pilot study showed that steam migrated outward from
the treatment area during ERH implementation. Volatilized contaminants could migrate away
from the treatment area during ERH with the steam. Therefore, wells will be positioned around
the perimeter of the Focused Treatment Area (even beyond the estimated extent of mobile
DNAPL) to recover volatilized contaminants along the edge of the thermal treatment area if
the need arises.
Because of differences in heating approach compared to that of steam injection and physical
properties of the UBA, the ERH thermal alternative would be implemented without a hot floor
strategy. Although the FS considered a "bottom up" heating approach would emulate
conditions offered by the hot floor methodology integrated into the steam injection alternatives,
the pilot ERH showed that this approach could hinder the recovery of contaminant vapors.
Thus, this approach would not be used during remediation.
Heated soil vapors would be extracted from the vapor extraction wells for onsite treatment.
Soil vapors would be extracted at a rate of approximately 750 scfm using blowers and cooled
to condense moisture before being delivered to the vapor treatment system. Three soil vapor
treatment process options were evaluated in the DNAPL FS, but a steam regenerable
carbon/resin system is the preferred option for the vapor treatment system. A process flow
diagram of the conceptual ERH remedial system is provided on Figure 2-23. Treated
condensate would be transferred to the groundwater treatment system associated with the OU-
3 Dual Site Groundwater remedy for subsequent reinjection into the BFS and Gage aquifers.
Volatilization is a key mechanism for chlorobenzene removal using ERH. Unlike the steam
injection thermal processes considered in Alternatives 5A and 5B, ERH would primarily
remove the chlorobenzene component of the DNAPL, leaving the DDT component in the
subsurface. DDT is insoluble in water and does not pose a significant risk to groundwater
70
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Legend:
llllllllllllllllllllllllll
llllllllllllllllllllllllll
~
LADWP
S204 •
MW002 9
PSB-7 •
DP—10 O
UBE-2®
#•
UBI-01 A
|1,000
h 0,000
, Location of Current Montrose Property
Boundary
• Parcel Boundary / Right-of-Way
Surveyed Fence Line
- Existing Railroad Tracks
• Former Railroad Tracks
Existing Building
Los Angeles Department of Water and Power
Soil Boring Location
Monitoring Well Location
Sonic Boring Location
Direct Push Boring Location
Extraction Well Location
Existing DNAPL Recovery Location
Injection Well Location
Entire DNAPL Impacted Area
DNAPL Isoconcentration in mg/kg
(MCB + Total DDT)
DNAPL Isoconcentration in mg/kg
(MCB + Total DDT)
DNAPL Isoconcentration in mg/kg
(MCB + Total DDT)
DNAPL Definite Thickness in Feet
Estimated Extent of Mobile DNAPL
Contiguous Area >53,000 mg/kg
Total Area: 25,949 Sq. Ft.
References:
1.
2.
Parcel Boundary Information from Los Angeles,
CA, Department of Public Works, Online Arclnfo
GIS data set, 2004. Montrose Chemical Corporation
Boundary Survey conducted August 13, 2001 by
Dulin—Boynton Land Surveyors.
Satellite/Aerial Photos Reference:
Urban Areas Georeferenced Satellite Imagery,
March 29, 2004.
DNAPL Present Contour from Hargis tc Assoc., Inc..
Technical Memorandum Addendum 2 to the Results
of DNAPL Reconnaissance Investigation, Montrose
Site, Torrance, CA to the EPA dated February 20, 2008.
Source: Earth Tech, 2008b
A
NORTH
0 60 120 FEET
SCALE: 1"- 120'
Montrose Chemical Corporation
Date: 12-11
Project No.
60212541
Montrose Superfund Site
AICOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-21
Focused Treatment Area, DNAPL Concentration >53,000 mg/kg
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
(s&)
% PKO^
71
-------
Legend:
, Location of Current Montrose Property
Boundary
Parcel Boundary / Right-of-Way
¦ ¦ Surveyed Fence Line
niiiiiiiiiiiiiiiiiiiiiiii Existing Railroad Tracks
iiiiiiiiiiiiiiiiiiiiiiiiii Former Railroad Tracks
I | Existing Building
Los Angeles Department of Water and Power
Soil Boring Location
Monitoring Well Location
Extraction Well Location
Injection Well Location
Entire DNAPL Impacted Area
° ET-DSP Electrode Location (101)
+ Multi-Phase Extraction Well Location (66)
21-Foot Spacing Between Electrode
Locations
Estimated Extent of Mobile DNAPL
Contiguous Area >53,000 mg/kg
Total Area: 25,949 Sq. Ft.
References:
1. Parcel Boundary Information from Los Angeles,
CA, Department of Public Works, Online Arclnfo
GIS data set, 2004. Montrose Chemical Corporation
Boundary Survey conducted August 13, 2001 by
Dulin—Boynton Land Surveyors.
2. Satellite/Aerial Photos Reference:
Urban Areas Georeferenced Satellite Imagery,
March 29, 2004.
3. DNAPL Present Contour from Hargis & Assoc., Inc..
Technical Memorandum Addendum 2 to the Results
of DNAPL Reconnaissance Investigation, Montrose
Site, Torrance, CA to the EPA dated February 20, 2008.
4. Source: Earth Tech, 2008b and 2008f
A
NORTH
0 60 120 FEET
SCALE: 1"= 120'
Montrose Chemical Corporation
Project No.
60212541
Montrose Superfund Site
AICOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
Figure 2-22
UBA Conceptual ERH Remedy Well Pattern Focused Treatment Area
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
I A \
132/
72
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LEGEND:
3,000 KVA 3-PHASE
ELECTRICAL POWER
CITY WATER - 75 GPM
(0.4 - 0.6 GPM PER ELECTRODE)
87 ERH ELECTRODE LOCATIONS
(THREE 10-FT. ELECTRODES EACH)
COOL WATER
INLET
ONE (1) 12 MM BTU's/HR
STEAM BOILER WITH
WATER PRE-TREATMENT
AMBIENT
AIR
ORIFICE
PLATE
PHOTOIONIZATION DETECTOR
TRANSFER PUMP
AUTOMATED VALVE
STEAM REGENERABLE
CARBON SYSTEM PACKAC
ORIFICE
PLATE
FIN FAN
HEAT
EXCHANGER
TYPICAL
MULTI-PHASE
EXTRACTION WELL
5,000 LB.
5,000 LB.
POLISHING
POLISHING
VGAC
VGAC
VESSEL
VESSEL
HEAT
EXCHANGER
DNAPL / WATER
SEPARATOR
GROUNDWATER
HOLDING TANK
3,000 LB.
LIQUID-PHASE
GAC VESSEL
3,000 LB.
LIQUID-PHASE
GAC VESSEL
Montrose Chemical Corporation
TO GROUNDWATER
TREATMENT SYSTEM
FOR PROCESSING
AND RE-INJECTION
Date: 12-11
Project No.
60212541
Montrose Superfund Site
AICOM
SOURCE: Revised DNAPL Feasibility Study, Montrose Superfund Site (AECOM, December 7, 2011).
73
Figure 2-23
Conceptual ERH Remedy Focused Treatment Area Process Flow Diagram
DNAPL OU Record of Decision
U.S. EPA Region IX
Montrose Superfund Site, Los Angeles, California
?' Q \
% PKO^"
-------
resources. DDT has low volatility with low solubility in water at significant depths will not pose a risk
to human health and the environment. The chlorobenzene component of the DNAPL is the
principal threat to groundwater resources; removal of chlorobenzene also will remove the
potential for future DNAPL migration.
Similar to steam injection remedial alternatives, two operating scenarios were evaluated in the
FS for Alternative 6A, including (1) low-energy input of 200 kilowatt hours (kWh), and (2)
High-energy input of 400 kWh per cubic yard. The ERH pilot study reduced chlorobenzene
concentrations to well below the mobility threshold using an average of 168 kWh per cubic
yard. The higher chlorobenzene content in the Focused Treatment Area will likely require
more energy than used in the pilot, but still the lower energy input scenario presented here is
likely to achieve the remedial goal of removing mobile DNAPL.
Duration. The duration of the heating is estimated to be 12 months. The duration of the thermal
treatment component of this remedial alternative is four years total for the low-energy scenario
based on the following schedule of activities:
• Year 1 = Design
• Year 2 = Construction
• Year 3 = O&M (one year)
• Year 4 = Verification and Decommissioning/Abandonment
The duration of the thermal treatment component of this remedial alternative is five years total for
the high-energy scenario based on the following schedule of activities:
• Year 1 = Design
• Year 2 = Construction
• Years 3-4 = O&M (two years)
• Year 5 = Verification and Decommissioning/Abandonment
ICs would remain in place as long as contamination preventing unrestricted use is present at the
Site, as discussed in Section 2.10.2 for Alternative 2. The duration of the SVE component of the
remedial alternative is assumed to be seven years, as presented for Alternative 3.
Performance Monitoring and Verification. Approximately 14 temperature monitoring points
would be installed throughout the Focused Treatment Area to monitor subsurface heating both
laterally and vertically. Thermal remediation soil verification sampling would be conducted in the
same manner as described for Alternative 5A; 10 soil verification borings would be drilled
throughout the Focused Treatment Area at the midpoint between extraction wells, and soil samples
would be analyzed for VOCs by EPA Method 8260B. Sampling results would be compared against
residual saturation to ensure that remaining DNAPL is not mobile. Based on physical properties
testing, chlorobenzene concentrations of 27,900 mg/kg in sand or 17,000 mg/kg in silts or more
are required for the DNAPL to be mobile.
Cost. The estimated capital and operation costs associated with implementation of ERH in the
Focused Treatment Area are summarized in Table 2-10. The cost was estimated for both the low-
and high-energy scenarios. As with the steam injection Alternatives 5A and 5B, a cost reduction
would be achieved by the combined application of SVE and focused thermal treatment due to
74
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similar infrastructure and ex-situ treatment requirements. Therefore, SVE costs were reduced to
reflect cost savings due to combined operation of ERH and SVE systems. Since the SVE
operations timeframe is tied to the amount of energy input in the form of electricity, a range of
capital and operation costs for unsaturated zone SVE also was developed for the low- and high-
energy scenarios.
Table 2-10: Alternative 6A—ICs, SVE (Unsaturated Zone), ERH for Focused Treatment
Area without Hot Floor Cost Summary
Montrose Superfund Site, Torrance, California
Activity
Low-Energy Input Cost
(NPV)1
High-Energy Input Cost
(NPV)1
ERH Power Density
200 kWh/cubic yard
400 kWh/cubic yard
Institutional Controls
$ 192,229
$ 192,229
SVE2
$2,521,673
$2,311,104
Focused Treatment Design
$ 1,115,673
$ 1,115,673
Well Construction
$ 9,050,943
$ 9,050,943
Wellfield Equipment Installation
Instrumentation and Controls Installation
Treatment Equipment Installation
Construction Management
Focused Treatment Operation and Maintenance -
Year 3 (1 of 1 years for low-energy scenario; 1 of
2 years for high-energy scenario)
$ 5,390,077
$ 5,390,077
Focused Treatment Operation and Maintenance -
Year 4 (2 of 2 years for high-energy scenario)
$ 5,182,767
Well Abandonment
$ 1,819,759
$ 1,749,769
Demobilization
Total NPV at Four (low-energy scenario)/Five
(high-energy scenario) Years1
$ 20,090,354
$ 24,992,562
Notes:
1 The NPV calculation is based on a discount rate of 4 percent.
2
The estimated cost for SVE was significantly reduced due to concurrent implementation and operation of thermal
treatment and SVE systems.
2.10.9 Alternative 6B—ICs, SVE (Unsaturated Zone), and ERH for Entire DNAPL
Area without Hot Floor
Under this remedial alternative, ERH would be implemented within the saturated UBA over the
entire DNAPL-impacted area to thermally treat both residual and mobile DNAPL. This remedial
alternative includes the following:
• ICs as described in Section 2.10.2 for Alternative 2.
• SVE as described in Section 2.10.3 for Alternative 3 with the addition of SVE implemented
in the unsaturated UBA and used to recover volatilized VOCs as a described in Section
2.10.6 for Alternative 5A.
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2
Thermal treatment using ERH would be implemented over an area of 160,000 ft, which is
the entire DNAPL-impacted area in the UB A. ERH would be implemented in the same manner
as described for the Focused Treatment Area, except that the target treatment volume would
be considerably larger.
Similar to other thermal remedial alternatives (Alternatives 5 A, 5B, and 6A), conceptually the
treatment interval is assumed to be from 60 to 105 feet bgs, consistent with the thickness of
the saturated UBA. The target treatment volume for this Alternative 6B would be 267,000
cubic yards within the saturated UBA. ERH electrodes and multiphase extraction wells would
be installed throughout the entire DNAPL-impacted area using the same well pattern and
spacing for the Focused Treatment Area, as described for Alternative 6A. An estimated total
of 456 ERH electrodes and 203 vapor extraction wells are estimated to be installed for thermal
treatment of the entire DNAPL-impacted area.
Heated soil vapors would be extracted from the multiphase extraction wells for onsite
treatment. Soil vapors would be extracted at a rate of approximately 2,000 scfm using blowers
and cooled to condense moisture before conveyance to the vapor treatment system. Treated
condensate would be transferred to the groundwater treatment system associated with the OU-
3 Dual Site Groundwater remedy for subsequent reinjection into the BFS and Gage aquifers.
The DNAPL FS assumed that because the proposed treatment area and volume are significant,
a pilot test would be implemented in advance of full-scale ERH to confirm design parameters
and assumptions required for implementation and operation of a full-scale system. Upon
completion of pilot testing, full-scale treatment of the entire DNAPL- impacted area would be
initiated. The pilot test would thermally treat an area of approximately 11,000 ft2 and 18,300
cubic yards within the saturated UBA. Assuming the same well spacing as for the full-scale
remedy, 30 ERH electrodes and 21 multiphase extraction wells would be installed within the
saturated UBA. However, an ERH pilot test was conducted during 2018 and 2019. Therefore,
the time period required for design and implementation of the pilot test (two year) has been
removed from the duration of Alternative 6B.
Similar to the remedial alternative for the Focused Treatment Area ERH (Alternative 6A),
two operating scenarios were evaluated for this RA: (1) low-energy input of 200 kWh, and
(2) high-energy input of 400 kWh per cubic yard.
Duration. The duration of the heating is estimated to be 24 months. The duration of the thermal
treatment component of this remedial alternative is five years for the low-energy scenario based
on the following schedule of activities:
Year 1 = Design
Year 2 = Construction
Years 3-4 = O&M (two years)
Year 5 = Verification and Decommissioning/Abandonment
The duration of the thermal treatment component of this remedial alternative is seven years for
the high-energy scenario based on the following schedule of activities:
Year 1 = Design
Year 2 = Construction
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• Years 3-6 = O&M (four years)
• Year 7 = Verification and Decommissioning/Abandonment
An ERH pilot test was conducted during 2018 and 2019. Therefore, the time period required for
design and implementation of the pilot test (two year) has been removed from the duration of
Alternative 6B. This has reduced the durations for both the low- and high-energy scenarios by
two years relative to what was presented in the DNAPL FS. ICs would remain in place as long
as contamination preventing unrestricted use is present at the Site, as discussed in Section 2.10.2
for Alternative 2. The duration of the SVE component of the remedial alternative is assumed to
be seven years, as presented for Alternative 3.
Performance Monitoring and Verification. Approximately 70 temperature monitoring points
would be installed throughout the DNAPL-impacted area to monitor subsurface heating both
laterally and vertically. Thermal remediation soil verification sampling would be conducted in
the same manner as described for Alternative 6A, except that 20 borings would be drilled across
the entire DNAPL-impacted area instead of only the Focused Treatment Area. To ensure
treatment of mobile DNAPL, 10 borings would be advanced within the Focused Treatment Area
(one boring per 2,600 ft2) to target the areas of mobile DNAPL; the remaining 10 borings would
be advanced outside the Focused Treatment Area where only residual DNAPL is believed to
occur (one boring per 13,400 ft2). Analyses would include VOCs by EPA Method 8260B.
Sampling results would be compared against residual chlorobenzene concentrations to ensure
that remaining DNAPL is not mobile. Based on physical properties testing chlorobenzene
concentrations of 27,900 mg/kg in sands or 17,000 mg/kg in silts or more are required for the
DNAPL to be mobile.
Cost. The cost was estimated for both low- and high-energy scenarios. The unsaturated UBA
SVE system and thermal options considered share similar infrastructure and ex-situ treatment
requirements as previously described. Therefore, SVE costs were reduced to reflect cost savings
due to combined operation of ERH and SVE systems. SVE costs also were estimated for the
low- and high-energy scenarios. The estimated capital and operations costs associated with
implementation of the entire treatment area ERH are summarized in Table 2-11.
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Table 2-11: Alternative 6B—ICs, SVE (Unsaturated Zone), and ERH for Entire DNAPL
Area without Hot Floor Cost Summary
Montrose Superfund Site, Torrance, California
Activity
Low-Energy
Input Cost
(NPV)1
High-Energy
Input Cost
(NPV)1
ERH Power Density
200 kWh/cubic
400 kWh/cubic
Institutional Controls
$ 192,229
$ 192,229
SVE
$ 1,439,564
$ 1,231,679
Pilot Test-Design
$ 2,276,204
$ 2,276,204
Pilot Test Well Construction
Pilot Test Well Field Equipment Installation
Pilot Test Instrumentation and Controls Installation
Pilot Test Implementation
$ 2,424,645
$ 2,424,643
Full-Scale Design HAZOP Preparation, and Permitting
$ 1,156,800
$ 1,156,800
Full-Scale Well Construction
$21,077,329
$21,077,329
Full-Scale Wellfield Equipment Installation
Full-Scale Instrumentation and Controls Installation
Full-Scale Treatment Equipment Installation
Construction Management
Operation and Maintenance - Year 3 (1 of 2 years for low-
energy scenario; 1 of 4 years for high-energy scenario)
$ 10,750,254
$ 10,717,570
Operation and Maintenance - Year 4 (2 of 2 years for low-
energy scenario; 3 of 4 years for high-energy scenario)
$ 8,382,993
$ 10,152,776
Operation and Maintenance - Year 5 (3 of 4 years for high-
energy scenario)
$ 8,028,911
Operation and Maintenance - Year 6 (4 of 4 years for high-
energy scenario)
$7,721,492
Well Abandonment
$ 4,920,969
$4,549,712
Demobilization and Project Close Out
Total NPV at Five (low-energy scenario)/Seven (high-
energy scenario) Years1
$52,620,987
$69,529,345
Notes:
1 The NPV calculation is based on a discount rate of 4 percent.
HAZOP - hazard and operability study: a structured and systematic examination of a planned or existing
process or operation in order to identify and evaluate problems that may represent risks.
2.11 COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES
In accordance with the NCP (Section 300.430(f)(5)(i)), the remedial alternatives were evaluated
against the following nine criteria:
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• Criterion 1: Overall Protection of Human Health and the Environment - This
criterion addresses whether each alternative provides adequate protection of human health
and the environment and describes how risks posed through each exposure pathway are
eliminated, reduced, or controlled, through treatment, ECs, and/or ICs. In every ROD, a
no action alternative is considered as a baseline for comparative analysis purposes. In
cases where the no action alternative is found to not meet this criterion, it is ruled out for
further consideration and therefore, need not be discussed further in the nine criteria
analyses.
• Criterion 2: Compliance with ARARs - This criterion addresses whether each
alternative complies with federal and state requirements that are applicable or relevant
and appropriate to the remedial action. Section 121(d) of CERCLA and NCP
300.430(f)(l)(ii)(B) require that remedial actions at CERCLA sites attain ARARs, unless
such ARARs are waived under CERCLA Section 121(d)4. For an alternative to pass into
the detailed analysis stage and thus become eligible for selection it must comply with its
ARARs or a waiver should be identified, and the justification provided for invoking it.
An alternative that cannot comply with ARARs or for which a waiver cannot be justified,
is eliminated from consideration for further discussion as a potential alternative in the
Proposed Plan or ROD.
• Criterion 3: Long-term Effectiveness and Permanence - Long-term effectiveness and
permanence refers to expected residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup goals have been
met. This criterion includes the consideration of residual risk that will remain onsite
following remediation and the adequacy and reliability of controls. Long-term
effectiveness and permanence of an alternative are viewed along a continuum (i.e., an
alternative can offer a greater or lesser degree of long-term effectiveness and
permanence). Alternatives that are more effective in the long term are more permanent.
• Criterion 4: Reduction of Toxicity, Mobility, or Volume through Treatment -
Reduction of toxicity, mobility, or volume through treatment refers to the anticipated
performance of the treatment technologies that may be included as part of a remedy. Each
characteristic is analyzed independently and collectively to determine how effectively
treatment is being employed by the remedial alternative. Treatment is required to satisfy
this criterion. In addition, other elements such as the risks posed by residuals are
considered.
• Criterion 5: Short-term Effectiveness - Short-term effectiveness considers the amount
of time until the remedy effectively protects human health and the environment at the site.
It also includes an evaluation of the adverse effects the remedy may pose to workers, the
community, and the environment during implementation. Possible adverse effects should
be evaluated in advance to determine mitigative steps to adequately minimize the impact
to workers, the community, or the environment and to minimize any risks that would
remain at the site.
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• Criterion 6: Implementability - Implementability considers the ease of implementing
the remedy in terms of construction and operation, and the availability of services and
materials required to implement the alternative. Technical consideration also includes the
reliability of the technology, the effect on future remedial action options, and monitoring
at the site. Variables such as the site's topography, location, and available space are
considered. Implementability is significant when evaluating treatment technologies that
are dependent on resources such as facilities, equipment, professionals or experts, and
especially technologies that have not been proven effective. In addition, administrative
feasibility, which includes activities that need to be coordinated with other offices and
agencies, is addressed when analyzing this criterion.
• Criterion 7: Cost - The cost of an alternative addresses all engineering, construction,
and O&M costs incurred over the life of the project. The assessment against this criterion
is based on the estimated present worth of these costs for each alternative. Present worth
is used to estimate expenditures that occur over different lengths of time. The costs of
remedies always are qualified as estimates with an expected accuracy of +50% to -30%.
• Criterion 8: State Acceptance - This assessment evaluates the technical and
administrative issues, concerns, and preferences the State agencies may have regarding
each of the alternatives. Resource agencies have reviewed the site documents and have
agreed with the selected remedies. Major support agency comments must be summarized
under this criterion and the lead agency's response to those comments are also
summarized.
• Criterion 9: Community Acceptance - This assessment evaluates the issues, concerns,
and preferences the public may have regarding each of the alternatives. Because
information available on the community acceptance criterion may be limited before the
public comment period for the Proposed Plan, this factor is fully evaluated in the ROD.
The nine criteria are categorized as threshold criteria, primary balancing criteria, or modifying
criteria. Threshold criteria are requirements that each alternative must meet to be eligible for
selection as the preferred alternative. The threshold criteria are 1 and 2 - overall protection of
human health and the environment and compliance with ARARs. Primary balancing criteria are
used to weigh effectiveness and cost tradeoffs among alternatives. They are the main technical
criteria upon which the alternative evaluation is based. The balancing criteria are 3 through 7 -
long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through
treatment; short-term effectiveness; implementability; and cost. Modifying criteria may be used
to modify aspects of the preferred alternative when preparing this ROD. The modifying criteria
are 8 and 9 - State acceptance and community acceptance.
The comparative analysis of the remedial alternatives based on the threshold and balancing
criteria is summarized in Table 2-12 and discussed in the following sections.
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Table 2-12: Comparative Analysis of Remedial
Alternatives Montrose Superfund Site, Torrance, California
NCP
Criterion
Alternative 1
No Action
Alternative 2
ICs
Alternative 3
ICs and SVE
(Unsaturated
Zone)
Alternative
4A
ICs, SVE
(Unsaturated
Zone), and
HD with
Untreated
Water
Injection
Alternative
4B
ICs, SVE
(Unsaturated
Zone), and
HD with
Treated
Water
Injection
Alternative
5A
ICs, SVE
(Unsaturated
Zone), and
Steam
Injection for
Focused
Treatment
Area with
Hot Floor
Alternative
5B
ICs, SVE
(Unsaturated
Zone), and
Steam
Injection for
Entire
DNAPL Area
with Hot
Floor
Alternative
6A
ICs, SVE
(Unsaturated
Zone), and
ERH for
Focused
Treatment
Area
Alternative
6B
ICs, SVE
(Unsaturated
Zone), and
ERH for
Entire
DNAPL Area
Protective of
Human Health
and the
Environment
No
Yes - Human
Health
No-
Enviromnent
Yes - Human
Health
No-
Enviromnent
Yes
Yes
Yes
Yes
Yes
Yes
Compliance
with ARARs
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Long-Term
Effectiveness
Not Effective
Not Effective
Not Effective
Less Effective
Less Effective
Effective
Effective
Effective
Effective
Mobility
Reduction
No
No
Yes
Partial
Partial
Yes
Yes
Yes
Yes
Vadose Zone
Volume
Reduction
(1,000 gallons
chlorobenzene)
Not Effective
Not Effective
Effective
Effective
Effective
Effective
Effective
Effective
Effective
0
0
27-30
27-30
27-30
27-30
27-30
27-30
27-30
Saturated Zone
Volume
Reduction
(1,000 gallons
chlorobenzene)
Not Effective
Not Effective
Not Effective
Less Effective
Less Effective
Effective
Very Effective
Effective
Very Effective
0
0
0
9-13
9-13
15-25
26-29
15-25
26-29
Short-Term
Effectiveness
Not Effective
Not Effective
Not Effective
Effective
Effective
Effective
Partially
Effective
Effective
Partially
Effective
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Table 2-12: Comparative Analysis of Remedial
Alternatives Montrose Superfund Site, Torrance, California
Alternative 1
Alternative 2
Alternative 3
Alternative
Alternative
No Action
ICs
ICs and SVE
Alternative
Alternative
5A
5B
Alternative
Alternative
6B
ICs, SVE
(Unsaturated
Zone), and
ERH for
Entire
DNAPL Area
(Unsaturated
4A
4B
ICs, SVE
ICs, SVE
6A
NCP
Criterion
Zone)
ICs, SVE
(Unsaturated
Zone), and
HD with
Untreated
ICs, SVE
(Unsaturated
Zone), and
HD with
Treated
(Unsaturated
Zone), and
Steam
Injection for
Focused
(Unsaturated
Zone), and
Steam
Injection for
Entire
ICs, SVE
(Unsaturated
Zone), and
ERH for
Focused
Water
Water
Treatment
DNAPL Area
Treatment
Injection
Injection
Area with
Hot Floor
with Hot
Floor
Area
Not
Not
Not
Not
Implementability
Implementable
(does not meet
ARARs)
Implementable
(does not meet
ARARs)
Implementable
(does not meet
ARARs)
Implementable
(does not meet
ARARs)
Implementable
Moderately
Implementable
Moderately
Implementable
Implementable
Moderately
Implementable
Cost ($ million
$0
Low
Low
Low
Moderate
Moderate
High
Moderate
High
NPV)
$0.2
$4.9
$12.1
$20.3
$24.1 -$32.5
$56.5 - $84.2
$20.1 -$25.0
$52.6 - $69.6
Relative RA Ranking:
Green High (remedial alternative achieves criterion)
Yellow Medium (remedial alternative partially achieves criterion but lags compared to other remedial alternatives)
Red Low (remedial alternative possesses major technical, financial, or administrative flaws compared to other remedial alternatives)
Source: Modified from the Final DNAPL FS (AECOM, 2013)
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2.11.1
Overall Protection of Human Health and the Environment
Alternative 1 would not be protective of human health or the environment and therefore does not
meet the threshold criteria. Alternative 2 would be protective of human health, but not the
environment, so it also does not meet the threshold criteria. Alternative 3 would be protective of
human health but would be only partially protect the environment (unsaturated zone only), and
therefore does not meet the threshold criteria.
Alternatives 4A through 6B would be protective of human health and the environment.
Alternatives 4A and 4B would protect the environment by removing mobile DNAPL mass from
the saturated UBA by HD, thereby reducing the future risk of lateral or vertical DNAPL migration
within the UBA or downward into the BFS. Although Alternatives 4A and 4B would not likely
remove all mobile DNAPL, the mobility of DNAPL that remains would be significantly reduced
and less likely to pose future threat to the environment through migration under normal hydrologic
conditions. Alternatives 5 A and 6A would protect the environment by removing most to all mobile
DNAPL and some residual DNAPL mass from the saturated zone by thermal treatment within the
Focused Treatment Area. Alternatives 5B and 6B would remove all mobile and most residual
DNAPL within the entire DNAPL-impacted area.
In summary, thermal Alternatives 5 A through 6B would be more protective of human health and
environment because they would remove all mobile DNAPL, and some to most of the residual
DNAPL from the subsurface. However, each of the candidate remedial alternatives can potentially
cause adverse migration of DNAPL during the remedy implementation. The risk of adverse
migration would be slightly higher under thermal remedial alternatives than under HD remedial
alternatives. The ERH pilot demonstrated that ERH can be implemented to recover chlorobenzene
without mobilizing DNAPL downward or laterally. In consideration of human health and the
environment, Alternatives 5A through 6B were deemed equally protective (see Table 2-12).
2.11.2 Compliance with ARARs
Alternative 4A would not meet the requirement for groundwater treatment to substantially reduce
hazardous constituents prior to reinjection, and also would not meet ARARs (unless an ARAR
waiver can be obtained). All remaining alternatives (Alternatives 2, 3, 4B, 5A, 5B, 6A, and 6B)
would comply with ARARs.
2.11.3 Long-Term Effectiveness and Permanence
The long-term effectiveness of the remedial alternatives is determined by their ability to reduce
mobile DNAPL mass, ensure that mobile DNAPL does not migrate laterally and/or vertically
outside the TI Waiver Zone, and increase the certainty of the success of the groundwater remedy
by reducing the potential for recontamination of groundwater.
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Alternatives 4A through 6B would be effective. The long-term effectiveness of thermal
Alternatives 5A, 5B, 6A, and 6B would be greater than Alternatives 4A and 4B, because thermal
alternatives would be more effective in removing mobile DNAPL. Unlike HD, the treatment
efficacy of thermal technologies has a low dependence on lithology or the architecture and
distribution of the DNAPL. For example, ERH can readily overcome physical constraints
attributed to subsurface heterogeneity since the technology relies on heat transfer mechanisms,
which have low sensitivity to soil type, mineralogy, or aquifer structure. Thermal treatment can
reach DNAPL trapped in coarse-grained (for example, sand) as well as fine-grained (silt or clay)
subsurface media.
Conversely, the effectiveness of Alternatives 4A and 4B would be severely impacted by the
heterogeneity of the aquifer formation beneath the former Montrose plant property, and may only
reach DNAPL in the most permeable layers following the preferential flow path, but fail to reach
DNAPL in less-permeable aquifer materials. Therefore, HD would be less effective in
environments with high heterogeneity and where DNAPL stringers and small zones of higher
saturation exist, such as the subsurface conditions present beneath the former Montrose plant
property.
While more aggressive thermal alternatives 5B and 6B would remove the greatest mobile and
residual DNAPL mass, the increase in mass recovery is not significant because most of the
chlorobenzene mass is in the Focused Treatment Area. Therefore, treatment of the entire area by
thermal Alternatives 5B and 6B offers little advantage over Focused Treatment Area Alternatives
5A and 6A for long-term effectiveness and remedy permanence. Treatment of mobile DNAPL is
necessary because if left in place, migration of mobile DNAPL to groundwater would significantly
increase the time required for long-term hydraulic containment under the OU-3 Dual Site
Groundwater remedy and remedy duration identified for this remedy would not be met. The
Focused Treatment Area contains the full extent of mobile DNAPL estimated for the Montrose
Site. Entire DNAPL-impacted area Alternatives 5B and 6B would target a larger soil volume;
however, long-term permanence would be similar to Focused Treatment Area Alternatives 5 A and
6A when considering reduction in mobile DNAPL mass, limiting DNAPL migration, and
minimizing potential for recontamination of the groundwater outside the TI Waiver Zone.
2.11.4 Reduction of Toxicity, Mobility, and/or Volume of Hazardous Constituents
through Treatment
Alternatives 4A through 6B would reduce the toxicity, volume, and mobility of the DNAPL
in both the unsaturated and saturated zones (see Table 2- 12). However, Alternatives 4A and
4B would remove the least chlorobenzene mass and would be less effective in reducing
DNAPL volume in the saturated zone compared to Alternatives 5A through 6B.
Conversely, thermal Alternatives 5A and 6A would be expected to remove mobile and
some residual DNAPL. Subsurface DNAPL that remains in the UBA following thermal
treatment would be below residual saturations (i.e., less than 18.9 percent) and immobile.
Since Alternatives 5B and 6B treat considerably larger volumes, these alternatives would
remove the greatest mass of mobile and residual DNAPL from the subsurface, and achieve
the greatest volume reduction. However, although the potential reduction in DNAPL volume
from the entire DNAPL-impacted area thermal
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alternatives is the largest, it is not significantly larger than the potential volume reduction of mobile
DNAPL under the Focused Treatment Area Alternatives 5A and 6A (see Table 2-12). This is
because most of the DNAPL occurs within the Focused Treatment Area. Consequently, a relatively
small incremental volume of residual DNAPL would likely be removed outside the Focused
Treatment Area by the alternatives for the entire DNAPL-impacted area. Additionally, the entire
DNAPL-impacted area remedial alternatives would not further reduce the mobility of DNAPL in
the saturated UBA compared to Alternatives 5A and 6A, because all mobile DNAPL is believed
to occur within the Focused Treatment Area.
2.11.5 Short-Term Effectiveness
Alternatives 4A, 4B, 5A, 5B, 6A, and 6B would be effective in protecting human health and the
environment in the short-term (Table 2-12). As discussed above, each of these
remedial alternatives can potentially cause some adverse migration of DNAPL during
implementation. While the risk of adverse migration is slightly higher under thermal
remedial alternatives (Alternatives 5A through 6B), these risks can be managed and effectively
mitigated. In addition, the risks of fugitive emissions are somewhat higher with steam-based
heating Alternatives 5A and 5B compared to ERH Alternatives 6A and 6B due to increased
pressure and hydraulic gradients generated in the subsurface.
The duration of SVE operations under Alternatives 4A through 6B would be seven years. The HD
components under Alternatives 4A and 4B have the longest durations, with a period of eight years.
The thermal treatment components have durations of four years under Alternatives 5 A and 6A and
durations of five years under Alternatives 5B and 6B. Because the SVE component of each of
these remedial alternatives is the same, the total time required for all six alternatives is comparable.
2.11.6 Implementability
Alternative 4A would not satisfy the threshold requirement of compliance with ARARs due to the
injection of untreated groundwater and would require an ARAR waiver for implementation to be
possible, which makes this remedial alternative not implementable (Table 2-12). Alternative 4B
is ranked implementable. The implementability of HD has already been demonstrated through
the 2004/2005 extraction testing for groundwater and DNAPL at wells UBE1, UBE2, UBE3,
UBE4, and UBT1, and the strategies proposed for treating groundwater extracted through this
remedial alternative are considered standard unit operations with a proven record of success.
Furthermore, the efficacy of water treatment operations proposed for Alternative 4B has been
demonstrated specifically for groundwater extracted from wells at the Montrose Superfund Site.
Alternative 5 A would require a large amount of infrastructure for subsurface heating, contaminant
recovery, and treatment of extracted fluids, as well as highly skilled field operators and specialized
technology vendors. In addition, the risks of uncontrolled DNAPL migration and fugitive
emissions are somewhat higher with steam-based heating alternatives than for ERH due to
increased pressure and hydraulic gradients generated in the subsurface. This consideration impacts
the implementability of Alternative 5A, because effective capture of chlorobenzene vapors is
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necessary given the proximity of commercial warehouse buildings located to the north of the
former Montrose plant property, and an active industrial plant located directly south of the former
Montrose plant property. There are several qualified commercial firms that provide steam
remediation services. Given multiple technical considerations for implementation of steam heating
combined with a limited pool of commercial technology suppliers, it is considered moderately
implementable.
Similar to Alternative 5A, Alternative 6A also would require a large amount of infrastructure for
subsurface heating, as well as highly skilled field operators and specialized technology vendors.
There are several qualified ERH vendors available and capable of implementing this remedial
alternative; ERH is more frequently implemented than steam injection remediation, has a broad
range of experience and knowledge. Steam injection into porous media has been studied
extensively for enhanced oil recovery and for remediation, but has been implemented for
remediation less frequently. However, large scale steam injections have recently been completed
at the former Williams Air Force Base in Region IX and at the Beede Waste Oil Superfund Site in
Region 1. Therefore, both of these alternatives are implementable.
Alternatives 5B and 6B, if implemented, would be some of the largest and most complex thermal
remedies ever performed. A significant amount of wells and infrastructure would be required for
these entire DNAPL-impacted area thermal alternatives, increasing the difficulty of implementing
or successfully completing the project. In addition, these remedial alternatives pose higher risks
of DNAPL migration and fugitive emissions, which need to be controlled due to the proximity of
commercial buildings. Because of implementability challenges associated with the substantially
increased scale and size of the entire area DNAPL remedy, Alternatives 5B and 6B are considered
to be moderately implementable.
2.11.7 Cost
As described in Section 2.6, the estimated cost of each remedial alternative includes common
components, such as ICs and unsaturated zone SVE. In general, ICs are a small portion of the
overall costs. The unsaturated zone SVE costs, however, are more substantial. In the thermal
treatment remedial alternatives (Alternatives 5 A through 6B), the combination of SVE and thermal
treatment results in lower costs to implement and operate the SVE equipment because the same
treatment train and vapor extraction/conveyance piping can be used simultaneously for both
systems. Figures 2-24 and 2-25 illustrate how the common cost elements of Alternatives 4A
through 6B are related, and show the comparison of total costs for these remedial alternatives. As
shown in these figures, costs for the thermal treatment remedial alternatives were estimated for
both low (Figure 2-24) and high (Figure 2-25) energy scenarios. The pilot ERH showed that it is
likely that the remedial objectives can be met using the lower energy scenario. Costs for
Alternatives 1 through 3 are not presented in these figures because the remedial alternatives would
not be protective of human health and the environment, and therefore cannot be selected as the
DNAPL OU remedy.
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Alternative Cost by Remedy Component - Low Energy
$- $20 $40 $60 $80 $100
H Institutional Controls H Unsaturated ZoneSVE
u Hydraulic Displacement Hi Steam Injection
M Electrical Resistance Heating
Figure 2-24
Low-Energy Alternative Cost Summary and
Comparison (Net Present Value)
DNAPL OU Record of Decision
U.S. EPA Region IX \
Montrose Superfund Site, Los Angeles, California m**'
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Alternative Cost by Remedy Component - High Energy
$-
$20
$40
$60
$80
$100
fil Institutional Controls W Unsaturated Zone SVE H HydraulicDisplacement
li Steam Injection H Electrical Resistance Heating
Figure 2-25
High-Energy Alternative Cost Summary and
Comparison (Net Present Value)
DNAPL OU Record of Decision
U, S, EPA Region IX \ v\|/v j
Montrose Superfund Site, Los Angeles, California St
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Overall, Alternative 4A is the lowest cost ($12.1 million NPV) remedial alternative for removal of
mobile DNAPL from the Focused Treatment Area. The remaining Focused Treatment Area
alternatives (Alternatives 4B, 5A, and 6A) all exhibit comparable costs ($20.3 to $32.5 million
NPV) to remove DNAPL from the UBA. Treatment of groundwater prior to reinjection
considerably increases the cost of Alternative 4B ($20.3 million NPV) compared to Alternative
4A, but would not add the additional mass removal advantages that are offered for the Focused
Treatment Area by thermal Alternatives 5A and 6A. Over the Focused Treatment Area, thermal
treatment by ERH under Alternative 6A is less costly ($20.1 to $25.0 million NPV) than thermal
treatment by steam injection under Alternative 5A ($24.1 to $32.5 million NPV). Despite the cost
difference, both heating approaches are anticipated to offer generally similar performance with
regard to removal of mobile DNAPL and some residual DNAPL.
Entire DNAPL-impacted area thermal treatment under Alternatives 5B and 6B are the highest cost
alternatives considered, ($52.6 to $84.2 million NPV), depending on the amount of energy required
to achieve the thermal performance objectives. However, as discussed above, treating a
significantly larger area as proposed by these remedial alternatives will not likely result in
removing significantly more DNAPL compared to Alternatives 5 A and 6A, because most DNAPL
occurs within the Focused Treatment Area.
2.11.8 State Acceptance
State stakeholders, including DTSC, WRD, and RWQCB, have been an integral part of the
CERCLA process for the Montrose Superfund Site. DTSC, serving as the lead agency for the State
and representing all State stakeholders, concurs with the remedy selected for the DNAPL OU in
this document.
2.11.9 Community Acceptance
EPA issued the Final Proposed Plan in September 2014 and held the Proposed Plan public meeting
on November 8, 2014. EPA received minimal comments that directly related to the DNAPL OU.
Responses to all community member comments received are presented in Part 3 of this document.
Partially to address community concerns Montrose proposed the ERH Pilot Study, which operated
for 153 days and 659,299 kilowatt hours of energy were applied to the treatment volume over 132
days of heating. On average, subsurface temperatures increased at a rate of approximately 0.5 to
2.3 degrees Celsius (°C) per day as the treatment volume temperature increased from ambient to a
maximum average temperature of 107.0°C.
Based on direct measurement of accumulated DNAPL and estimates of mass recovered on polish
Vapor-phased granulated activated carbon, approximately 26,600 pounds of total VOCs were
recovered from the pilot test treatment volume during ERH heating. A total of 2,519 gallons of
DNAPL were recovered by the steam regenerated granulated active carbon unit.
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Ambient air monitoring conducted before, during, and after ERH operations did not identify any
risks to site personnel or the public at large. The pilot test ambient air monitoring program
confirmed that the industry standard practice of monitoring ambient air during operations with a
handheld photoionization detector is acceptable for ensuring Site and public safety. Ambient air
monitoring for the remedial action will include passive air samplers such as Radiellos® to monitor
ambient air on a 30-day cycle during operations at up gradient and downgradient sampling
locations. In addition, when an operator is onsite, monitoring will be performed during daily site
perimeter walks with a handheld photoionization detector (or equivalent, such as a Flame
Ionization Detectors). The handheld device readings will detect any changes to air quality in real
time, allowing corrections or repairs to be made to the system immediately. Monthly data from
the Radiellos®, which will be compared to background data, will be used to demonstrate that air
quality meets residential standards. The asphalt cap will be maintained during ERH application in
the focused treatment area. The ERH pilot test demonstrated pneumatic control throughout
operations and no significant changes to the ERH design are anticipated for application to the
focused treatment area (TRS, 2019).
2.12 PRINCIPAL THREAT WASTE
The NCP establishes an expectation that EPA will use treatment to address the principal threats
posed by a site wherever practicable. Principal threat wastes are source materials considered to be
highly toxic or highly mobile that generally cannot be reliably contained or would present a
significant risk to human health or the environment should exposure occur. When present in the
subsurface, DNAPL or highly concentrated deposits of chemical contaminants can be considered
principal threat wastes. This classification is especially true for mobile DNAPL, or compounds
with high water solubility or leaching potential. At the former Montrose plant property, DNAPL
is present at saturation values above residual levels, which classifies it as mobile DNAPL under
the current hydrostratigraphic conditions (based on physical properties testing, chlorobenzene
concentrations of 27,900 mg/kg in sand or 17,000 mg/kg in silts or more are required for the
DNAPL to be mobile). Given these considerations, DNAPL within the DNAPL OU is considered
a principal threat waste. As previously described, mobile DNAPL consists primarily of
chlorobenzene and DDT, and a significant mass of DNAPL is present beneath the former Montrose
plant property. While the DNAPL provides no immediate risk to human and ecological receptors,
the mass of contamination present and its documented subsurface mobility remains a threat to
groundwater and soil vapor. In the absence of remedial action, mobile DNAPL remaining in the
subsurface is capable of continued vertical and lateral migration through unsaturated soil, and
mobile DNAPL beneath the water table will remain as an ongoing source of dissolved- and vapor-
phase contaminants to groundwater and soil vapor. Removing mobile DNAPL, therefore, is a
critical component in preserving the groundwater resource and ensuring protection of human
health and the environment by supporting the success of the OU-3 Dual Site Groundwater remedy
and the future OU-1 remedy. Removal of mobile DNAPL also will improve the success of the
groundwater remedy regardless of the estimated timeframe required for system operation.
Significant reduction of mobile DNAPL can be achieved by several alternatives considered
(Alternatives 4A, 4B, 5A, 5B, 6A, and 6B). The HD and steam injection treatments Alternatives
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4A, 4B, 5A and 5B would remove both chlorobenzene and DDT, but HD is unlikely to be able to
remove all mobile DNAPL. As previously described, the thermal treatment Alternatives 6A and
6B would preferentially remove chlorobenzene from the mobile DNAPL. This would result in
precipitation of DDT in-situ as the mass of chlorobenzene in the DNAPL is depleted by heating.
Therefore, DDT would remain in the subsurface trapped within the soil matrix of the saturated
UBA at depths exceeding 40 to 60 feet bgs. A similar result would occur during SVE of the
unsaturated zone since DDT is not a volatile DNAPL component and would not be removed by
SVE operations. As discussed in previous sections, DDT is not volatile or soluble in water, and at
significant depths will not pose a risk to human health and the environment. Each thermal
alternative would remove all mobile DNAPL and some residual DNAPL. However, residual
DNAPL (classified as chlorobenzene concentration of less than 27,900 mg/kg in sands or 17,000
mg/kg in silt) is not considered to be a principal threat, because it cannot migrate as free-phase in
the subsurface under current site conditions.
Chlorobenzene and other contaminants in residual DNAPL will continue dissolving into
groundwater when in contact with groundwater. However, hydraulic containment performed as
part of the OU-3 Dual Site Groundwater remedy (EPA, 1999) would contain dissolved-phase
contaminants within the TI Waiver Zone. Therefore, the Alternatives 4B through 6B appear to
adequately address principal threat waste identified as part of the DNAPL OU at the Montrose
Superfund Site. Alternatives 1 and 2 would not treat DNAPL and therefore would not address
principal threat waste associated with the DNAPL OU. Alternative 3 would treat DNAPL in the
unsaturated zone, but would not treat DNAPL in the unsaturated zone, and therefore does not
adequately address principal threat waste associated with the DNAPL OU. Alternative 4A would
remove DNAPL, but would not comply with ARARs, and therefore does not adequately address
principal threat waste associated with the DNAPL OU.
2.13 SELECTED REMEDY
The selected remedy is Alternative 6A - ICs, SVE (Unsaturated Zone), and ERH for the Focused
Treatment Area without a Hot Floor, to address DNAPL at the Montrose Superfund Site. A
summary of the rationale for the selected remedy and a detailed description of the selected remedy
are provided in the sections below. The detailed costs associated with the selected remedy are
provided in Appendix D.
2.13.1 Summary of Rationale for Selected Remedy
As discussed in this document, thermal treatment is considered the most appropriate technology
to achieve RAOs for mobile DNAPL removal beneath the former Montrose plant property
compared to the other remedial alternatives evaluated because thermal treatment more effectively
removes mobile DNAPL from both the saturated and unsaturated zones. Given site-specific
constraints, ERH affords several technical and administrative advantages over other the thermal
treatment option (e.g., steam injection) for the Focused Treatment Area.
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As summarized in this document and detailed in the DNAPL FS, subsurface heating by ERH
would be minimally affected by the soil types in the UBA. In addition, ERH treatment efficacy is
not dependent on DNAPL distribution and subsurface architecture. The ability of ERH to
overcome issues associated with the subsurface heterogeneity relies on heat transfer mechanisms,
which have low sensitivity to soil type, mineralogy, aquifer structure, or DNAPL distribution.
Thermal treatment using ERH can therefore reach DNAPL trapped in either coarse-grained (sand)
or fine-grained (silt or clay) subsurface media. Regardless of the media types where DNAPL
resides or its corresponding saturation level, it can be treated using ERH, provided it is located
within the subsurface zone where heating and SVE are conducted in the Focused Treatment Area.
Conversely, the effectiveness of the other treatment technologies, including steam injection, is
strongly influenced by subsurface lithology and heterogeneity characteristic of conditions within
the UBA. DNAPL removal technologies, including HD, which rely on the injection, propagation,
and recovery of subsurface fluids (surfactants, oxidants, groundwater, or steam), may only reach
DNAPL in the most permeable layers. In heterogeneous aquifers like the UBA, injected fluids
preferentially flow through high-permeability materials but fail to reach contamination that resides
in lower-permeability materials. Preferential steam flow can successfully heat low-permeability
zones through conductive and convective heat transfer mechanisms. However, given the
conditions in the UBA, this approach lacks both heating efficiency and contaminant removal
efficiency when compared to ERH. Non-thermal technologies are far less effective in treating
aquifers with high heterogeneity or complex DNAPL architecture, such as the subsurface
conditions present beneath the former Montrose plant property.
Thermal processes for in-situ remediation are increasingly being applied at a variety of sites where
DNAPL is encountered, including those managed under Superfund. Within Region IX, recent
applications of ERH for restoration of the Pemaco Superfund Site in Maywood, California, and
the Frontier Fertilizer Site in Davis, California, provide strong testimony to the versatility of this
technology for effectively and efficiently removing subsurface DNAPL. At each of these sites,
ERH was implemented near residential areas and was shown to be successful for addressing
DNAPL in the subsurface. Outside of Region IX, EPA also has demonstrated applications where
ERH was successfully implemented in close proximity to commercial interests. In Region VI, EPA
completed ERH system operation at the Grants New Mexico Superfund Site, which required
installation of an ERH system inside an active dry cleaner (Holiday Cleaners) facility. Throughout
system construction and following operation, Holiday Cleaners remained open for business and
maintained working conditions protective of employees and customers alike. Overall, this
experience demonstrates that, with proper engineering, construction, monitoring, and operational
oversight, ERH can be safely and effectively implemented in a variety of situations.
Based on the evaluation of candidate alternatives, Alternative 6A satisfies all threshold criteria and
provides the best balance of trade-offs for the balancing and modifying criteria. Alternative 6A is
more cost-effective and has higher implementability than other thermal treatment alternatives
considered (Alternatives 5A, 5B, and 6B). Although steam injection remains a viable thermal
treatment technology for DNAPL at the Montrose Superfund Site, higher implementation costs
for this technology resulted in a lower overall ranking of steam injection Alternatives 5A and 5B
compared to ERH performed under Alternative 6A. Treatment of the entire DNAPL-impacted area
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by ERH, evaluated under Alternative 6B, was also ranked lower because it would be far more
difficult to implement given its considerably larger treatment volume and project cost compared
to Alternative 6A. Finally, the effectiveness of entire DNAPL-impacted area thermal alternatives
(Alternatives 5B and 6B) in removing mobile DNAPL would be similar to that of Alternative 6A,
since the majority of the DNAPL (and all of the mobile DNAPL) volume is located within the
Focused Treatment Area.
A recent ERH pilot test conducted at the former Montrose plant property in 2018/2019
demonstrated the effectiveness of this technology and also supports the selection of Alternative
6A as the remedy for the DNAPL OU. The ERH pilot test system construction began on April 3,
2018 and covered an area of 3,289 ft2. Baseline sampling occurred between May 21, 2018 and
May 31, 2018. Vapor recovery system operations began on December 17, 2018, and were
completed on May 23, 2019. ERH system heating operations began on December 19, 2018, and
ended on April 30, 2019. Approximately 26,600 pounds of total VOCs were recovered during the
pilot test. Baseline sampling found the average concentration of chlorobenzene in soil within the
pilot test treatment area prior to ERH system operations was 970 mg/kg post treatment.
Confirmatory sampling within the pilot test treatment area indicated an average concentration of
chlorobenzene of 1.37 mg/kg, which equates to an average mass reduction of chlorobenzene of
99.86 percent (TRS, 2019). In addition, chlorobenzene concentrations in the confirmation soil
samples were found to be significantly below the concentrations equivalent to the residual DNAPL
saturation, which indicates that no mobile DNAPL remained within the pilot test treatment area
following completion of treatment.
Based on the factors cited above and discussed within this document, Alternative 6A meets the
threshold criteria and provides the best balance of tradeoffs with regard to the balancing and
modifying criteria established by the NCP.
2.13.2 Detailed Description of Selected Remedy
The following components are components of the selected remedy, Alternative 6A - ICs, SVE
(Unsaturated Zone), and ERH for the Focused Treatment Area
Institutional Controls and Monitoring
• ICs will be implemented to prevent access to DNAPL-impacted soils. A land use
covenant (deed restriction) will be established to restrict future activities at the former
Montrose plant property for industrial use only and to place limits on construction,
excavation, and drilling activities. Access to the former Montrose plant property is
currently restricted by perimeter fencing and warning signs, and these access restrictions
will remain in place. Annual site inspection and maintenance will be required to ensure
ICs are in place and functioning as intended.
• Continued quarterly monitoring and purging of the CMW002 well will follow the
approach in the Revised Technical Memorandum "Recommended Path Forward for
MBFC Well CMW002 Montrose Superfund Site, Los Angeles, California" (Group Delta,
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2020). If necessary, CMW002 will be replaced with two new wells. One will be screened
in the UBA, and the other in the BFS. Both wells will be equipped with a five-foot-long
sump. If DNAPL continues to accumulate in these new wells, additional characterization
in this area will be completed to determine the extent of mobile DNAPL and EPA will
decide on the need for ERH for this area.
Unsaturated Zone SVE
• SVE will be implemented in the unsaturated zone between approximately 10 and 60 feet
bgs. The conceptual design includes a series of extraction wells positioned throughout
the DNAPL-impacted unsaturated zone and installed to separately treat the lower and
higher permeability soils. Extraction wells will be screened between approximately 25 to
45 feet bgs for permeable sands and between approximately 10 to 25 and 45 to 60 feet
bgs for lower permeability silty sands and sandy silts. Spacing between extraction wells
will be based on the radius of influence but allowing for some overlap to ensure that all
unsaturated soils in the PD and PVS are effectively treated. Specific depths and
extraction well locations will be specified in the remedial action process.
• Soil vapors will be extracted using a blower; suspended solids will be filtered; and
entrained moisture will be separated or condensed. Soil vapors will then be passed to a
treatment system for removal or destruction of the VOC contaminants prior to
atmospheric discharge. Three soil vapor treatment options were retained, including
disposal GAC/resin, steam-regenerable GAC/resin, and thermal oxidation with acid-gas
scrubbing. The specific SVE treatment design will be specified in the remedial action
process.
• A series of soil vapor monitoring points/wells will be installed to monitor the
performance of the unsaturated zone SVE system (ten were assumed for costing
purposes). In order to monitor the vacuum influence within each of the three distinct
unsaturated zone layers, three nested monitoring points will be constructed at each
location within a single borehole. The concentration of VOCs in soil gas within the
monitoring points would also be tested routinely to demonstrate a reduction in VOC
concentrations over time. To confirm the reduction in sorbed VOC concentrations, soil
borings would be drilled and samples collected to verify the effectiveness of the SVE
remedy in the unsaturated zone (ten were assumed for costing purposes). Residual VOC
concentrations in soil would be compared against risk-based cleanup goals. The SVE
monitoring plan will be specified in the remedial action process.
Electric Resistive Heating for the Focused Treatment Area and SVE for Saturated Zone
• ERH will be implemented within the saturated UBA over the Focused Treatment Area,
which contains all areas of mobile DNAPL. ERH will target the full thickness of the
UBA, from 60 to 105 feet bgs. An estimated 102 ERH electrodes will be installed
throughout the Focused Treatment Area on an offset linear pattern. ERH electrodes
radius of influence will extend to or slightly beyond the edge of the Focused Treatment
Area. Electrodes used in ERH treatment are of a finite length and are often designed to
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accommodate vertical differences in soil resistivity. Heating thick saturated zones, such
as the UBA, will likely be completed using multiple electrode segments that are stacked
in a common boring. Specific depths and electrode numbers and locations will be
specified in the remedial action.
• SVE is an integral component of the ERH to recover heated soil vapors and volatilized
VOCs from the UBA. Vapor extraction wells will be located throughout the ERH
treatment area in sufficient numbers to maintain pneumatic control. Specific depths and
multiphase extraction well numbers and locations will be specified in the remedial action
process. Soil vapors will be extracted at a rate to maintain pneumatic control at the
perimeter of the treatment zone. Treated condensate will be transferred to the
groundwater treatment system associated with the OU-3 Dual Site Groundwater remedy
for treatment and subsequent reinjection into the BFS and Gage aquifers. The specific
dual-phase treatment design will be specified in the remedial action process.
2.14 EXPECTED OUTCOME OF THE SELECTED REMEDY
The expected outcome of the selected remedy is the removal of mobile DNAPL in the UBA within
the Focused Treatment Area, which will achieve the RAOs and protect human health and the
environment by limiting DNAPL migration laterally and vertically into deeper aquifers.
Groundwater cleanup goals cannot be achieved within the TI Waiver Zone due to the presence of
DNAPL. Therefore, the expected outcome of the DNAPL OU remedy is not groundwater
restoration within the TI Waiver Zone or achieving of any numeric standards for dissolved DNAPL
components. The expected outcome is to facilitate the success of the OU-3 Dual Site Groundwater
remedy's containment of contaminated groundwater within the TI Waiver Zone as well as the
success of the future OU-1 remedy. The DNAPL OU remedy will also prevent access to DNAPL-
impacted soils by restricting future land use to industrial use only and placing limits on
construction, excavation, and drilling activities. The ERH component of Alternative 6A is
anticipated to take five years, the SVE component of Alternative 6A is anticipated to take seven
years, and the IC component of Alternative 6A will remain in place as long as contamination
remains at the Montrose Superfund Site. Aquifer restoration will be achieved on the timeline set
for Dual Site Groundwater OU in the OU-3 Dual Site Groundwater ROD (EPA, 1999) and
available land uses will depend on the future remedy selected for the Soil OU.
2.15 STATUTORY DETERMINATIONS
Under CERCLA Section 121 and the NCP, the lead agency must select remedies that are protective
of human health and the environment, comply with ARARs (unless a statutory waiver is justified),
are cost-effective, and use permanent solutions and treatment or resource recovery technologies to
the maximum extent practicable. In addition, CERCLA includes a preference for remedies that
employ treatment that permanently and significantly reduces the volume, toxicity, or mobility of
hazardous wastes as a principal element and a bias against offsite disposal of untreated wastes.
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The following sections discuss how the selected remedy meets these statutory requirements and
explains the Five-Year Review requirements for the selected remedy.
2.15.1 Protection of Human Health and the Environment
EPA's primary responsibility at Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. The selected remedy (Alternative 6A
- ICs, SVE (Unsaturated Zone), and ERH for the Focused Treatment Area without a Hot Floor)
will remove mobile DNAPL from beneath the former Montrose plant property to the extent
practicable, thereby removing a significant source of soil and groundwater contamination. ICs will
prevent human exposure to DNAPL-impacted soils remaining beneath the former Montrose plant
property. The DNAPL OU remedy will facilitate the success of the OU-3 Dual Site Groundwater
remedy's containment of contaminated groundwater within the TI Waiver Zone by removing
mobile DNAPL and thereby limiting downward DNAPL migration into deeper aquifers, as well
as lateral DNAPL migration that could potentially re-contaminate groundwater outside the TI
Waiver Zone. This remedial action is not expected to present any unacceptable short-term risks or
cross-media impacts. All extracted water and soil vapor will be treated to meet ARARs and/or
independently applicable standards prior to discharge.
2.15.2 Compliance with ARARs
Remedial actions selected under CERCLA must comply with all ARARs under federal
environmental laws or, where more stringent than the federal requirements, state environmental or
facility siting laws. Where a state has delegated authority to enforce a federal statute, such as the
Resource Conservation and Recovery Act (RCRA), the delegated portions of the statute are
considered to be a federal ARAR unless the state law is broader in scope than the federal law.
ARARs are identified on a site-specific basis from information about site-specific chemicals,
specific actions that are being considered, and specific features of the site location. Appendix E
provides a complete list of ARARs for DNAPL OU.
This remedial action will comply with all ARARs, except for those ARARs that are being waived
as established by the OU-3 Dual Site Groundwater ROD, based on technical impracticability. The
specific ARARs that shall apply to this remedial action are listed in Appendix E. The TI waiver
applies only to groundwater within the TI Waiver Zone, as defined by the OU-3 Dual Site
Groundwater ROD (EPA, 1999).
2.15.3 Cost-Effectiveness
EPA must consider the cost-effectiveness of the proposed remedy. The NCP defines a cost-
effective remedy as one whose "costs are proportional to its overall effectiveness" (40 C.F.R. §
300.430(f)(l)(ii)(D)). Assessing cost-effectiveness has been accomplished by comparing costs to
overall effectiveness, which is determined by evaluating the following three of the five balancing
criteria: 1) longer-term effectiveness and permanence; 2) reduction in toxicity, mobility and
volume through treatment; and 3) short-term effectiveness. Section 2.11 compares the longer-term
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effectiveness and permanence; reduction in toxicity, mobility and volume through treatment; and
short-term effectiveness for all remedial alternatives. Alternative 6A was found to be the most
cost-effective given that it satisfies both threshold criteria, is more effective for removing mobile
DNAPL than other alternatives, and provides the best cost-balance based on estimated volume of
removed DNAPL relative to other alternatives.
The remedy selected by this ROD is cost-effective. It uses sufficiently aggressive actions given
the conditions, acknowledges the impracticability of complete DNAPL removal, and contains cost-
effective means for addressing mobile DNAPL.
The costs associated the selected alternative are presented in Appendix D. The total present-worth
cost for the selected remedy is $20,090,354 for the low-energy input, and $24,992,562 for the high-
energy input.
2.15.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy provides the best balance of trade-offs among the
alternatives with respect to the balancing criteria. The selected remedy represents the maximum
extent to which permanent solutions and treatment technologies can be used in a practicable
manner at the Montrose Superfund Site. The selected remedy removes and treats mobile DNAPL
from the Focused Treatment Area, which will reduce the regional threat to groundwater posed by
both lateral and vertical migration of mobile DNAPL. The selected remedy does not present short-
term risks different from the other remedial alternatives. In addition, the selected remedy is more
implementable and effective than non-ERH alternatives and is more cost- effective than the other
ERH alternative (Alternative 6B).
2.15.5 Preference for Treatment as a Principal Element
This remedial action satisfies the statutory preference for treatment as a principal element by
utilizing two treatment technologies, SVE and ERH, to physically remove the principal threat
(mobile DNAPL) from both the saturated and unsaturated zones of the Site. DNAPL remains as
an ongoing source of dissolved- and vapor-phase contaminants, so removal and treatment of
mobile DNAPL will minimize further impacts to soil and groundwater. Groundwater
contamination resulting from residual DNAPL will be contained and addressed by the OU-3 Dual
Site Groundwater remedy.
2.15.6 Five-Year Review Requirements
A five-year review will be required pursuant to CERCLA §121(c) and the NCP §300.430(f)(5)(iii)
(C), because waste will be left in place in excess of levels that would allow for unrestricted use of
the land and groundwater. A Five-Year Review will be conducted within five years after initiation
of the remedial action, and every five years thereafter, to ensure that the remedy is, or will be,
protective of human health and the environment.
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As described in this ROD, dissolved-phase groundwater contamination emanating from the
Montrose Site will be addressed indefinitely by the OU-3 Dual Site Groundwater remedy, which
has a separate Five-Year Review Process. Because of the interrelated nature of the Montrose
DNAPL OU remedy and the OU-3 Dual Site Groundwater remedy, some collaboration may occur
in the future between the two independent Five-Year Review processes.
2.16 DOCUMENTATION OF SIGNIFICANT CHANGES
All written and verbal comments submitted during the public comment period were reviewed by
EPA. In addition, EPA reviewed DAAC comments submitted on April 12, 2016. EPA responses
are included in Part III of this ROD (the Responsiveness Summary). Upon review of these
comments, EPA has determined that no significant changes are necessary to the preferred
alternative, "Alternative 6A - ERH, Focused Treatment Area" as presented in the Proposed Plan.
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3.0
PART 3: RESPONSIVENESS SUMMARY
EPA's responses to comments received on the Proposed Plan are provided in the sections below.
Oral comments on the Proposed Plan public meeting were recorded via court reporter, and that
transcript is included in Appendix B. Written comments received by EPA are included in Appendix
C. Written comments were received during the comment period from the following stakeholders:
• Del Amo Action Committee (DAAC)
• Montrose Chemical Corporation (Montrose)
• Sierra Club
• EPA's Technical Assistance Services for Communities (TASC)
• California Environmental Protection Agency (CalEPA) Department of Toxic
Substances Control (DTSC)
• Water Replenishment District of Southern California (WRD)
Written comments were also received from DAAC on April 12, 2016, after the close of the public
comment period on February 13, 2015.
3.1 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES
Part I: Summary of Community Comments and Response to Community Concerns
The major concerns expressed during the public comment period are summarized below.
Comment 1-1. Relocation - Several community members requested that they be permanently
relocated away from the Montrose/Del Amo Superfund Sites.
EPA Response: The safety and well-being of the community is of the utmost
importance to EPA. There is no exposure pathway for the community from the Sites.
EPA evaluated the potential for vapor intrusion from the Sites to residents and found
no health risks. Vapor intrusion is a process where underground VOCs move through
cracks and other openings in the foundation slabs of buildings. If this happens at high
levels, it may create a health risk for those breathing indoor air. However, after an
extensive vapor intrusion investigation that included indoor air sampling and soil gas
sampling, EPA found no health risks associated with vapor intrusion in the
neighborhoods from the Sites. In addition, concentrations of VOCs in groundwater
are regularly monitored as part of the OU-3 Dual Site Groundwater remedy.
The Montrose DNAPL remedy will be designed and implemented to not pose a safety
or health risk to the local community.
Comment 1-2. Drinking Water Quality - Community members expressed concern that their
drinking water might be contaminated.
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EPA Response: No one is presently drinking or using water contaminated by these
Sites. Currently, the drinking water provided to nearby homes and businesses is
regularly tested to verify that it meets California and Federal drinking water standards.
EPA will continue to work with the State and local agencies, WRD, and local water
purveyors to protect water supply wells.
Drinking water has not been impacted by the Sites. The nearest drinking water supply
well is approximately 1/2 to 1 mile downgradient of the groundwater contaminant
plume. Although the State of California designates all of the water- bearing units
beneath the former Montrose plant property as having potential potable beneficial use,
no municipal or private drinking water production wells are in use within the area of
site-related groundwater contamination.
Comment 1-3. TI Waiver Zone - Community members and the Sierra Club commented that
the use of a TI Waiver Zone needs to be revisited. The TI Waiver Zone allows contamination
to be left in place and extends the amount of time before the site is cleaned up, thereby
continuing to subject the community to contamination. Community members also
commented that the TI Waiver Zone gives the PRPs a "free pass," while the community has
to bear the burden of contamination. There is also concern that people live in homes located
above a portion of the TI Waiver Zone.
EPA Response: The OU-3 Dual Site Groundwater remedy established a TI Waiver
Zone, which is an area where it is technically impractical to clean the groundwater to
state and federal standards. There is no treatment or technology currently available
that can completely cleanup the groundwater area. Every five years, EPA will
conduct a review of the cleanup actions for the OU-3 Dual Site Groundwater remedy.
These Five-Year Reviews (FYRs) help EPA understand how cleanup actions are
working to protect human health and the environment. During the FYR, EPA inspects
the site; reviews site documents and data; identifies any new information; and seeks
input from partner agencies and interested community members. The OU-3 Dual Site
Groundwater FYR will specifically evaluate the protectiveness of the TI Waiver Zone
and confirms that the remedy remains protective of human health and the
environment. The last FYR for the OU-3 Dual Site Groundwater remedy was
completed in September 2015 and a new FYR will be completed in 2020.
Groundwater contamination is deep under the ground, and people cannot come into
direct contact with groundwater contamination. The only potential risk to people
living above the TI Waiver Zone is the possibility for vapor intrusion from VOCs in
groundwater. Vapor intrusion is a process where underground VOCs move through
cracks and other openings in the foundation slabs of buildings. After an extensive
vapor intrusion investigation that included both indoor air sampling and soil gas
sampling, EPA found no health risks associated with vapor intrusion from the OU-3
Dual Site Groundwater in the neighborhoods near the Sites. In addition,
concentrations of VOCs in groundwater are regularly monitored as part of the OU-3
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Dual Site Groundwater remedy. The pathway for vapor intrusion will continue to be
evaluated in the FYRs.
Comment 1-4. Screening of Additional Technologies - Community members raised concerns
regarding the screening of additional remedial technologies and requested a formal
technology screening. These comments referred to both the Montrose DNAPL remediation
as well as the OU-3 Dual Site Groundwater remedy. The Sierra Club specifically suggested
that EPA should consider biological forms of treatment, stating that microbes can degrade
DDT.
EPA Response: The technology screening process for the OU-3 Dual Site
Groundwater remedy was completed in 1998 and documented in the Final Joint
Groundwater Feasibility Study for the Montrose and Del Amo Sites (CH2M HILL,
1999). The Five-Year Review will provide an opportunity to assess the
effectiveness of the OU-3 Dual Site Groundwater remedy.
The technology screening process for DNAPL at the Montrose Site was completed in
2013 and documented in the Final DNAPL Feasibility Study (AECOM, 2013). The
DNAPL FS documents the comprehensive evaluation of multiple remediation
technologies and remedial alternatives by EPA, our technical contractors, and our
state partners. Because of the heterogeneity of the subsurface and the depth of
contamination, few technologies are both effective and protective of human health
and the environment. A total of 28 technologies/process options representing eight
general response actions were evaluated in Section 4.0 of the DNAPL FS, in addition
to the no action response action. This included biological forms of treatment as in-
situ bioremediation; however, the DNAPL FS determined that: 1) contaminants at the
Site may volatilize at a rate greater than they would biodegrade; 2) biodegradation
would not be effective for low permeability soils; and, 3) high contaminant
concentrations associated with DNAPL may have detrimental effects on microbial
populations. Therefore, biodegradation was not retained as a technology to be
incorporated into the assembled remedial alternatives.
Comment 1-5. Support for Selected Remedy - Montrose supported the selected remedy of
ERH to remediate mobile DNAPL at the Montrose Site, but indicated a preference for HD.
EPA Response: Although Montrose preferred HD, the selected alternative
(Alternative 6A - ICs, SVE (Unsaturated Zone), and ERH for the Focused Treatment
Area without a Hot Floor) provides the best balance of the nine criteria for remedy
selection. ERH can reach DNAPL in less-permeable silts and clays, while HD can
only reach DNAPL in the most permeable sandy layers, and will likely fail to reach
DNAPL in less-permeable silts and clays. Therefore, HD is much less effective for
the conditions present beneath the former Montrose plant property, where DNAPL is
present in various/diverse soil types, including fine- grained silts and clays.
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Comment 1-6. Agency Involvement - Written comments raised the concern that the WRD
was not included in the review process for the FS and the Proposed Plan for the both the Dual
Site Groundwater OU and the DNAPL OU.
EPA Response: EPA has included both the RWQCB and the WRD in the review
process for the FS and Proposed Plan. DTSC and EPA have agreed that DTSC will
be the lead agency for the state and will represent all state stakeholders, including
WRD and the RWQCB.
Comment 1-7. Coordination with Other Operable Units - Community members raised
concerns that there is a lack of coordination among the Montrose OUs, which are at various
phases of the CERCLA process. Furthermore, it is difficult to understand the "whole picture"
and provide public comment on one aspect at a time, such as the DNAPL Proposed Plan.
EPA Response: EPA acknowledges that the Montrose Superfund Site and Del Amo
Superfund Site are complex and understands that multiple OUs at different steps in
the CERCLA process can make it difficult to understand the Site as a whole. Dividing
the Site into multiple OUs allows EPA to better manage the process and address OUs
in a risk-based prioritization scheme that addresses the greatest risks to human health
and the environment first. EPA is working to address the site more holistically when
providing public updates. In 2016, EPA began issuing site update fact sheets to
provide updates on active OUs at both Sites. EPA has developed a simple conceptual
map to better visualize the OUs on both Sites, and a graphic to explain the OUs across
both Sites.
Comment 1-8. Length of Time to Aquifer Restoration - The TASC technical advisor working
with the DAAC commented that the Proposed Plan should have clearly stated the 3,000-year
duration required for the containment portion of the OU-3 Dual-Site Groundwater remedy.
EPA Response: The amount of time required for groundwater restoration is an aspect
of the OU-3 Dual Site Groundwater remedy, not the DNAPL OU remedy. The OU-
3 Dual Site Groundwater remedy had its own Proposed Plan and ROD process that
occurred in the late 1990s. Therefore, the Proposed Plan for the DNAPL OU did not
cover aspects of a remedy for another OU. The OU-3 Dual Site Groundwater remedy
defined a containment zone for the groundwater, meaning an area where the
contaminants should be contained while groundwater cleanup occurs outside the
containment zone. The containment zone is referenced as the TI Waiver Zone; it is
located in the immediate vicinity of the DNAPL beneath the former Montrose plant
property. Montrose started continuous operations of the groundwater extraction and
treatment system for the OU-3 Dual Site Groundwater remedy at low pumping rates
in February 2019. Now that this remedy is functional, it is estimated to clean up
groundwater outside the TI Waiver Zone within 50 years.
However, various sources of residual DNAPL will continue to contaminate the
groundwater within the TI Waiver Zone, because it cannot practicably be cleaned up
even with the most aggressive remedy. EPA estimates the groundwater
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contamination within the TI Waiver Zone will be present for thousands of years, but
the contamination will be contained by pumping for as long as it persists.
Comment 1-9. Reiniection of pCBSA - The Sierra Club commented that treatment to reduce
the concentration of pCBSA in reinjected groundwater needs to be adequate to protect
groundwater from contamination.
EPA Response: Reinjection of treated groundwater is an essential component of the
remedy for the OU-3 Dual Site Groundwater remedy, not the DNAPL OU remedy.
The OU-3 Dual Site Groundwater remedy had its own Proposed Plan and ROD
process in the late 1990s. Therefore, the DNAPL OU remedy did not cover aspects
of the OU-3 Dual Site Groundwater remedy.
Comment 1-10. Vapor Intrusion Due to Groundwater Contamination - Community members
raised the concern that there might be vapor intrusion at residential homes that overlie the
current groundwater contamination plume.
EPA Response: Vapor intrusion is a process where underground VOCs move
through cracks and other openings in the foundation slabs ofbuildings. If this happens
at high levels, it may create a health risk for those breathing indoor air. EPA shared
the concern about the potential for vapor intrusion at nearby residential homes and
completed a comprehensive vapor intrusion investigation from 2015-2016. This
vapor intrusion investigation included indoor air sampling of over 100 homes and
extensive soil gas sampling. EPA found no health risks associated with vapor
intrusion in the neighborhoods from the Dual Site Groundwater near the Sites. In
addition, concentrations of VOCs in groundwater are regularly monitored as part of
the OU-3 Dual Site Groundwater remedy.
Comment 1-11. Vapor Intrusion During Implementation of Electronic Resistance Heating
(ERR)
- Community members raised a concern that when ERH is implemented and the soil is
heated to mobilize chlorobenzene, the resulting vapors could migrate to the residential area
and impact indoor air quality. The Sierra Club commented that indoor air sampling should
be conducted prior to and during the remedial action.
EPA Response: The selected remedy includes heating the soil using ERH and
extracting the resulting vapors using SVE. Vapor extraction wells will be positioned
around the perimeter of the Focused Treatment Area (including beyond the estimated
extent of mobile DNAPL) to extract vapors before they leave the site if monitoring
indicates that all vapors are not being contained within the treatment area. These
extraction wells will capture volatilized contaminants along the edge of the Focused
Treatment Area. The nearest residences are more than 700 feet southeast of the
former Montrose plant property, where the DNAPL is present. The migration of
fugitive vapors beyond the boundaries of the former Montrose plant property will be
carefully monitored and prevented
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EPA shares the concerns regarding the protection of the indoor air of nearby
residences. Therefore, the remedial action process will include provisions to monitor
for vapors within the plant property and a plan of action to respond if that unlikely
situation were to occur.
Comment 1-12. Delineation of Groundwater Contamination - Community members raised a
concern that the extent of the groundwater contaminant plume beneath the nearby community
is uncertain.
EPA Response: Monitoring of the groundwater contamination plume is performed
under the OU-3 Dual Site Groundwater remedy and is very extensive. EPA believes
the extent is adequately characterized and continues to evaluate and update as needed.
The 2014 Groundwater Monitoring Report is available on the EPA Web site.
Comment 1-13. Preferred Alternative 6A Targets Only Mobile DNAPL - Community
members commented about the selected remedy being limited to mobile DNAPL, leaving
residual DNAPL in place even when the ERH technology could remove some residual
DNAPL. Comments range from requesting that EPA clarify that residual DNAPL will be
left in place, to requesting that EPA select Alternative 6B to remediate the entire DNAPL
area.
EPA Response: EPA selected alternative 6A because it achieves the RAO of
removing mobile DNAPL, which poses the most immediate potential risk to human
health and the environment. Removal of residual DNAPL, given the scale and
complexity of the necessary thermal treatment system, is not practical, even with the
most aggressive technology. Further, while Alternative 6B would remove all mobile
DNAPL, this alternative cannot remove all residual DNAPL. Some residual DNAPL
would be removed during the thermal treatment process, but residual DNAPL would
still remain at the former Montrose plant property. Given the additional costs to
implement Alternative 6B and that residual DNAPL will still remain, there is little
advantage to implementing Alternative 6B instead of Alternative 6A.
There is no exposure to contaminated groundwater, and the recent vapor intrusion
investigation found no evidence of vapor intrusion from contaminated groundwater at
the Dual Site.
Comment 1-14. Consider Cumulative Risk - A comment was received at the public meeting
that EPA should consider the cumulative effect of trichloroethene (TCE), chlorobenzene, and
pCBSA rather than looking at those chemicals individually.
EPA Response: The DNAPL OU remedy does not address TCE or pCBSA,
because they are not hazardous substances for the DNAPL OU. These
chemicals in groundwater are addressed by the OU-3 Dual Site Groundwater
remedy. However, no one is being exposed to these chemicals since they do
not drink groundwater contaminated by the Site. Concentrations of VOCs in
groundwater are regularly monitored as part of the OU-3 Dual Site
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Groundwater remedy. In addition, after a comprehensive vapor intrusion
investigation, EPA found no health risks associated with vapor intrusion in the
neighborhoods from the Sites.
Part II: Response to State Agencies
The major concerns expressed by state agencies during the public comment period are
summarized below.
Comments from the Southern California Water Replenishment District (WRD)
Comment II-1. Support for Remedial Action Objectives - WRD strongly supports all of
EPA's RAOs for the DNAPL OU remedy, as described in the DNAPL Proposed Plan.
EPA Response: Comment acknowledged.
Comment II-2. Removal of DDT - Soil and groundwater beneath the Montrose property is
contaminated with DNAPL that reportedly consists of both DDT and chlorobenzene (also
called monochlorobenzene or MCB).However, EPA's preferred alternative (6A) only
addresses mobile chlorobenzene beneath the focused treatment area of the Montrose property.
Alternative 6A leaves DDT in place. Because the chlorobenzene is only being remediated at
a limited area of the Site, there remains the potential for the entrained DDT to be remobilized
in the future. Thus, if Alternative 6A is implemented, EPA should consider mass removal of
both chlorobenzene and DDT beneath the Montrose property; otherwise, Alternative 6B
should be implemented.
EPA Response: In deep saturated soils where there is no human exposure pathway,
DDT will not pose a threat to groundwater resources or human health. The water
solubility of DDT is exceptionally low (approximately 25 |ig/L) and DDT affinity for
soil sorption is very high. Collectively its low water solubility and high soil sorption
coefficient dramatically limits the potential for DDT migration under natural
conditions. In the absence of a solvent, such as chlorobenzene, DDT will be
immobilized through precipitation and direct adsorption to the soil matrix.
Chlorobenzene is dissolved in the groundwater contamination plume. However, it is
not present in sufficient concentration to remobilize DDT solids that may remain in-
situ following DNAPL removal by thermal treatment processes. Given its low water
solubility, the mass of DDT that may partition from soil to groundwater will be
minimal. The potential for DDT to migrate from the Treatment Area is low because
this area is located within the TI Waiver Zone, where the OU-3 Dual Site Groundwater
remedy hydraulically contains contaminated groundwater and eliminates the potential
for DDT to migrate outside of the TI Waiver Zone.
Comment II-3. Public Meeting for the Monitoring and Aquifer Compliance Plan (MACP) -
WRD is very concerned about the volume/mass of contamination beneath the Montrose
property, especially since it has been confirmed that chlorobenzene has been detected as deep
as the Lynwood aquifer, a major water supply aquifer in the region. Groundwater monitoring
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by the responsible party should resume as soon as possible in order to continuously assess
DNAPL migration both laterally and vertically in the subsurface, including the Gage and
Lynwood aquifers. Given the extent of documented contamination beneath the Montrose
property, as well as the adjacent Del Amo property, and the significant known and potential
impacts to the quality of groundwater in the West Coast Basin, WRD recommends: a full
public participation process be implemented; the Draft MACP be circulated for a minimum
45- day public review period; and a public meeting be held by EPA to explain the monitoring
plan and to receive public comments for consideration. At a minimum, the MACP should
describe a groundwater monitoring program that designates adequate monitoring points
laterally and vertically. The MACP should also describe a monitoring frequency that
evaluates the overall performance of the Dual-Site Groundwater remedy, drinking water
protection, and the capture of all DNAPL that can migrate outside the TI WaiverZone.
EPA Response: EPA is continuously working with Montrose and Shell on updating
the MACP for the OU-3 Dual Site Groundwater remedy. The MACP for the OU-3
Dual Site Groundwater remedy will either be amended to include the MACP for the
DNAPL OU remedy, or a separate stand- alone MACP will be developed to monitor
the performance and potential adverse impacts of the DNAPL OU remedy.
Comment II-4. Preferred Alternative Should Treat the Entire DNAPL Area (Alternative 6B)
- The distinction between mobile and residual DNAPL serves as EPA's entire basis for the
limited DNAPL cleanup at the Montrose Site. On page 4 of the DNAPL Proposed Plan,
EPA states, "DNAPL at the Montrose Property occurs in both "mobile " and "residual"
forms. Mobile DNAPL is a continuous mass of DNAPL that can flow with groundwater
and/or sink under gravitational forces. Residual DNAPL is trapped in the pore spaces of
soil particles and cannot move laterally and/or vertically under natural conditions
According to the FS report, mobile DNAPL was defined based on physical properties
testing of one soil core sample collected from Boring 2DSB-1 at the Site, and the lateral and
vertical extent of mobile DNAPL was based on sampling conducted in 2004 (and prior) and
2008, respectively. Given the current extent of groundwater contamination downgradient
of the former Montrose plant property and the confirmed detection of chlorobenzene in the
Lynwood aquifer, it is possible and likely that mobile DNAPL has extended beyond the
Focused Treatment Area, as defined by EPA in the DNAPL Proposed Plan.
Additionally, residual DNAPL may become mobile as groundwater levels continue to rise.
WRD nested groundwater monitoring well Carson 2 (approximately 2 miles southeast and
downgradient of the Montrose and Del Amo Superfund Sites) shows groundwater levels
rising an average of 15 feet over the last 12 years in all underlying aquifers (Gage, Lynwood,
Silverado, and Sunnyside aquifers).
As a result, WRD recommends that EPA reconsider the preferred alternative and select a
treatment alternative that covers the entire 160,000-square foot DNAPL-impacted area. WRD
believes this more conservative approach could not only ensure the success of the Dual Site
Groundwater remedy, but also could better address areas that may now, or expect to, contain
mobile DNAPL should groundwater levels continue to rise in the region. On page 15 of the
DNAPL Proposed Plan, EPA states, "Alternative 6B, ERH treatment of the entire treatment
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area [i.e. full extent of both mobile and residual DNAPL at the Montrose Site], was ranked
lower because it is more difficult to implement due to the larger treatment volume, and
because of the considerably higher cost of this alternative compared to Alternative 6A [ERH,
Focused Treatment Area]."
Although Alternative 6B may cost more than Alternative 6A, Alternative 6B may be
conducted in multiple phases of work, starting with the focused treatment area, and allow
EPA the flexibility to refine the remedial design based on the current full extent of DNAPL.
Experience at many contaminated sites has shown that the best approaches for remediation
often contain a combination of remedial technologies, and that within these suites of
technologies, some may be multi-phased in order to neutralize all identified chemicals of
concern.
EPA Response: The DNAPL extent at the Montrose Site was delineated based on
numerous field and laboratory testing performed over a period of about 20 years, from
the 1990s through 2009. These investigations included drilling and sampling of over
200 soil borings, laboratory testing, DNAPL extraction tests, depth-discrete
groundwater and soil sampling, etc. The following lines of evidence were considered
for delineating DNAPL:
• Visual inspection
• Staining on a hydrophobic dye-impregnated fabric (FLUTe™ ribbon)
• Concentrations of chlorobenzene and DDT in discrete soil samples
• Depth-specific groundwater samples
• OVA field soil headspace measurements
After the ERH Pilot Study and additional investigations, we were able to further
define the solubility for different soil types. For the site-specific conditions, analytical
testing indicated that a DNAPL saturation greater than 27 percent in sands or 15.8
percent in silts may be considered mobile. The area of mobile DNAPL was further
refined during pilot scale implementation and it is documented in the Focus Treatment
Area Boundary Confirmation Sampling Report (TRS, 2020).
With regard to the comment on Alternative 6B, EPA determined that this alternative
is ranked lower than Alternative 6A and therefore will not be the selected remedy. This
is because Alternative 6B, while more aggressive than 6A, cannot remove sufficient
DNAPL mass to meaningfully reduce the time required for long-term hydraulic
containment performed as part of the OU-3 Dual Site Groundwater remedy (see Final
DNAPL FS, AECOM, 2013). Therefore, treatment of the entire area by ERH offers
little advantage over the focused treatment area alternative (Alternative 6A) in terms
of the long-term effectiveness and remedy permanence. Because mobile DNAPL
occurs primarily within the Focused Treatment Area, Alternative 6B is similar to
Focused Treatment Area Alternative 6A with regard to the ability to reduce the mobile
DNAPL mass, limit uncontrolled migration of mobile DNAPL, and reduce the
potential for recontamination of the aquifers outside the TI Waiver Zone. On the other
hand, and as acknowledged by your comments, Alternative 6B requires a large amount
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of infrastructure for subsurface heating, and if implemented, would be one of the
largest and most complex thermal remedies ever implemented. In addition, Alternative
6B poses higher risks of uncontrolled DNAPL migration and fugitive emissions, which
need to be controlled due to the proximity of commercial buildings to the former
Montrose plant property boundary. Alternative 6B has implementability challenges
associated with the substantially increased scale and size of the remedy. In addition,
the cost of Alternative 6B is significantly greater than Alternative 6A; however, long-
term effectiveness and remedy permanence of Alternatives 6A and 6B are relatively
similar. While multiple phases of work may reduce the complexity concerns, it does
not address the concerns regarding the greater cost of Alternative 6B with minimal
increased long-term effectiveness and remedy permanence compared to Alternative
6A. Therefore, Alternative 6B was not selected as a preferred alternative.
Finally, in response to rising groundwater levels causing residual DNAPL to become
mobile, residual DNAPL that may remain in the subsurface following completion of
treatment under the focused treatment area ERH alternative will be trapped in the pore
spaces of soil particles by capillary forces. This residual DNAPL cannot move laterally
and/or vertically under natural hydraulic conditions, and therefore will not be
remobilized by in the rising local water table elevations. In addition, although
Alternative 6A does not include treatment of all the residual DNAPL in the UBA, it
does include treatment via SVE of all of the DNAPL-contaminated unsaturated zone.
Thus, the rising groundwater table cannot mobilize DNAPL that becomes submerged
in the future.
We agree with the statement regarding a combination of remedial technologies.
However, based on the results from the ERH Pilot Study, we will not need a potential
polishing technology after the completion of the ERH treatment.
Comment II-5. Depth of the ERH Electrodes - The DNAPL Proposed Plan does not describe
the vertical extent of mobile DNAPL, so it is unclear how deep the ERH electrodes and
multiphase extraction wells will be installed as part of the preferred alternative - 6A.
According to the FS report, DNAPL has been found to a total depth of 101.5 feet below ground
surface. As such, the ERH electrodes and extraction wells should be installed at least to depths
of 101.5 feet below ground surface.
EPA Response: The vertical extent of DNAPL was delineated based on continuous
coring and sampling of over 200 soil borings, visual observations, screening using
FLUTe™ ribbon, and depth-discrete sampling and testing.
The cross-section and two others are included in the ROD (see Figures 2-5 through 2-
7). The vertical distribution data for DNAPL will be used to ensure that the ERH system
is designed to address both lateral and vertical extent of DNAPL within the Focused
Treatment Area and will consider all available vertical and lateral DNAPL distribution
data.
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The DNAPL FS assumed that 1) that 10-foot electrodes would be positioned at
approximately 58 to 68, 75 to 85, and 92 to 102 feet bgs, and 2) that the electrodes are
capable of heating approximately 3 to 4 feet above and below the electrode length.
During remedial design, the specific attributes of electrode placement and operation will
be defined. The intent of ERH application remains the removal of mobile DNAPL,
which is present in the UBA. As such, subsurface heating is anticipated to occur at a
minimum to the deepest depth of DNAPL observed in this aquifer unit.
Comment II-6. Preparation of a Contingency Plan - WRD agrees with the following
statements on page 5 of the DNAPL Proposed Plan, . . mobile DNAPL that is present at
the former Montrose Plant Property remains a threat to groundwater and soil vapor, because
it is capable of continued vertical and/or lateral migration outside the TI Waiver Zone. This
potential migration of mobile DNAPL may result in failure of the groundwater remedy.
Removing mobile DNAPL, therefore, is a critical component in preserving the groundwater
resource and ensuring protection of human health and the environmentTo meet EPA's
remedial action objective to prevent uncontrolled migration and the spread of mobile
DNAPL, WRD recommends preparation of a contingency plan to address other areas of the
Site that may be identified in the future to contain mobile DNAPL, especially since residual
DNAPL may become mobilized due to rising groundwater levels. It would be very helpful
if the contingency plan also summarized how the Montrose Site will continue to be monitored
in the future for mobile DNAPL and how newly identified mobile DNAPL areas will be
remediated.
EPA Response: The performance monitoring plan for the DNAPL remedy will be
developed after the ROD is signed (as part of the remedial design). In addition, the
groundwater MACP can be amended at that time if needed to ensure that both
documents complement each other and adequate data are collected to assess the
performance of both remedies, and to monitor the potential adverse migration of
DNAPL during thermal remedy implementation. As discussed above in the response
to Comment II-4, the residual DNAPL will not be remobilized by rising groundwater
levels.
The RAOs for the DNAPL remedy require limiting lateral and vertical migration of
mobile DNAPL and reducing mobile DNAPL mass to the extent practicable.
Consequently, the selected DNAPL remedy (Alternative 6A) targets the full lateral
and vertical extent of mobile DNAPL delineated by numerous investigations (see
responses to the above comments). Based on the results of these investigations, the
focused treatment area defined by Alternative 6A encompasses the full extent of
mobile DNAPL. Additional sampling to further delineate mobile DNAPL is included
in the Focus Treatment Area Boundary Confirmation Sampling Report (TRS, 2020).
Comment II-7. Institutional Controls - WRD agrees with EPA that the preferred alternative
should include institutional controls that restrict future activities at the entire Montrose
property for industrial use only, as described under Alternative 2 in the DNAPL Proposed
Plan. In addition to implementing a formal site inspection and maintenance program that
would continuously monitor the land use and access restrictions, WRD recommends that the
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institutional controls also prohibit the use of any chemical, including chlorobenzene that
could remobilize or solubilize the DDT that will remain in place onsite.
EPA Response: EPA partly concurs with this comment. The institutional controls for
the DNAPL OU will be limited to restrict future activities for industrial use only.
Further institutional controls will be considered for the soil remedy.
Comment II-8. WRD to be Copied in Technical Correspondence - As EPA is aware, the West
Coast Basin has complexities with regard to pumping rights, replenishment needs,
replenishment assessments, watermaster duties, and the interests of the various cities and
public/private utilities that supply groundwater to residents and businesses, in addition to
concerned stakeholder groups. As the agency responsible for groundwater replenishment, and
water quality and protection within the West Coast Basin and Central Basin, WRD requests
to be included in future stakeholder discussions and copied on all technical correspondence
regarding the cleanup of the Montrose and Del Amo Superfund Sites.
EPA Response: DTSC is the lead state agency and will include WRD as appropriate.
Comment II-9. Revise Document Title to Accurately Reflect the Scope of the Proposed Plan
- The Proposed Plan only addresses confirmed, free phase, mobile chlorobenzene DNAPL
in the UBA beneath a significantly smaller area of the Site (that is, the focused treatment
area).
Based on the limited scope of the DNAPL Proposed Plan, WRD requests the current title be
revised as follows, to more accurately reflect EPA's current remediation objectives:
"Proposed Plan for the Cleanup of Confirmed Mobile Chlorobenzene DNAPL in the Upper
Bellflower Aquitard beneath a Limited Area of the Montrose Chemical Superfund Site."
EPA Response: The Proposed Plan has already been published.
Comment 11-10. Add Section to Proposed Plan Describing the Dual Site Groundwater OU -
EPA's current design of the preferred alternative only addresses the chlorobenzene
component of mobile DNAPL. Thus, residual DNAPL beneath the site, including DDT and
those existing outside the focused treatment area, will remain in place and potentially could
continue to migrate further southeast (downgradient) beyond the limits of the TI Waiver
Zone. As such, the Dual Site Groundwater treatment system will be a necessary component
of the DNAPL cleanup since it will need to be relied upon to capture all contaminants that
will be migrating offsite. WRD recommends that a section be added to the DNAPL Proposed
Plan to describe how the current design of the Dual Site Groundwater treatment system will
accommodate any contamination, in particular, residual chlorobenzene and DDT, that is
anticipated to continue to migrate offsite.
EPA Response: The OU-3 Dual- Site Groundwater remedy includes long-term
hydraulic containment of the DNAPL-contaminated area and a buffer around this area
referred to as the TI Waiver Zone. The OU-3 Dual Site Groundwater remedy will
contain contaminated groundwater within the TI Waiver Zone and restore groundwater
outside the TI Waiver Zone. The removal and treatment of mobile DNAPL will assist
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the OU-3 Dual Site Groundwater remedy achieve these purposes within the timeframe
designated in the OU-3 Dual Site Groundwater ROD. Without removal of the mobile
DNAPL, migration of mobile DNAPL to groundwater would significantly increase the
time required for long-term hydraulic containment under the OU-3 Dual Site
Groundwater remedy and remedy duration identified for this remedy would not be met.
This long-term containment is also discussed in detail in the OU-3 Dual Site
Groundwater ROD (EPA, 1999).
Comment 11-11. Duration of Preferred Alternative is Inconsistent - On page 9 of the DNAPL
Proposed Plan where Alternative 6A is discussed, the duration of this treatment is described
as "4 to 7 years," while the duration of Alternative 6A is described as "4 years" on page 14
of the Proposed Plan. Please provide an explanation on why the duration is inconsistently
referenced for the same alternative. Secondly, WRD recommends adding a section to the
DNAPL Proposed Plan to describe the measures that will be in place to ensure that all mobile
DNAPL has been completely removed from the Montrose Site, how residual DNAPL will
continue to be monitored throughout the entire Site to confirm that it has not become
mobilized, and how onsite areas that are identified to contain mobile DNAPL in the future
will be remediated.
EPA Response: The duration of four to seven years for Alternative 6A represents an
FS-level estimate that will be refined during the remedial design. It reflects the
uncertainty associated with the amount of time required to run the ERH system to
remove all mobile DNAPL. The time duration for the selected alternative discussed in
the Proposed Plan will be refined in the future remedial action process. As discussed
in the above responses, the performance monitoring plan for the DNAPL remedy
(including the verification program for the removal of mobile DNAPL) will be
developed after the ROD is signed as part of the remedial action process.
Comment 11-12. Nearest Drinking Water Wells - On page 3 of the DNAPL Proposed Plan, it
states the following, "Although the State of California designates all of the water-bearing
units beneath the Montrose property as having potential potable beneficial use, there are
currently no known municipal or private potable production wells in use within the area of
DNAPL distribution and/or dissolved groundwater contamination at the Montrose Superfund
Site.
The nearest municipal supply wells are located more than 2 miles from the Montrose
property, and about 0.5 to 1 mile southeast from the furthest extent of groundwater
contamination related to the Montrose and Del Amo Superfund Sites." As a clarification, the
second sentence should be revised to add "downgradient," so that the sentence reads as
follows: "The nearest downgradient municipal supply wells are located more than 2 miles ..."
Secondly, EPA may want to consider designating a buffer zone around the Montrose and Del
Amo Superfund Sites and establishing formal notification procedures for future production
wells that may be installed in the area, which could potentially impact future operations of
the Dual Site Groundwater Treatment System.
Ill
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EPA Response: EPA partially concurs with these comments. However, the potential
impact of new production wells on EPA's ability to implement the OU-3 Dual Site
Groundwater remedy will be addressed under the Groundwater OU.
Comment 11-13. Figures 5 and 8 are Exactly the Same - Figures 5 and 8 have different titles,
but the figures are exactly the same. Based on the title of Figure 8 ("ERH in the Focused
Treatment Area") and the description of Figure 8 under the preferred alternative - 6A, it
appears that the wrong Figure 8 was inserted into the DNAPL Proposed Plan. Currently,
Figure 8 does not depict or reference ERH within the figure. Please issue a Revised DNAPL
Proposed Plan with the correct Figure 8.
EPA Response: Figures presented in the Proposed Plan that are carried forward to the
ROD will be reviewed and altered as necessary to reflect text content.
Comment 11-14. Permitting for Reiniection of Treated and Untreated Water - Waters of the
State beneath the Site, including the Upper Bellflower Aquitard (UBA), Middle Bellflower
Sand (BFS), Lower Bellflower Aquitard (LBA), Gage aquifer, and Lynwood aquifer, are
designated for beneficial use, and therefore must be protected. WRD strongly opposes the
discharge of untreated water into the subsurface that could further degrade the water quality
of these aquifers. With regard to reinjection of treated water, WRD recommends that EPA
and the Los Angeles RWQCB adopt limits of "nondetect" for anthropogenic chemicals of
concern where no scientific or regulatory criteria exist, which is in accordance with the State
Antidegradation Policy (Resolution No. 68-16 adopted by the State Water Resources Control
Board on October 28, 1968). The State Anti degradation Policy was established to maintain
aquifers with the "highest water quality consistent with the maximum benefit to the people
of the State" and protect the designated beneficial uses. All reinjection activities should
comply with State Waste Discharge Requirements.
EPA Response: Reinjection is a component of the remedy for the OU-3 Dual Site
Groundwater remedy.,. Under the OU-3 Dual Site Groundwater remedy, EPA will
work with the RWQCB with respect to State Waste Discharge Requirements and the
State Anti degradation Policy.
Comments from the Department of Toxic Substances Control (DTSC)
Comment 11-15 - The Proposed Plan for Montrose Superfund Site hinges on the removal of
mobile DNAPL within the focused treatment area (approximately 26,000 square feet) in the
UBA. The Proposed Plan states the fundamental assumption on page 7 under Summary and
Risk and Basis for Action that "Removing mobile DNAPL, therefore, is a critical component
in preserving the groundwater resource and ensuring protection of human health and the
environment. Residual DNAPL is trapped in pore spaces between soil particles and cannot
migrate in the subsurface under natural conditions. Therefore, only mobile DNAPL is
considered to be a principle threat." Subsequently, it points out the preferred remedial
alternative discussed in this Proposed Plan is focused on preventing uncontrolled migration
and spreading of mobile DNAPL to ensure (1) protection of human health and the
environment, and (2) the success of groundwater remedy at the Montrose Superfund Site.
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Basically, the Proposed Plan assumes the majority of mobile DNAPL only exists in the UBA
within the small area at CPA and neglects mobile DNAPL that may have migrated vertically
into deeper B-Sand, C-Sand, and Gage aquifers, and horizontally to a larger area outside the
focused treatment area due to historical releases.
EPA Response: EPA responded to this comment as part of the responses to the FS
comments that were accepted by DTSC. As detailed in the response to comment II-4,
the area of mobile DNAPL in the UBA was delineated, after numerous soil borings
were drilled during the DNAPL reconnaissance. The extent of mobile DNAPL may be
further refined, if warranted, during the remedial design and remedial action phases of
work, with input from the State. If it is determined that mobile DNAPL is present
outside the focused treatment area, the remedial action process will be adjusted to
include these additional areas of mobile DNAPL.
Comment 11-16. Protection of Human Health and the Environment - In our opinion, the
protection of human health by preventing either soil vapor emissions to surface inhabitants
(vapor intrusion potential) or direct contact with contaminated soils will be manageable and
less an issue, especially since the Site is unoccupied. The potential remains for vapor intrusion
to be an issue of concern in the downgradient residential area. Currently, the EPA Remedial
Project Manager is dealing with this issue as required. Therefore, the evaluation for human
health risk protection appears to be moving toward a reasonable resolution. However, the
protection of groundwater and drinking water resources remains. A few outstanding issues
that should be resolved include:
A. How to ensure DNAPL mass won't continuously spread outside TI Waiver Zone?
EPA Response: This is the primary objective of the DNAPL remedy and it will be
achieved by the implementation of ERH with SVE and it will be contained as required
by the OU 3 Groundwater ROD for the TI Waiver Zone.
B. No continuous vertical migration to deeper aquifers, especially to Gage and Lynwood zones.
EPA Response: Vertical migration of the dissolved plume will be addressed by the
OU-3 Dual Site Groundwater remedy and is not discussed in the Proposed Plan for
DNAPL. Vertical migration of DNAPL that may occur during implementation of ERH
will be addressed by the "bottom up heating approach" as described earlier in this ROD
and in the Final FS (AECOM, 2013) and performance monitoring.
C. Whose responsibility is it to maintain the hydraulic containment extraction wells to capture
outgoing plume (Proposed Plan or Groundwater Remedy), and where they are located?
EPA Response: Extraction well locations for the Chlorobenzene Plume are detailed
in the OU-3 Dual Site Groundwater remedy. These wells have been extracting at low
flow rates since February 2019 as part of functional testing of the groundwater
treating system in Montrose. The PRP will retain responsibility to evaluate and
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demonstrate that groundwater containment and restoration requirements stipulated by
the RODs for DNAPL OU remedy and the OU-3 Dual Site Groundwater remedy are
fulfilled. Montrose, Atkemix Thirty-Seven, Inc., and Aventis CropScience USA, Inc.
are jointly and severally liable for all costs of removal or remedial action incurred by
the United States or DTSC with respect to the former Montrose plant property,
including groundwater contamination.
D. The groundwater remedy is expected to shut down in 50 years, and the hydraulic
containment system is expected to operate for thousands of years. Discontinuation of the
groundwater remedy is contingent upon the hydraulic containment extraction wells stopping
plume migration and capturing the plume from the DNAPL source before it migrates to
downgradient areas. The interconnectivity between the DNAPL removal and containment
wells, and the containment wells and the groundwater remedy must be clearly specified.
Additionally, performance metrics must be established upfront with a contingency plan in
place in case of failure.
EPA Response: It is stated in the Proposed Plan that the remedial actions for the
selected DNAPL OU remedy will complement the groundwater cleanup action selected
by the OU-3 Dual Site Groundwater ROD for the Groundwater OU. The removal of
mobile DNAPL is critical to the success of the OU-3 Dual Site Groundwater remedy
because DNAPL acts as a source to groundwater contamination. Through removal of
the mobile DNAPL source, the likelihood of groundwater remedy failure is
substantially reduced. As such, performance monitoring and optimization for both the
DNAPL and groundwater remedies remains key to successful restoration of the Site.
E. The MACP for mobile DNAPL depletion and MACP for Dual Site Groundwater remedy
should be integrated as a holistic MACP for the entire groundwater medium, instead of
each MACP acting independently without linking to each other.
EPA Response: While we agree that this is the most technically appropriate approach,
the regulatory process may not allow for these two documents to be developed at the
same time. While the groundwater MACP is being developed now, the performance
monitoring plan for DNAPL can only be developed after the ROD is signed (as part of
the remedial design). However, the groundwater MACP can be amended at that time if
needed to ensure that both documents complement each other, and adequate data are
collected to assess the performance of both remedies.
F. How to ensure the Proposed Plan can remove mobile DNAPL at the source area and how
to effectively measure the system performance and effectiveness? Will the hydraulic
containment wells be designed to be part of DNAPL removal or groundwater remedy?
EPA Response: This was addressed by the FS in terms of the ability of the selected
technology to remove DNAPL, and will be verified in the field in accordance with the
performance monitoring plan that will be developed during the remedial action process.
The hydraulic containment wells are part of the OU-3 Dual Site groundwater remedy.
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G. If the Proposed Plan does not meet the designated objective (that is, leaking DNAPL
mass detected), then what are the corrective action or mitigation measures to be
implemented?
EPA Response: This issue will be addressed in the performance monitoring plan that
will be developed during the remedial action process. If mobile DNAPL is detected in
deeper aquifers (that is, the Middle Bellflower C Sand [MBFC]), the remedial actions
may be expanded to include these units. The RAOs established for DNAPL OU
requires removal of DNAPL to the extent practicable.
H. Will the dissolved plume emanating from the DNAPL source be contained and remediated
by OU-3 - Dual Site Groundwater remedy?
EPA Response: Yes. This is the primary objective of the OU-3 Dual Site Groundwater
remedy. The selected remedy for the DNAPL OU will complement the existing OU-3
Dual Site Groundwater remedy by removing and treating mobile DNAPL. This will
ensure that as the OU-3 Dual Site Groundwater remedy removes and treats
groundwater contamination outside the TI Waiver Zone and contains groundwater
contamination within the TI Waiver Zone, that mobile DNAPL will not continue
adding contamination to the groundwater.
Comment 11-17. Success of Groundwater Remedy at the Montrose Superfund Site.
A. Success of the groundwater remedy depends on the successful resolution of outstanding
issues outlined above. In particular, how to meaningfully shorten the estimated 5,000 years
of operation for the hydraulic containment wells is critical because it remains unreasonably
long. Funding source and complete operation costs are unclear and ill-defined. There is an
undeniable link between the groundwater remedy, hydraulic containment, and DNAPL
removal. Currently, the Proposed Plan is dependent on 5,000 years of hydraulic
containment to contain the DNAPL mass within the TI zone without operating the
groundwater remedy (which will be shut down after 50 years of operation if the chlorinated
volatile organic constituent [CVOC] concentrations in groundwater reach MCLs in
groundwater in the area surrounding the containment zone - a virtually impossible task if
the dissolved-phase CVOCs are not contained within the containment zone).
DNAPL removal is scheduled to take 4 to 7 years. Clearly monitoring should extend
beyond the DNAPL removal period and it may take decades to understand whether the
DNAPL removal was successful and did not push DNAPL deeper and wider than it
currently exists. It seems highly unlikely that the groundwater remedy will be completed
in proposed 50-year duration.
EPA Response: Groundwater monitoring will extend well beyond DNAPL removal
and during the entire duration of groundwater cleanup and containment.
B. In order to document conditions during and after the DNAPL removal, the performance of
DNAPL removal should be extensively monitored at all concerned aquifers (UBA, B-Sand,
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C-Sand, Gage, and Lynwood) to monitor changes in concentration and to ensure there is
no significant amount of DNAPL mass capable of dissolving into groundwater and
migrating away from the containment zone. The DNAPL mass includes mobile (under
gravity) and residual DNAPL mass together. The only way to quantify the mass is through
the groundwater sampling results in the dissolved form. The MACP for DNAPL removal
in the Proposed Plan must be able to indicate the system performance of DNAPL removal
and its effectiveness based on dissolved-phase concentration changes.
Unless proven otherwise, the Proposed Plan should be revised to include additional
remediation measures to augment the remedy by not allowing both DNAPL and dissolved
mass discharge downward or downgradient. Otherwise, the groundwater remedy will be
required to operate until it cleans up the groundwater at concentrations less than the MCL.
EPA Response: The recently complete ERH pilot study demonstrated that ERH can
be implemented to minimize/prevent vertical migration of DNAPL. In addition, as
discussed in EPA responses to the FS comments that were provided by DTSC, a
comprehensive monitoring program will be implemented in coordination with DTSC
to ensure that adverse DNAPL migration into the BFS does not occur during cleanup.
A comprehensive performance monitoring plan for the DNAPL remedy will be
developed during the remedial action process to ensure that DNAPL mass does not
migrate laterally and vertically outside the TI Waiver Zone and that both DNAPL and
groundwater performance monitoring data will be evaluated jointly to ensure that both
remedies meet their performance goals.
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3.2 WORKS CITED
AECOM, 2010. Letter to Carolyn d' Almeida. Montrose Technical Responses to EPA Comments
dated January 27, 2010, DNAPL Feasibility Study, Montrose Superfund Site, Los Angeles,
California. April 27.
AECOM, 2011a. Revised DNAPL Feasibility Study, Montrose Superfund Site, 20201 S. Normandie
Avenue, Los Angeles, California. December 7.
AECOM, 2011b. Report of Two Dimensional Bench Scale Evaluation of DNAPL Mobility During
Steam Flushing, Montrose Superfund Site, Los Angeles, California. December.
AECOM, 2011c. Revised Supplemental Soil Investigation Report, Montrose Superfund Site, Los
Angeles, California. December.
AECOM, 2013. Final DNAPL Feasibility Study, Montrose Superfund Site, 20201 S. Normandie
Avenue, Los Angeles, California. September 27.
ARCADIS, 2011. DNAPL Reconnaissance Investigation Data Report, JC! Jones Chemical, Inc., 1401
W. Del Amo Boulevard, Torrance, California. January 26.
California Department of Water Resources (CDWR), 1961. Planned Utilization of the Ground
Water Basins of the Coastal Plain of Los Angeles County, Appendix A: Ground Water Geology.
Bulletin 104.
California State Water Resources Control Board, 1968. Resolution No. 68-16, Statement of
Policy with Respect to Maintaining High Quality of Waters in California. October.
CH2M HILL, 1999. Final Joint Groundwater Feasibility Study for the Montrose and Del Amo Sites.
CH2M HILL, 2010. Memorandum to Carolyn d' Almeida. Evaluation of the MCB Mass in the UBA
and Bellflower Sand, and Estimates of DNAPL Dissolution and Longevity of Dissolved Plume,
Montrose Superfund Site, Los Angeles, California. September 29.
City of Los Angeles, 1996. Harbor Gateway Community Plan. December 6.
Davis, Eva L. 2006. Final Report and Addendum, One-Dimensional Thermal Remediation
Treatability Study, Montrose Chemical Superfund Site, Los Angeles County, California.
August 24.
Earth Tech, 2004a. Soil Vapor Extraction Pilot Test Report, Montrose Superfund Site. June 28.
Earth Tech, 2004b. Revised HiPOx Pilot Test Report, Montrose Superfund Site. September 23.
Earth Tech, 2004c. Revised Soil Gas Survey Report, Montrose Superfund Site. October 13.
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Earth Tech, 2007a. Revised Draft Workplan for Bench-Scale Evaluation of Electrical Resistance
Heating for the Removal of DNAPL from the Upper Bellflower Aquitard, Montrose Superfund Site.
October 10.
Earth Tech, 2007b. Letter to Mr. Jeffrey Dhont, EPA, Estimated Hydraulic Displacement Remedy
Costs, Montrose Superfund Site. November 12.
Earth Tech, 2008a. Addendum to the Revised Workplans for Two Dimensional Bench Scale
Evaluation of DNAPL Mobility During Steam Flushing and Electrical Resistance Heating, Montrose
Superfund Site, Torrance, California. February 21.
Earth Tech, 2008b. Technical Memorandum to Joe Kelly, Montrose Chemical Corporation, DNAPL
Focused Treatment Area Evaluation, Saturated Upper Bellflower Aquitard (UBA), Montrose
Superfund Site. June 5.
Earth Tech, 2008c. Liquid-Phase Granular Activated Carbon Bench-Scale Testing Report and Cost
Projection, Montrose Superfund Site. November 11.
Earth Tech, 2008d. Technical Memorandum to Joe Kelly, Montrose Chemical Corporation, DNAPL
Well UBE-5, Montrose Superfund Site, Torrance, California. November 13.
Earth Tech, 2009. Memorandum to Joe Kelly. Results of the Short-Term Extraction Test at DNAPL
Well UBE-5, Montrose Superfund Site, Los Angeles, California. May 12.
EPA, 1985. Community Relations Plan for the Montrose and Del Amo Superfund Sites, EPA DCN
0639-00482. July.
EPA, 1996. Update to the Community Relations Plan for the Montrose and Del Amo Superfund
Sites, EPA DCN 0639-02277. November.
EPA, 1998a. Final Remedial Investigation Report for the Montrose Superfund Site, Los Angeles,
California. May 18.
EPA, 1998b. Proposed Plan; Dual Site Groundwater Operable Unit, Montrose and Del Amo
Superfund Sites. June 26.
EPA, 1999. Record of Decision for Dual Site Groundwater Operable Unit, Montrose Chemical and
Del Amo Superfund Sites, Volume I: Declaration and Decision Summary. March .
EPA, 2004. Draft Report Former Montrose Plant Property Reuse Assessment. US EPA Contract
No. 68-W-98-225. CH2M HILL, Inc. and Team Subcontractors. January.
EPA, 2007. Responses to EPA Focus Questions Pertaining to the Application of Thermal
Treatment and Hydraulic Displacement at DNAPL Sites
EPA, 2008. Letter to Mr. Joe Kelly, Montrose Chemical Corporation, EPA Comments on Technical
Memo: Results of Field Investigation into the Presence of DNAPL in the Bellflower Sand;
Montrose Chemical Superfund Site, Los Angeles, CA. August 17.
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EPA, 2010a. Letter to Joe Kelly. EPA Comments on Draft DNAPL Feasibility Study, Montrose
Superfund Site, April2009. January 27.
EPA, 2010b. Community Involvement Plan for the Montrose Superfund Site and Del Amo
Superfund Sites. April.
EPA, 2013a. Memo to Jane Diamond. National Remedy Review Board Recommendations for the
Montrose Superfund Site, Operable Unit 3 - DNAPL, February.
EPA, 2013b. Memo to Amy Legare. Regional Response to the National Remedy Review Board
Recommendations for the Montrose Superfund Site Operable Unit 3 - DNAPL, March.
EPA 2014a, Letter to Joe Kelly. EPA Comments on Draf Final DNAPL Feasibility Study,
Montrose Superfund Site, January 13.
EPA, 2014b. Proposed Plan for the DNAPL Operable Unit, Montrose Superfund Site.
September.
EPA, 2019. Groundwater Treatment Plan Update, Montrose and Del Amo Superfund Sites.
October.
EPA, 2020. Del Amo and Montrose Superfund Sites Community Involvement Plan.
June.
Group Delta, 2017. DNAPL Purging and Recovery Test Results - MBFC Well CMW002
Montrose Superfund Site, Los Angeles, California. December 21
Group Delta, 2020. Recommended Path Forward for MBFC Well CMW002, Montrose Superfund
Site, Los Angeles, California. January 14
Hargis + Associates, Inc. (H+A), 1992. Groundwater Treatability Test Results, Phase I,
Montrose Site, Torrance, California. February 21.
H+A, 1999. Dense Non-Aqueous Phase Liquid Feasibility Study, Montrose Site, Torrance,
California. September 29.
H+A, 2004a. Technical Memorandum to Mr. Jeffrey Dhont, US EPA, DNAPL Investigation
Results, Bellflower Sand, Montrose Site, Torrance, California. January 23.
H+A, 2004b. Results of DNAPL Reconnaissance Investigation, Montrose Site, Torrance,
California, Revision 1.0. October 22.
H+A, 2006a. Technical Memorandum to Susan Keydel, US EPA, DNAPL Reconnaissance
Borings in Support of Earth Tech Soil Sampling Program, Montrose Site, Torrance, California.
January 19.
H+A, 2006b. Technical Memorandum to Mr. Jeffrey Dhont, US EPA, DNAPL Boiling Test
Results, Montrose Site, Torrance, California. August 7.
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H+A, 2007a. 2006 Groundwater Monitoring Results Report, Montrose Site, Torrance,
California. February 28.
H+A, 2007b. DNAPL Extraction Test Summary Report, Montrose Site, Torrance, California,
Revision 1.0. September 18.
H+A, 2008a. Technical Memorandum RE: Results of Depth Discrete Groundwater Sampling of
Three Bellflower Sand Wells, Montrose Superfund Site, Torrance, California. April 14.
H+A, 2008b. Technical Memorandum to Jeffrey Dhont, US EPA, Results of Field Investigation
into the Possible Presence of DNAPL in the Bellf lower Sand, Montrose Superfund Site, Torrance,
California. June 24.
H+A, 2008c. Technical Memorandum to Jeff Dhont, US EPA, Evaluation of Containment Zone
Timeframes Following a DNAPL Remedy at the Montrose Site, Torrance, California, September 4
and subsequent email, Lack of Documentation in Containment Zone/Timeframes Following a
DNAPL Remedy Tech Memo. September 9.
H+A, 2008d. Email to Jeff Dhont, US EPA, DNAPL Thickness Map. January 22.
H+A, 2008e. DNAPL Extraction Test Summary Report, Montrose Site, Torrance, California,
Revision 2. June 4.
H+A, 2009a. Technical Memorandum to Jeffrey Dhont, US EPA, Status of Hydraulic
Displacement Modeling, Montrose Site, Torrance, California. January 15.
H+A, 2009b. Results of Hydraulic Displacement Modeling, Montrose Site, Torrance, California.
April 6.
H+A, 2009c. Technical Memorandum to Carolyn d' Almeida, US EPA, Evaluation of Containment
Zone Timeframes Following a DNAPL Remedy at the Montrose Site, Torrance, California,
Revision 1.0 and Response to EPA Comments. March 25.
Latham & Watkins, 2010. Letter to Taly Jolish, Response to EPA Comments Regarding Montrose
Feasibility Study. April 28.
Queen's University, 2009. Technical Memorandum to J. Kelly, Montrose, Summary of
Bench Scale Evaluation of Electrical Resistance Heating for the Removal of DNAPL from the
Upper Bellflower Aquitard. March 17.
TRS, 2019. Electric Resistant Heating Pilot Study Report, Montrose Superfund Site, Los Angeles,
California. December.
TRS, 2020. Boundary Confirmation Focused Treatment Area Boundary Confirmation Sampling Event
Results Montrose Superfund Site. May.
University of Toronto, 2009. Letter to Michael Palmer, de maximis. Update on Two-
Dimensional Bench Scale Testing of Steam Flushing. March 17.
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APPENDIX A ADMINISTRATIVE RECORD INDEX FOR OU-3 - DNAPL
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SEMS-RM DOCID # 100021223
Montrose Chemical Corporation
Superfund Site
Torrance, California
Dense Non-Aqueous Phase Liquid
(DNAPL) Operable Unit (OU-3)
NPL Site Administrative Record File
Index
First Released: 09/05/2014
Updated: 08/18/2020
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About the Administrative Record
This administrative record file contains the documents that the U.S. Environmental Protection
Agency (EPA) is currently using to identify appropriate remedial activities for the Montrose
Chemical Corp. Superfund Site, Dense Non-Aqueous Phase Liquid Operable Unit in Torrance,
California. The administrative record file will be supplemented periodically; it will be complete
after public comments on EPA's Proposed Plan, EPA's response to comments, and the Record of
Decision (ROD) are included.
This administrative record file also includes by reference the documents in the Montrose
Chemical Corp. Superfund Site, Dual Site Groundwater Operable Unit Administrative Record,
first released May 29, 1998, updated June 30, 1998 and March 30, 1999.
EPA welcomes questions and comments on documents contained in the administrative record
file. Please contact:
Yarissa Martinez Leon or: Romie Duarte
Remedial Project Manager Community Involvement Coordinator
U.S. EPA (SFD-7-2) U.S. EPA (OPA-2)
Los Angeles, CA 90017 Los Angeles, CA 90017
Martinez.Yarissa@epa.gov Duarte.Romie@epa.gov
(213)244-1806 (213)244-1801
What is an Administrative Record?
An administrative record is a collection of documents that forms the basis for an agency's
decision, in this case the selection of a response action at a Superfund site. This does not mean
that only documents that support a response decision are placed in the administrative record.
Relevant documents that were relied upon in selecting the response action, as well as relevant
documents that were considered but ultimately rejected, are included. The administrative record
also acts as a vehicle for public participation in selecting a response action.
Under section 113(K) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act
(SARA), the U.S. Environmental Protection Agency (EPA) is required to establish an
administrative record for every Superfund response action and to make a copy of the
administrative record available at or near the site. The administrative record must be reasonably
available for public review during normal business hours. Questions regarding the maintenance
of the administrative record file should be directed to:
Elaine Chan, Administrative Record Coordinator, U.S. EPA (SFD-7-5), 75 Hawthorne Street,
San Francisco, CA 94105-3972, Phone: (415) 972-3128
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How to obtain copies of administrative record documents:
Individuals may copy any documents contained in the administrative record file according to the
procedures at the local repository or request copies of the records by calling the Regional
Records Center at (415) 947-8717.
Montrose Chemical Corp. Superfund Site
Dense Non-Aqueous Phase Liquid (DNAPL) Operable Unit (OU-3) Update
Administrative Record
Acronyms and Abbreviations
ABBREVIATION
MEANING
App
Appendix
AR
Administrative Record
Attch(s)
Attachment(s)
Ave
Avenue
CA
State of California
DNAPL
Dense Non-Aqueous Phase Liquid
DTSC
California Department of Toxic Substances Control
DVDs
Digital Video Disc(s) or Digital Versatile Disc(s)
E
East
EE/CA
Engineering Evaluation/Cost Analysis
Encl(s)
Enclosure(s)
EPA
Environmental Protection Agency
Et al
and others
fr
From
FS
Feasibility Study
FSP
Field Sampling Plan
GAC
Granular Activated Carbon
HiPOx
Oxidation process for water treatment
Inc
Incorporated
Info
Information
Ltr
Letter
MCB
Monochl orob enzene
Memo
Memorandum
MS
Microsoft (corporation)
Mtg
Meeting
NAPL
Non-Aqueous Phase Liquid
OU
Operable Unit
pCBSA
Para-Chlorobenzene Sulfonic Acid
PDF
Portable Document Format
PID
Photoionization detector (gas detector)
Pp
Pages
Ppmv
Parts per million by volume (unit of measurement)
Pt
Part
-------
QAPP
Quality Assurance Project Plan
RA
Remedial Action
Re
Regarding
Ref
Reference (indicates original title of email)
Rev
Revision
RI
Remedial Investigation
ROD
Record of Decision
Rpt(s)
Report(s)
S
South
SVE
Soil Vapor Extraction
TCE
Trichloroethene
TL(s)
Transmittal Letter(s)
UBA
Upper Bellflower Aquitard
USA
United States of America
V
Volume
vs
Versus
w/
with
w/o
without
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1144638
9/1/1968
Planned utilization of groundwater basins - coastal plain
of Los Angeles County (Dept of Water Resources Bulletin
#104)
R09: (CA Resources Agency - Dept of Water
Resources)
30406
7/11/1989
Amendment #2 to administrative order on consent for
FS, docket #85-04B, w/apps B-C (EE/CA & FS workplan)
R09: Zelikson, Jeff (Environmental
Protection Agency - Region 9)
88039775
2/21/1992
Groundwater treatability test results, phase 1
R09: (Hargis + Assoc, Inc)
88040526
6/28/1995
Preliminary endangerment assessment, Jones Chemicals
facility, Torrance, CA, vl
R09: (Levine-Frieke, Inc)
R09: (Jones Chemicals, Inc)
88040527
6/28/1995
Preliminary endangerment assessment, Jones Chemicals
facility, Torrance, CA, v2 (appendices)
R09: (Levi ne-Fri eke, Inc)
R09: (Jones Chemicals, Inc)
88042350
2/24/1997
Montrose natural attenuation study (phase 1), w/errors
Itr, 3/10/97, & TL to J Dhont fr F Bachman, 4/9/97
R09: Gray, A (Zeneca Inc), R09: Rumford, S
(Zeneca Inc)
R09: (Montrose Chemical Corp)
88042329
6/4/1997
Ltr: Discusses & transmits results of para-chlorobenzene
sulfonic acid (p-CBSA) activated carbon treatability
studv, w/attch
R09: Jones, Douglas (McLaren/Hart
Environmental Engineering Corp)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
88043311
5/18/1998
Final Rl rpt for Montrose site, vl of 2
R09: (Montrose Chemical Corp), R09:
(Environmental Protection Agency - Region
9)
88043312
5/18/1998
Final Rl rpt for Montrose site, v2 of 2
R09: (Montrose Chemical Corp), R09:
(Environmental Protection Agency - Region
9)
88044144
3/26/1999
Final rpt - sewer sediment removal action w/appendices
A-H
R09: (Earth Tech, Inc)
R09: (Montrose Chemical Corp)
46391
3/30/1999
Record of decision (ROD) for dual site groundwater OU,
vl of 2 - declaration & decision summary (03 ROD 02
fMontrosel) (03 ROD 03 fDel Amol)
R09: (Environmental Protection Agency -
Region 9)
2061797
9/1/1999
Soil FS, w/appendices & TL to J Dhont fr B Dean 9/17/99
R09: (Earth Tech, Inc)
R09: (Montrose Chemical Corp)
Page 1 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
88044167
9/29/1999
DNAPL FS, w/TL to J Dhont fr D Hargis
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2091236
7/19/2000
Ltr: DNAPL FS remedy selection
R09: Hargis, David (Hargis + Assoc, Inc)
R09: Bachman, Frank (Montrose
Chemical Corp)
2092697
3/27/2001
Ltr: Transmits comments on Technical Memo -
Clarification of groundwater ROD issues, 20201S
Normandie Ave (1/3/01), w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Bachman, Frank (Montrose
Chemical Corp)
2194143
3/27/2002
Overheads: Montrose site DNAPL program update
R09: Palmer, Michael (Hargis + Assoc, Inc)
2087398
4/22/2002
Memo: Review of 6 phase heating laboratory testing
workplan, FSP for reconnaissance DNAPL assessment, &
DNAPL extraction treatability test workplan, w/TL fr D
R09: Davis, Eva (Environmental Protection
Agency - National Risk Management
Research Laboratorv), R09: Acree, Steven
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
131728
5/24/2002
Memo: Comments on draft field sampling plan (FSP)
reconnaissance DNAPL assessment, w/TL to K Salyer fr H
Salloum 6/17/02
R09: Gonzales, Frank (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: Conti, Gloria (CA
Environmental Protection Agency
- Dept of Toxic Substances
131735
5/28/2002
Memo: Comments on draft DNAPL extraction
treatability test workplan, w/TL to K Salyer fr H Salloum
6/17/02
R09: Gonzales, Frank (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: Conti, Gloria (CA
Environmental Protection Agency
- Dept of Toxic Substances
131377
6/5/2002
Memo: Comments on draft 6 phase heating laboratory
testing workplan w/TL K Salyer fr H Salloum 6/17/02
R09: Bekele, Tizita (CA Dept of Health
Services - Toxic Substances Control Div)
R09: Conti, Gloria (CA
Environmental Protection Agency
- Dept of Toxic Substances
130954
6/24/2002
Partial consent decree #CV 90-3122-R, relating to
neighborhood areas, for recovery of response costs,
USA & State of CA vs Montrose Chemical Corp of CA, et
R09: (US Dept of Justice - Environment &
Natural Resources Div)
2187508
7/9/2002
CPT/ROST (Cone Penetrometer Test/Rapid Optical
Screening Tool) DNAPL reconnaissance field sampling
plan, w/TL to K Salver fr M Palmer & response to
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
131737
7/21/2002
Comments on proposed treatability study - steam
stripping treatability testing workplan, w/TL to K Salyer
fr M Palmer 8/14/02
R09: (Hargis + Assoc, Inc)
R09: (Environmental Protection
Agency - Region 9)
1134278
7/30/2002
Ltr: Advance groundwater work - preliminary
groundwater modeling, w/email TL
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
Page 2 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2088797
9/25/2002
Fact Sheet: Current ongoing activities for Montrose site
& groundwater for Del Amo site
R09: (Environmental Protection Agency)
1116935
11/26/2002
Email: Transmits & discusses revised thermal treatability
study workplan, w/attchs (Thermal Treatability Study
Work Plan Nov 26.wpd, Appendix A QAPP.wpd, &
R09: Salyer, Kathleen (Environmental
Protection Agency - Region 9)
R09: Conti, Gloria (CA
Environmental Protection Agency
- Dept of Toxic Substances
1114855
12/18/2002
Ltr: Comments on steam stripping treatability testing
workplan, w/encl & email TL fr M Palmer
R09: Palmer, Michael (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: Salyer, Kathleen
(Environmental Protection
Agencv - Region 9)
2090040
12/23/2002
DNAPL reconnaissance FSP, w/TL to K Salyer fr M Palmer
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2090069
1/23/2003
Ltr: Summarizes steam injection & 6 phase heating
(SPH) technology being considered for DNAPL extraction
test program
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2093522
1/23/2003
Technical Memo: DNAPL investigation results, Bellflower
sand, w/attch 1 (Figure 1), w/o attch 2 (Figure 2)
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1142054
2/5/2003
Email: SVE Pilot Test - emission limits for SVE skids
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1142073
2/6/2003
Email: Distance of nearest house fr SVE unit (ref SVE
Pilot Test Schedule), w/history
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1142053
2/10/2003
Email: SVE Pilot Test - stack height, diameter &
discharge velocity
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1114861
2/13/2003
Ltr: Comments on draft DNAPL reconnaissance field
sampling plan dated 12/23/02, w/email TL to J Kelly et al
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1117380
2/13/2003
Ltr: Documentation of 1/28 meeting on DNAPL
remediation, & EPA response to Montrose comments
on draft steam test workplan, w/email forward to J
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1116143
2/14/2003
Email: Reconnaissance workplan comments reflect DTSC
as well as EPA, w/history
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Sundberg, Paul (Paul V
Sundberg, Project Consultant)
Page 3 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1114862
2/19/2003
Ltr: EPA response to comments on steam plan /
outcome of DNAPL meeting, w/email TL to J Kelly et al
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1114814
2/24/2003
Ltr: Interim comments on DNAPL extraction test
workplan, w/email TL to J Kelly et al & attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1144637
3/3/2003
Ltr: Buried concrete debris & DDT-impacted soil
volumetric estimates, w/attchs
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1115087
3/11/2003
Email: Advanced Oxidation Potential Pilot Test,
w/forward to J Kelly 3/13/03
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Sundberg, Paul (Paul V
Sundberg, Project Consultant)
1116579
4/2/2003
Email: Response to your inquiries & additional direction
on soil gas investigation - transmits modified map,
w/attch (Soil Gas Survev Map.bmp)
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Sundberg, Paul (Paul V
Sundberg, Project Consultant)
2093281
4/3/2003
DNAPL reconnaissance FSP, w/TL to J Dhont fr M Palmer
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
1142080
4/18/2003
Email: Preliminary response to question on DNAPL
Curves & Residual Saturation, w/history
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1132866
4/28/2003
Email: Transmits & discusses 4/25/03 memo & 4/10/03
APT (Applied Process Technology, Inc) doc (ref HiPOx
Test (Advanced Oxidation), w/attchs (eoa-advise.doc &
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Conti, Gloria (CA
Environmental Protection Agency
- Dept of Toxic Substances
1114864
5/1/2003
Ltr: Conditional approval of DNAPL reconnaissance test
sampling plan, w/email TL to J Kelly et al
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2056693
5/1/2003
Fact Sheet: Update on field & laboratory studies at
former Montrose plant property (Spanish)
R09: (Environmental Protection Agency -
Region 9)
2056694
5/1/2003
Fact Sheet: Update on field & laboratory studies at
former Montrose plant property (English)
R09: (Environmental Protection Agency -
Region 9)
2194455
6/1/2003
HiPOx demonstration test workplan, w/TL to J Dhont fr
B Dean 6/16/03 & marginalia
R09: (Earth Tech, Inc)
R09: (Montrose Chemical Corp)
Page 4 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1142072
6/9/2003
Email: Confirmation re purging 3 well volumes before
monitoring (ref SVE Pilot Test Schedule), w/history
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1142087
6/9/2003
Email: Requests verification that purge volume is 3 well
volumes equivalent (ref SVE Pilot Test Schedule),
w/historv
R09: Pathak, Am it (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9), R09: Dean,
1114833
6/12/2003
Email: Transmits unsigned final 1-dimensional steam
test plan, QAPP & response to comments, w/attchs
(comments on Montrose CMTs 1-D Steam Work Plan, 1-
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2090010
6/12/2003
Ltr: Transmits Response to comments on EPA workplan
for 1-dimensional thermal treatability study using steam
injection (2/03), w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Sundberg, Paul (Paul V
Sundberg, Project Consultant)
2088871
7/18/2003
Ltr: Comments on Draft HiPOx pilot test rpt (6/03)
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2198009
7/24/2003
Ltr: Interim comments on draft workplan for DNAPL
extraction test, dated 7/8/03, & associated with white
paper dated 11/20/02, w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2235686
7/24/2003
Ltr: Meeting on DNAPL remediation held 1/28/03, EPA
response to Montrose comments on draft steam test
workplan, w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1142055
7/29/2003
Email: SVE Pilot Testing for Playa Deposit terminated,
testing activities now complete
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9), R09: Nezafati,
2090072
7/31/2003
Response to EPA comments on HiPOx demonstration
test workplan, w/TL to J Dhont fr B Dean 7/31/03
R09: (Earth Tech, Inc)
R09: (Environmental Protection
Agency - Region 9)
2198003
7/31/2003
Revised HiPOx demonstration test workplan
R09: (Earth Tech, Inc)
R09: (Montrose Chemical Corp)
1114878
9/8/2003
Ltr: Approval of HiPOx demonstration test workplan,
w/email TL to J Kelly et al
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2088875
9/8/2003
Ltr: Grants conditional approval of alternate drilling
methods for completing DNAPL reconnaissance project
(9/3/03)
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
Page 5 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1114789
9/22/2003
Technical Memo: Response to EPA conditional approval
of DNAPL reconnaissance program, w/email TL to J
Dhont, et al fr A Akacki 9/22/03 & attchs
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1141837
11/21/2003
Email: Update on status of DNAPL reconnaissance
borings
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Davis, Eva (Environmental
Protection Agency)
1141829
11/24/2003
Email: Update to issues of additional NAPL source areas
(ref Update on status of DNAPL reconnaissance borings),
w/historv
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Davis, Eva (Environmental
Protection Agency)
1141827
12/1/2003
Email: Response to email re time constraints for revised
DNAPL reconnaissance Boring Additional Sampling,
w/historv
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Sundberg, Paul (Paul V
Sundberg, Project Consultant)
2093528
12/9/2003
Article: Mechanistic evaluation of DNAPL mobility for
Montrose Torrance Superfund site (workplan)
R09: Udell, Kent (Univ of California,
Berkeley)
R09: (Environmental Protection
Agency - Region 9)
2061201
12/10/2003
Mtg Notes: 12/4/03 Montrose-EPA mtg
R09: Sturn, Richard (C H 2 M Hill, Inc)
2061232
1/1/2004
Draft rpt, former Montrose plant property reuse
assessment, w/TLto J Kelly fr S Keydel 1/30/04
R09: (C H 2 M Hill, Inc)
R09: (Environmental Protection
Agency - Region 9)
2090074
1/7/2004
Ltr: Comments on Technical Memo - siting of injection
wells for DNAPL extraction test program (12/19/03)
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1141822
1/12/2004
Email: Response to Montrose DNAPL reconnaissance
conference call reminder for 1/14, w/history
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (Hargis+
Assoc, Inc)
2194462
1/13/2004
Email: Summary of current status of DNAPL
reconnaissance program & rationale for proposed
boring locations, w/attchs (4) & marginalia
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1141833
1/20/2004
Email: Response to DNAPL reconnaissance conference
call summary
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (Hargis+
Assoc, Inc), R09: Sundberg, Paul
(Paul V Sundberg, Proiect
2090563
1/22/2004
Ltr: EPA comments on Mechanistic evaluation of DNAPL
mobility (12/15/03)
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
Page 6 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1117374
1/23/2004
Technical Memo: DNAPL investigation results, Bellflower
Sand, w/attchs
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1141762
1/23/2004
Email: Follow-up DNAPL reconnaissance - Boring E had
PID readings exceeding 9000 ppmv
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (Hargis+
Assoc, Inc), R09: Sundberg, Paul
(Paul V Sundberg, Proiect
2093282
2/6/2004
DNAPL extraction test workplan (revision 3.0), w/TL to J
Dhont fr M Palmer
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
1141761
2/10/2004
Email: DNAPL loose ends, w/history
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Sundberg, Paul (Paul V
Sundberg, Project Consultant)
1114838
2/27/2004
Ltr: Approval for DNAPL extraction test workplan -
requests 5 day notice before initiation of test, w/email
TL
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2061205
5/19/2004
Ltr: EPA summary of DNAPL & supplemental soil
sampling issues fr 3/4/04 mtg, w/attch
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2061772
6/1/2004
Soil vapor extraction pilot test rpt, w/TL to S Keydel fr B
Dean 6/28/04
R09: (Earth Tech, Inc)
R09: (Montrose Chemical Corp)
1114839
7/2/2004
Ltr: Comments on proposed modification to DNAPL
extraction test workplan, w/email TL
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1141779
8/6/2004
Email: Boring F for DNAPL reconnaissance program
scheduled to go in 8/7, w/history
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Gonzales, Frank (CA
Environmental Protection Agency
- Dept of Toxic Substances
2061273
8/24/2004
Ltr: Comments on 6/19/04 results of DNAPL
reconnaissance investigation, w/attch
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2061769
9/20/2004
Ltr: Comments on 7/22/04 revised DNAPL mobility study
workplan & Response to comments, w/attch
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2054472
9/23/2004
Ltr: Transmits revised HiPOx pilot test rpt & responses
to comments - discusses evaluation of multiple cost
scenarios, w/o attchs
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
Page 7 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2054473
9/23/2004
Revised HiPOx pilot test rpt, w/response to comments
(attch A)
R09: (Earth Tech, Inc)
R09: (Montrose Chemical Corp)
2054471
10/13/2004
Final pilot extraction & aquifer response test workplan,
w/TLs & appendix, w/o compact disc
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2056880
10/13/2004
Final pilot extraction & aquifer response test workplan,
w/TLs & attch (compact disc only)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2194109
10/13/2004
Revised soil gas survey rpt, w/attchs
R09: (Earth Tech, Inc)
R09: (Montrose Chemical Corp)
1141807
10/15/2004
Email: 10/25/04 submittal of DNAPL reconnaissance rpt
will be fine, w/history
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (Hargis+
Assoc, Inc)
2189740
10/22/2004
Results of DNAPL reconnaissance investigation, rev 1.0
(draft - 6/19/04, revised 10/22/04), w/TLs & sticky note,
w/o compact disc
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2189952
10/22/2004
Results of DNAPL reconnaissance investigation, rev 1.0
(draft - 6/19/04, revised 10/22/04), w/TLs & sticky note
(compact disc onlv)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
1141834
10/25/2004
Email: Revisions to Results of DNAPL reconnaissance
Investigation rpt received - requests complete final
version
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (Hargis+
Assoc, Inc)
1114890
11/2/2004
Ltr: Partial approval of pilot extraction & aquifer
response test workplan, w/email TL
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2090872
11/22/2004
Baseline groundwater sampling results rpt (1/04),
revision 1.0, w/TLs & appendices (compact disc only - pt
of Add B)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2092655
11/22/2004
Baseline groundwater sampling results rpt (1/04),
revision 1.0, w/TLs & appendices, w/o compact disc
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
1114491
11/23/2004
Email: Transmits replacement pages for Pilot extraction
& aquifer response test workplan, revision 2.0, w/attch
(857 Rot 2004-10 Rev 2.0.pdf)
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
Page 8 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2092656
11/23/2004
Pilot extraction & aquifer response test workplan,
revision 2.0 draft final (replacement pages only),
w/marginalia & TL to J Dhont fr M Palmer
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2255603
12/17/2004
Ltr: Final DNAPL mobility study workplan & responses to
comments, w/attchs
R09: Sundberg, Paul (Paul V Sundberg,
Project Consultant)
R09: Keydel, Susan
(Environmental Protection
Agencv - Region 9)
2116869
3/1/2005
Final revised FSP for supplemental soil investigation,
w/TL to S Keydel fr B Dean 3/11/05
R09: (Earth Tech, Inc)
R09: (Montrose Chemical Corp)
1141840
5/19/2005
Email: Update on DNAPL Treatability studies
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (Hargis+
Assoc, Inc), R09: Sundberg, Paul
(Paul V Sundberg, Proiect
2125683
6/13/2005
Email: Transmits survey data re location of abandoned E
Torrance extension trunk, w/history, attch 2 (E TOOR
EXTTRUNKSEWER.doc) & forward to C Robinson & M
R09: Gardner, Robert (Los Angeles County
Sanitation Districts)
R09: Dean, Brian (Earth Tech, Inc)
1141784
6/15/2005
Email: DNAPL update - rpt on conversation with M
Palmer
R09: Keydel, Susan (Environmental
Protection Agency - Region 9)
R09: Davis, Eva (Environmental
Protection Agency), R09: Dhont,
Jeffrev (Environmental Protection
1114859
6/21/2005
Ltr: Comments to EPA draft 1-dimensional steam test
rpt, w/email TL
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Keydel, Susan
(Environmental Protection
Agencv - Region 9)
2185279
6/27/2005
Pilot extraction & aquifer response test workplan
(draft), rev 3.0, w/TL to J Dhont fr M Palmer (compact
disc onlv)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2195285
6/27/2005
Pilot extraction & aquifer response test workplan
(draft), rev 3.0, w/TL to J Dhont fr M Palmer, w/o
compact disc
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2185260
8/12/2005
Pilot extraction & aquifer response test workplan, rev
4.0, w/TL to J Dhont fr M Palmer & response to
comments on rev 3.0 (compact disc onlv)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2194100
8/12/2005
Pilot extraction & aquifer response test workplan, rev
4.0, w/TL to J Dhont fr M Palmer & response to
comments on rev 3.0, w/o compact disc
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
1144734
10/13/2005
Ltr: Results of RSSCT (rapid small-scale column testing)
to determine expected GAC usage rates for removing
PCBSA & other organic contaminates fr site
R09: Graham, James (U S Filter Westates
Carbon)
R09: Ondic, Danielle (Hargis +
Assoc, Inc)
Page 9 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2186709
1/19/2006
Technical Memo: DNAPL reconnaissance borings in
support of Earth Tech soil sampling program, w/attchs &
stickv notes
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Keydel, Susan
(Environmental Protection
Agencv - Region 9)
2255624
6/20/2006
Memo: Comments & recommendations on DNAPL
extraction test summary rpt, w/TLfr D Burden
R09: Davis, Eva (Environmental Protection
Agency - National Risk Management
Research Laboratorv), R09: Acree, Steven
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1114816
6/30/2006
Ltr: Comments on Montrose DNAPL extraction test
summary rpt, dated 2/28/2006, w/email TL & attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2255605
6/30/2006
Ltr: Comments on 4/7/06 DNAPL boiling point test
results technical memo
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2255606
6/30/2006
Email: Response to urgent request for review of draft
comments on DNAPL extraction test intermittent
operation issue, w/historv & handwritten notes
R09: Davis, Eva (Environmental Protection
Agency - National Risk Management
Research Laboratorv)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1116904
8/7/2006
Email: Transmits revised technical memo re DNAPL
boiling test results, & Response to comments, w/attchs
(857 tm08 Rev 1.0 DNAPL BoilingPoint.pdf & 857
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2255608
8/7/2006
Technical Memo: DNAPL boiling point test results (rev
1.0), w/attchs
R09: Palmer, Michael (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2257985
8/24/2006
Final addendum, 1-dimensional thermal remediation
treatability study, w/figures, w/o tables
R09: Davis, Eva (Environmental Protection
Agency - Roberts Kerr Environmental
Research Center)
1114818
8/25/2006
Email: Transmits DNAPL thermal remediation
treatability study rpt, addendum, & response to
Montrose comments, w/attchs
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1114819
10/25/2006
Ltr: EPA approval of revised boiling point test results
technical memo, dated 8/7/06, w/email TL
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2218866
11/1/2006
Ltr: Comments on draft rpt for mechanistic evaluation of
DNAPL mobility, w/email TL
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2218872
12/4/2006
Ltr: Response to Montrose ltr of 11/15/06 re NAPL
mechanistic study
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9), R09: Keydel,
Susan (Environmental Protection Agencv-
R09: Kelly, Joseph (Montrose
Chemical Corp)
Page 10 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1143100
12/21/2006
Email: Assures that requested info will be provided &
discusses attendance of specialists at meeting re
Mechanistic Studv rot, w/historv (DNAPL)
R09: Kelly, Joseph (Montrose Chemical
Corp)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2185241
2/28/2007
2006 groundwater monitoring results rpt, w/TL to J
Dhont fr M Palmer & appendices (compact disc only -
appendix B)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2188572
2/28/2007
2006 groundwater monitoring results rpt, w/TL to J
Dhont fr M Palmer & appendices A & C, w/o compact
disc
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2214442
4/19/2007
Compact Disc: Supplemental soil investigation quality
assurance summary rpts (MS Word format)
R09: (Earth Tech, Inc)
2186903
4/27/2007
Technical Memo: Interrelationships of Montrose site
groundwater, DNAPL & soil remedies
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2199102
6/29/2007
Ltr: Provides comments on technical memo re
interrelationships of Montrose site groundwater,
DNAPL, & soil remedies, & transmits interconnections
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2255581
9/7/2007
Draft revised workplan for 2 dimensional bench scale
evaluation of DNAPL mobility during steam flushing,
w/TL to J Dhont fr B Dean
R09: (Univ of Toronto - Dept of Civil
Engineering)
R09: (Montrose Chemical Corp)
1142065
10/10/2007
Email: Revised ERH (electrical resistive heating) 2-
dimensional workplan should arrive tomorrow by FedEx,
w/historv
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9), R09:
2186714
10/10/2007
Draft revised workplan for bench-scale evaluation of
electrical resistance heating for removal of DNAPL fr
Upper Bellflower Aauitard, w/TL to J Dhont fr B Dean
R09: (Queen's Univ - Dept of Civil
Engineering)
R09: (Montrose Chemical Corp)
1114821
10/19/2007
Ltr: Comments on SVE pilot test rpt 6/28/04, w/attch &
email TL
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1124717
11/9/2007
Memo: Responses to EPA focus questions pertaining to
application of thermal treatment & hydraulic
displacement at DNAPL sites, w/email TL fr J Dolegowski
R09: (C H 2 M Hill, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2186909
11/9/2007
Memo: Responses to EPA focus questions pertaining to
application of thermal treatment & hydraulic
displacement at DNAPL sites
R09: (C H 2 M Hill, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
Page 11 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2186910
11/12/2007
Ltr: Transmits & discusses list of thermal remediation
case studies, w/attch
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2186928
11/12/2007
Ltr: Transmits & discusses summary of estimated
thermal remediation costs, w/attch
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2186929
11/12/2007
Ltr: Transmits & discusses summary of estimated
hydraulic displacement remedy costs, w/attch
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2257987
11/12/2007
Email: DNAPL focus questions for meeting - transmits
technical memo of responses by CH2M Hill, w/history,
w/o attch (Responses to Focus Questions.pdf)
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Sundberg, Paul (Paul V
Sundberg, Project Consultant)
2185243
11/29/2007
DNAPL extraction test summary rpt, rev 1.0 (9/18/07,
revised 11/29/07), w/TLs & appendices (compact disc
onlv)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2188573
11/29/2007
DNAPL extraction test summary rpt, rev 1.0 (9/18/07,
revised 11/29/07), w/TLs & appendices, w/o compact
disc
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
1142068
1/8/2008
Email: Availability this week for follow-up discussion for
DNAPL Remedy Costing Assumptions, w/history
R09: Dean, Brian (Earth Tech, Inc)
R09: Cole, Jason (C H 2 M Hill, Inc)
1143262
1/22/2008
Email: Transmits & discusses table giving summary of
data used to generate DNAPL Thickness Map, w/history
& attch (Table of DNAPL thickness intervals.epa.xls)
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1116921
2/20/2008
Technical Memo: Addendum 2 to results of DNAPL
reconnaissance investigation, w/attchs & email forward
to J Dhont, et al 2/21/08
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2189961
2/20/2008
Results of DNAPL reconnaissance investigation (final) -
includes addenda 1 & 2, (10/22/04, updated 2/20/08),
w/TLs & stickv note (compact disc onlv)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2190493
2/20/2008
Compact Disc: Results of DNAPL reconnaissance
investigation, rev 1.0 (10/22/04, updated 2/20/08), with
revised pp. addenda 1 & 2 & TLs (Adobe PDF format)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
1114783
2/21/2008
Technical Memo: Workplan for field investigation into
possible presence of DNAPL in Bellflower sand, w/attchs
& email TL
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
Page 12 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1143267
2/21/2008
Email: Transmits addendum to revised workplans for
bench scale evaluation of DNAPL mobility during steam
flushing & electrical resistance heating (2-D Studv
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2255590
2/26/2008
Mtg Agenda: 2/26/08 DNAPL technical meeting,
w/attchs (handwritten and typed notes) & marginalia
2251832
3/20/2008
Technical Memo: Proposed geostatistical evaluation of
lithology, Montrose DNAPL impacted area, w/attch
(compact disc onlv)
R09: Palmer, Michael (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2255617
3/20/2008
Technical Memo: Proposed geostatistical evaluation of
lithology, Montrose DNAPL impacted area, w/o compact
disc
R09: Palmer, Michael (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1114829
3/21/2008
Ltr: Transmits comments on DNAPL extraction pilot test
& hydraulic displacement modeling workplan, w/attchs
& email TL
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2255618
3/25/2008
Ltr: EPA approval of results of DNAPL reconnaissance
investigation rpt, rev 1.0, with addenda, w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2190460
4/1/2008
Overall operational design rpt based on remedial well
field optimization
R09: (C H 2 M Hill, Inc)
R09: (Environmental Protection
Agency - Region 9)
2255584
4/14/2008
Technical Memo: Results of depth discrete groundwater
sampling of 3 Bellflower sand wells, w/attch
R09: Palmer, Michael (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
1114788
4/17/2008
Email: DNAPL source area maps shown during 4/15
meeting, w/attchs (103649 Figure 1.0308.pdf, 103649
Figure 2.DNAPL-known.thick.0408.pdf & 103649 Figure
R09: Dean, Brian (Earth Tech, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2189741
6/4/2008
DNAPL extraction test summary rpt, rev 2.0, w/TL to J
Dhont fr D Ondic, comment response & appendices,
w/o compact disc
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2189954
6/4/2008
DNAPL extraction test summary rpt, rev 2.0, w/TL to J
Dhont fr D Ondic, comment response & appendices
(compact disc onlv)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2255619
6/5/2008
Memo: DNAPL focused treatment area evaluation -
saturated Upper Bellflower Aquitard (UBA), w/attchs
R09: Dean, Brian (Earth Tech, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
Page 13 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2257988
6/24/2008
Technical Memo: Results of field investigation into
possible presence of DNAPL in Bellflower sand, w/attchs
R09: Ondic, Danielle (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2281042
7/15/2008
Technical Memo: Geostatistical analysis of lithological
continuity, w/attchs
R09: Ondic, Danielle (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc),
R09: Dale, Tim (INTERAInc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2255620
7/17/2008
Ltr: Comments on technical memo - results of field
investigation into presence of DNAPL in Bellflower Sand,
w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2185265
7/21/2008
Memo: Revised DNAPL steam injection cost evaluation,
w/attchs (compact disc only - Energy Demand
Calculation)
R09: Dean, Brian (Earth Tech, Inc), R09:
Barnes, Jacob (Earth Tech, Inc), R09: Bush,
Dacre (T N & Assoc, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2194112
7/21/2008
Memo: Revised DNAPL steam injection cost evaluation,
w/attchs, w/o compact disc
R09: Dean, Brian (Earth Tech, Inc), R09:
Barnes, Jacob (Earth Tech, Inc), R09: Bush,
Dacre (T N & Assoc, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1144621
7/30/2008
Technical Memo: Updated hydraulic displacement
model workplan, w/attch
R09: Ondic, Danielle (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2185266
7/31/2008
Memo: DNAPL focused treatment area steam injection
cost evaluation for Montrose site, w/attchs (compact
disc onlv)
R09: Dean, Brian (Earth Tech, Inc), R09:
Barnes, Jacob (Earth Tech, Inc), R09: Bush,
Dacre (T N & Assoc, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2194113
7/31/2008
Memo: DNAPL focused treatment area steam injection
cost evaluation for Montrose site, w/attchs, w/o
compact disc
R09: Dean, Brian (Earth Tech, Inc), R09:
Barnes, Jacob (Earth Tech, Inc), R09: Bush,
Dacre (T N & Assoc, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2185267
8/7/2008
Memo: Revised DNAPL electrical resistance heating
(ERH) cost evaluation for Montrose site, w/attchs
(compact disc onlv)
R09: Dean, Brian (Earth Tech, Inc), R09:
Barnes, Jacob (Earth Tech, Inc), R09: Bush,
Dacre (T N & Assoc, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2194114
8/7/2008
Memo: Revised DNAPL electrical resistance heating
(ERH) cost evaluation for Montrose site, w/attchs, w/o
compact disc
R09: Dean, Brian (Earth Tech, Inc), R09:
Barnes, Jacob (Earth Tech, Inc), R09: Bush,
Dacre (T N & Assoc, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2246070
8/8/2008
Email: Thermal cost estimates & request
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (de
maximis, inc)
2185268
8/22/2008
Memo: DNAPL focused treatment area electrical
resistance heating (ERH) cost evaluation for Montrose
site, w/attchs (compact disc onlv - Energv Demand
R09: Dean, Brian (Earth Tech, Inc), R09:
Barnes, Jacob (Earth Tech, Inc), R09: Bush,
Dacre (T N & Assoc, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
Page 14 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2194115
8/22/2008
Memo: DNAPL focused treatment area electrical
resistance heating (ERH) cost evaluation for Montrose
site, w/attchs, w/o compact disc
R09: Dean, Brian (Earth Tech, Inc), R09:
Barnes, Jacob (Earth Tech, Inc), R09: Bush,
Dacre (T N & Assoc, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2247646
9/4/2008
Compact Disc: Technical Memo - evaluation of
containment zone timeframes following DNAPL remedy
at site & attchs (Adobe pdf & MS xls formats)
R09: Ondic, Danielle (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2246870
9/10/2008
Ltr: EPA comments on focused treatment area
evaluation, saturated Upper Bellflower Aquitard,
w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2246065
9/29/2008
Ltr: EPA comments on geostatistical analysis of
lithological continuity, w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2246848
10/28/2008
Ltr: Approval of DNAPL extraction test summary rpt,
revision 2.0
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2194125
10/29/2008
Compact Disc: Geotechnical & chemical evaluation -
groundwater treatment plant site soils (Adobe pdf
format)
R09: (Earth Tech AECOM, Inc)
R09: (Montrose Chemical Corp)
2194446
11/1/2008
Draft Rl workplan for JCI Jones Chemicals, w/appendices
R09: (L F R Inc)
R09: (J C 1 Jones Chemicals, Inc)
2194120
11/7/2008
UV-oxidation bench-scale testing rpt & cost comparison -
HiPOx & UV (ultraviolet) oxidation, w/TL to J Dhont fr B
Dean & appendices
R09: (Earth Tech AECOM, Inc)
R09: (Montrose Chemical Corp)
2185270
11/11/2008
Liquid-phase granular activated carbon bench-scale
testing rpt & cost projection, w/appendices (compact
disc onlv - Appendix B)
R09: (Earth Tech AECOM, Inc)
R09: (Montrose Chemical Corp)
2194121
11/11/2008
Liquid-phase granular activated carbon bench-scale
testing rpt & cost projection, w/appendices, w/o
compact disc
R09: (Earth Tech AECOM, Inc)
R09: (Montrose Chemical Corp)
2281048
11/13/2008
Memo: Summary of installation & monitoring activities
associated with DNAPL well UBE-5, w/attchs
R09: Dean, Brian (Earth Tech AECOM, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2200454
12/3/2008
Ltr: Review of technical memo re plan for DNAPL well
UBE-5 extraction test, w/attch
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
Page 15 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2246062
12/23/2008
Ltr: EPA comments on technical memo re evaluation of
containment zone timeframes following DNAPL remedy
R09: Dhont, Jeffrey (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2281050
1/15/2009
Technical Memo: Status of hydraulic displacement (HD)
modeling, w/attch
R09: Ondic, Danielle (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc),
R09: Dale, Tim (INTERAInc)
R09: Dhont, Jeffrey
(Environmental Protection
Agencv - Region 9)
2255717
2/25/2009
Ltr: EPA approval of DNAPL extraction test summary rpt,
revision 2.0, w/attch 1 (article), w/o attch 2
R09: Ondic, Danielle (Hargis + Assoc, Inc)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2255718
3/17/2009
Ltr: Update on 2-dimensional bench scale testing of
steam flushing (for removal of DNAPL), w/TL to C
d'Almeida fr M Palmer 3/19/09
R09: Sleep, Brent (Univ of Toronto - Dept of
Civil Engineering)
R09: Palmer, Michael (de
maximis, inc)
2256924
3/17/2009
Technical Memo: Summary of bench-scale evaluation of
electrical resistance heating for removal of DNAPL fr
Upper Bellflower Aauitard, w/TL to C d'Almeida fr M
R09: Kueper, Bernard (Queen's Univ - Dept
of Civil Engineering)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2256946
3/25/2009
Technical Memo: Response to EPA comments on
technical memo re containment zone timeframes
following DNAPL remedv at site, w/o figures or attchs
R09: Ondic, Danielle (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2256956
3/25/2009
Compact Disc: Technical Memo - evaluation of
containment zone timeframes following DNAPL remedy
at site (revision 1.0), & attchs (Adobe PDF & MS Excel
R09: Ondic, Danielle (Hargis + Assoc, Inc),
R09: Niemeyer, Roger (Hargis + Assoc, Inc)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2256948
4/6/2009
Results of hydraulic displacement modeling, w/TL to C
d'Almeida fr D Ondic & R Niemeyer & app A
R09: (Hargis + Assoc, Inc), R09: (INTERA Inc)
R09: (Montrose Chemical Corp)
2257965
4/6/2009
Compact Disc: Results of hydraulic displacement
modeling, TL to C d'Almeida fr D Ondic & R Niemeyer &
Appendix A (Adobe PDF file format)
R09: (Hargis + Assoc, Inc), R09: (INTERA Inc)
R09: (Montrose Chemical Corp)
2282594
4/21/2009
Compact Disc: Draft DNAPL FS, w/TL to C d'Almeida fr B
Dean & appendices A-M
R09: (Earth Tech AECOM, Inc)
R09: (Montrose Chemical Corp)
2255720
5/12/2009
Memo: Results of short-term extraction test at DNAPL
well UBE-5, w/attchs
R09: Dean, Brian (Earth Tech AECOM, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2256922
5/27/2009
Technical Memo: 2008 DNAPL physical properties
testing results, w/attchs
R09: Dean, Brian (Earth Tech AECOM, Inc)
R09: Kelly, Joseph (Montrose
Chemical Corp)
Page 16 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1144737
6/3/2009
Revised SVE pilot test rpt, w/appendices & TL to C
d'Almeida fr B Dean
R09: (Earth Tech AECOM, Inc)
R09: (Montrose Chemical Corp)
2256925
6/9/2009
Technical Memo: Evaluation of hydraulic properties &
estimates of horizontal & vertical fluxes in UBA (Upper
Bellflower aauitard), within DNAPL source area, w/stickv
R09: Lechler, Benjamin (C H 2 M Hill, Inc),
R09: Basial, Michael (C H 2 M Hill, Inc), R09:
Ravkhman, Natasha (C H 2 M Hill, Inc)
R09: Dolegowski, John (C H 2 M
Hill, Inc), R09: Huntley, David (San
Diego State Univ)
1123309
7/13/2009
Supplemental groundwater sampling & analysis results,
4/09, w/TL to C d'Almeida fr D Ondic & R Cardoso &
Appendices, w/o compact disc (appendices B & C)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
2257964
7/13/2009
Supplemental groundwater sampling & analysis results,
4/09, w/TL to C d'Almeida fr D Ondic & R Cardoso &
appendices (compact disc onlv - appendices B & C)
R09: (Hargis + Assoc, Inc)
R09: (Montrose Chemical Corp)
1122425
8/17/2009
Ltr: Status update - completion of 2-dimensional bench
scale testing of stream flushing, w/email TLs
R09: Sleep, Brent (Univ of Toronto - Dept of
Civil Engineering)
R09: Palmer, Michael (de
maximis, inc)
2256928
8/17/2009
Ltr: Completion of 2-dimensional bench scale testing of
steam flushing run 2 (for removal of DNAPL), w/TL to C
d'Almeida fr M Palmer 8/20/09
R09: Sleep, Brent (Univ of Toronto - Dept of
Civil Engineering)
R09: Palmer, Michael (de
maximis, inc)
2256931
9/28/2009
Technical Memo: Review of revised SVE pilot test rpt
(EarthTech AECOM, 6/3/09)
R09: Dolegowski, John (C H 2 M Hill, Inc),
R09: Breedlove, William (C H 2 M Hill, Inc)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2255711
10/15/2009
Ltr: Transmits & discusses compact disc with draft
DNAPL compendium Appendix M for DNAPL FS, w/o
attch
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2257961
10/15/2009
Compact Disc: Draft DNAPL FS - Appendix M, draft
DNAPL compendium
R09: (Earth Tech AECOM, Inc)
2200478
12/18/2009
Supplemental soil investigation rpt, w/TL to R Mechem
fr B Dean 12/21/09 & appendices, w/o compact discs
R09: (Earth Tech AECOM, Inc)
R09: (Montrose Chemical Corp)
2279389
1/15/2010
Final soil & NAPL FS - v 1 (of 3) - text, table & figures,
w/TL to D Rodriguez fr G Landreth & appendices
(compact disc onlv - v 2)
R09: (U R S Corp)
R09: (Dow Chemical Co, The),
R09: (Shell Oil Co)
2282488
1/15/2010
Final soil & NAPL FS - v 1 (of 3) - text, table & figures,
w/TL to D Rodriguez fr G Landreth & appendices, w/o
compact disc
R09: (U R S Corp)
R09: (Dow Chemical Co, The),
R09: (Shell Oil Co)
Page 17 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1122918
1/27/2010
Ltr: Comments on draft DNAPL FS, dated 4/21/09,
w/encls & email TLs
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2255710
1/27/2010
Ltr: Review of draft Montrose DNAPL FS, w/encl
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1122751
1/28/2010
Email: Transmits 4 attchs to EPA comment ltr on
Montrose DNAPL FS, w/attchs (Figure 1 of FS
Review.pdf, Montrose Chlorobenze Upper Bellflower
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Sayed, Safouh (CA
Environmental Protection Agency
- Dept of Toxic Substances
1143417
2/23/2010
Ltr: Request for clarification of comments on draft
DNAPL FS
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1123168
3/11/2010
Email: Responses on mass estimate calculations (ref EPA
comments on DNAPL FS), w/history & attchs
(dnaplFSaddendum.ltr.pdf, ~8948294.tif. Mass
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (de
maximis, inc), R09: Dean, Brian
(AECOM)
1124084
3/11/2010
Email: Responses on mass estimate calculations (ref EPA
comments on DNAPL FS), w/history, attchs
(dnaplFSaddendum.ltr.pdf, ~8948294.tif. Mass
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (de
maximis, inc), R09: Dean, Brian
(AECOM)
2256951
3/11/2010
Ltr: 2/23/10 request for clarification of comments for
draft DNAPL FS study, & addendum to 1/27/10 EPA
comment ltr dated 1/27/10, w/encls, w/o Excel
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1123312
4/27/2010
Ltr: Transmits & summarizes technical responses to EPA
comments on Montrose DNAPL FS, w/o attch
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1123313
4/27/2010
Montrose technical responses to EPA comments on
Montrose DNAPL FS
R09: (AECOM)
1122564
4/28/2010
Email: Transmits Montrose responses to EPA comments
on draft DNAPL FS, w/attchs (4) & forward to S Sayed fr
C d'Almeida 7/15/10
R09: Palmer, Michael (de maximis, inc)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1123311
4/28/2010
Ltr: Response to EPA comments on legal issues re
Montrose DNAPL FS, w/attch
R09: Lytz, Karl (Latham & Watkins
(Attorneys))
R09: Jolish, Taly (Environmental
Protection Agency - Region 9)
2260819
6/1/2010
Fact Sheet: EPA requests comments on proposed soil &
NAPL cleanup plan
R09: (Environmental Protection Agency -
Region 9)
Page 18 of 29
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Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2256934
6/28/2010
Technical Memo: Assessment of continuity of UBA
(Upper Bellflower aquitard) basal silty sand layer &
impact of DNAPL migration
R09: Basial, Michael (C H 2 M Hill, Inc), R09:
Raykhman, Natasha (C H 2 M Hill, Inc), R09:
Huntlev, David (San Diego State Univ)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2247649
8/19/2010
Draft soil & soil-gas data rpt, JCI Jones Chemicals facility,
w/appendices, w/o compact discs
R09: (ARCADIS U S, Inc)
R09: (J C 1 Jones Chemicals, Inc)
1161279
8/27/2010
(Privileged) Overheads (47): Montrose concerns -
evaluation of DNAPL remedial alternatives, DNAPL FS,
8/27/10 (privileged document target onlv)
R09: (AECOM)
2255712
9/1/2010
Article: State-of-the-practice review of in situ thermal
technologies (Groundwater monitoring & remediation v
30, #4 / Fall 2010, pp 64-72)
R09: Triplett Kingston, Jennifer (Haley &
Aldrich, Inc), R09: Dahlen, Paul (AZ State
Univ - Dept of Civil, Environmental, &
1144639
9/29/2010
Technical Memo: Evaluation of MCB mass in UBA &
Bellflower sand, & estimates of DNAPL dissolution &
longevity of dissolved plume
R09: Raykhman, Natasha (C H 2 M Hill, Inc),
R09: Huntley, David (San Diego State Univ)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1144736
10/4/2010
Email: Transmits technical memo re MCB mass
estimates in UBA & Bellflower Sand, & estimates of
DNAPL dissolution & plume longevity, w/forward to M
R09: Raykhman, Natasha (C H 2 M Hill, Inc)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1133249
10/7/2010
Email: DNAPL FS reconciliation of focused treatment
area, w/attchs (4)
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9), R09:
1161275
10/8/2010
(Privileged) Overheads (54): Reconciliation call 10/8/10-
EPA comments on DNAPL FS (privileged document
target onlv)
R09: (AECOM)
1161276
11/3/2010
(Privileged) Overheads (52): Reconciliation call 11/3/10-
EPA comments on DNAPL FS (privileged document
target onlv)
R09: (AECOM)
1161274
11/20/2010
(Privileged) Email: Transmits updated DNAPL
reconciliation table (ref Montrose Torrance - Nov 23
DNAPL Reconciliation Call -Agenda), w/historv, attch &
R09: Palmer, Michael (de maximis, inc)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1161277
11/23/2010
(Privileged) Overheads (26): Reconciliation call 11/23/10
- EPA comments on DNAPL FS (privileged document
target onlv)
R09: (AECOM)
1161280
11/23/2010
(Privileged) Mtg Agendas (2 drafts): DNAPL
reconciliation call, 11/23/10, w/overheads & marginalia
(privileged document target onlv)
R09: (AECOM)
Page 19 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2256938
12/2/2010
Memo: Applicability of electrical resistance heating in
various hydrogeologic conditions
R09: Bush, Dacre (Oneida Total Integrated
Enterprises, LLC)
R09: Palmer, Mike (NONE), R09:
Dean, Brian (AECOM)
1161278
12/9/2010
(Privileged) Overheads (18): Reconciliation call 12/09/10
- EPA comments on DNAPL FS
R09: (AECOM)
1161270
1/18/2011
(Privileged) Email: Reconciliation table (redline/strikeout
version), w/attch (Reconciliation Meeting Minutes 1-4-
2011 Ver.doc) (privileged document target onlv)
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Palmer, Michael (de
maximis, inc)
2256935
1/18/2011
Technical Memo: Evaluation of entry pressure used in
HD (hydraulic displacement) model
R09: Raykhman, Natasha (C H 2 M Hill, Inc),
R09: Huntley, David (San Diego State Univ)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1133819
1/19/2011
Email: Forwards 8/08 focused ERH (electrical resistance
heating) cost evaluation email & attchs, w/history & 3rd
attch onlv (figures)
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1137220
1/19/2011
Email: Forwards 8/08 DNAPL focused treatment area
ERH (Electrical Resistance Heating) cost evaluation,
w/historv & forward to Y Martinez fr C d'Almeida
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1137221
1/19/2011
Email: Forwards & discusses 7/31/08 DNAPL focused
steam injection cost evaluation, w/history & forward to
Y Martinez fr C d'Almeida 11/16/11
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1161273
1/23/2011
(Privileged) Email: Transmits copy of slides presented
during 1/19/11 DNAPL FS reconciliation call, w/history,
attch (DNAPL Slides Reconciliation
R09: Palmer, Mike (NONE)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1128573
1/26/2011
Draft DNAPL Reconnaissance investigation data rpt-
appendices A, B, & D-l
R09: (ARCADIS U S, Inc)
R09: (J C 1 Jones Chemicals, Inc)
1128574
1/26/2011
Draft DNAPL Reconnaissance investigation data rpt
(text, tables, figures)
R09: (ARCADIS U S, Inc)
R09: (J C 1 Jones Chemicals, Inc)
1161271
2/2/2011
(Privileged) Overheads (16): Reconciliation call - EPA
comments on DNAPL FS (privileged document target
onlv)
R09: (Latham & Watkins (Attorneys))
1135100
2/18/2011
Memo: DNAPL remedy evaluation - applicability of
steam injection & hydraulic displacement to RA
objectives for DNAPL
R09: Kueper, Bernard (Queen's Univ - Dept
of Civil Engineering)
R09: Palmer, Michael (de
maximis, inc)
Page 20 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1137229
2/18/2011
Email: Transmits memo re approach for incorporating
greenhouse gas emissions into DNAPL FS, & response to
proposed additions to mtg minutes, w/attchs (2) &
R09: Palmer, Michael (de maximis, inc)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2256944
2/18/2011
Memo: Recommended approach for incorporation of
GHG (greenhouse gas) emissions into DNAPL FS,
w/attchs
R09: Dean, Brian (AECOM)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2256952
2/18/2011
Memo: DNAPL remedy evaluation - applicability of
steam injection & hydraulic displacement to RA
objectives for DNAPL
R09: Kueper, Bernard (Queen's Univ- Dept
of Civil Engineering)
R09: Palmer, Michael (de
maximis, inc)
1135101
2/22/2011
Applicability of steam injection for in-situ thermal
remediation at site
R09: Mcgee, Bruce (McMillan-McGee
Corp), R09: Winder, D (McMillan-McGee
Corp)
2256943
2/22/2011
Technical rpt on applicability of steam injection for in-
situ thermal remediation at site
R09: Mcgee, Bruce (McMillan-McGee
Corp), R09: Winder, D (McMillan-McGee
Corp)
1161281
2/24/2011
(Privileged) Overheads (43): Reconciliation meeting,
2/24/11 - EPA comments on DNAPL FS (privileged
document target onlv)
R09: (AECOM)
1137219
3/25/2011
Email: Transmits memo re soil sampling, w/attch
(Thermal Remediation Soil Verification Sampling
Memo final.pdf) & forward to Y Martinez 11/16/11
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2257978
3/25/2011
Memo: Thermal remediation soil verification sampling,
DNAPL FS, w/marginalia & attchs
R09: Dean, Brian (AECOM)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1144735
4/21/2011
Mtg Minutes: DNAPL reconciliation meeting minutes
(final)
R09: (AECOM)
1161272
4/21/2011
(Privileged) Email: Transmits revised & updated DNAPL
reconciliation meeting minutes - proposed changes to
1/18 revisions shown in red, w/attch (Reconciliation
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2256942
5/11/2011
Ltr: Resolution of technical comments on 4/21/09 draft
DNAPL FS, w/encls
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
2282593
5/20/2011
Ltr: Green remediation guidance as To Be Considereds
(TBC) materials for DNAPL FS
R09: Richardson, Kelly (Latham & Watkins
(Attorneys))
R09: Jolish, Taly (Environmental
Protection Agency - Region 9)
Page 21 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1137226
5/23/2011
Email: Forwards email with 5/20/11 Itr re green
remediation guidance at site, w/history & forward to Y
Martinez fr C d'Almeida 11/16/11
R09: Palmer, Mike (NONE)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1135438
6/1/2011
Ltr: Montrose objections to including Jones Chemical Co
site in Montrose Superfund site, w/exhibits
R09: Richardson, Kelly (Latham & Watkins
(Attorneys))
R09: Jolish, Taly (Environmental
Protection Agency - Region 9)
2256954
6/1/2011
Ltr: FS for DNAPL - reinjection of partially treated
groundwater above MCLs (maximum contamination
levels)
R09: Richardson, Kelly (Latham & Watkins
(Attorneys))
R09: Jolish, Taly (Environmental
Protection Agency - Region 9)
2256941
6/3/2011
Ltr: Response to Itr dated 5/11/11 - draft FS for
alternative remedies
R09: Kelly, Joseph (Montrose Chemical
Corp)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1136259
6/17/2011
Ltr: Montrose responses to EPA comments - thermal
remediation soil verification sampling, w/attch & email
TL
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
2256940
6/17/2011
Ltr: Response to 6/3/11 Itr re DNAPL FS - clarification re
alternatives available to address DNAPL, & EPA review
process for remedv selection
R09: Blank, Roberta (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1136641
8/15/2011
Ltr: Montrose responses to EPA comments on
Recommended approach for incorporation of GHG
(greenhouse gas) emissions in DNAPL FS, w/attch &
R09: Dean, Brian (AECOM)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1137102
8/15/2011
Email: Revised DNAPL FS Schedule - response to
comments, w/attch (Revised DNAPL FS Schedule
Letter 08-15-11.pdf) & forward to R Blank & Y Martinez
R09: Dean, Brian (AECOM)
R09: Blank, Roberta
(Environmental Protection
Agencv - Region 9)
2297374
9/1/2011
Compact Disc: Revised addendum - soil gas survey rpt,
w/TL & appendices (PDF & XLS file formats)
R09: (AECOM)
2297373
9/7/2011
TL: Revised soil gas survey addendum
R09: Dean, Brian (AECOM)
R09: Mechem, Russell
(Environmental Protection
Agencv - Region 9)
1129122
11/10/2011
Ltr: EPA conditional acceptance of revised soil gas
survey report addendum dated 9/7/11, w/attch
R09: Mechem, Russell (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1137242
11/17/2011
Email: Materials for 11/22/11 Del Amo interagency
coordination meeting, w/attchs (3) & forward to Y
Martinez fr C d'Almeida 11/17/11
R09: Warren, Scott (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: Blank, Roberta
(Environmental Protection
Agencv - Region 9)
Page 22 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
2255715
12/7/2011
Compact Discs (3 DVDs): Revised DNAPL FS, Appendix L-
compendium of DNAPL references, case studies, &
technical & guidance documents (Adobe pdf, MS Excel,
R09: (AECOM)
2255716
12/7/2011
Revised DNAPL FS, w/appendices A-K & M, w/o
appendix L
R09: (Environmental Protection Agency -
Region 9)
R09: (Montrose Chemical Corp)
2255713
12/16/2011
Ltr: Water Replenishment District concerns re Del Amo
& Montrose sites
R09: Katherman, Robert (Water
Replenishment District of Southern
California)
R09: Scandura, John (CA
Environmental Protection Agency
- Dept of Toxic Substances
2253559
12/30/2011
Rpt - 2-dimensional bench scale evaluation of DNAPL
mobility during steam flushing, w/TLto C d'Almeida fr B
Dean & appendices (compact discs onlv)
R09: (Univ of Toronto - Dept of Civil
Engineering), R09: (AECOM)
R09: (Montrose Chemical Corp)
2256947
12/30/2011
Rpt - 2-dimensional bench scale evaluation of DNAPL
mobility during steam flushing, w/TLto C d'Almeida fr B
Dean & appendices, w/o compact discs
R09: (Univ of Toronto - Dept of Civil
Engineering), R09: (AECOM)
R09: (Montrose Chemical Corp)
1137586
3/2/2012
Email: Requests written comments fr DTSC articulating
position & concerns re DNAPL FS (ref Montrose/Del
Amo action conference call reauest), w/historv
R09: D'almeida, Carolyn (Environmental
Protection Agency - Region 9)
R09: Sayed, Safouh (CA
Environmental Protection Agency
- Dept of Toxic Substances
1137644
4/4/2012
Email: Transmits Powerpoint presentation & questions
sent on 3/1, for today's discussion, w/attchs (4-4-2012
DTSC-USEPA Montrose Del Amo Coordination Mtg.ppt &
R09: Warren, Scott (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: Blank, Roberta
(Environmental Protection
Agencv - Region 9)
2255576
4/23/2012
Compact Disc: Revised supplemental soil investigation
rpt, TL to R Mechem fr B Dean 4/24/12 & appendices A-
D & F-L (various file formats)
R09: (AECOM)
R09: (Montrose Chemical Corp)
2255577
4/23/2012
Compact Discs (2 DVDs): Revised supplemental soil
investigation rpt, Appendix E - laboratory rpts & chain of
custodv forms (Adobe PDF format)
R09: (AECOM)
R09: (Montrose Chemical Corp)
1133580
5/7/2012
Ltr: National Remedy Review Board process for revised
DNAPL FS
R09: Martinez Leon, Yarissa (Environmental
Protection Agency - Region 9)
R09: Sayed, Safouh (CA
Environmental Protection Agency
- Dept of Toxic Substances
1133581
5/7/2012
Ltr: National Remedy Review Board process for DNAPL
FS
R09: Martinez Leon, Yarissa (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1137737
5/7/2012
Memo: Review of revised DNAPL FS (prepared by
AECOM, 12/7/11), w/attchs & email forward to C
d'Almeida fr S Saved
R09: Peng, Ted (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: Sayed, Safouh (CA
Environmental Protection Agency
- Dept of Toxic Substances
Page 23 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1137738
5/7/2012
Email: Transmits review of Montrose comments on
DNAPL FS, w/forward to Y Martinez & R Blank, w/o
attchs (Montrose FS Comments 5-7-12 Part l.pdf &
R09: Sayed, Safouh (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9)
1133579
5/9/2012
Ltr: National Remedy Review Board process for OU3,
DNAPL FS, w/attch
R09: Martinez, Yarissa (Environmental
Protection Agency - Region 9)
R09: Babich, Cynthia (Del Amo
Action Committee)
1137747
5/9/2012
Email: Transmits updated version of WRD (Water
Replenishment District) comments for Montrose,
w/attch (120409 FINAL WRD Memo to DTSC on
R09: Sayed, Safouh (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: D'almeida, Carolyn
(Environmental Protection
Agencv - Region 9), R09: Hiett,
1144673
8/21/2012
Memo: Review of revised DNAPL FS, dated 12/7/11,
w/attch
R09: Warren, Scott (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: Sayed, Safouh (CA
Environmental Protection Agency
- Dept of Toxic Substances
1142573
9/1/2012
Review of DNAPL FS (National Remedy Review Board
stakeholder's submittal), w/attch & TL to Y Martinez fr C
Babich 10/2/12
R09: Niebanck, Markus (Amicus
Environmental Consulting)
1142574
10/1/2012
DNAPL remediation - executive summary (Montrose
input for National Remedy Review Board)
R09: Palmer, Michael (de maximis, inc),
R09: Dean, Brian (AECOM)
1144710
12/1/2012
Fact Sheet: Technical Assistance Services for
Communities (TASC) revised DNAPL FS fact sheet
R09: (Environmental Protection Agency -
Region 9)
1144672
1/30/2013
Technical Memo: Draft review comments on revised
DNAPL FS for site, prepared by AECOM 12/7/11
R09: Davis, Eva (Environmental Protection
Agency), R09: Cole, Jason (C H 2 M Hill, Inc),
R09: Ravkhman, Natasha (C H 2 M Hill, Inc)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
1137826
2/1/2013
Memo: National Remedy Review Board
recommendations for site, OU3 - DNAPL
R09: Legare, Amy (Environmental
Protection Agency - National Remedy
Review Board)
R09: Diamond, Jane
(Environmental Protection
Agencv - Region 9)
1144709
3/1/2013
Fact Sheet: Montrose Superfund Site (OU descriptions,
contacts, & project status)
R09: (Environmental Protection Agency -
Region 9)
1137827
3/22/2013
Memo: Response to National Remedy Review Board
recommendations for site, OU3 - DNAPL
R09: Diamond, Jane (Environmental
Protection Agency - Region 9)
R09: Legare, Amy (Environmental
Protection Agency - National
Remedv Review Board)
1142575
3/26/2013
Ltr: DTSC agrees with summary of issues in 3/14/14 ltr &
concurs with DNAPL FS (general concurrence)
R09: Black, Stewart (CA Environmental
Protection Agency - Dept of Toxic
Substances Control)
R09: Diamond, Jane
(Environmental Protection
Agencv - Region 9)
Page 24 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1144708
9/1/2013
Fact Sheet: Montrose Superfund Site (OU descriptions,
contacts, & project status) (Spanish)
R09: (Environmental Protection Agency -
Region 9)
1144609
9/27/2013
Final DNAPL FS (appendices A-l & M)
R09: (AECOM)
R09: (Montrose Chemical Corp)
1144610
9/27/2013
Final DNAPL FS (text, tables & figures)
R09: (AECOM)
R09: (Montrose Chemical Corp)
2297372
9/27/2013
Compact Discs (3 DVDs): Final DNAPL FS (appendix L-
compendium of DNAPL references) (PDF, XLS & CSV file
formats)
R09: (AECOM)
R09: (Montrose Chemical Corp)
1144608
9/30/2013
TL: Final DNAPL FS
R09: Dean, Brian (AECOM)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
1144707
11/5/2013
Email: Provides Dropbox account email for DNAPL FS,
w/history
R09: Babich, Cynthia (Del Amo Action
Committee)
R09: Diaz, Alejandro
(Environmental Protection
Agencv - Region 9)
1142572
1/13/2014
Ltr: EPA approval on final Dense Non-Aqueous Phase
Liquid (DNAPL) FS for site
R09: Martinez Leon, Yarissa (Environmental
Protection Agency - Region 9)
R09: Kelly, Joseph (Montrose
Chemical Corp)
1144568
2/26/2014
Memo: Concerns with final DNAPL FS, dated 9/27/13 -
discusses unaddressed comments provided in memo
dated 4/2/12
R09: Davis, Eva (Environmental Protection
Agency - National Risk Management
Research Laboratory)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
1144526
4/4/2014
Ltr: Response to E Davis comments on final DNAPL FS
(2/26/14 memo)
R09: Kelly, Joseph (Montrose Chemical
Corp)
R09: Ball, Harold (Environmental
Protection Agency - Region 9)
1144549
4/29/2014
Ltr: Response to TASC (Technical Assistance for
Communities) memo reviewing 12/7/11 DNAPL FS
R09: Martinez, Yarissa (Environmental
Protection Agency - Region 9)
R09: Russell-hedstrom, Krissy
(Skeo Solutions, Inc)
1144828
5/23/2014
List of US EPA guidance documents consulted during
development & selection of response action for site
R09: (Environmental Protection Agency -
Region 9)
1146224
8/26/2014
Public Notice: EPA requests comments on proposed
DNAPL cleanup plan
R09: (Environmental Protection Agency -
Region 9)
Page 25 of 29
-------
Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1146225
8/26/2014
Public Notice: EPA requests comments on proposed
DNAPL cleanup plan (Spanish)
R09: (Environmental Protection Agency -
Region 9)
1146226
9/1/2014
Fact Sheet: EPA requests comments on proposed DNAPL
cleanup plan
R09: (Environmental Protection Agency -
Region 9)
1146227
9/1/2014
Fact Sheet: EPA requests comments on proposed DNAPL
cleanup plan (Spanish)
R09: (Environmental Protection Agency -
Region 9)
1161349
9/5/2014
Montrose Chemical Corp Torrance CA Dense Non-
Aqueous Phase Liquid Operable Unit administrative
record (AR) index
R09: (Environmental Protection Agency -
Region 9)
1159497
10/27/2014
Written comment cards (5) - Comments fr public at
DNAPL workshop 10/27/14 (redacted)
R09: (Environmental Protection
Agency - Region 9)
1149478
11/8/2014
Meeting transcript for EPA public meeting - DNAPL OU
presentation & public comment, 11/8/14, w/word index
R09: Silva, Brittany (Huntington Court
Reporters & Transcription, Inc)
100019885
2/5/2015
(Redacted) Email: Discusses scheduling meeting on
Montrose DNAPL cleanup, w/history & forward to Y
Sanchez fr A Diaz 2/10/15
R09: Babich, Cynthia (Del Amo Action
Committee)
1149477
2/13/2015
Ltr: WRD (Water Replenishment District) comments on
proposed plan for cleanup of DNAPL at site
R09: Johnson, Ted (Water Replenishment
District of Southern California)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
1149479
2/13/2015
Ltr: Del Amo Action Committee comments on DNAPL
remediation proposed plan
R09: Babich, Cynthia (Del Amo Action
Committee), R09: Medina, Cynthia (Del
Amo Action Committee), R09: Gharibian,
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
1149480
2/13/2015
Ltr: Comments on DNAPL proposed cleanup plan
R09: Kelly, Joseph (Montrose Chemical
Corp)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
1149481
2/13/2015
Ltr: Comments fr Sierra Club on DNAPL cleanup
proposed plan
R09: Sattler, Al (Sierra Club - Palos Verdes-
South Bay Regional Group)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
100021117
7/2/2015
(Redacted) Email: Scheduling followup DNAPL
technology screening call, w/history
R09: Babich, Cynthia (Del Amo Action
Committee)
R09: Barton, Dana
(Environmental Protection
Agencv - Region 9), R09: Lvons,
Page 26 of 29
-------
Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
1161456
9/1/2015
Email: Montrose site TASC support strategy through end
of calendar year (DNAPL, vapor intrusion), w/attch
R09: Sanchez, Yolanda (Environmental
Protection Agency - Region 9)
R09:Yogi, David (Environmental
Protection Agency - Region 9),
R09: Babich, Cvnthia (Del Amo
100019893
12/18/2015
Email: Response to email re TASC Support on Del Amo &
Montrose - states that DAAC will not participate in any
Communitv Advisorv Panel (CAP) formation, w/historv
R09: Babich, Cynthia (Del Amo Action
Committee)
R09: Sanchez, Yolanda
(Environmental Protection
Agencv - Region 9)
100019910
12/18/2015
Email: Clarifies EPA's pause in TASC support (on DNAPL)
for Del Amo & Montrose sites
R09: Sanchez, Yolanda (Environmental
Protection Agency - Region 9)
R09: Babich, Cynthia (Del Amo
Action Committee)
100019841
1/31/2016
Technical Memo: Montrose DNAPL technology
screening - meeting materials, 11/2/15-1/25/16
R09: (Skeo Solutions, Inc)
100019918
2/8/2016
(Redacted) Email: DNAPL technology screening 2/8
conference call info & TASC final deliverable, w/history
& attchs
R09: Sanchez, Yolanda (Environmental
Protection Agency - Region 9)
R09: Gharibian, Florence (NONE)
100019899
2/11/2016
Email: Response to your remarks re facilitation of
DNAPL call on 2/11/16, w/history
R09: Sanchez, Yolanda (Environmental
Protection Agency - Region 9)
R09: Babich, Cynthia (Del Amo
Action Committee)
100020185
2/19/2016
Email: Summary of 2/8/16 DNAPL technology screening
path forward conference call, w/attchs
R09: Martinez, Yarissa (Environmental
Protection Agency - Region 9)
R09: Gharibian, Florence (NONE)
100019900
2/21/2016
Email: Provides link to Coalition for Clean Air post (ref
DNAPL Technology Screening Path Forward Conference
Call), w/historv
R09: Babich, Cynthia (Del Amo Action
Committee)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
100019851
4/11/2016
Ltr: Final comments on Dense Non-Aqueous Phase
(DNAPL) USEPA preferred remedy - Electrical Resistance
Heating (ERH), w/o attchs
R09: Babich, Cynthia (Del Amo Action
Committee), R09: Gharibian, Florence (Del
Amo Action Committee)
R09: Barton, Dana
(Environmental Protection
Agencv - Region 9), R09:
100007424
5/1/2016
Fact Sheet: Montrose & Del Amo Superfund sites
(overview) (English)
R09: (Environmental Protection Agency -
Region 9)
1173440
12/2/2016
Email: Del Amo & Montrose Superfund sites updates on
community involvement - materials fr community open
house event on 11/9, anti-degradation policv analysis.
R09: Sanchez, Yolanda (Environmental
Protection Agency - Region 9)
1173457
4/1/2017
Fact Sheet: Montrose & Del Amo Superfund sites (Spring
2017 site updates) (English)
R09: (Environmental Protection Agency -
Region 9)
Page 27 of 29
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Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
100019850
4/25/2017
Email: Discusses DNAPL detection in well CMW002
sampling results & forwards final rpt, w/history & attch
R09: Palmer, Michael (de maximis, inc)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
100017247
10/1/2017
Revised mobile DNAPL boundary confirmation
workplan, 20201S Normandie Ave, Los Angeles, CA,
w/appendix A & TL to Y Martinez Leon fr K Hewlett
R09: (T R S Group, Inc)
100007192
5/1/2018
Final electrical resistance heating pilot test workplan,
w/TL to K Hewlett fr L Stauch, 5/25/18
R09: (T R S Group, Inc)
100007152
5/22/2018
Fact Sheet: Montrose & Del Amo Superfund sites - site
update fact sheet, Spring 2018 (English)
R09: (Environmental Protection Agency -
Region 9)
100007153
5/24/2018
Fact Sheet: Montrose & Del Amo Superfund sites - site
update fact sheet, Spring 2018 (Spanish)
R09: (Environmental Protection Agency -
Region 9)
100019853
9/10/2018
Ltr: Comments on final electrical resistance heating pilot
test workplan
R09: Wells, James (L Everett & Assoc, LLC)
R09: Babich, Cynthia (Del Amo
Action Committee)
100021116
9/11/2018
(Redacted) Email: Del Amo Action Committee comments
on Electrical Resistance Heating pilot test (DNAPL) -
DAAC remains opposed, w/o attch
R09: Babich, Cynthia (Del Amo Action
Committee)
R09: Barton, Dana
(Environmental Protection
Agencv - Region 9)
100019884
10/30/2018
(Redacted) Ltr: Response to DAAC comments on
Electrical Resistance Heating pilot (DNAPL), w/attchs 1 &
2
R09: Martinez, Yarissa (Environmental
Protection Agency - Region 9)
R09: Babich, Cynthia (Del Amo
Action Committee)
100015277
11/18/2018
Fact Sheet: Montrose & Del Amo Superfund sites - site
update fact sheet, fall 2018 (English)
R09: (Environmental Protection Agency -
Region 9)
100019857
12/4/2018
Draft final Dec 2018 Community Involvement Plan (CIP)
for review, Del Amo & Montrose Superfund sites,
w/appendices
R09: (Environmental Protection Agency)
100019856
12/7/2018
Public Notice: Montrose & Del Amo Superfund Sites
update - draft Community Involvement Plan issued
(reauest for comments), w/email TL fr D Yogi, w/o
R09: (Environmental Protection Agency -
Region 9)
100017241
3/25/2019
Ltr: Revised ERH pilot test boundary confirmation &
baseline sampling rpt, 20201S Normandie Ave, Los
Angeles, CA, w/o attchs
R09: Stauch, Lynette (T R S Group, Inc),
R09: Trowbridge, Brett (T R S Group, Inc)
R09: Hewlett, Ken (de maximis,
inc)
Page 28 of 29
-------
Montrose Chemical Corporation Dense Non-Aqueous Phase Liquid (DNAPL) in CHRONOLOGICAL order
Superfund Site Operable Unit (OU-3) Administrative Record Final Index
Torrance, California First Released 09-05-2014; Updated 08-18-2020
Document ID
Document Date
Title
Author
Addressee
100017248
3/29/2019
Operations & maintenance manual - Electrical
Resistance Heating pilot test, w/appendices A-B
R09: (T R S Group, Inc)
100018256
6/14/2019
Fact Sheet: Montrose & Del Amo Superfund sites - site
update, Spring 2019 (English)
R09: (Environmental Protection Agency -
Region 9)
100019913
11/13/2019
Final Electrical Resistance Heating (ERH) pilot test rpt,
w/o appendices A-K
R09: (T R S Group, Inc)
100019057
12/2/2019
Fact Sheet: Montrose & Del Amo Superfund Sites Site
update, Fall 2019
R09: (Environmental Protection Agency -
Region 9)
100019917
12/30/2019
Memo: Response to EPA comments on ERH (Electrical
Resistance Heating) pilot test rpt & Final ERH pilot test
rot, w/attchs 1 & 2
R09: Davis, Eva (Environmental Protection
Agency - Center for Environmental
Solutions & Emergency Response)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
100019914
1/14/2020
Technical Memo (Revised): Recommended path forward
for MBFC (Middle Bellflower C-Sand) well CMW002,
w/attch A
R09: Dean, Brian (Group Delta Consultants,
Inc)
R09: Martinez, Yarissa
(Environmental Protection
Agencv - Region 9)
100020458
5/12/2020
Ltr: Focused Treatment Area boundary confirmation
sampling event results (draft submittal package),
w/attchs A-D
R09: Joyce, Patrick (T R S Group, Inc)
R09: Hewlett, Ken (de maximis,
inc)
100020491
5/19/2020
Ltr: Focused treatment area boundary confirmation
sampling event results, w/attchs A-D
R09: Stauch, Lynette (T R S Group, Inc),
R09: Trowbridge, Brett (T R S Group, Inc)
R09: Hewlett, Kevin (de maximis,
inc)
100020722
6/1/2020
Community involvement plan, Del Amo & Montrose
Superfund sites, w/appendices 1-8
R09: (Environmental Protection Agency)
Page 29 of 29
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APPENDIX B TRANSCRIPT FROM EPA PUBLIC MEETING ON NOVEMBER 8, 2014
155
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
1
2
3
4
5
6
7
8
9
EPA PUBLIC MEETING
10
11
MONTROSE SUPERFUND SITE
12
DNAPL OPERABLE UNIT
13
PRESENTATION AND PUBLIC COMMENT
14
NOVEMBER 8, 2 014
15
19800 SOUTH VERMONT AVENUE
16
TORRANCE, CALIFORNIA
17
18
19
20
21
22
23
24
25
Huntington Court Reporters & Transcription, Inc. 1
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
1
APPEARANCES:
2
Environmental Protection Agency:
3
4
5
6
7
8
U.S. EPA Region 9
BY: YARISSA A. MARTINEZ, Remedial Project Manager
600 Wilshire Blvd., Ste. 1460
Los Angeles, California 90017
Office of Community Involvement
BY: ALEJANDRO DIAZ, Community Involvement Coordinator
75 Hawthorne Street
San Francisco, California 94105
(415)972-3242
9
10
Community Members:
11
Cynthia Babich
12
Florence Gharibian
13
Marlene Puentes
14
Philip Fernando
15
Cynthia Medina
16
Margaret Manning
17
Alfred Sattler
18
Savanna Medina
19
20
21
22
23
24
25
Huntington Court Reporters & Transcription, Inc. 2
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
1
INDEX
2
SPEAKER PAGE
3
MR. DIAZ 4
4
MS. MARTINEZ 7
5
MS. BABICH 23, 54
6
MS. GHARIBIAN 2 9
7
MS. PUENTES 35, 51
8
MR. FERNANDO 4 9
9
MS. C. MEDINA 51
10
MS. MANNING 52
11
MR. SATTLER 58
12
MR. S. MEDINA 61
13
14
15
16
17
18
19
20
21
22
23
24
25
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TORRANCE, CALIFORNIA, SATURDAY, NOVEMBER 8, 2014
2
O
10:32 a.m.
>3
4
MR. DIAZ: Welcome, everybody. Thank you guys so
5
much for coming. I just wanted to thank everybody for
6
joining us today, and good morning, everyone, also. My name
7
is Alejandro Diaz. I'm with the U.S. Environmental
8
Protection Agency. I'm the community involvement
9
coordinator, and I have to my left here Yarissa Martinez who
10
you'll be hearing very shortly from about the DNAPL
11
contamination and the proposed plan itself, and then I also
12
wanted to give an opportunity for any local officials that
13
would wish to identify themselves to just really quickly
14
identify themselves. So I'm not sure --
15
MR. WARREN: I could say I'm Scott Warren. I'm a
16
geologist for the State of California.
17
MR. DIAZ: Great. Anyone?
18
MS. LY: Good morning, everybody. I'm Phunong Ly
19
with the Water Replenishment District. I'm an engineer, and
20
I manage the Groundwater Contamination Prevention Program.
21
MR. DIAZ: Great. Thanks. I also wanted to
22
introduce someone that's really important. We have been
23
working in the last couple of years with an independent
24
technical advisor, and he's here today. I just wanted him to
25
wave to us. Marcus, if you can just say hi to everyone.
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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Thank you. Marcus, has been really great, and we like having
2
him here. If you guys have any questions for him, if you
3
kind of wanted to talk to him during any of the breaks,
4
you're more than welcome to, and he has agreed that he is
5
also willing to talk to any community members.
6
So finally we're here to talk about the Montrose
7
DNAPL proposed plan. We use the word -- term "DNAPL" a lot,
8
and we'll be explaining it in the presentation. I just
9
wanted to let everyone know we have restrooms just kind of
10
right around the corner. The sign-in sheet is also really
11
important. It's over on that table. So we're hoping that
12
everyone who has a chance can get to sign in. I am also
13
going to say something In Spanish really quickly in case we
14
have anyone who needs Spanish interpretation.
15
(Testimony in Spanish.)
16
MR. DIAZ: There's also some coffee and pastries
17
available in the back, and if you can please silence or turn
18
off your cell phones. I just want to give you guys a run
19
through of the agenda really quickly. This is a lot
20
different than normal public meetings. This is an official
21
meeting that's required by law. So there's a lot of things
22
that need to run in a particular order. The first thing that
23
you'll hear from is you'll here from me for about 10 minutes
24
which you're doing is now which I appreciate.
25
Secondly, Yarissa will talk about the plan for a few
Huntington Court Reporters & Transcription, Inc. 5
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
1
minutes, and then afterwards or during the presentation, if
2
you have any clarifying questions, feel free to ask those.
3
Clarifying questions are, you know, what is the area of
4
DNAPL, if it's not clear or things like that, and then
5
afterwards the formal public comments. We'll let everyone
6
who wants to say some public comments to come up to the
7
microphone here, and originally I had planned for three
8
minutes, but it doesn't look like there's a lot of folks
9
here. We'll kind of just let you run as long as you would
10
need to -- to make those formal comments. We're also not
11
going to do the public speaking cards because of the same
12
reasons. Sometimes there's a lot of people, and we want to
13
keep track of everyone. So we'll just kind of do it by raise
14
of hands when we get started with the public comment period.
15
Then also, just wanted to let you know that the
16
public comment period has been extended through February
17
13th, 2015. We announced that on the website, and we have a
18
postcard that will be coming to the community to the same
19
names on the list that everybody received letting people know
20
that the public comment period has been extended to February
21
13th, 2015, and in addition, one of the things that's
22
different in this public meeting is that we also have a court
23
reporter here to my right who is recording, who makes sure
24
that your comments are recorded accurately. So when you guys
25
do come up, the first thing I'm going to ask you guys to do
Huntington Court Reporters & Transcription, Inc. 6
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
1
is approach the court reporter and just make sure she has
2
your name correctly.
3
Finally, there's these ways of submitting public
4
comments also. You don't have to submit them today if you're
5
not ready. There's e-mail. There's regular mail. There's
6
phone and fax, and also if you don't like speaking in public
7
but would rather just say something, then after the meeting,
8
you can approach the court reporter, and she can transcribe
9
your comments herself. So that being said, I'll go ahead and
10
turn it over to Yarissa who is going to talk a little bit
11
about DNAPL.
12
MS. MARTINEZ: Hello. Can everybody hear me? No?
13
Yes? I know that during the DNAPL workshop, a lot of people
14
complained that I wasn't using the mike correctly. So now I
15
have two. If anybody feels that I don't -- I'm not able to
16
express through the mike, let me know, and I can get the
17
other one, just double it. Okay. So good morning again.
18
Thanks for being here so early. As Alejandro said, I'm going
19
to be talking about DNAPL. I would like to talk to you about
20
the Montrose Superfund Site. I will start with what is
21
DNAPL. A quick summary of basic facts of the former Montrose
22
property and the previous activities that caused DNAPL to be
23
in this site. Followed by a description of components of the
24
DNAPL and how remediation of groundwater has been decided and
25
how it affects DNAPL. The differences between mobile and
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residual DNAPL, technology screens, remedies evaluated, and a
2
preferred remedy for DNAPL. So please bear with me through
3
this presentation.
4
So what is DNAPL? To give you a mental picture,
5
DNAPL looks like molasses. DNAPL is a term given to one or a
6
group of substances that do not dissolve in water easily and
7
are heavier than water. So it doesn't float. As the term
8
says, it is still considered a liquid, and it is not water.
9
It has its own characteristics and depending on the
10
contaminants is how you can treat it. DNAPL at the former
11
Montrose Plant Property happened as a result of the
12
production of DDT and management of the chemicals used to
13
make the pesticide. A little background about Montrose, it
14
was the largest manufacturer of DDT in the United States,
15
active from the '40s to the '80s and produced up to 7 million
16
pounds of DDT per month.
17
This means that approximately 80 million pounds per
18
year of technical grade DDT powders, which were manufactured
19
in this property and included a network of waste streams,
20
waste ponds, sanitary sewers, and even dumped in the open
21
ocean. Therefore, in this site we have groundwater, soil,
22
and surface water contamination from previous DDT
23
manufacturing activities. The Montrose Superfund Site was
24
included in the National Priority List, which is a list of
25
the most contaminated sites in the US in 1989. It has been
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divided in seven operational units to address all the media
2
that had been affected.
3
EPA, the lead agency, makes the final remedy
4
selection and documents it in a decision document. So this
5
slide will give you a snapshot of the chemistry behind DDT
6
activities in the Montrose Property. This is important
7
because you will see some of these chemicals later on in this
8
presentation. So you have the raw materials which are
9
Chloral and Monochlorobenzene, which we will refer to as
10
Chlorobenzene, which are mixed with Sulfuric Acid, which is a
11
very strong acid that is used as the catalyst to react and
12
produce DDT.
13
So as you saw in the previous slide, Chlorobenzene
14
was used to produce the pesticide. The DNAPL that we have in
15
this site is composed approximately half DDT and half
16
Chlorobenzene by weight. Let me talk a little big about
17
these two contaminants. DDT is a pesticide that was widely
18
used in the 1950s and '60s very effectively against malaria
19
and other insect carrying diseases before being banned in
20
1970s. DDT is a white waxy solid that attaches to soil
21
particulates and remains in the environment, without breaking
22
down easily. DDT is not soluble in water, but when it is
23
mixed with Chlorobenzene it forms DNAPL. Chlorobenzene is a
24
semi-volatile, meaning that it can evaporate easily and
25
dissolves little in groundwater.
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These two contaminants that make up the DNAPL when
2
looked at separately have the following characteristics:
3
DDT, pesticide, bioaccumulates, meaning that it stays in the
4
body of animals through the food chain. It is highly toxic
5
to wildlife even at low concentrations, affects the way the
6
human body deals with hormones, and it is a know carcinogen.
7
Chlorobenzene affects the liver, and it is not a carcinogen.
8
By the mid 1960s, the area saw additional industrial and
9
commercial growth. I want to point out where the central
10
processing area was, because that is where we found DNAPL.
11
The next picture shows an archive picture of the processing
12
equipment for technical grade grinding. So by 1982, Montrose
13
had discontinued the production of DDT, and in 1985 an
14
asphalt cover was installed on the surface. As you can see,
15
the former Montrose Plant Property is vacant, and it is
16
surrounded by commercial, industrial, and residential areas.
17
Currently the water treatment plant is being built here and
18
will be completed in a couple of weeks.
19
So now that we have seen the area and have a little
20
bit of story of the site, I would like to talk to you about
21
how DNAPL and groundwater are related. To give you an easy
22
example, if you have a gallon of milk in the fridge, and it
23
has a hole and you see milk everywhere and you start cleaning
24
up the milk, but you don't remove that gallon of milk or
25
empty it, you will still have a lot to clean up. So DNAPL is
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like that gallon of milk that you -- that we are seeing as a
2
source. So it would be the source of the groundwater plume.
3
Again, the DNAPL happens just -- and you'll see it in the
4
maps following this. It just happens inside the Montrose
5
Plant Property.
6
So I want to stress that the drinking water for all
7
Southern California from water purveyors, LADWP being one of
8
them in the area, and that there are not drinking water wells
9
in the contaminated water, and at least one mile away from
10
the plume, and they are sampled routinely. So let's talk a
11
little bit about the groundwater remedy. Around the 1980s
12
and '90s, EPA determined that due to the mixed groundwater
13
contamination from Del Amo and Montrose, a dual groundwater
14
remedy should be in place. In 1999, the record of decision
15
for this dual site groundwater was published to prevent
16
exposure and to address the various contaminants in the site.
17
One of the main active remedies of this decision is the
18
groundwater treatment plant. There's a picture just looking
19
towards Normandie of the new groundwater treatment plan. So
20
to put everything in perspective, here's -- I'm going to need
21
your pencil.
22
Here's Montrose and Del Amo. So you have Montrose
23
and then you have the Del Amo Superfund Site, and you have in
24
red, you can see the Benzene plume from Del Amo, groundwater
25
plume, and you can see green which is in the middle, the
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Chlorobenzene plume, and then you can see the blue blob or
2
the blue plume is the TCE that comes from different TCE
3
parties -- responsible parties. So one thing I want to point
4
out in this map is the dark blue area right there. So it has
5
two different parts of it. That's the DNAPL -- the mobile
6
DNAPL inside the Montrose property. The green boundary that
7
you can see very defined, that includes mobile and residual
8
DNAPL. Again, it just happens inside the Montrose Plant
9
Property. So this slide was included in the proposed plan.
10
NAPL occurs in two forms, LNAPL and DNAPL, and even
11
though the concepts are the same for this slide and related
12
to the slide, we'll refer to it as DNAPL. So in this figure
13
you can see a drawing of mobile and residual. The mobile
14
DNAPL is the mass that holds together and it's continuous.
15
Because of the properties of DNAPL, some portions get stuck
16
between the soil particles, and those portions are considered
17
the residual DNAPL. As we said -- and as we said in the
18
October workshop, once it becomes residual, it does not
19
become mobile. So DNAPL has been defined by more than 200
20
soil borings, which are holes in investigations we did in the
21
ground for over 10 years, and it was detected from a minimum
22
of seven feet below ground surface up to a maximum of 101.5
23
feet below ground surface.
24
This shows the extent -- the lateral extent of
25
DNAPL, which when you add up the two blue areas, it's almost
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half the area of a football field. Simply stated, the
2
revenue objectives for the DNAPL in this area are to prevent
3
human exposure to DNAPL, limit the migration and reduce
4
mobile DNAPL contamination as much as possible and to make
5
sure DNAPL does not continue to act as a source of
6
groundwater contamination. During the process of looking at
7
what technologies are able to address the DNAPL at the site,
8
we looked at many technologies. Some of the technologies
9
that we looked on at early stages included Hydraulic
10
extraction, bioremediation, or other injections to reduce
11
contaminants, excavations and slurry walls. However, due to
12
the contaminants, the location of the site, depth of the
13
contaminants, and the groundwater plume of the area, most of
14
these technologies were discarded because they were not the
15
right actions for the site.
16
The technologies that were right for the site were
17
when we looked a little bit further. In summary we have
18
eight remedial actions composed of four different
19
technologies, SVE, hydraulic displacement, steam injection,
20
and electrical resistance heating, and various institutional
21
controls are being considered in this plan. So going to the
22
technologies that were considered, one of the technologies
23
that was considered as part of all the different remedial
24
actions active is the soil vapor extraction. It mainly -- it
25
basically vacuums vapors out of the soil and treats the
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vapors on the site. With this technology, you would drill
2
extraction wells into the contaminated soil to a depth above
3
the water table and attached to the wells is equipment that
4
creates a vacuum. The vacuum pulls air and vapors through
5
the soil and up the well to the ground surface for treatment,
6
and this is what you would see at the site. In your -- you
7
see the Del Amo soil vapor extraction system.
8
The other technology that was considered was
9
hydraulic displacement. Hydraulic displacement, in summary,
10
uses injection and extraction wells of water to move
11
contaminants. Extraction and injection of the groundwater at
12
the same time to help control water flow and pull DNAPL
13
toward extraction wells, and this is what you would see at
14
the site. It's usually underground wells. Two of the active
15
technologies that can address DNAPL are thermal remedies. In
16
thermal remedies, heat is applied to the ground to turn
17
contaminants into vapors so as to collect and treat them. In
18
situ, which just means at the site, thermal treatment methods
19
heat chemicals and soil and groundwater to turn them into
20
vapors. The chemicals move through soil and groundwater
21
toward wells where they are collected and piped to the ground
22
service to be treated.
23
One of the thermal remedies is called steam
24
injection where steam is injected underground to help turn
25
contaminants into vapor to help collect and treat them. It
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injects steam underground by pumping it through wells drilled
2
in the contaminated area. The steam heats the area and
3
mobilizes and evaporates the contaminants. The electrical
4
resistance heating is another type of thermal remedy. It
5
delivers an electrical current between metal rods, called
6
electrodes, installed underground. So heat is generated as
7
movement of the current meets resistance from soil converts
8
groundwater. So it basically -- there's metal rods in the
9
ground that you apply electricity and this will heat the
10
contaminants and vaporize them, and then you can collect
11
them. So the proposed remedies are listed here. I'll go
12
through each of them individually.
13
EPA is required to look at this alternative, no
14
action, and the reason of it is to be able to compare what
15
would happen if we didn't do anything at the site. Our
16
second alternative will be just doing institutional controls.
17
Institutional controls are legal and administrative controls
18
that applies to properties to minimize the potential for
19
exposure. So in this case, it would be a land use covenant
20
that will restrict activities at the Montrose property for
21
industrial use. Our remedial alternative number three would
22
be to make sure of institutional controls and soil vapor
23
extraction. The remedial alternative four would be hydraulic
24
displacement. We have two different versions of the
25
alternative four which included with treated water or with
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untreated water.
2
Our remedial alternative five would be steam
3
injection and it's included steam injection only on the
4
mobile DNAPL or over the entire DNAPL area. And our sixth
5
remedial alternative would include electrical resistance
6
heating, or as we call it, ERH, over the mobile DNAPL area or
7
over the entire DNAPL area. So EPA, after -- after we go
8
through the technologies considered and we make up remedial
9
alternatives, we do a comparison, which is part of our
10
regulations and we look at if they're protective of human
11
health and the environment which determines whether the
12
alternative eliminates, reduces, or controls the threats to
13
human health. We take a look at the compliance which is,
14
does the remedy comply with local, state, and federal
15
regulations. We look at long-term effectiveness which is
16
considered an alternative ability to maintain reliable
17
protection of human health in the environment. We look at
18
the mobility reduction, quality of reduction, which means if
19
the treatment addresses or reduces the contaminants on site.
20
Then we look at short-term effectiveness which says
21
if during the implementation process, there's any adverse
22
effect to human health in the environment. So this is just a
23
pictorial graph of how we do this comparison. As you can see
24
here, our remedial alternative, the one that is preferred by
25
EPA, is the one that most complies with all of the different
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requirements. So looking at long-term effectiveness,
2
reduction of the mobility, the volume, and then comparing it
3
to cost, we have chosen ERH, focused treatment area as EPA's
4
preferred remedy. The duration of this ERA implementation
5
would be from three to seven years, and it would cost between
6
20 and 25 million. Again, I would like to say that the cost
7
presented here is basically a comparison tool. So it might
8
be up or down a little bit. It's not the actual cost for
9
implementation. So following the regulations that --
10
following the superfund regulations, we are required to
11
choose a remedy that is the most cost effective.
12
This would be a diagram of how the electrodes would
13
be put in the ground for electrical resistance heating
14
applied to the two areas that have mobile DNAPL. These are
15
just pictures of another ERH implementation in San Francisco.
16
Our estimated schedule for this, today is the proposed plan
17
meeting. We have extended the public comment period all the
18
way to February, and hopefully by 2015, we have a record of
19
the decision very late in 2015, and we can start the remedial
20
design and the remedial design would be starting in 2015,
21
2016. And then by 2018, hopefully the remedial construction
22
and clean up happens. And Alejandro will rap up this.
23
MR. DIAZ: So again, February 13th is the last day
24
to submit public comments. If you're sending them by mail,
25
they must be postmarked before or on February 13th, and in
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addition, what happens next is that the EPA takes the public
2
comments as a criteria for -- as one of the nine criteria for
3
finally making a decision, and EPA will provide a response to
4
those comments submitted when we publish the record decision
5
itself. So that concludes our meeting -- I mean, no. Not
6
our meeting. I'm sorry. That concludes the presentation.
7
Right now I just wanted to open the floor up if anybody had
8
any clarifying questions, if something wasn't clear, if you
9
would like one of the alternatives to be explained a little
10
bit more or anything like that. Anybody?
11
UNIDENTIFIED SPEAKER: Yes. Explain the
12
bioremediation more.
13
MS. MARTINEZ: So hello. So bioremediation, it was
14
not retained because of the high concentrations of
15
Chlorobenzene we have in the area. DNAPL are toxic to
16
Chlorobenzene in creating bacteria. So during the section
17
four of the FS, we do this because there was some returned
18
data that indicated a Chlorobenzene can be biodegraded to
19
some extent and also DDT is not biodegradable. So it was
20
ruled out.
21
MR. DIAZ: Did you have a follow-up to that, or did
22
you have something else?
23
UNIDENTIFIED SPEAKER: No.
24
MR. DIAZ: Yes?
25
MS. C. MEDINA: (Inaudible).
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MR. DIAZ: Yes. How will you handle the extracted
2
vapors?
3
MS. MARTINEZ: So everything will be on a vacuum
4
which is part of this whole vapor extraction system and
5
everything will be filtered.
6
MR. DIAZ: And can you clarify if we know how we
7
will be treating those? I think that was his question. What
8
type of treatment?
9
MS. MARTINEZ: So as of now, we're evaluating the
10
use of carbon. So we will not have any flames or any thermal
11
issues at the site. We will not.
12
MS. C. MEDINA: I don't know if this pertains to it,
13
but you mentioned that it was going to cost -- an estimated
14
cost of 20 to 25 million just for the DNAPL extraction. So
15
the (inaudible) clean up was 20 million -- or 10 million.
16
Sorry, and the water that construction is going on for the
17
water clean up now, wasn't there any discussion of how much
18
money is spent to clean up compared to just removing the
19
people, you know, get the people out of the way and just
20
cover it all up and just save all that money? It's -- that
21
is a lot of money.
22
MS. MARTINEZ: I understand.
23
MS. C. MEDINA: And during this whole process we're
24
still exposed. No matter how filtered or how clean
25
everything that you propose to do, we're still going to be
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exposed. It's still going to be there. When you use the
2
example of the gallon of milk spilling into a refrigerator --
3
so we have this contamination spilling into our soil and
4
where we live, and you're going to clean it up, but you're
5
not removing the gallon of milk. You're not removing the
6
DNAPL that's the -- the resistant one.
7
Anyway, this is not my expertise, but to compare the
8
money that you're spending on clean up is nothing compared to
9
just removing the people out of the danger. I mean, in my
10
opinion, it's (inaudible) to why would the government who was
11
always, always saying that, you know, they're stretched out
12
to the max, and they don't have money for this and for that
13
and they can just spend 20 million dollars like that to clean
14
up something that's not even guaranteed to be cleaned and
15
it's not going to guarantee that we're going to be safe. I'm
16
getting emotional here so here you go.
17
MR. DIAZ: So thank you, Cynthia. If you want to
18
come up during the comment period and say that again, you're
19
more than welcome to. If not, we'll consider that as a
20
comment.
21
MS. C. MEDINA: Thank you.
22
MR. DIAZ: So is it another clarifying question?
23
UNIDENTIFIED SPEAKER: In other words, will there be
24
a competitive cost comparison between removing people and the
25
cost of the clean up? Will there be a very clear cost
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comparison?
2
MS. MARTINEZ: I don't know if that was ever done.
3
I think, you know, following the superfund process -- and I'm
4
sorry. I have to go back to what I'm presenting here. We
5
just looked at the technologies available to mediate the
6
issue at hand.
7
MR. DIAZ: So it it looks like we're --
8
UNIDENTIFIED SPEAKER: Just a clarifying question.
9
I realize this is a DNAPL meeting, but you had a slide
10
covering the groundwater treatment system. Can you just
11
clarify on whether or not that groundwater treatment system
12
is in operation now? Are you done with the construction of
13
the treatment system?
14
MS. MARTINEZ: No. We're not. It should be --
15
construction should be completed in the next couple of weeks.
16
MR. DIAZ: Okay, and with that --
17
UNIDENTIFIED SPEAKER: And again, I guess it's
18
outside the scope of this public hearing, but, you know,
19
perhaps some greater understanding of the relationship of
20
that groundwater clean up system to this might well be
21
helpful in the group understanding here in the room.
22
MS. MARTINEZ: Okay. So can you put the slide of
23
the groundwater plumes? Okay. I'm going to try this, and
24
again, this is just a pictorial. I wanted to showcase how
25
DNAPL only happened in the Montrose property. We have
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various commingled plumes of groundwater in the area. The
2
DNAPL serves as a source of the Chlorobenzene in the
3
Chlorobenzene plume, and that's how it pertains to the DNAPL
4
removal here. If you wanted me to talk a little bit more --
5
MR. DIAZ: Maybe you can talk about all of the
6
sources that are known in the area of groundwater
7
contamination.
8
MS. MARTINEZ: Okay. So we -- again, this is not my
9
operational unit. So I would like to limit the discussion as
10
much as we can as to DNAPL. So for the Chlorobenzene, we
11
know what the source is which is the DNAPL. For Benzene,
12
there's a couple of (inaudible) and we also have the waste
13
piles and then for TCE, there's more than 10 responsible
14
parties that through the history of activities in the area
15
have discharged TCE to the groundwater. TCE is a soil vent
16
that is used in many industrial --
17
MR. DIAZ: Can you give the name of the chemical?
18
UNIDENTIFIED SPEAKER: Inaudible.
19
MR. DIAZ: Does that help clarify your question? I
20
want to make sure that you -- okay. Great. So with that,
21
we'll go ahead and get started with the formal public
22
comments. Again, I'll be calling you guys up one by one and
23
you guys can use the podium where Yarissa is. So Yarissa, if
24
you can clean up your stuff that you have there, and you can
25
go ahead and like I said, since there's not that many people
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here today, we'll just go ahead and go as long as you need to
2
talk. So with that, the first person that approached me and
3
requested to talk before was Cynthia Babich. So I want to go
4
ahead --
5
MS. BABICH: Good morning, everyone. Thank you for
6
coming. I'm Cynthia Babich, and I'm director of the Del Amo
7
action committee. The Del Amo action committee was formed by
8
community residents over 23 years ago to work specifically
9
on the contamination issues impacting our community from the
10
Del Amo and Montrose sites. I'd like to express our
11
thankfulness to the extension of the comment period until
12
February the 13th of 2015, and I would like to also make a
13
request that this type of a meeting is repeated closer to the
14
end of the comment period because the reason that we asked
15
for the extension of the comment period was so that we could
16
do appropriate education inside the committee door to door.
17
As you can see, there are people that have come
18
today, but in my thinking back of my 23 years of work in the
19
committee, there are people that I have been working with for
20
that long that were already in retirement when I started. So
21
I think that their input is key and valuable, but I do not
22
think that they would be able go make the truck even though
23
the hotel is very close to the community to this type of a
24
meeting. So we are hoping that through our outreach, we will
25
be able to take comment cards out with the EPA. So that we
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can capture people's comments that way as well.
2
So I think it is also very important again though
3
that this venue be repeated because a lot of people will want
4
to give their comments verbally, and I think having the asset
5
of somebody who types down their comments word for word is
6
very important rather than the retelling of their particular
7
story by somebody else's version. Which would lead me to my
8
first comment. Many years ago in a meeting similar to this
9
with an EPA person that, at that time, I would call a
10
visionary. His name is Mike Montgomery. We were talking
11
about accountability, and he had the strangest look on his
12
face and he said yes. Absolutely right. Accountability. In
13
fact, I'm going to print that out in big block letters, and
14
I'm putting that over my desk which then made me think a
15
little bit differently of what we were talking about.
16
I said well, what are you talking about, and he said
17
well, I have to be accountable to people in San Francisco and
18
on Washington on the decisions that we make in this
19
community, and so accountability is very important for me,
20
and I said well, that is clearly different than what I'm
21
thinking about accountability. I think that the
22
accountability that we are seeking through this process and
23
other processes that are before us with regards to this kind
24
of contamination is the accountability that needs to be made
25
to the impacted community. I think that what their needs are
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need to be put foremost and first, and I think that the
2
comments that Mrs. Medina made were very, very important, and
3
people would argue that this is not the time or place to talk
4
about relocation or moving people out of harms way.
5
I would argue that every opportunity that we have is
6
the time and place to remind people that this has been going
7
on for decades and the clean ups that are being planned are
8
going to occur for 3,000 to 5,000 years, and I make that
9
remark because over 15 years ago, somebody decided, not the
10
community, that they could have a technical impracticability
11
waiver for cleaning up contamination in this area. Meaning
12
that at that time 15 years ago, somebody decided that it was
13
technically impracticable to try to clean up the gross
14
contamination that has been heaped upon our community. I
15
would like to also point out that somebody else also had the
16
bright idea of actually including people's homes in this
17
containment zone.
18
I would think that would be against the law, and
19
that would be apart of taking -- you're taking somebody's
20
property, and so many years ago I asked the EPA about this
21
technical impracticability waiver sometimes called the
22
containment zone, and people looked at me curiously saying
23
well, don't you realize it's going to take 3,000 to 5,000
24
years to even get there as if I shouldn't really worry about
25
the fact that we're all going to be dead and our children are
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going to be dead and their children's children's children are
2
going to be dead by the time we actually see containment of
3
this contamination. And I think it is wrong on many levels
4
to leave people as genie pigs sitting on top of this
5
contamination. When we talk about pieces of contamination,
6
Yarissa mentioned that this wasn't her particular operable
7
unit when she was discussing some of the other plumes.
8
I'd just like to point out that Montrose has seven
9
operable units and Del Amo has three and they share one, and
10
how in the world with anybody who has a degree in common
11
sense like I do would think that, how are you going to fit
12
all those pieces together? Yet time after time and even in
13
the feasibility study, we're told that somehow magically this
14
removal action is going to impact that removal action, and I
15
think that was the question that was asked earlier. How are
16
you possibly going to measure the changes or any clean up
17
that's going to happen when you have all these operable units
18
that going on at different rates, and I think that to give
19
people an answer that somehow it's magically going to come
20
out really great at the end is not reasonable, and I don't
21
think it's an honest answer.
22
So I would like to say we are looking for
23
accountability for our community, and I think that everybody
24
in this room should be holding that for most as well. The
25
discussions that were made 15 years ago in 1999 need to be
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revisited. Had people made a decision and got right to work
2
on putting in the treatment system, we would have an up and
3
running treatment system and that system would require that
4
every five years we review new technologies and emerging
5
things that, you know, we didn't know about 15 years ago to
6
make sure that we are really getting this mess cleaned up in
7
the best way possible and that has not happened. In fact,
8
there would have been three five-year reviews. So we have
9
asked and we will continue to ask that the technical
10
impracticability waiver zone be revisited.
11
I think this needs to be done with all state holders
12
especially the community because while it's been presented
13
today that people have worked very hard for 15 years to come
14
to this conclusion that we want to stick electrodes in the
15
ground and fire those puppies up and start moving this
16
contamination, that I'm not clear we even know where it's at
17
now and yet we're going to start moving it around and somehow
18
magically it's not going to make things worse that we would
19
want to make sure that indeed there isn't something better
20
and the conversations that have gone on with different
21
agencies like the department of toxic substance control and
22
the water replenishment district, and there's probably others
23
that I'm not mentioning have probably all been very
24
fascinating and full of great information.
25
Again, the people who are being impacted by this
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contamination are left back at the starting gate trying to
2
somehow figure out how all those come together. Why people's
3
homes are in a technical impracticability waiver zone. Why
4
some promising technologies have been screened out and why
5
time is of such an essence that they can't wait for us to get
6
up to speed and utilize the technical advisors that have been
7
put at our disposal considering that we're talking about 3-
8
to 5,000 years to get to containment. I understand from the
9
documents that have been presented to us that as far as the
10
DNAPL portion of the remediation goes, they're estimating a
11
three- to seven-year timeline, but still as Mrs. Medina
12
pointed out, that's going to leave contamination behind.
13
If Angela Johnson was here who is one of our most
14
favorite people who loves and helps our community, she would
15
argue that if you thought that DNAPL was syrup, it would keep
16
giving its sugary goodness to us for decades to come. So we
17
think that when we look at these technologies, we really need
18
to look at actually removing the contamination, and when we
19
think about what's going to go on at the groundwater
20
treatment system that's being put into place now and being
21
tested and somebody mentioned about the carbon treatment
22
system that's going to happen, and that sounds really --
23
something that won't blow up which is always nice, but it
24
sounds something very passive and very nice, but really the
25
fact remains is that that carbon that becomes contaminated is
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going to go to native tribes around the Colorado River.
2
It's going to be burned and regenerated there in one
3
of their systems. So simply to remove it from our backyard
4
and put it in somebody else's is not always the answer and
5
that is why I believe and many others believe that you have
6
to have average community people at the table to look at some
7
of these concerns not with the lense of how much it costs. I
8
would like to request that the EPA do a formal technology
9
screening very quickly where we look at the technologies that
10
are at our disposal today, and before any decisions are made
11
on the technologies that EPA has screened so far. I would
12
also like to point out that doing anything is not the same as
13
doing something. Thank you.
14
MR. DIAZ: Thank you, Cynthia. It looks like
15
Florence here wants to make some comments.
16
MS. GHARIBIAN: My name is Florence Gharibian. The
17
first thing I want to say to the people in this room who are
18
empowered to do something about the Del Amo/Montrose
19
site -- I do not call it sites. I do not call it operating
20
units. I call it the Del Amo/Montrose site because the
21
co-mingled waste is the problem, and it needs to be solved
22
holistically. What I want to say to you is you really can
23
clean this up. You can clean it up, and you can clean it up
24
in our lifetime, and I want you to believe that it's possible
25
to do that and not accept impossibilities or discussions of
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how it's going to take 5,000 years. I want you to think you
2
can do it, and you can do it in our lifetime.
3
I want to do some time frames here. We had a draft
4
viability study that was published in 2011 and that study was
5
there and then commented on in December of 2012 by both the
6
department of toxic substances control and by the water
7
replenishment district, which is the organization that helps
8
ensure that all of us have clean drinking water. Then it
9
went to an EPA review board in 2013, and then they gave their
10
comments and now we're sitting here and it's November of 2014
11
and we're still working on it. So the timing of all these
12
things is really an issue. As Cynthia mentioned, work on the
13
site started in the early '80s and the groundwater treatment
14
system is going to go online recently soon, I guess.
15
Although the group has a very serious concern about that, and
16
just to let you know, I am honored to serve with Cynthia as
17
the chair of the Del Amo action committee. Something that I
18
am very privileged to do.
19
So timing is important, and now I want to get to my
20
first comment and say this is an identified comment to be
21
found in the comments that were prepared by our technical
22
advisor, and I'm going to do a quote. "In order to be more
23
transparent, EPA should clearly state that the proposed
24
remedy neither addresses DNAPL that could be practically
25
remediated outside the focus treatment area or the DNAPL
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below the residual saturation inside the treatment area. EPA
2
should also be more forthright and transparent with respect
3
to the decision namely that it is because it is still
4
believed that the most aggressive and expensive remedial
5
approach could not possibly remove all the DNAPL from the
6
Montrose site. So it is therefore acceptable to leave a
7
large residual fraction behind even if a potentially
8
significant fraction of this residual DNAPL could be
9
remediated."
10
So I'm saying remediate this DNAPL, and do that with
11
the belief that in remediating this, you are going to make a
12
big step forward in cleaning up the Del Amo/Montrose site. I
13
happened to know that there are wells on the Montrose site.
14
One well, if you pump it, you get DNAPL. It comes to the
15
surface. Another well that is really not very far away from
16
the first well, you can pump it, and you don't get DNAPL and
17
that caused me to believe that it's possible to do a removal
18
and make a big difference, and I have in the EPA response to
19
the comments that were made by the technical advisor, a
20
statement that excavation of the DNAPL impacted soils to a
21
depth of a 105 feet over a 160,000 square foot source area
22
would be infeasible and might cause a billion dollars.
23
I have a lot of trouble with all of those numbers
24
and trying to make them make sense when I see these two
25
concentrated areas of DNAPL on this map, and let's be clear
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about it. We're not talking about molasses or syrup. We're
2
talking about toxic chemicals that are in our area and in our
3
groundwater that ought to be cleaned up. Another thing I
4
want to say is that in order to achieve this goal, you need
5
the best minds at the table, and I would like to suggest that
6
there be a convening of a group that includes the department
7
of toxic substances control, the water replenishment
8
district, the regional water quality control board and others
9
possibly even from academic settings to look at these issues
10
holistically, and see if we can't come up with a better
11
approach.
12
I would also want our technical advisors to be part
13
of that group. Great minds can come up with great things,
14
and that's what we need here and the community needs to be
15
partnered in that effort. The department of toxic substances
16
control prepared written comments, our advisor prepared
17
written comments, the water replenishment district provided
18
written comments on this plan. I want to see them in the
19
public record and responded to in the public record. So
20
they're not a letter somewhere in a file. Believe me, I have
21
spent hours and hours trying to find all this information and
22
make sense out of it. It's a big job and having these
23
materials available to the public and in the public record
24
and part of the process is an important step.
25
Now, I also want to ask -- I also want to talk a
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little bit about another chemical that wasn't mentioned in
2
the charts. We talked about how DDT is not water soluble.
3
We talked about how Chlorobenzene is not water soluble, but
4
they did use a solvent and that solvent is water soluble and
5
possibly was used at the Montrose site because it's water
6
soluble and I know for sure three places where that solvent,
7
which is called PCBSA, turns up in this great United States
8
of America and one of them is right here at Montrose and one
9
of them is a little town in Michigan called Saint Louis,
10
Michigan, where they have their drinking water wells
11
contaminated with their material and another one is a string
12
fellow acid pits in Riverside County, and there was one point
13
when I thought I was going to have -- she worked on the
14
string wallow acid pits on my grave stone, but that was
15
another day and another time.
16
I want to know if PCBSA is in this DNAPL because I
17
remain concerned that it is enabling this material to be more
18
mobile. I want to know that it's not in our drinking water,
19
and I read some documents that suggested that EPA would be
20
monitoring the drinking water to make sure it wasn't in it.
21
I want to know they have actually done that work. PCBSA is
22
not something that drinking water companies routinely monitor
23
for when you get your drinking water, and I want to make sure
24
that we understand the extent of the pollution that was
25
caused by that chemical. There's another issue related to
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the wastewater treatment system related to PCBSA as well and
2
that is, will it be removed sufficiently because the water
3
that's treated in that groundwater treatment unit will
4
ultimately go into the clean portion of our groundwater
5
basin, and I see that as something we need to be very careful
6
about and very concerned about.
7
So I hope I haven't used too many technical terms or
8
gotten into too many territories that may not be actually
9
related to DNAPL, but I'm saying you got to look at the big
10
picture. I also want to make another very important point
11
that I make whenever I have any conversation about this
12
subject. When they test the human health effects of
13
chemicals, they test them individually. So there's data on
14
the harm caused by TCE, and there's data on the harm caused
15
by Chlorobenzene and there is some very, very limited data on
16
the health problems cause by CPSA.
17
Of the data that is available on what happens when
18
all of those materials are all present in one place, what is
19
the potential health effect on people of those combined
20
co-mingled chemicals that is really rough science and there's
21
not really a lot of information known about that, and that
22
makes doing the most careful -- the most conservative thing
23
possible to solve this problem, a really important thing. So
24
thank you for listening, and I'm glad I can be here today.
25
MR. DIAZ: Thank you, Florence. Marlene, you're
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next.
2
MS. PUENTES: Sorry I was late. I had my son. My
3
daughter was here earlier. I live at 1072 West Torrance. I
4
lived at 20430 Catalina Street right there in the
5
neighborhood. I lived at -- on Budlong. I lived on Kenwood.
6
My grandfather lived on 204 Street. My grandfather was an
7
employee at Montrose Chemical. He came from Colorado,
8
Denver, Colorado. They were healthy. All my family was very
9
healthy, abundant and healthy. He was working at Montrose
10
Chemical, and his first child that was born during that time
11
was my aunt Gloria, and she was born a dwarf, and our family
12
with all our numerous children that we have in my mom's
13
immediate family, my sister and I have, two of my sisters and
14
also I have 12 autistic children. My two are nonverbal.
15
One is 19 and the other one is 13. It's been a lot
16
of work, I'll tell you that right now. I'm suffering from a
17
terminal brain tumor, and I know about all these figures, but
18
I know what's going on in the community straightforward.
19
We're getting brutalized by the police department. We have
20
got yellow school busses in and out all day long. Now they
21
got this thing going on in the street right in front of my
22
house, and these ungrateful people. I gave them on the
23
hottest days of the year, lemonade, twice a day. I put a
24
little stand out there and I put lemonade, and I would always
25
serve them twice a day because I thought to appreciate what
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they were doing.
2
I actually at first wanted to make the biggest signs
3
I could ever make and just torture these people to stop them
4
because what in the heck is going on, and what I thought was
5
going on is that we're getting new pipes. We're not getting
6
new pipes. We're getting the same pipes that were parallel
7
to the pipes that were already there. So if you think those
8
pipes aren't contaminated, you're wrong, and all we're doing
9
is putting a band aid over a big thing that's bigger than 3-
10
to 5,000 years. It's happening now. It's filling up our
11
jail systems with people would have brain damage, people that
12
are born with autism.
13
In 1999, I just heard that the first meeting of this
14
sort was taken place, and I'd like to know -- or no. I do
15
know that Mary Bradley was instrumental in this and Angela
16
Back from Eyewitness News, and it was amazing to see it local
17
like that, and I was just a little girl, kind, and I was kind
18
of polite so I didn't do what I would do now. I would be all
19
over that. In 1999 is when I got my son's diagnosis. He was
20
the cutest little baby, the best little baby, you know, just
21
beautiful. And when he was diagnosed, I didn't know what
22
autism was, and I'm a smart person. I had already worked for
23
a real estate corporation. I was the young agent at 24. I
24
had two children. My daughter was very smart.
25
She was just here a little while ago. She has been
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to USC. I heard in third grade that when she took her first
2
test and it was a really big one that it was all downhill
3
from here because there's nothing as extraordinary as that
4
test score. Then I look at my son, and he's been going to
5
school since he was two and his backpack when he got on that
6
yellow school bus was bigger than him, but when I learned
7
what autism was at the beginning, I didn't know what it was.
8
I thought he could draw good. That's how uninformed and how
9
unrament was. Now, we went from one in 800 kids being born
10
with autism to one in 60.
11
We're not just talking aspergers and maybe this kid
12
might have AD -- whatever that's called. This is a life
13
form. This is not something that will go away because what
14
you're saying is ratify autism. These are individuals just
15
like -- I'm not for or against homosexuality, but they were
16
born like that. They have got laws protecting them. These
17
kids were born like that, and we look at ourselves and when
18
you hear the words it's environmental. You think was I not
19
eating enough nuts in the beginning of the first semester?
20
Was I doing something wrong through my pregnancy? Was I not
21
doing something right? Did I make a mistake? No. It's
22
already built within my family, and I personally am stuck at
23
home every single day. I have got this young, beautiful
24
husband, and he's so willing to try.
25
He's amazing because he knows so much more, and I'm
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just pouring it into him because I'm on my way out. I won't
2
see 3- to 5,000 years, but who's to say that kids are not
3
going to be important then? What if we're a society -- if
4
you look at this in the spectrum of what's going on, it feels
5
like when these kids are born in this manner, it's one in 60
6
now. We're going to be nation of people taking care of
7
people with autism because I have counted the people that
8
take care of my kids on an individual basis. There's 15
9
people every day that work for these kids, and I just can't
10
image why -- if a child was dying in a hospital, every 60 of
11
them, there would be an investigation. There would be
12
something going on, but they're alive and healthy and walking
13
around in society, and they're saying get rid of autism
14
speaks. It doesn't speak.
15
It's quiet. The people taking care of them are
16
quiet because we're stuck in the house because I call it
17
glassy glass. Everywhere you go everything is made of glass
18
and they're going to shatter it, and they're going to run.
19
I'm not feeling as well as I used to. I can catch if I need
20
to, and I have saved their lives a couple of times, and I
21
will continue to do that (inaudible). Children in schools
22
and senior citizens with Alzheimer's because they're like
23
little children too (inaudible). We could give free art
24
lessons to kids with autism in special needs units. We
25
created the slogan "don't do that." DDT. What's the first
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thing that we learn when we're born? Don't do that. DDT.
2
Dumping dangerous toxins. The problem here is that the
3
people that need the help most can't help themselves. They
4
don't know how to reach out. They have got POs chasing them
5
down.
6
They have got all these behavioral problems.
7
There's no social (inaudible) with these guys, and it's
8
really not even their fault. This is what I call zombie
9
warfare. We're going to have -- I have seen my kids, and I'm
10
not calling them zombies, but when your kids are born and
11
they're not going to talk, they're just going to walk up and
12
down throughout your house and flapping their hands in the
13
air, moaning. It looks like that and these guys know what's
14
going on, but I'll tell you what's even harder then getting
15
rid of DDT, getting social workers to get off your back and
16
help.
17
All of this matters and these kids are so hard
18
sometimes because I got two. They're opposites. When one is
19
good, the other is bad, but I'll tell you one thing. They're
20
my little angels. The 19-year-old, he is -- he's like a
21
little guy. He's been dummied down at his school because LA
22
Unified is running out, I see see-through walls being put
23
into the bank stuff. You know when you can't touch the
24
banker no more because that acrylic stuff? I see that at
25
school and I'm think this is a really bad South Park joke and
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I ask what that's for and they say it's for security.
2
It says on the top of the door "do not lock during
3
business hours" and they're locking that door. So what is
4
the door there for, and why is it important to have that door
5
there when we need therapy in therapy room environments when
6
they're giving speech lessons in class when everybody else is
7
doing morning circle, they got to go to their desk and try to
8
listen to someone they have never seen before, they're in and
9
out, these employees, they're totally inexperienced. I have
10
been doing this a long time and I talk a lot. Trust. I'm
11
running out of things to say. I'm running out of reasons to
12
make it more possible to show you a day in the life of
13
Marlene because it's really difficult. A lot of people say
14
you should go out more. A lot of people like Jenny McCarthy
15
talk about things like, well, if you see someone with a kid
16
with autism, go and babysit for them. We can't allow that
17
because it's dangerous.
18
We have to be there for safety reasons and when
19
we're warn out, then we have got social workers saying you
20
didn't fill out this paper, you didn't do that right, or
21
they're just not doing what you asked them to do, and you're
22
fighting with the school. You're fighting with the people
23
that you used to encourage. I volunteered for seven to 10
24
years walking these kids from the classroom to the McDonald's
25
down the street in San Pedro off Western, and I, to this day,
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appreciate people that do that. I can't go in the sun. I
2
just came from radiation. I give them $1 lottery tickets,
3
and if they win, maybe I'll see them again on TV or
4
something.
5
The thing is, I think we should appreciate care
6
providers. We're going to deal with the DDT one day in
7
5,000, 10,000 years, or we're going to find something worse I
8
bet, but you know what? Right now we got to deal with this,
9
and they say what do you want, Marlene? I believe I talked
10
to someone from the EPA that called my house, and I said I
11
want to be relocated. Why is the plumage area at the door of
12
the hospital? Because they don't want that kind of a public
13
cry out because everybody gets sent over there. God forbid
14
you should drink water from there or be bathed in it.
15
It's going in our showers. It's in our skin. It's
16
not like we're sitting there -- I have seen footage today,
17
just today, on the little cell phone that my daughter has.
18
1946 was advertising and showing that some expert in
19
toxicology or whatever it was, showing these African tribe
20
men how to spray DDT over their food and eat it, and they
21
were going through towns with big trucks and they were
22
spraying it all over the community with people walking
23
around. So now, the government -- this has totally been
24
federally funded. They have -- they could have done what
25
they wanted to do, and that's what they did.
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What they thought was, we were far away from
2
everybody that was rich, and this was just a bunch of
3
strawberry fields. Yeah. There's 100 foot wells. I know
4
this because in my backyard where I own my home, I was
5
terrified for, like, three months because there was a crack
6
in my backyard, and I went to fill it up with water thinking
7
well, it's just a shift change or a little bit shaking earth.
8
About four hours later the water never filled up. I don't
9
know where it went. I thought we were just going to
10
disappear in the backyard one day. Well, it has filled up.
11
Out of side, out of mind. I still have things to worry
12
about. The guy across the street was building an extra house
13
on his property. He got stopped by 100 (inaudible) the fire
14
department found it. I don't think they filled it up
15
(inaudible).
16
So that brings me to my next point. This thing
17
going on in the street. I have the greatest feeling in my
18
heart because I know sinister people that they created this
19
thing to sidetrack us from going on Normandie, from even
20
going on Normandie. If you try to drive down Normandie right
21
now -- first of all, they're going to have police all over.
22
Second of all, they're going to have trucks in and out, going
23
in and out. They have cones. They have a bunch of --
24
everything blocking it off so that we avoid going that way
25
because we're residents, we know better than that. Guess
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what? I think that's the whole plot, and I also happen to
2
know -- because it goes right across my street in front of my
3
house on Torrance. It sounds like a bomb or a tank has gone
4
off every time these trucks go by.
5
It's rattling. I had a friend spend the night. He
6
came from Louisiana, and you know how they talk. It was
7
like, I can't believe that. I can't believe it, and I did
8
verbatim what you're doing and wrote down everything he had
9
to say, and unfortunately I didn't have a printer to print it
10
out today, but he was like how do you live like this, and
11
he's holding onto his chair and the coffee is rattling and he
12
is saying how do you do that because I have to listen for my
13
kids. I have cameras all over the house. I have got video
14
as well as audio and the amazing thing is we had an incident.
15
We had an incident where they were doing the flushing in the
16
middle of the street, and my husband was doing his business
17
in the bathroom, and I was doing laundry and I was also in
18
the kitchen, you know, doing kitchen things so the water was
19
running. We didn't get forewarning that this was just going
20
to happen. They just went down the middle of the street and
21
starting flushing.
22
Well, my husband comes running out of the bathroom
23
saying I just got a mushroom bomb came up from the toilet.
24
So he was exposed that day to raw sewage, possibly Hepatitis
25
C, definitely DDT. We know that's already in there, but all
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of this raw sewage came up on him. After that, we had a leak
2
in our pipes. So we went outside and we talked about it to
3
the workers. They sent it to the city. The city said they
4
didn't have permission to go there and start digging, but
5
they did it anyway. After two -- and by the way, did I
6
mention I have a terminal brain tumor? I had to use a water
7
bucket to use my water because when we turn the water on, it
8
starts squirting out of the water heater because of the
9
pressure when we turned off the main valve, it caused a
10
little leak in the little water hose there. So there I am,
11
fixed income, social security for my kids. I am working not
12
getting paid, not feeling well, carrying these buckets, and
13
you know what, it made me so mad. I feel a little better.
14
I didn't want to come today because I just got out
15
of the hospital, but I came because I think the real story
16
here is not what happened and pointing fingers. I think it's
17
about the human aspect of this, if I correctly read
18
everybody's faces. The human aspect of it is this is in our
19
DNA. The people of this community have been greatly
20
affected. I always grew up thinking, like, I know all my
21
neighbors, and we love it here. We're not going anywhere.
22
We love it here, but I think we have been contained with
23
circumstances and parole offices and jail cells and no
24
church, liquor stores on every corner. Billboards don't say
25
anything great. They said tequila. They say need a lawyer.
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Things like that. There's no youth functions for them.
2
There's nothing.
3
Even when they come out there and they offer this
4
little health expo, that's ridiculous. They need to get
5
people in there with MRIs. You guys got to really, really
6
dig deep into their DNA to figure out how bad it's going to
7
get for them because even if they tried, they don't have the
8
capacity because of the brain damage because of the people
9
around them that they got to deal with that died. Just last
10
year, I lost two friends to leukemia. The lady sitting back
11
there in the back row, her son almost died a couple of times
12
on her, and I know that Kenwood is the worst. It's the
13
worst.
14
By the way, we should mention that farmers
15
brothers -- I have been around the world a little bit. I
16
have traveled, and I was amazed to see that the coffee that I
17
was getting in Hawaii was from farmers brothers. They're
18
contaminated too. So we're passing it around. It's not just
19
like right here, and everybody stay there and they're letting
20
us die off. Yeah. They're letting us die off, and they're
21
putting us in a situation where we don't see a way out. I
22
was complaining about the pipe problem and guess what they
23
told me? It was my fault, and they didn't do anything wrong.
24
They let it go. That's how Mr. Alejandro right here got my
25
letter, and I guess they have a committee that has to report
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problems, incidents, and stuff. Do you remember that letter?
2
Wasn't it really good?
3
MR. DIAZ: Yes.
4
MS. PUENTES: He says yes. He doesn't know.
5
MR. DIAZ: No. I have read the letter.
6
MS. PUENTES: Yeah. It was kind of rude and wrong,
7
and I was amazed when I tried to talk to these people, they
8
didn't care about me giving them lemonade for, like, three
9
weeks straight. They didn't care about not being able to
10
wash their hands. I have two autistic kids. One of them is
11
walking around flapping all day long and moaning which is
12
cool. It's a community that's inflicted with problems that I
13
think have occurred because brain damage, and he does look
14
like a little gangster, quote on quote, because I cut his
15
hair. He doesn't go to a barber and I have to use the
16
clippers and he's flapping and I call it Chinese gang signs.
17
Sorry about that, but it's real fast. I'm afraid my son is
18
going to get shot out there. I think we should be protecting
19
the community more in training officers to deal with people
20
that have survived DDT poisoning.
21
If it was something else, like (inaudible) disease,
22
they dealt with it. They gave them medical help. They gave
23
them a form. Everyone knows about it that. It was one
24
weekend in a hotel, and it got all these people sick. 2 9
25
people have died from that poisoning right there. I don't
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know how long that I can keep being ignored on phone calls
2
and keep telling my story over and over and over to LA
3
Unified to state workers to just dealing with people that
4
aren't -- I feel as smart as I am, and they're in such high
5
positions and they're not accountable. They're not
6
accountable. As a matter of fact, their secretaries will be
7
rude to you, and they're just administrative assistants,
8
paper pushers. We're doing the actual job. We're raising
9
these victims of this poisoning, and we're being affected by
10
it. I have no social (inaudible).
11
It doesn't take me to go from zero to pissed off in
12
no time flat and that's because I'm fed up. I have asked
13
them time and time again to relocate. They won't fix pipes.
14
We have got bombs going off all day long with these trucks
15
going over this one spot, and I seen the crowd. People
16
waving their hands. It's loud. It is like living in a war
17
zone. So if we got to get used to that already living in
18
California, earthquake and all, we're prepared, but we don't
19
want to be like that all day long with the shaking of our
20
houses. I don't know how long it's going to take before it
21
falls down, you know. We don't have money to fix anything,
22
but I don't think it's about fixing it. I think it's about
23
realizing this is a hazardous waste area. The plumage means
24
that just like with (inaudible), there's a plumage area and
25
everything needs to go in that area. There's no one living
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over there.
2
There's sweeping under the rug of things like this
3
but that seems ridiculous. I'm not moving to (inaudible) and
4
I don't want to live Southern California, but I will if
5
somebody helps me get out of here because I want -- it's not
6
going to help me and my daughter and my son, but it will help
7
somebody else's daughter or maybe somebody else's that
8
doesn't know about this, and they're just going to re-label
9
the neighborhood, like they took the dirt out and put new
10
dirt in it. And they always talk about when they're digging
11
these pipes that it's 100 feet down, and I'm only going 10
12
feet and this and that. It's all over the place. It's all
13
over the place, and it's going to pass state lines which will
14
make it a federal problem. It should already be that way,
15
but it really needs to be handled. I have been to this
16
meeting before just like this and nothing happened. We're
17
being told what they're going to do, ask to give comments,
18
and our comments are ignored.
19
As far as it goes, nobody in this community is
20
really going to get up and try because they feel that there
21
was (inaudible) there was going to be a soccer field put
22
there a few years ago, but they were actually bated along to
23
believe that there was going to be a soccer field there.
24
That's ridiculous. That was never on the table, but they
25
wasted years on that project. They made them believe that it
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was okay. That was smoke and mirrors, and right now we need
2
to get to the situation of what are we going to do for the
3
people in the community? How are we going to get them out
4
there? How are we going to make them accountable with the
5
relocation process and put a big fence around this area and
6
make people drive around it? Get guards to guard it. Don't
7
let people in here. There's not going to be a soccer field
8
there. There is not going to be houses here in 100 years if
9
anybody does anything right. So that's how I feel about it.
10
I wish I was more prepared. Sorry I was late. I
11
don't feel well, but I want people to start looking at the
12
human aspect of this, and my shirt says DDT. Don't do that.
13
Dumping dangerous toxins. Stop that. I don't know what to
14
say except for I want to be relocated, and that's the only
15
thing I want to hear about, and I don't want to move
16
someplace where it's vaporized and then it moves over there
17
like acid rain. What comes up -- what goes up, must come
18
down. So I don't want to be any further in the hole than I
19
already am with nowhere to go. All right. Thank you.
20
Sorry.
21
MR. DIAZ: Thank you. So thanks, Marlene. We'll go
22
ahead and go with the next person. Go ahead.
23
MR. FERNANDO: My name is Philip Fernando. I live
24
on 20512 Bernando Avenue, Torrance, 90502. I will listen to
25
my neighbor, who like me, has been here for about 3 0 or 4 0
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years. I would like to put this on the record. The
2
community here is greatly affected by the contamination. So
3
whatever remedial action has been done so far we appreciate.
4
However, in view of the 3,000 year span that is being talked
5
about all the time, it is imperative that a plan to relocate
6
the residents of the area should get top priority. As just
7
said by my previous speaker, the previous speaker, my
8
neighbor.
9
That plan should be a part of the over all action
10
plan. I think it has to be taken seriously because of the
11
human factor. How the people are affected, how the kids are
12
affected, the number of cases that is going to rise in time
13
to come. The kids with autism and cancer and so on. So
14
that's my main concern that we incorporate the cost, a
15
realistic cost, of relocation as a part of this plan. Thank
16
you.
17
MR. DIAZ: Thank you very much. Is there anybody
18
else who would like to come up and make comments?
19
MS. C. MEDINA: My name is Cynthia Medina. Okay.
20
I'd like to make a comment for my mother, Lydia Valdez, who
21
is just not able to come up here. I'm going to read it. "So
22
I have lived in my home for about 2 7 years on Kenwood Avenue.
23
When I learned about all the contamination and the cleanups
24
that were going on and being removed from my home for a
25
period of time when they did the clean up on Kenwood Avenue,
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it makes me wonder about all the money being spent by a
2
government that doesn't have any money, and they can spend
3
millions of dollars on a cleanup when you can clean and
4
remove the most important thing, the people for much less.
5
Think about it. If you are spending -- spending, sure. I
6
can sell my house and move, but I can't do that and put
7
another family in danger by being exposed to chemicals that
8
will never be guaranteed clean and safe to live in." Thank
9
you.
10
MR. DIAZ: The next --
11
MS. PUENTES: I just have one last thing to say.
12
When I was 18, I worked for (inaudible) real estate and they
13
were a prominent company that was located in Manhattan Beach.
14
We have a lot of properties. Anyway, when we joined up
15
forces with an international company, one of the owners of
16
Honda, we had (inaudible) we built country clubs, and when we
17
went through the planning (inaudible) and we did things like
18
that, we also had relocation for wild life. That means the
19
rats, the squirrels, the birds, the mountain lions,
20
everything in the country club area as we were building it,
21
but we don't have a relocation program for human beings that
22
are being affected in this community, and that's what I just
23
wanted to say because it was my job to work with wildlife
24
people to relocate rats and squirrels and I don't like rats
25
or squirrels, but we sure did what we had to do. That's all
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I wanted to say. Thank you.
2
MR. DIAZ: Thank you. Is there anyone else who
3
would like to --
4
MS. MANNING: My name is Margaret Manning, and I'm a
5
resident. I will be brief. I think the big picture here is
6
that it's been 15 years since the TI waiver zone was approved
7
by the APA and that we -- it has already been stated by
8
Cynthia and Florence that it needs to be revisited. In the
9
15 years, a lot of things have happened as we are now aware
10
of chemicals, the potential for vapor intrusion, and as
11
Florence said that these chemicals can interact and this is
12
all mingling under our feet and our homes. I have got a very
13
strange smell in the middle of my house. So I have
14
volunteered to be one of the very first people for soil vapor
15
intrusion which I hope will start soon.
16
I had a plumber under the house to make sure there
17
was no leaks and no dead animals, but every morning when I
18
get up, I can smell that smell. I think one of the things
19
that we need to recognize about why this area hasn't received
20
the attention that it should, it's unincorporated. If it was
21
Torrance, it would have the city all over it. People
22
wouldn't be able to sell homes to unsuspecting buyers and get
23
away with it. They wouldn't be able to build things in this
24
neighborhood, and it certainly didn't happen in a place like
25
Malibu or Beverly Hills. This has been a working class
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neighborhood for all of its life, and it's an orphan. I
2
looked at the services provided by the LA County, and there's
3
a public health webpage and it's got an environmental place
4
where you can look at and it doesn't even talk about any of
5
the stuff that we have got.
6
It talks about lead and educating your kids on lead.
7
So who do we -- and we don't have any politicians here today.
8
Somebody just got elected in area 66, which I believe is the
9
assembly district here. If it's not, then it's in between 66
10
and 64. We should have somebody here, a brand-new guy or
11
else it's Gibson from the other side of 64. Why aren't they
12
here? It should be -- if this was on the Torrance side of
13
Western Avenue, you bet they would know about it, and I think
14
that this is the big picture that we should be looking at. I
15
think we are probably spinning our wheels here right now
16
dealing with individual problems, soil vapor, DNAPL, PC,
17
whatever it is, BS or something. These are all new things
18
popping out. Although the DNAPL seems like it's been a
19
(inaudible) for a while. So this is a human issue, yes, but
20
I think that in the end, that TI waiver gave a lot of the,
21
quote, responsible parties a free pass.
22
That was the war. That battle and war has been
23
fought and won. So we're all here having these discussions
24
on a regular basis, and we don't seem to be making much
25
progress at all and in the end everybody getting tired and
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worn out. To me, 20 million is not a lot of money. I mean,
2
I'd like to have it personally, but that is not a lot of
3
money for this cleanup with the rods heated in the ground.
4
That is a very small amount. I mean, you could buy a couple
5
of apartment buildings in Hawthorn for that kind of money
6
because I know, but we should be looking at the big picture
7
and go back and revisit the TI waiver because we have so much
8
more information in 15 years, and this is -- this isn't even
9
going to start if we did approve and go along with these rods
10
in the ground. It's still not going to start for a couple
11
more years. So that's what I have to say. Thank you.
12
MR. DIAZ: Thank you very much. Is there any other
13
person who would like to speak? Anybody else before this
14
gentleman here or anyone want to clarify a comment?
15
MS. BABICH: You know, it just really -- well, I
16
would say it breaks my heart to hear the stories from the
17
community, but my heart was broken a long time ago, and the
18
Del Amo action committee and myself -- I don't mind spending
19
the rest of my life probably maybe another 20 years sitting
20
around and trying to help figure out the best way to clean up
21
the messes that were made by the polluters. But I really do
22
mind that the community is being treated like a guinea pig
23
and it's wrong. We were able to get 65 homes relocated where
24
the park is going to be, and we're not saying that we want
25
the EPA to come in and relocate people because what will
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happen is they will use a way called imminent domain where
2
you won't get full value for your home and you won't be able
3
to relocate to another, like, area without the contamination,
4
but we do have the plan that we worked out with the
5
responsibility party.
6
It was a private buy out. It was not ordered by
7
court. It was because our congresswomen at the time, Jane
8
Harmon, thought that there was some common ground between the
9
community's needs and the responsible parties, and she
10
insisted that we all go in a room and try to figure this out
11
and we did and it's been the best relocation in the country.
12
And at the time when only half of 204 Street was offered a
13
relocation and that's not to say that we thought that the
14
contamination was confined to that area, but even way back
15
15, 23 years ago, we knew that that was a ground zero and
16
there was a meeting where Montrose would not come to the
17
table and negotiate and the homeowner's that were left behind
18
on 204 Street graciously stepped back so that the other
19
portion of 2 04 Street could be relocated and the commitment
20
that (inaudible) made at that time that we still hold to us
21
is to get the rest of our community up and out of there.
22
So I know we have responsible party representatives
23
here today, and I know that I'm not always as nice as I
24
should probably be like my grandmother taught me to be, but I
25
am indeed very angry. Unfortunately since I don't have maybe
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the ground (inaudible) as Montrose to poke in the eye, I
2
continue to attack their consultants and maybe that's a harsh
3
word. I don't really attack them, but I am very stern with
4
our messages. And again, I give you another message to take
5
back to the person who ensures that you have a paycheck
6
coming in and that you have hopefully a good retirement and
7
that you can provide and care for your family in the way that
8
we all try to provide in our families and come to the table
9
and do the right thing.
10
The land use for this area is not appropriate for
11
people but it's certainly appropriate for trucks. It's not
12
like we have this area that needs to be written off as
13
unusable, and certainly if, I guess, we had more time and
14
capacity, we could pull all the resources of all the
15
residents and we could probably finance our own relocation.
16
We could all probably get pretty rich when we sell it to the
17
goods movement folks to move goods from the (inaudible), but
18
that's not what we're asking. We have lives and we struggle
19
with our lives and we struggle to make a difference, and I
20
really appreciate Marlene. I have heard her speak twice at a
21
similar meeting, and thankfully at this meeting she was not
22
told this is not the place for her to make her comments like
23
she was before.
24
MS. PUENTES: That was before I was diagnosed.
25
MS. MANNING: And I'm so sorry, Marlene. So we have
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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an opportunity to be compassionate and be part of the human
2
race and do the right thing, and so please take that message
3
back to whomever makes the decisions for the Montrose
4
chemical corporation, and we will reach out to (inaudible)
5
but you can't leave people as genie pigs as I have said
6
before on top of this. We have new people who have testified
7
today that they had no knowledge of this and they are recent
8
home owners in the committee. That's not right, and you have
9
Lydia who has lived here for 40-plus years who doesn't want
10
to sell her property because she knows the cycle that's going
11
on. So we have got a very complicated cleanup problem in
12
front of us and, you know, maybe electrical resistance
13
heating is a good idea if there aren't people living around
14
it, but we're going to have to stop and oppose things that
15
are going to further put our community in danger.
16
So there's a real opportunity, and we are handing
17
out the green leaf as we always do, but to really try and
18
figure out a way so that people can move on and the people
19
who have chosen to do as a profession, cleaning up toxic
20
waste, can get on with what they like to do. But we really
21
need to do something, and I can only tell you that we're
22
being very polite now, but it's only going to get worse as
23
the desperation sets in. People are really understanding
24
what's going on now that these pipelines have gone in. It's
25
really touching home. It's not just something that's going
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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on over there.
2
People have waited for a park to come in, and a lot
3
of people want to know why in the world we would put a park
4
so close to a toxic waste site, but on the other hand
5
generations are growing up and having their own families with
6
no place for their children to be that safe. So we are
7
moving forward with the park area, and we hope to have a
8
meeting with the community in the next couple months to tell
9
them where we are with the plans, but really we don't need to
10
be there. So, you know, arguing is going to come down the
11
road, but it would really be nice.
12
I used to have brown hair when I started doing this
13
work. I'm very proud of my gray hair. I worked really hard
14
for it, but it's only going to get -- we're only going to get
15
more (inaudible) in our positions if we don't find a way to
16
come forward. So I would -- I'll leave you with that today,
17
and I appreciate the compassion and respect that you have
18
shown to people in the community. It's very hard to come
19
here over and over again when you feel like you're not being
20
heard. So please hear us today. Thank you.
21
MR. SATTLER: Good day. My name Alfred Sattler. I
22
am speaking just for myself at this point. I may be
23
associated with formal comments later on. Okay. Just for
24
you who don't know me, I am chair of the Sierra Club, but I
25
am not speaking -- as I said, I am speaking for myself at
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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this point. To a certain extent, I have more questions than
2
answers. My understanding is that this DNAPL cleanup that's
3
being proposed is just to give the biggest lump -- biggest
4
amount of the Chlorobenzene contamination out so that it
5
doesn't continue contaminating the rest of the groundwater
6
that's present; is that correct? Can we have a -- is it
7
possible to do it -- I'm just supposed to talk.
8
Okay. An alternative 6A seems like it will get the
9
biggest amount of DNAPL per dollar, but 6B gets a greater
10
amount of DNAPL out. So I think that 6B should be further
11
considered to avoid having further lingering problems there.
12
As for impact on residents living in the area, I think that
13
there should be continual monitoring of the residents of the
14
air that they are breathing, and if there's shown to be
15
contamination as a result of this process, the residents
16
should be evacuated and the process should be stopped.
17
As a separate note, as I was -- you know, just
18
October 24th, science magazine had a very interesting article
19
about biologic (inaudible) and some recent research where
20
they have found more fundamental information about the
21
structures in the microbes that makes this possible and that
22
is why I ask whether bioremediation had been considered.
23
(inaudible) told me today that the DNAPL itself is too
24
concentrated for the microbes to work on it. Once the DNAPL
25
is removed, the concentrations may be low enough to
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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bioremediate, and that should be strongly considered as a
2
follow on so that we are not hopefully faced with 3,000 years
3
of lingering contamination.
4
Somebody should be making grants to biological,
5
biochemical researchers to see if they can find some bacteria
6
that can biodegrade these chemicals and make sure the
7
biodegradation compounds are also benign or not themselves
8
toxic. (inaudible) and the comment was made that DDT is not
9
biodegradable. That may be well old information on the --
10
where it went out through the pipe, there is some evidence
11
that there is now a (inaudible) of the DDT in the (inaudible)
12
there. It's been a long time coming, but there seems to be
13
some compounds there, and again, I don't even know whether
14
those are better or worse than DDT at this point, but I do
15
know that ongoing research is going -- is happening on that
16
so I definitely want to correct that point about DDT not
17
being biodegradable.
18
This is just dealing with the big lump of really
19
concentrated stuff that's down under there. It's not -- as I
20
understand, once the biggest amount of stuff is removed from
21
down there at least, presumedly things will start getting
22
better, but my gosh. The local residents have suffered so
23
much. If there could be someway to buy them out and move
24
them, that is somebody to strongly consider.
25
MR. DIAZ: Thank you, all. Is there anyone else
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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that would like to formally make any comments? If not, we'll
2
be closing the meeting. Going once? Going twice?
3
MS. PUENTES: My husband and I would like anybody
4
that wants to put a sign in front of their house, there's a
5
couple of signs that I thought might be illegal. We might
6
need some legal advice on it, but I would just like you guys
7
to know you can come to my house at 1072 West Torrance
8
Boulevard. You guys can pick up some canvasses. We have
9
many that are bigger than me so we could just make it loud
10
and clear. Every time I put a sign up somewhere, somebody
11
comes along and takes it because it's really pretty or
12
whatever and some are not done as well as others.
13
I will donate to anybody who wants to put a sign in
14
front of their house, any type of thing that they want on a
15
canvass or a weather proofed item. It's going to be a long
16
time, but we need to start verbalizing with words that people
17
can read and say what are these signs everywhere. I live on
18
Torrance Boulevard. I flip them around when the traffic is
19
coming in off the 110, and I flip them the other way in the
20
afternoon when they're going out so that they don't miss my
21
message. I'll try to make them more legible but yeah. DDT.
22
Don't do that. Dumping dangerous toxins. That's it.
23
MR. DIAZ: Thank you, Marlene. So yes. Would you
24
like to come, Savanna? Great.
25
MS. S. MEDINA: My name is Savanna Medina. I am 17
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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years old. I was born in this community on 20501 on Kenwood
2
Avenue. My family, my uncle at the age of nine was diagnosed
3
with diabetes. My mom as arthritis. At the age of 19, my
4
other uncle has allergies and bone pain off and on. We need
5
you guys to do something about this. Move us out, please.
6
MR. DIAZ: Thank you, Savanna. At this time, any
7
last calls of anybody? Okay. Going once? Going twice? So
8
as a reminder, if you go to the last slide, there's -- this
9
slide, there's some contact information that's not too late
10
obviously to submit comments, and there's all these different
11
ways that you can do so. So please do, and if we have any
12
updates you'll be hearing from us in terms of this
13
proposed plan. Yes?
14
UNIDENTIFIED SPEAKER: You can send in, you know,
15
two or three times, 20 times, 100 times, you know, go to your
16
neighbors and, you know, give them the information and have
17
them send something in. It all helps.
18
MS. MARTINEZ: Thanks for everybody who came here.
19
I've been listening, and I don't want you to think that
20
because I had to go to the restroom real quick that I was not
21
listening to everybody who spoke. I am pretty available.
22
The only request that I make is if you're going to give me a
23
comment, please state it. I will be around doing hopefully
24
door-to-door soon. Let me know if this is my comment, and I
25
can take -- you can tell me. I'm write it. I'll make sure
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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to write it as you want to say it, and that's another way you
2
can provide comments.
3
MR. DIAZ: Great. Thank you, Yarissa, for
4
clarifying that. If there's anything else that needs to be
5
clarified, we can have informal conversations after the
6
meeting, but at this time, the meeting is now adjourned, and
7
thank you again.
8
(At 12:38 p.m. the meeting was concluded.)
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
1
STATE OF CALIFORNIA )
) SS.
2
o
COUNTY OF LOS ANGELES )
O
4
I, BRITTANY SILVA, CSR No. 13 940, do hereby certify:
5
That said public meeting was taken before me at the
6
time and place therein set forth and was taken down by me in
7
shorthand and thereafter was transcribed into typewriting
8
under my direction and supervision, and I hereby certify the
9
foregoing transcript is a full, true and correct transcript
10
of my shorthand notes so taken.
11
I further certify that I am neither counsel for nor
12
related to any party to said action, nor in any way
13
interested in the outcome thereof.
14
IN WITNESS WHEREOF, I have hereunto subscribed my
15
name this 24th day of November, 2014.
16
17
18
19
20
21
BRITTANY SILVA, CSR #13 940
22
23
24
25
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
WORD INDEX
20430 35:4
90s 11:;2
afternoon 61:20
APA 52:7
20501 62:1
94105 2:7
age 62:2, 3
apart 25:19
A
va
V
20512 49:24
972-3242 2:7
agencies 21:21
apartment 54:5
$1 41:2
23 3:5 23:8,18
Agency 2:2 4:8
APPEARANCES
55:15
< A>
9:3
2:1
<1>
24 36:23
a.m 4:2
agenda 5:19
applied 14:16
10 5:23 12:21
24th 59:18 64:15
ability 16:16
agent 36:23
11:14
19:15 22:13
25 17:<5 19:14
able 1:15 13:7
aggressive 31:4
applies 15:;8
40:23 48:ii
27 50:22
15:14 23:22,25
ago 23:8 24:8
apply 15:9
10,000 41:7
29 3:6 46:24
46:9 50:21 52:22,
25:9,12, 20 26:25
appreciate 5:24
10:32 4:2
23 54:23 55:2
21:5 36:25 48:22
35:25 41:1,5
100 42:3,13
< 3 >
Absolutely 24:12
54J7 55:15
50:3 56:20 58:17
48:;; 49:8 62:15
3 28:7 36:9 38:2
abundant 35:9
agreed 5:4
approach 1:1, 8
101.5 12:22
3,000 25:8,23
academic 32:9
ahead 7:9 22:21,
31:5 32:11
105 31:2;
50:4 60:2
accept 29:25
25 23:1,4 49:22,
approached 23:2
1072 35:3 61:7
30 49:25
acceptable 31:<5
22
appropriate 23:16
110 61:19
35 3:7
accountability
aid 36:9
56:10,11
12 35:14
24:;;, 12,19, 21,
air 14:4 39:13
approve 54:9
12:38 63:8
< 4 >
22,24 26:23
59:14
approved 52:6
13 35:15
4 3:3
accountable 24:; 7
ALEJANDRO 2:6
approximately
13940 64:4,21
40 49:25
41:5,6 49:4
4:7 1:18 11:22
8:;7 9:15
13th 6:17,21
40-plus 57:9
accurately 6:24
45:24
archive 10:;;
11:23,25 23:12
40s 8:15
achieve 32:4
Alfred 2:17 58:2;
area 6:3 10:8,10,
1460 2:4
415 2:7
Acid 9:10,11
alive 38:12
19 11:8 12:4
15 25:9,12 26:25
49 3:8
33:12,14 49:17
allergies 62:4
13:1,2,13 15:2, 2
21:5,13 38:8
acrylic 39:24
allow 40.16
16:4, 6, 7 11:3
52:6,9 54:8 55:15
< 5 >
act 13:5
alternative 15 :;3,
18:15 22:1, 6,14
160,000 31:2;
5,000 25:8,23
action 15:14 23:7,
16,21,23,25 16:2,
25:11 30:25 31:;,
17 61:25
28:8 30:; 36:10
7 26:14,14 30:17
5,12, 16, 24 59:8
21 32:2 41:11
18 51:;2
38:2 41:7
50:3,9 54:18
alternatives 16:9
41:23,24,25 49:5
19 35:15 62:3
51 3:7,9
64:12
18:9
50:6 51:20 52:19
1946 41:;8
52 3:10
actions 13 :;5,18,
Alzheimer's 38:22
53:8 55:3,14
1950s 9:18
54 3:5
24
amazed 45:16
56:10,12 58:7
1960s 10:8
58 3:11
active 8:15 11:17
46:7
59:12
1970s 9:20
13:24 14:14
amazing 36.16
areas 10:;<5 12:25
19800 1:15
< 6 >
activities 7:22
31:25 43:14
11:14 31:25
1980s 11:;;
60 31:10 38:5,10
8:23 9:6 15:20
America 33:8
argue 25:3, 5
1982 10:;2
600 2:4
22:14
Amo 11:;3, 22, 23,
28:15
1985 10:;3
60s 9:18
actual 17:8 47:8
24 14:7 23:<5, 7,
arguing 58:10
1989 8:25
61 3:12
AD 31:12
10 26:9 29:18,20
art 38:23
1999 11:14 26:25
64 53:10,11
add 12:25
30:17 31:12 54:18
arthritis 62:3
36:13,19
65 54:23
addition 6:21
amount 54:4 59:4,
article 59:18
19-year-old 39:20
66 53:8, 9
18:;
9,10 60:20
asked 23:14
6A 59:8
additional 10:8
Angela 28:13
25:20 26:15 21:9
< 2 >
6B 59:9,10
address 9:1 11:16
36:15
40:21 41:12
20 17:<5 19:14,15
13:7 14:;5
Angeles 2:4 64:2
asking 56:18
20:13 54:1,19
< 7 >
addresses 16:;9
angels 39:20
aspect 44:17,18
62:15
7 3:4 8:15
30:24
angry 55:25
49:12
200 12:19
75 2:6
adjourned 63:6
animals 10:4
aspergers 31:11
2011 30:4
administrative
52:17
asphalt 10:14
2012 30:5
< 8 >
15:;7 47:7
announced 6:17
assembly 53:9
2013 30:9
8 1:14 4:1
adverse 16:2;
answer 26:19, 21
asset 24:4
2014 1:14 4:1
80 8:17
advertising 41:18
29:4
assistants 47:7
30:10 64:15
800 37:9
advice 61 :<5
answers 59:2
associated 58:23
2015 6:17,21
80s 8:15 30:13
advisor 4:24
anybody 1:15
attached 14:3
11:18,19,20 23:12
30:22 31:19 32:16
18:7,10 26:10
attaches 9:20
2016 11:21
< 9 >
advisors 28:6
49:9 50:17 54:13
attack 56:2, 3
2018 11:21
9 2:3
32:12
61:3,13 62:7
attention 52:20
204 35:6 55:12,
90017 2:4
afraid 46:; 7
Anyway 20:7
audio 43:14
18,19
90502 49:24
African 41:;9
44:5 51:14
aunt 35:11
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
autism 36:12, 22
believed 31:4
brain 35:77
care 38:<5, 8, 75
city 44:3, 3 52:27
31:7,10,14 38:7,
benign 60:7
36:77 44:<5 45:8
41:5 46:8,9 56:7
clarified 63:5
13,24 40:16 50:13
Benzene 11:24
46:73
careful 34:5, 22
clarify 19:6 21:77
autistic 35:14
22:77
brand-new 53:70
carrying 9:79
22:79 54:74
46:10
Bernando 49:24
breaking 9:27
44:72
clarifying 6:2, 3
available 5:17
best 27:7 32:5
breaks 5:3 54:16
case 5:73 15:79
18:8 20:22 21:8
21:5 32:23 34:17
36:20 54:20 55:11
breathing 59:74
cases 50:72
63:4
62:21
bet 41:8 53:73
brief 52:5
Catalina 35:4
class 40:6 52:25
AVENUE 1:15
better 21:19
bright 25:7(5
catalyst 9:77
classroom 40:24
49:24 50:22,25
32:10 42:25
brings 42:16
catch 38:79
clean 10:25 17:22
53:13 62:2
44:13 60:74,22
BRITTANY 64:4,
cause 31:22 34:16
19:75, 77, 18,24
average 29:6
Beverly 52:25
27
caused 7:22
20:4, 8,13, 25
avoid 42:24 59:11
big 9:16 24:73
broken 54:77
31:77 33:25
21:20 22:24 25:7,
aware 52:9
31:72, 78 32:22
brothers 45:75, 77
34:74, 74 44:9
13 26:76 29:23,
34:9 36:9 37:2
brown 58:72
cell 5:78 41:77
23,23 30:8 34:4
< B >
41:27 49:5 52:5
brutalized 35:79
cells 44:23
50:25 51:3, 8
Babich 2:11 3:5
53:14 54:6 60:78
BS 53:77
central 10:9
54:20
23:3,5,6 54:15
bigger 36:9 31:6
bucket 44:7
certain 59:7
cleaned 20:74
baby 36:20,20
61:9
buckets 44:72
certainly 52:24
27:6 32:3
babysit 40:16
biggest 36:2 59:3,
Budlong 35:5
56:77, 73
cleaning 10:23
back 5:17 21:4
3,9 60:20
build 52:23
certify 64:4,8,11
25:77 31:72 57:79
23:18 28:1 36:16
Billboards 44:24
building 42:72
chain 10:4
cleanup 51:3
39:15 45:10,11
billion 31:22
51:20
chair 30:77 43:77
54:3 57:77 59:2
54:7 55:14,18
bioaccumulates
buildings 54:5
58:24
cleanups 50:23
56:5 51:3
10:3
built 10:77 37:22
chance 5:72
clear 6:4 18:8
background 8:13
biochemical 60:5
51:7(5
change 42:7
20:25 27:76
backpack 31:5
biodegradable
bunch 42:2,23
changes 26:7 <5
31:25 61:70
backyard 29:3
18:79 60:9, 77
burned 29:2
characteristics 8:9
clearly 24:20
42:4, 6,10
biodegradation
bus 31:6
10:2
30:23
bacteria 18:7(5
60:7
business 40:3
charts 33:2
clippers 46:76
60:5
biodegrade 60:6
43:7(5
chasing 39:4
close 23:23 58:4
bad 39:19,25
biodegraded 18:78
busses 35:20
chemical 22:77
closer 23:73
45:6
biologic 59:79
buy 54:4 55:6
33:7,25 35:7, 70
closing 61:2
band 36:9
biological 60:4
60:23
57:4
club 51:20 58:24
bank 39:23
bio remediate 60:7
buyers 52:22
chemicals 8:72
clubs 51:76
banker 39:24
bioremediation
9:7 14:79,20
coffee 5:76 43:77
banned 9:19
13:70 18:72, 73
32:2 34:13,20
45:76
barber 46:15
59:22
CALIFORNIA
51:7 52:70,77
collect 14:17,25
basic 1:21
birds 51:79
1:16 2:4, 7 4:1,
60:6
15:70
basically 13:25
bit 1:10 10:20
16 11:7 47:78
chemistry 9:5
collected 14:27
15:8 17:7
11:77 13:77 17:8
48:4 64:7
child 35:70 38:70
Colorado 29:7
basin 34:5
18:70 22:4 24:75
call 16:6 24:9
children 25:25
35:7, 8
basis 38:8 53:24
33:7 42:7 45:75
29:79, 79, 20
26:7 35:72, 74
combined 34:79
bated 48:22
blob 12:7
38:76 39:8 46:16
36:24 38:27,23
come 6:6,25
bathed 41:14
block 24:73
called 14:23 15:5
58:6
20:78 23:77
bathroom 43:77,
blocking 42:24
25:27 33:7,9
children's 26:7, 7
26:79 27:73 28:2,
22
blow 28:23
37:72 41:70 55:7
Chinese 46:76
76 32:70, 73
battle 53:22
blue 12:7,2, 4, 25
calling 22:22
Chloral 9:9
44:74 45:3 49:77
Beach 51:73
Blvd 2:4
39:70
Chlorobenzene
50:73, 78, 27
bear 8:2
board 30:9 32:8
calls 47:7 62:7
9:70, 73, 76, 23, 23
54:25 55:76 56:8
beautiful 36:21
body 10:4, 6
cameras 43:73
10:7 12:7 18:75,
58:2, 70, 76, 78
31:23
bomb 43:3,23
cancer 50:73
76, 78 22:2, 3, 70
61:7, 24
beginning 31:7,19
bombs 47:74
canvass 61:75
33:3 34:75 59:4
comes 12:2 31:74
behavioral 39:6
bone 62:4
canvasses 61:8
choose 17:77
43:22 49:77 61:77
beings 51:27
borings 12:20
capacity 45:8
chosen 17:3 57:79
coming 4:5 6:78
belief 31:77
born 35:70, 77
56:74
church 44:24
23:6 56:6 60:72
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Huntington Court Reporters & Transcription, Inc. 2
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
-------
EPA PUBLIC MEETING, NOVEMBER 8, 2 014
20-.18,20 23:11,
composed 9:75
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Huntington Court Reporters & Transcription, Inc. 3
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
-------
EPA PUBLIC MEETING, NOVEMBER 8, 2 014
displacement
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Huntington Court Reporters & Transcription, Inc. 4
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
-------
EPA PUBLIC MEETING, NOVEMBER 8, 2 014
fraction 31:7,8
45:24 46:75
greater 21:79
happening 36:70
holds 12:74
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Huntington Court Reporters & Transcription, Inc. 5
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
-------
EPA PUBLIC MEETING, NOVEMBER 8, 2 014
27:25 31:20
input 23:27
19:6,12,19 20:11
leukemia 45:70
looked 10:2 13:8,
impacting 23:9
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Huntington Court Reporters & Transcription, Inc. 6
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
-------
EPA PUBLIC MEETING, NOVEMBER 8, 2 014
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Huntington Court Reporters & Transcription, Inc. 7
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
-------
EPA PUBLIC MEETING, NOVEMBER 8, 2 014
people's 24:7
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Huntington Court Reporters & Transcription, Inc. 8
301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988
-------
EPA PUBLIC MEETING, NOVEMBER 8, 2 014
relocate 47:73
researchers 60:5
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Huntington Court Reporters & Transcription, Inc. 9
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
somebody 24:5, 7
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27:73 29:70
Huntington Court Reporters & Transcription, Inc. 10
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EPA PUBLIC MEETING, NOVEMBER 8, 2 014
34:24 41:16,17
48:20 55:70 56:8
33:4 44:6, 7
47:79 48:4, 5
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Huntington Court Reporters & Transcription, Inc. 11
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worry 25:24
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Huntington Court Reporters & Transcription, Inc. 12
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APPENDIX C WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
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-------
that there could be options available to us today that were not back then. Had the treatment plant
been built soon after the ROD was signed we would have undergone three five-year reviews
which I believe would have had a component to them to revisit current technology practices to
see if the treatment system was doing the best it can.
The concerns we have raised here and that we have repeatedly stated verbally are why we remain
terrified that impacts to our health, which we believe are due in some part to the exposure and
combined effects of these chemicals, in our groundwater, soil, air, homegrown produce, chicken
and eggs will increase. The community is not as healthy and vibrant as it should be. The Del
Amo Acton Committee was formed by community residents in response to the diminished health
conditions we observed back in 1993 and we have dedicated the past 23 years to make our
community a healthier place to live, work and play. A vision many of us believe may not be
attainable for our community which is living at ground zero, we deserve better. Relocation is a
serious goal for us. A plan to contain contamination under our homes over the next 5,000 years
is not an option we can support.
A holistic approach that pulls all the operable units back together so we can look at the whole
picture and not the piece meal approach which is overly complicated and hard to grasp needs to
be developed. Until this time the pieces as proposed, like the DNAPL proposed plan, are
fragmented and overwhelming to those that will be most impacted by the decisions made
yesterday and today, the residents of this community.
Our technical advisor, Markus Niebanck, has reviewed EPA documents for this piece of the
puzzle and has made several comments which we are including here:
1. The technical advisor recommends that EPA more clearly state that the groundwater remedy
selected to contain DNAPL outside the focused treatment areas is estimated to take over 3,000
years at this site.
2. The advisor recommends that EPA state clearly that the proposed remedy will not remove the
residual DNAPL trapped between soil particles, or the DNAPL located outside the "focused
treatment area."
3. The advisor recommends that the Proposed Plan reference all California agencies, including
the Water Replenishment District, that have been engage in the Proposed Plan preparation to
assure stakeholders that relevant agencies have been given an opportunity to participate in this
important process.
Just doing anything is not the same as doing something. Precious lives are living on top the toxic
soup created by the Montrose Chemical responsible parties. We are not safe living here and are
scared things will get worse if "heated up".
Cynthia Babich Cynthia Medina
Director, Del Amo Action Committee Assistant Director, Del Amo Acton Committee
Florence Gharibian
Chair of the Del Amo Action Committee Board of Directors
-------
Montrose Chemical Corporation of California
mccc@montrosechemical.com
February 13,2015
U.S. Environmental Protection Agency
ATTN; Yarissa Martinez
600 Wilshire Blvd., Suite 1460
Los Angeles, CA 90017
Re: Comments on DNAPL Proposed Cleanup Plan
Dear Ms, Martinez:
Montrose Chemical Corporation of California ("Montrose") is pleased to provide these
comments on the U.S. Environmental Protection Agency's ("EPA") Dense Non-Aqueous Phase
Liquid ("DNAPL") Proposed Cleanup PI an. Montrose appreciates EPA's efforts in developing
the DNAPL Proposed Cleanup Plan, and supports the Plan along with EPA's preferred
alternative, Alternative 6A (Electrical Resistance Heating in a Focused Treatment Area).
The National Contingency Plan requires EPA to select remedies based on overall
protection of human health and the environment, and compliance with Applicable and Relevant
or Appropriate Requirements. Remedies that satisfy these threshold criteria are evaluated based
on the following factors: long-term effectiveness; reduction of toxicity, mobility, or volume;
short-term effectiveness; implementability; and cost.
Montrose believes that the only technologies that satisfy these threshold criteria are
focused electrical resistance heating ("ERH") and hydraulic displacement. Both would be highly
effective at removing DNAPL and preventing migration, protective of the environment and the
community, and more easily implemented than other technologies. Although Montrose believes
that hydraulic displacement is the best remedy for this site, focused ERH is a reasonable
alternative that meets NCP criteria.
By contrast, steam injection, such as described in Alternatives 5 A and 5B, would create
significant risks by promoting DNAPL mobility through increased saturation. Montrose believes
that there is greater potential for downward migration of DNAPL with steam as compared to the
other remedial alternatives. Furthermore, the extreme temperatures produced by steam injection
create risks of fugitive emissions and explosions. Steam injection also involves significantly
higher greenhouse gas emissions and implementation costs than hydraulic displacement.
Full-scale ERH treatment (as opposed to the focused ERH treatment preferred by EPA)
would pose somewhat diminished safety risks compared to steam injection, but would still
require enormous amounts of energy, contributing to excessive emissions and operating costs.
600Ericksen Ave. Nil ~Suite380~ BainbridgeIsland »WA* 98110* Phone206-780-9840~ Fax206-780-2109
SDM558769.7
-------
Montrose, however, believes that the Preferred Alternative avoids the majority of the
drawbacks common to steam injection and full-scale ERII. As such, and because Alternative 6A
reasonably balances the remedy selection factors established by the National Contingency Plan,
as discussed in detail in the attachment, Montrose supports the selection of Alternative 6A as the
preferred DNAPL remedy at the Montrose site.
600 Erieksen Ave. NE ~ Suite 380 ~ Bainbridge Island ~ WA ~ 98110 ~ Phone 206-780-9840 ~ Fax 206-780-2109
SD\1558769.7
Sincerely,
President
Encl.
-------
Attachment I: Montrose Comments on DNAPL Proposed Plan
Montrose Chemical Superfund Site
Executive Summary
Montrose Chemical Corporation of California ("Montrose") supports a remedy for remediation of Dense Nonaqueous Phase Liquid ("DNAPL")
at the Montrose Superfund Site ("Site") that is green, effective, safe, cost-effective, and that provides the best balance among the National
Contingency Plan ("NCP") factors for remedy selection.
Of all the potential remedies for the Site, Hydraulic Displacement
provides the best balance among the NCP factors and is effective at
eliminating risks to human health and the environment in a reliable and
cost-effective manner. Focused Electrical Resistance Heating ("ERH") is
also a reasonable remedy, which satisfies the NCPfactors. The other
thermal remedies, studied in the DNAPL Feasibility Study including full
scale thermal and steam injection, are not implementable, not cost-
effective, and may result in irreparable, catastrophic harm to human
health and the environment.
What is the Site? A 13-acre property located at 20201 S. Normandie Avenue
in the Harbor Gateway area of Los Angeles that was used for the manufacture
of technical grade DDT from 1947 until 1982.
What type of contamination is being addressed at the Site? DDT
contaminated soil and groundwater, as well as DNAPL composed of DDT and
monochlorobenzene ("MCB"), a raw material used in the DDT manufacturing
process, have been detected in certain areas at and beneath the Site.
How is the Site unique? The Site exhibits a unique lithology, consisting of
highly layered heterogeneous silt with low permeability, with DNAPL at
depths of more than 100 feet below ground surface. The Del Amo Site, which is located across the street from the Site, has a nearly identical lithology. At
the Del Amo Site, EPA did not select thermal remediation because such unique lithology is not well-suited for application of thermal technologies: "the low
permeability and heterogeneous character of soils at the former plant site would interfere with the uniform transmission of the steam through the subsurface."
Additionally, as explained in the 1999 Record of Decision for the Site ("ROD"), EPA has recognized that it is technically infeasible to remove enough
DNAPL to attain drinking water standards in the immediate vicinity of the DNAPL. As a result, EPA has issued a waiver of the in-situ groundwater
standards in that area (the "TI Waiver Zone").
How is the contamination at the Site Unique? The DNAPL found at the Site differs from DNAPLs commonly found at other sites. Only three other sites
in the country contain similar DNAPL and the DNAPL remedies at those sites involved hydraulic containment and/or extraction. Due to the infrequent
occurrence of similar DNAPL, the behavior of such DNAPL is not well-documented. There is a limited basis to evaluate the effectiveness of thermal
remedies at remediating Montrose DNAPL, but several factors suggest that full-scale thermal technologies would not be implementable: Montrose DNAPL
exhibits a boiling point that is approximately 19 degrees higher than other typical DNAPLs, Montrose DNAPL exhibits low vapor pressure, and the DDT
in Montrose DNAPL precipitates when MCB is removed. These factors lead to reduced mass removal efficiencies when thermally treated.
-------
Executive Summary
What are the possible remedies for DNAPL at the Site? In detail, the DNAPL Feasibility Study analyzed Hydraulic Displacement with untreated water injection.
Hydraulic Displacement with treated water injection. Focused Steam Injection, Full Scale Steam Injection, Focused ERH, and Full Scale ERH. Other remedies were
also studied and rejected including bioremediation, cosolvent injection, conductive heating, and polymer flooding. Additionally. Montrose conducted numerous
laboratory and field pilot tests to evaluate all feasible and effective candidate technologies as thoroughly as possible.
Hydraulic Displacement is a safe and cost-effective remedy: Hydraulic Displacement is a green, safe, simple, and cost-effective remedy for the Site that would
protect human health and the environment by removing the majority of mobile DNAPL mass within the saturated zone, removing more mobile DNAPL mass than
any other proposed remedy (the primary threat to groundwater), desaturating and significantly demobilizing any remaining DNAPL, limiting the potential for
migration of DNAPL. and limiting the potential for human exposure to contaminants with significantly lower energy consumption and resulting GHG emissions.
Full-scale thermal remediation poses unnecessary and irreversible risks to
human health and the environment and is not cost-effective:
• Full-scale thermal remediation is potentially a $100 million complex
remedy that poses risks of catastrophic explosion, fugitive emissions,
contaminant migration to neighboring properties, soil weakening and
diminished structural stability of nearby buildings, and threatens to
introduce as much greenhouse gas ("GHG") into the surrounding
community as a large power plant (see page 6).
• The safety risks associated with full-scale thermal remediation are
magnified by the proximity of neighboring properties. The industries
north of the Site share a near-zero lot line with Montrose, there is a
chlorine plant located immediately south of the Site that supplies chlorine
to all municipal water supplies in the Los Angeles area, and there are
residential homes across the street from the Site (see page 1). Therefore,
contaminant migration, fugitive emissions, decreased structural stability,
or explosion could therefore have devastating effects.
• Steam injection poses a significant risk for downward migration of
contaminants. Presently, no DNAPL has been found in the Bellflower
Sand, the aquitard that lies underneath the Upper Bellflower Aquitard.
However, due to increased saturation and mobility of DNAPL and weakening of capillary barriers caused by thermal remediation, DNAPL can migrate
along the top of low permeability silt layers in the Upper Bellflower Aquitard and when the DNAPL intercepts a discontinuity in a silt layer, the DN APL
can migrate down to an underlying aquitard.
The massive environmental and safety risks and the immense cost of thermal remediation are not justified by any considerable benefits. While full-scale
thermal remedies have the potential to remove more DNAPL mass than Hydraulic Displacement or Focused ERH. full-scale thermal remedies will not
remove more mobile mass ~ the principle DNAPL threat ~ and like all other remedies, including Hydraulic Displacement, thermal remedies will still
reauire over 3.000 vears of groundwater contaimnent within the TI Waiver Zone.
Moreover, the unique character of Montrose DNAPL and the unique lithology of the Site are not suited for thermal remedies, thus making the
effectiveness of a thermal remedy uncertain and increasing the risks of contaminant migration and fugitive emissions.
ON-PROPERTY HYDROGEOLOGY
PLAYA DEPOSITS
PALOS VERDES SAND
WtfS«1,SM
-------
Executive Summary
DNAPL Is Completely Contained Within Tl Waiver Zone
Legend:
Montrosn Property Bouncfciry
—¦ m m mm Del Ama Superfund Sifec Boundary
i—^ H wtfwr tent Bcirdary h the UBA
E*t*nt fll Posslblt WAPL
Prsasncfl In the Saturated USA
FJI Scale TrwtinsRt Arcq
Focused T"reatm«n1 Area
-------
Summary of Available Remedies
Increasing Risks to Human Health & the Environment
Increasing Complexity
Increasing Costs
Hydraulic
Displacement
- Groundwater is
simultaneously
extracted and injected to
induce hydraulic
gradients that mobilize
DNAPL towards
extraction wells.
- The extracted
DNAPL/ groundwater
requires separation,
followed by off-Site
disposal of the DNAPL
and reinjection of the
groundwater.
- There is a possibility
of treating groundwater
prior to reinjection, but
it should not be
necessary in the TI
Waiver Zone.
- 69 extraction and
injection wells would
be required.
Focused
ERH
- ERH is accomplished by
installing electrodes
throughout the treatment
zone (mobile DNAPL
area) and transmitting an
electric current between
them to heat the soil by
electrical resistance.
- The electrodes are
typically spaced from 12
to 25 feet apart depending
upon soil resistivity, and
are installed within soil
borings using standard
methods.
- The vapors generated by
this process are recovered
by SVE for ex-situ
treatment.
- 102 electrodes and 66
extraction wells would be
needed.
Focused
Steam
- Pressurized steam is
injected into subsurface (in
the mobile DNAPL area) to
vaporize contaminants for
SVE recovery. Steam will
condense in the subsurface
and can displace or flush
contaminants towards
recovery wells. A hot floor
may be needed to reduce
potential for downward
migration.
- Steam Injection and multi-
phase extraction wells are
positioned throughout the
DNAPL-impacted zone.
Vapor-phase contaminants ^
are removed by SVE and
liquid-phase contaminants
are removed by direct
extraction. DNAPL is
separated and disposed off-
Site. A total of 55 injection,
extraction and monitoring
wells would be required.
Full Scale
ERH
- Same as Focused
ERIi, except treatment
would occur over entire
DNAPL-impacted area,
rather than just the area
containing mobile
DNAPL."
-456 electrodes and 203
extraction wells would
be required to treat the
entire DNAPL-
impacted area.
Full Scale Steam
- Same as Focused
Steam except treatment
would occur over entire
DNAPL-impacted area,
rather than just the area
containing mobile
DNAPL.
-186 injection,
extraction, and
monitoring wells would
be necessary to treat the
entire DNAPL-
impacted area.
-------
Effectiveness of Available Remedies
Hydraulic Displacement
ERH
Steam Injection
Predicted to remove 36,000-43,000 gallons of
total MCB, and 9,000-13,000 gallons of
saturated zone total DDT.
Predicted to remove 80% of the mobile
DNAPL mass.
Effectiveness is certain: Hydraulic
Displacement was field pilot tested at the Site
in 1991, 2005/2005, and 2008.
Some DNAPLs are not readily
mobilized for extraction by Hydraulic
Displacement. Although residual
saturations of DNAPL would be left in
place, such DNAPL poses little or no
risk of mobilization.
Discontinuous sand layers which are not
in hydraulic communication with the
extraction and injection wells may limit
the effectiveness of this and other
displacement technologies such as
Steam Injection.
Predicted to remove 42,000-55,000 (Focused)
or 53,000-59,000 (Full Scale) gallons of total
MCB, and 0 gallons of saturated zone DDT.
• However, effectiveness is uncertain: ERH
has not been implemented at a site comparable
to a full-scale ERH remedy at Montrose and has
not been proven at this Site. Multiple factors
suggest that remedy may encounter
effectiveness problems:
o Desaturated soils, boiling of the
groundwater may result in higher
resistivity soils, inhibiting transmission of
electricity through soils. This may result
in inefficient and non-uniform heating
under full-scale ERH.
o The 45-feet thick interval at the Site can
pose challenges to uniform heating. A
longer electrode will be needed, which
may not effectively heat soils in the
middle of the treatment interval under
full-scale.
o The depth of the water in the BFS is only
slightly deeper than the UBA, so some
cooling from the BFS may occur, thus
increasing the required heating duration.
However, ERH presents fewer effectiveness
risks than Steam Injection because ERH heats
resistively and does not rely on soil
permeability for heat distribution, and has a
higher well density thus increasing the potential
for recovering MCB vapors. ERH is more
commonly applied at sites like the Montrose
Site, where soils exhibit lower permeability
Predicted to remove 42,000-55,000 (Focused)
or 53,000-59,000 (Full Scale) gallons of total
MCB, and 0 gallons of saturated zone DDT.
• However, effectiveness is uncertain: Steam
Injection has not been implemented at a
comparable site and has not been proven at this
Site. Numerous factors suggest that the remedy
may encounter remedy problems:
o Preferential steam flow through higher
permeability soils will make achieving
necessary target temperatures
problematic. The complex lithology of
the Site cannot be easily engineered to
control steam distribution.
o The highly layered nature of the UBA
may limit the ability to recover volatized
MCB. If volatilized MCB vapors are not
effectively recovered, they have the
potential to condense and accumulate in
other parts of the UBA.
o Steam Injection increases the saturation
and thus mobility of DNAPL. Downward
mobilization may exacerbate
environmental impacts rather than
mitigating them.
o The high boiling point of Montrose
DNAPL and the low vapor pressure of
MCB may result in reduced mass removal
efficiencies.
c Reinjection of treated groundwater into
the UBA may potentially cool the
subsurface, reducing the effectiveness of
the remedy
Environmental Risks of Full Scale Thermal Remediation and Steam Injection
5
-------
"Green
remediation is the
practice of
considering all
environmental
effects of remedy
implementation
and incorporating
options to
minimize the
environmental
footprints of
cleanup actions"
U.S. EPA, Superfund
& Green Remediation.
Candidate DNAPL
Remedial Alternative
Carbon Footprint Analysis
Carbon Dioxide Emissions Summary
Total Mass of C02
Released (lbs)1
Trees Required to Offset
C02 Emissions2
Acres Required to Support
Trees3
Hydraulic Displacement with
Untreated Water Injection
11 million
72,000
120
Hydraulic Displacement with
Treated Water Injection
26 million
169,000
282
ERH, Focused
33 - 61 million
215,000-393,000
358 - 655
Steam Injection, Focused
51-106 million
333,000 -684,000
555-1,140
ERH, Full-Scale
143 - 227 million
928,000-1,468,000
1,547 - 2,447
Steam Injection, Full-Scale
189-412 million
1,220,000-2,667,000
2,033 - 4,445
"To protect
human health and
the environment,
policy makers,
remediation
practitioners, and
the public should
be aware of wider
potential impacts
of remedial
options and
incorporate this
information into
the remedy-
selection process."
California DTSC Interim
Advisory for Green
Remediation.
Full Scale Thermal Remedies Require a Massive Amount of Energy and are Inconsistent With State and Federal Goals:
An enormous amount of energy is required to heat the entire DNAPL impacted area to the target temperatures necessary for effective
implementation of a Full Scale Thermal Remedy. Accordingly, the energy-based carbon footprint of Full Scale Thermal Remediation is
exceptionally high. Full Scale Thermal Remediation has the potential to produce up to 500 million pounds of GHGs- a 3 to 15 times larger
carbon footprint than Hydraulic Displacement or Focused ERH.
Full Scale Thermal Remediation would likely trigger both state and federal reporting requirements, is inconsistent with EPA and
California green remediation initiatives, and would not advance the goals outlined in the California Global Wanning Act of 2006.
Steam Injection is an Energy Intensive Technology: The amount of energy required to treat even the focused treatment area with Steam
Injection would be large. The resulting carbon footprint may be up to 3 times the footprint of Focused ERH, or almost 10 times the footprint of
Hydraulic Displacement.
Hydraulic Displacement Has the Lowest Carbon Footprint of All Effective Remedies: Hydraulic Displacement will produce only 4 to 11
million pounds of GHGs, and will comply with EPA and California green remediation initiatives.
6
"With the recognition of a global warming trend and significant estimated
carbon dioxide (C02) emissions at federal Superfund sites
(USEPA/OSWER, April 2008), the United States Environmental
Protection Agency (USEPA), numerous state environmental regulatory
agencies, and a variety of organizations are developing policies, practices,
and evaluation methods aimed at reducing the environmental footprint of
cleanup sites." California DTSC Interim Advisory for Green Remediation.
-------
Environmental Risks of Full Scale Thermal Remediation
Annual GHG Emissions Comparison
DNAPL Remedial Alternatives vs. California PowerPlants
Montrose Superfund Site
HD 'with Untreated Groundwater
Escondido Power Plant
HD with Treated Groundwater
Miramar Energy Facility
Yuba City Energy Center
Focused ERH
CalPeak Power - El Cajon LLC
Ripon Generation Station
Rwerside Energy Resource Center
Focused Steam Injection
Anaheim Combustion Turbine
Fresno Cogeneration Partners. LP
Larkspur Energy Facility
Full-Scale ERH
Los Esteros Critical Energy Facility
Gilroy Energy Center. LLC
FulFScale Steam Injection
Indigo Generation Facility
Contra Costa Power Plant
Redding Power Plant
t
iiiili
jPvlandatory reporting for GHG emissions
jexceeding 25 ,000 metric tons per year
:
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% i
10,000 20,000 30,000 40,000 50,000 60,000 70,000
GHG Emissions in Metric Tons/Year
80,000
90,000
100,000
Notes:
= Candidate DNAPL Remedies
= California PowerPlants (2007)
1. Annual GHG emissions for California power plants obtained from Americas'Biggest Polluters Carbon Dioxide Emissions from Power Plants in 2007 (Environment Oregon Research &
Policy Center, 2009).
7
GHG emissions from Full Scale Thermal Remediation at the Site would be greater than the GHG
emissions reported at 40% of California's power plants
-------
Safety Risks of Steam Injection
Steam Injection Poses Severe Risks to the Surrounding Community:
Steam Injection May Cause Pollutants to Migrate to Previously Uncontaminated
Areas: Steam Injection increases DNAPL saturation. Because the mobility of DNAPL
is highly dependent on its saturation levels, an increase in DNAPL saturation makes the
DNAPL more prone to lateral and vertical migration. Additionally, Steam Injection
desaturates capillary barriers in soils, thus reducing their ability to support DNAPL
pools and prevent downward migration.
The risks of lateral and vertical migration are very real:
Lateral migration of DNAPL occurred at Route 44 Taunton Site and up to 8
feet of DNAPL was found in downgradient extraction wells after thermal
treatment.
Downward mobilization through a desaturated capillary barrier was
observed during bench-scale testing of Montrose DNAPL.
Hot floors do not amply prevent migration- they have been utilized at only 7
sites and failed almost 30% of the time. Additionally, the wells required for
hot floors create vertical conduits that increase the chance of DNAPL
migration.
The complex lithology of the Site increases the chance of vertical migration:
In rejecting Steam Injection at the neighboring Del Amo site, the FS states
"the low permeability and heterogeneous character of soils at the former
plant site would interfere with the uniform transmission of the steam
through the subsurface'' and thus "the source areas at this site are generally
not well suited for application of this technology. . . " If uncontrolled steam
distribution occurs near the northern Site boundary, DNAPL may migrate
under buildings on the GLJ Holdings Property that are constructed on the lot
line.
Steam Injection May Cause Explosion and Fugitive Emissions
Catastrophic failure and fugitive emissions have occurred at similar sites:
Thermal Remedy Well Failure at Visalia Pole Yard Site,
Visalia, CA
For example, catastrophic failure occurred at the Visalia site and fugitive emissions occurred at the Cape Fear site. At this Site,
contaminated vapors may escape through more than 200 borings and wells at the Site that are unable to withstand the elevated
temperatures of Steam Injection.
EPA rejected Steam Injection at the Del Amo Site across the street because "heating of the ground could cause uncontrolled vapor
migration and explosions if not properly designated, constructed, and operated. "
8
Steam Release at Cape Fear Site, Fayetteville. NC
-------
Safety Risks of ERH and Hydraulic Displacement
Focused ERH Poses Significantly Less Risk to the Surrounding Community:
ERH Carries Some Risk of Migration: The potential for mobilization during ERH treatment is a concern; heated vapors must be
effectively recovered in order to prevent migration. The layered and heterogeneous nature of the saturated UBA may reduce the
effectiveness of recovering MCB that is volatized by ERH in a full-scale remedy. Additionally, the drilling of numerous ERH wells
creates conduits for migration.
However, the risk of migration is less problematic for ERH than Steam Injection, and significantly less for focused
EHR. ERH does not hydraulically displace DNAPL and does not rely on mobilization of the DNAPL for recovery,
so there is a reduced risk of uncontrolled contaminant migration as compared with Steam Injection. Further, a
"bottom up" heating approach may be used to reduce the potential for downward migration.
ERH Carries Some Risk of Fugitive Emissions and Explosion, But Focused ERH Can Better Control Those Risks: With all
thermal remediation projects, there is an increased potential for accidental release of heated vapors or contaminated steam. However,
the high density of ERH wells (relative to steam injection) reduces the risk of vapor migration. Additionally, the risks under focused
ERH are less than for Steam Injection due to lower operating pressures and a more gradual heating process.
9
-------
Remedial Action Objectives
Remedial Action Objectives ("RAOs") for the Site:
1) Prevent human exposure to DNAPL constituents (via
ingestion, inhalation, or dermal contact) that would pose
an unacceptable health risk to on- or off-property
receptors under industrial land uses of the Montrose plant
property and adjacent properties;
2) To the extent practicable, limit uncontrolled lateral and
vertical migration of mobile NAPL under industrial
land use and hydraulic conditions in groundwater;
3) Increase the probability of achieving and maintaining
containment of dissolved-phase contamination to the
extent practicable, as required by the existing
groundwater ROD, for the time period that such
containment remains necessary;
4) Reduce mobile NAPL mass to the extent practicable;
5) To the extent practicable, reduce the potential for
recontamination of aquifers that have been restored by
the groundwater remedial actions, as required by the
groundwater ROD, in the event containment should fail;
and
Remedial Action Objectives identify
remediation goals that "establish
acceptable exposure levels that are
protective of human health and the
environment.'''' 40 C.F.R. 430
11 to the extent practicable means the
remedy that provides "the best
balance of trade-offs" among the
NCP Criteria. It does not mean to the
maximum extent possible, epa. a Guide
lo Preparing Superfund Proposed Plans. Records of
Decision, and Other Remedy Selection Decision
Documents at 6-51. OSWER 9200.1-23P (July 1999)
6) To the extent practicable, reduce the dissolved-phase
concentrations within the containment zone over time.
10
-------
Compliance with RAOs
Remedial Action Objectives
Hydraulic Displacement Remedy
Steam Injection/ Full Scale Thermal
1.
Prevent human exposure to
DNAPL.
Hydraulic Containment is Effective at Preventing Human
Exposure to DNAPL: Limited risk for migration, explosion, or
fugitive emissions; effective at removing DNAPL mass.
Steam Injection is Not Effective at Preventing Human Exposure:
Due to the high risk of fugitive emissions, migration, and explosion,
thermal creates a significant risk to nearby neighbors.
2.
To the extent practicable, limit
uncontrolled lateral and vertical
migration of mobile NAPL.
Hydraulic Displacement Limits Lateral and Vertical
Migration of DNAPL: Removes enough DNAPL that it is
unlikely a large enough pool would accumulate to create the
pressure required for vertical migration. Additionally, Hydraulic
Displacement desaturates DNAPL, therefore reducing the
mobility of any remaining DNAPL so that it is unlikely to pose a
significant threat.
Steam Injection May Increase Risk of Lateral and Vertical
Migration: Steam Injection saturates and mobilizes DNAPL and
weakens capillary barriers that would otherwise prevent migration; 2-D
studies confirm.
3.
&
5.
Increase the probability of
achieving and maintaining
containment to the extent
practicable; To the extent
practicable, reduce the potential
for recontamination of aquifers.
Hydraulic Displacement Increases the Probability of
Achieving and Maintaining Containment and Reducing the
Potential for Recontamination: The removal of mobile
DNAPL will eliminate much of the continuing source of
groundwater contamination and Hydraulic Displacement
pumping will act as a secondary containment system.
Full Scale Thermal Presents No Benefits for Containment:
Thermal remediation removes less mobile DNAPL than Hydraulic
Displacement and does not have a pumping system to act as a
secondary containment system.
4.
Reduce mobile NAPL mass to the
extent practicable.
Hydraulic Displacement is Effective at Removing Mobile
DNAPL Mass to the Extent Practicable: Removes the
majority (80%) of all mobile DNAPL mass (more mobile
DNAPL mass than thermal remediation) — which is the principle
DNAPL threat, and also removes a large quantity of DDT mass.
DNAPL in low permeability layers of UBA will
not be remediated by Hydraulic Displacement, but
such DNAPL has a low risk of migration.
The Effectiveness of Hvdraulic Displacement is Certain:
Hydraulic Displacement was performed successfully in a
2004/2005 pilot test and at the most similar DNAPL sites in the
county.
Steam/Full Scale are Potentially Effective at Removing Mobile
DNAPL Mass: Steam Injection and Full Scale may potentially
remove approximately 64% of mobile and residual MCB mass.
However:
- The highly layered and heterogeneous nature of the UBA
(same lithology as the Del Amo Site) presents challenges for
controlling steam distribution, heating less permeable layers,
and recovering heated MCB vapors, which may result in
decreased effectiveness and spreading of contamination
during steam treatment.
Effectiveness of Steam/ Full Scale Thermal is Uncertain: DDT and
the Site lithology are unique, and unlike the successful pilot test for
Hydraulic Displacement, thermal remediation has not been proven at
the Site.
6.
To the extent practicable, reduce
the dissolved-phase concentrations
within the containment zone over
time.
Containment Timeframe: Hydraulic Displacement does not
meaningfully reduce the timeframe for long-term hydraulic
containment (between 4,300 and 4,900 years). However,
technological advances in the future may significantly reduce this
timeframe.
Containment Timeframe: No thermal remedy meaningfully
decreases the timeframe for long-term hydraulic containment (between
3,100 and 4,900 years). However, technological advances in the future
may significantly reduce this timeframe.
Effective and Compliant Effectiveness Uncertain
with RAOs and Not Compliant
-------
NCP Factors: Compliance with ARARs and Protection of Health and Environment
Hydraulic Displacement
Focused ERH
Steam Injection and Full Scale Thermal Remediation
ARARs: Reinjection of treated
groundwater is compliant; reinjection of
untreated water is conditionally compliant
with ARARs.
o A waiver of in-situ groundwater
standards is appropriate. Reinjection
of treated groundwater that does not
meet MCLs would occur fully within
the TI Waiver Zone, will not
adversely affect water quality, will not
violate anti-degradation policies
which apply only to "high quality
waters", and would not violate
environmental regulations: a waiver
was previously approved for the
2004/2005 pilot tests.
Human Health and the Environment: By
preventing human exposure to DNAPL,
limiting migration of DNAPL, and removing
significant DNAPL mass without any large
risk to the environment or the community,
Hydraulic Displacement meets all ARARs
and RAOs and is, overall, protective of
human health and the environment.
ARARs: Likely fully
compliant with all
ARARs.
Human Health and
the Environment: By
removing the majority
of the DNAPL mass,
focused ERH controls
migration of
contaminants, removes
the source of VOCs,
and limits the chance of
human exposure, thus
protecting human health
and the environment.
While there are some
mobilization risks and
upset risks associated
with ERH that make the
remedy less protective
than Hydraulic
Displacement, those
risks are far lower than
the risks associated with
Full Scale Thermal
Remediation or Steam
Injection.
ARARs: May be fully compliant with all ARARs.
Human Health and the Environment:
In order to be eligible for selection, a remedy
must achieve overall protection of human health and
the environment. Numerous legislative and
administrative actions by the federal, State, and local
governments have recognized that GHG emissions
present a significant risk to human health and the
environment. Due to the significant GHG emissions
from thermal remediation, it is not protective of human
health and the environment.
The high risks for upset conditions, fugitive
emissions, and contaminant migration also decrease the
protectiveness of a Steam Injection remedy.
SERA
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12
-------
NCP Factors: Cost
Hydraulic Displacement Remedy
Focused ERH
Full Scale Thermal Remedy and Steam Injection
Cost is half to six times less expensive
than the cost of thermal remedies.
Lowest cost per pound of contaminants
removed.
Cost-Effectiveness: means "costs
proportional to its overall effectiveness.'
While the cost of ERH
may be double the cost of
Hydraulic Displacement
due to energy and
equipment costs, the costs
of ERH are reasonable and
are half to four times less
expensive than Full Scale
Thermal Remediation.
EPA Policy declares that cost is a critical factor in
remedy selection. EPA, The Role of Cost in the Superfund
Remedy Selection Process (September 1986).
A Full Scale Thermal Remedy would be the largest
privately funded thermal remediation project ever
implemented in the United States and the financial
burden to Montrose is prohibitive.
High costs of Full Scale Thermal Remediation and Steam
Injection derive from expensive equipment, soil vapor and
groundwater extraction, high energy demand, waste
disposal, and a necessary hot floor.
High cost is grossly disproportionate to the limited benefits
gained by Full Scale Thermal Remediation:
The additional amount of MCB removal by Full Scale
Thermal Remediation will not provide environmental
benefits that are ten times greater than HD; the
benefits are at best, marginal.
Failure to consider cost-effectiveness could be "arbitrary and capricious." US v.
Hard age, 982 F.2d 1436 (10th Cir. 1992); Ohio v. EPA, 997 F.2d 1520 (D.C. Cir. 1993).
Candidate DNAPL Remedial Alternative1
Estimated Total Cost
(NPY)
Unit NPY Cost'
($/Ib MCB removed)
RA4a
Hydraulic Displacement- untreated water
injection
$13.2 million
$53-$79;lb MCB
RA4b
Hydraulic Displacement- treated water injection
$21.4 million
$1124168 lb MCB
RA 6a
ERH over focused treatment area
$21.2-$26.1 million
$66-$ 146,1b MCB
RA 5a
Steam Injection over focused treatment area
$25.2433.6 million
$834200,lb MCB
RA 6b
ERH over entire treatment area
$53.7-$70.6 million
$1784269 lb MCB
RA 5 b
Steam Injection over entire treatment area
$57.6485.3 million
$2014330/lb MCB
-------
\( P Factors: 1111 piemen tnhility
Hydraulic Displacement Remedy
Focused ERH
Steam Injection/ Full Scale Thermal
Equipment/Maintenance:
o Hydraulic Displacement requires the least
maintenance of all effective remedies.
o No specialized equipment is required.
Extraction wells can be installed using standard
drilling methods and equipment, and ordinary
techniques can be used to separate DNAPL
from groundwater.
o Remedy has been successfully pilot-tested at the
Site.
Technical Issues: Injection well fouling is a common
problem and could increase difficulty of implementation.
A routine well development program would be required to
abate the effects.
Potential for Implementability Challenges: Treating
water to ISGS prior to reinjection would require more
highly skilled operators, a higher level of maintenance,
and more infrastructure. However, consistent with TI
Waiver policies, injection limits in the ROD do not apply
for injection of treated water that does not meet MCLs, so
treatment is unlikely to be required:
o Temporary and limited reinjection of untreated
water into the already heavily contained TI
Waiver Zone will not negatively affect
groundwater or pose health risks.
o The extraction and injection pumping under HD
will act to contain the injected groundwater
within the TI Waiver Zone, therefore creating
"double containment" when combined with the
groundwater treatment system.
o This has been approved at other large DNAPL
sites and a waiver was granted for 2004/2005
testing at the Site without an adverse impact on
groundwater.
o Reinjection of untreated water will still achieve
RAOs.
Equipment/Maintenance:
A significant amount of
complex above and below
ground infrastructure
would be required to
generate and deliver
electricity.
ERH requires skilled
operators and high level of
maintenance.
o Unlike Steam Injection,
three qualified vendors are
available and ERH is more
frequently implemented
than Steam Injection.
Additionally, ERH would
not require use of steam
boilers or general boiler
emissions and brine waste.
Equipment/Maintenance:
o Steam Injection and Full Scale Thermal
Remedies require intricate and sizeable
infrastructure to heat the entire subsurface
to depths of more than 100 feet, recover
contaminants and water, and treat water,
o Steam Injection and Full Scale Thermal
Remedies require considerable
maintenance, highly skilled field
operators, and specialized technology
vendors,
o Steam Injection would require
incorporation of a hot floor, which
requires sophisticated drilling methods,
and considerable maintenance.
o A lack of adequate commercial Steam
Injection vendors may limit the
implementability of Steam Injection.
Technical Issues: Reinjection of groundwater
would cool the subsurface, reducing the ability
to implement Steam Injection.
Size and Complexity:
o A Full Scale Thermal Remedy would
likely be the largest remedy of this kind.
There are no comparable sites of this size,
c Due to the highly layered nature of the
saturated aquitard and the uniqueness of
Montrose DNAPL, a Full Scale Thermal
Remedy would be the most complex
thermal remedy ever conducted. For the
same reasons, thermal remedies were
rejected at the neighboring Del Amo site.
14
-------
NCP Factors: Comparative Analysis
NCP Criterion
Hydraulic
Displacement No
Treatment
Hydraulic
Displacement
Treatment
ERH Focused
Steam Focused
Full Scale ERH
Full Scale Steam
Protective of Human
Health & Environment
Yes
Yes
Yes
Yes
Questionable
Questionable
ARAR Compliance
Yes (Conditional)
Yes
Yes
Yes
Yes
Yes
Effectiveness
Effective
Effective
Theoretically
effective, but
untested at unique
Site/DNAPL
Theoretically
effective, but
untested with unique
Site/DNAPL
Theoretically
effective, but
untested at unique
Site/DNAPL
Theoretically
effective, but
untested at unique
Site/DNAPL
Hydraulic Containment
Timeframe (years)*
4700-5400
4700-5400
4300-4900
4300-4900
3100-4900
3100-4900
Vadose Zone Volume
Reduction (1,000 gallons of
MBC)
27-30
27-30
27-30
27-30
27-30
27-30
Saturated Zone Volume
Reduction (1,000 gallons of
mobile DNAPL)
9-13 MCB
9-13 DDT
9-13 MCB
9-13 DDT
15-25 MCB
limited DDT
15-25 MCB
limited DDT
26-29 MCB
limited DDT
26-29 MCB
limited DDT
Implementability
Highly
Implementable
Moderately
Implementable
Moderately
Implementable
Moderately
Implementable
Difficult to
Implement
Difficult to
Implement
Cost (Smillion NPV)
$13.2
$21.4
$21.2-$26.1
$25.2-$33.6
$53.7-$70.6
$57.6-$85.3
Public Acceptance
Likely
Likely
Potentially
Unlikely
Unlikely
Unlikely
GHG Emissions (million
lbs)3
11
26
33-61
51-106
143-227
189-412
Safety & Environmental
Risks
Limited
Limited
Moderate
High
High
Very High
*Hydraulic containment involves pumping groundwater to contain and isolate the dissolved phase contamination surrounding the DNAPL at the Site so that it
cannot escape the contaimnent zone, thus assuring that the contamination will not move downward or sideways in response to hydraulic extraction of contaminated
groundwater. The hydraulic containment timeframe is the number of years that contaimnent will be required so as to prevent recontamination of the clean
groundwater after treatment and reinjection.
-------
Comparative Analysis: Drawbacks of Full Scale Compared to Focused Treatment
Significant Risks
• Because the treatment area for Full Scale is six
times larger than Focused Remedies, the potential
for uncontrolled migration of DNAPL is increased.
• The large size of Full Scale Remediation makes it
more difficult to implement than a Focused
Remedy and increases the cost by almost a four-
fold (cost prohibitive).
• Because a larger area is heated, more energy is
required and Full Scale Remediation produces 77%
more GHG emissions than Focused Thermal
Remediation.
• Due to the increased capacity of a Full Scale
Thermal Remedy, the risk for catastrophic failure,
fugitive emissions, explosions, and soil weakening
is higher for Full Scale Remedies than Focused
Remedies.
For Minimal Increased
Effectiveness
• A thermal remedy of the Full Scale size and complexity is
unprecedented and untested.
• Only approximately 13- 40% of the total DNAPL mass
occurs outside the focused treatment area.
• Full Scale Remediation does not remove more mobile
DNAPL (the principal threat) than Focused Thermal
Remedies.
• Long-term hydraulic containment time would not be
meaningfully reduced: containment would still be
required for between 3,100 and 4,900 years.
• The ability of a Full Scale Remedy to reduce the potential
for recontamination of the aquifers is identical to that of
remedies that involve only the focused treatment area.
16
DNAPL recovered from UBE-5 at the Site
-------
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Sierra
Club
I iK'K [)(|i
Palos Verdes - South Bay Group / Angeles Chapter
February 13, 2015
Comments from Sierra Club on DNAPL (Dense Non-Aqueous Phase Liquid) cleanup from
the Montrose DDT Superfund site in Los Angeles near Torrance:
The determination of a Technical Impracticability (TI) Waiver Zone needs to be
revisited. Leaving large quantities of DDT and chlorobenzene underground puts
groundwater resources forever at risk of contamination. If the DDT were a valuable
resource like gold, it would already have been dug up. Water in California is a precious
resource that should not be put at risk. The public should be offered the alternative of
responsible parties removing the contamination and relocating it where it will not put
ground water and human health at risk while being treated.
There are two important objectives for the DNAPL (Dense Non-Aqueous Phase Liquid)
cleanup from Montrose DDT facility in Los Angeles near Torrance. The first objective is
safeguarding groundwater from contamination, especially groundwater used for
drinking water. The second objective is safeguarding the health of people living and
working in the area.
The so-called "lower cost" alternatives, especially Alternative 1, No Action, are only
lower cost if water quality and human health are assigned no value. In reality, water is
precious in California, and human health is precious everywhere. The less stringent
cleanup methods, by allowing continuing and expanding contamination of groundwater,
would only be postponing and making more expensive the groundwater cleanup that
would eventually be necessary.
Alternative 6A, Electrical Resistance Heating for a Focused Treatment Area, is stated to
be most effective in protecting groundwater from contamination, but it is not clear why
Alternative 6B, Electrical Resistance Heating for the Entire Treatment Area, would be
less effective. Alternative 6B would seem to do more cleanup, and if so, should be
preferred.
In either case, treatment to reduce the concentration of pCBSA (p-chlorobenzenesulfonic
acid) in re-injected groundwater needs to be adequate to protect groundwater from
contamination, in order to protect public health. If it is necessary to promptly start
operation of the DNAPL cleanup system to protect groundwater from contamination by
chlorobenzene, a larger, more effective treatment process to remove/degrade pCBSA (p-
chlorobenzenesulfonic acid) needs to be constructed and put into operation as soon as
possible.
P.O Box 2464 « Palos Verdes Peninsula, California 90274
© Printed on Recycled Paper
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To safeguard the health of people living and working in the area, there needs to be
sampling and analysis of air beneath and in homes in the area to establish a baseline
before DNAPL cleanup treatment begins, with frequent repeat sampling and analysis of
air while treatment is occurring. If air beneath and in the homes has a significantly
increased concentration of volatile contaminants after DNAPL cleanup treatment has
begun, the DNAPL cleanup treatment process must stop to allow troubleshooting or the
residents must be relocated.
To address the issue of remaining DDT and chlorobenzene within the Technical
Impracticability (TI) Waiver Zone, the EPA should solicit proposals and make grants for
further treatment methods. In particular, consideration should be given to biological
forms of treatment, although of course this could introduce its own set of problems,
which should be carefully investigated before implementation. There reportedly is some
biological degradation of DDT in sediments on the Palos Verdes Shelf, showing that
microbes can degrade this material.
Sincerely,
/s
Alfred Sattler
Chair
Palos Verdes-South Bay Regional Group
Sierra Club
P.O Box 2464 » Palos Verdes Peninsula, California 90274
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The Proposed Plan for Montrose Superfund Site hinges on the removal of mobile DNAPL within
the focused treatment area (~26,000 square feet) in the Upper Bellflower Aquiclude (UBA). The
Proposed Plan states the fundamental assumption on page 7 under Summary and Risk and
Basis for Action that "Removing mobile DNAPL, therefore, is a critical component in preserving
the groundwater resource and ensuring protection of human health and the environment.
Residual DNAPL is trapped in pore spaces between soil particles and cannot migrate in the
subsurface under natural conditions. Therefore, only mobile DNAPL is considered to be a
principle threat." Subsequently, it points out the preferred remedial alternative discussed in
this Proposed Plan is focused on preventing uncontrolled migration and spreading of mobile
DNAPL to ensure (1) protection of human health and the environment, and (2) the success of
groundwater remedy at the Montrose Superfund Site.
Basically, the Proposed Plan assumes the majority of mobile DNAPL only exists at UBA within
the small area at central processing area and neglects mobile DNAPL that may have migrated
vertically into deeper B-Sand, C-Sand and Gage aquifers, and horizontally to a larger area
outside the focused treatment area due to historical releases. The proposed plan also ignores
the dissolved phase plume originating from residual DNAPL (acting as continuous
contamination source). They anticipate the groundwater remedy for OU-3 Dual Site
Groundwater is designed to contain and remediate the dissolved plume coming from the
DNAPL source.
The following section briefly describes the main goal for the Proposed Plan mentioned above in
(1) and (2).
1. Protection of Human Health and the Environment
In our opinion, the protection of human health by preventing either soil vapor emissions to
surface inhabitants (VI potential) or direct contact with contaminated soils will be manageable
and less an issue, especially since the site is unoccupied. The potential remains for vapor
intrusion to be an issue of concern in the downgradient residential area. Currently, the USEPA
Remedial Project Manager (RPM: Kevin Mayer) is dealing with this issue as required. Therefore,
the evaluation for human health risk protection appears to be moving towards a reasonable
resolution.
However, the protection of groundwater and drinking water resources remains. A few
outstanding issues that should be resolved include:
A. How to ensure DNAPL mass won't continuously spread outside Tl waiver zone?
B. No continuous vertical migration to deeper aquifers, especially to Gage and Lynwood
zones.
C. Whose responsibility it is to maintain the hydraulic containment extraction wells to
capture outgoing plume (Proposed Plan or Groundwater Remedy), and where they are
located?
D. The groundwater remedy is expected to shut down in 50-years, and the hydraulic
containment system is expected to operate for thousands of years. Discontinuation of
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the groundwater remedy is contingent upon the hydraulic containment extraction wells
stopping plume migration and capturing the plume from the DNAPL source before it
migrates to downgradient areas. The interconnectivity between the DNAPL removal
and containment wells, and the containment wells and the groundwater remedy must
be clearly specified. Additionally, performance metrics must be established upfront
with a contingency plan in place in case of failure.
E. Monitoring and Contingency Plan (MACP) for mobile DNAPL depletion and MACP for
dual-site groundwater remedy should be integrated as a holistic MACP for the entire
groundwater medium, instead of each MACP acts independently without linking to each
other.
F. How to ensure the Proposed Plan can remove mobile DNAPL at the source area and how
to effectively measure the system performance and effectiveness? Will the hydraulic
containment wells design to be part of DNAPL removal or groundwater remedy?
G. If the Proposed Plan does not meet the designated objective (i.e. leaking DNAPL mass
detected), then what is the corrective action or mitigation measures to be
implemented?
H. Will the dissolved plume emanating from the DNAPL source be contained and
remediated by OU-3 Dual Site groundwater remedy?
2. Success of Groundwater Remedy at the Montrose Superfund Site:
Success of groundwater remedy depends on the successful resolution of outstanding issues
outlined above. In particular, how to meaningfully shorten the estimated 5,000 years of
operation for the hydraulic containment wells is critical because it remains unreasonably long.
Funding source and complete operation costs are unclear and ill-defined. There is an
undeniable link between the groundwater remedy, hydraulic containment and DNAPL removal.
Currently, the Proposed Plan is dependent on 5,000 years of hydraulic containment to contain
the DNAPL mass within the Tl zone without operating the groundwater remedy (which will be
shut down after 50 years of operation if the Chlorinated Volatile Organic Constituent (CVOC)
concentrations in groundwater reach Maximum Contaminant Levels (MCLs) in groundwater in
the area surrounding the containment zone. A virtually impossible task if the dissolved phase
CVOCs are not contained within the containment zone.
DNAPL removal is scheduled to take 4 to 7 years. Clearly monitoring should extend beyond the
DNAPL removal period and it may take decades to understand whether the DNAPL removal was
successful and did not push DNAPL deeper and wider that it currently exists. It seems highly
unlikely the groundwater remedy will be completed in proposed 50-year duration.
In order to document conditions during and after the DNAPL removal; the performance of
DNAPL removal should be extensively monitored at all concerned aquifers (UBA, B-Sand,
C-Sand, Gage and Lynwood) to monitor changes in concentration and to ensure there is no
significant amount of DNAPL mass capable to dissolve into groundwater and migrate away from
containment zone. The DNAPL mass includes mobile (under gravity) and residual DNAPL mass
together. The only way to quantify the mass is through the groundwater sampling results in the
dissolved form. The MACP for DNAPL removal in the Proposed Plan must be able to indicate the
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system performance of DNAPL removal and its effectiveness based on dissolved phase
concentration changes. Unless proven otherwise; the Proposed Plan should be revised to
include additional remediation measures to augment the remedy by not allowing both DNAPL
and dissolved mass discharge downward or downgradient. Otherwise, the groundwater remedy
will be required to operate until it cleans up the groundwater at concentration less than MCL.
Therefore, the success of groundwater remedy depends on satisfying the above conditions. If
these conditions are not met, the Proposed Plan should be considered incomplete.
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Technical Assistance Services for Communities
Contract Number: EP-W-13-015
TASC WA Number: 1 OSRTI-Multi-Regions & HQ
Technical Directive Number: R9 TD #8 Del Amo-Montrose
September 2014
Review of the technical document
"EPA Request for Comments on Proposed DNAPL Cleanup Plan"
Montrose Superfund Site, Los Angeles, CA
1.0 Introduction
In September 2014 the United States Environmental Protection Agency (EPA) published the
technical document "EPA Requests Comments on Proposed DNAPL Cleanup Plan" (DNAPL
Proposed Plan). The DNAPL Proposed Plan describes EPA's preferred remediation alternative
among the several considered in the September 27, 2013 Dense Non-Aqueous Phase Liquid
(DNAPL) Feasibility Study (FS) prepared for the Montrose Chemical Corporation of California
(Montrose) by EPA's environmental consultant, AECOM. These alternatives are also described
again in the DNAPL Proposed Plan.
This review and comment document provides a brief summary of site history and environmental
conditions, a description of the remedial alternative considerations and stakeholder comment
process associated with the FS development, and comments on the EPA DNAPL Proposed Plan.
This review and comment document is provided by EPA's Technical Assistance Services for
Communities (TASC) program, which is implemented by independent technical and
environmental consultants. Its contents do not necessarily reflect the policies, actions or positions
of EPA. This report is provided to the Del Amo Action Committee (DAAC) and other members
of the community neighboring the Montrose site.
2.0 Purpose of the Proposed DNAPL Cleanup Plan
Environmental response activities have been under way at the Montrose facility since the
discovery of process-related contamination in the early 1980s. EPA proposed the Site for the
Superfund National Priorities List (NPL) in 1984, and the listing was finalized in 1989.
The DNAPL at Montrose has been designated its own "Operable Unit" by EPA, and is managed
essentially as a project unto itself. Other aspects of Montrose contamination, including soil and
groundwater, have been designated by EPA as separate Operable Units. In September 2013, EPA
released the FS for the Montrose site, which identifies and evaluates potentially viable
alternatives for the remediation of the DNAPL portion of site-related contamination. The
DNAPL Proposed Plan selects a preferred cleanup for public comment before finalizing a
Record of Decision (ROD) establishing the remedy for the Operable Unit.
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3.0 Site and Environmental Summary
The 13-acre Montrose site is located at 20201 South Normandie Avenue in unincorporated
Los Angeles County, just south of the Los Angeles County line near the town of Torrance. The
Montrose site is neighbored to the east by the Del Amo Superfund Site. A residential community
occupies the land immediately southeast of the Montrose site.
Montrose began operations at the property in 1947, and until termination of operations in 1982
produced large quantities of the chemical DDT (dichlorodiphenyltrichloroethane) for off-site
transportation and sale. DDT was detected in soil and groundwater beneath the former industrial
operation at about the time plant operations were discontinued.
Contamination beneath the Montrose site consists primarily of DDT production-related raw
material and wastes detected in soil, soil vapor and groundwater. DNAPL contamination is the
subject of the FS and DNAPL Proposed Plan. As noted above, DNAPL is an abbreviation for
Dense Non-Aqueous Phase Liquid, which in simpler terms means a liquid that is not water that
sinks when mixed in water or sediments that are saturated with water. The DNAPL beneath the
Montrose site was shown by laboratory testing to consist of approximately 50 percent
monochlorobenzene (MCB) by weight and 50 percent DDT. The FS indicates that the DNAPL is
present in the unsaturated sediments above the water table aquifer that is first encountered at
about 60 feet below the ground surface and to depths of at least 105 feet below grade (in water-
saturated sediments).
4.0 The Technical Impracticability Zone
A fundamental element of the Montrose DNAPL remedy selection process is the Technical
Impracticability Zone (TI Zone). Sometimes also referred to as a "containment zone," the TI
Zone was established at the Montrose site in the 1999 EPA Record of Decision (ROD) for the
Joint Groundwater Feasibility Study (JGWFS), which was conducted in conjunction with the
nearby Del Amo Superfund site.
The TI Zone was proposed by the authors of the JGWFS as an administrative tool for the
management of NAPL (DNAPL at Montrose and LNAPL, or light non-aqueous phase liquid, at
Del Amo), as its complete removal at the time was said to be "impracticable." In establishing the
TI Zone at the Montrose and Del Amo sites, EPA relied upon its 1993 technical document
entitled "Guidance for Evaluating Technical Impracticability of Groundwater Restoration
(U.S. EPA OSWER Directive 9234.2-25). The 1993 guidance relies on studies and data
produced in the years prior to 1993.
EPA described the rationale for the TI Zone in the 1999 ROD, stating:
"EPA has recognized that much of the groundwater at the Joint Site can be restored... In order
to do so, a zone of dissolved phase contamination in groundwater surrounding the NAPL must be
contained, thereby isolating the NAPL. "
The rationale was further described in ROD Section 10.2 (Summary of Why NAPL Areas
Cannot Be Restored to Drinking Water Standards):
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"... it will not be practicable to remove enough (virtually all) DNAPL so as to attain drinking
water standards in the immediate vicinity of the DNAPL. "
In ROD Section 10.4 (Extent and Configuration of the TI Waiver Zone), EPA describes
proposals by parties to extend the boundaries of the TI Zone (TI Zone and "TI Waiver" are used
interchangeably in the technical documents) to encompass the entire dissolved contaminant
plume. EPA rejected these proposals, stating in the ROD that this "clearly would have been an
inappropriate use ofaTI waiver because, regardless of any relative difficulties or risks which
might exist in attempting to restore groundwater in the downgradient portions of the plume, it is
technically practicable to do so and to do so without compromising the objectives of the
remedial action."
Finally, with respect to the remedial alternatives evaluated by the FS, the FS states:
"The lateral extent of the TI Waiver Zone was selected to be as small as possible without causing
adverse migration due to containment pumping (EPA, 1999). Since the groundwater ROD
requires a containment zone downgradient of the DNAPL-impacted area to contain MCB-
impacted groundwater, the TI Waiver zone must be sufficiently large to ensure that DNAPL
would not be mobilized by containment pumping. Thus, the TI Waiver zone is larger than the
known extent of the DNAPL (Figure 1.21). "
5.0 Remedial Action Objectives (RAO)
The objectives for the remedy proposed in the DNAPL Proposed Plan are the basis and
framework for the remedy selection process. In the case of Montrose, EPA makes assumptions
with respect to the ability to actually restore the local environment to its pre-Montrose condition,
and these assumptions frame a decision-making process that results in a recommendation to
remove only a portion of the DNAPL mass that is present in the subsurface.
As described in the FS:
"... the generalized objectives for remediation within the DNAPL-impacted zone are to remove
mobile DNAPL mass to the extent practicable, to reduce the mobility of mobile DNAPL in the
subsurface, and to decrease the uncertainty associated with the groundwater remedy and
containment requirements. As a result, RAOs for DNAPL are more appropriately specified in
terms of contaminant mobility and mass reduction than they would be in terms of contaminant
concentrations. Accordingly, the RAOs for DNAPL at the Site are as follows:
1. Prevent human exposure to DNAPL constituents (via ingestion, inhalation, or dermal
contact) that would pose an unacceptable health risk to on- or off-property receptors under
industrial land uses of the Montrose plant property and adjacent properties;
2. To the extent practicable, limit uncontrolled lateral and vertical migration of mobile NAPL
under industrial land use and hydraulic conditions in groundwater;
3. Increase the probability of achieving and maintaining containment of dissolved-phase
contamination to the extent practicable, as required by the existing groundwater ROD, for
the time period that such containment remains necessary;
4. Reduce mobile NAPL mass to the extent practicable;
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5. To the extent practicable, reduce the potential for recontamination of aquifers that have been
restored by the groundwater remedial actions, as required by the groundwater ROD, in the
event containment shouldfail; and
6. To the extent practicable, reduce the dissolved-phase concentrations within the containment
zone over time."
6.0 Proposed Remedy
As described in the DNAPL Proposed Plan, after review of the proposed alternatives, EPA
selected Electrical Resistance Heating (ERH) over a focused treatment area as the technology
best suited to satisfy the project remedial objectives. As described previously and in the
following sections - these objectives do not include the removal of all DNAPL from beneath the
Montrose site or that fraction that is practicably recoverable. The objectives are restricted to the
removal of the "mobile fraction" of DNAPL only. The preferred remedy is presented in the
DNAPL Proposed Plan as follows:
Electrical Resistance Heating (ERH) over a focused treatment area would be implemented for
vaporizing DNAPL. This would be done by installing electrodes throughout the treatment zone
and transmitting an electric current between them to heat the soil by electrical resistance. The
ERH process would remove chlorobenzene from the DNAPL by vaporizing it. The vapors
generated by this process would then be recovered by SVE wells for above-ground vapor
treatment. The DDT component of DNAPL will then precipitate out of DNAPL and will remain
immobile and adsorbed to soil particles at depths exceeding 40 to 60 feet bgs [below ground
surface]. As discussed above, DDT is not soluble in water and will "stick" to soils deep below
the surface and will therefore be immobilized. Therefore, DDT does not pose a risk to
groundwater resources and/or human health and the environment. A total of 102 ERH electrodes
for heating the subsurface and 66 multiphase extraction wells for removing DNAPL vapors and
contaminated groundwater would be required for this alternative. Each location will include
multiple electrode segments stacked in a common hole to allow heating at the bottom of the
treatment zone, and then gradually heating upper intervals. This "bottom up " heating approach
is similar to conditions in the "hot floor " methodology integrated into the steam injection
alternatives; creating a heated soil barrier at the bottom of the DNAPL treatment zone to
prevent DNAPL from moving into deeper zones. Heated soil vapors would be extractedfrom the
multiphase extraction wells for onsite treatment using a regenerable carbon/resin system.
Groundwater extractedfrom the multiphase extraction wells would be treated by a combination
of GAC to remove chlorobenzene and other VOCs, andHiPOx to destroy pCBSA by oxidation.
Treated groundwater would be transferred to the treatment system for the Dual Site
Groundwater for reinjection. [GAC stands for Granular Activated Carbon and HiPOx is a trade
name for a groundwater treatment technology]
7.0 Review and Comment Process for the Draft DNAPL FS
The September 2014 DNAPL Proposed Plan presents a remedial recommendation that is the
result of the FS publication and review process.
A draft FS was published in December 2011 by AECOM for Montrose. The draft document was
circulated to selected stakeholder groups, including the Department of Toxic Substance Control
(DTSC) and DAAC. DTSC and DAAC submitted comments to the EPA in August and
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September 2012 respectively. The DTSC submittal included comments from the Water
Replenishment District of Southern California as an attachment (WRD). The WRD is the
manager of groundwater resources in this area of Southern California. EPA arranged a meeting
with DTSC for discussion of comments in October and November 2012. Agreement reached
between EPA and DTSC is documented in a March 26, 2013 letter from DTSC to EPA, though
the topics discussed and the substance of the agreement is not presented in the letter. There is no
mention in the letter of attendance or participation by the WRD.
Pursuant to protocol, EPA also submitted the DRAFT FS to the National Remedy Review Board
(NRRB) for review and comment. The purpose of the NRRB is described in their response to
EPA as follows:
The Administrator established the Board as one of the October 1995 Superfund Administrative
Reforms to help control response costs and promote consistent and cost-effective remedy
decisions. The Board furthers these goals by providing a cross-regional, management-level,
"real time " review of high cost proposed response actions prior to their being issuedfor public
comment. The Board reviews all proposed cleanup actions that exceed its cost-based review
criteria.
The Board review is intended to help control remedy costs and to promote both consistent and
cost effective decisions. Consistent with CERCLA and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), in addition to being protective, all remedies are
to be cost-effective. The Board considers the nature of the site; risks posed by the site; regional,
state, tribal and potentially responsible party (PRP) opinions on proposed actions; the quality
and reasonableness of the cost estimates; and any other relevant factors or program guidance in
making our advisory recommendations. The overall goal of the review is to ensure sound
decision making consistent with current law, regulations, and guidance.
The NRRB provided comments to EPA in February 2013; EPA responded to these comments in
March 2013.
Again, as noted above, DAAC submitted comments to EPA in September 2012. A response to
these comments was received in April 2014.
8.0 Comments on the EPA DNAPL Proposed Plan and Stakeholder Involvement
In association with the information presented in the preceding pages, TASC comments on the
EPA September 2014 DNAPL Proposed Plan are provided below. The aspect of the remedy or
process presented in the DNAPL Proposed Plan is described for context before each comment.
Remedial Action Objectives (Two Comments)
RAO Comment 1
The FS evaluated remedial options within the context of assumptions and parameters deemed
relevant by report authors and EPA. One assumption is that the groundwater beneath the
Montrose Superfund site is not used for drinking water, and is as such, a less sensitive resource
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than if it were in current production. As stated on Page 3 of the 2014 EPA DNAPL Proposed
Plan:
Although the State of California designates all of the water-bearing units beneath the
Montrose property as having potential potable beneficial use, there are currently no known
municipal or private potable production wells in use within the area of DNAPL distribution
and/or dissolved groundwater contamination at the Montrose Superfund Site. The nearest
municipal supply wells are located more than 2 miles from the Montrose Property, and about
0.5 to 1 mile southeast from the furthest extent of groundwater contamination related to the
Montrose and Del Amo Superfund Sites.
A second assumption is that the complete removal of DNAPL from the subsurface is technically
impossible. This assumption, documented in the 1999 Record of Decision for the Dual Site
Groundwater Operable Unit, is described in the context of the TI waiver zone on Page 3 of the
DNAPL Proposed Plan as follows:
What is a TI Waiver Zone?
The groundwater remedy includes long-term hydraulic containment of the DNAPL-contaminated
area and a buffer around this area referred to as the "Technical Impracticability (TI) Waiver
Zone. " The TI Waiver Zone was established because, as documented in the groundwater ROD,
EPA determined that removal of all DNAPI was not practicable, given current technologies.
This area will be evaluated for protection again in 2015.
Essentially, the assumptions make a foundation for the conclusion that because it is impossible to
remove all DNAPL from the subsurface, it is therefore acceptable to remove only a portion of it
(the "mobile fraction"), irrespective the fact that the removal of a significant amount of what is
presently planned to be left behind (the DNAPL that exists below saturation concentrations)
could also be removed using the same technology as that used in the proposed remedial
alternative.
The DNAPL Proposed Plan recommends removing mobile DNAPL, a process that is expected to
take between four and seven years and allowing the residual DNAPL to be addressed over time
by the network of extraction wells designed to remove contamination dissolved in migrating
groundwater. Technical documents prepared for the Dual-Site Groundwater OU indicate that
containment pumping will be required for at least 3,000 years.
For members of the public that have not studied the documents in the technical record, the
DNAPL Proposed Plan use of the words "long-term" may not accurately convey the actual
contemplated duration of the containment portion of the groundwater remedy. For the
sake of transparency, it is recommended that EPA state clearly the 3,000-year duration
that containment is presently estimated to be required.
RAO Comment 2
The FS restricts the ERH remedial action to the "focused treatment area" because deployment
over the entire area of DNAPL occurrence is seen as technically challenging and expensive.
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Regarding the cost of an expanded remedy designed to address the entire area of DNAPL
occurrence (Remedial Alternative 6b), the FS states:
Cost. The estimated cost of RA 6b is $46.2 to $69.5 MM... The estimated cost of this full-scale
ERH RA is very high. If implemented, this RA would be the largest and probably the most
expensive ERH RA ever implemented in the United States and highly financially burdensome for
Montrose. The financial burden to Montrose would be far more significant, if not prohibitive,
than the financial burden to the Federal Government or State agencies funding many of the
large-scale thermal remediation projects as described in Appendix K. Montrose does not possess
the financial resources comparable to those government agencies, and therefore, the very high
cost of this full-scale ERH RA must be given serious consideration during remedy evaluation.
Additionally, general and somewhat unsubstantiated statements are made in the technical
documents regarding the effect aggressive residual DNAPL removal will have on the overall
length of the groundwater containment/remediation remedy. As described in the EPA DNAPL
Proposed Plan:
While more aggressive thermal Alternatives 5B and 6B would remove the greatest mobile and
residual DNAPL mass, even these alternatives cannot remove all DNAPL and/or sufficient
DNAPL mass to meaningfully [emphasis added] reduce the time requiredfor long-term
hydraulic containment that will be performed as part of the OU-3 Groundwater remedy.
Therefore, treatment of the entire area by thermal alternatives (5B and 6B) offers little
advantage over the focused treatment area alternatives (5A and 6A) in terms of the long-term
effectiveness and permanence.
The NRRB addresses this issue as well:
The package presented to the Board identified several remedial action objectives (RAOs) that
included language "to the extent practicable "for addressing the mobile nonaqueous phase liquid
(NAPL). The Board notes that this language does not provide measurable criteria typically used
to define when treatment is no longer necessary for either the proposed thermal treatment or
SVE remedy components.
In addition, the package presented limited remediation goals, including: 1) reduction in mobility
and mass, 2) reduction of NAPL saturation to residual levels in the saturated zone (i.e., goal for
the ERH remedy), and 3) achieving asymptotic mass reduction in the unsaturated zone (i.e., goal
for the SVE remedy). The package also indicated that a performance verification program would
be implemented to assess if remediation goals are met. The Board recommends that the Region
more clearly define the RAOs and remediation goal/treatment end points for the proposed
remedy in the decision documents.
In their response to the NRRB, the EPA states:
The decision documents will better define the remediation objectives, goals and treatment end
points for the proposed remedy, including the goals of reducing NAPL saturation to residual
levels for the saturated zone, achieving asymptotic mass reduction in the unsaturated zone
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[emphasis added], temperature goals, and other remedy- and technology specific goals, as
appropriate. We are currently evaluating additional performance measures.
The remediation of DNAPL outside the treatment area would require an expansion of the treatment
system or a phased deployment of treatment if one sub-area is completed at a time. However,
remediation of DNAPL mass inside the treatment area to asymptotic levels (the point at which no
DNAPL can be practicable remediated), could conceivably be accomplished with the same
equipment and configuration deployed in the proposed alternative. The proposed remedy stops short
of achieving asymptotic levels, and instead proposes only to reduce DNAPL to "residual" levels.
In order to be more transparent, EPA should state clearly that the proposed remedy neither
addresses DNAPL that could be practicably remediated outside the focused treatment area nor
that DNAPL present below residual saturation inside the treatment area. EPA should also be
more forthright and transparent with respect to the decision - namely that because it is still
believed that even the most aggressive and expensive remedial approach could not possibly
remove all the DNAPL from beneath the Montrose site, it is therefore acceptable to leave a
large residual fraction behind, even if a potentially significant fraction of this residual DNAPL
could actually be remediated.
It is noted and appreciated that EPA uses the word "meaningfully" in an effort to convey this
information. However, providing a more thorough treatment of the issue in place of this word
would eliminate interpretation of the word "meaningful" differently by different audiences.
Stakeholders (One Comment)
As described earlier in this document, EPA engaged selected stakeholders in the review of the draft
FS. The DTSC review and letter of agreement is available on the Department's online database,
Envirostor. There is no record of Regional Water Quality Control Board (RWQCB) tracking or
involvement visible on the State Water Resources Control Board database (Geotracker). No
comments or responses to comments are posted to the EPA online Superfund Site Overview.
The DNAPL Proposed Plan makes reference to process participation by the California Department
of Toxic Substance Control (DTSC). As described above, the WRD submitted comments in concert
with the DTSC (as an attachment to DTSC comments). Given the WRD role as the manager of
groundwater resources in this basin, and considering the increasing importance of groundwater for
potable supply during the California drought, we believe that the follow-on participation by the WRD
should be described in the DNAPL Proposed Plan in addition to that of DTSC.
Additionally, as the RWQCB has more direct regulatory oversight with respect to water resources,
they should also have the opportunity to comment on the DNAPL Proposed Plan, irrespective the
designation of DTSC as the lead California state representation (if this designation was ever formally
made). Again, this seems especially important in light of the record low rainfall and increasing
reliance on groundwater resources for domestic, industrial and agricultural water supply. The
regional perspective of the RWQCB would supplement the local insight of the WRD.
We understand that the RWQCB had historic involvement with aspects of the Dual-Site
Groundwater OU and ROD. We expect they have been engaged in some capacity more
recently, either in association with the Dual-Site remedy or the DNAPL FS. As with the WRD,
8
-------
the engagement could be referenced in the DNAPL Proposed Plan to assure stakeholders that
all relevant California agencies have been given an opportunity to participate in this important
process.
TASC Contact Information
TASC Technical Advisor
Markus B. Niebanck, P.G.
510-693-1241
markus@amicusenv.com
Skeo Solutions Project Manager
Miranda Maupin
434-975-6700, x227
mmaupin@skeo.com
Skeo Solutions Task Order Manager
Krissy Russell-Hedstrom
719-256-6701
krissv@skeo.com
Skeo Solutions Program Manager
Michael Hancox
434-989-9149
mhancox@skeo.com
Skeo Solutions Director of Finance and Contracts
Briana Branham
434-975-6700 ext. 232
bbranham@skeo.com
Skeo Solutions Quality Control Monitor
Eric Marsh
512-505-8151
emarsh@skeo.com
9
-------
SDMS DOCID# 1142575
%
Department of Toxic Substances Control
Matthew Rodriqtiez
Secretary for
Environmental Protection
Deborah O Raphael, Director
1001 "I" Street
P.O. Box 806
Sacramento, California 95812-0806
Edmund G. Brown Jr.
Governor
March 26, 2013
Ms. Jane Diamond
Director, Superfund Division
United States Environmental Protection Agency
Region IX
75 Hawthorne Street
San Francisco, California 94105-3901
Dear Ms. Diamond:
Thank you for your letter of March 14, 2014, regarding the Montrose Dense Non-
Aqueous Phase Liquid (DNAPL) Feasibility Study (FS). In your letter you accurately
summarized the agreements reached between the Department of Toxic Substances
Control (DTSC) and the United States Environmental Protection Agency (U.S. EPA)
over the six issues that were raised by DTSC in a letter dated August 21, 2012. These
issues were discussed in meetings between the two agencies on October 26, 2012 and
November 9, 2012.
DTSC appreciates the efforts you and your staff have made to resolve DTSC's
concerns over the proposed DNAPL remedy for the Montrose Superfund Site. DTSC
agrees with the summary of issues and resolution described in your letter and concurs
with the FS.
DTSC looks forward to working with the U.S. EPA on implementation of the Montrose
DNAPL remedy and on developing a performance monitoring program for that remedy.
We also look forward to working with the U.S.EPA to develop a monitoring and
compliance plan for the Montrose and Del Amo Dual Site remedy that will prevent
migration of DNAPL outside the containment zone set forth in the Operable Unit 3
Record of Decision.
If you have any questions, please do not hesitate to contact me at (916) 322-3148 or
John Scandura at (714) 484-5456.
Sincerely,
Stewart W. Black, P.G
cc: See next page.
-------
Ms. Jane Diamond
March 26. 2013
Page 2
cc: (via e-mail)
Mr. John Scandura
Brownfields and Environmental Restoration Program
Department of Toxic Substances Control
iohn.scandura@dtsc.ca.gov
Mr. Safouh Sayed
Brownfields and Environmental Restoration Program
Department of Toxic Substances Control
safouh.sayed@dtsc.ca gov
Mr. Roberg Senga
Brownfields and Environmental Restoration Program
Department of Toxic Substances Control
robert.senga@dtsc.ca.gov
Mr. Ted Peng
Brownfields and Environmental Restoration Program
Department of Toxic Substances Control
ted peng@dtsc.ca.gov
Mr. Scott Warren
Brownfields and Environmental Restoration Program
Department of Toxic Substances Control
scott warren@dtsc ca.gov
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105-3901
March 14, 2013
Mr. Stewart Black
Deputy Director
California Department of Toxic Substances Control
1001 "I" Street
P.O. Box 806
Sacramento, CA 95812-0806
Re: Montrose DNAPL Feasibility Study
Dear Mr. Black:
This letter is in follow up to the U.S. EPA (EPA) and DTSC meetings of October 26,
2012 and November 9, 2012, regarding the revised Feasibility Study (FS) for Dense Non-
Aqueous Phase Liquids (DNAPL) at the Montrose Superfund Site. We appreciate your
participation and attention to this important milestone in cleanup of the Montrose site.
The purpose of these meetings was to discuss issues raised by DTSC on the DNAPL FS.
DTSC submitted comments to EPA regarding the revised DNAPL FS on August 21,
2012. The main issues in the DTSC comments focused on: 1) estimates of DNAPL and
chlorobenzene mass and extent, 2) scope of remedial alternatives and consideration of
additional actions, 3) cost estimates and time frames used in the FS, 4) delineation of
DNAPL, 5) vertical migration of DNAPL, and 6) the need for DDT removal.
This letter summarizes EPA's responses to the issues raised in DTSC's August 2012
comments. On the basis of the conclusions summarized below, EPA intends to finalize
the FS and propose a remedy for the mobile DNAPL detected in the Upper Bellflower
Aquitard (UBA).
1. The DNAPL mass estimates in the FS are based on multiple lines of evidence
collected during rounds of DNAPL reconnaissance and other site-specific
investigations and testing focused primarily on Upper Bellflower Aquitard where
DNAPL is documented. The lines of evidence included visible staining, odor,
soil headspace, FLUTe™ ribbon staining, and soil sample results. The DNAPL
mass estimates developed based on the results of these investigations provide a
reliable basis for the analysis of alternatives in the FS. EPA and DTSC agree that
these mass estimates will be further refined in the design process.
2. In the detailed comments from last summer, DTSC suggested that additional
alternatives be considered (such as excavation, slurry walls, DDT isolation, and/or
a combination of physical and chemical remedial actions). The alternatives in the
n wotf>
-------
2
revised DNAPL FS are based on a comprehensive process of screening
technologies in consultation with the leading experts in the field of NAPL
remediation. As we discussed, the specific technologies mentioned by DTSC
were considered at earlier stages of the FS process and screened out because they
were difficult to implement or not effective for conditions at the Montrose site
(i.e., heterogeneity of subsurface sediments, depth to groundwater, DNAPL
distribution and properties, etc.). EPA and DTSC agree that sufficient evaluation
of the available technologies has been conducted and the FS should be finalized.
3. EPA will include in the FS a cost estimate at a discount rate of 7% for the
anticipated DNAPL mass removal period estimated at 3 to 7 years. As agreed
during the October 26th meeting, the reference to the cost of groundwater
containment included in the current version of the DNAPL FS will be removed to
avoid confusion over long-term O&M costs of the remedy. Hydraulic
containment was selected in the 1999 Record of Decision for the Dual Site
Groundwater Operable Unit and associated O&M costs were addressed in the FS
for that ROD.
4. For the Montrose site, mobile DNAPL was estimated as a residual DNAPL
saturation of greater than 18.9 percent measured in a sandy sample collected at the
site. The area of mobile DNAPL in the UBA was delineated, after numerous soil
borings were drilled during the DNAPL reconnaissance, using the equivalent
threshold concentration of 53 grams per kilogram (g/kg). EPA, with DTSC input,
may further refine this measurement in the remedial design and remedial action
phases, as we work together to modify remedy performance criteria.
5. DTSC remains concerned that currently there is inadequate data and analysis on
DNAPL presence in the Bellflower Sands (BFS). EPA and DTSC agree that
additional monitoring of the BFS is necessary as the project moves forward. The
remedy will be designed to minimize/eliminate the potential downward migration
of DNAPL into the BFS. Additionally a comprehensive monitoring program will
be implemented in coordination with DTSC to ensure that adverse DNAPL
migration into the BFS is not occurring during cleanup. Post-remediation soil
samples will be collected to demonstrate that DNAPL saturations are reduced to
meet the measurement criteria used to define the performance in the future ROD.
6. DTSC is concerned that removal of DDT within the DNAPL is not an explicit
remedial action objective. In the absence of a solvent such as chlorobenzene,
DDT will be relatively immobile in the saturated zone. DDT solubility in
groundwater is very low and, when adsorbed to deep soils (depths exceeding 40 to
60 feet bgs), does not pose a risk to groundwater resources and/or human health
and the environment.
EPA appreciates DTSC's careful examination of the technical information presented in
the FS. In the meetings between EPA and DTSC on October 26 and November 9, 2012,
DTSC agreed that EPA may proceed with finalizing the DNAPL Feasibility Study. EPA
agreed to involve DTSC in the development of the Monitoring and Compliance Plan for
-------
3
the Montrose and Del Amo Dual Site Operable Unit 3 groundwater remedy. EPA also
agreed to coordinate with DTSC on the development of the DNAPL performance
monitoring plan and the verification monitoring program. We are currently developing
the Monitoring and Compliance Plan(s) for the OU3 Dual Site Groundwater remedy,
which my staff mentioned in the meetings with you, and are incorporating comments on
the outline received from your staff.
Thank you for your continued efforts to make the Montrose DNAPL cleanup successful.
We look forward to working with you and your team through the subsequent phases of
this project, including the Proposed Plan, ROD and Remedial Design/Remedial Action.
For questions or discussion, I can be reached at (415) 972-3275 or
— or you may contact Michael Montgomery, Assistant Director, at
(415) 972-3438 or w^u*k»> jiucha;gov.
Sincerely,
Jane Diamond
Director, Superfund Division
U.S. EPA, Region 9
cc: John Scandura, DTSC
Safouh Sayed, DTSC
Robert Senga, DTSC
Ted Peng, DTSC
Scott Warren, DTSC
Joe Kelly, Montrose
-------
m/RD
DIRECTORS
SERGIO CALDERON, president
WttLARD H. MURRAY, JR., vice president
ROB KATHERMAN, secretary
ALBERT ROBLES, treasurer
WA TER REPLENISHMENT DISTRICT J°HN S*ALLEN' °mcim
OF SOUTHERN CALIFORNIA B0BB WH,TAKER^RE- g*rai manager
February J 3, 2015
Attn: Ms. Yarissa Martinez
United Slates Environmental Protection Agency, Region 9
600 Wilshire Blvd. Ste. J460
Los Angeles, CA 90017
Subject: WRD Comments on the Proposed Plan for the Cleanup of DNAPL at the
Montrose Chemical Superfund Site, Los Angeles, California
Dear Ms. Martinez:
The Water Replenishment District of Southern California (WRD) appreciates this opportunity to
submit our comments regarding the United States Environmental Protection Agency's (EPA)
Proposed Plan for the cleanup of dense non-aqueous phase liquid (DNAPL) residing in soil and
groundwater beneath the Montrose Chemical Superfund Site in the City of Los Angeles,
California (DNAPL Proposed Plan). As you are aware, the Site is located within the West Coast
Groundwater Basin (West Coast Basin), a valuable drinking water resource for nearly 1.5 million
residents in the Los Angeles area. Per the California Water Code, WRD is a State special district
tasked with managing groundwater replenishment and preserving high-quality groundwater within
the West Coast Basin, as well as the adjacent Central Basin, These responsibilities make WRD a
primary stakeholder within these basins. As such. WRD has been working closely with the EPA.
as well as State regulator)- agencies, for years to help expedite the investigation and cleanup of the
Montrose Superfund Site as well as other high-priority groundwater contaminated sites, in
particuLu thiough data sharing and review of technical documents.
WRD looks forward to the rapid implementation of a DNAPL remediation plan by EPA that
adequately halts the further spread of contamination in groundwater. To assist WRD in
preparing for our comments, we also reviewed the following:
1.) Final DNAPL Feasibility Study for (he Montrose Superfund Site, prepared by AECOM
and dated September 27, 2013 (DNAPL FS Report) and
2.) Memorandum Regarding the Revised Montrose Dense Non Aqueous Phase Liquid
(DNAPL) Feasibility Study, Los Angeles, CA, prepared by the California Department of
Toxic Substances Control (DTSC) and dated August 21, 2012 (DTSC Memo).
Below are our General and Specific Comments related to EPA's DNAPL Proposed Plan, as well
as the DNAPL FS Report.
4040 Paramount Boulevard. Lakewood, California 90712 (562) P21-5521 Fax (562) 921-6101. www.wid.org
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February 13, 2015
Ms. Yarissa Martinez, EPA Region 9
Page 2 of 7
I. GENERAL COMMENTS
WRD strongly supports all of EPA's remediation objectives for the DNAPL remedy, as
described in the DNAPL Proposed Plan:
1) Prevent human exposure to DNAPL constituents (via ingestion, inhalation, or dermal contact)
that would pose an unacceptable health risk to on or offproperty receptors under industrial
land uses of the Montrose Property and adjacent properties;
2) To the extent practicable, limit uncontrolled lateral and vertical migration of mobile DNAPL
under industrial land use and hydraulic conditions in groundwater;
3) Increase the probability of achieving and maintaining containment of dissolved-phase
contamination to the extent practicable, as required by the existing groundwater ROD, for the
time period that such containment remains necessary;
4) Reduce mobile DNAPL mass to the extent practicable;
5) To the extent practicable, reduce the potential for recontamination of aquifers that have been
restored by the groundwater remedial actions, as required by the groundwater ROD, in the
event containment should fail; and
6) To the extent practicable, reduce the dissolved-phase concentrations within the containment
zone over time.
As discussed in the DNAPL Proposed Plan, EPA selected Alternative 6A - Electrical Resistance
Heating (ERH) treatment for a limited area (i.e. Focused Treatment Area) of the Montrose Site
as the Preferred Alternative, based on the review of six remediation alternatives for DNAPL
cleanup. EPA reported that this Preferred Alternative only address the mass removal/reduction
of "mobile" DNAPL and thus, the proposed cleanup will not address the full extent of all
DNAPL (i.e. mobile and residual) at the Montrose Site. On page 4 of the DNAPL Proposed
Plan, EPA states, " The extent of mobile DNAPL may be further refined, if needed, during the
remedial design and remedial action phases of work, with input from the StateNo other details
were provided to describe how and when the extent of mobile DNAPL would be further refined.
As a public agency entrusted with protecting and preserving groundwater resources in the West
Coast Basin, WRD is very concerned about the limited extent of DNAPL cleanup at the
Montrose Site, as further explained below.
A. Soil and groundwater beneath the Montrose Site is contaminated with DNAPL that
reportedly consists of both DDT and chlorobenzene (also called monochlorobenzene or
MCB). However, EPA's Preferred Alternative (6A) only addresses mobile
chlorobenzene beneath the Focused Treatment Area of the Montrose Site and leaves DDT
in place. Because the chlorobenzene is only being remediated at a limited area of the site,
there remains the potential for the entrained DDT to be remobilized in the future. Thus,
if Alternative 6A is implemented, EPA should consider mass removal of both
chlorobenzene and DDT beneath the Montrose Site; otherwise, Alternative 6B should be
implemented.
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February 13, 2015
Ms. Yarissa Martinez, EPA Region 9
Page 3 of 7
B. WRD is very concerned about the volume/mass of contamination beneath the Site,
especially since it has been confirmed that chlorobenzene has been detected as deep as
the Lynwood Aquifer, a major water supply aquifer in the region. Groundwater
monitoring by the responsible party should resume as soon as possible in order to
continuously assess DNAPL migration both laterally and vertically in the subsurface,
including the Gage and Lynwood Aquifers. Given the extent of documented
contamination beneath the Montrose Superfund Site, as well as the adjacent Del Amo
Superfund Site, and the significant known and potential impacts to the quality of
groundwater in the West Coast Basin, WRD recommends that a full public participation
process be implemented and that the Draft Monitoring and Aquifer Compliance Plan
(MACP) be circulated for a minimum 45-day public review and that a public meeting be
held by the EPA to explain the monitoring plan and to receive public comment for
consideration. At a minimum, the MACP should describe a groundwater monitoring
program that designates adequate monitoring points laterally and vertically and a
monitoring frequency that not only evaluates the overall performance of the Dual Site
Groundwater Treatment System and drinking water protection, but also complete capture
of all DNAPL that can migrate off site.
C. The distinction between mobile and residual DNAPL serves as EPA's entire basis for the
limited DNAPL cleanup at the Montrose Site. On page 4 of the DNAPL Proposed Plan,
EPA states, "DNAPL at the Montrose Property occurs in both "mobile" and "residual"
forms. Mobile DNAPL is a continuous mass of DNAPL that can flow with groundwater
and/or sink under gravitational forces. Residual DNAPL is trapped in the pore spaces of
soil particles and cannot move laterally and/or vertically under natural conditions
According to the FS Report, mobile DNAPL was defined based on physical properties
testing of one soil core sample collected from Boring 2DSB-1 at the site and the lateral
and vertical extent of mobile DNAPL was based on sampling conducted in 2004 (and
prior) and 2008, respectively. Given the current extent of groundwater contamination
downgradient of the site and the confirmed detection of chlorobenzene in the Lynwood
Aquifer, it is possible and likely that mobile DNAPL has extended beyond the Focused
Treatment Area, as defined by EPA in the DNAPL Proposed Plan. Additionally, residual
DNAPL may become mobile as groundwater levels continue to rise. WRD nested
groundwater monitoring well Carson 2 (approximately 2 miles southeast and
downgradient of the Montrose and Del Amo Superfund Sites) show groundwater levels
rising an average of 15 feet over the last 12 years in all underlying aquifers (Gage,
Lynwood, Silverado, and Sunnyside Aquifers).
As a result, WRD recommends that EPA reconsider the Preferred Alternative and select a
treatment alternative that covers the entire 160,000-square foot DNAPL-impacted area.
WRD believes this more conservative approach could not only ensure the success of the
Dual Site Groundwater Remedy, but also better address areas that may now, or expect to,
contain mobile DNAPL should groundwater levels continue to rise in the region. On
page 15 of the DNAPL Proposed Plan, EPA states, "Alternative 6B, ERH treatment of the
entire treatment area [i.e. full extent of both mobile and residual DNAPL at the Montrose
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February 13, 2015
Ms. Yarissa Martinez, EPA Region 9
Page 4 of 7
Site], was ranked lower because it is more difficult to implement due to the larger
treatment volume, and because of the considerably higher cost of this alternative
compared to Alternative 6A [ERH, Focused Treatment Area]." Although Alternative 6B
may cost more than Alternative 6A, Alternative 6B may be conducted in multiple phases
of work, starting with the Focused Treatment Area, and allow EPA the flexibility to
refine the remedial design based on the current full extent of DNAPL. Experience at
many contaminated sites has shown that the best approaches for remediation often
contain a combination of remedial technologies and that within these suites of
technologies, some may be multi-phased in order to neutralize all identified chemicals of
concern.
D. The DNAPL Proposed Plan does not describe the vertical extent of mobile DNAPL, so it
is unclear how deep the Electrical Resistance (ERH) electrodes and multiphase extraction
wells that will be installed as part of the Preferred Alternative - 6A. According to the FS
Report, DNAPL has been found to a total depth of 101.5 feet below ground surface. As
such, the ERH electrodes and extraction wells should be installed at least to depths of
101.5 feet below ground surface.
E. WRD agrees with the following statements on page 5 of the DNAPL Proposed Plan,
. . mobile DNAPL that is present at the former Montrose Plant Property remains a
threat to groundwater and soil vapor, because it is capable of continued vertical and/or
lateral migration outside the TI Waiver Zone. This potential migration of mobile DNAPL
may result in failure of the Groundwater remedy. Removing mobile DNAPL, therefore, is
a critical component in preserving the groundwater resource and ensuring protection of
human health and the environmentTo meet EPA's remediation objective to prevent
uncontrolled migration and the spread of mobile DNAPL, WRD recommends preparation
of a contingency plan to address other areas of the site that may be identified in the future
to contain mobile DNAPL, especially since residual DNAPL may become mobilized due
to rising groundwater levels. It would be very helpful if the contingency plan also
summarized how the Montrose Site will continue to be monitored in the future for mobile
DNAPL and how newly identified mobile DNAPL areas will be remediated.
F. WRD agrees with EPA that the Preferred Alternative should include institutional controls
that restrict future activities at the entire Montrose property for industrial use only, as
described under Alternative 2 in the DNAPL Proposed Plan. In addition to implementing
a formal site inspection and maintenance program that would continuously monitor the
land use and access restrictions, WRD recommends that the institutional controls also
prohibit the use of any chemical, including chlorobenzene, that could re-mobilize or
solubilize the DDT that will remain in place on site.
G. As EPA is aware, the West Coast Basin has complexities with regards to pumping rights,
replenishment needs, replenishment assessments, watermaster duties, and the interests of
the various cities and public/private utilities that supply groundwater to residents and
businesses, in addition to concerned stakeholder groups. As the agency responsible for
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February 13, 2015
Ms. Yarissa Martinez, EPA Region 9
Page 5 of 7
groundwater replenishment and water quality and protection within the West Coast Basin
and Central Basin, WRD requests to be included in future stakeholder discussions and
copied on all technical correspondence regarding the cleanup of the Montrose and Del
Amo Superfund Sites.
II. SPECIFIC COMMENTS
A. Revise Document Title to Accurately Reflect the Scope of the Proposed Plan
The Proposed Plan only addresses confirmed, free phase, mobile chlorobenzene DNAPL
in the Upper Bellflower Aquitard beneath a significantly smaller area of the Site (i.e.
Focused Treatment Area). Based on the limited scope of the DNAPL Proposed Plan,
WRD requests the current title be revised as follows, to more accurately reflect EPA's
current remediation objectives: "Proposed Plan for the Cleanup of Confirmed Mobile
Chlorobenzene DNAPL in the Upper Bellflower Aquitard Beneath a Limited Area of the
Montrose Chemical Superfund Site."
B. Add Section to Proposed Plan Describing the Dual Site Groundwater Operable Unit
EPA's current design of the Preferred Alternative only address the chlorobenzene
component of mobile DNAPL. Thus, residual DNAPL beneath the site, including DDT
and those existing outside the Focused Treatment Area, will remain in place and
potentially could continue to migrate further southeast (downgradient) beyond the limits
of the TI Waiver Zone. As such, the Dual Site Groundwater Treatment System will be a
necessary component of the DNAPL cleanup since it will need to be relied upon to
capture all contaminants that will be migrating off site. WRD recommends that a section
be added to the DNAPL Proposed Plan to describe how the current design of the Dual
Site Groundwater Treatment System will accommodate any contamination, in particular
residual chlorobenzene and DDT, that is anticipated to continue to migrate off site.
C. Duration of Preferred Alternative is Inconsistent
On page 9 of the DNAPL Proposed Plan where Alternative 6A is discussed, the duration
of this treatment is described as "4 to 7 years," while the duration of Alternative 6A is
described as "4 years" on page 14 of the Proposed Plan. Please provide an explanation
on why the duration is inconsistently referenced for the same Alternative. Secondly,
WRD recommends adding a section to the DNAPL Proposed Plan to describe the
measures that will be in place to ensure that all mobile DNAPL has been completely
removed from the Montrose Site, how residual DNAPL will continue to be monitored
throughout the entire site to confirm that it has not become mobilized, and how on-site
areas that are identified to contain mobile DNAPL in the future will be remediated.
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February 13, 2015
Ms. Yarissa Martinez, EPA Region 9
Page 6 of 7
D. Nearest Drinking Water Wells
On page 3 of the DNAPL Proposed Plan, it states the following, "Although the State of
California designates all of the water-bearing units beneath the Montrose property as
having potential potable beneficial use, there are currently no known municipal or
private potable production wells in use within the area of DNAPL distribution and/or
dissolved groundwater contamination at the Montrose Superfund Site. The nearest
municipal supply wells are located more than 2 miles from the Montrose Property, and
about 0.5 to 1 mile southeast from the furthest extent of groundwater contamination
related to the Montrose and Del Amo Superfund SitesAs a clarification, the second
sentence should be revised to add "downgradient," so that the sentence is revised as
follows: "The nearest downgradient municipal supply wells are located more than 2
miles ..." Secondly, EPA may want to consider designating a buffer zone around the
Montrose and Del Amo Superfund Sites and establishing formal notification procedures
for future production wells that may be installed in the area, which could potentially
impact future operations of the Dual Site Groundwater Treatment System.
E. Figures 5 and 8 Are Exactly the Same
Figures 5 and 8 have different titles, but the figures are exactly the same. Based on the
title of Figure 8 ("ERH in the Focused Treatment Area") and the description of Figure 8
under the Preferred Alternative - 6A, it appears that the wrong Figure 8 was inserted into
the DNAPL Proposed Plan. Currently, Figure 8 does not depict or reference ERH within
the figure. Please issue a Revised DNAPL Proposed Plan with the correct Figure 8.
F. Permitting for Reinjection of Treated and Untreated Water
Waters of the State beneath the Site, including the Upper Bellflower Aquitard (UBA),
Middle Bellflower Sand (BFS), Lower Bellflower Aquitard (LBA), Gage Aquifer, and
Lynwood Aquifer, are designated for beneficial use, and therefore must be protected.
WRD strongly opposes the discharge of untreated water into the subsurface that could
further degrade the water quality of these aquifers. With regards to reinjection of treated
water, WRD recommends that the EPA and Los Angeles Regional Water Quality Control
Board adopt limits of "nondetect" for anthropogenic chemicals of concern where no
scientific or regulatory criteria exist, which is in accordance with the State
Antidegradation Policy (Resolution No. 68-16 adopted by the State Water Resources
Control Board on October 28, 1968). The State Anti degradation Policy was established
to maintain aquifers with the "highest water quality consistent with the maximum benefit
to the people of the State" and protect the designated beneficial uses. All reinjection
activities should comply with State Waste Discharge Requirements.
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February !3, 2015
Ms. Yarissa Martinez, EPA Region 9
Page 7 of 7
WRD appreciates the opportunity to comment on the Proposed DNAPL Cleanup Plan and we
trust that our comments are helpful and support EPA's efforts. We look forward to continuing
our close working relationship to expedite groundwater cleanup at the Montrose and Del A mo
Super fund Sites. Please continue to keep us involved on this important project. If you have any
questions regarding this letter, please contact me at lLuhii>:on(t;s\ ixtorg or (562) 275-4240.
Yours truly.
Tdd Johnson, P.G., C.HG
Chief Hydrogeologist
cc: (via e-mail only)
Scott Warren, California Department of Toxic Substances Control
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APPENDIX D DETAILED COSTS FOR THE SELECTED REMEDY
280
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Appendix D
Detailed Costs for the Selected Remedy
This appendix provides Detailed Cost Estimates for the selected remedy for DNAPL OU at the Montrose
Superfund Site. The following tables were originally provided in Appendix J of the Final DNAPL
Feasibility Study (AECOM, 2013) and include:
• Appendix J Table 1.0 — Cost Summary Institutional Controls
• Appendix J Table 5.0 (5.1 through 5.9) — Cost Summary Unsaturated Zone SVE Coupled with
Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
• Appendix J Table 7.0 (7.1 through 7.9) — Cost Summary Unsaturated Zone SVE Coupled with
Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
• Appendix J Table 13.0 (13.1 through 13.9) — Cost Summary ERH (200 kW-hrs/cubic yard) Focused
Treatment Area
• Appendix J Table 14.0 (14.1 through 14.9) — Cost Summary ERH (400 kW-hrs/cubic yard) Focused
Treatment Area
EN1217151028SCO
D-l
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Montrose Superfund Site
Los Angeles, California
Appendix J
Table 1.0
Cost Summary
Institutional Controls
Cost
NPV)
Year
Activity
Cost
(Undiscounted)
DR =
4%
DR =
7%
1
Deed Restriction and Sign Installation - On Property
$ 100,000
S
110.577
S
107.477
Deed Restriction
$ 15,000
2
$ 5,000
S
4.623
S
4.367
3
$ 5,000
s
4.445
s
4.081
4
$ 5,000
s
4.274
s
3.814
5
$ 5,000
s
4.110
s
3.565
6
$ 5,000
s
3.952
s
3.332
7
$ 5,000
s
3.800
s
3.114
8
$ 5,000
s
3.653
s
2.910
9
$ 5,000
s
3.513
s
2.720
10
$ 5,000
s
3.378
s
2.542
11
$ 5,000
s
3.248
s
2.375
12
$ 5,000
s
3.123
s
2.220
13
$ 5,000
s
3.003
s
2.075
14
$ 5,000
s
2.887
s
1.939
15
Deed Restriction Renewal (On and Off Property)
and Fence/Signage Maintenance
$ 5,000
s
2.776
s
1.812
16
$ 5,000
s
2.670
s
1.694
17
$ 5,000
s
2.567
s
1.583
18
$ 5,000
s
2.468
s
1.479
19
$ 5,000
s
2.373
s
1.383
20
$ 5,000
s
2.282
s
1.292
21
$ 5,000
s
2.194
s
1.208
22
$ 5,000
s
2.110
s
1.129
23
$ 5,000
s
2.029
s
1.055
24
$ 5,000
s
1.951
s
986
25
$ 5,000
s
1.876
s
921
26
$ 5,000
s
1.803
s
861
27
$ 5,000
s
1.734
s
805
28
$ 5,000
s
1.667
s
752
29
$ 5,000
s
1.603
s
703
30
$ 5,000
s
1.542
s
657
Net Present Value at 30 Years = | $ 192,229 | $ 164,849
Notes
DR = Discount rate
NPV = Net present value
Final DNAPL Feasibility Study
Institutional Controls
June 2013
J-1.0 Cost Summary, Institutional Controls
Page 1 of 1
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.0
Cost Summary
Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Cost
NPV)
Year
Activity
Detailed Cost Table
Cost
(Undiscounted)
DR= 4%
DR=
7%
1
Design
J-5.1 Design
$ 94,359
S
90.729
S
88.186
J-5.2 Well Construction
$ 188,329
2
System Construction
J-5.3 Well Field Eguipment Installation
$ 60,013
S
447.218
S
422.492
J-5.4 Treatment Eguipment Installation
$ 189,831
J-5.5 Construction Management
$ 45,538
3
Operation and Maintenance - Year 1
J-5.6 Annual O&M - Carbon Regen for Vapor Treatment
$ 449,164
s
399.305
s
366.651
4
Operation and Maintenance - Year 2
$ 653,591
s
558.692
s
498.621
5
Operation and Maintenance - Year 3
J-5.7 Annual O&M - Disposable Carbon for Vapor Treatment
$ 586,491
s
482.053
s
418.160
6
Operation and Maintenance - Year 4
$ 539,411
s
426.304
s
359.432
7
Verification and Abandonment
J-5.8 Well Abandonment
$ 60,764
s
117.372
s
96.186
J-5.9 Demobilization
$ 93,690
Totals|| $ 2,961,178 | S 2.521.673 | S 2.249.7281
Notes
DR = Discount rate
NPV = Net present value
J-5.0 Cost Summary
Page 1 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.1
Detailed Cost, Unsatured Zone SVE
Coupled with Focused Treatment Area Thermal
(2.5 UBA PVs or 200 kW-hrs/cubic yard)
Design
TOTAL DESIGN COST
94,359
Item
Consultant Labor
Quantity
Unit Cost
Cost
1
Project Manager
90
$
150
/Hour
s
13.467
2
Senior Engineer/Geologist
180
$
125
/Hour
s
22.446
3
Mid-Level Engineer/Geologist
360
$
100
/Hour
s
36.000
4
Junior/Field Engineer/Geologist
180
$
75
/Hour
s
13.467
5
Field Technician
0
$
75
/Hour
s
-
6
Clerical/Drafting
180
$
50
/Hour
s
8.978
Consultant Labor
$
94,359
J-5.1 Design Cost
Page 2 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.2
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Well Construction
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
24
$
150
/Hour
$
3,600
2
Senior Engineer/Geologist
24
$
125
/Hour
$
3,000
3
Mid-Level Engineer/Geologist
52
$
100
/Hour
$
5,200
4
Junior/Field Engineer/Geologist
120
$
75
/Hour
$
9,000
5
Field Technician
42
$
75
/Hour
$
3,150
6
Clerical/Drafting
24
$
50
/Hour
$
1,200
Total Consultant Labor Cost
$
25,150
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
HSA Rig Mobilization
1
$ 1,200
/Each
$
1,200
1
8
Palos Verdes Sands SVE Wells (12" HSA Drilling to 45' bgs)
a
Install Well Constructed of 6" LCS Casing w/ 20' of SS Screen
1
$ 8,500
/Each
$
8,500
1
b
Forklift and Hopper Rental for Waste Handling
0.5
$ 250
/Day
$
125
1
c
Drill Crew per Diem
0.5
$ 450
/Night
$
225
1
d
Vehicle Usage
0.5
$ 100
/Day
$
50
e
Equipment Rental and Supplies
0.5
$ 500
/Day
$
250
f
Other Direct Costs
0.5
$ 300
/Day
$
150
Cost per Well
$
9,300
Number of Wells (2 Wells Installed per Day)
7
Subtotal - PVS Wells
$
65,100
J-5.2 Well Construction Cost
Page 3 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.2
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
9
UBA SVE Wells (12" HSA Drilling to 60 bgs)
a
Install Well Constructed of 6" LCS Casing w/15' of SS Screen
1
$ 9,700
/Each
$
9,700
1
b
Forklift and Hopper Rental for Waste Handling
0.5
$ 250
/Day
$
125
1
c
Drill Crew per Diem
0.5
$ 450
/Night
$
225
1
d
Vehicle Usage
0.5
$ 100
/Day
$
50
e
Equipment Rental and Supplies
0.5
$ 500
/Day
$
250
f
Installation Permit
1
$ 201
/Each
$
201
g
Other Direct Costs
0.5
$ 300
/Day
$
150
Cost per Well
$
10,701
Number of Wells (2 Wells Installed per Day)
5
Subtotal - UBA Wells
$
53,505
10
Lab Analytical (Three PVS Borinngs and Four UBA Borings)
a
Soil Analysis - Pesticides (EPA Method 8081 A)
10
$ 90
/Sample
$
900
2
b
Soil Analysis - VOCs (EPA Method 8260B)
10
$ 95
/Sample
$
950
2
c
Soil Analysis - pCBSA (Modified EPA Method 314.0)
10
$ 80
/Sample
$
800
2
d
Water Analysis - Pesticides (EPA Method 8081 A)
2
$ 90
/Sample
$
180
2
e
Water Analysis - VOCs (EPA Method 8260B)
2
$ 95
/Sample
$
190
2
f
Water Analysis - pCBSA (Modified EPA Method 314.0)
2
$ 80
/Sample
$
160
2
Total Lab Analytical (Extraction Wells)
$
3,180
J-5.2 Well Construction Cost
Page 4 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.2
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
11
Waste Management
a
Waste Tank Rental
36
$
38
/Day
$
1,368
3
b
Waste Tank Rental Delivery - Mob and Demob
1
$
900
/Each
$
900
3
c
Waste Bin Rental
60
$
15
/Day
$
900
3
d
Waste Bin Rental Delivery - Mob and Demob
2
$
500
/Each
$
1,000
3
e
Transport of Hazardous Soil Cuttings
2
$
1,100
/Each
$
2,200
3
f
Disposal of Hazardous Soil Cuttings
29
$
550
/Ton
$
15,932
3
g
Transport of Hazardous Water
1
$
1,100
/Each
$
1,100
3
h
Disposal of Hazardous Water
1200
$
0.8
/Gal
$
960
3
i
Waste Characterization/Profiling
2
$
500
/Each
$
1,000
Subtotal - Waste Management
$
25,360
Total Subcontractor Cost w/10% Markup
$
163,179
TOTAL WELL CONSTRUCTION COST $ 188,329 ||
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Verbal Quote from Test America
3 Verbal Quote from NRC Environmental
J-5.2 Well Construction Cost
Page 5 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.3
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Well Field Equipment Installation
Item
Consultant Labor and Direct Costs
Quantity
Unit Cost
Cost
Cost
Ref.
1
a
b
c
d
3
a
b
4
Extraction Well Assemblies
Static Pressure Gage
Temperature Indicator
Flow Sensor
Differential Pressure Gage
12
12
12
12
$ 48
$ 127
$ 121
$ 315
/Each
/Each
/Each
/Each
$ 576
$ 1,524
$ 1,452
$ 3,780
1
1
2
2
3
3
Total Extraction Well Assemblies
SVE Piping
8-Inch Carbon Steel Pipe and Fittings
6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
320
120
$ 94.71
$ 67.65
LF
LF
$ 7,332
$ 30,307
$ 8,118
Total SVE Piping
Pipe Supports
44
$ 200
LF
$ 38,425
$ 8,800
DIRECT COSTS w/10% MARKUP
$ 60,013
| TOTAL WELL FIELD EQUIPMENT INSTALLTION COST $ 60,013
Cost Source Reference
1 Grainger Catalog Price
2 Dwyer Instruments, Inc. Catalog Price
3 Cost in 2008 dollars based on 2006 RS Means and an assumed inflation rate if 3% per year
J-5.3 Well Field Equipment Installation Cost
Page 6 of 16
-------
Final DNAPL Feasibilty Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.4
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Treatment Equipment Installation
Item
Direct Costs
Quantity
Unit Cost
Cost
Cost
Ref.
Carbon Regen System Upgrade (from 5000-lb to vessels to 10000-lb vessels)
1
$
46,000
/ LS
s
46,000
1
Polishing Carbon Vessel Upgrade (from 5000-lb to 10000-lb)
2
$
16,000
/Each
s
32,000
2
Additional Initial Carbon Fill (Virgin Coconut)
10,000
$
1.07
/lb
s
10,700
2
Oriface Plate and Transmitter
1
$
10,000
/Each
s
10,000
Moister Separator
1
$
4,000
/Each
$
4,000
3
Transfer Pump (50 gpm)
1
$
536
/Each
s
536
4
1000 SCFM Positive Displacement Blower (for PVS)
1
$
30,000
/Each
s
30,000
5
300 SCFM Liquid Ring Blower (Hi Vac for UBA)
0
$
45,980
/Each
s
-
5
Inline Stack PID
0
$
3,775
/Each
s
-
6
Static Pressure Gage
3
$
48
/Each
s
144
4
Temperature Indicator
3
$
127
/Each
$
381
4
Interconnecting Piping (10% of Blower, KO Tank, and Regen and Polishing Carbon Vessel Upgrade)
1
$
12,598
LS
s
12,598
Electrical Allowance (20% of elec components)
1
$
8,107
LS
s
8,107
Control System Allowance (20% of elec components)
1
$
8,107
LS
s
8,107
Treatment Plant Pad and Building
0
$
-
LS
s
-
7
Subcontractor Installation Cost
1
$
10,000
LS
$
10,000
TOTAL TREATMENT EQUIPMENT INSTALLATION COST w/10% MARKUP
$
189,831
Cost Source Reference
1 Based on MEGTEC Systems, Inc. Quote Dated April 20, 2008
2 Based on July 1 2008 BakerCorp Quote
3 Verbal Quote from Enviro Supply and Services
4 Grainger Catalog Price
5 Yardley Pump and Vacuum Quote Dated July 16, 2008
6 Verbal Quote from RAE Systems
7 Based on Building/Lab Site Improvements Cost for 350 gpm LGAC Adsorber System in 1998 Joint Groundwater Feasibility Study for the Montrose and Del Amo Sites
J-5.4 Treatment Equipment Installation Cost
Page 7 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013 Appendix J
Table 5.5
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal
(2.5 UBA PVs or 200 kW-hrs/cubic yard)
Construction Management
Item
Consultant Labor
Quantity
Unit Cost
Cost
1
Project Manager
20
$
150
/Hour
$
3.000
2
Senior Engineer/Geologist
45
$
125
/Hour
$
5.625
3
Mid-Level Engineer/Geologist
90
$
100
/Hour
$
8.978
4
Junior/Field Engineer/Geologist
180
$
75
/Hour
$
13.467
5
Field Technician
180
$
75
/Hour
$
13.467
6
Clerical/Drafting
20
$
50
/Hour
$
1.000
TOTAL CONSTRUCTION MANAGEMENT COST
$
45,538
Montrose Superfund Site
Los Angeles, California
J-5.5 Construction Management Cost
Page 8 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June2013 Appendix J
Table 5.6
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Annual Operations and Maintenance (Year 1)
Item
Consultant Labor (Operations)
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
3
4
5
6
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
65
65
130
260
0
0
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 9,750
$ 8,125
$ 13,000
$ 19,500
$
$
Consultant Labor Cost for Operations
S 50.375
Item
Consultant Labor (Reporting, H&S, and Data Mngt)
Quantity
Unit Cost
Cost
Cost
Ref.
7
8
9
10
11
12
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
40
80
160
160
0
160
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 6,000
$ 10,000
$ 16,000
$ 12,000
$
$ 8,000
Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance
S 52.000
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
13
Waste Management
a
Additional Polishing VGAC and regen system VGAC change-outs
45,000
$ 1.53
/lb
$ 68,625
1
b
Additional Carbon Regen System Solvent
i
Transportation
4
$ 3,650
/load
$ 14,600
2
ii
Disposal (Listed Waste for Incineration)
159,870
$ 0.5
/lb
$ 79,935
2
c
Additional Boiler Water Pre-Treatment Brine and Blowdown
i
Transportation
7
$ 950
/10,000 gals
$ 6,650
3
ii
Disposal (non-Haz)
63,009
$ 0.14
/gal
$ 8,821
3
Total Waste Management
S 178.631
J-5.6 Annual Operations and Maintenance (Year 1) Cost
Page 9 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013
Appendix J
Table 5.6
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Annual Operations and Maintenance (Year 1)
Montrose Superfund Site
Los Angeles, California
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
14
a
b
c
15
a
b
Lab Analytical and Monitoring
Summa Can Rental
Vapor VOCs Analysis (EPA TO-15)
Tedlar Bags
48
48
12
$ 40
$ 200
$ 10
/Each
/Each
/Each
$ 1,920
$ 9,600
$ 120
4
4
Total Lab Analytical and Monitoring
Miscellaneous - Year 1
Miscellaneous Parts
Fed Ex and Deliveries
12
12
$ 1,000
$ 100
/Month
/Month
S 11.640
$ 12,000
$ 1,200
Total Miscellaneous - Year 1
S 13.200
Item
Direct Cost
Quantity
Unit Cost
Cost
Cost
Ref.
16
a
b
c
Utilities
Natural Gas (additional Steam for Carbon Regen Unit)
Municipal Water (additional steam for Carbon Regen Unit)
Electricity - PD Vacuum Blower
77,740
750,528
489,925
$ 1.14
$ 0.0029
$ 0.1045
/therm
/gal
/kWh
$ 88,624
$ 2,177
$ 51,197
5
6
Total Utilities
S 141.997
CONSULTANT LABOR COST
S
102.375
SUBCONTRACTOR COST w/10% MARKUP - YEAR 1
S
204.791
UTILITIES COST (NO MARKUP)
141,997
TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 1
S
449.164
Cost Source Reference
1 Based on carbon costs associated with the Montrose Henderson SVE System
2 Clean Harbors Quote Dated October 10, 2007
3 NRC Environmental Seivices, Inc. Email Quote Dated June 30, 2008
4 Verbal Quote from Calscience
5 GN-10, Tier III, SoCal Gas Co. Rate (Effective May 1, 2008)
6 Shedule A-3 LADWP Rate (Second Quarter 2008)
J-5.6 Annual Operations and Maintenance (Year 1) Cost Page 10 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013
Appendix J
Table 5.7
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Annual Operations and Maintenance (Years 2 through 4)
Montrose Superfund Site
Los Angeles, California
Item
Consultant Labor (Operations)
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
52
$ 150
/Hour
$
7,800
2
Senior Engineer/Geologist
52
$ 125
/Hour
$
6,500
3
Mid-Level Engineer/Geologist
208
$ 100
/Hour
$
20,800
4
Junior/Field Engineer/Geologist
520
$ 75
/Hour
$
39,000
5
Field Technician
1,040
$ 75
/Hour
$
78,000
6
Clerical/Drafting
0
$ 50
/Hour
$
-
Consultant Labor Cost for Operations
S 152.100
Item
Consultant Labor (Reporting, H&S, and Data Mngt)
Quantity
Unit Cost
Cost
Cost
Ref.
7
Project Manager
40
$ 150
/Hour
$
6,000
8
Senior Engineer/Geologist
80
$ 125
/Hour
$
10,000
9
Mid-Level Engineer/Geologist
160
$ 100
/Hour
$
16,000
10
Junior/Field Engineer/Geologist
160
$ 75
/Hour
$
12,000
11
Field Technician
0
$ 75
/Hour
$
-
12
Clerical/Drafting
160
$ 50
/Hour
$
8,000
Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance
S 52.000
J-5.7 Annual Operations and Maintenance (Years 2 through 4) Cost
Page 11 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013
Appendix J
Table 5.7
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Annual Operations and Maintenance (Years 2 through 4)
Montrose Superfund Site
Los Angeles, California
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
13
a
b
c
Turnkey VGAC Change-Out Service (incl. fresh VGAC and T&D of spent VGAC as Haz)
Year 2
Year 3
Year 4
140,000
100,000
60,000
$ 1.53
$ 1.53
$ 1.53
/lb VGAC
/lb VGAC
/lb VGAC
$
$
$
213,500
152,500
91,500
1
1
1
14
Final Spent VGAC (40,000 lbs) Transportation and Disposal
40,000
$ 0.46
/lb VGAC
$
18,200
1
Total VGAC (Year 2)
Total VGAC (Year 3)
Total VGAC (Year 4)
s
s
s
213.500
152.500
109.700
15
a
b
c
Lab Analytical and Monitoring
Summa Can Rental
Vapor VOCs Analysis (EPA TO-15)
Tedlar Bags
84
84
12
$ 40
$ 200
$ 10
/Each
/Each
/Each
$
$
$
3,360
16,800
120
2
2
Total Lab Analytical and Monitoring
S 20.280
J-5.7 Annual Operations and Maintenance (Years 2 through 4) Cost
Page 12 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013
Appendix J
Table 5.7
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Annual Operations and Maintenance (Years 2 through 4)
Montrose Superfund Site
Los Angeles, California
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
16
a
b
c
d
e
f
g
Miscellaneous - Years 2 through 4
Temporary Office 24'x60' Rental
Temporary Storage Trailer
Portable Toilet Rental
Miscellaneous Parts
Fed Ex and Deliveries
Temporary office comm. (internet, telephone, fax)
Operator Truck Usage (One Truck per Operator)
12
12
12
12
12
12
260
$ 1,030
$ 149
$ 76
$ 1,000
$ 100
$ 1,000
$ 100
/Month
/Month
/Month
/Month
/Month
/Month
/Day/Truck
$ 12,356
$ 1,784
$ 908
$ 12,000
$ 1,200
$ 12,000
$ 26,000
3
4
5
Total Miscellaneous - Years 2 through 4
S 66.248
Total Subcontractor Cost - Year 2
Total Subcontractor Cost - Year 3
Total Subcontractor Cost - Year 4
S 300.028
S 239.028
S 196.228
Item
Utilities
Quantity
Unit Cost
Cost
Cost
Ref.
17
Utilities
Electricity - PD and Liquid Ring Vacuum Blowers
1,143,158
$ 0.1045
/kWh
$ 119,460
6
Total Utilities
S 119.460
CONSULTANT LABOR COST
SUBCONTRACTOR COST w/10% MARKUP - YEAR 2
SUBCONTRACTOR COST w/10% MARKUP - YEAR 3
SUBCONTRACTOR COST w/10% MARKUP - YEAR 4
UTILITIES COST (NO MARKUP)
TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 2
TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 3
TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 4
204.100
330.031
262.931
215.851
119,460
653.591
586.491
539.411
Cost Source Reference
1 Based on carbon costs associated with the Montrose Henderson SVE System
2 Verbal Quote from Calscience
3 Mobile Mini, Inc. Quote Dated October 11, 2007
4 Verbal Quote from Mobile Mini, Inc.
5 Verbal Quote from A-1 Coast Port-A-Toilet
6 Shedule A-3 LADWP Rate (Second Quarter 2008)
J-5.7 Annual Operations and Maintenance (Years 2 through 4) Cost Page 13 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.8
Detailed Cost, Unsatuared Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Well Abandonment
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
3
4
5
6
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
10
20
20
80
20
20
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 1,500
$ 2,500
$ 2,000
$ 6,000
$ 1,500
$ 1,000
Total Consultant Labor Cost
$ 14,500
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
8
a
b
c
d
e
f
g
Mobilization/Demobilization of Drill Rig
Abandon PVS SVE Wells
Drill out well materials
Pressure grout well
Forklift and mini-hopper
Abandonment Crew per Diem
Vehicle Usage
Equipment Rental and Supplies
Other Direct Costs
Cost per Well
Number of Wells (2 Wells Abandoned per Day)
1
5
45
0.5
0.5
0.5
0.5
0.5
$ 2,000
$ 65
$ 30
$ 500
$ 200
$ 100
$ 150
$ 150
/LS
/Foot
/Foot
/Day
/Night
/Day
/Day
/Day
$ 2,000
$ 325
$ 1,350
$ 250
$ 100
$ 50
$ 75
$ 75
$ 2,225
7
1
1
1
1
1
Total for Extraction Well Adandonment
15,575
J-5.8 Well Abandonment Cost
Page 14 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 5.8
Detailed Cost, Unsatuared Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Well Abandonment
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
9
a
b
c
d
e
f
g
Abandon UBA SVE Wells
Drill out well materials
Pressure grout well
Forklift and mini-hopper
Abandonment Crew per Diem
Vehicle Usage
Equipment Rental and Supplies
Other Direct Costs
Cost per Well
Number of Wells (2 Wells Abandoned per Day)
5
60
0.5
0.5
0.5
0.5
0.5
$ 65
$ 30
$ 500
$ 200
$ 100
$ 150
$ 150
/Foot
/Foot
/Day
/Night
/Day
/Day
/Day
$ 325
$ 1,800
$ 250
$ 100
$ 50
$ 75
$ 75
$ 2,675
5
1
1
1
1
Total for Injection Well Abandonment
13,375
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
10
a
b
c
d
e
f
g
h
i
j
Waste Management
Waste Tank Rental
Waste Tank Rental Delivery - Mob and Demob
Waste Bin Rental
Waste Bin Rental Delivery - Mob and Demob
Transport and Disposal/Recycling of Steel
Transport of Hazardous Soil Cuttings
Disposal of Hazardous Soil Cuttings
Transport of Hazardous Water
Disposal of Hazardous Water
Waste Characterization/Profiling
36
1
36
2
1
1
3.71
1
1200
2
$ 38
$ 900
$ 15
$ 500
$ 1,100
$ 1,100
$ 550
$ 1,100
$ 0.8
$ 500
/Day
/Each
/Day
/Each
/Load
/Each
/Ton
/Each
/Gal
/Each
$ 1,368
$ 900
$ 540
$ 1,000
$ 1,100
$ 1,100
$ 2,040
$ 1,100
$ 960
$ 1,000
2
2
2
2
2
2
2
2
Total Waste Management
$ 11,108
Total Subcontractor Cost w/10% Markup
$ 46,264
TOTAL WELL ABANDONMENT COST $ 60,764
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Verbal Quote from NRC Environmental Services
J-5.8 Well Abandonment Cost
Page 15 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (Coupled with Thermal Remedy) Los Angeles, California
June2013 Appendix J
Table 5.9
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Demobilization
Item Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1 Project Manager
2 Senior Engineer/Geologist
3 Mid-Level Engineer/Geologist
4 Junior/Field Engineer/Geologist
5 Field Technician
6 Clerical/Drafting
8
20
40
120
50
20
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 1,200
$ 2,500
$ 4,000
$ 9,000
$ 3,750
$ 1,000
Consultant Labor Cost
S 21.450
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
8
9
a
b
c
d
e
f
g
h
i
Remove Purchased Treatment Equipment
Demob Office Trailer
Close-Out Borings
Drilling and backfilling (6-Inch Sonic to 45 feet bgs at $65/foot)
Drilling and backfilling (6-Inch Sonic to 60 feet bgs at $65/foot)
Disposal of Hazardous Soil Cuttings
Transportation of Hazardous Soil Cuttings
Waste Bin Rental Delivery - Mob and Demob
Waste Bin Rental
Soil Pesticides (EPA Method 8081 A)
Soil VOCs (EPA Method 8260B)
Soil pCBSA (Modified EPA Method 314.0)
1
1
3
2
3.0
1
1
30
10
10
10
41,000
$ 1,746
$ 2,925
$ 3,900
$ 550
$ 1,100
$ 500
$ 15
$ 90
$ 95
$ 80
/LS
LS
/Boring
/Boring
/Ton
/Each
/Each
/Day
/Sample
/Sample
/Sample
S 41.000
S 1.746
$ 8,775
$ 7,800
$ 1,651
$ 1,100
$ 500
$ 450
$ 900
$ 950
$ 800
1
2
2
3
3
3
3
4
4
4
Total for Close-Out Borings
S 22.926
Total Subcontractor Cost w/10% Markup
S 72.240
TOTAL DEMOBILIZATION COST S 93.690
Cost Source Reference
1 Mobile Mini, Inc. Quote Dated October 11, 2007
2 Water Development Corporation Quote Dated 10/09/08
3 Verbal Quote from NRC Environmental Services
4 Verbal Quote from Test America
J-5.9 Demobilization Cost
Page 16 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.0
Cost Summary
Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Cost
NPV)
Year
Activity
Detailed Cost Table
Cost
(Undiscounted)
DR= 4%
DR=
7%
1
Design
J-7.1 Design
$ 94,359
S
90.729
S
88.186
J-7.2 Well Construction
$ 188,329
2
System Construction
J-7.3 Well Field Eguipment Installation
$ 60,013
S
447.218
S
422.492
J-7.4 Treatment Eguipment Installation
$ 189,831
J-7.5 Construction Management
$ 45,538
3
Operation and Maintenance - Year 1
J-7.6 Annual O&M - Carbon Regen for Vapor Treatment
$ 468,191
s
416.220
s
382.183
4
Operation and Maintenance - Year 2
J-7.6 Annual O&M - Carbon Regen for Vapor Treatment
$ 387,467
s
331.209
s
295.597
5
Operation and Maintenance - Year 3
J-7.7 Annual O&M - Disposable Carbon for Vapor Treatment
$ 586,491
s
482.053
s
418.160
6
Operation and Maintenance - Year 4
J-7.7 Annual O&M - Disposable Carbon for Vapor Treatment
$ 539,411
s
426.304
s
359.432
7
Verification and Abandonment
J-7.8 Well Abandonment
$ 60,764
s
117.372
s
96.186
J-7.9 Demobilization
$ 93,690
Totals|| $ 2,714,082 | S 2.311.104 | S 2.062.2351
Notes
DR = Discount rate
NPV = Net present value
J-7.0 Cost Summary
Page 1 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.1
Detailed Cost, Unsatured Zone SVE
Coupled with Focused Treatment Area Thermal
(6 UBA PVs or 400 kW-hrs/cubic yard)
Design
TOTAL DESIGN COST
94,359
Item
Consultant Labor
Quantity
Unit Cost
Cost
1
Project Manager
90
$
150
/Hour
s
13.467
2
Senior Engineer/Geologist
180
$
125
/Hour
s
22.446
3
Mid-Level Engineer/Geologist
360
$
100
/Hour
s
36.000
4
Junior/Field Engineer/Geologist
180
$
75
/Hour
s
13.467
5
Field Technician
0
$
75
/Hour
s
-
6
Clerical/Drafting
180
$
50
/Hour
s
8.978
Consultant Labor
$
94,359
J-7.1 Design Cost
Page 2 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.2
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Well Construction
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
24
$
150
/Hour
$
3,600
2
Senior Engineer/Geologist
24
$
125
/Hour
$
3,000
3
Mid-Level Engineer/Geologist
52
$
100
/Hour
$
5,200
4
Junior/Field Engineer/Geologist
120
$
75
/Hour
$
9,000
5
Field Technician
42
$
75
/Hour
$
3,150
6
Clerical/Drafting
24
$
50
/Hour
$
1,200
Total Consultant Labor Cost
$
25,150
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
HSA Rig Mobilization
1
$ 1,200
/Each
$
1,200
1
8
Palos Verdes Sands SVE Wells (12" HSA Drilling to 45' bgs)
a
Install Well Constructed of 6" LCS Casing w/ 20' of SS Screen
1
$ 8,500
/Each
$
8,500
1
b
Forklift and Hopper Rental for Waste Handling
0.5
$ 250
/Day
$
125
1
c
Drill Crew per Diem
0.5
$ 450
/Night
$
225
1
d
Vehicle Usage
0.5
$ 100
/Day
$
50
e
Equipment Rental and Supplies
0.5
$ 500
/Day
$
250
f
Other Direct Costs
0.5
$ 300
/Day
$
150
Cost per Well
$
9,300
Number of Wells (2 Wells Installed per Day)
7
Subtotal - PVS Wells
$
65,100
J-7.2 Well Construction Cost
Page 3 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.2
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
9
UBA SVE Wells (12" HSA Drilling to 60 bgs)
a
Install Well Constructed of 6" LCS Casing w/15' of SS Screen
1
$ 9,700
/Each
$
9,700
1
b
Forklift and Hopper Rental for Waste Handling
0.5
$ 250
/Day
$
125
1
c
Drill Crew per Diem
0.5
$ 450
/Night
$
225
1
d
Vehicle Usage
0.5
$ 100
/Day
$
50
e
Equipment Rental and Supplies
0.5
$ 500
/Day
$
250
f
Installation Permit
1
$ 201
/Each
$
201
g
Other Direct Costs
0.5
$ 300
/Day
$
150
Cost per Well
$
10,701
Number of Wells (2 Wells Installed per Day)
5
Subtotal - UBA Wells
$
53,505
10
Lab Analytical (Three PVS Borinngs and Four UBA Borings)
a
Soil Analysis - Pesticides (EPA Method 8081 A)
10
$ 90
/Sample
$
900
2
b
Soil Analysis - VOCs (EPA Method 8260B)
10
$ 95
/Sample
$
950
2
c
Soil Analysis - pCBSA (Modified EPA Method 314.0)
10
$ 80
/Sample
$
800
2
d
Water Analysis - Pesticides (EPA Method 8081 A)
2
$ 90
/Sample
$
180
2
e
Water Analysis - VOCs (EPA Method 8260B)
2
$ 95
/Sample
$
190
2
f
Water Analysis - pCBSA (Modified EPA Method 314.0)
2
$ 80
/Sample
$
160
2
Total Lab Analytical (Extraction Wells)
$
3,180
J-7.2 Well Construction Cost
Page 4 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.2
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
11
Waste Management
a
Waste Tank Rental
36
$
38
/Day
$
1,368
3
b
Waste Tank Rental Delivery - Mob and Demob
1
$
900
/Each
$
900
3
c
Waste Bin Rental
60
$
15
/Day
$
900
3
d
Waste Bin Rental Delivery - Mob and Demob
2
$
500
/Each
$
1,000
3
e
Transport of Hazardous Soil Cuttings
2
$
1,100
/Each
$
2,200
3
f
Disposal of Hazardous Soil Cuttings
29
$
550
/Ton
$
15,932
3
g
Transport of Hazardous Water
1
$
1,100
/Each
$
1,100
3
h
Disposal of Hazardous Water
1200
$
0.8
/Gal
$
960
3
i
Waste Characterization/Profiling
2
$
500
/Each
$
1,000
Subtotal - Waste Management
$
25,360
Total Subcontractor Cost w/10% Markup
$
163,179
TOTAL WELL CONSTRUCTION COST $ 188,329 1
Cost Source Reference
1
Verbal
Quote
from
Water Development Corporation
2
Verbal
Quote
from
Test America
3
Verbal
Quote
from
NRC Environmental
J-7.2 Well Construction Cost
Page 5 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.3
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Well Field Equipment Installation
Item
Consultant Labor and Direct Costs
Quantity
Unit Cost
Cost
Cost
Ref.
1
a
b
c
d
3
a
b
4
Extraction Well Assemblies
Static Pressure Gage
Temperature Indicator
Flow Sensor
Differential Pressure Gage
12
12
12
12
$ 48
$ 127
$ 121
$ 315
/Each
/Each
/Each
/Each
$ 576
$ 1,524
$ 1,452
$ 3,780
1
1
2
2
3
3
Total Extraction Well Assemblies
SVE Piping
8-Inch Carbon Steel Pipe and Fittings
6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
320
120
$ 94.71
$ 67.65
LF
LF
$ 7,332
$ 30,307
$ 8,118
Total SVE Piping
Pipe Supports
44
$ 200
LF
$ 38,425
$ 8,800
DIRECT COSTS w/10% MARKUP
$ 60,013
| TOTAL WELL FIELD EQUIPMENT INSTALLTION COST $ 60,013
Cost Source Reference
1 Grainger Catalog Price
2 Dwyer Instruments, Inc. Catalog Price
3 Cost in 2008 dollars based on 2006 RS Means and an assumed inflation rate if 3% per year
J-7.3 Well Field Equipment Installation Cost
Page 6 of 16
-------
Final DNAPL Feasibilty Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.4
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Treatment Equipment Installation
Item
Direct Costs
Quantity
Unit Cost
Cost
Cost
Ref.
Carbon Regen System Upgrade (from 5000-lb to vessels to 10000-lb vessels)
1
$
46,000
/ LS
s
46,000
1
Polishing Carbon Vessel Upgrade (from 5000-lb to 10000-lb)
2
$
16,000
/Each
s
32,000
2
Additional Initial Carbon Fill (Virgin Coconut)
10,000
$
1.07
/lb
s
10,700
2
Oriface Plate and Transmitter
1
$
10,000
/Each
s
10,000
Moister Separator
1
$
4,000
/Each
$
4,000
3
Transfer Pump (50 gpm)
1
$
536
/Each
s
536
4
1000 SCFM Positive Displacement Blower (for PVS)
1
$
30,000
/Each
s
30,000
5
300 SCFM Liquid Ring Blower (Hi Vac for UBA)
0
$
45,980
/Each
s
-
5
Inline Stack PID
0
$
3,775
/Each
s
-
6
Static Pressure Gage
3
$
48
/Each
s
144
4
Temperature Indicator
3
$
127
/Each
$
381
4
Interconnecting Piping (10% of Blower, KO Tank, and Regen and Polishing Carbon Vessel Upgrade)
1
$
12,598
LS
s
12,598
Electrical Allowance (20% of elec components)
1
$
8,107
LS
s
8,107
Control System Allowance (20% of elec components)
1
$
8,107
LS
s
8,107
Treatment Plant Pad and Building
0
$
-
LS
s
-
7
Subcontractor Installation Cost
1
$
10,000
LS
$
10,000
TOTAL TREATMENT EQUIPMENT INSTALLATION COST w/10% MARKUP
$
189,831
Cost Source Reference
1 Based on MEGTEC Systems, Inc. Quote Dated April 20, 2008
2 Based on July 1 2008 BakerCorp Quote
3 Verbal Quote from Enviro Supply and Services
4 Grainger Catalog Price
5 Yardley Pump and Vacuum Quote Dated July 16, 2008
6 Verbal Quote from RAE Systems
7 Based on Building/Lab Site Improvements Cost for 350 gpm LGAC Adsorber System in 1998 Joint Groundwater Feasibility Study for the Montrose and Del Amo Sites
J-7.4 Treatment Equipment Installation Cost
Page 7 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013 Appendix J
Table 7.5
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal
(6 UBA PVs or 400 kW-hrs/cubic yard)
Construction Management
Item
Consultant Labor
Quantity
Unit Cost
Cost
1
Project Manager
20
$
150
/Hour
$
3.000
2
Senior Engineer/Geologist
45
$
125
/Hour
$
5.625
3
Mid-Level Engineer/Geologist
90
$
100
/Hour
$
8.978
4
Junior/Field Engineer/Geologist
180
$
75
/Hour
$
13.467
5
Field Technician
180
$
75
/Hour
$
13.467
6
Clerical/Drafting
20
$
50
/Hour
$
1.000
TOTAL CONSTRUCTION MANAGEMENT COST
$
45,538
Montrose Superfund Site
Los Angeles, California
J-7.5 Construction Management Cost
Page 8 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013
Appendix J
Table 7.6
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal -6 UBA PVs or 400 kW-hrs/cubic yard
Annual Operations and Maintenance (Years 1 through 2)
Item
Consultant Labor (Operations)
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
3
4
5
6
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
65
65
130
260
0
0
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
Consultant Labor Cost for Operations
$ 50,375
Item
Consultant Labor (Reporting, H&S, and Data Mngt)
Quantity
Unit Cost
Cost
Cost
Ref.
7
8
9
10
11
12
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
40
80
160
160
0
160
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance
$ 52,000
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
13
Waste Management
a
Additional Polishing VGAC and regen system VGAC change-outs
Year 1
Year 2
45,000
45,000
$ 1.53
$ 1.53
/lb
/lb
68.625
1
b
ii
Additional Carbon Regen System Solvent
Year 1
Transportation
Disposal (Listed Waste for Incineration)
4
159,870
$ 3,650
$ 0.5
/load
/lb
14.600
79.935
2
2
Year 2
Transportation
Disposal (Listed Waste for Incineration)
1
35,000
$ 3,650
$ 0.5
/load
/lb
17,500
c
ii
Additional Boiler Water Pre-Treatment Brine and Blowdown
Transportation
Disposal (non-Haz)
7
63,009
$ 950
$ 0.14
/10,000 gals
/gal
6,650
8.821
3
3
Total Waste Management - Year 1
$
178,631
Total Waste Management - Year 2
$ 105,246
J-7.6 Annual Operations and Maintenance (Years 1 and 2) Cost
Page 9 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013
Appendix J
Table 7.6
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal -6 UBA PVs or 400 kW-hrs/cubic yard
Annual Operations and Maintenance (Years 1 through 2)
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
14
a
b
c
15
a
b
Lab Analytical and Monitoring
Summa Can Rental
Vapor VOCs Analysis (EPA TO-15)
Tedlar Bags
48
48
12
$ 40
$ 200
$ 10
/Each
/Each
/Each
4
4
Total Lab Analytical and Monitoring
Miscellaneous - Years 1 and 2
Miscellaneous Parts
Fed Ex and Deliveries
12
12
$ 1,000
$ 100
/Month
/Month
$ 11,640
Total Miscellaneous - Years 1 and 2
$ 13,200
Item
Direct Cost
Quantity
Unit Cost
Cost
Cost
Ref.
16
a
b
c
Utilities
Natural Gas (additional Steam for Carbon Regen Unit)
Municipal Water (additional steam for Carbon Regen Unit)
Electricity - PD Vacuum Blower
77,740
750,528
489,925
$ 1.14
$ 0.0029
$ 0.1045
/therm
/gal
/kWh
S 8&.OZ4
S 51.197
5
6
Total Utilities
$ 141,997
CONSULTANT LABOR COST
$
102,375
SUBCONTRACTOR COST w/10% MARKUP - YEAR 1
$
223,818
SUBCONTRACTOR COST w/10% MARKUP - YEAR 2
$
143,095
UTILITIES COST (NO MARKUP)
$
141,997
TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 1
$
468,191
TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 2
$
387,467
Cost Source Reference
1 Based on carbon costs associated with the Montrose Henderson SVE System
2 Clean Harbors Quote Dated October 10, 2007
3 NRC Environmental Services, Inc. Email Quote Dated June 30, 2008
4 Verbal Quote from Calscience
5 GN-10, Tier III, SoCal Gas Co. Rate (Effective May 1, 2008)
6 Shedule A-3 LADWP Rate (Second Quarter 2008)
J-7.6 Annual Operations and Maintenance (Years 1 and 2) Cost
Page 10 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013
Appendix J
Table 7.7
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Annual Operations and Maintenance (Years 3 through 4)
Montrose Superfund Site
Los Angeles, California
Item
Consultant Labor (Operations)
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
52
$ 150
/Hour
$
7,800
2
Senior Engineer/Geologist
52
$ 125
/Hour
$
6,500
3
Mid-Level Engineer/Geologist
208
$ 100
/Hour
$
20,800
4
Junior/Field Engineer/Geologist
520
$ 75
/Hour
$
39,000
5
Field Technician
1,040
$ 75
/Hour
$
78,000
6
Clerical/Drafting
0
$ 50
/Hour
$
-
Consultant Labor Cost for Operations
S 152.100
Item
Consultant Labor (Reporting, H&S, and Data Mngt)
Quantity
Unit Cost
Cost
Cost
Ref.
7
Project Manager
40
$ 150
/Hour
$
6,000
8
Senior Engineer/Geologist
80
$ 125
/Hour
$
10,000
9
Mid-Level Engineer/Geologist
160
$ 100
/Hour
$
16,000
10
Junior/Field Engineer/Geologist
160
$ 75
/Hour
$
12,000
11
Field Technician
0
$ 75
/Hour
$
-
12
Clerical/Drafting
160
$ 50
/Hour
$
8,000
Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance
S 52.000
J-7.7 Annual Operations and Maintenance (Years 3 through 4) Cost
Page 11 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013
Appendix J
Table 7.7
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Annual Operations and Maintenance (Years 3 through 4)
Montrose Superfund Site
Los Angeles, California
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
13
Turnkey VGAC Change-Out Service (incl. fresh VGAC and T&D of spent VGAC as Haz)
b
c
Year 3
Year 4
100,000
60,000
$ 1.53
$ 1.53
/lb VGAC
/lb VGAC
$
$
152,500
91,500
1
1
14
Final Spent VGAC (40,000 lbs) Transportation and Disposal
40,000
$ 0.46
/lb VGAC
$
18,200
1
Total VGAC (Year 3)
Total VGAC (Year 4)
s
s
152.500
109.700
15
a
b
c
Lab Analytical and Monitoring
Summa Can Rental
Vapor VOCs Analysis (EPA TO-15)
Tedlar Bags
84
84
12
$ 40
$ 200
$ 10
/Each
/Each
/Each
$
$
$
3,360
16,800
120
2
2
Total Lab Analytical and Monitoring
S 20.280
J-7.7 Annual Operations and Maintenance (Years 3 through 4) Cost
Page 12 of 16
-------
Final DNAPL Feasibility Study
Unsaturated Zone SVE (with Thermal)
June 2013
Appendix J
Table 7.7
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Annual Operations and Maintenance (Years 3 through 4)
Montrose Superfund Site
Los Angeles, California
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
16
a
b
c
d
e
f
g
Miscellaneous - Years 3 through 4
Temporary Office 24'x60' Rental
Temporary Storage Trailer
Portable Toilet Rental
Miscellaneous Parts
Fed Ex and Deliveries
Temporary office comm. (internet, telephone, fax)
Operator Truck Usage (One Truck per Operator)
12
12
12
12
12
12
260
$ 1,030
$ 149
$ 76
$ 1,000
$ 100
$ 1,000
$ 100
/Month
/Month
/Month
/Month
/Month
/Month
/Day/Truck
$ 12,356
$ 1,784
$ 908
$ 12,000
$ 1,200
$ 12,000
$ 26,000
3
4
5
Total Miscellaneous - Years 2 through 4
S 66.248
Total Subcontractor Cost - Year 3
Total Subcontractor Cost - Year 4
S 239.028
S 196.228
Item
Utilities
Quantity
Unit Cost
Cost
Cost
Ref.
17
Utilities
Electricity - PD and Liquid Ring Vacuum Blowers
1,143,158
$ 0.1045
/kWh
$ 119,460
6
Total Utilities
S 119.460
CONSULTANT LABOR COST
SUBCONTRACTOR COST w/10% MARKUP - YEAR 3
SUBCONTRACTOR COST w/10% MARKUP - YEAR 4
UTILITIES COST (NO MARKUP)
TOTAL OPERATIONS AND MAINTENANCE COST ¦
TOTAL OPERATIONS AND MAINTENANCE COST ¦
YEAR 3
YEAR 4
204.100
262.931
215.851
586.491
539.411
Cost Source Reference
1 Based on carbon costs associated with the Montrose Henderson SVE System
2 Verbal Quote from Calscience
3 Mobile Mini, Inc. Quote Dated October 11, 2007
4 Verbal Quote from Mobile Mini, Inc.
5 Verbal Quote from A-1 Coast Port-A-Toilet
6 Shedule A-3 LADWP Rate (Second Quarter 2008)
J-7.7 Annual Operations and Maintenance (Years 3 through 4) Cost Page 13 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.8
Detailed Cost, Unsatuared Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Well Abandonment
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
3
4
5
6
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
10
20
20
80
20
20
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 1,500
$ 2,500
$ 2,000
$ 6,000
$ 1,500
$ 1,000
Total Consultant Labor Cost
$ 14,500
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
8
a
b
c
d
e
f
g
Mobilization/Demobilization of Drill Rig
Abandon PVS SVE Wells
Drill out well materials
Pressure grout well
Forklift and mini-hopper
Abandonment Crew per Diem
Vehicle Usage
Equipment Rental and Supplies
Other Direct Costs
Cost per Well
Number of Wells (2 Wells Abandoned per Day)
1
5
45
0.5
0.5
0.5
0.5
0.5
$ 2,000
$ 65
$ 30
$ 500
$ 200
$ 100
$ 150
$ 150
/LS
/Foot
/Foot
/Day
/Night
/Day
/Day
/Day
$ 2,000
$ 325
$ 1,350
$ 250
$ 100
$ 50
$ 75
$ 75
$ 2,225
7
1
1
1
1
1
Total for Extraction Well Adandonment
15,575
J-7.8 Well Abandonment Cost
Page 14 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (with Thermal) Los Angeles, California
June 2013 Appendix J
Table 7.8
Detailed Cost, Unsatuared Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Well Abandonment
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
9
a
b
c
d
e
f
g
Abandon UBA SVE Wells
Drill out well materials
Pressure grout well
Forklift and mini-hopper
Abandonment Crew per Diem
Vehicle Usage
Equipment Rental and Supplies
Other Direct Costs
Cost per Well
Number of Wells (2 Wells Abandoned per Day)
5
60
0.5
0.5
0.5
0.5
0.5
$ 65
$ 30
$ 500
$ 200
$ 100
$ 150
$ 150
/Foot
/Foot
/Day
/Night
/Day
/Day
/Day
$ 325
$ 1,800
$ 250
$ 100
$ 50
$ 75
$ 75
$ 2,675
5
1
1
1
1
Total for Injection Well Abandonment
13,375
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
10
a
b
c
d
e
f
g
h
i
j
Waste Management
Waste Tank Rental
Waste Tank Rental Delivery - Mob and Demob
Waste Bin Rental
Waste Bin Rental Delivery - Mob and Demob
Transport and Disposal/Recycling of Steel
Transport of Hazardous Soil Cuttings
Disposal of Hazardous Soil Cuttings
Transport of Hazardous Water
Disposal of Hazardous Water
Waste Characterization/Profiling
36
1
36
2
1
1
3.71
1
1200
2
$ 38
$ 900
$ 15
$ 500
$ 1,100
$ 1,100
$ 550
$ 1,100
$ 0.8
$ 500
/Day
/Each
/Day
/Each
/Load
/Each
/Ton
/Each
/Gal
/Each
$ 1,368
$ 900
$ 540
$ 1,000
$ 1,100
$ 1,100
$ 2,040
$ 1,100
$ 960
$ 1,000
2
2
2
2
2
2
2
2
Total Waste Management
$ 11,108
Total Subcontractor Cost w/10% Markup
$ 46,264
TOTAL WELL ABANDONMENT COST $ 60,764
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Verbal Quote from NRC Environmental Services
J-7.8 Well Abandonment Cost
Page 15 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
Unsaturated Zone SVE (Coupled with Thermal Remedy) Los Angeles, California
June2013 Appendix J
Table 7.9
Detailed Cost, Unsaturated Zone SVE
Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Demobilization
Item Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1 Project Manager
2 Senior Engineer/Geologist
3 Mid-Level Engineer/Geologist
4 Junior/Field Engineer/Geologist
5 Field Technician
6 Clerical/Drafting
8
20
40
120
50
20
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 1,200
$ 2,500
$ 4,000
$ 9,000
$ 3,750
$ 1,000
Consultant Labor Cost
S 21.450
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
8
9
a
b
c
d
e
f
g
h
i
Remove Purchased Treatment Equipment
Demob Office Trailer
Close-Out Borings
Drilling and backfilling (6-Inch Sonic to 45 feet bgs at $65/foot)
Drilling and backfilling (6-Inch Sonic to 60 feet bgs at $65/foot)
Disposal of Hazardous Soil Cuttings
Transportation of Hazardous Soil Cuttings
Waste Bin Rental Delivery - Mob and Demob
Waste Bin Rental
Soil Pesticides (EPA Method 8081 A)
Soil VOCs (EPA Method 8260B)
Soil pCBSA (Modified EPA Method 314.0)
1
1
3
2
3.0
1
1
30
10
10
10
41,000
$ 1,746
$ 2,925
$ 3,900
$ 550
$ 1,100
$ 500
$ 15
$ 90
$ 95
$ 80
/LS
LS
/Boring
/Boring
/Ton
/Each
/Each
/Day
/Sample
/Sample
/Sample
S 41.000
S 1.746
$ 8,775
$ 7,800
$ 1,651
$ 1,100
$ 500
$ 450
$ 900
$ 950
$ 800
1
2
2
3
3
3
3
4
4
4
Total for Close-Out Borings
S 22.926
Total Subcontractor Cost w/10% Markup
S 72.240
TOTAL DEMOBILIZATION COST S 93.690
Cost Source Reference
1 Mobile Mini, Inc. Quote Dated October 11, 2007
2 Water Development Corporation Quote Dated 10/09/08
3 Verbal Quote from NRC Environmental Services
4 Verbal Quote from Test America
J-7.9 Demobilization Cost
Page 16 of 16
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area AppGndix J
June2013 Table 13.0
Cost Summary
ERH (200 kW-hrs/cubic yard)
Focused Treatment Area
Cost
NPV)
Year
Activity
Detailed Cost Table
Cost
(Undiscountech
DR = 4%
DR = 7%
1
Focused Treatment Design
J-13.1 Design and Permitting Cost
$ 1,160,300
$ 1,115,673
$ 1,084,393
2
Focused Treatment Build
J-13.2 Well Construction
$ 3,996,515
$ 9,050,943
$ 8,550,529
J-13.3 Well Field Equipment Installation
$ 2,170,154
J-13.4 Instrumentation and Controls Installation
$ 64,124
J-13.5 Treatment Equipment Installation
$ 3,160,979
J-13.6 Construction Management
$ 397,728
3
Focused Treatment Operation and Maintenance
J-13.7 Operations and Maintenance
$ 6,063,104
$ 5,390,077
$ 4,949,299
4
Verification and Abandonment
J-13.8 Well Abandonment
$ 1,411,846
$ 1,819,759
$ 1,624,098
J-13.9 Demobilization
$ 717,015
Totals||"$ 19,141,765 1$ 17,376,453 | $ 16,208,3181
Notes
DR = Discount rate
NPV = Net present value
J-13.0 Cost Summary
Page 1 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
June 2013 Table 13.1
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Design and Permitting
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
790
$
150
/Hour
$
118,500
2
Senior Engineer/Geologist
1,170
$
125
/Hour
$
146,250
3
Mid-Level Engineer/Geologist
4,600
$
100
/Hour
$
460,000
4
Junior/Field Engineer/Geologist
3,310
$
75
/Hour
$
248,250
5
Field Technician
0
$
75
/Hour
$
-
6
Clerical/Drafting
1,106
$
50
/Hour
$
55,300
Consultant Labor
$
1,028,300
TOTAL DESIGN AND PERMITTING COST $ 1,160,300
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
1
Outside Thermal Expert
1
$120,000
/LS
$ 120,000
Subcontractor Costw/10% Markup
$ 132,000
J-13.1 Design and Permitting Cost
Page 2 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 13.2
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Construction
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
507
$
150
/Hour
$
76,050
2
Senior Engineer/Geologist
507
$
125
/Hour
$
63,375
3
Mid-Level Engineer/Geologist
1,352
$
100
/Hour
$
135,200
4
Junior/Field Engineer/Geologist
3,050
$
75
/Hour
$
228,750
5
Field Technician
482
$
75
/Hour
$
36,150
6
Clerical/Drafting
507
$
50
/Hour
$
25,350
Total Consultant Labor Cost
$
564,875
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
Abandon Existing Site Wells Prior to Thermal Treatment
a
Drill out well materials
90
$ 65
/Foot
$ 5,850
1
b
Grout resulting boring
90
$ 30
/Foot
$ 2,700
1
c
Forklift and mini-hopper
1
$ 500
/Day
$ 500
1
d
Excavate and remove well box
1
$ 2,000
/LS
$ 2,000
1
e
Abandonment Crew per Diem
1
$ 200
/Night
$ 200
f
Vehicle Usage
1
$ 100
/Day
$ 100
g
Equipment Rental and Supplies
1
$ 150
/Day
$ 150
h
Other Direct Costs
1
$ 150
/Day
$ 150
Cost per Well
$ 11,650
Number of Wells
5
Total for Existing Site Well Abandonment
$ 58,250
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-13.2 Well Construction Cost
Page 3 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 13.2
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
8
UBA Multi-Phase Extraction Wells (12" HSA Drilling to 108' bgs)
a
Install Well Constructed of 6" LCS Casing w/ 60' of
SS Screen and 3-foot Sump, Type II Cement Grout, and Sand Pack
1
$ 12,000
/Each
$
12,000
2
b
Forklift and Hopper Rental for Waste Handling
1
$ 250
/Day
$
250
2
c
Drill Crew per Diem
1
$ 450
/Night
$
450
2
d
Vehicle Usage
1
$ 100
/Day
$
100
e
Equipment Rental and Supplies
1
$ 500
/Day
$
500
f
Installation Permit
1
$ 201
/Well
$
201
g
Other Direct Costs
1
$ 300
/Day
$
300
Cost per Well
$
13,801
Number of Wells (1 Well Installed per Day)
66
Subtotal - UBA Multi-Phase Extraction Wells
$
910,866
9
Lab Analytical (Sixteen UBA Multi-Phase Extraction Well Borings)
a
Soil Analysis - Pesticides (EPA Method 8081 A)
54
$ 90
/Sample
$
4,860
3
b
Soil Analysis - VOCs (EPA Method 8260B)
54
$ 95
/Sample
$
5,130
3
c
Soil Analysis - pCBSA (Modified EPA Method 314.0)
54
$ 80
/Sample
$
4,320
3
d
Water Analysis - Pesticides (EPA Method 8081 A)
9
$ 90
/Sample
$
810
3
e
Water Analysis - VOCs (EPA Method 8260B)
9
$ 95
/Sample
$
855
3
f
Water Analysis - pCBSA (Modified EPA Method 314.0)
9
$ 80
/Sample
$
720
3
Total Lab Analytical (UBA Extraction Wells]
$
16,695
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-13.2 Well Construction Cost
Page 4 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 13.2
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
10
Electrode Wells (15" HSA Drilling to 105' bgs)
a
Drill Rig, Crew, and Support Equipment
1
$ 4,000
/Each
$ 4,000
4
b
Cement Backfill Material
54
$ 30
/Foot
$ 1,620
4
c
Sand Backfill Material
51
$ 20
/Foot
$ 1,020
4
d
Drill Crew per Diem
1
$ 450
/Night
$ 450
4
e
Forklift and Hopper Rental for Waste Handling
1
$ 250
/Day
$ 250
4
f
Plastic Sheeting and Hole Prep
1
$ 25
/Well
$ 25
4
g
5% Fuel Surcharge
1
$ 368
/Day
$ 368
4
h
Vehicle Usage
1
$ 100
/Day
$ 100
i
Equipment Rental and Supplies
1
$ 500
/Day
$ 500
j
Installation Permit
1
$ 201
/Well
$ 201
k
Other Direct Costs
1
$ 300
/Day
$ 300
Cost per Well
$ 8,834
Number of Wells (1 Well Installed per Day)
102
Subtotal - Electrode Wells
$ 901,094
11
Develop UBA Multi-Phase Extraction Wells
a
Development Rig
1
$ 2,000
/Day
$ 2,000
2
b
Development Crew per Diem
1
$ 200
/Night
$ 200
2
Cost per Well
$ 2,200
Number of Wells (1 Well Developed per Day)
66
Subtotal - Develop UBA Wells
$ 145,200
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-13.2 Well Construction Cost
Page 5 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 13.2
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Construction
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
12
Mobilization/Demobilization of Mud Rotary Drill Rig
1
$
12,000
/Each
$
12,000
4
13
Hot Floor Multi-Phase Extraction Wells
a
Move Between Well Locations
1
$
2,000
/Each
$
2,000
5
b
Install 14", .25" Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout
110
$
220
/Foot
$
24,200
5
c
Mud Change-Out and Pit Decon
1
$
2,000
/Each
$
2,000
5
d
12" Boring Under Conductor
8.5
$
80
/Foot
$
680
5
e
Install 6" Low Carbon Steel Sched. 40 Casing
110.5
$
88
/Foot
$
9,724
5
f
Install 6" Type 304 Stainless Steel Screen with 3' Sump
8
$
175
/Foot
$
1,400
5
g
Type II Cement Grout and Sand Pack
118.5
$
30
/Foot
$
3,555
5
h
Forklift and Hopper Rental for Waste Handling
4
$
400
/Day
$
1,600
5
i
Standby for Cement Curing
6
$
550
/Hour
$
3,300
5
j
Well Development
10
$
165
/Hour
$
1,650
5
k
Vehicle Usage
4
$
100
/Day
$
400
I
Equipment Rental and Supplies
4
$
500
/Day
$
2,000
m
Installation Permit
1
$
201
/Well
$
201
n
Other Direct Costs
4
$
300
/Day
$
1,200
Cost per Well
$
53,910
Number of Wells (4 Days per Well for Installation and Development)
0
Subtotal - Hot Floor Multi-Phase Extraction Wells
$
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-13.2 Well Construction Cost
Page 6 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 13.2
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Construction
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
14
Hot Floor Steam Injecton Wells
a
Move Between Well Locations
1
$ 2,000
/Each
$
2,000
5
b
Install 10", .25" Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout
110
$ 180
/Foot
$
19,800
5
c
Mud Change-Out
1
$ 1,500
/Each
$
1,500
5
d
9" Boring Under Conductor
5.5
$ 75
/Foot
$
413
5
e
Install 2" Low Carbon Steel Sched. 40 Casing
110.5
$ 45
/Foot
$
4,973
5
f
Install 2" Type 304 Stainless Steel Screen
5
$ 90
/Foot
$
450
5
g
Type II Cement Grout and Sand Pack
115.5
$ 20
/Foot
$
2,310
5
h
Forklift and Hopper Rental for Waste Handling
4
$ 400
/Day
$
1,600
5
i
Standby for Cement Curing
5
$ 550
/Hour
$
2,750
5
j
Well Development
6
$ 165
/Hour
$
990
5
k
Vehicle Usage
4
$ 100
/Day
$
400
I
Equipment Rental and Supplies
4
$ 500
/Day
$
2,000
m
Installation Permit
1
$ 201
/Well
$
201
n
Other Direct Costs
4
$ 300
/Day
$
1,200
Cost per Well
$
40,586
Number of Wells (4 Days per Well for Installation and Development)
0
Subtotal - Hot Floor Steam Injecton Wells
$
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-13.2 Well Construction Cost
Page 7 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 13.2
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
15
Temperature Monitoring Points (7" HAS Drilling to 105' bgs)
a
Move Between Well Locations
1
$ 4,000
/Each
$
4,000
b
Install 10", .25 Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout
0
$ 180
/Foot
$
-
c
Mud Change-Out
0
$ 1,500
/Each
$
-
d
8" Boring Under Conductor
0
$ 75
/Foot
$
-
e
Install 1.5" Low Carbon Steel Casing with Bottom Cap
105
$ 40
/Foot
$
4,200
f
Type II Cement Grout
105
$ 20
/Foot
$
2,100
g
Forklift and Hopper Rental for Waste Handling
1
$ 250
/Day
$
250
h
Standby for Cement Curing
0
$ 550
/Hour
$
-
i
Vehicle Usage
1
$ 100
/Day
$
100
j
Equipment Rental and Supplies
1
$ 500
/Day
$
500
k
Installation Permit
1
$ 201
/Well
$
201
i
Other Direct Costs
1
$ 300
/Day
$
300
Subtotal
$
11,651
Number of Wells (3 Days per Point - no Development Needed)
14
Subtotal - Temperature Monitoring Points
$
163,114
16
BFS Monitoring Wells
a
Well Installation (4 Days per Well for Installation and Development)
2
$ 54,000
/Well
$
108,000
1
b
Installation Permit
2
$ 201
/Well
$
402
Subtotal - BFS Monitoring Wells
$
108,402
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-13.2 Well Construction Cost
Page 8 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 13.2
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
17
Waste Management
a
Waste Tank Rental
290
$ 38
/Day
$
11,020
6
b
Waste Tank Rental Delivery - Mob and Demob
1
$ 900
/Each
$
900
6
c
Waste Bin Rental
1762
$ 15
/Day
$
26,430
6
d
Waste Bin Rental Delivery - Mob and Demob
58
$ 500
/Each
$
29,000
6
e
Transport of Hazardous Soil Cuttings
58
$ 1,100
/Each
$
63,800
6
f
Disposal of Hazardous Soil Cuttings
1178
$ 550
/Ton
$
647,900
6
g
Transport of Hazardous Mud
0
$ 500
/Each
$
-
6
h
Disposal of Hazardous Mud
0
$ 1.1
/Gal
$
-
6
i
Transport of Hazardous Water
6
$ 1,100
/Each
$
6,600
6
j
Disposal of Hazardous Water
21753
$ 0.8
/Gal
$
17,402
6
k
Waste Characterization/Profiling
2
$ 500
/Each
$
1,000
Subtotal - Waste Management
$
804,052
Total Subcontractor Cost w/10% Markup
$
3,431,640
TOTAL WELL CONSTRUCTION COST $ 3,996,515
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Cascade Drilling, Inc. Quote Dated 7/15/08
3 Verbal Quote from Test America
4 Cascade Drilling, Inc. Quote Dated 8/01/08
5 Water Development Corporation Quote Dated 4/25/08
6 Verbal Quote from NRC Environmental
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-13.2 Well Construction Cost
Page 9 of 24
-------
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Focused Treatment Area
June 2013
Appendix J
Table 13.3
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Field Equipment Installation
Montrose Superfund Site
Los Angeles, California
Item
Consultant Labor and Direct Costs
Quantity
Unit Cost
Cost
1
Electrical Service Upgrade
1
$ 50,000
LS
$ 50,000
2
Natural Gas Pipeline
1
$ 200,000
LS
$ 200,000
3
Electrode Well Equipment and Piping
a
Electrodes (3 per Electrode Well)
306
$ 1,500
Each
$ 459,000
b
Armored Electrical Cable
2380
$ 4.89
Foot
$ 11,638
c
1.5-Inch Carbon Steel Pipe and Fittinqs for Recirc Water Delivery
2380
$ 12.00
LF
$ 28,560
Total Electrode Well Equipment
$ 499,198
4
Groundwater Extraction Assemblies
a
Well Head Assemblies
66
$ 1,000
Each
$ 66,000
b
Extraction Pump (High Temperature Hammerhead Pro)
66
$ 3,070
Each
$ 202,620
c
Downwell Air Supply Hose (3/8" SS Brainded, Teflon Lined)
6600
$ 11
LF
$ 72,600
d
Downwell Air Exhaust Hose (1/2" SS Brainded, Teflon Lined)
6600
$ 16
LF
$ 105,600
e
Downwell Discharge Hose (1/4" SS Brainded, Teflon Lined)
6600
$ 22
LF
$ 145,200
Total Groundwater Extraction Assemblies
$ 592,020
5
Steam Injection Well Head Assemblies
0
$ 7,000
Each
$
6
Field Technician - Pump and Well Head Assembly Construction and Installation
(Consultant Labor - Not Subject to Markup)
1,370
$ 75
Hour
$ 102,750
7
Steam Injection Piping
a
6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
0
$ 67.65
LF
$
b
4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
0
$ 43.45
LF
$
c
2-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
0
$ 34.10
LF
$
Total Steam Injection Piping
$
8
Vapor Extraction Piping
a
8-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
605
$ 94.71
LF
$ 57,300
b
6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
1810
$ 67.65
LF
$ 122,447
c
4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
677
$ 43.45
LF
$ 29,416
Total Vapor Extraction Piping
$ 209,162
J-13.3 Well Field Equipment Installation Cost
Page 10 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area AppGndix J
June2013 Table 13.3
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Field Equipment Installation
Item
Consultant Labor and Direct Costs
Quantity
Unit Cost
Cost
Cost
Ref.
9
a
b
c
d
e
f
10
11
Groundwater Extraction Piping
4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
2-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
1.5-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
Total Piping Length
Piping Heat Trace, VLBTVWire
Misc fittings and heat trace elements (30% of Groundwater Extraction Piping cost)
605
1810
677
3092
3092
1
$ 43.45
$ 34.10
$ 31.45
$ 15.75
$ 47,399.67
LF
LF
LF
LF
LF
LS
$ 26,287
$ 61,721
$ 21,292
$ 48,699
$ 47,400
4
4
4
6
4
Total Groundwater Extraction Piping
Compressed Air Pipe and Fittings (2-Inch Carbon Steel)
Pipe Supports
3092
309.2
$ 20.00
$ 200
LF
LF
$ 205,399
$ 61,840
$ 61,840
CONSULTANT LABOR COST
DIRECT COSTS w/10% MARKUP
$ 102,750
$ 2,067,404
TOTAL WELL FIELD EQUIPMENT INSTALLTION COST $ 2,170,154
Cost Source Reference
1 Verbal Quote from McMillan-McGee Corp.
2 McMaster-Carr Catalog Price
3 QED Environmental Systems, Inc. Quote Dated May 16, 2008
4 2007 RS Means Database. Unit price shown includes 10% inflation rate and local area cost factor.
5 Unit rate assumed to be approximately 40% higher than rate for 6-inch carbon steel pipe and fittings with fiberglass insulation and aluminum jacket.
6 2006 Raychem quote obtained by CH2MHILL
J-13.3 Well Field Equipment Installation Cost
Page 11 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubicyard) Los Angeles, California
Focused Treatment Area Appendix J
June 2013 Table 13.4
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Instrumentation and Controls Installation
Item
Consultant Labor and Direct Costs
Quantity
Unit Cost
Cost
Cost
Ref.
1
a
b
c
Steam Injection Wells
Pressure Gage (0-300 PSI)
Temperature Indicator
Orifice Plate and Transmitter
0
0
0
$
$
$
48
127
10,000
/Each
/Each
/Each
S
$
s
1
1
Total Steam Injection Wells and Piping l&Cs
$
-
2
Groundwater Exraction Pressure Gage (0-300 PSI)
66
$
48
/Each
$
3,168
1
3
Vapor Extraction Vacuum Gage (30 in Hg)
66
$
50
/Each
$
3,326
1
4
a
b
Thermocouple String
Type T Thermocouple Wire (24 Gauge w/Fiberglass Insulation and Jacket)
Analog Decoder
1,400
1
$
$
0.75
500
/Foot
/Each
s
s
1,050
500
2
Cost per Temp Monitoring Point
Number of Temperature Monitoring Points
s
1,550
14
Total Thermocouple String
21,700
5
Field Technician - Installation of Items 1 Through 4 (Instrumentation and Controls)
(Consultant Labor - Not Subject to Markup)
152
$
75
/Hour
$
11,400
6
Electrical Allowance (20% of Instrumentation and Controls cost)
1
$
8,458
/LS
$
8,458
7
Control System Allowance (30% of Instrumentation and Controls cost)
1
$
11,278
/LS
$
11,278
CONSULTANT LABOR COST
DIRECT COSTS w/10% MARKUP
$
$
11,400
52,724
TOTAL INSTRUMENTATION AND CONTROLS INSTALLATION COST
$
64,124
Cost Source Reference
1 Grainger Catalog Price
2 McMaster-Carr Catalog Price
J-13.4 Instrumentation and Controls Installation Cost
Page 12 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 13.5
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Treatment Equipment Installation
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
1
a
b
c
d
e
f
g
h
i
j
k
I
Vapor T reatment
12,000-gallon Brine Holding Tank
Fin-Fan Heat Exchanger
Steam-Regenerable Carbon System
(incl. two 5,000-lb GAC vessels, condenser, separator, and inline stack PID)
2MM BTUs/Hr Steam Generator (Gas Fired)
Water Softening Unit for Steam Generator
Interconnecting Piping (20% of Steam-Regen Carbon System cost)
5000-lb Polishing Vapor-Phase GAC Vessel
Orifice Plate and Transmitter
1000 SCFM Liquid Ring Vacuum Blower (standard cast iron construction)
Moisture Separator
500-Gallon Collection Tank
Transfer Pump (50 gpm)
1
1
1
1
1
1
2
2
2
1
1
9
$ 18,538
$ 14,306
$ 750,000
$ 5,000
$ 5,000
$ 150,000
$ 16,000
$ 10,000
$ 80,000
$ 4,000
$ 2,078
$ 536
/Each
/Each
/LS
/Each
/Each
/LS
/Each
/Each
/Each
/Each
/Each
/Each
$ 18,538
$ 14,306
$ 750,000
$ 5,000
$ 5,000
$ 150,000
$ 32,000
$ 20,000
$ 160,000
$ 4,000
$ 2,078
$ 4,820
1
2
3
4
5
6
1
7
Total for Vapor Treatment
S 1.165.742
2
a
b
c
d
e
f
g
h
i
j
k
Groundwater Exraction and Treatment
Shell and Tube Heat Exchanger
DNAPL/Water Separator
Groundwater Holding Tank
Two 3,000-lb Liquid-Phase GAC Vessels Each w/lnitial Virgin Coconut Shell GAC Fill
Air Compressor
500-Gallon Collection Tank
Cooling Tower (540 gpm Recirculation Rate)
Transfer Pump (50 gpm)
Transfer Pump (540 gpm)
Transfer Pump (145 gpm)
HiPOx System (50 gpm)
1
2
1
1
1
1
1
8
2
2
1
$ 22,112
$ 56,450
$ 50,000
$ 16,830
$ 20,000
$ 2,078
$ 37,713
$ 536
$ 2,756
$ 1,348
$ 768,750
/Each
/Each
/Each
LS
/Each
/Each
/Each
/Each
/Each
/Each
/Each
$ 22,112
$ 112,900
$ 50,000
$ 16,830
$ 20,000
$ 2,078
$ 37,713
$ 4,284
$ 5,513
$ 2,696
$ 768,750
8
9
10
11
1
12
7
13
7
14
Total for Groundwater Exraction and Treatment Equipment
S 1.042.876
J-13.5 Treatment Equipment Installation Cost
Page 13 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 13.5
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Treatment Equipment Installation
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
3
Equipment Pads and Containment
1
$ 150,000
/LS
s
150.000
11
4
80' X 110' Treatment Plant Building
1
$ 150,000
ILS
s
150.000
5
Subcontractor Installation Cost
1
$ 365,000
ILS
s
365.000
15
TOTAL TREATMENT EQUIPMENT INSTALLATION COST w/10% MARKUP
s
3.160.979
Cost Source Reference
1 Harrington Plastic Catalog Price
2 Heat Exchanger Sales and Engineering Company, LLC Quote Dated July 17, 2008
3 MEGTEC Systems, Inc. Quote Dated April 20, 2008
4 BakerCorp Quote Dated July 1, 2008
5 Yardley Pump and Vacuum Quote Dated July 18, 2008
6 Verbal Qoute from Enviro Supply and Services
7 Grainger Catalog Price
8 SEC Heat Exchanger Quote Dated July 1, 2008
9 Pan America Environmental Quote Dated July 28, 2008
10 BakerCorp Quoted Dated July 23, 2008
11 McMillan-McGee November 2006 Feasibility Study for Steam Injection, Page 34
12 Cooling Tower Systems Quote Dated July 2, 2008
13 McMaster-Carr Catalog Price
14 Unit price scaled down to a 75 gpm system from $2,050,000 quote from Applied Process Technologies (June 6, 2006) for a 200 gpm system.
15 Verbal Quote from J.C. Palomar Construction, Inc.
J-13.5 Treatment Equipment Installation Cost
Page 14 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
June 2013 Table 13.6
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Construction Management
Item
Consultant Labor
Quantity
Unit Cost
Cost
1
Project Manager
195
$150
/Hour
$ 29.250
2
Senior Engineer/Geologist
400
$125
/Hour
S 50.000
3
Mid-Level Engineer/Geologist
1,062
$100
/Hour
S 106.200
4
Junior/Field Engineer/Geologist
1,365
$ 75
/Hour
S 102.375
5
Field Technician
1.365
$ 75
/Hour
S 102.375
6
Clerical/Drafting
151
$ 50
/Hour
S 7.528
TOTAL CONSTRUCTION MANAGEMENT COST
$ 397,728
J-13.6 Construction Management Cost
Page 15 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 13.7
Detailed Cost, ERH (200 kW-hr/cubic yard)
Operations and Maintenance
Item
Consultant Labor (Operations)
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
3
4
5
6
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist (One Full Time Mid-Level Engineer)
Junior/Field Engineer/Geologist (One Full Time Junior Engineer)
Field Technician (Three Full Time Operators - 40 Hours per Week Each)
Clerical/Drafting
520
520
2,080
2,080
6,240
520
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 78,000
$ 65,000
$ 208,000
$ 156,000
$ 468,000
$ 26,000
Consultant Labor Cost for Operations
S 1.001.000
Item
Consultant Labor (Reporting, H&S, Data Mngt, and Website Maintenance)
Quantity
Unit Cost
Cost
Cost
Ref.
7
8
9
10
11
12
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
20
80
1,300
2,080
0
180
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 3,000
$ 10,000
$ 130,000
$ 156,000
$ 9,000
Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance
S 308.000
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
13
a
14
a
b
c
d
e
f
Equipment Rentals
12-million BTUs/hr Low NOx Steam Generator (incl. water softening package)
0
$ 18,500
/Month
$
1
2
2
3
Total Equipment Rentals
Consumables (Excluding Utilities)
Salt for Steam Generator Feed Water Treatment
Virgin Coconut Shell Vapor-Phase Carbon (7,000-lbs of polishing GAC per month plus 10,000 lbs of
regen system carbon changed-out after six months)
Vapor-Phase Carbon Change-Out Service
Hydrogen Peroxide for HiPOx
Oxygen for HiPOx
3000-lb Liquid-Phase Carbon Change-Out (Includes T&D as Hazardous Waste)
52
94,000
10
166,650
1,165,100
48
$ 100
$ 1.07
$ 1,739
$ 3.00
$ 0.35
$ 6,746
/Week
/lb
/Change-Out
/Gal
/100 SCF
/Each
s
$ 5,200
$ 100,580
$ 17,390
$ 499,950
$ 407,785
$ 323,808
Total Consumables
S 1.354.713
J-13.7 Operations and Maintenance Cost
Page 16 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 13.7
Detailed Cost, ERH (200 kW-hr/cubic yard)
Operations and Maintenance
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
15
a
b
c
d
e
f
g
h
16
a
b
c
d
e
f
g
17
a
b
c
d
e
f
g
h
i
j
k
Waste Management
Vapor-Phase GAC Disposal (Listed Waste for Incineration)
(incl. 10,000 lbs of regen system carbon at year end)
Vapor-Phase GAC Transportation
Carbon Regen System Solvent Waste Disposal (Listed Waste for Incineration)
Carbon Regen System Solvent Waste Transportation - inlcude pre heat transport
Filtration Generated Waste Disposal (Listed Waste for Incineration)
Filtration Generated Waste Transportation
Boiler Water Pre-Treatment Brine and Blowdown Off-Site Disposal (non-Haz)
Boiler Water Pre-Treatment Brine and Blowdown Transportation
80,000
5
169,500
5
39,300
3
43,526
5
$ 0.71
$ 4,286
$ 0.50
$ 3,650
$ 0.25
$ 2,800
$ 0.14
$ 950
/lb
/Load
/lb
/Load
/lb
/Load
/Gal
/1 0,000 Gals
$ 56,800
$ 21,430
$ 84,750
$ 18,250
$ 9,825
$ 8,400
$ 6,094
$ 4,750
4
4
5
5
5
5
6
6
7
7
8
8
8
9
10
10
10
11
12
12
13
Total Waste Management
Lab Analytical and Monitoring
Summa Can Rental
Vapor VOCs Analysis (EPA Method TO-15)
Liquid Pesticides (EPA Method 8260B)
Liquid VOC Analysis (EPA Method 8081 A)
Liquid pCBSA Analysis (Modifed EPA Method 314.0)
Tedlar Bags
TVA-1000B PID/FID Rental
288
288
288
288
24
240
12
$ 40
$ 200
$ 90
$ 95
$ 80
$ 10
$ 1,200
/Each
/Each
/Each
/Each
/Each
/Each
/Month
S 210.299
$ 11,520
$ 57,600
$ 25,920
$ 27,360
$ 1,920
$ 2,400
$ 14,400
Total Lab Analytical and Monitoring
Miscellaneous
Temporary Office 24'x60' Delivery and Setup
Temporary Office 24'x60' Rental
Temporary Office 24'x60' Demobilization
Temporary Storage Trailer
Portable Toilet Delivery
Portable Toilet Rental
Standby Generator (800 kW)
Maintenance Parts
Fed Ex and Deliveries
Temporary office comm. (internet, telephone, fax)
Operator Truck Usage (One Truck per Operator)
1
12
1
12
1
12
12
12
260
12
780
$ 2,939
$ 1,030
$ 1,746
$ 149
$ 22
$ 76
$ 8,775
$ 1,000
$ 150
$ 1,000
$ 100
/Each
/Month
/Each
/Month
/Each
/Month
/Month
/Month
/Day
/Month
/Day/Truck
S 141.120
$ 2,939
$ 12,356
$ 1,746
$ 1,784
$ 22
$ 908
$ 105,300
$ 12,000
$ 39,000
$ 12,000
$ 78,000
Total Miscellaneous
S 266.055
J-13.7 Operations and Maintenance Cost
Page 17 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 13.7
Detailed Cost, ERH (200 kW-hr/cubic yard)
Operations and Maintenance
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
18
Steam License for UBA
0
$ 0.50 |/CY Treated
S
14
Total Subcontractor Cost (O&M Year 1)
S 1.972.186
Item
Utilities
Quantity
Unit Cost
Cost
Cost
Ref.
19
a
b
Electricity Usage
Electrodes in UBA
HiPOx and other Treatment Equipment
11,680,994
10,148,151
$ 0.1045
$ 0.1045
/kWh
/kWh
$
$
1,220,664
1,060,482
15
15
Total Electricity Usage
S
2.281.146
20
Natural Gas for Steam Generation
53,702
$ 1.14
/Therm
s
61.220
16
21
a
b
c
Municipal Water
Cooling Tower Makeup Water (5 GPM)
Municipal Water for Steam Generation
water for electrodes
2,628,000
518,457
80,416,800
$ 0.0029
$ 0.0029
$ 0.0029
/Gal
/Gal
/Gal
$
$
$
7,621
1,504
233,209
Total Municipal Water Usage
s
242.333
Total Utilities
s
2.584.699
FULL SCALE CONSULTANT LABOR COST
S
1.309.000
FULL SCALE SUBCONTRACTOR COST w/10% MARKUP
S
2.169.405
UTILITIES COST (NO MARKUP)
S
2.584.699
TOTAL OPERATIONS AND MAINTENANCE COST
S
6.063.104
J-13.7 Operations and Maintenance Cost
Page 18 of 24
-------
Final DNAPL Feasibility Study
ERH (200 kW-hrs/cubic yard)
Montrose Superfund Site
Los Angeles, California
Focused Treatment Area
June 2013
Appendix J
Table 13.7
Detailed Cost, ERH (200 kW-hr/cubic yard)
Operations and Maintenance
Cost Source Reference
1 Nationwide Boiler Quote Dated July 30, 2008
2 BakerCorp Quote Dated June 30, 2008. Unit price for carbon change-out services is scaled down for a 9,400-lb change-out from BakerCorp quote of $1,850 per change-out for 10,000 lbs.
3 BakerCorp Quote July 23, 2008
4 NRC Environmental Services, Inc. Quote Dated June 30, 2008
5 Clean Harbors Quote Dated October 10, 2007
6 NRC Environmental Services, Inc. Email Quote Dated July 18, 2008
7 Verbal Quote from Calscience Environmental Laboratories, Inc.
8 Verbal Quote from Test America
9 Verbal Quote from Ashtead Technology Rentals
10 Mobile Mini, Inc. Quote Dated October 11, 2007
11 Verbal Quote from Mobile Mini, Inc.
12 Verbal Quote from A-1 Coast Port-A-Toilet
13 Kohler Rental Quote Dated June 30, 2008
14 McMillan-McGee November 2006 Feasibility Study for Steam Injection, Page 33
15 Shedule A-3 LADWP Rate (Second Quarter 2008)
16 GN-10, Tier III, SoCal Gas Co. Rate (Effective May 1, 2008)
J-13.7 Operations and Maintenance Cost
Page 19 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
June 2013 Table 13.8
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Abandonment
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
3
4
5
6
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
70
420
170
1,872
70
70
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
S 10.500
S 52.500
S 17.000
S 140.400
S 5.250
S 3.500
Total Consultant Labor Cost
S 229.150
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
a
b
c
d
e
f
g
Mobilization/Demobilization of Drill Rig
Abandon UBA Multi-Phase Extraction Wells
Drill out well materials (upper 15 feet)
Pressure grout well
Forklift and mini-hopper
Abandonment Crew per Diem
Vehicle Usage
Equipment Rental and Supplies
Other Direct Costs
Cost per Well
Number of Wells (1 Well Abandoned per Day)
1
15
108
1
1
1
1
1
$ 2,000
$ 65
$ 30
$ 500
$ 200
$ 100
$ 150
$ 150
/LS
/Foot
/Foot
/Day
/Night
/Day
/Day
/Day
$ 2,000
S 975
S 3.240
S 500
S 200
S 100
S 150
S 150
S 5.315
66
1
1
1
1
Total for UBA Multi-Phase Extraction Well Adandonment
350,790
J-13.8 Well Abandonment Cost
Page 20 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
June 2013 Table 13.8
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Abandonment
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
3
Abandon Electrode Wells
a
Drill out well materials (upper 15 feet)
15
$
65
/Foot
S
975
1
b
Pressure Grout Electrodes
105
$
30
/Foot
S
3.150
1
c
Forklift and mini-hopper
1
$
500
/Day
S
500
1
d
Abandonment Crew per Diem
1
$
200
/Night
S
200
e
Vehicle Usage
1
$
100
/Day
S
100
f
Equipment Rental and Supplies
1
$
150
/Day
S
150
g
Other Direct Costs
1
$
150
/Day
S
150
Cost per Well
S
5.225
Number of Wells (1 Well Abandoned per Day)
102
Total for Electode Well Adandonment
532,950
4
Abandon Hot Floor Multi-Phase Extraction Wells
a
Pressure grout well
118.5
$
30
/Foot
S
3.555
1
b
Forklift and mini-hopper
1
$
500
/Day
S
500
1
c
Abandonment Crew per Diem
1
$
200
/Night
S
200
d
Vehicle Usage
1
$
100
/Day
S
100
e
Equipment Rental and Supplies
1
$
150
/Day
S
150
f
Other Direct Costs
1
$
150
/Day
S
150
Cost per Well
S
4.655
Number of Wells (1 Well Abandoned per Day)
0
Total for Hot Floor Multi-Phase Extraction Well Abandonment
$
J-13.8 Well Abandonment Cost
Page 21 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
June 2013 Table 13.8
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Abandonment
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
5
Abandon Hot Floor Steam Injection Wells
a
Pressure grout well
115.5
$
30
/Foot
S
3.465
1
b
Forklift and mini-hopper
1
$
500
/Day
S
500
1
c
Abandonment Crew per Diem
1
$
200
/Night
S
200
d
Vehicle Usage
1
$
100
/Day
S
100
e
Equipment Rental and Supplies
1
$
150
/Day
S
150
f
Other Direct Costs
1
$
150
/Day
S
150
Cost per Well
S
4.565
Number of Wells (1 Well Abandoned per Day)
0
Total for Hot Floor Steam Injection Well Abandonment
$
-
6
Abandon Temperature Monitoring Points
a
Pressure grout well
105
$
30
/Foot
S
3.150
1
b
Forklift and mini-hopper
1
$
500
/Day
s
500
1
c
Abandonment Crew per Diem
1
$
200
/Night
s
200
d
Vehicle Usage
1
$
100
/Day
s
100
e
Equipment Rental and Supplies
1
$
150
/Day
s
150
f
Other Direct Costs
1
$
150
/Day
s
150
Cost per Well
s
4.250
Number of Wells
14
Total for Temperature Monitoring Point Abandonment
$
59,500
J-13.8 Well Abandonment Cost
Page 22 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
June 2013 Table 13.8
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Well Abandonment
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
Waste Management
a
Waste Tank Rental
0
$
38
/Day
S
-
b
Waste Tank Rental Delivery - Mob and Demob
0
$
900
/Each
s
-
c
Waste Bin Rental
360
$
15
/Day
s
5.400
2
d
Waste Bin Rental Delivery - Mob and Demob
12
$
500
/Each
s
6.000
2
e
Transport of Hazardous Soil Cuttings
12
$
1,100
/Each
s
13.200
2
f
Disposal of Hazardous Soil Cuttings
186
$
550
/Ton
s
102.025
2
g
Transport of Hazardous Mud
0
$
500
/Each
s
-
h
Disposal of Hazardous Mud
0
$
1.1
/Gal
s
-
i
Transport of Hazardous Water
1
$
1,100
/Each
s
1.100
2
j
Disposal of Hazardous Water
1517
$
0.8
/Gal
s
1.214
2
k
Waste Characterization/Profiling
2
$
500
/Each
s
1.000
Total Waste Management
s
129.939
Total Subcontractor Cost w/10% Markup
$
1,182,696
TOTAL WELL ABANDONMENT COST $ 1,411,846
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Verbal Quote from NRC Environmental Services
J-13.8 Well Abandonment Cost
Page 23 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (200 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
june 2013 Table 13.9
Detailed Cost, ERH (200 kW-hrs/cubic yard)
Demobilization
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
55
$
150
/Hour
s
8,250
2
Senior Engineer/Geologist
180
$
125
/Hour
s
22,500
3
Mid-Level Engineer/Geologist
572
$
100
/Hour
s
57,200
4
Junior/Field Engineer/Geologist
720
$
75
/Hour
s
54,000
5
Field Technician
380
$
75
/Hour
s
28,500
6
Clerical/Drafting
125
$
50
/Hour
s
6,250
Consultant Labor Cost
$
176,700
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
7
Remove Purchased Treatment Equipment
1
$
317,000
/ LS
$
317,000
8
Close-Out Borings
a
Drilling
9
$
12,000
/Boring
s
108,000
1
b
Waste Disposal
9
$
5,500
/Boring
s
49,500
2
c
Soil Pesticides (EPA Method 8081A)
54
$
90
/Sample
s
4,860
3
d
Soil VOCs (EPA Method 8260B)
54
$
95
/Sample
s
5,130
3
e
Soil pCBSA (Modified EPA Method 314.0)
54
$
80
/Sample
s
4,320
3
f
Liquid Pesticides (EPA Method 8081A)
9
$
90
/Sample
s
810
3
g
Liquid VOCs (EPA Method 8260B)
9
$
95
/Sample
s
855
3
h
Liquid pCBSA (Modified EPA Method 314.0)
9
$
80
/Sample
$
720
3
Total for Close-Out Borings
$
174,195
Total Subcontractor Cost w/10% Markup
$
540,315
| TOTAL DEMOBILIZATION COST
$ J,*
I
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Verbal Quote from NRC Environmental Services
3 Verbal Quote from Test America
J-13.9 Demobilization Cost
Page 24 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area AppGndix J
June2013 Table 14.0
Cost Summary
ERH (400 kW-hrs/cubic yard)
Focused Treatment Area
Cost
NPV)
Year
Activity
Detailed Cost Table
Cost
(Undiscountech
DR= 4%
DR= 7%
1
Focused Treatment Design
J-14.1 Design and Permitting Cost
$ 1,160,300
$ 1,115,673
$ 1,084,393
2
Focused Treatment Build
J-14.2 Well Construction
$ 3,996,515
$ 9,050,943
$ 8,550,529
J-14.3 Well Field Equipment Installation
$ 2,170,154
J-14.4 Instrumentation and Controls Installation
$ 64,124
J-14.5 Treatment Equipment Installation
$ 3,160,979
J-14.6 Construction Management
$ 397,728
3
Focused Treatment Operation and Maintenance
J-14.7 Operations and Maintenance
$ 6,063,104
$ 5,390,077
$ 4,949,299
4
J-14.7 Operations and Maintenance
$ 6,063,104
$ 5,182,767
$ 4,625,513
5
Verification and Abandonment
J-14.8 Well Abandonment
$ 1,411,846
$ 1,749,769
$ 1,517,848
J-14.9 Demobilization
$ 717,015
Totals||~$ 25,204,869 | $ 22,489,229 | $ 20,727,582 |
Notes
DR = Discount rate
NPV = Net present value
J-14.0 Cost Summary
Page 1 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 14.1
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Design and Permitting
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
790
$
150
/Hour
$
118,500
2
Senior Engineer/Geologist
1,170
$
125
/Hour
$
146,250
3
Mid-Level Engineer/Geologist
4,600
$
100
/Hour
$
460,000
4
Junior/Field Engineer/Geologist
3,310
$
75
/Hour
$
248,250
5
Field Technician
0
$
75
/Hour
$
-
6
Clerical/Drafting
1,106
$
50
/Hour
$
55,300
Consultant Labor
$
1,028,300
TOTAL DESIGN AND PERMITTING COST $ 1,160,300
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
1
Outside Thermal Expert
1
$120,000
/LS
$ 120,000
Subcontractor Costw/10% Markup
$ 132,000
J-14.1 Design and Permitting Cost
Page 2 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 14.2
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Construction
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
507
$
150
/Hour
$
76,050
2
Senior Engineer/Geologist
507
$
125
/Hour
$
63,375
3
Mid-Level Engineer/Geologist
1,352
$
100
/Hour
$
135,200
4
Junior/Field Engineer/Geologist
3,050
$
75
/Hour
$
228,750
5
Field Technician
482
$
75
/Hour
$
36,150
6
Clerical/Drafting
507
$
50
/Hour
$
25,350
Total Consultant Labor Cost
$
564,875
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
Abandon Existing Site Wells Prior to Thermal Treatment
a
Drill out well materials
90
$ 65
/Foot
$ 5,850
1
b
Grout resulting boring
90
$ 30
/Foot
$ 2,700
1
c
Forklift and mini-hopper
1
$ 500
/Day
$ 500
1
d
Excavate and remove well box
1
$ 2,000
/LS
$ 2,000
1
e
Abandonment Crew per Diem
1
$ 200
/Night
$ 200
f
Vehicle Usage
1
$ 100
/Day
$ 100
g
Equipment Rental and Supplies
1
$ 150
/Day
$ 150
h
Other Direct Costs
1
$ 150
/Day
$ 150
Cost per Well
$ 11,650
Number of Wells
5
Total for Existing Site Well Abandonment
$ 58,250
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-14.2 Well Construction Cost
Page 3 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 14.2
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
8
UBA Multi-Phase Extraction Wells (12" HSA Drilling to 108' bgs)
a
Install Well Constructed of 6" LCS Casing w/ 60' of
SS Screen and 3-foot Sump, Type II Cement Grout, and Sand Pack
1
$ 12,000
/Each
$
12,000
2
b
Forklift and Hopper Rental for Waste Handling
1
$ 250
/Day
$
250
2
c
Drill Crew per Diem
1
$ 450
/Night
$
450
2
d
Vehicle Usage
1
$ 100
/Day
$
100
e
Equipment Rental and Supplies
1
$ 500
/Day
$
500
f
Installation Permit
1
$ 201
/Well
$
201
g
Other Direct Costs
1
$ 300
/Day
$
300
Cost per Well
$
13,801
Number of Wells (1 Well Installed per Day)
66
Subtotal - UBA Multi-Phase Extraction Wells
$
910,866
9
Lab Analytical (Sixteen UBA Multi-Phase Extraction Well Borings)
a
Soil Analysis - Pesticides (EPA Method 8081 A)
54
$ 90
/Sample
$
4,860
3
b
Soil Analysis - VOCs (EPA Method 8260B)
54
$ 95
/Sample
$
5,130
3
c
Soil Analysis - pCBSA (Modified EPA Method 314.0)
54
$ 80
/Sample
$
4,320
3
d
Water Analysis - Pesticides (EPA Method 8081 A)
9
$ 90
/Sample
$
810
3
e
Water Analysis - VOCs (EPA Method 8260B)
9
$ 95
/Sample
$
855
3
f
Water Analysis - pCBSA (Modified EPA Method 314.0)
9
$ 80
/Sample
$
720
3
Total Lab Analytical (UBA Extraction Wells]
$
16,695
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-14.2 Well Construction Cost
Page 4 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 14.2
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
10
Electrode Wells (15" HSA Drilling to 105' bgs)
a
Drill Rig, Crew, and Support Equipment
1
$ 4,000
/Each
$ 4,000
4
b
Cement Backfill Material
54
$ 30
/Foot
$ 1,620
4
c
Sand Backfill Material
51
$ 20
/Foot
$ 1,020
4
d
Drill Crew per Diem
1
$ 450
/Night
$ 450
4
e
Forklift and Hopper Rental for Waste Handling
1
$ 250
/Day
$ 250
4
f
Plastic Sheeting and Hole Prep
1
$ 25
/Well
$ 25
4
g
5% Fuel Surcharge
1
$ 368
/Day
$ 368
4
h
Vehicle Usage
1
$ 100
/Day
$ 100
i
Equipment Rental and Supplies
1
$ 500
/Day
$ 500
j
Installation Permit
1
$ 201
/Well
$ 201
k
Other Direct Costs
1
$ 300
/Day
$ 300
Cost per Well
$ 8,834
Number of Wells (1 Well Installed per Day)
102
Subtotal - Electrode Wells
$ 901,094
11
Develop UBA Multi-Phase Extraction Wells
a
Development Rig
1
$ 2,000
/Day
$ 2,000
2
b
Development Crew per Diem
1
$ 200
/Night
$ 200
2
Cost per Well
$ 2,200
Number of Wells (1 Well Developed per Day)
66
Subtotal - Develop UBA Wells
$ 145,200
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-14.2 Well Construction Cost
Page 5 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 14.2
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Construction
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
12
Mobilization/Demobilization of Mud Rotary Drill Rig
1
$
12,000
/Each
$
12,000
4
13
Hot Floor Multi-Phase Extraction Wells
a
Move Between Well Locations
1
$
2,000
/Each
$
2,000
5
b
Install 14", .25" Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout
110
$
220
/Foot
$
24,200
5
c
Mud Change-Out and Pit Decon
1
$
2,000
/Each
$
2,000
5
d
12" Boring Under Conductor
8.5
$
80
/Foot
$
680
5
e
Install 6" Low Carbon Steel Sched. 40 Casing
110.5
$
88
/Foot
$
9,724
5
f
Install 6" Type 304 Stainless Steel Screen with 3' Sump
8
$
175
/Foot
$
1,400
5
g
Type II Cement Grout and Sand Pack
118.5
$
30
/Foot
$
3,555
5
h
Forklift and Hopper Rental for Waste Handling
4
$
400
/Day
$
1,600
5
i
Standby for Cement Curing
6
$
550
/Hour
$
3,300
5
j
Well Development
10
$
165
/Hour
$
1,650
5
k
Vehicle Usage
4
$
100
/Day
$
400
I
Equipment Rental and Supplies
4
$
500
/Day
$
2,000
m
Installation Permit
1
$
201
/Well
$
201
n
Other Direct Costs
4
$
300
/Day
$
1,200
Cost per Well
$
53,910
Number of Wells (4 Days per Well for Installation and Development)
0
Subtotal - Hot Floor Multi-Phase Extraction Wells
$
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-14.2 Well Construction Cost
Page 6 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 14.2
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Construction
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
14
Hot Floor Steam Injecton Wells
a
Move Between Well Locations
1
$ 2,000
/Each
$
2,000
5
b
Install 10", .25" Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout
110
$ 180
/Foot
$
19,800
5
c
Mud Change-Out
1
$ 1,500
/Each
$
1,500
5
d
9" Boring Under Conductor
5.5
$ 75
/Foot
$
413
5
e
Install 2" Low Carbon Steel Sched. 40 Casing
110.5
$ 45
/Foot
$
4,973
5
f
Install 2" Type 304 Stainless Steel Screen
5
$ 90
/Foot
$
450
5
g
Type II Cement Grout and Sand Pack
115.5
$ 20
/Foot
$
2,310
5
h
Forklift and Hopper Rental for Waste Handling
4
$ 400
/Day
$
1,600
5
i
Standby for Cement Curing
5
$ 550
/Hour
$
2,750
5
j
Well Development
6
$ 165
/Hour
$
990
5
k
Vehicle Usage
4
$ 100
/Day
$
400
I
Equipment Rental and Supplies
4
$ 500
/Day
$
2,000
m
Installation Permit
1
$ 201
/Well
$
201
n
Other Direct Costs
4
$ 300
/Day
$
1,200
Cost per Well
$
40,586
Number of Wells (4 Days per Well for Installation and Development)
0
Subtotal - Hot Floor Steam Injecton Wells
$
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-14.2 Well Construction Cost
Page 7 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 14.2
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
15
Temperature Monitoring Points (7" HAS Drilling to 105' bgs)
a
Move Between Well Locations
1
$ 4,000
/Each
$
4,000
b
Install 10", .25 Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout
0
$ 180
/Foot
$
-
c
Mud Change-Out
0
$ 1,500
/Each
$
-
d
8" Boring Under Conductor
0
$ 75
/Foot
$
-
e
Install 1.5" Low Carbon Steel Casing with Bottom Cap
105
$ 40
/Foot
$
4,200
f
Type II Cement Grout
105
$ 20
/Foot
$
2,100
g
Forklift and Hopper Rental for Waste Handling
1
$ 250
/Day
$
250
h
Standby for Cement Curing
0
$ 550
/Hour
$
-
i
Vehicle Usage
1
$ 100
/Day
$
100
j
Equipment Rental and Supplies
1
$ 500
/Day
$
500
k
Installation Permit
1
$ 201
/Well
$
201
i
Other Direct Costs
1
$ 300
/Day
$
300
Subtotal
$
11,651
Number of Wells (3 Days per Point - no Development Needed)
14
Subtotal - Temperature Monitoring Points
$
163,114
16
BFS Monitoring Wells
a
Well Installation (4 Days per Well for Installation and Development)
2
$ 54,000
/Well
$
108,000
1
b
Installation Permit
2
$ 201
/Well
$
402
Subtotal - BFS Monitoring Wells
$
108,402
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-14.2 Well Construction Cost
Page 8 of 24
-------
Montrose Superfund Site
Los Angeles, California
Appendix J
Table 14.2
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Construction
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
17
Waste Management
a
Waste Tank Rental
290
$ 38
/Day
$
11,020
6
b
Waste Tank Rental Delivery - Mob and Demob
1
$ 900
/Each
$
900
6
c
Waste Bin Rental
1762
$ 15
/Day
$
26,430
6
d
Waste Bin Rental Delivery - Mob and Demob
58
$ 500
/Each
$
29,000
6
e
Transport of Hazardous Soil Cuttings
58
$ 1,100
/Each
$
63,800
6
f
Disposal of Hazardous Soil Cuttings
1178
$ 550
/Ton
$
647,900
6
g
Transport of Hazardous Mud
0
$ 500
/Each
$
-
6
h
Disposal of Hazardous Mud
0
$ 1.1
/Gal
$
-
6
i
Transport of Hazardous Water
6
$ 1,100
/Each
$
6,600
6
j
Disposal of Hazardous Water
21753
$ 0.8
/Gal
$
17,402
6
k
Waste Characterization/Profiling
2
$ 500
/Each
$
1,000
Subtotal - Waste Management
$
804,052
Total Subcontractor Cost w/10% Markup
$
3,431,640
TOTAL WELL CONSTRUCTION COST $ 3,996,515
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Cascade Drilling, Inc. Quote Dated 7/15/08
3 Verbal Quote from Test America
4 Cascade Drilling, Inc. Quote Dated 8/01/08
5 Water Development Corporation Quote Dated 4/25/08
6 Verbal Quote from NRC Environmental
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Focued Treatment Area
June 2013
J-14.2 Well Construction Cost
Page 9 of 24
-------
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Focused Treatment Area
June 2013
Appendix J
Table 14.3
Detailed Cost, ERH
Well Field Equipment Installation
Montrose Superfund Site
Los Angeles, California
Item
Consultant Labor and Direct Costs
Quantity
Unit Cost
Cost
1
Electrical Service Upgrade
1
$ 50,000
LS
$ 50,000
2
Natural Gas Pipeline
1
$ 200,000
LS
$ 200,000
3
Electrode Well Equipment and Piping
a
Electrodes (3 per Electrode Well)
306
$ 1,500
Each
$ 459,000
b
Armored Electrical Cable
2380
$ 4.89
Foot
$ 11,638
c
1.5-Inch Carbon Steel Pipe and Fittinqs for Recirc Water Delivery
2380
$ 12.00
LF
$ 28,560
Total Electrode Well Equipment
$ 499,198
4
Groundwater Extraction Assemblies
a
Well Head Assemblies
66
$ 1,000
Each
$ 66,000
b
Extraction Pump (High Temperature Hammerhead Pro)
66
$ 3,070
Each
$ 202,620
c
Downwell Air Supply Hose (3/8" SS Brainded, Teflon Lined)
6600
$ 11
LF
$ 72,600
d
Downwell Air Exhaust Hose (1/2" SS Brainded, Teflon Lined)
6600
$ 16
LF
$ 105,600
e
Downwell Discharge Hose (1/4" SS Brainded, Teflon Lined)
6600
$ 22
LF
$ 145,200
Total Groundwater Extraction Assemblies
$ 592,020
5
Steam Injection Well Head Assemblies
0
$ 7,000
Each
$
6
Field Technician - Pump and Well Head Assembly Construction and Installation
(Consultant Labor - Not Subject to Markup)
1,370
$ 75
Hour
$ 102,750
7
Steam Injection Piping
a
6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
0
$ 67.65
LF
$
b
4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
0
$ 43.45
LF
$
c
2-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
0
$ 34.10
LF
$
Total Steam Injection Piping
$
8
Vapor Extraction Piping
a
8-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
605
$ 94.71
LF
$ 57,300
b
6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
1810
$ 67.65
LF
$ 122,447
c
4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
677
$ 43.45
LF
$ 29,416
Total Vapor Extraction Piping
$ 209,162
J-14.3 Well Field Equipment Installation Cost
Page 10 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area AppGndix J
June2013 Table 14.3
Detailed Cost, ERH
Well Field Equipment Installation
Item
Consultant Labor and Direct Costs
Quantity
Unit Cost
Cost
Cost
Ref.
9
a
b
c
d
e
f
10
11
Groundwater Extraction Piping
4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
2-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
1.5-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket)
Total Piping Length
Piping Heat Trace, VLBTVWire
Misc fittings and heat trace elements (30% of Groundwater Extraction Piping cost)
605
1810
677
3092
3092
1
$ 43.45
$ 34.10
$ 31.45
$ 15.75
$ 47,399.67
LF
LF
LF
LF
LF
LS
$ 26,287
$ 61,721
$ 21,292
$ 48,699
$ 47,400
4
4
4
6
4
Total Groundwater Extraction Piping
Compressed Air Pipe and Fittings (2-Inch Carbon Steel)
Pipe Supports
3092
309.2
$ 20.00
$ 200
LF
LF
$ 205,399
$ 61,840
$ 61,840
CONSULTANT LABOR COST
DIRECT COSTS w/10% MARKUP
$ 102,750
$ 2,067,404
TOTAL WELL FIELD EQUIPMENT INSTALLTION COST $ 2,170,154
Cost Source Reference
1 Verbal Quote from McMillan-McGee Corp.
2 McMaster-Carr Catalog Price
3 QED Environmental Systems, Inc. Quote Dated May 16, 2008
4 2007 RS Means Database. Unit price shown includes 10% inflation rate and local area cost factor.
5 Unit rate assumed to be approximately 40% higher than rate for 6-inch carbon steel pipe and fittings with fiberglass insulation and aluminum jacket.
6 2006 Raychem quote obtained by CH2MHILL
J-14.3 Well Field Equipment Installation Cost
Page 11 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubicyard) Los Angeles, California
Focused Treatment Area Appendix J
June 2013 Table 14.4
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Instrumentation and Controls Installation
Item
Consultant Labor and Direct Costs
Quantity
Unit Cost
Cost
Cost
Ref.
1
a
b
c
Steam Injection Wells
Pressure Gage (0-300 PSI)
Temperature Indicator
Orifice Plate and Transmitter
0
0
0
$
$
$
48
127
10,000
/Each
/Each
/Each
S
$
s
1
1
Total Steam Injection Wells and Piping l&Cs
$
-
2
Groundwater Exraction Pressure Gage (0-300 PSI)
66
$
48
/Each
$
3,168
1
3
Vapor Extraction Vacuum Gage (30 in Hg)
66
$
50
/Each
$
3,326
1
4
a
b
Thermocouple String
Type T Thermocouple Wire (24 Gauge w/Fiberglass Insulation and Jacket)
Analog Decoder
1,400
1
$
$
0.75
500
/Foot
/Each
s
s
1,050
500
2
Cost per Temp Monitoring Point
Number of Temperature Monitoring Points
s
1,550
14
Total Thermocouple String
21,700
5
Field Technician - Installation of Items 1 Through 4 (Instrumentation and Controls)
(Consultant Labor - Not Subject to Markup)
152
$
75
/Hour
$
11,400
6
Electrical Allowance (20% of Instrumentation and Controls cost)
1
$
8,458
/LS
$
8,458
7
Control System Allowance (30% of Instrumentation and Controls cost)
1
$
11,278
/LS
$
11,278
CONSULTANT LABOR COST
DIRECT COSTS w/10% MARKUP
$
$
11,400
52,724
TOTAL INSTRUMENTATION AND CONTROLS INSTALLATION COST
$
64,124
Cost Source Reference
1 Grainger Catalog Price
2 McMaster-Carr Catalog Price
J-14.4 Instrumentation and Controls Installation Cost
Page 12 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June 2013 t-_ i_i _ j j f
Table 14.5
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Treatment Equipment Installation
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
1
a
b
c
d
e
f
g
h
i
j
k
I
Vapor T reatment
12,000-gallon Brine Holding Tank
Fin-Fan Heat Exchanger
Steam-Regenerable Carbon System
(incl. two 5,000-lb GAC vessels, condenser, separator, and inline stack PID)
2MM BTUs/Hr Steam Generator (Gas Fired)
Water Softening Unit for Steam Generator
Interconnecting Piping (20% of Steam-Regen Carbon System cost)
5000-lb Polishing Vapor-Phase GAC Vessel
Orifice Plate and Transmitter
1000 SCFM Liquid Ring Vacuum Blower (standard cast iron construction)
Moisture Separator
500-Gallon Collection Tank
Transfer Pump (50 gpm)
1
1
1
1
1
1
2
2
2
1
1
9
$ 18,538
$ 14,306
$ 750,000
$ 5,000
$ 5,000
$ 150,000
$ 16,000
$ 10,000
$ 80,000
$ 4,000
$ 2,078
$ 536
/Each
/Each
/LS
/Each
/Each
/LS
/Each
/Each
/Each
/Each
/Each
/Each
$ 18,538
$ 14,306
$ 750,000
$ 5,000
$ 5,000
$ 150,000
$ 32,000
$ 20,000
$ 160,000
$ 4,000
$ 2,078
$ 4,820
1
2
3
4
5
6
1
7
Total for Vapor Treatment
S 1.165.742
2
a
b
c
d
e
f
g
h
i
j
k
Groundwater Exraction and Treatment
Shell and Tube Heat Exchanger
DNAPL/Water Separator
Groundwater Holding Tank
Two 3,000-lb Liquid-Phase GAC Vessels Each w/lnitial Virgin Coconut Shell GAC Fill
Air Compressor
500-Gallon Collection Tank
Cooling Tower (540 gpm Recirculation Rate)
Transfer Pump (50 gpm)
Transfer Pump (540 gpm)
Transfer Pump (145 gpm)
HiPOx System (50 gpm)
1
2
1
1
1
1
1
8
2
2
1
$ 22,112
$ 56,450
$ 50,000
$ 16,830
$ 20,000
$ 2,078
$ 37,713
$ 536
$ 2,756
$ 1,348
$ 768,750
/Each
/Each
/Each
LS
/Each
/Each
/Each
/Each
/Each
/Each
/Each
$ 22,112
$ 112,900
$ 50,000
$ 16,830
$ 20,000
$ 2,078
$ 37,713
$ 4,284
$ 5,513
$ 2,696
$ 768,750
8
9
10
11
1
12
7
13
7
14
Total for Groundwater Exraction and Treatment Equipment
S 1.042.876
J-14.5 Treatment Equipment Installation Cost
Page 13 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June 2013 t-_ i_i _ j j f
Table 14.5
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Treatment Equipment Installation
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
3
Equipment Pads and Containment
1
$ 150,000
/LS
s
150.000
11
4
80' X 110' Treatment Plant Building
1
$ 150,000
ILS
s
150.000
5
Subcontractor Installation Cost
1
$ 365,000
ILS
s
365.000
15
TOTAL TREATMENT EQUIPMENT INSTALLATION COST w/10% MARKUP
s
3.160.979
Cost Source Reference
1 Harrington Plastic Catalog Price
2 Heat Exchanger Sales and Engineering Company, LLC Quote Dated July 17, 2008
3 MEGTEC Systems, Inc. Quote Dated April 20, 2008
4 BakerCorp Quote Dated July 1, 2008
5 Yardley Pump and Vacuum Quote Dated July 18, 2008
6 Verbal Qoute from Enviro Supply and Services
7 Grainger Catalog Price
8 SEC Heat Exchanger Quote Dated July 1, 2008
9 Pan America Environmental Quote Dated July 28, 2008
10 BakerCorp Quoted Dated July 23, 2008
11 McMillan-McGee November 2006 Feasibility Study for Steam Injection, Page 34
12 Cooling Tower Systems Quote Dated July 2, 2008
13 McMaster-Carr Catalog Price
14 Unit price scaled down to a 75 gpm system from $2,050,000 quote from Applied Process Technologies (June 6, 2006) for a 200 gpm system.
15 Verbal Quote from J.C. Palomar Construction, Inc.
J-14.5 Treatment Equipment Installation Cost
Page 14 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
june 2013 Table 14.6
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Construction Management
Item
Consultant Labor
Quantity
Unit Cost
Cost
1
Project Manager
195
$150
/Hour
$ 29.250
2
Senior Engineer/Geologist
400
$125
/Hour
S 50.000
3
Mid-Level Engineer/Geologist
1,062
$100
/Hour
S 106.200
4
Junior/Field Engineer/Geologist
1,365
$ 75
/Hour
S 102.375
5
Field Technician
1.365
$ 75
/Hour
S 102.375
6
Clerical/Drafting
151
$ 50
/Hour
S 7.528
TOTAL CONSTRUCTION MANAGEMENT COST
$ 397,728
J-14.6 Construction Management Cost
Page 15 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 14.7
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Operations and Maintenance
Item
Consultant Labor (Operations)
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
3
4
5
6
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist (One Full Time Mid-Level Engineer)
Junior/Field Engineer/Geologist (One Full Time Junior Engineer)
Field Technician (Three Full Time Operators - 40 Hours per Week Each)
Clerical/Drafting
520
520
2,080
2,080
6,240
520
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 78,000
$ 65,000
$ 208,000
$ 156,000
$ 468,000
$ 26,000
Consultant Labor Cost for Operations
S 1.001.000
Item
Consultant Labor (Reporting, H&S, Data Mngt, and Website Maintenance)
Quantity
Unit Cost
Cost
Cost
Ref.
7
8
9
10
11
12
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
20
80
1,300
2,080
0
180
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
$ 3,000
$ 10,000
$ 130,000
$ 156,000
$ 9,000
Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance
S 308.000
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
13
a
14
a
b
c
d
e
f
Equipment Rentals
12-million BTUs/hr Low NOx Steam Generator (incl. water softening package)
0
$ 18,500
/Month
$
1
2
2
3
Total Equipment Rentals
Consumables (Excluding Utilities)
Salt for Steam Generator Feed Water Treatment
Virgin Coconut Shell Vapor-Phase Carbon (7,000-lbs of polishing GAC per month plus 10,000 lbs of
regen system carbon changed-out after six months)
Vapor-Phase Carbon Change-Out Service
Hydrogen Peroxide for HiPOx
Oxygen for HiPOx
3000-lb Liquid-Phase Carbon Change-Out (Includes T&D as Hazardous Waste)
52
94,000
10
166,650
1,165,100
48
$ 100
$ 1.07
$ 1,739
$ 3.00
$ 0.35
$ 6,746
/Week
/lb
/Change-Out
/Gal
/100 SCF
/Each
s
$ 5,200
$ 100,580
$ 17,390
$ 499,950
$ 407,785
$ 323,808
Total Consumables
S 1.354.713
J-14.7 Operations and Maintenance Cost
Page 16 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 14.7
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Operations and Maintenance
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
15
a
b
c
d
e
f
g
h
16
a
b
c
d
e
f
g
17
a
b
c
d
e
f
g
h
i
j
k
Waste Management
Vapor-Phase GAC Disposal (Listed Waste for Incineration)
(incl. 10,000 lbs of regen system carbon at year end)
Vapor-Phase GAC Transportation
Carbon Regen System Solvent Waste Disposal (Listed Waste for Incineration)
Carbon Regen System Solvent Waste Transportation - inlcude pre heat transport
Filtration Generated Waste Disposal (Listed Waste for Incineration)
Filtration Generated Waste Transportation
Boiler Water Pre-Treatment Brine and Blowdown Off-Site Disposal (non-Haz)
Boile Water Pre-Treatment Brine and Blowdown Transportation
80,000
5
169,500
5
39,300
3
43,526
5
$ 0.71
$ 4,286
$ 0.50
$ 3,650
$ 0.25
$ 2,800
$ 0.14
$ 950
/lb
/Load
/lb
/Load
/lb
/Load
/Gal
/1 0,000 Gals
$ 56,800
$ 21,430
$ 84,750
$ 18,250
$ 9,825
$ 8,400
$ 6,094
$ 4,750
4
4
5
5
5
5
6
6
7
7
8
8
8
9
10
10
10
11
12
12
13
Total Waste Management
Lab Analytical and Monitoring
Summa Can Rental
Vapor VOCs Analysis (EPA Method TO-15)
Liquid Pesticides (EPA Method 8260B)
Liquid VOC Analysis (EPA Method 8081 A)
Liquid pCBSA Analysis (Modifed EPA Method 314.0)
Tedlar Bags
TVA-1000B PID/FID Rental
288
288
288
288
24
240
12
$ 40
$ 200
$ 90
$ 95
$ 80
$ 10
$ 1,200
/Each
/Each
/Each
/Each
/Each
/Each
/Month
S 210.299
$ 11,520
$ 57,600
$ 25,920
$ 27,360
$ 1,920
$ 2,400
$ 14,400
Total Lab Analytical and Monitoring
Miscellaneous
Temporary Office 24'x60' Delivery and Setup
Temporary Office 24'x60' Rental
Temporary Office 24'x60' Demobilization
Temporary Storage Trailer
Portable Toilet Delivery
Portable Toilet Rental
Standby Generator (800 kW)
Maintenance Parts
Fed Ex and Deliveries
Temporary office comm. (internet, telephone, fax)
Operator Truck Usage (One Truck per Operator)
1
12
1
12
1
12
12
12
260
12
780
$ 2,939
$ 1,030
$ 1,746
$ 149
$ 22
$ 76
$ 8,775
$ 1,000
$ 150
$ 1,000
$ 100
/Each
/Month
/Each
/Month
/Each
/Month
/Month
/Month
/Day
/Month
/Day/Truck
S 141.120
$ 2,939
$ 12,356
$ 1,746
$ 1,784
$ 22
$ 908
$ 105,300
$ 12,000
$ 39,000
$ 12,000
$ 78,000
Total Miscellaneous
S 266.055
J-14.7 Operations and Maintenance Cost
Page 17 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
June2013 Table 14.7
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Operations and Maintenance
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
18
Steam License for UBA
0
$ 0.50 |/CY Treated
S
14
Total Subcontractor Cost (O&M Year 1)
S 1.972.186
Item
Utilities
Quantity
Unit Cost
Cost
Cost
Ref.
19
a
b
Electricity Usage
Electrodes in UBA
HiPOx and other Treatment Equipment
11,680,994
10,148,151
$ 0.1045
$ 0.1045
/kWh
/kWh
$
$
1,220,664
1,060,482
15
15
Total Electricity Usage
S
2.281.146
20
Natural Gas for Steam Generation
53,702
$ 1.14
/Therm
s
61.220
16
21
a
b
c
Municipal Water
Cooling Tower Makeup Water (5 GPM)
Municipal Water for Steam Generation
water for electrodes
2,628,000
518,457
80,416,800
$ 0.0029
$ 0.0029
$ 0.0029
/Gal
/Gal
/Gal
$
$
$
7,621
1,504
233,209
Total Municipal Water Usage
s
242.333
Total Utilities
s
2.584.699
FULL SCALE CONSULTANT LABOR COST
S
1.309.000
FULL SCALE SUBCONTRACTOR COST w/10% MARKUP
S
2.169.405
UTILITIES COST (NO MARKUP)
S
2.584.699
TOTAL OPERATIONS AND MAINTENANCE COST
S
6.063.104
J-14.7 Operations and Maintenance Cost
Page 18 of 24
-------
Final DNAPL Feasibility Study
ERH (400 kW-hrs/cubic yard)
Montrose Superfund Site
Los Angeles, California
Focused Treatment Area
June 2013
Appendix J
Table 14.7
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Operations and Maintenance
Cost Source Reference
1 Nationwide Boiler Quote Dated July 30, 2008
2 BakerCorp Quote Dated June 30, 2008. Unit price for carbon change-out services is scaled down for a 9,400-lb change-out from BakerCorp quote of $1,850 per change-out for 10,000 lbs.
3 BakerCorp Quote July 23, 2008
4 NRC Environmental Services, Inc. Quote Dated June 30, 2008
5 Clean Harbors Quote Dated October 10, 2007
6 NRC Environmental Services, Inc. Email Quote Dated July 18, 2008
7 Verbal Quote from Calscience Environmental Laboratories, Inc.
8 Verbal Quote from Test America
9 Verbal Quote from Ashtead Technology Rentals
10 Mobile Mini, Inc. Quote Dated October 11, 2007
11 Verbal Quote from Mobile Mini, Inc.
12 Verbal Quote from A-1 Coast Port-A-Toilet
13 Kohler Rental Quote Dated June 30, 2008
14 McMillan-McGee November 2006 Feasibility Study for Steam Injection, Page 33
15 Shedule A-3 LADWP Rate (Second Quarter 2008)
16 GN-10, Tier III, SoCal Gas Co. Rate (Effective May 1, 2008)
J-14.7 Operations and Maintenance Cost
Page 19 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
june 2013 Table 14.8
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Abandonment
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
3
4
5
6
Project Manager
Senior Engineer/Geologist
Mid-Level Engineer/Geologist
Junior/Field Engineer/Geologist
Field Technician
Clerical/Drafting
70
420
170
1,872
70
70
$ 150
$ 125
$ 100
$ 75
$ 75
$ 50
/Hour
/Hour
/Hour
/Hour
/Hour
/Hour
S 10.500
S 52.500
S 17.000
S 140.400
S 5.250
S 3.500
Total Consultant Labor Cost
S 229.150
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
1
2
a
b
c
d
e
f
g
Mobilization/Demobilization of Drill Rig
Abandon UBA Multi-Phase Extraction Wells
Drill out well materials (upper 15 feet)
Pressure grout well
Forklift and mini-hopper
Abandonment Crew per Diem
Vehicle Usage
Equipment Rental and Supplies
Other Direct Costs
Cost per Well
Number of Wells (1 Well Abandoned per Day)
1
15
108
1
1
1
1
1
$ 2,000
$ 65
$ 30
$ 500
$ 200
$ 100
$ 150
$ 150
/LS
/Foot
/Foot
/Day
/Night
/Day
/Day
/Day
$ 2,000
S 975
S 3.240
S 500
S 200
S 100
S 150
S 150
S 5.315
66
1
1
1
1
Total for UBA Multi-Phase Extraction Well Adandonment
350,790
J-14.8 Well Abandonment Cost
Page 20 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
june 2013 Table 14.8
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Abandonment
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
3
Abandon Electrode Wells
a
Drill out well materials (upper 15 feet)
15
$
65
/Foot
S
975
1
b
Pressure Grout Electrodes
105
$
30
/Foot
S
3.150
1
c
Forklift and mini-hopper
1
$
500
/Day
S
500
1
d
Abandonment Crew per Diem
1
$
200
/Night
S
200
e
Vehicle Usage
1
$
100
/Day
S
100
f
Equipment Rental and Supplies
1
$
150
/Day
S
150
g
Other Direct Costs
1
$
150
/Day
S
150
Cost per Well
S
5.225
Number of Wells (1 Well Abandoned per Day)
102
Total for Electode Well Adandonment
532,950
4
Abandon Hot Floor Multi-Phase Extraction Wells
a
Pressure grout well
118.5
$
30
/Foot
S
3.555
1
b
Forklift and mini-hopper
1
$
500
/Day
S
500
1
c
Abandonment Crew per Diem
1
$
200
/Night
S
200
d
Vehicle Usage
1
$
100
/Day
S
100
e
Equipment Rental and Supplies
1
$
150
/Day
S
150
f
Other Direct Costs
1
$
150
/Day
S
150
Cost per Well
S
4.655
Number of Wells (1 Well Abandoned per Day)
0
Total for Hot Floor Multi-Phase Extraction Well Abandonment
$
J-14.8 Well Abandonment Cost
Page 21 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
june 2013 Table 14.8
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Abandonment
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
5
Abandon Hot Floor Steam Injection Wells
a
Pressure grout well
115.5
$
30
/Foot
S
3.465
1
b
Forklift and mini-hopper
1
$
500
/Day
S
500
1
c
Abandonment Crew per Diem
1
$
200
/Night
S
200
d
Vehicle Usage
1
$
100
/Day
S
100
e
Equipment Rental and Supplies
1
$
150
/Day
S
150
f
Other Direct Costs
1
$
150
/Day
S
150
Cost per Well
S
4.565
Number of Wells (1 Well Abandoned per Day)
0
Total for Hot Floor Steam Injection Well Abandonment
$
-
6
Abandon Temperature Monitoring Points
a
Pressure grout well
105
$
30
/Foot
S
3.150
1
b
Forklift and mini-hopper
1
$
500
/Day
s
500
1
c
Abandonment Crew per Diem
1
$
200
/Night
s
200
d
Vehicle Usage
1
$
100
/Day
s
100
e
Equipment Rental and Supplies
1
$
150
/Day
s
150
f
Other Direct Costs
1
$
150
/Day
s
150
Cost per Well
s
4.250
Number of Wells
14
Total for Temperature Monitoring Point Abandonment
$
59,500
J-14.8 Well Abandonment Cost
Page 22 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) _ Los Angeles, California
Focused Treatment Area Appendix J
june 2013 Table 14.8
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Well Abandonment
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Cost
Ref.
7
Waste Management
a
Waste Tank Rental
0
$
38
/Day
S
-
b
Waste Tank Rental Delivery - Mob and Demob
0
$
900
/Each
s
-
c
Waste Bin Rental
360
$
15
/Day
s
5.400
2
d
Waste Bin Rental Delivery - Mob and Demob
12
$
500
/Each
s
6.000
2
e
Transport of Hazardous Soil Cuttings
12
$
1,100
/Each
s
13.200
2
f
Disposal of Hazardous Soil Cuttings
186
$
550
/Ton
s
102.025
2
g
Transport of Hazardous Mud
0
$
500
/Each
s
-
h
Disposal of Hazardous Mud
0
$
1.1
/Gal
s
-
i
Transport of Hazardous Water
1
$
1,100
/Each
s
1.100
2
j
Disposal of Hazardous Water
1517
$
0.8
/Gal
s
1.214
2
k
Waste Characterization/Profiling
2
$
500
/Each
s
1.000
Total Waste Management
s
129.939
Total Subcontractor Cost w/10% Markup
$
1,182,696
TOTAL WELL ABANDONMENT COST $ 1,411,846
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Verbal Quote from NRC Environmental Services
J-14.8 Well Abandonment Cost
Page 23 of 24
-------
Final DNAPL Feasibility Study Montrose Superfund Site
ERH (400 kW-hrs/cubic yard) Los Angeles, California
Focused Treatment Area Appendix J
june 2013 Table 14.9
Detailed Cost, ERH (400 kW-hrs/cubic yard)
Demobilization
Item
Consultant Labor
Quantity
Unit Cost
Cost
Cost
Ref.
1
Project Manager
55
$
150
/Hour
s
8,250
2
Senior Engineer/Geologist
180
$
125
/Hour
s
22,500
3
Mid-Level Engineer/Geologist
572
$
100
/Hour
s
57,200
4
Junior/Field Engineer/Geologist
720
$
75
/Hour
s
54,000
5
Field Technician
380
$
75
/Hour
s
28,500
6
Clerical/Drafting
125
$
50
/Hour
s
6,250
Consultant Labor Cost
$
176,700
Cost
Item
Subcontractor Cost
Quantity
Unit Cost
Cost
Ref.
7
Remove Purchased Treatment Equipment
1
$
317,000
/ LS
$
317,000
8
Close-Out Borings
a
Drilling
9
$
12,000
/Boring
s
108,000
1
b
Waste Disposal
9
$
5,500
/Boring
s
49,500
2
c
Soil Pesticides (EPA Method 8081A)
54
$
90
/Sample
s
4,860
3
d
Soil VOCs (EPA Method 8260B)
54
$
95
/Sample
s
5,130
3
e
Soil pCBSA (Modified EPA Method 314.0)
54
$
80
/Sample
s
4,320
3
f
Liquid Pesticides (EPA Method 8081A)
9
$
90
/Sample
s
810
3
g
Liquid VOCs (EPA Method 8260B)
9
$
95
/Sample
s
855
3
h
Liquid pCBSA (Modified EPA Method 314.0)
9
$
80
/Sample
$
720
3
Total for Close-Out Borings
$
174,195
Total Subcontractor Cost w/10% Markup
$
540,315
| TOTAL DEMOBILIZATION COST
$ J,*
I
Cost Source Reference
1 Verbal Quote from Water Development Corporation
2 Verbal Quote from NRC Environmental Services
3 Verbal Quote from Test America
J-14.9 Demobilization Cost Page 24 of 24
-------
APPENDIX E ARARS FOR THE SELECTED REMEDY
363
-------
APPENDIX E
DNAPL ARARs and TBCs
Montrose Superfund Site
Authority
Citation
Synopsis of Requirement
Action to be Taken to Attain Requirement
Applicable
Relevant and Appropriate
TBC
Porter-Cologne
Water Act (CWA),
California Water
Code
California Water Code
§13140-13147
Establishes water quality objectives, including narrative and
numerical standards and establishes implementation plans to
meet objectives and protect beneficial uses. Incorporates state-
wide water quality control plans and policies.
Restoration of groundwater associated with the Montrose Site
was addressed by the 1999 Groundwater ROD. A Technical
Impracticability (Tl) Waiver Zone was established for
groundwater underlying the Site and extends beyond the
extent of the DNAPL operable unit. The DNAPL remedy will
remove mobile DNAPL and protect waters of the State outside
of the Tl waiver zone.
Any contaminants reinjected from the DNAPL treatment
system will be conveyed to the groundwater treatment system
for treatment and reinjection pursuant to the 1999
Groundwater ROD and its ARARs, except as waived in the Tl
waiver zone.
South Coast Air
Quality Managemenl
District (SCAQMDJj
Permit Screening
Emission Level for
Chloroform
SCAQMD Permit
tApplication Package
L", Table 1A,
September 10, 2010
SCAQMD has established screening emission levels for various
toxic air contaminants to determine if a screening risk
assessment should be performed. The screening emission levels
for chloroform, at three distances from the emission source, are
as follows (may vary based upon cumulative health risk of all
toxic air contaminants being emitted):
Acute:
Chloroform is a site-related VOC that may be generated by the
DNAPL remedy. An assessment of emissions in comparison to
these screening levels is used to determine if a more detailed
screening risk assessment is required under SCAQMD Rule
1401.
25 Meters: .0852 pounds per year
50 Meters: .17 pounds per year
100 Meters: .456 pounds per year
Chronic:
25 Meters: 6.01 pounds per year
50 Meters: 15.8 pounds per year
100 Meters: 47.0 pounds per year
Migratory Bird
T reaty Act
Title 16 USC
§703-712
Except as permitted by regulations, it is unlawful to pursue, hunt,
take, capture, offer to sell, barter, purchase, or deliver any
migratory bird, nest, or egg.
No migratory birds, nests, or eggs are currently present at the
Site; however, these regulations would be applicable if
migratory birds were discovered at the site during DNAPL
remedy implementation.
Page 1 of 8
-------
APPENDIX E
DNAPL ARARs and TBCs
Montrose Superfund Site
Authority
Citation
Svnoosis of Requirement
Action to be Taken to Attain Reauirement
Applicable
Relevant and AoDrooriate
TBC
Endangered Species
Act of 1973;
Protection of
Endangered and
Threatened Species
Title 16 USC §1531 et.
seq.;
50 CFR Parts 17 and
402
Requires action to conserve endangered species and critical
habitats upon which endangered species depend. Includes
consultation with the Dept. of the Interior.
Activities at all remedial sites must be performed in such a
manner as to identify the presence of and protect endangered or
threatened plants and animals at the site.
No known endangered species are currently present at the
site; however, these regulations will be considered and
followed if endangered or threatened species are discovered.
Remedial actions should avoid disturbance of terrain which is
habitat for endangered species.
X
State Water
Resources Control
Board (SWRCB)
Resolution No. 68-16
Statement of Policy
with Respect to
Maintaining High
Quality of Waters in
California; Water
Code §13140
State Anti-degradation Policy sets forth in State Board Resolution
No. 68-16, which has been incorporated into all Regional Board
Basin Plans. The resolution requires protection of the existing
quality of water whenever it is better than that necessary to
protect present and potential beneficial uses. Applies to the
discharge of waste to waters, including re-injection into the
aquifer.
Within the Tl Waiver Zone, the 1999 Groundwater ROD
requires groundwater treatment in compliance with the
conditions established for the Tl Waiver Zone.
Any contaminants reinjected from the DNAPL treatment
system will be conveyed to the groundwater treatment
system for treatment and reinjection pursuant to the 1999
Groundwater ROD and its ARARs, except as waived in the Tl
waiver zone.
X
State Water
Resources Control
Board (SWRCB)
Resolution No. 92-49
III.G
23 CCR §2550.4
Background Water
Quality; Policy and
Procedures for
Investigation and
Cleanup and
Abatement of
Discharges under
Water Code §13304
To protect groundwater, the resolution requires cleanup to
either background water quality or the best water quality that is
reasonable if background water quality cannot be restored. Non-
background cleanup levels must be consistent with maximum
benefit to the public, present and anticipated future beneficial
uses, and conform to water quality control plans and policies.
Restoration of groundwater quality associated with the
Montrose Site was addressed by the 1999 Groundwater ROD.
A Tl Waiver Zone was established for groundwater underlying
the Site and extends beyond the extent of the area impacted
by the DNAPL remedy.
Any contaminants reinjected from the DNAPL treatment
system will be conveyed to the groundwater treatment system
for treatment and reinjection pursuant to the 1999
Groundwater ROD and its ARARs, except as waived in the Tl
waiver zone.
X
Page 2 of 8
-------
APPENDIX E
DNAPL ARARs and TBCs
Montrose Superfund Site
Authority
Citation
Svnoosis of Requirement
Action to be Taken to Attain Reauirement
Applicable
Relevant and AoDrooriate
TBC
Code of Federal
Regulations and
California Code of
Regulations
Identification and
Characterization of
Hazardous Waste
40 CFR Part 261 et
seq.
22 CCR §66261 et
seq.
Defines wastes that are subject to regulation as a RCRA (or
California) hazardous waste. Contaminated soil and groundwater
(solid wastes), once extracted for treatment, must be managed
as state and federal hazardous waste if such soil or groundwater
contains levels of hazardous substances that meet or exceed
state and federal hazardous waste toxicity criteria for specific
hazardous wastes and/or contains one or more RCRA-listed
hazardous wastes.
40 CFR §261.24 identifies waste containing >100 mg/L
chlorobenzene as hazardous under the toxicity characteristic
(waste code D021).
40 CFR 261.33 identifies waste containing DDT, as a discarded
commercial product, as hazardous (waste code U061).
In addition to federal hazardous waste standards, California also
has specific state-regulated hazardous wastes. DNAPL exhibits
the characteristic of "toxicity" if representative samples have:
»100.0 mg/L chlorobenzene by Toxicity Characteristic Leaching
Potential (TCLP)
»1.0 mg/kg wet-weight DDT
» 0.1 mg/L DDT by Soluble Threshold Limit Concentration (STLC)
These regulations establish provisions for characterizing
wastes as hazardous (characteristic or by rule) and are
applicable to DNAPL solid wastes. The determination of
whether wastes generated during remedial activities are
hazardous will be made at the time the wastes are generated.
Some contaminated media treated to specified cleanup levels
will no longer need to be managed as a hazardous waste;
applicable to toxicity characteristic wastes (e.g.,
chlorobenzene, federal waste code D021).
X
Page 3 of 8
-------
APPENDIX E
DNAPL ARARs and TBCs
Montrose Superfund Site
Authority
Citation
Svnoosis of Requirement
Action to be Taken to Attain Reauirement
Applicable
Relevant and AoDrooriate
TBC
Solid Waste Disposal
Act and Resource
Conservation and
Recovery Act (RCRA)
Code of Federal
Regulations and
California Code of
Regulations
Generators of
Hazardous Waste
40 CFR Part 262 et
seq. 22 CCR §66262 et
seq. Ch 12
incorporates by
reference:
• 49 CFR parts 172,
173, 178, and
179
• 40 CFR part 265,
Subparts C, D, 1,
J, AA, BB, CC
• 22 CCR Chapter
15, Articles 3, 4,
9, 10, 27, 28, and
28.5
Under 42 (JSC §6901 et seq., RCRA mandates "cradle-to-grave"
management of hazardous waste, and regulates three types of
hazardous waste handlers: (1) generators, (2) transporters, and
(3) owners and operators of treatment, storage, or disposal
facilities (TSDFs). Only the substantive requirements of RCRA
must be met if a CERCLA action is to be conducted on-site (does
not require RCRA permits, nor compliance with the
administrative requirements).
Standards applicable to generators include requirements for
waste determination, reporting, shipment, packaging, labeling,
accumulation, documentation, and recordkeeping.
In California, the State's promulgated regulations replace the
equivalent Federal regulations as potential ARARs. See RCRA
3006(b), and 40 CFR §271. See Chapter 6.5 of H&S Code (HWCA),
§25100 et seq.
DNAPL associated with the former operations of the Montrose
plant may be classified as a California and/or RCRA hazardous
waste, if the source of any toxic constituents (such as MCB) in
the DNAPL is known (i.e., a listed waste). If the source of the
toxic constituents is not generally known, the DNAPL may still
be classified as a characteristic hazardous waste (e.g., toxicity,
flammability, etc.). If the source of the toxic constituents is
generally not known and the DNAPL and/or DNAPL-related
waste (e.g., filters or PPE) is not characteristically hazardous,
then the waste will not be classified as hazardous. In the
course of remediating the DNAPL contamination, DNAPL
and/or DNAPL- related waste will be generated, accumulated
and possibly stored, and transported for off-site disposal.
X
Resource
Conservation and
Recovery Act (RCRA)
Interim Control of
Hazardous Waste
Injection
42 U.S.C. §6939b(b)
Under 42 U.S.C. §6939b(b), for actions under CERCLA,
contaminated groundwater must be treated to substantially
reduce hazardous constituents prior to reinjection into the
aquifer from which it was withdrawn, if the water-bearing units
beneath the site are a underground source of drinking water.
Hazardous constituents in extracted groundwater will be
substantially reduced prior to reinjection either through
removal of separate-phase DNAPL and/or through removal of
dissolved-phase constituents. The degree of reduction that will
be considered "substantial" will be determined on a case-by-
case basis.
X
Code of Federal
Regulations and
California Code of
Regulations
Land Disposal
Restrictions
40 CFR Part 268 et
seq., 22 CCR §66268
et seq.
Chapter 18 of both 40 CFR and 22 CCR identifies hazardous
wastes that are restricted from land disposal and defines those
limited circumstances under which an otherwise prohibited
waste may continue to be land disposed. This chapter includes
regulations governing various aspects of land disposal
requirements, including waste analysis, treatment, and storage
and recordkeeping.
22 CCR §66268.100 establishes land disposal prohibitions for
non-RCRA hazardous wastes.
"Disposal" means:
(a) the discharge, deposit, injection, dumping, spilling, leaking
or placing of any waste or hazardous waste into or on any
land or water so that such waste or any constituent thereof
may enter the environment or be emitted into the air or
discharged into any waters, including groundwaters;
(b) the abandonment of any waste.
Hazardous waste generated from the DNAPL remedy is
required to comply with the applicable provisions of these
regulations. Land disposal restrictions would not be triggered
if the media is treated to reduce contaminant concentrations
in compliance with the treatment standards.
X
Page 4 of 8
-------
APPENDIX E
DNAPL ARARs and TBCs
Montrose Superfund Site
Authority
Citation
Svnoosis of Requirement
Action to be Taken to Attain Reauirement
Applicable
Relevant and AoDrooriate
TBC
California Hazardous
Waste Control Act
(HWCA)
California Health and
Safety Code §25100,
et seq.
HWCA has many elements that control hazardous wastes from
their point of generation through handling, treatment, and
ultimate destruction or disposal.
Wastes generated during DNAPL remedy implementation is
required to meet these standards as noted in the regulations
referred to herein.
X
South Coast Air
Quality Management
District (South Coast
AQMD)
Rule 201 and 201.1
Requires that any person building, erecting, installing, altering or
replacing any equipment which may cause the discharge of air
contaminants obtain a permit and construct/operate the
equipment in accordance with the permit conditions.
DNAPL remedy must have vapor control and treatment
systems, designed to comply with the substantive portions of
South Coast Air Quality Management District requirements.
X
Regulation II
South Coast AQMD
Regulation IV
Rule 401
Limits the discharge of visible emissions.
Vapor control and treatment systems associated with the
DNAPL remedy must be designed and operated to comply with
these regulations to the extent applicable.
X
Rule 402
Prohibits discharge of pollutants that (i) cause injury, detriment,
nuisance, or annoyance, (ii) endanger the health or safety of the
public, or (iii) cause (or tend to cause) injury or damage to
business or property.
Vapor control and treatment systems associated with the
DNAPL remedy must be designed and operated to comply with
these regulations to the extent applicable.
X
Rule 403
Requires actions to prevent, reduce, or mitigate fugitive dust.
Soil handling during remedy construction and implementation
will need to comply with these requirements. Fugitive dust
would need to be controlled using water spray or other
common methods. Measurement of dust levels would be
performed to document compliance with this rule.
X
Rule 404
Prohibits discharge of particulate matter in excess of certain
concentrations.
Vapor control and treatment systems associated with the
DNAPL remedy must be designed and operated to comply with
these regulations to the extent applicable.
X
Rule 405
Prohibits discharge of solid particulate matter in excess of certain
rates.
Vapor control and treatment systems associated with the
DNAPL remedy must be designed and operated to comply with
these regulations to the extent applicable.
X
Rule 408
Cannot build, install or use any equipment that reduces or
conceals an emission that would otherwise be a violation.
Vapor control and treatment systems associated with DNAPL
remedy must be designed and operated to comply with these
regulations to the extent applicable.
X
Page 5 of 8
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APPENDIX E
DNAPL ARARs and TBCs
Montrose Superfund Site
Authority
Citation
Svnoosis of Requirement
Action to be Taken to Attain Reauirement
Applicable
Relevant and AoDrooriate
TBC
South Coast AQMD
Regulation IV (cont.)
Rule 409
Limits the emission of particulate matter from a combustion
source to 0.10 grain per standard cubic foot, at 12% carbon
dioxide, averaged over 15 minutes.
Vapor control and treatment systems associated with DNAPL
remedy must be designed and operated to comply with these
regulations to the extent applicable. This rule is potentially
applicable to natural gas fired steam boilers or thermal
oxidizers.
X
Rule 466
Any pump, compressor, valve, etc exposed to reactive organic
compounds must be equipped with adequate seals and in good
working order, except for equipment that is exempted from the
requirements for reasons listed in the rule, including equipment
in contact with liquid with greater than 80% water content.
Vapor control and treatment systems associated with the
DNAPL remedy must be designed and operated to comply with
these regulations to the extent applicable.
X
Rule 474
Limits the concentration of oxides of nitrogen to a range of 125
to 300 ppm for gaseous fuels and 225-400 ppm for solid and
liquid fuels depending on equipment size.
If the Vapor control and treatment systems associated with
the DNAPL remedy meets applicable equipment size, then the
DNAPL remedy must be designed and operated to comply with
these regulations.
This rule includes provisions for steam generating equipment
using steam boilers subject to the rule. This rule would
additionally apply to natural gas-fired thermal oxidizers for
treatment of vapor-phase contaminants if applicable.
X
Rule 476
Steam generating equipment: Prohibits discharge into the
atmosphere of certain combustion contaminants from
equipment having a heat input rate of more than 50 million
BTUs.
Steam generating equipment used for the DNAPL treatment
system would need to comply with this rule if rated at more
than 50 million BTUs.
X
South Coast AQMD
Regulation XI
Rule 1146
Prohibits discharge of certain limits of nitrogen dioxide from
steam generators and process heaters rated greater than 5
million BTUs per hour (or between 2-5 million for small
operators).
Vapor control and treatment systems associated with the
DNAPL remedy (e.g., steam generators used for thermal
treatment) must be designed and operated to comply with the
substantive requirements of these regulations to the extent
applicable.
X
Rule 1166
Regulates volatile organic compound (VOC) emissions from
decontamination of soil. This rule establishes requirements for
excavation, grading, or handling of soil containing VOCs (i.e., to
prevent uncontrolled evaporation of VOCs to the atmosphere).
More than one cubic yard of VOC-impacted soils (e.g.,
chlorobenzene) will be subject to this rule. Soil cuttings
generated during remedy construction (i.e., well installation)
would be subject to this rule and must be handled in a manner
consistent with the provisions of this rule to minimize
evaporation of VOCs to atmosphere during soil handling.
X
Page 6 of 8
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APPENDIX E
DNAPL ARARs and TBCs
Montrose Superfund Site
Authority
Citation
Svnoosis of Requirement
Action to be Taken to Attain Reauirement
Applicable
Relevant and AoDrooriate
TBC
South Coast AQMD
Regulation XI (cont.)
Rule 1166 (cont.)
This rule includes requirements for monitoring, odor control,
stockpiling, segregation, loading, and transporting VOC-impacted
soils. Handling of less than one cubic yard of VOC-impacted soil is
exempt from this rule.
Rule 1176
Regulates volatile organic compound leaks and emissions from
facilities.
Vapor control and treatment systems associated with DNAPL
remedy alternatives must be designed and operated to comply
with these regulations to the extent applicable.
X
South Coast AQMD
Regulation XIII
Rule 1301
Sets forth pre-construction review requirements for new,
modified, or relocated sources/facilities, to ensure that the
operation of such facilities does not interfere with progress in
attainment of the national ambient air quality standards.
Vapor control and treatment systems associated with DNAPL
remedial alternatives must be designed and operated to
comply with these regulations by using the Best Available
Control Technology (BACT).
X
South Coast AQMD
Regulation XIV
Rule 1401
New source review of toxic air contaminants. This rule specifies
limits for maximum individual cancer risk (MICR), cancer burden,
non-cancer acute, and chronic hazard index. This rule limits
emissions of toxic air contaminants to:
(a) an MICR less than 1x10 s for systems without best
available control technology (BACT);
(b) an MICR less than lxlO"5 for systems with BACT;
(c) a cancer burden less than 0.5;
(d) a chronic hazard index less than 1.0;
(e) a non-cancer acute hazard index less than 1.0.
This rule establishes the primary air emission limits for site-
related toxic air contaminants including chlorobenzene and
chloroform.
Chloroform contributes to the MICR and cancer burden.
Chlorobenzene is not a carcinogen and only contributes to the
hazard index.
Vapor control and treatment systems associated with DNAPL
remedy must be designed and operated to comply with this
rule.
X
South Coast AQMD
Rule 1470
Requirements for Stationary Diesel-Fueled Internal Combustion
and Other Compression Ignition Engines. This rule applies to any
person who owns or operates a stationary IC engine in the South
Coast Air Quality Management District with brake horsepower
greater than 50. This rule controls the particulate matter
emissions from such engines by establishing fuel requirements,
operating requirements, emission standards, and reporting and
monitoring requirements.
During implementation of the DNAPL remedy (primarily during
construction), large diesel engines may be used for specific
tasks, e.g., drilling rigs, air compressor, or mobile generator.
For diesel engines with greater than 50 brake horsepower,
only engines with valid and current SCAQMD emission
certificates will be used.
Any large diesel engines without a valid emissions certification
will be prohibited from working at the site.
X
Page 7 of 8
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APPENDIX E
DNAPL ARARs and TBCs
Montrose Superfund Site
Authority
Citation
Svnoosis of Requirement
Action to be Taken to Attain Reauirement
Applicable
Relevant and AoDrooriate
TBC
Land Use Covenant
Regulation
22CCR §67391.1 (a),
(d)
Establishes substantive requirements for land use restrictive
covenants.
Since hazardous materials, hazardous wastes, or constituents, or
hazardous substances will remain at the property after
implementation of the remedy at levels which are not suitable or
unrestricted use of the land, this requirement is relevant and
appropriate.
A response action decision document which includes
limitations on land use or other institutional controls, requires
that the limitations or controls are clearly set forth and
defined in the response action decision document, specifies
that the limitation or controls will be incorporated into an
appropriate land use covenant as required by Section 67391.1,
and includes an implementation and enforcement plan. The
DNAPL remedy will be subject to these standards.
X
Environmental
Covenant
Requirements
CA Civil Code §1471
Specifies manner by which environmental covenants are
recorded and binding on successors to the land restricted by the
covenant.
Since hazardous materials, hazardous wastes or constituents,
or hazardous substances will remain at the property after
implementation of the remedy at levels which are not suitable
for unrestricted use of the land, this requirement is relevant
and appropriate. The DNAPL remedy will be subject to these
standards.
X
Mandatory
Greenhouse Gas
Reporting Rule
40 CFR Part 98
Establishes reporting requirements for sources generating in
excess of 25,000 metric tons per year of greenhouse gases.
Estimated emissions of greenhouse gases, certified by a third
party, must be submitted to EPA.
X
TO BE CONSIDERED (TBCs)
California Well
Standards,
Department of
Water Resources
Bulletins 74-90 and
74-81
Provides minimum construction and destruction/abandonment
criteria and specifications for groundwater monitoring wells,
extraction wells, injection wells, and exploratory borings.
The standards are meant to be a model of minimum standards
and are enforced locally through Los Angeles County, but are not
enforced by the State.
Design, construction, and destruction of wells or borings into
the saturated zone must comply with the substantive portions
of these standards. Hydraulic displacement and thermal
remediation technologies would include wells installed within
the saturated zone at the Site and would be subject to these
standards.
X
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