AROlW SFUND RECORDS CTR SFUND RECORDS CTR 88105497 … · Cancer slope factors Dichloroethane Department of Toxic Substances Control ... If at the five year review the regional aquifer

SFUND RECORDS CTR AROlW |

SFUND RECORDS CTR

88105497

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

RECORD OF DECISION

GROUNDWATER OPERABLE UNIT

MCCOLL SUPERFUND SITE FULLERTON, CALIFORNIA

May 9, 1996

TABLE OF CONTENTS

Page

SITE NAME AND LOCATION 1

STATEMENT OF BASIS AND PURPOSE 1

ASSESSMENT OF THE SITE 1

DESCRIPTION OF THE REMEDY 1

STATUTORY DETERMINATIONS 2

DECISION SUMMARY 2 I. SITE LOCATION AND DESCRIPTION 3

A. Site Name and Location 3 B. Site Description 3 C. Land and Water Use 3 D. Regional Topography 6 E. Hydrology 6

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 7 A. Source Remedy (Operable Unit) 7 B. Groundwater Investigation Conducted by Agencies 7 C. RI/FS Performed by McColl Site Group (MSG) under US EPA Order . 9

III. HIGHLIGHTS OF COMMUNITY INVOLVEMENT 10 IV. SCOPE AND ROLE OF THE RESPONSE ACTION 10 V. SUMMARY OF SITE CHARACTERISTICS (GROUNDWATER) 11

A. Groundwater 11 Orqanics (not including THT compounds) 12 Tetrahvdrothiophene (THT) Compounds 12 Inorganic Compounds 12

B. Data Validation 13 VI. SUMMARY OF SITE RISKS 13

Selection of Chemicals of Potential Concern 13 Toxicity Assessment 15 Exposure Assessment 16 Risk Characterization 17 Uncertainty 19 Conclusions 19

VII. DESCRIPTION OF ALTERNATIVES 19 A. Alternative #1 20 B. Alternative #2 20 C. Alternative #3 20 D. Alternative #4 21

VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 21 A. Protection of Human Health and The Environment 21 B. Compliance With ARARS 21 C. Long-Term Effectiveness and Permanence 22

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D. Reduction of Toxicity, Mobility, or Volume Through Treatment .... 22 E. Short-Term Effectiveness 22 F. Implementability 23 G. Cost 23 H. State Acceptance 23 I. Community Acceptance 24

IX. SELECTED REMEDY 24 X. STATUTORY DETERMINATIONS 25

A. Protection of Public and the Environment 25 B. Attainment of ARARS 25 C. Cost-Effectiveness 25 D. Use of Permanent Solutions and Alternative Treatment Technologies

or Resource Recovery Technologies to the Maximum Extent Practicable 25

E. Preference for Treatment as a Principal Element 26 F. Documentation of Significant Changes 26

LIST OF FIGURES

FIGURE 1 SITE LOCATION MAP 4 FIGURE 2 MCCOLL SITE 5 FIGURE 3 CAP AND SLURRY WALL FOR SOURCE OPERABLE UNIT REMEDY 8

LIST OF ATTACHMENTS

ATTACHMENT A ATTACHMENT B ATTACHMENT C

ADMINISTRATIVE RECORD INDEX PUBLIC MEETING COMMENTS RESPONSIVENESS SUMMARY

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ARARs CERCLA

COPC CSF DCA DTSC E&E EPA EPCs FS GAC HEAST HI IAC MCLs MCLGs MDLs /jg/L

MSG NCP NPL O&M OTC PPb PRG RAO RCRA RfDs Rl RME ROD SARA SVOCs THTs VOCs

LIST OF ACRONYMS

Applicable or relevant and appropriate requirements Comprehensive Environmental Response, Compensation, and Liability Act of 1980 Chemicals of potential concern Cancer slope factors Dichloroethane Department of Toxic Substances Control Ecology and Environment Environmental Protection Agency Exposure point concentrations Feasibility Study granular activated carbon Health Effects Assessment Summary Tables Hazard index Interagency Committee Maximum Contaminant Levels Maximum Contaminant Level Goals Method detection limits micrograms per liter McColl Site Group National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List Operation and maintenance Odor threshold concentration Parts per billion Preliminary remediation goal Remedial Action Objective Resource Conservation and Recovery Act Reference doses Remedial Investigation Reasonable maximum exposure Record of Decision Superfund Amendments and Reauthorization Act of 1986 Semi-volatile organic compounds Tetrahydrothiophene compounds Volatile organic compounds

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DECLARATION FOR THE GROUNDWATER OPERABLE UNIT RECORD OF DECISION

SITE NAME AND LOCATION

McColl Site 2650 Rosecrans Avenue Fullerton, CA 92633

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) presents the groundwater operable unit remedial action selected for the McColl Site in the City of Fullerton, County of Orange, California. This remedial action 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) (42 CFR § 9601 et sea.), and, to the extent practicable, with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR § 300 et seq.). The attached Administrative Record Index (Attachment A) identifies the documents upon which the decision is based. The State of California has commented in support of the selected remedy.

ASSESSMENT OF THE SITE

If the actual or threatened releases of hazardous substances from the Site are not addressed by implementing the remedial response action selected in this ROD, the Site may present an imminent and substantial endangerment to public health, welfare, or the environment.

DESCRIPTION OF THE REMEDY

EPA has selected Alternative #3 as presented in the Feasibility Study Report, Groundwater Operable Unit, McColl Superfund Site (EPA, February 1996) as the groundwater operable unit remedy for the McColl Site. The remedial action for groundwater is designed to work in conjunction with the remedial action for the McColl waste sumps, which includes capping of the sumps and construction of subsurface slurry walls around the sumps. The waste sump remedy will significantly reduce infiltration of site surface water and precipitation, thus reducing the potential for the sumps to impact groundwater in the future. The selected remedy for the contaminated groundwater operable unit for the McColl Site includes evaluation, design, and construction of infiltration controls to significantly (order of magnitude) reduce surface water infiltration from baseline estimates. These engineered controls will be implemented outside of the waste sump area. Measures/controls for consideration during design may include some or all of the following:

• Onsite management of surface water running onto the site property.

• Lining existing major drainage channels with low permeability materials.

• Grading or modifying (through placement of low permeability soils) areas adjacent to, but outside of the planned closure containment system.

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• Groundwater monitoring (including additional wells) to demonstrate that the infiltration controls are effectively preventing further migration of site contaminants to and throughout the regional aquifer.

• EPA or the relevant State agency will implement offsite institutional controls as a contingency measure. If at the five year review the regional aquifer beyond the current site boundary is found (in more than one offsite well) to contain site-specific contaminants above State or Federal Maximum Contaminant Levels (MCLs)1 or above the recommended (3.6 parts per billion (ppb)) or revised preliminary remediation goal (PRG) for tetrahydrothiophene (THT) compounds, offsite institutional controls will be implemented.

• Site maintenance and security until final operation and maintenance (O&M) plans take effect under the source operable unit remedy.

The groundwater remedy is intended to work in conjunction with the source remedy, and together will achieve the anticipated goal of protection of groundwater resources.

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment as required by section 121 of CERCLA. The selected remedial action, when complete, shall comply with applicable or relevant and appropriate environmental standards established under Federal and State environmental laws. The selected remedy is cost-effective and considered permanent treatment technologies to the maximum extent practicable. Because the source operable unit remedy2 will result in hazardous substances remaining onsite above health-based levels, a review will be conducted within five years after commencement of the remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment.

DECISION SUMMARY

This Decision Summary provides an overview of the problems posed by the McColl Site groundwater operable unit. It also includes a description of the remedial alternatives considered and the analysis of these alternatives against the criteria set forth in the NCP. The Decision Summary explains the rationale for the remedy selection and how the selected remedy satisfies the statutory requirements of CERCLA.

If both a Federal and a State of California MCL exist for a particular compound, the lower of the two MCLs is applied.

2 The June 1993 Record of Decision presents the source operable unit remedial action, which consists of a

closure/containment system remedy for the twelve waste sumps.

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I. SITE LOCATION AND DESCRIPTION

A. Site Name and Location

McColl Superfund Site 2650 Rosecrans Avenue Fullerton, California 92633

B. Site Description

The McColl Superfund Site (the "Site") is located in Orange County, California on the northwest edge of the City of Fullerton closely bordering the City of Buena Park (Figure 1). The 22 acre Site was the location of 12 disposal pits operated by Eli McColl from 1942 to 1946 (Figure 2). During the operation of the disposal pits various oil refining companies disposed of refinery waste, predominantly spent sulfuric acid catalyst.

The predominant type of waste at the site is a hard black (asphaltic) waste with smaller volumes of viscous waste, contaminated drilling mud, and soils. The hard and viscous waste is characterized as having a low pH, high sulfur content, high concentrations of organic sulfur compounds, aromatic hydrocarbons and aliphatic hydrocarbons.

The Los Coyotes Country Club Golf Course was built in 1956/1957, with a portion of the course overlying the covered waste sump area referred to as the Los Coyotes area. That portion of the golf course is currently closed. The McAuley LCX Corporation purchased the Los Coyotes Country Club in December 1980. The Ramparts area of the site was never developed. A housing tract borders the site immediately to the east and southeast. The Ralph B. Clark Regional (County) Park is adjacent to the west of the site boundary. The southern boundary of the site is the Los Coyotes golf course. The northern boundary is Rosecrans Avenue. All of the sumps are currently covered by overburden of varying thickness.

C. Land and Water Use

Use around the site is predominantly residential with some developed and undeveloped open space. The residential use throughout the area is single family homes on approximately quarter acre lots. The residences are valued in the $200,000 to $300,000 range. Site demographics are dominated by older European-American professionals with families or retirees. There has been an increase of Asian professionals (predominantly Korean) with young families throughout the late 1980s and 1990s.

Surface water flows from the upper reaches of the hills across the site from north to south. The largest of these drainage areas runs from the West Coyote Hills area to the north, into a drainage channel under Rosecrans and onto the site. Once onsite, this channel drains to the low-lying area to the north and west of the Los Coyotes waste pit area. Surface water from the Ramparts portion of the site and the eastern side of the Los Coyotes waste pits drains into a channel at the boundary of the southeastern portion of site and then into the regional surface water collection system.

Groundwater near the site is not currently used for public water supply. The nearest municipal well (Coyote Well 12A) is located at the corner of Gilbert and Pioneer, 3,000 feet crossgradient from the site.


Figure I: Site Location Map

J96-024.ed Mc 4 7

Figure 2: McColl Site Map Showing Locations of Monitoring Wells

W-9B »*W-9C

W-10B Rosecrans Avenue

Ralph B. Clark Regional Park

P-1D

McColl

Site w-4

Los Coyotes sump;4

P-21 }p-5l <^P-5S

P-5D Los Coyotes Golf Course

#-10D

•P-10L

P-9D

P-5L

P-6S P-6D

A N

L E G E N D

Perched Monitor Wells

• Regional Monitor Wells

• Site Boundary

Seal*tnfMt

J96-024.ed Mc 4 3

D. Regional Topography

As described in the Final Remedial Investigation Report, Groundwater Operable Unit, McColl Site (ENVIRON, December 1995), the site is located on the lower portion of the south side of the east-west trending West Coyote Hills at a median elevation of approximately 300 feet above mean sea level.

E. Hydrology

The regional hydrology consists of the near-surface sediment of the Pleistocene La Habra Formation. Beneath the relatively fine-grained La Habra Formation sediments are the coarser sandy gravels and gravelly sands of the Coyote Hills Formation. The sedimentary units dip approximately 10 degrees to the southwest.

Groundwater beneath the site is found in multiple shallow perched units and in the regional aquifer approximately 160 to 200 feet below the Site ground surface. The shallow perched units have been designated during the Remedial Investigation alphabetically from the shallowest to the deepest.

The shallowest perched groundwater unit is the "A" unit. The lower permeability layer of natural soils which underlies the "A" unit surfaces onsite in the vicinity of the Los Coyotes portion of the site. The "A" unit does not directly intersect with the regional aquifer near the site. The "A" unit is monitored by the following monitoring wells: P-2S and P-3S.

The "B" unit originates in the central portion of the site. The surface of the "B" unit low permeability layer is approximately 50 feet below the bottom of the Los Coyotes Sumps. The "B" unit is perched to the north of the southern McColl site boundary. Approximately five hundred feet south of the site, the "B" clay packet dips to the saturated interval of the "C" flow unit. The "B" unit is monitored by the following wells: P-2I, P-4I, P-5S, P-5I, P-6S, and P-10D.

The "C" unit originates in the upper (northern or upland) portions of the site. The surface of the "C" unit low permeability layer lies approximately 50 feet below the bottom of the Ramparts sumps/pits and 150 feet below the Los Coyotes portion of the site. Because of the characteristics of the subsurface conditions, the "C" zone is perched in the northern portion of the Site and is part of the regional aquifer in the southern portion of the site and to the south of the site. The "C" unit has been found to intersect the regional aquifer in the vicinity of well P-2D(R), at the southern site boundary. The wells that monitor the perched portion of the "C" unit are: W-6AandW-8A. The wells that monitor the "C" portion of the regional aquifer are: P-2D(R), P-3D, P-4D, P-5L, P-6D, P-9D, and P-10L.

A deeper "D" unit lies largely within the regional aquifer beneath the site. The "D" unit is monitored by the following wells: W-4, W-8B, W-9B, W-9C, W-10B, P-1D, and P-5D.

The gradient of the regional aquifer ("D" flow unit) is estimated to be approximately 0.0077 feet/feet beneath the McColl Site. Groundwater within the "A", "B", and "C" flow units is seasonally recharged by surface infiltration at or near the site and along buried coarse-grained sediments of current or historical drainage swales along the western and eastern boundaries of the site.

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Two municipal production wells were identified within seven thousand feet of the site during the Remedial Investigation (ENVIRON, December 1995). The closer of the two is the Coyote 12A Well. The "D" flow unit may have some equivalency to the shallowest screened interval of the Coyote 12A well. However, the Coyote 12A well is located three thousand feet cross-gradient to the site (ENVIRON, December 1995).

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Source Remedy (Operable Unit)

The McColl Site was added to the Superfund National Priorities List (NPL) in 1982.

Historically the source operable unit has been the subject of multiple investigations, pilot tests, and proposed remedies. A complete description of these can be found in the June 1993 ROD (US EPA) and the Final Full Scale Demonstration Test Report (US EPA, with contributions from ICF, Morrison Knudson, June 1995).

The McColl Site waste sumps are currently managed under the contingency remedy outlined in the June 1993 ROD. The remedy for the waste sumps is a Resource Conservation and Recovery Act (RCRA) equivalent cap(s) with subsurface barriers and monitoring. The current design includes a closure system consisting of two RCRA equivalent caps and slurry walls (Figure 3). The slurry walls are planned to extend a minimum of 3 feet below the bottom of the deepest sump and to completely surround the waste. The design of this final remedy is scheduled for completion in December 1996.

B. Groundwater Investigation Conducted by Agencies

The following information is a brief summary of the historical groundwater investigations that have been conducted at the McColl Site.

Groundwater sampling/testing and investigations have been conducted at the McColl Site by various contractors to the State of California and EPA since 1981. More recently, the McColl Site Group (MSG) tasked ENVIRON to perform a Remedial Investigation/Feasibility Study (RI/FS). Beginning in 1981, the California Department of Health Services (DOHS), now the California Department of Toxic Substances Control (DTSC), started the first investigation of groundwater with the installation of one monitoring well (Well A-13). A groundwater sample collected from monitoring well A-13 in 1981 was found to contain sulfate, arsenic, t-butanol, and exhibited a pH of 2.8 (CH2M Hill, 1987). From 1981 to the start of the MSG RI/FS, a total of 22 monitoring wells were installed at and near the McColl Site to investigate the nature and extent of groundwater contamination. Five wells were screened at depths of less than 110 feet below ground surface (bgs), and seventeen wells were screened at depths ranging from 216 to 320 feet bgs. Subsequently, seven of these wells were abandoned. The table below presents a history of the well installation/abandonment program that was completed at the McColl Site prior to commencement of the MSG RI/FS.

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Figure 3: Cap and Slurry Wall for Source Operable Unit Remedy

J96-024 Mc 2 6.

WELL INSTALLATIONS AND ABANDONMENTS PRIOR TO MSG RI/FS McCOLL SITE

Installer Date Scope

DTSC, Caitrans, ARB, SCAQMD

1981 In Ramparts area, 12 boreholes were drilled, including six in sumps, five in adjacent soils, and one in background. Analyses were for pH, sulfates, and heavy metals.

DOHS 1981 In Ramparts area, monitoring well A-13 was installed and a groundwater sample was collected. Analyses were for pH, sulfate and organic compounds.

Radian 1982 Three deep wells (depths of 232 to 273 feet) were installed. Well W-2 was located north of Ramparts area. Wells W-1 and W-3 were located south and southeast of the Los Coyotes areas. Wells W-1 and W-2 were later abandoned in 1991. The well head of well W-3 was covered during repaving of its street location.

DTSC 1983/1984 Four deep monitoring wells (W-4, W-5, W-6B, and W-8B) and two shallow wells 9W-6A and W-8A) were installed. Wells were first sampled in 1987. Wells W-5 and W-6B has since been abandoned.

CH2M Hill 1987 Six deep monitoring wells (P-1D through P-6D), and three shallow wells (P-3S, P-5S, and P-6S) were installed during an expanded groundwater assessment. Wells were sampled for organic and inorganic parameters. Well P-2D was replaced by Well P-2D(R) because Well P-2D had been damaged during installation.

Ecology and Environment

June 1989 Three deep upgradient wells (W-9B, W-9C, and W-1 OB) were installed.

Between June 1989 and December 1992, EPA performed routine groundwater quality monitoring. All sampling and testing of groundwater under this program followed a detailed sampling and analysis plan and data validation was performed.

C. RI/FS Performed by McColi Site Group (MSG) under US EPA Order

As a part of the EPA order issued to the four oil companies in August of 1993, EPA directed the oil companies, now called MSG, to complete the RI/FS for groundwater. The investigation supplemented the data from the existing 14 wells installed by EPA and the State. The investigation was conducted in two phases. At the completion of phase II of the investigation, MSG had installed nine additional wells. Following evaluation of the phase II results, EPA and MSG agreed that one additional well would be required. The RI/FS included four rounds of groundwater sampling and analysis and aquifer testing. A baseline risk assessment was


performed by ICF, contractor to EPA. MSG submitted the Draft Remedial Investigation Report to EPA on October 13, 1995. The Final Remedial Investigation Report was submitted on December 29,1995. The Draft Feasibility Study Report was submitted on December 5,1995. The Final Feasibility Study Report was revised by EPA based on the original draft and issued on February 7, 1996.

III. HIGHLIGHTS OF COMMUNITY INVOLVEMENT

The public participation requirements of Sections 113(k)(2)(B)(i-v) and 117 of CERCLA have been satisfied in the remedy selection process.

While the community has historically had very strong, organized, and vocal opinions regarding the remedy selection process on the source operable unit, there has been less interest regarding groundwater as there are not any municipal or private wells impacted and results have generally indicated minimal impact on the regional aquifer. EPA has continued to provide fact sheets (10+) as updates on new groundwater information and to make itself available to answer questions regarding groundwater.

EPA has also regularly met with the local regulatory agencies and provided them with information on the groundwater investigation and proposed plan through the McColl Site Interagency Committee (IAC). The IAC consists of State regulatory, local regulatory, political, and community representatives. The IAC meetings have been held on a monthly or bimonthly basis since the 1980s.

Consistent with requirements of CERCLA and the NCP, EPA has conducted the following community relations activities. Recently, EPA issued the August 1995 Fact Sheet to summarize the results of the Remedial Investigation. In February 1996, EPA issued a Proposed Plan Fact Sheet. An announcement of the proposed plan, public comment period, date, and location of the public meeting was printed in the Orange County Register on February 25,1996. EPA issued a press release on the first day of the public comment period (March 6, 1996). EPA briefed the IAC on the proposed plan on the day of the public meeting. On March 14, 1996, a public meeting was held at Parks Junior High School and was attended by approximately 10 community members, representatives of the State agencies, local agencies, McAuley LCX representatives, and MSG representatives. All of the community represented at the meeting that chose to publicly comment were in favor of the proposed plan.

Responses to local community comments made at the public meeting are presented in Attachment B. Details of the community involvement activities and responses to public comments received from the State and MSG are presented in the Responsiveness Summary (Attachment C).

IV. SCOPE AND ROLE OF THE RESPONSE ACTION

The planned construction of the closure and containment system over the source waste sumps should serve to reduce long-term contamination of shallow or deeper groundwater at the site. However, based on the results of the EPA Baseline Risk Assessment for the McColl Superfund Site Groundwater Operable Unit (ICF, November 1995), residual contamination in the shallow groundwater exceeds Federal and California standards for drinking water and may present an


imminent and substantial endangerment to human health if not addressed. The appropriate response for the shallow water takes into account the important fact that perched groundwater is not present in sufficient volume to serve as an exclusive source of future water supply.

V. SUMMARY OF SITE CHARACTERISTICS (GROUNDWATER)

In August of 1993, EPA ordered the McColl Site Group to complete the Rl and to perform the Feasibility Study. As part of the completion of the Rl, MSG installed ten new monitoring wells. These new wells, along with the previously installed wells, totalled 24 monitoring wells. The results of three quarters of sampling performed during the MSG Rl were used for the Baseline Risk Assessment for the Groundwater Operable Unit. No known natural resource concerns exist for the site groundwater. As a result, an ecological assessment was not performed.

A. Groundwater

Initial (phase I) efforts of the MSG Rl focused on the characterization of perched groundwater. Unfortunately, the cone penetrometer technology that was used did not reach the depth required to characterize deeper perched zones. Data were, however, collected from perched wells that had been installed and locations for new monitoring wells were selected based on these results along with the limited cone penetrometer data. The results for the groundwater monitoring are summarized in the following sections. Groundwater investigation results indicate that while contaminants from the waste sumps are present in perched water, they do not appear to result in contamination of the regional groundwater. A comprehensive list of the compounds of potential concern as presented and evaluated in the baseline risk assessment for the groundwater operable unit is presented below:

THIOPHENES VOCs SVOCs INORGANICS

Tetrahydrothiophene Acetone Bis(2-ethylhexyl)phthalate Aluminum 2-methyltetrahydrothiophene Benzene Butylbenzylphthalate Arsenic 3-methyltetrahydrothiophene 2-butanone Dimethylphthalate Barium

Carbon Disulfide Di-n-butylphthalate Beryllium3

Chloroform Isophorone Cadmium 1,2-dichloroethane 2-Methylphenol Chromium Ethylbenzene Nitrobenzene Cobalt 2-hexanone Phenol Copper Methylene Chloride Pyrene Lead Toluene Manganese Xylenes (total) Mercury

Nickel Selenium Thallium Vanadium Zinc

VOCs = Volatile Organic Compounds SVOCs = Semi-volatile Organic Compounds

Although beryllium was not identified in waste and sump samples (CH2M Hill, 1987), beryllium was selected as a

COPC for the risk assessment because it was positively detected in at least one groundwater sample. The existence of

beryllium in groundwater may be associated with the leachability of chemicals in vadose zone soils due to the low pH in groundwater.


Organics (not including THT compounds)

The two VOCs detected above MCLs in the groundwater system are benzene and, at low concentrations, 1,2-dichloroethane (1,2-DCA). Semi-volatile organic compounds were not consistently detected in the groundwater or were determined to be laboratory contaminants. Benzene concentrations have equaled or exceeded (up to 470 ppb) the State MCL of 1 ppb in the "B" flow unit. Benzene in the perched "C" well W-6A ranged from 500 to 800 ppb. 1,2-DCA concentrations exceeded the State MCL of 0.5 ppb in one "B" flow unit well (P-5I) and one "C" flow unit well (P-5L) and the results were as low as 1 and 2 ppb.

Tetrahvdrothiophene (TH"n Compounds

THT compounds, including tetrahydrothiophene, 2-methyltetrahydrothiophene, 3-methyltetrahydrothiophene, were detected in several monitoring wells during the sampling program. THT compounds have a very low odor threshold (50 percent of the population can detect at 0.6 ppb) and readily degrade water to less than aesthetically acceptable conditions.

THT compounds have been detected regularly in the perched "A", "B","C" and the regional "C" units. THT compounds have not been detected in the "D" unit; however, additional monitoring will be required to confirm the absence of THTs in the "D" unit southwest (downgradient) of the site.

Concentrations of THT compounds in the perched units have ranged as high as 43,000 ppb (W-6A). Approximately five hundred feet downgradient of the Los Coyotes sump area, THT compounds are detected in portions of the "B" and "C" flow units (Wells P-10D and P-10L at 1,490 and 190 ppb, respectively). It is suspected that the rate of migration is limited by the seasonal saturation and natural attenuation in the perched units. This migration of site contaminants (THTs) from the perched to the regional aquifer indicates a possible pathway exists for other organics found in the perched units. However, it is also important to point out that there are regional "C" wells downgradient of the site and sump areas that have no detected THT compounds, such as Well P-9D.

Inorganic Compounds

Concentrations of inorganics in the onsite perched groundwater exceed background concentrations calculated for the regional aquifer. However, it is important to note that the source waste in the waste pits at the McColl Site does not contain elevated inorganics (with the exception of sulfur dioxide). The waste is acidic and as liquid (water) comes into contact with the waste, the water also becomes acidic. The presence of these higher concentrations of inorganics in perched groundwater samples may be attributed to the preferential leachability of inorganics in the vadose zone soils from contact with acidic perched water.

Four inorganic compounds occur above background concentrations or state MCLs: arsenic, beryllium, chromium, and manganese. Arsenic is ubiquitous at low concentrations in groundwater at the site. Evaluation of "D" flow unit background wells indicate a background concentration of 9.7 ppb. The State and Federal MCL is 50 ppb and has been slightly exceeded in perched well P-2I. The higher concentrations of arsenic occur in wells with low pH and concentrations significantly decrease off-site once the pH rises to natural levels downgradient of the site.


Background "D" flow unit wells indicate a concentration for beryllium of 8,3 ppb. This background concentration exceeds the State MCL of 4 ppb for beryllium. Dissolved beryllium was detected above the state MCL in three on-site wells (P-21, P-41, W-6A) of the twenty-four wells. Beryllium concentrations exceeding the State MCL ranged from 5.7 to 90 ppb.

The "D" flow unit background wells indicate a background concentration for chromium of 3.2 ppb. Dissolved chromium was detected above the State MCL of 50 ppb in perched wells P-41 and W-6A. Chromium concentrations in these wells ranged from 67.8 to 424 ppb, and the water in these wells had a low pH.

Manganese was measured at a background concentration of 4,300 ppb. Manganese has been found to occur at concentration as high as 30,100 to 41,700 ppb in perched wells with low pH. Concentrations of manganese are closer to background in wells in the regional aquifer. There is no MCL for manganese. However, the Federal secondary drinking water standard for manganese is 50 ppb.

B. Data Validation

Data validation of analytical results was performed in accordance with procedures outlined in the Quality Assurance Project Plan prepared by ENVIRON for MSG.

VI. SUMMARY OF SITE RISKS

The Baseline Risk Assessment for the Groundwater Operable Unit was completed in November 1995 by an EPA contractor (ICF). The purpose of the Risk Assessment was to evaluate the public health and environmental risks posed by contaminants detected in groundwater at the site. The wells screened in both the perched and regional aquifer were evaluated in the Risk Assessment. A separate baseline public health evaluation for the source/soil waste sumps was performed in May 1992 (ICF).

The Baseline Risk Assessment for the Groundwater Operable Unit and this ROD recognize that the perched portion of each individual flow zone would not yield sufficient volume of water for potential exposures. This ROD also recognizes that the perched zones are of potential concern because it has been demonstrated by the presence of THT compounds in the regional aquifer wells that contaminants found in shallower zones can migrate into the regional aquifer.

The following sections on risk assessment are presented in the Executive Summary of the Baseline Risk Assessment for the Groundwater Operable Unit (ICF, November 1995):

Selection of Chemicals of Potential Concern

Groundwater data obtained from the three most recent quarterly groundwater sampling events were identified as the most appropriate database to evaluate current site conditions. The sampling events occurred in September 1994, January 1995, and April 1995 (ENVIRON, 1995a, 1995b, and 1995c).

A screening analysis was conducted to determine the areas of groundwater within each zone that may have the highest concentrations of chemicals. It was assumed that a well(s) in each flow unit represents the center of any potential plume migrating from the Site. The manner in which the wells were selected to represent chemical concentrations in each flow unit is designed to be


conservative, by selecting narrow areas in which the highest concentrations are observed. The analysis consisted of comparing the maximum chemical concentrations in each individual well with the most conservative chemical-specific Federal or California MCL4 and a chemical-specific tap water PRG, as summarized by EPA Region IX (EPA, 1995a). Individual wells or a group of wells was selected based on the frequency of detection of chemicals, the toxicity of the chemicals detected, and the ratios of the maximum chemical concentration to the MCLs and tap water PRGs.

Individual wells were selected to represent groundwater in the "A" and "D" flow units, and groundwater in the perched and regional "C" flow units. Two separate wells were selected to represent the "B" flow unit primarily because of different chemical constituents. The wells selected as a result of this screening evaluation are presented below.

AQUIFER FLOW UNIT ZONE WELL

perched A P-3S

perched B P-2I & P-6S

perched C W-6A

regional C P-5L

regional D W-4

Chemicals of potential concern (COPCs) were selected if organic and inorganic chemicals were detected in at least one sample above their respective method detection limits (MDLs). Detected chemicals (from the wells identified based on the results of the screening analysis) were selected to represent the chemicals that are attributable to the Site and that are of greatest concern from a health risk standpoint (i.e., the COPCs). Of the inorganics, iron, magnesium, potassium, and sodium were eliminated as COPCs because they are considered essential nutrients. Inorganic chemicals that are present at naturally occurring levels may also be eliminated from the risk assessment. Groundwater data collected from three off-site upgradient wells were used to represent background. However, given that these wells are screened in the "D" flow unit of the regional aquifer, a comparison can only be made for groundwater data that were also collected from wells screened in the "D" flow unit (i.e., well W-4). Based on an analysis of groundwater data, it is unclear whether the inorganics detected in the "D" flow unit are natural or anthropogenic in origin. Consequently, with the exception of the essential nutrients, inorganics detected in at least one sample above the MDL from well W-4 were selected as COPCs. A comprehensive list of COPCs evaluated in this risk assessment is presented below.

If both a Federal and a California MCL exist for a particular compound, the lower of the two MCLs was used in the

screening analysis. For instance, benzene has a Federal and a California MCL of 5 and 1 jig/L, respectively. In this

scenario, the California MCL was used in the screening evaluation.

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THIOPHENES VOCs SVOCs INORGANICS

Tetrahydrothiophene Acetone Bis(2-ethylhexyl)phthalate Aluminum 2-methyltetrahydrothiophene Benzene Butylbenzylphthalate Arsenic 3-methyltetrahydrothiophene 2-butanone Dimethylphthalate Barium

Carbon Disulfide Di-n-butylphthalate Beryllium5

Chloroform Isophorone Cadmium 1,2-dichloroethane 2-Methylphenol Chromium Ethylbenzene Nitrobenzene Cobalt 2-hexanone Phenol Copper Methylene Chloride Pyrene Lead Toluene Manganese Xylenes (total) Mercury

Nickel Selenium Thallium Vanadium Zinc

VU(Js = Volatile Organic Compounds SVOCs = Semi-volatile Organic Compounds

Toxicity Assessment

For each of the COPCs identified for this risk assessment, relevant toxicity criteria were identified from EPA's Integrated Risk Information System (IRIS) database (EPA, 1995b). When not available on IRIS, the Health Effects Assessment Summary Tables (HEAST) (EPA, 1994) and EPA's Region IX Preliminary Remediation Goals (PRGs) (EPA 1995a) were consulted. If no values could be identified from either source, the chemical was not evaluated quantitatively. COPCs that lack agency-derived toxicity criteria include the thiophene-based compounds. In addition, there are no available toxicity values for evaluating dermal (uptake) exposures. For this risk assessment, oral cancer slope factors (CSFs) and reference doses (RfDs) were used to evaluate dermal exposures.

Regulatory toxicity criteria that have been developed by Cal/EPA were also used and separately evaluated in this risk assessment. When Cal/EPA toxicity values were not available, EPA values were used. Cal/EPA has not derived RfDs or RfCs, and therefore an evaluation of potential risks was only conducted for chemicals that are classified as carcinogens.

Of the chemicals identified as being COPCs at the McColl Site, 11 are considered to be known or suspected human carcinogens. Two chemicals are known human carcinogens based on sufficient evidence in human studies (Group A). One chemical is considered to be a probable human carcinogen based on limited evidence in human studies (Group B1). Eight chemicals are considered probable human carcinogens based on sufficient evidence in animal studies (Group B2). A list of carcinogenic COPCs is summarized below.

Although beryllium was not identified in waste and sump samples (CH2M Hill, 1987), beryllium was selected as a

COPC for this risk assessment because it was positively detected in at least one groundwater sample. The existence of

beryllium in groundwater may be associated with the teachability of chemicals in vadose zone soils due to the low pH in groundwater.


Group A Group B1 Group B2

Arsenic Benzene

Cadmium Beryllium Bis(2-ethylhexyl)phthalate

Butylbenzylphthalate Chloroform

1,2-DCA Isophorone

Methylene Chloride Lead

Exposure Assessment

The McColl Site is located in an area zoned for single family residences. Residential homes are located adjacent to the Site on the east and south boundaries with the nearest home located approximately 200 feet from the sumps. It is assumed that no future residential development will occur on the McColl Site sumps and that the surrounding areas are likely to continue to support residential homes. Based on the current and expected future uses of the McColl Site, residential adults and children living in the vicinity of the Site represent potential exposed populations.

Groundwater is not currently used as a source of potable water within the McColl Site. Water for adjacent communities is supplied by the local water district through a municipal distribution system. No shallow domestic wells are known to exist in the vicinity of the Site and irrigation water is supplied by the City of Buena Park. Therefore, no complete exposure pathways for chemicals in groundwater exist under current land use scenarios. However, potential future uses of the surrounding areas may result in the development and use of private and municipal water supply wells.

Based on an evaluation of current and future conditions at the McColl Site, the following exposure pathways were identified and evaluated for this risk assessment:

• incidental ingestion and dermal absorption of chemicals in groundwater; and • inhalation of chemicals released from groundwater during domestic uses.

To quantify human health risks, exposure point concentrations (EPCs) of the chemicals in groundwater appropriate to each specific exposure pathway at each appropriate receptor location were developed. Potential exposures to groundwater were estimated based on chemicals already existing in groundwater, as observed in the selected set of onsite wells. No groundwater transport or contaminant leaching modeling was performed for this risk assessment. Furthermore, it was assumed that the chemical concentrations are unlikely to increase or decrease in the future. Concentrations of volatile chemicals in air released from potable water were conservatively estimated using EPA's default volatilization constant (0.5 mg/m3/mg/L) (EPA, 1991b).

Average concentrations from the three groundwater sampling rounds were used to represent the EPCs from the wells identified from the screening analysis. EPCs representing background were developed based on the arithmetic average of data collected from three off-site wells over three quarters. Potential risks were evaluated based on doses that were estimated both for a reasonable maximum exposure (RME) estimate and a more probable estimate of exposure.


Risk Characterization

EPA has established an acceptable range of risk (1 x 10"6 to 1 x 10"4 excess cancer risks) for known or suspected carcinogens at Superfund sites. If the calculated risks exceed 1 x 10"4 excess cancer risks, then remediation is usually required. For noncarcinogenic effects, a hazard index (HI) in excess of 1 generally indicates an unacceptable condition requiring remediation (EPA, 1992b).

The results of the risk assessment indicate that with the exception of the RME exposures for well W-4 (flow unit D), the carcinogenic risks associated with the regional aquifer are below or within the acceptable range of 1 x 10"6 and 1 x 10"4. The average and RME risks for well P-5L (flow unit C) are below 1 x 10"6. The RME cancer risks associated with well W-4 are 3 x 10"4 and 1 x 10"4 for adults and children, respectively, and are slightly above the target risk of 1 x 10"4. Arsenic is the primary chemical contributor to the overall risks. However, the concentrations of arsenic observed in well W-4 are below the MCL.

The potential risks associated with chemicals detected in background wells were also estimated. As indicated above, the only available site-specific background data are for the D flow zone. Under an average exposure scenario, the total background risks are below or within the acceptable range of 1 x 10"6 and 1 x 10"4. On the other hand, the estimated RME cancer risks attributed to chemicals detected in background wells are 2 x 1 (T4 and 1 x 10"4 for adults and children, respectively, and are primarily associated with the ingestion of beryllium. Although the RME risks are slightly above the target risk range, the RME background risks are comparable to the estimated risks associated with regional well W-4. A summary of the total carcinogenic risks associated with the selected wells screened in the regional aquifer, including background wells, is provided below. The estimated risks using Cal/EPA CSFs are presented in parentheses.

SUMMARY OF TOTAL CARCINOGENIC RISKS (REGIONAL AQUIFER)

Flow Unit (Well) Average Risk

Adult RME Risk

Adult Average Risk

Child RME Risk

Child

C (P-5L) 2 X 10"7 (2 x 10"7) 7 X 10"7 (1 x 10"6) 2 X 10"7 (3 x 10"7) 3 X 10"7 (5 x 10-7)

D (W-4) 5 X 10"5 (5 x 10"5) 2 X 10"4 (3 x 10"4) 8 X 10"5 (8 x 10"5) 1 X 10-4 (1 x 10"4)

D (background wells) 4 X 10"5 (5 x 10"5) 2 X 10"4 (2 x 10"4) 7 X 10"5 (8 x 10"5) 1 X 10"4 (1 x 10"4)

The lowest and highest estimated risk values for individual wells screened in the perched flow zones are 6 x 10 and 4 x 10"3. The lowest risk is associated with chemicals detected in well P-3S (flow zone A) for adult receptors under an average exposure scenario. The highest estimated risk corresponds to chemicals detected in well W-6A (flow unit C) for child receptors under an RME exposure scenario. The primary exposure pathway contributing to the overall risks is from ingestion of groundwater. Arsenic in well P-3S and beryllium in well W-6A are the primary chemicals responsible for the majority of the risks.

The potential noncarcinogenic effects associated with the exposure pathways evaluated above were combined in the same manner as was done for the carcinogenic effects to yield total


Site His. Of the three potentially complete exposure pathways Evaluated, ingestion of groundwater contributes most to overall noncarcinogenic health effects.

The noncarcinogenic His associated with regional well P-5L are below the target HI level of 1. Conversely, the noncarcinogenic His associated with regional well W-4 are slightly above the target HI level and are primarily associated with arsenic. However, as stated above, the concentrations of arsenic observed in well W-4 are below the MCL. The His associated with background wells are slightly above the target level and are primarily attributed to manganese. A summary of the cumulative noncarcinogenic His is provided below.

SUMMARY OF TOTAL NONCARCINOGENIC HAZARD INDEX (REGIONAL AQUIFER)

Flow Unit (Well) Average HI

Adult RME HI Adult

Average HI Child

RME HI Child

C (P-5L) 0.3 0.4 0.6 0.9

D (W-4) 1 2 3 4

D (background wells) 0.9 1 2 3

The lowest and highest noncarcinogenic His associated with wells screened in the shallow zones are 0.4 (P-3S) and 300 (W-6A). Analogous to the carcinogenic risks, the lowest and highest His correspond to adult receptors for an average exposure scenario and to children under a RME exposure scenario, respectively. The ingestion of manganese is the primary chemical and exposure pathway contributing to the overall total HI from well W-6A.

Incremental risks may be estimated by subtracting background carcinogenic risks and noncarcinogenic His from the total carcinogenic and noncarcinogenic chemical- and pathways-specific risks. If the incremental risks exceed the target risk ranges, it is possible that these risks are associated with site-related activities rather than ambient conditions. In the case of arsenic, the incremental cancer risks are above the target risk level for the RME adult exposure scenario and the incremental His are above the target range for the average and RME child exposure scenario. However, the concentrations of arsenic detected in background wells and well W-4 are below the arsenic MCL of 50 pg/L.

Analytical data from samples obtained during test pumping of Coyote municipal well 12A show that manganese was also detected slightly above the Federal secondary drinking water standard. Given that manganese was detected in samples collected from a crossgradient municipal well, it is possible that manganese detected in onsite groundwater wells in the perched and regional zones is naturally occurring. However, it should be noted that the concentrations of manganese, specifically in well W-6A, are several orders of magnitude greater than the Federal secondary drinking water standard, the levels in Coyote Well 12A, and the three upgradient background wells.


Uncertainty

There are numerous sources of uncertainty associated with the methodologies and data used in this risk assessment that tend to limit the confidence in the resulting quantitative estimates of carcinogenic risks and non-carcinogenic hazards. Uncertainty is unavoidable in quantifying health risks, and many parameters are not well known (toxicity values) or contain significant variability. Thus, it is expected that the risks are conservative at least to some degree. Therefore, actual risks may be lower than those estimated for both the more probable average and RME cases.

Conclusions

In summary, given the inherent uncertainties, the exposures that are most likely to pose excess carcinogenic risks and noncarcinogenic hazard effects at the McColl Site are those experienced by residential receptors who are exposed to COPCs in groundwater by incidental ingestion. The chemicals that contribute most to these excess carcinogenic risks include arsenic and beryllium in wells screened in the perched aquifer. Arsenic was identified as a COPC in soil samples collected from the Site, whereas beryllium was not. The concentrations of beryllium in groundwater may be attributed to the leachability of naturally-occurring chemicals in the vadose zone due to the low pH in groundwater.

It is unlikely that locally perched groundwater would be classified as a potable source because perched groundwater is not present in sufficient volume to serve as an exclusive source of future water supply. However, it is important to evaluate the potential health risks of perched groundwater because it is possible that some areas of the perched zones are hydraulically connected to the deeper regional aquifer which serves as a potential drinking water source.

Carcinogenic risks associated with wells screened in the deeper regional aquifer are within and are slightly above (RME scenario) the established risk range (1 x 10"4 to 1 x 10"6). In addition, noncarcinogenic hazard effects may occur from groundwater ingestion of chemicals detected in wells screened in the regional aquifer. However, the concentrations of the risk-driving chemicals in the regional wells are either below the corresponding MCL (arsenic) or appear to be within background levels (manganese).

The potential risks associated with thiophene-based compounds could not be assessed quantitatively because of the lack of EPA-verified toxicity criteria. The odor threshold concentration (OTC) for THT, which is the concentration at which 50 percent of the population can detect an odor, is 0.6 ppb or 0.0018 mg/m3. In comparison to most chemicals, THT can be detected at relatively low concentrations.

VII. DESCRIPTION OF ALTERNATIVES

This section will describe four alternatives that EPA has evaluated in selecting the final cleanup plan for the Site. The four alternatives were evaluated and compared to the nine criteria required by the NCP (40 CFR § 300.430(e)(9)) in the Feasibility Study Report, Groundwater Operable Unit, McColl Site (EPA, February 1996). The nine criteria are described in greater detail in Part VIII of this decision document, entitled Summary of Comparative Analysis of Alternatives.


The Draft Feasibility Study (ENVIRON) and the work leading up to the Draft was provided by MSG to EPA. EPA revised portions of the MSG text and finalized the document on February 7, 1996.

The general Remedial Action Objective (RAO) for groundwater at the site is long-term protection of potable groundwater for public health purposes and to ensure its current and future beneficial use as a source of drinking water supply.

A. Alternative #1

The NOP requires that a no-action alternative be considered at every site. The no-action alternative usually serves primarily as a point of comparison to other alternatives; however, in this case it was considered. There are no costs, except monitoring, associated with this alternative.

B. Alternative #2

Institutional controls that would limit future use of groundwater in the vicinity of the site would prevent non-natural migration of waste from the perched to the regional aquifer. Under this alternative. EPA or a Responsible Party would negotiate limitations on the use of groundwater beneath the adjacent properties with the owners.

Implementation of offsite institutional controls would require determination of an appropriate PRG for THTs upon which to base the lateral extent of controls required or recommended. EPA recommends 3.6 ppb as the PRG for total THT compounds. This is based on an MSG analysis of domestic use performed during the Rl. It is anticipated that affected properties outside the current site property boundaries could include adjacent residential properties along Tiffany and Fairgreen, the golf course property adjacent to the southern boundary, and possibly Island Drive residential properties.

While there are no capital costs associated with this alternative there are costs associated with conducting negotiations and many adjacent property owners may be reluctant to agree to the limitations. The costs of this alternative are estimated at $744,000 to $1,934,000 in addition to the monitoring costs.

C. Alternative #3

This is the alternative selected in this decision document. Modifications to the selected alternative are outlined in Section X, Statutory Determinations, Documentation of Significant Changes (page 26). This alternative would include evaluation, design, and construction of infiltration controls to significantly (order of magnitude) reduce surface water infiltration from baseline estimates. Measures/controls for consideration during design may include some or all of the following:

• Onsite management of surface water running onto the site property;

• Lining existing major drainage channels with low permeability materials;

• Grading or modifying (through placement of low permeability soils) areas adjacent to, but outside of the planned closure containment system;


• Groundwater monitoring (including additional wells) to demonstrate that the infiltration controls are effectively preventing further migration of site contaminants to and throughout the regional aquifer; and

• Site maintenance and security until final O&M plans take effect under the source operable unit remedy.

The groundwater remedy (Alternative #3) is intended to work in conjunction with the source remedy, and together will achieve the anticipated goal of protection of groundwater resources.

There would be a capital cost of $744,000 to $1,934,000 for this alternative in addition to the monitoring costs. The likely net present value would range between $2,294,000 and $3,484,000.

D. Alternative #4

This alternative would extract water from the deeper aquifer and treat this water at the site surface. It was assumed that granular activated carbon (GAC) would be used to treat water; however, additional treatability studies would have to be performed to determine efficacy. The treated water would be reused as irrigation water, discharged to surface water, or reinjected into the groundwater through wells. This alternative would also include groundwater monitoring. The rate of extraction was estimated at 6 gpm and the groundwater would be drawn from existing monitoring wells.

The total estimated capital costs for this alternative range from $1,648,000 to $2,904,000. The annual operation and maintenance costs would be $383,000 plus additional monitoring wells and monitoring. The net present value is estimated to be $5,707,000 to $6,963,000.

VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In the Feasibility Study, alternatives were developed assuming that alternative #3 may include components of #2 and that #4 may include components of #3 and #2. In the presentation of alternatives for comparative purposes each alternative is evaluated based on its own merits.

A. Protection of Human Health and The Environment

Overall protection of human health and the environment addresses whether an alternative provides adequate protection from exposure to contamination and describes how risks for the exposure pathways are eliminated or reduced.

Because there are no current exposure pathways and concentrations of contaminants in the regional aquifer fall within the acceptable risk range, all of the alternatives are sufficiently protective of human health.

B. Compliance With ARARS

The primary applicable or relevant and appropriate requirements (AFIARs) that have been identified for the groundwater at the McColl site are the federal MCLs and non-zero Maximum Contaminant Level Goal (MCLGs) as promulgated and applied under the Safe Drinking Water Act and State MCLs. Chemicals of concern in the regional aquifer either already meet MCLs, have


background concentrations above MCLs, or appear as localized occurrences. Chemicals of concern have been detected in perched groundwater at concentration exceeding MCLs. The perched groundwater would provide insufficient yield to be used as a sole source of groundwater and as a result is not considered to be subject to the MCLs as ARARs. It should be noted that the migration of site contaminants (THTs) from the perched to the regional aquifer indicates a possible pathway for future contaminant migration.

For the purpose of comparing alternatives, all of the alternatives generally comply with ARARs. When evaluating relevant environmental law it is important to recognize that the limited contamination of the regional aquifer by THTs affects the secondary water quality standards of taste and odor. Secondary standards are "to be considered" in the evaluation process. In comparing alternatives in light of THT contamination, all of the alternatives, with the exception of the no-action, would serve to prevent further migration of THTs in the regional aquifer.

EPA recommends that all of the interested agencies and parties work to determine an appropriate site-specific concentration for evaluation of THTs. EPA recommends, based on an analysis of domestic use performed during the Rl, that a PRG concentration of 3.6 ppb total THTs be used for the five year review in evaluating the effectiveness of the remedy in the regional aquifer.

C. Long-Term Effectiveness and Permanence

Long term effectiveness and permanence refers to the ability of a remedy to maintain reliable protection of human health and the environment over time.

Alternatives 3 and 4 are considered more permanent and effective than alternatives 1 and to a lesser degree 2, due simply to the fact that they would serve to prevent future contamination of the regional aquifer and would therefore be most protective overtime. Alternative 3 is considered more effective than Alternative 4 because it would not generate treatment residuals or require constant energy and resources which have secondary environmental effects.

D. Reduction of Toxicity, Mobility, or Volume Through Treatment

Reduction of toxicity, mobility, or volume through treatment refers to the preference for a remedy that uses treatment to reduce health hazards, contaminant migration, or the quantity of contaminants at the site.

While Alternative 4 is the only alternative to consider treatment, the volume of contaminants treated is expected to be very low. The volume of groundwater extracted is estimated at 6 gpm and would contain contaminants in the parts per billion range. The treatment process would generate residuals and require frequent maintenance.

E. Short-Term Effectiveness

Short-term effectiveness refers to the period of time needed to complete the remedy and to prevent adverse impacts on human health and the environment that may be posed during construction and implementation of the remedy. Since a complete health and safety plan would be implemented prior to the construction of the remedies, short-term adverse impacts during construction of the remedies would be minimized.

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All of the alternatives could be implemented in a reasonable timeframe. Alternative 4 would likely take the longest to implement and would have to consider a site-specific remediation goal for THTs. Alternatives 3 and 4 would provide the maximum short-term effectiveness in reducing the THTs in the regional aquifer.

Alternatives 1 and 2 present the minimum short-term impacts of the alternatives considered. Short-term impacts associated with Alternative 3 are limited to the risk posed to workers working with heavy equipment during the construction of the infiltration controls; there are no foreseeable risks to the community. Alternative 4 has some short-term risks for workers and possibly some risks associated with operation of construction equipment in the community.

F. Implementability

Implementability refers to the technical and administrative feasibility of a remedy, including the availability of materials and services needed to implement the selected remedy. It also includes coordination of Federal, State, and local governments during cleanup of the site.

With the exception of the no further action Alternative (#1), Alternative #3 would be the easiest to implement. Alternative #3 can be directly integrated with the construction of the closure and containment system and may not require any complex negotiations regarding institutional controls (Alternative #2) or permits (or coordination) for operation of treatment system (Alternative #4). Alternatives #2 and #4 would also require significant additional community involvement which can complicate the implementation process.

G. Cost

This criterion examines the estimated costs for each remedial alternative. For comparison, capital costs and annual O&M costs are used to calculate a total net present worth cost for each alternative.

Costs between alternatives 1, 2 and 3 compare well. All of these three include annual monitoring ($139,000). All alternatives would include at least one additional monitoring well ($146,400), and Alternative #4 would include $77,900 for monitoring of extraction wells. The costs of conducting the negotiations under alternative #2 are not assessed but could be significant. Alternative #4 alone would have total estimated capital costs ranging from $1,648,000 to $2,904,000, annual operation and maintenance costs would be $383,000 plus additional monitoring wells and monitoring, and the net present value is estimated to be $5,707,000 to $6,963,000.

In the Feasibility Study, alternatives were developed assuming that alternative #3 may include components of #2 and that #4 may include components of #3 and #2. In the presentation of alternatives for comparative purposes each alternative is evaluated based on its own merits.

H. State Acceptance

The State of California has commented in support of the remedy selected with the comment that offsite institutional controls should be considered in addition to the infiltration controls. EPA has addressed this concern by requiring that offsite institutional controls be implemented at the five year review in the event that the regional aquifer beyond the current site boundary is found (in more than one offsite well) to contain site-specific contaminants above State or Federal MCLs or the above the recommended or revised PRG for THTs.


I. Community Acceptance

The community has supported the selected remedy during the comment period of the public meeting. No specific written comments were received during the public comment period. The public meeting comments are provided in Attachment B.

IX. SELECTED REMEDY

EPA has selected Alternative #3 as the remedy for the McColl Superfund Site. The selected remedy for contaminated groundwater at the McColl Site consists of:

• Evaluation, design, and construction of infiltration controls to significantly (order of magnitude) reduce surface water infiltration from baseline estimates. Measures/controls for consideration during design may include some or all of the following:

Onsite management of surface water running onto the site property.

Lining existing major drainage channels with low permeability materials.

Grading or modifying (through placement of low permeability soils) areas adjacent to, but outside of the planned closure containment system.

Groundwater monitoring to demonstrate that the infiltration controls are effectively preventing further migration of site contaminants to the regional aquifer (in excess of Federal or State MCLs or the site-specific PRG for THTs).

Institutional controls at the five year review in the event that the regional aquifer beyond the current site boundary is found (in more than one offsite well) to contain site specific contaminants above State or Federal MCLs or above the recommended or revised PRG for THTs.

Site Maintenance and Security until final O&M plans take effect under the source operable unit remedy.

Implementation of this remedy will prevent the spread of groundwater contamination and reduce the possibility of future contamination of the regional aquifer, thereby reducing any future risk of exposure to contaminated groundwater. These controls will remain in-place in perpetuity along with the closure and containment system. Because the source operable unit remedy does result in hazardous substances remaining on the site above health-based levels, the groundwater remedy five year review shall apply coincident with the source remedy five year review. Based on an estimated construction completion of 1997, the initial five year review will occur in 2002.

The decision to select Alternative 3 as the remedy is based on a comparative analysis of the alternatives presented above and provides the best balance of trade-offs with respect to the nine evaluation criteria.

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A long-term groundwater monitoring program shall be implemented to evaluate the effectiveness of the infiltration controls and to demonstrate continued achievement of Federal or State MCLs and the proposed (3.6 ppb) or revised PRG for total THTs.

X. STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment as required by Section 121 of CERCLA. The selected remedial action, when complete, shall comply with applicable or relevant and appropriate environmental standards established under Federal and State environmental laws. The selected remedy is cost-effective and considered permanent treatment technologies to the maximum extent practicable. The following sections discuss how the selected remedy for the McColl groundwater contamination operable unit meets these statutory requirements.

A. Protection of Public and the Environment

Prevention of further future degradation of the regional aquifer from site contaminants will protect the aquifer as an important natural resource and prevent any future unacceptable exposures from site contaminants via groundwater usage. The implementation of this remedy will not create any short-term risks to the community nor any negative cross-media impacts.

B. Attainment of ARARS

All ARARs will be met by the selected remedy. The selected remedy will maintain compliance with chemical-specific ARARs by reducing migration of contaminants to the regional aquifer. There are no action specific or location specific ARARs.

C. Cost-Effectiveness

EPA believes the selected remedy is cost-effective and addresses the contaminated groundwater within a reasonable period of time. The selected remedy fulfills the nine criteria of the NCP and provides overall effectiveness in relation to its cost.

Alternative #3 has a capital cost of approximately $744,000 to $1,934,000 and an approximate annual O&M cost of $146,000. The net present value is $2,294,000 to $3,484,000 based on an assumed 20-year project life.

D. Use of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the Maximum Extent Practicable

The primary rationale for selection of Alternative #3, the preferred alternative, is that it provides the best balance of long-term effectiveness versus cost, and it is relatively easy to implement. The selected remedy was evaluated against treatment technologies that were determined to be less cost effective. EPA has determined that the selected remedy provides the best balance of long-term effectiveness and permanence; reduction of toxicity, mobility, and volume through treatment; short-term effectiveness; implementability; and cost effectiveness. The selected remedy has also been accepted by the State and community.


E. Preference for Treatment as a Principal Element

While contaminants in the groundwater will not be extracted and treated, it is important to point out that natural degradation processes will be closely monitored. EPA considered treatment as an alternative in the evaluation process and determined that it was not cost-effective or implementable when compared with the preferred alternative.

F. Documentation of Significant Changes

EPA considered institutional controls as a part of its description of all remedial actions in the GWFS. However, for the purposes of conducting the comparative analysis, in the GWFS, EPA evaluated each remedial alternative individually (versus cumulatively). Accordingly, because the Proposed Plan fact sheet is based on the comparative analysis, it only discussed infiltration controls without institutional controls for Alternative 3.

Consistent with the GWFS, EPA has incorporated institutional controls in the final remedy as a contingency measure for the regional aquifer. Specifically, institutional controls shall be considered at the five year review if the regional aquifer beyond the current site boundary is found (in more than one offsite well) to contain site-specific contaminants above State or Federal MCLs or above the recommended (3.6 ppb) or revised PRG for total THTs. Institutional controls were included primarily to address State concerns.

T^Ot\Cc-Keith A. Takata Director, Superfund Division U.S. EPA, Region IX

Date '

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REFERENCES

ENVIRON, 1995. Final Remedial Investigation Report, Groundwater Operable Unit, McColl Site, Fullerton, California. December.

ICF, 1995. Final Baseline Risk Assessment for the McColl Superfund Site Groundwater Operable Unit, Fullerton, California. November.

ICF, 1996. Feasibility Study Report, Groundwater Operable Unit, McColl Site, Fullerton, California. February.

US EPA, 1993. Source Operable Unit Record of Decision. June.

US EPA, 1995. Final Full Scale Demonstration Test Report, McColl Site. June.

REFERENCES FOR RISK ASSESSMENT

CH2M Hill, 1987. Field Report. Various Tasks to Supplement the Previous RI/FS. Prepared for EPA, Hazardous Site Control Division. Contract No. 68-01-7251.

ENVIRON, 1995a. Quarterly Groundwater Monitoring Report. First Quarter Sampling Period (1994). March.

ENVIRON, 1995b. Quarterly Groundwater Monitoring Report. Second Quarter Sampling Period (1995). April

ENVIRON, 1995c. Quarterly Groundwater Monitoring Report. Third Quarter Sampling Period (1995). July.

EPA (U.S. Environmental Protection Agency). 1989a. Risk Assessment Guidance for Superfund. Volume I, Human Health Evaluation Manual (Part A), Interim Final. EPA 540/1 -89/002. December.

EPA, 1989b. Exposure Factors Handbook. Office of Health and Environmental Assessment, Office of Research and Development. EPA/600/8-89/043. July.

EPA, 1991a. Human Health Evaluation Manual, Supplemental Guidance: "Standard Default Exposure Factors." Office of Solid Waste and Emergency Response. OSWER Directive 9285.6-03. March.

EPA, 1991b. Risk Assessment Guidance for Superfund. Volume I: Human Health Evaluation Manual. Part B, Development of Risk-based preliminary Remediation Goals. Office of Emergency and Remedial Response. OSWER Directive 9285.7-Olb. December.

EPA, 1992a. Guidelines for Exposure Assessment. Federal Register, Volume 57, No. 104. May.

EPA, 1992b. Code of Federal Regulations (40 CFR) Part 300 - National Oil and Hazardous Substances Pollution Contingency Plan, Subpart E - Hazardous Substance Response


EPA, 1994. Health Effects Assessment Summary Tables (HEAST). Prepared by Office of Health and Environmental Assessment, Environmental Assessment and Criteria Office, Cincinnati, Ohio, for the Office of Solid Waste and Emergency Response, Office of Emergency and Remedial Response, Washington, D.C. FY-1993.

EPA, 1995a. "Region IX Preliminary Remediation Goals (PRGS)". September.

EPA, 1995b. "Integrated Risk Information System (IRIS)". Environmental Criteria and Assessment Office, Cincinnati, Ohio. September.

ICF (ICF Technology, Inc.). 1992a. Baseline Public Health Evaluation, McColl Superfund Site. Prepared for U.S. EPA, Region IX. May.

ICF 1992b. Public Health Evaluation of Remedial Alternatives (PHERA), McColl Superfund Site. Prepared for U.S. EPA, Region IX. May.

ICF 1995. "Risk Assessment Revised Work Plan and Cost Estimate, McColl Superfund Site." June 22.


ATTACHMENT A

ADMINISTRATIVE RECORD INDEX

Page 1

03/01/96 McColl Superfund Site

Groundwater Operable Unit

Fullerton, California CHRONOLOGICAL ORDERn

DATE AR # ROLL # FRAME #

yy/mm/dd

AUTHOR ADDRESSEE SUBJECT

00/00/00 AR 1 001 0001 Environmental Protection Agency

Notes: EIR, groundwater study, reevaluation of alternatives & options (Privileged - FOIA ex 5)

00/00/00 AR 2 001 0003

00/00/00 AR 3 001 0005

McColl Groundwater Sampling Uorkplan outline

Portion of site map showing underground irrigation valves, electrical lines, towers

00/00/00 AR 4 001 0007 Electric well logs for

wells P2D - P6D

00/00/00 AR 5 001 0009 Groundwater investigation figure A-3: Hydrogeologic

cross section B-B1 w/marginalia

00/00/00 AR 6 001 0011 US Dept of Interior Geological Survey

00/00/00 AR 7 001 0013 C H 2 M Hill

Map: Well location

Fence diagram w/markings

re screen & water level

locations

00/00/00 AR 8 001 0015 C H 2 M Hill

00/00/00 AR 9 001 0021

Overlays: Construction

diagrams for monitoring

wells (shallow perched-water, deep monitoring,

shallow gas) for

groundwater investigation

Figure 1-1: Map of sump &

boring locations, scale 1"=120'

00/00/00 AR 10 001 0024

00/00/00 AR 11 001 0031 Norman Hatch, Elaine Hayes C H 2 M Hill

Photos: 12 - 4x6, color

w/notation "from groundwater box, no

i ndex"

Article: Orisite

incineration &

groundwater treatment: A

unique solution to cleanup & closure of inactive waste disposal

Page 2

03/01/96

McColl Superfund Site Groundwater Operable Unit

Fullerton, California CHRONOLOGICAL ORDER

DATE AR # ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT yy/mm/dd

site...(pp273-94)

00/00/00 AR 12 001 0054 Logs: Drilling operations for BCL Ass #1 - 28 at Los Coyotes, Caltrans #1 - 13 at Los Coyotes. & Ramparts all at varying elevations

00/00/00 AR 13 001 0105 Logs: Drilling operations

- Canonie #1 - #6 (marked

as being "interpreted fr

the original bore log") (Privileged - FOIA ex 4)

00/00/00 AR 14 001 0107 Radian Corp Section 3: Air emissions measurements, Section 4:

Groundwater, Section 5: Quality assurance

00/00/00 AR 15 001 0476 Radian Corp Technical information &

requirements for groundwater monitoring activities to implement

remedial action w/marginalia

00/00/00 AR 16 001 0501 Steven Linder

Environmental Protection

Agency - Region 9

Peer review outline for


scope of work

00/00/00 AR 17 001 0535 Environmental Protection

Agency - Region 9 Tabs 1 - 6 re PRP proposal/EPA analysis, ROD schedule, gw fact

sheets & well P-2-D info,

thermal destruction cost analysis (Privileged -

FOIA ex 5)

00/00/00 AR 18 001 0537 Groundwater remedial

investigation (RI) phase

1 workplan guidelines for

inclusion w/unilateral

adninistrative order

00/00/00 AR 19 001 0552 American Sigma Operating instructions

for model 5003 controller w/attch operating

instructions for GEOGUARD bladder pumps

LR #

20

21

22

23

24

25

26

27

: 28

i 29

! 30


Fullerton, California

CHRONOLOGICAL ORDER

ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT

001

001

0581

0594

Environmental Protection Agency - National Enforcement Investigations Center

Tables 1-12: Organic analytical results

Routine groundwater monitoring program workptan guidelines for inclusion with unilateral administrative order

001 0630 Aerial photo: Uell locations, 4/87 water

levels

001 0632 Aerial photo: Uell locations

001 0634 John Blevins Charles Silver Environmental Protection CA Dept of Health

Agency - Region 9 Services

001 0636 John Blevins Nestor Acedera Environmental Protection CA Dept of Health


001 0638 John Blevins William Duchie Environmental Protection Shell Oil Co

Agency - Region 9

001 0640

TL:Groundwater Investigation QA/QC Laboratory Data

TL:McColl Groundwater Investigation Rpt: Slope

Stability Monitoring

Technical Memorandum &

Analysis of Lower Ramparts Slope Stability

TL: QA/QC laboratory data

recent groundwater

investigation

Sequence of events re

Special Notice Letters for ground water RI/FS,

O&M

001 0642

001 0646

I C F Technology, Inc Comments on Morrison

Knudsen draft QAPP for RD

work, w/comments on draft community contingency

plan presented by MSG

8/93

Map: Existing monitoring

well array & proposed

001 0648 Table 3 - Summary

Page 4

03/01/96




00/00/00 AR 31 001 0653 I C F Kaiser Engineers,

Inc

statistics, inorganic analyses fr contract lab, w/method & scope of investigation

Map: Deep well inorganics, w/tables of surface soil concentrations

80/10/24 AR 32 001 0657 Rpt: Groundwater Quality,

Tentative Results From EPA-NEIC

80/12/01 AR 33 001 0662 James M Montgomery CA Regional Water Quality Sariple Analysis from

Consulting Engineers, Inc Control Board Chevron Well taken

11/4/80, Faxed to Jim

Grove 10/2/81

80/12/01 AR 34 001 0664 James M Montgomery CA Regional Water Quality Sample Analysis from

Consulting Engineers, Inc Control Board Coyote #2 taken 11/4/80,

Faxed to Jim Grove

10/2/81

80/12/03 AR 35 001 0666

80/12/03 AR 36 001 0686

80/12/08 AR 37 001 0691

McColl Dump Site

Groundwater Quality

James Parsons James Anderson Memo: McColl & Los

CA Regional Water Quality CA Regional Water Quality Coyotes Country Club

Control Board Control Board Sumps: Boring Log Tests & Analysis

Richard Fox Howard Hatayama

CA Dept of Transportation CA Dept of Health

Services

Log of Test Borings w/TL

to Howard Hatayama

1/29/81

81/01/09 AR 38 001 0699 James M Montgomery CA Regional Water Quality Report of Water Analysis

Consulting Engineers, Inc Control Board by GC/MS for

Base/Neut raI/Ac i di c Extractable Organics

81/02/09 AR 39 001 0703 James M Montgomery

Consulting Engineers, Inc Water Analysis by GC/MS for Purgeable Volatile Organics

81/02/17 AR 40 001 0706 Environmental Research

Labs Water Analysis by GC/MS for Purgeable Volatiles


Labs Lab Report: Water

Analysis by GC/MS for

Page 5

03/01/96

McColl Superfund Site

Groundwater Operable Unit Fullerton, California

CHRONOLOGICAL ORDER

DATE AR # ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT

yy/mm/dd

Purgeable Volatile Organics (Incomplete)

81/04/23 AR 42 001 0720 Chip Demarest US Dept of Commerce National Oceanic & Atmospheric Administration

Bart Simmons CA Dept of Health Services

ROC: Update on McColl: Water Samples, Lining Material, Public Hearing

81/04/23 AR 43

81/10/02 AR 44

001 0722 Chip Demarest US Dept of Commerce National Oceanic &

Atmospheric

Administration

001 0724 Ph iIi p Guadagni no

Bart Simmons CA Dept of Health

Services

ROC: Update on site re

water samples, lining material tests, new wells

for groundwater studies,

public hearing

McColl Site Investigation Report: Executive Summary of Drilling Investigation

81/10/02 AR 45 001 0729 Phi lip Guadagnino McColl Site Investigation

Report, Executive Suimary: Drilling

Investigation

81/10/16 AR 46 001 0734 Bart Simmons CA Dept of Health

Services

Notes: DOHS Sampled Perched Water, Analysis

of Testing, Odors

82/00/00 AR 47 001 0739 C H 2 M Hill Construction & development information

for wells W1, W2, U3, W4,

W5, W6B, W8B

82/01/00 AR 48 001 0748 Graphs: Water levels layer 1 & seepage

velocities in upper

levels for 1982 & 1977

82/04/14 AR 49 001 0753 Map of sampling locations

at Ramparts


Labs

82/07/07 AR 51 001 0971 William Duchie Shell Oil Co

Rpt of odorgram analysis

by GC & GC/MS (missing

pages 1-174)

Radian having difficulty

completing groundwater

wells w/attch geohydrological suimary

7/6/82, FAX TL to K

AR i

AR 52

AR 53

AR 54

AR 55

AR 56

AR 57

AR 58

AR 59

AR 60

AR 61

AR 62

AR 63




Shimmin fr U Duchie 7/8/82

001 0977 William Duchie Shell Oil Co

Kathleen Shimmin Environmental Protection Agency - Region 9

Radian having difficulty completing groundwater wells w/attch data

001 0983 Wi lliarn Duchie

Shell Oil Co Participants Committee Memo: Groundwater Data,

Phase I w/attch maps

001 0991 Donald Rothenbaum

CA Dept of Health Services

Inventory worksheets:

Soils, water,

containment, waste analysis, population data

001 1001 Craig Saunders

Ecology & Environment,

Inc


Memo: Critique of Groundwater Investigation

(Privileged - FOIA ex 5)

001 1003 Craig Saunders


Inc

Kathleen Shimmin

Environmental Protection Agency - Region 9

Memo: Comments on


001 1007 William Duchie

Shell Oil Co

Interpretation of

Groundwater Data from

Part 2, Phase I w/TL to K Shimmin 11/11/82

001 1010 Thomas Blair Radian Corp

Thomas Bailey

CA Dept of Health

Services

Ltr: Results of Well Sampling Analysis

001 1020 Thomas Blair Radian Corp

Thomas Bailey CA Dept of Health

Services

Ltr: Response to Memo of 11/15/82 Concerning Third Well (W-3) at Site

001 1028 Donald Rothenbaum

CA Dept of Health

Services

Participant Committee

Members Memo: Addendum to "McColl

Site Ground Water" Letter

of 12/01/82 w/Attachments

001 1041 Orange County - Water

District Key well monitoring

within Orange County

groundwater basin 1983

001 1109 Orange County - Water

District 1982-83 engineers rpt on

groundwater conditions, water supply & basin

utilization

001 1173 Craig Saunders Kathleen Shimmin Memo: Critique of

Page 7




DATE yy/rrm/dd

AR # ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT

83/01/31 AR 64 001 1175


Inc

Craig Saunders Environmental Protection

Agency - Region 9

Environmental Protection groundwater investigation Agency - Region 9 (Privileged - FOIA ex 5)

Kathleen Shi rani n Environmental Protection

Agency - Region 9

Memo: Comments on Radian

recommendation for additional observation & monitoring wells w/attch participants committee member list

83/03/02 AR 65 001 1180 Radian Corp CA Dept of Health

Services

Phase II Hydrogeologic

Aspects of Site (Technical Memorandum) w/TL 03/02/83 RADIAN to CADOHS (Report 4 of 5)

83/03/02 AR 66 001 1264 Radian Corp CA Dept of Health

Services

Technical Memo: Phase 2 hydrogeologic aspects of

McColl site

83/03/15 AR 67

83/04/29 AR 68

83/06/28 AR 69

001

001

001

1312 Radian Corp

1358

1360

Craig Saunders Ecology & Environment,

Inc

Kathleen Shimmin Environmental Protection

Agency - Region 9

McCol'l Site Phase III

Groundwater Monitoring

Activities: Technical

Approach

Memo: Review of technical

information &

requirements for monitoring well bid package (Privileged -

FOIA ex 5)

Protocol for assessing Drinking Water Quality at

Coyote Hills Meadows

83/07/29 AR 70 001 1365 C H 2 M Hill Questions re

hydrogeologic aspects of

site

83/08/00 AR 71 001 1368 CA Dept of Health Services

Rpt: McColl Site Health

Survey: An

Epidemiological and Toxicological Assessment

w/TL to Distribution,

83/08/00 AR 72 001 1579 McColl site health survey

- epidemiological & toxicological assessment

Page 8

03/01/96



DATE AR # yy/mm/dd


83/08/01 AR 73 001 1826 CA Dept of Health

Servi ces

Report on Water Sampling, Coyote Hills, Fullerton

(Document Date 8/83)

83/08/15 AR 74 001 1835 Fritz Carlson

C H 2 M Hill

William Winter

C H 2 M Hill

Memo: Preliminary comments re groundwater & hydrogeologic aspects of site w/marginalia (Privileged - FOIA ex 5)


Services

Report on Water Sampling, Coyote Hills, Fullerton


Rpt: Follow-up water

sampling, Coyote Hills

84/04/27 AR 77 001 1852 Keith Takata


Agency - Region 9

Terry Stumph


Agency - Region 9

Memo: OES supervision of

monitoring well

construction (concurrence

copy), ROC: Need for

geologist, routing slips

(3) 5/84

84/05/02 AR 78 001 1858 ROC: Geologist to Replace

5 Reynolds, DOHS for 2

Weeks, w/Memo Re OES Monitoring Well Construction Supervision, 6 Transmittals (Privilege

- FOIA ex 5)

84/05/14 AR 79 001 1860 Paula Bisson Environmental Protection Agency - Region 9

Keith Takata


Memo: Groundwater

monitoring at McColl (Privileged - FOIA ex 5)

84/05/14 AR 80 001 1862

84/05/22 AR 81 001 1864

Paula Bisson Keith Takata Memo: Groundwater Environmental Protection Environmental Protection monitoring (Privilege

Agency - Region 9 Agency - Region 9 FOIA ex 5)

Report on Groundwater

Monitoring System

w/Handwritten Note:

"Handed Out By Shell"

84/06/07 AR 82 001 1868 Anne St. Clair

Radian Corp

Keith Takata


Agency - Region 9

Ltr: Response to an

Inquiry from Paula Bisson

re Occurence of Perched

Groundwater w/Log of

Drilling Operations

Page 9

03/01/96 HcColl Superfund Site


CHRONOLOGICAL ORDER

DATE AR #

yy/nm/dd


84/08/30 AR 83 001 1874 Stephen Reynolds CA Dept of Health

Services

Patti Cleary Environmental Protection Agency - Region 9

Ltr: Perched Groundwater at the Site w/Copies of Drill Logs and Rpt -

Geotechnical Investigation of the Site

84/08/30 AR 84 001 J959

84/11/00 AR 85 001 2044

85/00/00 AR 86 001 2046

Stephen Reynolds CA Dept of Health

Services

Environmental Protection Agency - Environmental

Monitoring Systems

Laboratory


Ltr: Perched groundwater at site w/attch drilling

logs

Geographic information systems technology & groundwater management (Privileged - FOIA ex 5)

Estimate of Work, Specifications and Bid Schedule and Maps w/Note to Patti Cleary 10/01/85

85/05/03 AR 87 001 2062 Harvey Collins CA Dept of Health

Services

Hugh Berry, Asst City

Mgr City of Fullerton

Ltr: Lab Analysis results

of Drinking Water in Meadow's subdivision in

Fullerton

85/07/23 AR 88 001 2066

85/10/18 AR 89

85/11/01 AR 90

001

001

2068

2076

Keith Takata Environmental Protection

Agency - Region 9

Thomas Bailey CA Dept of Health

Services

Harry Seraydarian


Agency - Region 9

William Duchie

Shell Oil Co

Memo: CH2M Hill work

assignment - supplemental

reevaluation of

alternatives, groundwater

investigation

(concurrence copy)


Ltr: Response To 9/16/85 Ltr (Attached): Shallow

Subsurface Analysis

Maps: Groundwater contour, date range: 11/1/44- 11/1/85 (box

531)

85/11/13 AR 91 001 2098 Bryant Wong, William J Winter

C H 2 M Hill

Memo: Meeting to Discuss

Groundwater Investigation

& Supplemental

Reevaluation of

Alternatives

w/Attachments

85/11/13 AR 92 001 2115 Bryant Wong William J Memo: Meeting to Discuss

Page 10

03/01/96



DATE AR # yy/mm/dd


Winter

C H 2 M Hill


and Supplemental Reevaluation of Alternatives (Privileged - FOIA ex 5)

85/11/20 AR 93 001 .2117 Patti Cleary Environmental Protection Agency - Region 9

Fi les Memo: McColl Emergency Action, Assessment of

Alternatives, Berm Stabilization & Proposed


85/12/00 AR 94 001 2121 Bryant Wong

C H 2 M Hill

Handwritten notes:

Groundwater investigation, upcoming

events, SROA, monies w/o

handout (Privileged -

FOIA ex 5)

85/12/16 AR 95 001 2123 Keith Takata


Harry Seraydarian


Agency - Region 9

Memo: CH2M Hill Work Assignment increase for


85/12/18 AR 96 001 2125 Wi11iam J Winter

C H 2 M Hill

Workplan - Task 4 -Groundwater Investigation


Services

Protocol for assessing

Drinking Water Quality at

Coyote Hills Meadows

86/01/11 AR 98 001 2134 Jeff Zelikson


Hugh Berry,

Engr/Community

Development

City of Fullerton

Ltr: Drilling program for

groundwater monitoring

wells in Fullerton Crest

area

86/02/00 AR 99 001 2137 Environmental Protection Agency - Region 9

Microfiche: Groundwater Investigation ID# 011-

9L04.0: RAS volatiles &

semivolatiles, RAS metals, SAS inorganics,

RAS metals (soil) (25mf)

86/02/12 AR 100 001 2139 Keith Takata Environmental Protection

Agency - Region 9

Harry Seraydarian


Agency - Region 9


Groundwater Investigation w/Concurrences &

Procurement Request/Order 2/7/86 (Privileged - FOIA ex 5)

Page 11



CHRONOLOGICAL ORDER

DATE yy/nm/dd


86/02/21 AR 101 001 2141 B Wong C H 2 M Hill

Rescoping chart w/activities, schedule, mtgs for gw investigation, soil &

water characterization, incineration evaluation

86/03/11 AR 102 001 2143 Bryant Wong

C H 2 M Hill


Agency - Region 9

Memo: Summary of Observation from 2/7/86 Auger Borings and Condition of Existing Monitoring Uells

86/03/11 AR 103 001 2155 Bryant Wong C H 2 M Hill


Memo: Transmits memo re summary of observations fr 2/7/86 auger borings 2/28/86 & handwritten

memo re condition of existing monitoring wells, w/encls

86/03/12 AR 104 001 2167 C H 2 M Hill Environmental Protection

Agency - Region 9

Draft workplan groundwater investigation

w/TL to Patti Cleary fr

Bryant Wong, 3/12/86 (Privileged - FOIA ex 5)


Agency - Region 9

Harry Seraydarian Environmental Protection

Agency - Region 9


gw investigation

w/Concurrences & Procurement Request/Order

3/17/86 (Privileged -

FOIA ex 4)

86/03/18 AR 106 001 2171 Log of differential

levels at varying

elevations for 2/18/86,

3/18/86

86/04/02 AR 107 001 2175 Workplan Revision Request

for Additional Money for Groundwater Investigation

w/Final Workplan and TL

(Redacted -FOIA ex 4)

86/04/10 AR 108 001 2198 C H 2 M Hill Final Workplan: McColl Groundwater Investigation

86/05/13 AR 109 001 2219 C H 2 M Hill Environmental Protection Draft quality assurance

Page 12

03/01/96




Agency - Region 9 project plan (QAPP) &

site sampling plan -groundwater investigation (Privileged - FOIA ex 5)

86/05/23 AR 110 001 2221 Jim Rielly Mike Bitner Orange County - Water C H 2 M Hill

District

TL: Groundwater contour maps 11/1/76, 11/1/81, 11/1/84, 11/1/85 w/attchs

86/05/27 AR 111 001 2227 William Duchie

Shell Oil Co

Paula Bisson


Ltr: Comments on CH2M

Hill's Groundwater

Investigation Workplan


Shell Oil Co

Paula Bisson

Envi ronmentaI Protect i on Agency - Region 9

Ltr: General comments on

groundwater investigation workplan w/attch detailed

comments on final

workplan 4/10/86


Agency - Region 9

Kurt Berchtold Ltr: Workplans for CA Regional Water Quality CRWQCB-SA review w/o

Control Board - Santa Ana attch groundwater Region investigation workplan,

w/addressees list

(concurrence copy) (Privileged - FOIA ex 5)


Agency - Region 9

Kurt Berchtold Ltr: Workplans to be CA Regional Water Quality submitted to CRWQCB-SA

Control Board - Santa Ana for review w/o encl Region groundwater investigation

workplan, w/list of

addresses (redacted)


Agency - Region 9

Kathleen Shimmin


Agency - Region 9

Memo: Review of the

McColl Groundwater

Investigation Site

Sampling Plan

w/Concurrences


86/06/18 AR 116 001 2242 Robert Merryman

Orange County • Health Care Agency

Keith Takata Ltr: Conments on Revised

Environmental Protection Workplan will be Agency - Region 9 submitted after

opportunity to review

86/06/23 AR 117 001 2244 John Blevins Paula Bisson Memo: Issues raised at

Environmental Protection Environmental Protection mtg with SCAQMD, County

Agency - Region 9 Agency - Region 9 of Orange, & City of Fullerton concerning

Page 13




CHRONOLOGICAL ORDER

DATE yy/mm/dd


86/07/00 AR 118 001 2246 C H 2 M Hill Environmental Protection

Agency - Region 9

Drilling Permits (Privileged - FOIA ex 5)

Contract docs for drilling, geophysical logging, installation & testing of gw monitoring wells w/TL to J Blevins fr M Bitner (Privileged -

FOIA ex 5)

86/07/02 AR 119 001 2248

86/07/11 AR 120 001 2250

Orange County - Water

District

Paula Bisson Environmental Protection Agency - Region 9

Uilliam Duchie Shell Oil Co

Draft Orange County Water

District Proposed

Groundwater Protection

Policy

Ltr: Acknowledge comments on groundwater workplan,

transmittal of quality assurance project plan/site sampling plan (QAPP/SSP) w/o encl (redacted)

86/07/25 AR 121 001 2252 Terry Stumph Environmental Protection

Agency - Region 9


Agency - Region 9

Memo: Comments by Rose

Fong on McColl Groundwater Investigation

QAPP (Privileged - FOIA

ex 5)

86/08/04 AR 122 001 2254 Orange County -Sanitation District

Rpt: Temporary Acceptance

of Groundwater for

Cleanup Projects (Ref

#913) w/attchments

86/08/07 AR 123 001 2280 David Spath CA Dept of Health

Services

Hamid Saebfar

CA Dept of Health

Services

Memo: Water Sampling,

Coyote Hills w/attached

Sampling Protocol,

6/28/83

86/08/12 AR 124 001

86/08/20 AR 125 001

2286 Susan Keydel, Stewart

Simpson, Laura Tom


Inc

2288 Mike Bitner C H 2 M Hill

John Blevins Environmental Protection

Agency - Region 9


Agency - Region 9

Memo: Review of groundwater sampling plan

w/marginalia (Privileged

- FOIA ex 5)

Ltr: Inspection of groundwater monitoring

well # W-1

86/08/22 AR 126 001 2290 Terry Stumph Keith Takata Memo: Comments on revised

Page 14

03/01/96



DATE AR # yy/mn/dd


Environmental Protection Environmental Protection McColl Groundwater Agency - Region 9 Agency - Region 9 Investigation QAPP


86/09/03 AR 127 001 2292 William J Winter C H 2 M Hill

John Blevins Environmental Protection Agency - Region 9

Ltr: Revisions to Draft Site Sampling Plan (SSP) (Privileged - FOIA ex 5)

86/09/03 AR 128 001 2294 William Winter

C H 2 M Hill

John Blevins


Ltr: Responses to comments re groundwater

investigation draft site

sampling plan (Privileged

- FOIA 5)

86/09/15 AR 129 001 2296 Keith Takata


Kurt Berchtold Ltr: Final workplan for

CA Regional Water Quality various tasks to

Control Board - Santa Ana supplement previous Region RI/FS, w/o attch

(concurrence copy) (Privileged - FOIA ex 5)

86/09/15 AR 130 001 2298 Keith Takata


Kurt Berchtold Ltr: Final workplan for CA Regional Water Quality various tasks to

Control Board - Santa Ana supplement previous

Region remedial

i nvest i gat i on/feas ibiIi ty

study (RI/FS) w/o attch

(redacted)

86/09/16 AR 131 001 2301 Al Vargas Ecology & Environment,

Inc

John Blevins Memo: Review of Sampling Environmental Protection Plan by CH2M Hill Agency - Region 9 (9/19/86)

86/09/18 AR 132 001 2304 Jeff Zelikson


David Howekamp Environmental Protection Agency - Region 9

Memo: McColl Supplemental RI/FS Workplan & Groundwater Monitoring

Workplan w/Concurrences (Privileged - FOIA ex 5)

86/09/18 AR 133 001 2306 Jeff Zelikson


Agency - Region 9

Carl Morthole


Memo: Supplemental RI/FS

Workplan & Groundwater

Monitoring Workplan

w/Concurrences


86/09/18 AR 134 001 2308 Jeff Zelikson Environmental Protection Agency - Region 9

Frank Covington Environmental Protection Agency - Region 9

Memo: Supplemental RI/FS Workplan & Groundwater Monitoring Workplan

w/Concurrences


Page 15




DATE yy/mm/dd


86/09/19 AR 135 001 2310

86/09/19 AR 136 001 2312

86/09/19 AR 137 001 2314

86/09/19 AR 138 001 2316

86/09/19 AR 139 001 2319

Al Vargas Ecology & Environment,

Inc


Inc


Inc

Uilliam Duchie

Shell Oil Co

Ui lliam Duchie

Shell Oil Co

John Blevins Memo: Review of Sampling

Environmental Protection Plan by CH2M Hill Agency - Region 9 (9/19/86) (Privileged -

FOIA ex 5)

John Blevins Memo: Review of sampling Environmental Protection plan (Privileged - FOIA

Agency - Region 9 ex 5)

John Blevins Memo: Review of sampling

Environmental Protection plan (Privileged - FOIA

Agency - Region 9 ex 5)

Paula Bisson Ltr: Comments on Quality

Environmental Protection Assurance Project Plan &

Agency - Region 9 Site Sampling Plan

Paula Bisson Ltr: Comments on draft Environmental Protection quality assurance project

Agency - Region 9 plan (QAPP) & site

sampling plan

86/09/22 AR 140 001 2322 Sam Ziegler Betty Porras

Environmental Protection McColl Action Group

Agency - Region 9

Ltr: Transmits final workplans for gw inves & tasks to supplement RI/FS, final draft rpt on

slope stability & info re

EIS, w/o encls (concurrence cpy)

86/09/22 AR 141 001 2325

86/09/25 AR 142 001 2328

Sam Ziegler Betty Porras Environmental Protection McColl Action Group

Agency - Region 9

Jeff Zelikson Environmental Protection

Agency - Region 9

Phil Bobel Environmental Protection

Agency - Region 9

Ltr: Transmits final

workplans for gw invest &

tasks to supplement

previous RI/FS, final

draft rpt on slope stability & info re EIS,

w/o encls

Memo: Supplemental RI/FS & groundwater monitoring

workplans w/attch

workplans or ROD (concurrence copy)


86/09/25 AR 143 001 2330 Barry Eaton, Planner City of Fullerton


Agency - Region 9

Ltr: Questions & comments

on final workplan for

various tasks to supplement previous RI/FS

effort

Page 16

03/01/96

HcColl Superfund Site Groundwater Operable Unit


CHRONOLOGICAL ORDER

DATE AR # yy/mm/dd


86/09/30 AR 144 001 2337

86/09/30 AR 145 001 2419

86/09/30 AR 146

Michael Bitner

C H 2 M Hill

C H 2 M Hill

001 2421 William J Winter

C H 2 M Hill




Site sampling plan (CH2M

Hill Project #W63412.QS)

Quality assurance project plan (QAPP) (Privileged -FOIA ex 5)

Ltr: Transmittal of Revised QAPP & SSP for Groundwater Investigation , & Summary of the

Revisions

86/10/03 AR 147 001 2424 Keith Takata


Agency - Region 9

Terry Stumph


Agency - Region 9

Memo: Review of McColl


QAPP w/revisions by EPA &

E&E w/Concurrences

86/10/06 AR 148

86/10/23 AR 149

001 2426 Keith Takata Environmental Protection

Agency - Region 9

001 2428 Paula Bisson



Nestor Acedera


Memo: Resubmittal of Site Sampling Plan for the Groundwater Investigation

incorporating comments by

E&E, EPA w/Concurrences

Ltr: Comments on Draft

Protocol for McColl Site Water Sampling Follow-up Study (Privileged - FOIA

ex 5)

86/11/00 AR 150

86/11/00 AR 151

001 2430

001 2575

C H 2 M Hill Contract Documents for Drilling, Geophysical Logging, Installation & Testing of Groundwater Monitoring Wells

Chapter 6.6, Safe drinking water & toxic

enforcement act of 1986

re prohibition on

contaminating dringking

water w/carcinogenic

chemicals...

86/11/01 AR 152 001 2579 Ecology & Environment,

Inc Bid Specifications for

Installation of Monitor Wells

86/11/04 AR 153 001 2626 C H 2 M Hill Contract Documents for Drilling, Geophysical

Page 17




DATE AR #

yy/mm/dd


Logging, Installation;

and Testing of Groundwater Monitoring

Wells

86/11/06 AR 154 002 0001 C H 2 M Hill Revision #3 to QAPP Groundwater Investigation w/Transmittal to J Blevins 11/06/86

86/11/06 AR 155 002 0011 Mike Bitner C H 2 M Hill


Copies of Transmittal Forms indicating distribution of the Contract Documents prepared for McColl Groundwater Investigation

w/TL to EPA-9


Agency - Region 9

Barry Eaton, Planner City of Fullerton

Ltr: Response to 9/25/86 comments on workplan for

additional work

(redacted)

86/11/10 AR 157 002 0034 C H 2 M Hill Results of initial sampling at wells U1

6B, U8B


Agency - Region 9

Terry Stumph Environmental Protection

Agency - Region 9

Memo: Enclosure of rev

tables (4-1,8-1, & 8-2)

from gw investigation

QAPP rev to incorporate

comments in Memo of


FOIA ex 5)

86/11/20 AR 159 002 0038

86/11/20 AR 160 002 0040

Terry Stumph


Agency - Region 9

Terry Stumph Environmental Protection

Agency - Region 9


Agency - Region 9


Agency - Region 9

Memo: Approval of


QAPP

Memo: Groundwater

i nves t i gat i on qua Ii ty

assurance project plan

(QAPP) is approved w/marginalia, w/o title & e ? nnnti ipo naflO


Fact sheet: EPA to

conduct groundwater

sampling

Page 18

03/01/96



DATE AR # ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT yy/nm/dd


EPA Fact Sheet: McColl

Superfund Site, EPA to conduct groundwater sampling (Document date: December,1986)

86/12/02 AR 163 002 .0048 QAPP Approval Signature Sheets for Groundwater Investigation w/Transmittal to J

Blevins 1/6/87

86/12/13 AR 164 002 0053

86/12/22 AR 165 002 0055

Peter Rubenstein Environmental Protection

Agency - Region 9

Keith Takata


Don White


William Bresnick

Texaco, Inc

Memo: Summary of items &

issues from mtg re well

drilling & field work


Ltr: Request comments on

workplan, gw investigation, fact sheet

w/remediation schedule

w/o attchs (concurrence copy) (Privileged - FOIA ex 5)

86/12/22 AR 166 002 0057 C H 2 M Hill Envi ronmentaI Protect i on Agency - Region 9

Supplemental soil gas sampling to groundwater investigation site sampling plan

86/12/22 AR 167 002 0115 Keith Takata


Agency - Region 9

William Bresnick

Texaco, Inc

Ltr: Request comments on

workplans for additional

tasks, groundwater

investigation, fact sheet

w/schedule for

remediation w/o attchs (redacted)

86/12/24 AR 168 002 0121 John Blevins


Hamid Saebfar CA Dept of Health

Services

Ltr: Response to Surface

Water Contamination concerns voiced by

Residents at November Meeting: Analysis & Findings

87/01/00 AR 169 002 0126 William Winter

C H 2 M Hill

John Blevins


QAPP for supplemental

soil gas sampling to gw

investigation - 3 copies

w/differing marginalia


Page 19




DATE yy/mm/dd



Drinking Water Action

Levels recommended by CADOHS

87/01/15 AR 171 002 0132

87/01/28 AR 172 002 0148


Agency - Region 9

William Duchie

Shell Oil Co

Hamid Saebfar

CA Dept of Health

Services


Agency - Region 9

Ltr: Comments on Second

Draft of Drinking Water Sampling Protocol w/Protocol

Ltr: Highlights of areas

of concern on "Final Workplans for Groundwater

Investigation" & "Various other tasks w/Comments

87/01/28 AR 173 002 0159 William Duchie Shell Oil Co

Keith Takata Environmental Protection Agency - Region 9

Ltr: Shell comments on final workplans for gw investigation & various...tasks to

supplement previous RI/FS efforts w/attch specific

comments

87/02/11 AR 174 002 0170

87/02/16 AR 175 002 0172

Jeff Zelikson Hugh Berry

Environmental Protection City of Fullerton

Agency - Region 9

William J Winter

C H 2 M Hill


Agency - Region 9

Ltr: Response to concerns

re EPA drilling program


Ltr: Request for Amendment to Groundwater

Investigation QAPP & Site Sampling Plan for two

Soil Analysis Methods

87/02/25 AR 176 002 0177 C H 2 M Hill Lab Results of McColl

Groundwater Data w/Transmittal to EPA-9,

07/22/87

87/02/27 AR 177 002 0201 Hany Malek

C H 2 M Hill


Agency - Region 9

Transmittal Form for

Tabulation of Bids for

Drilling & Sampling,

Proposal of Selected

Bidder & Addendum 1-3 w/Documents (Privilege rniA oy

87/03/02 AR 178 002 0203 Terry Stimph Environmental Protection

Agency - Region 9

Keith Takata Memo: Approval of QAPP


Agency - Region 9

Page 20

03/01/96


Groundwater Operable Unit Fullerton, California CHRONOLOGICAL ORDER


87/03/09 AR 179 002 0205

87/03/12 AR 180 002 0224 William Dennison Fred Lattice South Coast Air Quality Management District

hrs), gamma logs W-8B, U-5, W-6B, P-3D, W-4

Keith Takata Ltr: Comments on Draft Environmental Protection Field Sampling Plan Agency - Region 9

87/03/12 AR 181 002 0231 Peter Rubenstein Sample Plan Memo: Preparation of EPA-

Environmental Protection Writers/Project Managers 9 sample plan Agency - Region 9 w/marginalia

87/03/18 AR 182 002 0233

87/03/27 AR 183

87/03/27 AR 184

87/04/01 AR 185

87/04/01 AR 186

87/04/20 AR 187

87/04/29 AR 188

87/05/19 AR 189

002

002

002

002

002

002

002

0267

0275

0285

0287

0291

0318

0323

Paul Johnson


Inc


Keith Takata Fred Lettice

Environmental Protection South Coast Air Quality

Agency - Region 9 Management District

C H 2 M Hill

Bertrand Palmer

Earth Technology Corp

Scott McKinley

C H 2 M Hill

Dale Rowlison

C H 2 M Hill

Dave Mark, Mike Bitner C H 2 M Hill

Quality assurance rpt

(TDD #F9-8701-04) Case

#6799/2692Y #3 for anions & water quality parameters fr Rocky

Mountain Analytical labs

Ltr: Response to Ltr of 3/12/87 requesting certain conditions be incorporated into field

plan w/Ltr of 3/12/87

Daily drilling plan -

boring MT3-LO-SO-01 - 09

w/marginalia

CA preliminary 20-day

notice for water well drilling & equipment

CA preliminary 20 day

notice for water well drilling & equipment

Ltr: Preliminary results

for geotechnical testing, w/attch lab rpts

Monitoring well measuring point elevation w/marginalia (box 530)

Draft outline groundwater investigation (2 copies

w/differing marginalia),

waste & soil field

Page 21




CHRONOLOGICAL ORDER


yy/mm/dd


drilling/sampling rpt

w/marginalia

87/06/01 AR 190 002 0332 Draft Outlines: Groundwater investigation, waste & soil investigation field drilling & sampling rpt (Privileged - FOIA ex 5)

87/07/15 AR 191 002 0334 Cross section diagram of

monitoring well (marked

superceded)

87/07/31 AR 192 002 0336 Bryant Wong C H 2 M Hill

John Blevins Transmittal: Microfiche Environmental Protection duplicates of groundwater

Agency - Region 9 investigation w/o

enclosure

87/08/24 AR 193 002 0338 April 1987 water levels chart scale: 1:200

87/08/27 AR 194 002 0340 C H 2 M Hill

87/09/01 AR 195 002 0345 Ted Turk Tetra Tech, Inc

87/09/14 AR 196

87/09/18 AR 197

002 0350 Angelo Bellomo CA Dept of Health

Services

002 0352 C H 2 M Hill

Nestor Acedera

CA Dept of Health

Services

Interagency Committee

Members

Technical Memo I: Review

of Potentially Responsible Parties Remedial Action &

Stabilization Plan

Ltr: Need to incorporate

EPA investigations on

groundwater, waste & soil

& SROA into EIR for

remediation (marked:

"Advance copy")

Draft Memo: Minutes of

9/14/87 IAC mtg w/attch

potential indications of

gw contamination, site

map, attendees list (Privileged - FOIA ex 5)

Maps (9) for groundwater

investigation (site &

monitoring well

locations, elevations for

4/87) some w/marginalia

87/09/18 AR 198 002 0371 Map: McColl site &

Page 22

03/01/96




87/09/22 AR 199 002 0374

monitoring well locations fr McColl groundwater investigation rpt, figure 1-2, scale 1"=200'

Photocopied database

labels for CLP data

87/09/24 AR 200 002 0376

87/09/24 AR 201 002 0499

87/09/25 AR 202 002 0622

C H 2 M Hill

C H 2 M Hill

Donald Chance

Geo-Sec, Inc Willi am MacLeod

Prime of California

Final Draft Groundwater Investigation Report

Groundwater Investigation Report - Final Draft

Container Corp soil/water

quality assessment

progress rpt &

recommendations w/lab

rpts, chain of custody,

TL to M Zunde fr U MacLeod 9/30/87

87/09/30 AR 203 002 0629 Donald Chance Geo-Sec, Inc

William MacLeod Prime of California

Container Corp site specific groundwater flow direction

87/10/01 AR 204 002 0631 Orange County - Health

Care Agency Press Release: DHS has released Report containing Preliminary Results of recent


87/10/07 AR 205 002 0634 Donna Davis Orange County Register

Newsclip: Tainted groundwater found at

McColl

87/11/00 AR 206 002 0637 Robert Kerr

Environmental Protection Agency - Robert S Kerr Environmental Research Laboratory

Robert Kerr Environmental

Research Laboratory, Ada, Okla

87/11/16 AR 207 002 0763 DHS/EPA Meeting with McColl Action Group

w/Handouts

87/12/04 AR 208 002 0768 Gary Young

Environmental Protection Agency - National Enforcement

Keith Takata


Ltr: Offer to Assist with Groundwater Analysis

Page 23



CHRONOLOGICAL ORDER


yy/mm/dd

Investigations Center

87/12/14 AR 209

88/02/01 AR 210

88/03/07 AR 211

88/04/27 AR 212

88/04/28 AR 213

88/06/28 AR 214

88/07/00 AR 215

88/09/15 AR 216

88/09/19 AR 217

002 0770 CA Dept of Health Servi ces

002 0780 Bryant Wong C H 2 M Hill


Agency - Region 9

002 0782 Steve Reynolds Fi les

002

002

002

0784

0794

0797

002

002

002

Paul Kunkel C H 2 M Hill

Douglas Kendall Environmental Protection

Agency - National

Enforcement


Barry Blodgett CA Dept of Health

Services

Joe Loury Environmental Protection

Agency - National

Enforcement


0816

0818

0820

Mike Bitner

C H 2 M Hill

C H 2 M H i l l

Paul Kunkel, Mark Henry

C H 2 M Hill

McColl Water Sampling Pre-visit Information

Sheet

Transmittal Form for Analysis of Lower Ramparts Slope Stability, Waste & Contaminated Soil

Investigation, Groundwater Investigation

Rpt

Memo: Comments on gw & soil/waste studies w/list of phase 1 & 2 tasks w/rtg slip to P Kunkel fr

J Blevins 3/28/88 (Privileged - FOIA ex 5)

Laboratory Reports: McColl Drinking Water

Study

Meeting notes re groundwater investigation

Memo: Analysis of wells

W-2, W-5, P-2D samples &

procedures for groundwater analysis

w/data tables, TL to K

Takata fr J Lattimer

Table 1: Monitoring well

groundwater elevations

for 4/87, 1/88, 4/88,

7/88

Memo: Review of groundwater technical

memo

Technical Memo: Groundwater Elevations

Measurement Study results, w/TL to John Blevins, 9/19/88, & Maps

Page 24

03/01/96



DATE AR # yy/mm/dd


88/10/00 AR 218 002 0840 Stephen Reynolds CA Dept of Health Services

Preliminary groundwater remedial investigation phase 1 workplan w/marginalia (Privileged - FOIA ex 5)



Technical Memo: Review of McColl Site Groundwater Remedial Investigation,

Phase I Workplan, October

1988 w/Request Form (Privileged - FpIA ex 5)

88/11/02 AR 220 002 0844 Robert Merryman Orange County - Health Care Agency

Stephen Reynolds


Ltr: Review & comments on

Groundwater RI Workplan: Public Health Issues,

Contingency Plan

w/attached Community

Safety/Contingency Plan

88/11/02 AR 221 002 0869 John Blevins


Agency - Region 9

Jan Meyer

CA Dept of Health

Services

Ltr: Comments on Phase I

Groundwater Remedial

Investigation Preliminary

Draft Workplan


88/12/27 AR 222 002 0871 Paul Kunkel

C H 2 M Hill John Blevins Environmental Protection Agency - Region 9

TL: Waste & contaminated

soil & gw investigation

rpts, w/12/27/88 memo:

response to comments by B Vance, to File fr P Kunkel (Privileged - FOIA ex 5)

88/12/27 AR 223 002 0873 John Blevins


Agency - Region 9

Jan Meyer

CA Dept of Health

Services

Ltr: Comments on 2nd draft of phase I gw RI

preliminary draft

workplan (Privileged -FOIA ex 5)

89/00/00 AR 224 002 0875 Bechtel Environmental,

Inc

Figure 2: Map of

groundwater monitor well

locations, scale 1"=200', w/marginalia



Memo: Suggested locations for Upgradient Monitoring

Wells w/attached Maps

89/01/19 AR 226 002 0885 William Duchie Paula Bisson, Ted Rauh Ltr: Follow-up to 1/9/89

Page 25



CHRONOLOGICAL ORDER

DATE yy/mm/dd


Shell Oil Co Environmental Protection

Agency - Region 9

phone conversation w/John Blevins re Standing water

at McColl Site

89/01/19 AR 227

89/01/19 AR 228

89/02/01 AR 229

89/02/27 AR 230

002 0888 Charles McAuley McAuley Oil Co

002 0891 William Duchie Shell Oil Co

002 0894 Stephen Reynolds CA Dept of Health

Services

002 0896 John Blevins Environmental Protection

Agency - Region 9


Agency - Region 9

Ltr: McCauley will-Abandon Idle Water Well

on Los Coyotes Club

Property

Paula Bisson Ltr: Concern About Envirormental Protection Standing Water on Site

Agency - Region 9

Charles McAuley

McAuley Oil Co

Due to Rain

Draft groundwater remedial investigation.

Phase I workplan w/TL to

John Blevins 2/23/89 (Privileged - FOIA ex 5)

Ltr: Regarding the

Abandonment of "Idle-

Water-Well" on Los Coyotes Country Club

89/03/13 AR 231 002 0898 Ecology & Environment, ^aUatlon oT I nc . .

Background Monitor Well

Clusters

89/03/20 AR 232 002 0929 Gerald George US Dept of Justice

89/03/20 AR 233 002 0931 Gerald George US Dept of Justice

89/03/31 AR 234 002 0933 Robert Powell Shell Oil Co

Jon Wactor Ltr: Comments on state's

Envirormental Protection draft phase 1 workplan

Agency - Region 9 for gw RI (US v Stringfellow, Jr, et al, civil #83-2501 JMI (C.D. Cal.) (Privileged - FOIA

ex 5)

Jon Wactor Ltr: Comments on state

Envirormental Protection draft phase 1 workplan

Agency - Region 9 for groundwater RI (Privileged - FOIA ex 5)

John Blevins Stephen Ltr: Comments of Reynolds Companies on McColl Site

Environmental Protection proposed Groundwater Agency - Region 9 Investigation, Upgradient

Monitoring Wells (Privileged - FOIA ex 5)

Page 26

03/01/96



DATE AR # yy/mm/dd


89/03/31 AR 235 002 0935

89/04/01 AR 236

89/04/06 AR 237

002

002

0937

0966

William Duchie Shell Oil Co

Stephen Reynolds

CA Dept of Health

Services

Robert Merryman

Orange County - Health

Care Agency


John Blevins


Agency - Region 9

Ltr: Comments of the companies on proposed groundwater investigations, upgradient monitoring wells w/attachments (Privileged - FOIA ex 5)

Groundwater remedial investigation phase 1

workplan

Ltr: Encouragement to

Include Requirements in

the Workplan

w/Application for Well

Permi t

89/04/19 AR 238 002 0969

89/05/03 AR 239 002 0975

David Spath


All Interested Parties

Jon Wactor Cynthia Burch

Environmental Protection Pillsbury, Madison & Agency - Region 9 Sutro

TL: Action levels for contaminants of drinking

water & maximum

contaminant levels w/attchs

TL: Sampling &

groundwater rpts

89/05/29 AR 240

89/07/17 AR 241

002

002

0977 Oil companies

1388

89/07/17 AR 242 002 1406

89/07/27 AR 243 002 1408

Santiago Lee I C F Technology, Inc

Santiago Lee

I C F Technology, Inc

Santiago Lee


Neil Ziemba


Agency - Region 9

PRP comments on draft EIR

of 5/29/89 (?) -

appendices A-N

Data validation rpt: Case #LV916 memo #1 - RAS

semi-volatiles, w/quality

assurance rpt 7/19/89 & TL to N Ziemba fr K

Kitchingman 8/11/89

Data validation report LV916 Memo #1 w/cover

sheet 7/21/89, TL to Neil

Ziemba fr Kent Kitchingman, 7/28/89


Data validation rpt: Case #LV916, memo #2, 27 water

samples for SAS volatiles analyses, w/TL to N

Page 27




CHRONOLOGICAL ORDER


yy/mm/dd


89/08/03 AR 244 002 1427 I C F Technology, Inc

89/08/09 AR 245 002 1442

89/09/05 AR 246 002 1455

Burmah Technical Services, lnc

Pacific Environmental

Management Corp

Ziemba fr K Kitchingman

8/11/89

Data validation rpt: Case #LV916, memo #3, 26 water

samples for RAS & SAS inorganic analysis, w/QA rpt & TL to N Ziemba fr IC

Kitchingman 8/11/89

Analytical reports BUS-3194 on water samples, BWS-6775 on soil samples

Jerry Clifford Terry Stumph Memo: Acknowledgement of

Envirormental Protection Environmental Protection sampling & analysis of Agency - Region 9 groundwater wells

conducted in June 1989, & request for more sampling

Agency - Region 9

89/09/18 AR 247 002 1457

89/10/02 AR 248 002 1540

89/10/03 AR 249 002 1548

89/10/03 AR 250 002 1550

89/10/03 AR 251 002 1552

89/11/00 AR 252 002 1554

Dawn Zemo Ecology & Environment,

Inc

Gregg Wurtz I C F Technology, Inc

John Blevins Pam

Uieman Environmental Protection

Agency - Region 9

John Blevins FIT Monitor Well Environmental Protection Installation Report, Agency • Region 9 McColl Site, Fullerton,

California

Kent Kitchingman Memo: Operation of

Environmental Protection Bladder Pimp Systems at

Agency - Region 9

Interagency Committee

Members

John Blevins Cynthia Burch Environmental Protection Pillsbury, Madison &

Agency - Region 9 Sutro

John Blevins Charles McAuley

Envirormental Protection McAuley Oil Co

Agency - Region 9

Tom Huetteman Environmental Protection

Agency - Region 9

McColl Site

Memo: Transmittal* of

Monitoring Well Installation Report

TL: 5 copies of

Monitoring Well

Installation Report

TL: Copy of Monitoring

Well Installation Report

& Results of Test Burn •

Treatability Study

Draft 1989 groundwater

investigation report


89/11/00 AR 253 002 1556 Bechtel Environmental, Inc

Technical specifications

for well redevelopment

Page 28

03/01/96



DATE AR # yy/rrm/dd


89/11/04 AR 254

89/11/17 AR 255

002

002

1584

1586

89/12/04 AR 256 002 1592

89/12/05 AR 257 002 1594

89/12/05 AR 258 002 1596

89/12/19 AR 259 002 1598

89/12/20 AR 260 002 1600

90/00/00 AR 261 002 1645

90/00/00 AR 262 002 1647

Daniel McCarrel Pillsbury, Madison & Sutro

Salem Attiga .

Bechtel Environmental, Inc

Pam Wieman, et al


Stephen Reynolds

CA Dept of Health

Services

Karl Leist


Stephen Reynolds CA Dept of Health

Services

John Blevins


Pam Wieman



Pam Wieman


Agency - Region 9

Salem Attiga

Bechtel Environmental,

Inc


John Blevins


Ltr: Items missing from data packages for groundwater collected during 6/89

Ltr: Well development section for wells W2, W9B & W10B of activity workplan w/attch plan (Redacted - FOIA ex 4)

Work assignment form (Cont #68-W9-0060, WA

360-06-9L04 rev 1) for

remedial investigation


Remedial investigation

deep well redevlopment w/cost estimate, TL to Pam Wieman fr Salem

Attiga 12/5/89


Workplan memo remedial

investigation w/schedule,

cost estimate, TL to Pam Wieman fr Salem Attiga


FOIA ex 4)

Ltr: Comments on proposed

well development

procedures (Privileged -FOIA ex 5)

Interoffice Memo: Health

& safety plan compilation

for well redevelopment w/attchs

Comments on Bechtel

Environmental well redevelopment report (Privileged - FOIA ex 5)

Ltr: Review & comments on Bechtel1s well

development report (Privileged - FOIA ex 5)

Page 29




CHRONOLOGICAL ORDER

DATE AR # yy/mm/dd


90/00/00 AR 263 002 1649

90/01/03 AR 264 002 1661

CA Dept of Water Resources


Agency - Region 9

John Blevins, Pam

Uieman Environmental Protection

Agency - Region 9

CA well standards -water, monitoring & cathodic protection wells (Bulletin 74-90), cover &

pp605 w/marginalia

w/attch 12/81 standards,

cover & pp52-7

Memo: Groundwater sampling at McColl Site,

round 2 w/attached

revisions

90/01/03 AR 265 002 1674 Tom Huetteman , Environmental Protection

Agency - Region 9

John Blevins, et al Environmental Protection Agency - Region 9

Memo: Groundwater sampling for week of 1/15/90 w/attch revised map, request for analysis

table

90/01/24 AR 266 002 1687

90/01/25 AR 267 002 1689


Agency - Region 9


John Blevins, Pam Uieman Environmental Protection Agency - Region 9

Memo: McColl groundwater

sampling round 2

Routine gw monitoring program - workplan

guidelines for inclusion

with unilateral

administrative order (Privileged - FOIA ex 5)

90/02/14 AR 268 002 1691 Margie Weiner I C F Technology, Inc


Agency - Region 9

Data validation rpt: Case

#13471 Memo #2, Lab:

Skinner & Sherman,

Analysis: RAS metals, Samples: MYE131-150,

1/16-18 '90 w/cover memo,

3/2/90



Agency - Region 9


#13471 Memo #4, Lab:

Skinner & Sherman,

Analysis: RAS metals. Samples: MYE151...172,

1/18-20, '90 w/cover

memo, 3/2/90

90/02/26 AR 270 002 1711 David Bingham Environmental Protection

Agency - Region 9

I C F Technology, Inc Memo: Request for unvalidated data table 1

&/or data validation u tA-k¥e\ ual i rlat i nn QA£

Page 30

03/01/96



DATE AR # yy/mm/dd


90/02/28 AR 271

90/03/00 AR 272

002 1728 David Bingham


002 1743 Bechtel Environmental,

Inc



semi-volatiles, 22 water samples

Memo: Request for

invalidated data table 1 &/or data validation w/attached data for SAS volatiles & tetrahydrothi aphenes

Well redevelopment rpt w/attchs, TL to Pam Wieman fr Peter Nunn


Fact Sheet: EPA Announces Installation of Three New Monitoring Wells And

Ground Water Sampling

Results


Inc


Agency - Region 9 Well redevelopment at the

McColl site, Fullerton,

CA w/TL to Pam Wieman from Peter Nunn, 3/16/90

90/03/02 AR 275 002 1787

90/03/13 AR 276 002 1796

Margie Weiner

I C F Technology, Inc Environmental Protection Agency - Region 9

Margie Weiner


Data validation rpt: Case #13471 Memo #3A, Lab: Skinner & Sherman,

Analysis: RAS metals, Samples: MYE171...180,

1/18-21, '90 w/cover memo, 3/7/90


#SAS 5185Y memo #6,

Analyses Alkalinity, COO, chlroide, nitrate-N...,

w/attchs & TL to J

Blevins fr S Lee 3/13/90

90/03/13 AR 277

90/03/16 AR 278

002 1807 Margie Weiner


002 1816 Garrett Day


Inc

Salem Attiga


Inc

Data validation rpt Case

#SAS 5185Y Memo #6 Analyses: Inorganics w/Tl to John Blevins fr

Santiago Lee, 3/13/90

Interoffice Memo:

Transmittal of

preliminary well

redevelopment rpt for

Page 31



CHRONOLOGICAL ORDER

DATE

yy/mm/dd


90/03/26 AR 279 002 1818

90/04/00 AR 280 002 1832

90/04/00 AR 281 002

90/04/26 AR 282 002

90/05/23 AR 283 002

1853

1855

1857

90/05/23 AR 284 002 1885

Thorsten Anderson I C F Technology, Inc


Agency - Region 9


Inc

Michelle Vranizan Orange County Register

Robert Hughes Bechtel Environmental,

Inc


Agency - Region 9

Peter Nunn Bechtel Environmental,

Inc

Environmental Protection ARCO, Phillips, Shell,

Agency • Region 9 Texaco, Union Oil, AminoiI


Agency - Region 9

90/05/30 AR 285 002 1915

90/06/08 AR 286 002 1917

Lois Grunwald Environmental Protection

Agency - Region 9

Robert Powell

ENVIRON Corp

review w/o rpt (BEI

#20376-006-006)


#LV0S02 Memo #8 SAS volatiles & THTHP in

water collection date: 1/16-1/21/90 w/TL to John Blevins fr Santiago Lee

4/5/90

Redevelopment of wells U-

9B, W-10B, and U-2 at McColl w/TL to Pam Uieman

fr Ed Baquerizo, 4/26/90

Newsclipping: EPA orders study of water at McColl

Document review notice (BEI #20376-006) for rpt:

Redevelopment of wells U-

9B, W-10B, U-2

Unilateral Administrative

Order for partial remedial investigation &

response actions (Section

106 Order) docket #90-12

Ltr: Response to offer

and issuance of unilateral administrative

order for partial RI &

response actions w/attch

administrative order

Docket 90-12

Press Release: EPA Orders

Oil Companies to Conduct

McColl Superfund Work

Environmental Protection Response to 106 Order: Agency - Region 9 Declaration of Robert

Powell - review of

William Leake Atlantic Richfield Co

groundwater data to Jafapmi na anHanaprniPnt

90/06/08 AR 287 002 2004 Joseph Rodricks ENVIRON Corp

Environmental Protection Response to 106 Order: Agency - Region 9 Declaration of Joseph

Page 32

03/01/96



DATE AR # yy/mm/dd


90/06/09 AR 288 002 2053 Robert Scofield

ENVIRON Corp Environmental Protection Agency - Region 9

Rodricks - review of groundwater data to

assess human health risk

Response to 106 Order: Declaration of Robert Scofield - assessment of potential health implications w/exhibit A: resume of Mr Scofield

90/06/09 AR 289 002 2065 Michael Montgomery


Kent Rogers


Ltr: Response to 6/3/94 request for extension of

schedule

90/06/11 AR 290 002 2068 Cynthia Burch

Allen, Matkins, Leek, Gamble & Mai lory

Jeff Zelikson


Ltr: Response to letter of 5/23/90 & to the

unilateral adninistrative

order for partial remedial investigation

response actions (106 Order)

90/06/11 AR 291

90/06/11 AR 292

002 2134 ARCO, Phillips, Shell,

Texaco, Union Oil,

AminoiI

002 2319 Cynthia L Burch

Allen, Matkins, Leek,

Gamble & Mai lory


Agency - Region 9

Jeff Zelikson


Agency - Region 9

Response to 106 Order:

Appendix - historical

documents, 1941-1945

Response by oil companies

to 05/23/90 ltr and

unilateral admin order

for partial RI response

actions (Privileged -FOIA ex 5)

90/06/11 AR 293 002 2321

90/06/11 AR 294 002 2423

Ed Baquerizo


Ed Baquerizo


Inc

Pam Wieman Environmental Protection Agency - Region 9

Pam Wieman


Agency - Region 9

Ltr: Modifications to field sampling plan for quarterly groundwater

monitoring, draft w/attchMcColl 1989

grounwater field sampling

plan w/appendices

Ltr: Modifications to

field sampling plan (FSP)

for quarterly groundwater

monitoring w/attch site sampling plan, health & safety plan

90/06/19 AR 295 002 2586 Tom Huetteman Pam Wieman Memo: Modifications to

Page 33




CHRONOLOGICAL ORDER

DATE

yy/mm/dd


90/06/22 AR 296 002 2588

90/06/22 AR 297 003 0001

90/06/22 AR 298 003 0163


Ed Baquerizo Bechtel Environmental,

Inc


Inc


Inc


Pam Uieman Environmental Protection

Agency - Region 9

Pam Uieman Environmental Protection Agency - Region 9


Agency - Region 9

field sampling plan for qtrly groundwater monitoring approved

Ltr: Modifications to FSP for qtrly groundwater

monitoring w/attached sampling plan 05/30/90 and appendices A - D

Ltr: Modifications to field sampling plan for quarterly groundwater monitoring w/5/89 site

sampling plan w/appendices A-D, 6/90 health & safety plan

Ltr: Modifications to

field sampling for quarterly groundwater monitoring rpt w/Memo

1/3/90 re same, lab analyses. Table 5.0, site

map

90/06/22 AR 299 003 0179 Robert Hughes, et aI Bechtel Environmental,

Inc

Health & safety plan for

site maintenance,

groundwater monitoring &

well abandonment

activities

90/06/22 AR 300 003 0241 Ed Baquerizo Bechtel Environmental,

Inc


Agency - Region 9

Ltr: Modification to

field sampling plan (FSP)

for quarterly groundwater

monitoring rev 1 w/attch

sampling plan 5/30/89

90/07/00 AR 301 003 0404

90/07/02 AR 302 003 0406


Agency - Region 9

Lilya Rikshpun Environmental Protection

Agency - Region 9


Draft groundwater investigation rpt for EPA

sampling at McColl (Privileged - FOIA ex 5)

Memo: Request for

unvalidated data table 1

Case #LV0S13 memo #1 RAS

semi-volatiles in water 4 A 0 I D

90/07/19 AR 303 003 0412 Lilya Rikshpun I C F Technology, Inc Request data validation

Page 34

03/01/96

HcColl Superfund Site


CHRONOLOGICAL ORDER

DATE AR #

yy/mm/dd ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT

90/07/19 AR 304 003 .0420


Steven Linder Environmental Protection Agency - Region 9

Teri Shearer Environmental Protection Agency - Risk Reduction Engineering Laboratory

Case #14386 Memo #1 Analyses: RAS inorganics

w/attch rpt, TL to John

Blevins fr Victoria Taylor, 8/13/90

TL: 1987 groundwater investigation rpt w/o rpt

90/07/20 AR 305 003 0422' Lilya Rikshpun

Environmental Protection Agency

I C F Technology, Inc Request data validation Case #14386 Memo #2

Analyses: RAS inorganics

w/attch rpt, TL to John Blevins fr Victoria Taylor, 8/8/90

90/07/20 AR 306 003 0432 Lilya Rikshpun


I C F Technology, Inc Memo: Request for unvalidated data table 1

Case #14386 memo #2 RAS-

total metals in water

w/attch unvalidated table 1, 7/27/90



I C F Technology, Inc Memo: Request for unvalidated data table 1 Case #14316 memo #5 oil samples for high

concentration aroclor

w/attch unvalidated data table 1, 7/23/90

90/07/30 AR 308 003 0446 Sharon Lin

I C F Technology, Inc Environmental Protection

Agency - Region 9 Data validation rpt Case

#LV0S13 memo #2 RAS volatiles in water &

solids w/attch TLs to J Blevins fr V Taylor

7/30/90 & to ICF fr L Rikshpun 7/6/90

90/07/30 AR 309 003 0460 Sharon Lin I C F Technology, Inc



#LV0S13 Memo #2 RAS volatiles in water/solids

col 6/1/90 w/TL to J Blevins fr V Taylor

8/2/90, to ICF fr L

Rikshpun 7/6/90

90/08/00 AR 310 003 0475 Tom Huetteman Final groundwater

Page 35

03/01/96




DATE AR # yy/im/dd


90/08/06 AR 311 003 0644

90/08/06 AR 312 003 0668


Pam Uieman, Dolores Morrison Environmental Protection Agency - Region 9

Jerry Clifford Environmental Protection

Agency - Region 9

Jeff Zelikson Environmental Protection Agency - Region 9

investigation report for

EPA sampling at McColl w/appendices A-J

UAF for RI, (mod #23) w/attch SOU for groundwater OU, 9/10/90

Memo: Initial LOE & funding phase 1 gw RI/FS

approval, w/attch memo re SOW fr S Linder, procurement request, SI rtg slip, UAF (Privileged

- FOIA ex 4)

90/08/07 AR 313 003 0670

90/08/07 AR 314 003 0672

90/08/07 AR 315 003 0687

90/08/08 AR 316 003 0704

CA Dept of Health

Services


Lilya Rikshpun I C F Technology, Inc


Agency - Region 9





Agency - Region 9

Comments on statement of work for ground water RI w/TL to Steven Linder fr

Kathleen Considine,


FOIA ex 5)

Request data validation

Case #LVOS14 Memo #3

Analyses: RAS & VOA

w/attch rpt, TL to John Blevins fr Victoria

Tualor, 9/17/90


Case 0LVOS14 Memo #4

Analyses: RAS w/attch rpt, TL to John Blevins

fr Victoria Taylor

9/14/90


SAS #5499Y Memo #5

Analyses: SAS inorganics

w/rpt, Tl to J Blevins fr

V Taylor 9/5/90,

telephone log 8/29/90 re

questions


Inc

Pam Uieman Ltr: Transmittal of draft

Environmental Protection acitvity workplan for Agency - Region 9 abandonment of wells W-1,

U-2, U-5 rev 0 w/attch

Page 36

03/01/96

McColl Super-fund Site Groundwater Operable Unit


DATE AR # yy/mm/dd


90/08/15 AR 318 003 0733

90/08/17 AR 319 003 0736

Lisa Hanusiak I C F Technology, Inc



workplan

ROC (CLP): Re Case LV0S13 for 8/14 & 8/15/90

Data validation rpt case #LV0S13 memo #1 RAS semi-volatiles in water &

solids col 6/1/90 w/TL to J Blevins fr V Taylor

8/20/90, request memo

8/20/90

90/08/20 AR 320 003 0752 Rich Freitas, Herb

Levine


Agency - Region 9

Steven Linder


Memo: Gw 0U -

recommendations re

placement of additional gw monitoring wells

w/attch outline of summary hydrogeologic rpt (Privileged - FOIA ex 5)

90/08/21 AR 321 003 0754 Lisa Hanusiak



LV0S13 memo #3 RAS pesticide/PCB in water &

solids col 6/1/90 w/TL to J Blevins fr V Taylor,


7/16/90

90/08/22 AR 322 003 0766 Lisa Hanusiak I C F Technology, Inc

90/08/23 AR 323

90/08/24 AR 324

003

003


0783 Steven Linder Steve Gaytan

Environmental Protection CA Dept of Health


0785 Cynthia Burch


Pam Uieman



LV0S13 memo #4 RAS volatiles in water &

solids col 6/22 & 6/26/90 w/TL to J Blevins fr V Taylor 8/23/90, request

memo 7/20/90

Ltr: Abandonment of

groundwater wells

Ltr: Comments on

bi d/package/speci f i cat i on s for drilling of

boreholes (Privileged -FOIA ex 5)

90/08/27 AR 325 003 0787 Lisa Hanusiak Environmental Protection

I C F Technology, Inc Agency - Region 9 Data validation rpt Case LV0S13 memo #6 RAS seim-volatiles in water &

Page 37

03/01/96 McColl Superfund Site >



CHRONOLOGICAL ORDER


yy/mm/dd

solids col 6/21-22/90 w/TL to J Blevins fr V Taylor 8/28/90, request

memo7/26/90

90/09/00 AR 326 003 0807

90/09/03 AR 327 003 0863




Agency - Region 9

ARCSUEST services subcontract #20376-006-005-01-TSC exhibit D: Technical specifications, data & drawings for well

abandonment, revision 0

Data validation rpt Case LV0S13 memo #8 RAS pesticides/PCB in water &

solids col 6/21-22/90 w/TL to J Blevins fr V

Taylor 9/5/90, request

memo 8/2/90

90/09/05 AR 328 003 0876

90/09/10 AR 329 003 0878

Steve Gaytan



Inc


Pam Uieman ' Environmental Protection

Agency - Region 9

Ltr: Comments on scope of

work for groundwater RI

Ltr: Final activity

workplan for abandonment

of wells U-1, W-2, & W-5 w/workplan (redacted)


Inc

Pam Uieman


Ltr: Final activity

workplan for abandonment of wells U-1, U-2 & U-5

w/attch workplan (Privileged - FOIA ex 4)


Inc

Pam Uieman


Agency - Region 9

Ltr: Transmittal of final

activity workplan for

abandonment of wells U-1, U-2, U-5 w/attch workplan

90/09/10 AR 332 003 0916

90/09/10 AR 333 003 0931

Ed Baquerizo, Peter Nunn, Pam Uieman Robert Hughes Environmental Protection

Bechtel Environmental, Agency - Region 9

Inc

Steven Linder Bechtel Environmental,

Environmental Protection Inc

Agency - Region 9

Final activity workplan for abandonment of wells

U-1, U-2 & U-5

Groundwater operable unit

(OU) statement of work rsouT

90/09/13 AR 334 003 0954 Dolores Morrison Robert Hughes Ltr: Assignment of UAM

Page 38

03/01/96



DATE AR # yy/mm/dd


Environmental Protection Bechtel Environmental, Agency - Region 9 Inc

w/attch WA form for RI

activity w/SOU for groundwater operable unit, BEI routing slip

(Job #20376-011)

90/09/13 AR 335 003 0981 Dolores Morrison Environmental Protection Agency - Region 9

Robert Hughes


Ltr: WA workplans w/attch WAF for RI (Cont 68-UD-0060, UA 60-11-9L04, mod 23) dtd 8/6/90 w/attch

SOU for groundwater OU,

9/10/90

90/09/13 AR 336 003 1006 Margie Weiner



Data validation rpt SAS

#5466Y memo #7 RAS/SAS in soil, water & oil col

6/21-22/90 w/TL to J

Blevins & J Rosai fr V

Taylor 9/17/90, request memo

90/09/13 AR 337 003 1023 Steven LInder


Charles McAuley

Los Coyotes Country Club TL: Groundwater investigation rpt for EPA sampling at site w/o

attch

90/09/13 AR 338 003 1025 Steven Linder


Agency - Region 9

Cynthia Burch


Gamble & Mai lory

Ltr: Pamela Andes to

distribute final


rpt for EPA sampling to

PRPs represented by

Allen, Matkins, et al w/o

rpt

90/09/14 AR 339 003 1027 Ed Baquerizo


Inc


Ltr: Submittal of revised field sampling, health & safety plan, QAPP (review

summary) for groundwater monitoring program (UA 60-06-9L04) w/attch plans

90/09/14 AR 340 003 1250 Ed Baquerizo


Pam Uieman


Ltr: Draft field sampling, health & safety, & QAPP review

summary for groundwater

monitoring program w/FSP,

QAPP review, partial HSP


Joyce Mathews


Purchase memo for closure

of monitor wells w/attch

Page 39

03/01/96 HcColl Superfund S i t e

G r o u n d w a t e r O p e r a b l e U n i t


CHRONOLOGICAL ORDER

\


yy/mm/dd

Inc Inc memo re companies, technical specifications for well abandonment

90/09/19 AR 342

90/09/19 AR 343

90/09/19 AR 344

003 1440 Ed Baquerizo Bechtel Environmental,

Inc


Inc


Inc


Charles McAuley City of Buena Park


Agency - Region 9

Ltr: Summary of topics discussed at Task Review Meeting for groundwater monitoring activities held at ICF Universal

City offices

Ltr: Docunentation of information discussed re closure of monitor wells

W-1, U-2, U-5

Ltr: Summary of key issues discussed at task review meeting for groundwater monitoring

activities 8/24/90


Inc

Charles McAuley McAuley LCX Corp

Ltr: Info re closure of monitor wells W-1, W-2 &

W-5, plans for field

activities

90/09/28 AR 346 003 1457 Tom Huetteman Environmental Protection

Agency - Region 9

Pam Ui eman Environmental Protection

Agency - Region 9

Memo: Review of draft groundwater field

sampling plan (FSP) &

QAPP review surinary

w/attch lab analysis

rpts, chain of custody

record, packing list

90/10/00 AR 347 003 1477

90/10/02 AR 348 003 1480


Agency - Region 9

Ed Baquerizo


Inc

Pam Uieman


Agency - Region 9

Fact Sheet: McColl Groundwater Activities

Ltr: Staffing plan &

schedule for RI w/attch

groundwater RI organization chart, tentative schedule,

90/10/04 AR 349 003 1488 Kathleen Considine CA Dept of Health

Services

Steven Linder TL: Statement of work

Environmental Protection (SOW) for groundwater Agency - Region 9 remediation investigation

90/10/04 AR 350 003 1496 Steve Gaytan Steven Linder Ltr: Reasons for

Page 40

03/01/96

McColI Superfund Site Groundwater Operable Unit


DATE AR # yy/mm/dd




abandonment of monitoring

wells A-13 and W-3

90/10/04 AR 351 003 1499 Steve Gaytan CA Dept of Health

Services

Steven Linder


Ltr: Reasons for abandonment of monitoring wells A-13 & W-3

90/10/09 AR 352 003 1502 Ed Baquerizo, et al Bechtel Environmental,

Inc

Environmental Protection-Agency - Region 9

Final groundwater field sampling plan

w/transmittal information

sheet

90/10/10 AR 353 003 1660 John Blevins Mark Leary Environmental Protection CA Dept of Health

Agency - Region 9 , Services

Ltr: Request document review time frames in

site action plan be waived for documents relating to phase 1


workplan

90/10/16 AR 354 003 1662 Pam Uieman, Steven

Linder


Dave Jones Memo: Issues re McColI

Environmental Protection project - AR, response

Agency - Region 9 summary, cost recovery, groundwater RI (Privileged - FOIA ex 5)

90/10/16 AR 355 003 1664 Environmental Protection Bechtel Environmental,

Agency - Region 9 Inc

Preliminary draft

comments on workplan memo

for phase 1 groundwater

RI/FS w/attch BEI routing slip 10/17/90 (Privilege

- FOIA ex 5)

90/10/22 AR 356 003 1666 Ed Baquerizo


Inc

Steven Linder Ltr: Well location memo

Environmental Protection for groundwater monitor Agency - Region 9 wells (RI) w/attch memo

90/10/29 AR 357 003 1676 Gymala Perry I C F Technology, Inc

Ed Baquerizo


Inc

Ltr: Points raised at follow-up quarterly groundwater sampling

meeting of 10/23/90


Inc


Ltr: Submittal of revised table from field sampling

plan for McColI

w/attached Table 5:

sunmary of requested chem

analyses for groundwater

samples...

Page 41




DATE

yy/mm/dd


90/10/31 AR 359 003 1684 Molly Kirkley Bechtel Environmental,

Inc

90/11/01 AR 360 003 1818 Paul Kunkel C H 2 M Hill

Darrell Tweidt Beylik Drilling, Inc

Steven Linder Environmental Protection

Agency - Region 9

Ltr: Well abandonment

subcontract w/attch services subcontract exhibits A: General conditions, B: Special conditions, G: Health &

safety plan

TL: Electronic groundwater data, TCLP, EP TOX, CA WET test data

w/o attchs

90/11/05 AR 361 003 1820 Darrell TWeidt Beylik Drilling, Inc

90/11/09 AR 362 003 1823 Cynthia Burch Allen, Matkins, Leek,

Gamble & Mai lory


Inc


Agency - Region 9

Ltr: Clarification on request to not obtain well drilling permits

(Subcont #20376-006-005-01-SC) w/FAX TL to Molly

Kirkley fr Darrell Tweidt, 11/5/90

Ltr: Comments on 1990 final groundwater

investigation rpt w/attch

declaration by Robert

Powell 11/08/90 and

exhibits

90/11/09 AR 363 003 1864 Cynthia Burch Allen, Matkins, Leek, Gamble & Mai lory

Jeff Zelikson Ltr: Comments re 8/90

Environmental Protection Final groundwater

Agency - Region 9 investigation rpt w/attch

declaration of Robert Powell 11/9/90 w/exhibits


Inc

Neutron/gamma-ray log for

well W-2, daily field

rpts 11/5/90-11/20/90 re

well abandonment (Job

#20376-006-005)

90/11/13 AR 365 003

90/11/13 AR 366 003

1934 Matthew Mitguard Peter Nunn Environmental Protection Bechtel Environmental,

Agency - Region 9 Inc

1936 Matthew Mitguard Environmental Protection Agency - Region 9

WAF for RI phase 1

w/attch SOW for gw RI phase 1, TL to D Morrison

fr R Hughes 12/5/90


WAF for RI phase 1

w/attch SOW for groundwater RI phase 1


Page 42

03/01/96



DATE AR # yy/mm/dd


90/11/15 AR 367 003 1938

90/11/15 AR 368 003 1955

90/11/21 AR 369

90/11/23 AR 370

003

003

2049

2051

Lilya Rikshpun


Gymala Perry I C F Technology, Inc


Michael Francis

Demetriou, Del Guercio & Lovejoy

Lilya Rikshpun Environmental Protection

Agency - Region 9


Inc

Allan Zable



Request data validation Case #LVOS24 Memo #2 Analyses: RAS w/attch rpt, TL to Pam Wieman fr Victoria Taylor 90/12/13

Ltr: Submittal of draft quarterly groundwater

sampling rpt for 6/90 & notification of unavailability w/attch

rpt

Ltr: Request copies of

documentation re well abandonment on McAuley

property (Los Coyotes)

Request data validation SAS #5699Y Memo #3


w/attch data validation

rpt, TL to Pam Wieman fr Victoria Taylor 12/18/90

90/11/23 AR 371 003 2061 Lilya Rikshpun I C F Technology, Inc


Agency - Region 9


Case #15127 Memo #5,

Analyses: RAS metals

w/attch rpt, TL to Pam Weiman fr Victoria Taylor

12/12/90

90/11/23 AR 372 003 2072 Lilya Rikshpun I C F Technology, Inc


Request data validation Case #LV0524 Memo #4, Analysis: SAS-inorganic w/attch rpt, TL to Pam

Wieman fr Margie Weiner

12/13/90

90/11/23 AR 373 003 2080 Steven Linder


Agency - Region 9

Steve Gaytan

CA Dept of Health

Services

Ltr: PRP ltr & rpt re

1990 final groundwater i nvest igat i on

recommending well W-4 be abandoned due to

increased arsenic

concentrations w/o rpt

90/11/23 AR 374 003 2082 Steven Linder Steve Gaytan

Environmental Protection CA Dept of Health Agency - Region 9 Services

Ltr: 1990 final groundwater investigation rpt recommends

Page 43




CHRONOLOGICAL ORDER

DATE yy/nm/dd


abandonment of well W-4 due to increased arsenic concentrations

90/11/26 AR 375

90/11/27 AR 376

90/11/29 AR 377

003

003

003

2084

2086

2185

90/11/29 AR 378 003 2196


Peter Nunn Bechtel Environmental,

Inc

Margie Weiner I C F Technology, Inc

Margie Weiner I C F>Technology, Inc

Kent Kitchingman Environmental Protection Agency - Region 9



Agency - Region 9


Memo: Request for assistance in maintaining quarterly groundwater monitoring program

Ltr: Submittal of draft groundwater monitoring rpt for 6/90 w/attch rpt


LV0S13 memo #18 SAS EP Tox metals in soils col

6/21-22/90 w/TL to J

Blevins & J Rosati fr V Taylor 11/29/90, request

memo

Data validation rpt Case LV0S13 memo #19 RAS/SAS metals in water col 6/22 & 6/26/90 w/TL to J

Blevins & J Rosati 12/3/90, request memo

11/14/90

90/11/30 AR 379 003 2207

90/11/30 AR 380 003 2222

90/11/30 AR 381 003

Lisa Hanusiak Data Validation Rpt

I C F Technology, Inc LV0S24 Memo #1 w/TL to Pam Wieman fr Victoria

Taylor, Memo to ICF fr

Lilya Rikshpun, 11/08/90


LV0S13 memo #15 RAS/SAS

in water col 6/1/90 w/TL to John Blevins & Janet

Rosati fr V Taylor


11/7/90

Doug Steele Memo: Request for

Envirormental Protection Environmental Protection technical assistance on Agency - Region 9 Agency - Region 9 groundwater issue w/o

attch technical support

2232 John Blevins

90/12/11 AR 382 003 2234 Robert King, et al Pam Wieman Ltr: Concerns re

Page 44

03/01/96



DATE AR # yy/itm/dd


90/12/12 AR 383 003 2240

McColl Site Group



Envi ronmenta t Protect i on Agency - Region 9

conditions observed on

site visits 11/13-14/90

w/photographs

(photocopies)

Data validtion rpts Case #LVOS24 Memo #2 RAS semi-volatiles, #4 (unvalidated SAS-IN), #5 RAS metals, routing slip

to Peter Nunn fr Pam Uieman 12/19/90


McColl Site Group

Steven Linder


Ltr: Request surveyed

coordinates for groundwater monitoring

wells, soil & waste

borings

90/12/12 AR 385 003 2277 Pam Uieman Cynthia Burch

Environmental Protection Allen, Matkins, Leek, Agency - Region 9 Gamble & Mai lory

Ltr: Response to 11/9/90

ltr re comments on EPA groundwater sampling rpt

of 8/90 - your

recommendation to abandon well U-4

90/12/14 AR 386 003 2280 Ed Baquerizo, et at


Inc

Steven Linder


Agency - Region 9

Final groundwater

monitoring rpt for June

1990 (ARCS)

90/12/14 AR 387 003 2381 Ed Baquerizo


Inc


Agency - Region 9

Draft activity summary

rpt for abandonment of


wells W-1, W-2, W-5 w/TL to P Uieman fr P Nunn

90/12/14 AR 388 003 2443 Ed Baquerizo


Pam Uieman


Draft activity summary

rpt for abandonment of groundwater monitoring wells U-1, U-2, U-3 w/TL

to P Uieman fr P Nunn (Privileged - FOIA ex 5)



Agency - Region 9

I C F Technology, Inc Request data validation

Case #LV0S24 Memo #4


w/attch rpt, TL to Pam

Uieman fr Victoria Taylor 12/20/90

Page 45

03/01/96 McColI Superfund Site



DATE yy/mm/dd

I


91/00/00 AR 390 003 2456 I C F Technology, Inc Quarterly groundwater monitoring draft workplan memorandum w/attch OF60, org chart, marginalia

(Privileged - FOIA ex 4 &

ex 5)

91/00/00 AR 391 003 2458 I C F Technology, Inc Figure 3 (rev2): Taks &

charge code breakdown, Figure 1 (rev2):

Quarterly groundwater organization chart

91/01/03 AR 392 003 2461

91/01/07 AR 393 003 2464

Pam Uieman, Steven

Linder Environmental Protection

Agency - Region 9

Fraser Felter

Robert King, et al Union Oil Co of

California

David Bushey

Ltr: Response to 12/11/90 Itr re well maintenance,

boreholes, & waste

storage

TL: SITE trial excavation

Environmental Protection Fullerton Hills Community rpt, 12/90 & final Agency - Region 9 Assn groundwater monitoring

rpt for 6/90, dated

12/14/90 w/o encls

91/01/07 AR 394 003 2466 Fraser Felter Environmental Protection

Agency - Region 9

Archives Librarian

City of Fullerton -

Public Library

TL: SITE trial excavation, 12/90 & final


rpt for 6/90, dated

12/14/90 w/o encls


Gamble & Mai lory


Agency - Region 9

TL: Aerial photograph

w/orthophoto mylar

overlay (scale: 1"=40')

w/o encls (for photo see

doc 1654-02962)

91/01/14 AR 396 003

91/01/15 AR 397 003

2470 William Duchie McColI Site Group

2475 Cynthia Burch Allen, Matkins, Leek, Gamble & Mai lory

John Blevins Ltr: Off-site Envirorwental Protection observations re standing

Agency - Region 9 water after 1/4/91 rainstorm w/attch 3

photographs, color, 4x6

Pam Uieman Ltr: Response to 1/12/90

Environmental Protection ltr re Companies

Agency - Region 9 recommendation for • I _ £. .,-.1 I ll_/.

91/01/16 AR 398 003 2478 Rich Freitas Environmental Protection

Agency - Region 9


Agency - Region 9

Memo: Groundwater flow direction data review

included in monitoring

Page 46

03/01/96




rpt 6/90, memo: Elevations, final investigation rpt 9/87, hydrogeologic memo 3/83

91/01/16 AR 399 003 2482 Rich Freitas Environmental Protection Agency - Region 9

Steven Linder


Memo: Conclusions fr data review re groundwater

flow direction

91/01/22 AR 400 003 2486 Tom Huetteman


Steven Linder


Memo: Groundwater

sampling for week of

1/28/91 w/attch piston pimp operating procedure, revised analyses requested Table 5.0

91/01/23 AR 401 003 2493 Ed Morelan


Inc

Daily field rpt (Job

#20376-006-005) for well

abandonment w/attch sample location map

91/02/01 AR 402 003 2496 Peter Nunn Bechtel Environmental,

Inc


Agency - Region 9

Ltr: Draft groundwater

monitoring rpt for 10/90

w/marginalia, rpt

91/02/12 AR 403 003 2602 Ed Baquerizo, et al


Inc


Agency - Region 9

Final groundwater

monitoring rpt for

October 1990 (ARCS

program)

91/02/12 AR 404 004 0001 Ed Baquerizo


Inc

Roseanne Sakamoto Environmental Protection Agency - Region 9

TL: Resubmittal of chain of custody records &

traffic rpts for groundwater sampling

10/99 w/attchs

91/02/12 AR 405 004 0028 Peter Nunn


Steven Linder


TL: Final groundwater

monitoring rpt for 10/90 sampling w/o rpt

91/02/20 AR 406 004 0030 Tom Huetteman


Steven Linder


Memo: Quarterly

groundwater sampling

collected 1/29-31/91

91/02/25 AR 407 004 0032 Cynthia Burch


Pam Wieman


Ltr: 1/16/91 site visit

photographs, concerns re well P2-D & on-site waste storage w/attch

91/03/05 AR 408 004 0039 Steven Linder IAC Member TL: Final groundwater

Page 47




yy/mm/dd

91/03/07 AR 409 004 0041



Agency - Region 9

Kent Kitchingman Environmental Protection

Agency - Region 9

monitoring rpt for 10/90 w/o encl rpt

Memo: Appreciation for

assistance in quarterly groundwater sampling event & request for

further assistance

91/03/25 AR 410 004 0043 Kathleen Considine, Steven Gaytan

CA Dept of Health

Services


Ltr: Condition of

monitoring wells

91/03/26 AR 411 004 0047 Ed Morelan Bechtel Environmental,

Inc

Daily field rpt for well abandonment (Job 20376-

006-005 w/attch Falcon

Disposal Service transportation rpt #123697, TL to P Nunn fr E Morelan 3/28/91

91/03/29 AR 412 004 0052 Margie Ueiner I C F Technology, Inc


Agency - Region 9

Data validation rpt CAse #15799 memo #3 RAS metals in groundwater col 1/30-

2/1/91 w/TL to Pam Wieman

fr Victoria Taylor


3/11/91

91/04/02 AR 413

91/04/02 AR 414

004 0061 Steven Linder, Pam Wieman


Agency - Region 9

004 0064 Steven Linder, Pam

Wieman Environmental Protection

Agency - Region 9

Kathleen Considine, Steven Gaytan CA Dept of Health

Services

Ltr: 3/25/91 memo re condition of monitoring

wells - EPA does not

agree with Health Services assumptions

Kathleen Considine, Steve Ltr: Memo on condition of

Gaytan site monitoring wells

CA Dept of Health 3/25/91

Services

91/04/04 AR 415 004 0067 Sripriya Chari I C F Technology, Inc


Agency - Region 9


#15799 memo #6 RAS metals

in groundwater col 1/29-

30/91 w/TL to Pam Wieman

fr Victoria Taylor


3/13/91

91/04/04 AR 416 004 0076 Sripriya Chari Environmental Protection Data validation rpt Case

Page 48

03/01/96



DATE yy/mm/dd


I C F Technology, Inc Agency - Region 9 LV1S21 memo #2 RAS semi-volatiles in groundwater col 1/29-2/1/91 w/TL to P Wieman fr V Taylor

4/4/91, request memo 3/5/91

91/04/05 AR 417 004 0093 Cynthia Burch



Ltr: Photographs taken during 2/28/91 site visit, drainage at well

P2D w/photographs (color

photocopies)

91/04/06 AR 418

91/04/08 AR 419

004 0101 Ed Baquerizo


Inc

004 0103 Ed Baquerizo, Peter Nunn Bechtel Environmental,

Inc

Pam Wieman


ARCS regions 9 & 10

document quality

assurance check for draft final well abandonment

rpt

Final activity summary rpt for abandonment of


wells W-1, W-2, W-5 w/TL to P Wieman fr P Nunn

91/04/08 AR 420 004 0172 Ed Baquerizo, Peter Nunn


Inc

Pam Wieman


Final activity summary

rpt for abandonment of


wells W-1, W-2 & W-5 w/TL

to P Wieman 4/8/91

91/04/08 AR 421 004 0241 Margie Weiner



Agency - Region 9


#LV1S21 memo #4 SAS inorganics in groundwater

col 1/29-2/1/91 w/TL to P Wieman 4/8/91, request

memo 3/11/91



Data validation rpt SAS #6017Y memo #5 SAS chemical 02 demand/total

organic carbon in water

col 1/29-2/1/91 w/TL 4/9/91, request memo

3/13/91

91/04/11 AR 423 004 0262 Peter Nunn


Inc

Pam Wieman


Ltr: Well closure rpt

final technical activity

Page 49

03/01/96



CHRONOLOGICAL ORDER

DATE AR if yy/mm/dd


91/04/22 AR 424 004 0264

91/04/23 AR 425

91/05/09 AR 426

004

004

0271

0273

91/05/09 AR 427 004 0275

Robbie Hedeen Environmental Protection Agency - Region 9

Steven Linder, Pam

Wieman Environmental Protection Agency - Region 9

John Blevins Envi ronmentaI Protect i on Agency - Region 9


Cynthia Burch


Memo: April groundwater sampling to be done 4/29-5/3/91 w/attch piston pump operating procedure,

analyses request table

5.0

Ltr: Response to 4/5/91

ltr re drainage at site

Kent Kitchingman Memo: Appreciation for Environmental Protection support in groundwater

Agency - Region 9

Steven Linder Caroline Rudolph Environmental Protection CA Dept of Health


sampling & pump repair,

request for assistance in

next sampling event

Ltr: Summary of decisions fr 5/8/91 meeting w/attch

4/30/91 memo re

geotechnical details for drilling, w/o scope of work for source control

unit

91/05/20 AR 428 004 0280 Kathleen Considine CA Dept of Health

Servi ces


Agency - Region 9

Ltr: Comments on draft groundwater investigation statement of work (SOU)

5/7/91 (Privileged - FOIA

ex 5)

91/05/28 AR 429 004 0282 Steven Linder, Pam

Wieman Environmental Protection

Agency - Region 9

I C F Technology, Inc Groundwater operable unit

scope of work (SOU),

w/WAF 7/16/91


Gamble & Mai lory

Pam Wieman Environmental Protection

Agency - Region 9

Ltr: Preliminary comments

on 6/90 & 10/90 final


rpts w/attch declaration

of Robert Powell 5/28/91

91/05/28 AR 431 004 0353 Cynthia Burch


Gamble & Mai lory

Pam Wieman


TL: Preliminary commends

on 6/90 & 10/90 final groundwater monitoring

rpts w/o declaration of

Robert aPowell 5/28/91

91/05/29 AR 432 004 0355 Steven Linder E V Krinovae WAF, mod #22, for

Page 50

03/01/96



DATE AR # yy/mm/dd



I C F Technology, Inc groundwater RI/FS w/attch SOW 5/28/91 (Privileged -

FOIA ex 4)

91/06/06 AR 433 004 0357 Caroline Rudolph

CA Dept of Health

Services


Ltr: Resolutions re recommendations &

comments on draft groundwater investigation statement of work (SOU)

5/91

91/06/18 AR 434 004 0360 Sharon Lin



#LV1S31 memo #2 RAS/SAS volatiles &

tetrahydrothiophenes in

water col 4/29-5/2/91

w/TL to Steven Linder fr V Taylor 6/20/91

91/07/02 AR 435 004 0376 Roseanne Sakamoto


Addressees


TL: Updated CLP sample

estimates Jun-Sep 1991

w/attch 6/28/91 CLP

estimates

91/07/02 AR 436 004 0396 Donald Clay

Environmental Protection Agency - Office of Solid

Waste & Emergency

Response

Regional Acfcninistrators

Environmental Protection Agency - Regions 1-10

Memo: Supplemental guidance on performing

risk assessments in RI/FSs conducted by PRPs



Data validation rpt Case #LV1S31 memo #3 SAS inorganics in groundwater

col 4/29-5/2/91 w/TL to

Steven Linder fr Victoria Taylor, 7/12/91

91/07/12 AR 438 004 0411 Sripriya Chari




#16299 memo #5 RAS metals in groundwater col 4/29-

5/2/91 w/TL to Steven

Linder fr Victoria Taylor, 7/15/91

91/07/16 AR 439 004 0422 Gail Jones



Agency - Region 9 Data validation rpt SAS

#6209Y memo #4 SAS

chemical 02 demand/total organic carbon in water

col 4/29-5/2/91 w/TL to

Steven Linder fr V

Page 51




CHRONOLOGICAL ORDER

DATE yy/rrm/dd


91/07/25 AR 440

91/07/26 AR 441

004 0431 Robbie Heeden Environmental Protection

Agency - Region 9

004 0437 Caroline Rudolph CA Environmental Protection Agency - Dept of Toxic Substances

Control


Agency -Region 9


Agency - Region 9

Taylor, 7/19/91

Memo: Groundwater sampling to be conducted 8/19-24/91 w/attch table 5.0: Analyses requested, mat r ix=groundwater

Ltr: Geologist comments,

observations & recommendations re groundwater wells w/attch

7/22/91 memo re welt survey to C Rudolph fr K

Considine

91/07/29 AR 442 004

91/07/31 AR 443 004

0446 Steven Linder Environmental Protection

Agency - Region 9

E Krivanec I C F Technology, Inc

WAF rev 1 for groundwater

RI/FS w/attch SOW rev 1 (Privileged - FOIA ex 4)

0448 Steven Linder File Memo: Evaluation of CAL-Envirormental Protection Environmental Protection EPA 7/26/91 comments on

Agency - Region 9 Agency - Region 9 monitoring well condition


91/08/00 AR 444 004 0450 Robbie Hedeen Environmental Protection

Agency - Region 9

Draft groundwater

monitoring rpt 1/91 &

4/91 (Privileged - FOIA

ex 5)

91/08/00 AR 445 004 0452

91/08/05 AR 446

91/08/08 AR 447

004

004


Fact Sheet: U.S. EPA to conduct quarterly

groundwater monitoring,

community contingency

plan revised

0454 Steven Linder Dave Bushey Ltr: Response to concerns

Envirorvnental Protection Fullerton Hills Community re monitoring well P-2D Assn w/attch site & monitoring

well locations map Agency - Region 9

0457 Keith Egan I C F Technology, Inc

Steven Linder Memo: Summary of first

Environmental Protection groundwater monitoring

Agency - Region 9 scoping session 8/7/91 w/attch memo

91/08/08 AR 448 004 0462 Keith Egan I C F Technology, Inc

Steven Linder Memo: Summary of first gw

Environmental Protection monitoring scoping Agency - Region 9 session 8/7/91, info

reauest w/attch meeting

Page 52

03/01/96



DATE AR tt ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT yy/rrm/dd

s urinary

91/08/08 AR 449 004 0467

91/08/19 AR 450 004 0472

Keith Egan I C F Technology, Inc

Keith Egan



Earle Krivanec, et al


Memo: Sunmary of first groundwater monitoring scoping session 8/7/91 w/attch memo re same to Earle Krivanec, et al, fr Keith Egan 8/8/91

Memo: Sunmary of initial scoping session for

quarterly groundwater

monitoring

91/08/22 AR 451 004 0477 Keith Egan

I C F Technology, Inc Steven Linder


Memo: Quarterly


site familiarization

draft sunmary

w/marginalia by Steven Linder (Privileged - FOIA ex 5)

91/08/23 AR 452 004 0479 Well condition inventory form for 8/20/91-8/23/91

(2 pages undated)

91/08/23 AR 453 004 0497 Groundwater purging/sampling logs for

8/20/91-8/23/91

91/08/23 AR 454 004 0519

91/08/27 AR 455 004 0521

Laura Gentile Environmental Protection Agency - Region 9

Earle Krivanec


Environmental Instrumentation Leasing Co

Steven Linder


Procurement request/order for replacement bladder cartridges for field sampling

Ltr: Quarterly gw

monitoring draft workplan

memorandum (WPM) w/attch workplan, org chart,

schedule, OF-60


91/09/00 AR 456 004 0523 I C F Technology, Inc Environmental Protection Agency - Region 9

1st draft SROA ARAR review & update rpt

w/marginalia (pages

missing) (Privileged

FOIA ex 5)

91/09/00 AR 457 004 0525 Robbie Hedeen

Environmental Protection Final groundwater monitoring rpt 1/91 &

Page 53

03/01/96 HcCotl Superfurid Site


CHRONOLOGICAL ORDER

DATE

yy/mm/dd


91/10/00 AR 458 004 0711

91/10/17 AR 459 004 0714

91/10/28 AR 460 004 0716

Agency - Region 9


Agency - Region 9

Lynn Trujillo Environmental Protection Agency - Region 9


IAC Members

4/91 w/appendices

Fact Sheet: Several field

activities scheduled

TL: Final groundwater monitoring rpt 9/91 w/o rpt

Environmental Protection Quarterly gw monitoring Agency - Region 9 final workplan memorandum

w/TL to S Linder fr E Krivanec on 10/28/91,

w/marginalia (Privileged - FOIA ex 5)

91/11/00 AR 461

91/11/04 AR 462

004

004

0718

0720


Earle Krivanec I C F Technology, Inc



ARCSWEST progress rpt RI/FS groundwater w/attch

site specific detail rpt,

labor hours rpt (Privileged - FOIA ex 4)

Ltr: Response to work

task 5 (interim gw sampling) w/attch

schedule, team org chart,

LOE chart, cost proposal


91/11/06 AR 463 004 0722 Keith Egan


Jeff Eppink, et al


Memo: Additional

information for groundwater monitoring

91/11/08 AR 464

91/11/15 AR 465

91/11/21 AR 466

004

004

004

0724

0726

0728



Keith Egan




Agency - Region 9

Steve Linder Environmental Protection

Agency - Region 9

TL: Final groundwater monitoring rpt 9/91 w/o

rpt

Ltr: Concerns re gw sampling - possibility of

biased gw data, suggestions for changes

in sampling methods

(Privilege - FOIA ex 5)

Ltr: Transmittal of

revisions - interim

groundwater sampling / Dr> i v/i I ana/4 • CHTA

91/11/25 AR 467 004 0730 Keith Egan Steve Linder Ltr: Clarifies previous

Page 54

03/01/96



DATE AR # yy/mm/dd



Itrs re sampling (Privileged - FOIA ex 5)


Agenda for groundwater sampling final pre-sampling meeting w/FAX

cover sheet to Steven Linder fr Jeff Eppink,

11/26/91

91/11/27 AR 469 004 0735 Earle Krivanec I C F Technology, Inc

Steven Linder


Ltr: Final workplan

memorandum (WPM) for

quarterly groundwater

monitoring w/attch plan w/attchs (Privileged -

FOIA ex 4)


Final groundwater monitoring rpt


Steven Linder


Ltr: Groundwater sampling

event summary w/attch

summary, costs, logbook

entries 12/2-6/91, gw purging/sampling logs

91/12/23 AR 472 004 0946 Cynthia Burch


Gamble & Mai lory

Pam Uieman


Agency - Region 9

Ltr: Comments on final


rpts 1/91 & 4/91 w/attch

declaration of Robert

Powell 12/20/91



Ltr: Request for

documents to complete groundwater monitoring

rpt

92/00/00 AR 474 004 0961 Rationale for using ICF

San Francisco personnel for groundwater sampling (Privilege - FOIA ex 5)

92/00/00 AR 475 004 0963 Keith Egan


Handwritten notes:

Groundwater sampling meeting

92/01/00 AR 476 004 0966 I C F Technology, Inc Steven Linder Environmental Protection Agency - Region 9

Draft workplan groundwater monitoring/site maintenance w/attch

Page 55



CHRONOLOGICAL ORDER

DATE

yy/mm/dd



schedule of tasks (Privileged - FOIA ex 4 &

5)

Draft gw workplan,

s e c t i o n s 3 - 5 w/marginalia, FAX cover sheet to S Linder fr K Egan, 1/30/92 (Privileged

- FOIA ex 5)

92/01/17 AR 478 004 0970

92/01/24 AR 479 004 0979


Jeff Eppink I C F Technology, Inc

Rob Stern Memo: 7-point Environmental Protection justifications for

Agency - Region 9


equipment for groundwater

sampling w/attchs

Memo: Justification for

gw sampling manpower requirements w/marginalia

(Note to "Steve" fr "Keith") (Privileged -

FOIA ex 5)

92/01/27 AR 480 004 0981 Jeri Simmons Earle Krivanec Environmental Protection I C F Technology, Inc

Agency - Region 9

Ltr: Comments on draft gw

workplan 1/92 w/attch comments, LOE spreadsheet






Environmental Protection Data validation rpt: Case

Agency - Region 9 #SAS 6618Y, memo #04, analyses - total organic carbon & chemical oxygen

demand, w/TL to S Linder

fr V Taylor 1/29/92

Draft workplan gw

monitoring/site

maintenance w/attch draft

schedule of tasks (Privileged - FOIA ex 4 &

5)

Steven Linder Ltr: Draft workplan for

Environmental Protection quarterly groundwater Agency - Region 9 monitoring for review w/o

attch workplan

Environmental Protection Final groundwater

Agency - Region 9 monitoring rpt


Agency - Region 9

Page 56

03/01/96





Draft workplan for RI gw monitoring & site

maintenance, w/ltr to S Linder fr A Ng transmitting same 4/13/92 (Privileged - FOIA ex 4 & 5)

92/03/00 AR 486 004 1198 Environmental Protection

Agency - Region 9 Fact Sheet: U.S. EPA to conduct quarterly McColl groundwater monitoring

92/03/03 AR 487 004 1201 Keith Egan

I C F Technology, Inc Sampling Team


Memo: Quarterly


meeting w/attch 3/92 groundwater sampling

schedule


Data validation rpts: Case #LV2S18, memo #s1,3

& 4, analyses - RAS & SAS, w/TLs to S Linder fr

V Taylor 3/11/92-3/12/92


Data validation rpt: Case #17520, memo #05,

analyses - RAS metals,

w/TL to S Linder fr V

Taylor 3/13/92

92/03/19 AR 490 004 1255 I C F Technology, Inc Proposed revisions for interim groundwater sampling plan w/FAX cover sheet to Steven Linder fr

Keith Egan, 3/19/92

92/03/28 AR 491 004 1260 Jeri Simmons



Ltr: Comments on 3/6/92 gw workplan with marginalia (Privileged -FOIA ex 5)

92/04/00 AR 492 004 1262 Robbie Hedeen


Final gw monitoring rpt

92/04/00 AR 493 004 1379 I C F Technology, Inc Steven Linder


Final workplan for

remedial investigation

gw monitoring & site maintenance

Page 57




CHRONOLOGICAL ORDER

DATE yy/irm/dd

AR it ROLL # FRAME it AUTHOR ADDRESSEE SUBJECT


Cost estimate for gw

monitoring & site maintenance (Privileged FOIA ex 4)

92/04/02 AR 495 004 1407

92/04/21 AR 496

92/04/22 AR 497

004

004

1432

1434

Bicka Barlow I C F Technology, Inc

Adam Ng I C F Technology, Inc



Agency - Region 9

Memo: Sampling rpt for 3/92 gw sampling event, w/sampling logs & logbooks (Redacted - FOIA

ex 6)

TL: Draft quarterly gw monitoring rpt for 12/91

Table 3-2 - Inorganic

chemicals detected in soil & waste at site,

1992

92/05/18 AR 498 004 1436 Steven Linder Adam Ng

Environmental Protection I C F Technology, Inc

Agency - Region 9

Ltr: Comments on draft gw

monitoring rpt for 12/91

sampling event (Privileged - FOIA ex 5)

92/05/22 AR 499

92/05/22 AR 500

004 1438 Steven Linder Environmental Protection Agency - Region 9

004 1440 Steven Linder Environmental Protection

Agency - Region 9

Caroline Rudolph

CA Environmental Protection Agency - Dept

of Toxic Substances

Control

Kent Kitchingman


Agency - Region 9

Ltr: Request for review

of field sampling plan (FSP) & quality assurance project plan (QAPjP) -

transmits same, w/o encls

Memo: Request for review

of sampling and analysis

plan (SAP) & quality

assurance project plan

(QAPjP)

92/06/10 AR 501

92/06/23 AR 502

004 1442 Robbie Hedeen Environmental Protection

Agency - Quality

Assurance Management

Section

004 1444 William Duchie McColl Site Group


Agency - Region 9


Agency - Region 9

Memo: Comments on gw sampling plan (Privileged

- FOIA ex 5)

Ltr: Comments on final gw

monitoring rpt 8/91

92/07/00 AR 503 004 1447 1 C F Technology, Inc Environmental Protection Final groundwater Agency - Region 9 monitoring rpt

Page 58

03/01/96



DATE AR # yy/mm/dd


92/07/13 AR 504 004 1605 -Robbie Hedeen Environmental Protection Agency - Region 9


Memo: Review & approval of revised gw sampling plan (SAP), w/approval form & rtg slips to S

Linder fr R Hedeen 7/14/92


Interim final quality assurance project plan (QAPjPj for gw sampling,

w/ltr & TL to S Linder fr

A Ng 8/7/92

92/08/21 AR 506 004 1673 Steve Reynolds Steve Gaytan


of Toxic Substances

Control

Memo: Analysis of

geophysical & video logs fr well P2D (Privilege -

FOIA ex 5)


CA Environmental

Protection Agency - Dept

of Toxic Substances

Control

Steven Linder


Agency - Region 9

Ltr: Transmits comments

on final workplan RI gw

monitoring & site

maintenance 4/92 & draft sampling plan 5/92,

w/attchs (Privileged -

FOIA ex 5)


Draft well

abandonment/mai ntenance rpt, w/TL to S Linder fr A Ng 9/14/92



#18516-9, memo #07, analyses - RAS total

metals, w/TL to S Linder

fr M Weiner 10/1/92



of Toxic Substances Control


Ltr: Transmits comments on 10/92 draft gw OU data

evaluation rpt to C

Rudolph fr K Considine 11/16/92, w/encl (Privileged - FOIA ex 5)


Final groundwater

monitoring rpt

92/12/09 AR 512 004 1851 Adam Ng


Steven Linder Ltr: Well recommendations

Environmental Protection for quarterly gw sampling

Page 59

03/01/96 HcColI Superfund Site



CHRONOLOGICAL ORDER

DATE AR # ROLL # FRAME # AUTHOR

yy/rtm/dd

92/12/14 AR 513 004 1854 Gary Jensen I C F Technology, Inc

92/12/29 AR 514 004 ]856 I C F Technology, Inc


93/01/25 AR 516 004 1942 Ian Jensen I C F Technology, Inc


ADDRESSEE SUBJECT

Agency - Region 9 event 12/92

Steven Linder Memo: Quarterly gu Environmental Protection sampling event 12/92 Agency - Region 9 (Privileged - FOIA ex 5)

Environmental Protection Site well information Agency - Region 9 rpt, w/FAX TL to S Linder

fr G Sato 12/29/92

Steven Linder TL: Draft gw monitoring

Environmental Protection reporting for 7/92 Agency - Region 9 quarterly sampling event

Envirormental Protection Data validation rpt: SAS Agency - Region 9 LV3S13, memo #4, 9 water

samples collected 12/8-9/92, w/TL to S Linder fr

C Studeny 1/28/93

Environmental Protection Data validation rpts: SAS Agency - Region 9 #LV3S13, memo #s 1-3, 9

groundwater samples

collected 12/8-9/92,

w/TLs to S Linder fr ICF

1/7/93-2/4/93

93/02/08 AR 518 004 1996 I C F Technology, Inc Table showing gw concentrations of

concern, w/FAX TL to S

Linder fr A Ng 3/9/93

93/02/09 AR 519 004 2001 I C F Technology, Inc Environmental Protection Data validation rpt: SAS

Agency - Region 9 #7669Y, memo # 6, SY4071-SY4079 collected 12/9/92, w/TL to S Linder fr V Tawl/tr ?/in/0^

93/02/17 AR 520 004 2010 Robert Landreth Steven Linder Memo: Review of cap

Environmental Protection Environmental Protection design & recommendation Agency - Waste Agency - Region 9 for geosynthetic material

Minimization, Destruction

& Disposal Research

Division

93/02/19 AR 521 004 2013 I C F Technology, Inc Environmental Protection

Agency - Region 9

Data validation rpt: SAS

LV3S13, memo #7, 9 water

samples collected 12/8-9/92, w/TL to S Linder fr

M Weiner 2/22/93

Page 60

03/01/96



DATE yy/rmi/dd


93/03/23 AR 522 004 2023 Adam Ng Steven Linder I C F Technology, Inc Environmental Protection

Agency - Region 9

Ltr: Transmits final gw data evaluation & recommendations rpt, w/o

encl

93/05/00 AR 523 004

93/05/00 AR 524 004

2026 I C F Technology, Inc




Agency - Region 9

Groundwater operable unit - data evaluation & recommendations final rpt

Final gw monitoring rpt,

12/91, rev 1,

w/handwritten post-it

note

93/06/00 AR 525 004 2350 I C F Technology, Inc Environmental Protection

Agency - Region 9 Final gw monitoring rpt,

7/92


Cumulative index to

Administrative Record of 11/88, updated 12/91, 8/92 & 6/93

93/06/14 AR 527 005 0316 Pam Uieman Ian Webster

Environmental Protection Unocal Corp Agency - Region 9

Ltr: Request for comments

on "groundwater operable

unit data evaluation &

recommendation rpt" -

transmits same, w/o encl

93/06/15 AR 528 005 0318 Pam Uieman Charles McAuley

Environmental Protection McAuley LCX Corp Agency - Region 9

TL: Groundwater operable

unit data evaluation &

recommendations final rpt 5/93

93/06/17 AR 529 005 0320 Gary Jensen Pam Uieman I C F Technology, Inc Environmental Protection'

Agency - Region 9

TL: Final groundwater monitoring rpts 12/91, 3/92 & 7/92

93/06/21 AR 530 005 0322 Pam Uieman David Bushey, resident

Environmental Protection City of Fullerton Agency - Region 9


monitoring rpts 12/91,

3/92 & 7/92

93/06/21 AR 531 005 0324 Pam Uieman Charles McAuley

Environmental Protection McAuley LCX Corp

Agency - Region 9


monitoring rpts 12/91, 3/92 & 7/92

93/06/21 AR 532 005 0326 Pam Uieman Frank Hamamura

Environmental Protection CA Dept of Health

Agency - Region 9 Services - Office of Drinking Water


monitoring rpts 12/91,

3/92 & 7/92

Page 61

03/01/96



CHRONOLOGICAL ORDER

DATE AR # yy/mm/dd


93/06/21 AR 533 005 0328 Pam Uieman Environmental Protection Agency - Region 9

93/06/21 AR 534 005 0330

93/06/21 AR 535 005 0332

93/06/21 AR 536 005 0334

93/06/21 AR 537 005 0336

93/07/01 AR 538 005 0338

93/07/08 AR 539 005 0340


Barry Eaton

City of Fullerton

Nabil Henien City of Buena Park


TL: Final groundwater monitoring rpts 12/91,

3/92 & 7/92

Pam Uieman Kurt Berchtold TL: Final groundwater Environmental Protection Santa Ana Regional Uater monitoring rpts 12/91, Agency - Region 9 Quality Control Board 3/92 & 7/92



Agency - Region 9

Robert Allen Orange County - Dept of Environmental Health


Pam Uieman Joanne Hardy Environmental Protection City of Fullerton Agency - Region 9 Public Library

Jeff Zelikson


Agency - Region 9

Ramon Lopez

Shell Oil Co

TL: Final groundwater monitoring rpts 12/91,

3/92 & 7/92



monitoring rpts 12/91, 3/92 & 7/92

Ltr: EPA decision not to

use special notice

procedures - transmits

ROD & "Administrative order for RD & other

response actions," w/o

encls

93/07/08 AR 540 005 0343 Jeff Zelikson


Charles McAuley

McAuley LCX Corp

Ltr: EPA decision not to

use special notice procedures - transmits

R00 & "Administrative order for RD & other

response actions," w/o

encls

93/07/19 AR 541 005 0346 Gary Jensen I C F Technology, Inc


Agency - Region 9

TL: Final groundwater monitoring rpt 12/92

93/07/20 AR 542 005 0348 John Uise Rand Schulman

Environmental Protection Shell Oil Co

Agency - Region 9

Ltr: Response to concerns

re orders for RD &

protocol for site

specific issues

93/07/20 AR 543 005 0350 John Uise Rand Shulman Ltr: PRP compliance with

Page 62

03/01/96



DATE AR # yy/mm/dd



Shell Oil Co administrative orders (AOCs) for RD

93/07/21 AR 544 005 0352 Rand Shulman, et al

Shell Oil Co


Ltr: Notice of Oil Co respondents intent to comply with AO for RD & other response actions dated 7/8/93, w/project coordinator resume (RD start)

93/07/21 AR 545 005 0360 Cynthia Burch


Gregory Ritter


Ltr: Transmits materials

distributed at 7/20/93

conference re administrative order for

RD & other response

actions, w/attchs

93/07/21 AR 546 005 0367 Jeff Zelikson Environmental Protection

Agency - Region 9

Shell Oil Co, et al Amendment to administrative order for RD & other response

actions

93/07/22 AR 547 005 0389 Caroline Rudolph CA Environmental Protection Agency - Dept of Toxic Substances

Control


Ltr: Comments on final groundwater operable unit data evaluation &

recommendations rpt, w/attch (Privileged -

FOIA ex 5)

93/07/26 AR 548 005 0391 John Blevins Environmental Protection

Agency - Region 9

William Duchie

McColl Site Group

Memo: Modification #2 to

attachments 1-3 of

unilateral administrative order (UAO), w/attchs

93/07/27 AR 549 005 0408 Pam Uieman Environmental Protection Agency - Region 9

Chris Meyer

City of Fullerton


monitoring rpt 12/92

93/07/27 AR 550 005 0410 Pam Wieman Environmental Protection Agency - Region 9

Nabil Henein City of Buena Park


93/07/27 AR 551 005 0412

93/07/27 AR 552 005 0414

Pam Wieman

Envi ronmentaI Protect i on

Agency - Region 9

Pam Wieman


Barry Eaton

City of Fullerton

William Duchie, resident

City of Fullerton





Page 63





yy/mm/dd

93/07/27 AR 553

93/07/27 AR 554

93/07/27 AR 555

93/07/27 AR 556

93/07/27 AR 557

93/08/04 AR 558

93/08/04 AR 559

93/08/12 AR 560

93/08/12 AR 561

005

005

005

005

0416 Pam Wieman Environmental Protection Agency - Region 9

0418 Pam Uieman Environmental Protection

Agency - Region 9

0422

005

005

005

005

005

0424

0426

0434

0458

93/08/16 AR 562 005

Ted Commerdinger City of Fullerton

David Bushey, resident

City of Fullerton

0420 Pam Uieman Robert Allen Environmental Protection Orange County - Dept of Agency - Region 9 Environmental Health

Pam Uieman Caroline Rudolph Environmental Protection CA Environmental Agency - Region 9 Protection Agency - Dept

of Toxic Substances

Control

Pam Wieman Environmental Protection

Agency - Region 9

Uilliam Duchie McColl Site Group

William Duchie McColl Site Group








John Blevins -Environmental Protection

Agency - Region 9


Agency - Region 9

0436 McColl Site Group

John Blevins

Ltr: Transmits

communication &

coordination plan, w/encl

TL: Draft project

management plan & computer disk containing

text/project schedule

Draft tetrahydrothiophene

(THT) control ltr rpt,

w/TL to J Blevins fr W

Duchie 8/12/93

Ltr: Perched water sample Caroline Rudolph CA Environmental Environmental Protection results fr sump L-4 -Protection Agency - Dept Agency - Region 9 transmits laboratory rpt

of Toxic Substances re same, w/encl

Control

0472 Cynthia Burch Allen, Matkins, Leek,

Gamble & Mai lory

Gregory Ritter Environmental Protection

Agency - Region 9

Ltr: Response to Itrs re

certification of

administrative record &

deadline for additions -

transmits list of supplemental docs for

1984 ROD, w/encl

Page 64

03/01/96




DATE AR # yy/mm/dd


93/08/20 AR 563 005 0495 Cynthia Burch Allen, Matkins, Leek, Gamble & Mai lory

Gregory Ritter Environmental Protection Agency - Region 9

Ltr: Further to Itrs re addition of documents to administrative record -transmits list of additions 8/20/93, w/encl


Ann Cornel Morrison-Knudsen Corp

TL: Site safety plan

93/08/27 AR 565 005 0534 ENVIRON Corp Environmental Protection Draft routine gw

Agency - Region 9 monitoring analysis &

recommendation rpt

93/09/23 AR 566 005 0582

93/09/28 AR 567 005 0584

John Blevins Robert Allen Environmental Protection Orange County - Dept of Agency - Region 9

John Blevins


Environmental Health

William Duchie

Shell Oil Co

TL: Final ltr rpt 9/10/93

Ltr: Comments on draft

routine groundwater

monitoring analysis &

recommendation rpt,

w/attch


CA Environmental



John Blevins


Ltr: Comments on draft

routine groundwater

monitoring analysis &

recommendation rpt 8/27/93, w/attch (Privileged - FOIA ex 5)

93/10/04 AR 569 005 0592 William Duchie McColl Site Group


Agency - Region 9

Ltr: Draft groundwater RI/FS workplan -

transmits same, w/o encl

93/10/13 AR 570 005 0594 Michael Montgomery William Duchie

Environmental Protection McColl Site Group

Agency - Region 9

Ltr: Mtgs, progress &

resolution of issues for

tasks 2 & 3 & task 11

deliverables

93/10/19 AR 571 005 0597 Environ Corp McColl Site Group Routine groundwater

monitoring analysi s/recommendat ions rpt & workplan, w/TL to J Blevins fr W Duchie

10/19/93

93/10/19 AR 572 005 0776 William Duchie McColl Site Group


Ltr: "Routine groundwater monitoring analysis &

recommendations rpt" & draft groundwater

Page 65

03/01/96



CHRONOLOGICAL ORDER


yy/mm/dd

monitoring workplan transmits same, w/o attchs


Fact sheet: EPA to perform work on monitoring wells

93/11/04 AR 574 005 0781 Michael Montgomery Environmental Protection Agency - Region 9

Uilliam Duchie McColl Site Group

Ltr: Transmits list of deliverables appropriate

for IAC & FHCA distribution, FHCA request for documents 8/16/93 & revised draft

task sched, w/attchs

93/11/16 AR 575 005 0788 Michael Montgomery Environmental Protection

Agency - Region 9

William Duchie

McColl Site Group

Ltr: Transmits EPA

comments on draft sumps

rpt & final work plans, state comments on rpts for removals & EPA comments on draft gw workplan, w/attchs

93/12/03 AR 576 005 0803

93/12/10 AR 577 005 0806

94/00/00 AR 578 005 0809

William Duchie

McColl Site Group

Robert Merryman Orange County - Dept of

Environmental Health

Thermo Analytical, Inc

Michael Montgomery Ltr: Revisions to draft

Environmental Protection groundwater RI/FS

Agency - Region 9

William Duchie

Shell Oil Co

workplan

Ltr: Well permits

required prior to work on

monitoring wells by MSG

contractors

Detection limit study

1994, task 10, w/TL fr K Rogers to M Wolfram

9/8/94



Agency - Region 9

Ltr: Conditional approval

of draft groundwater

RI/FS workplan -

transmits EPA & State

comments re same,

w/attchs



Agency - Region 9

Ltr: Conditional approval

of draft groundwater

RI/FS workplan -transmits EPA & State

comments re same,

Page 66

03/01/96



CHRONOLOGICAL ORDER


yy/mm/dd

w/attchs w/marginalia

94/02/04 AR 581

94/02/04 AR 582

94/03/16 AR 583

94/04/04 AR 584

94/04/08 AR 585

94/04/12 AR 586

94/05/02 AR 587

94/05/11 AR 588

94/05/13 AR 589

94/05/17 AR 590

005

005

005

005

005

005

005

005

005

005

0902 William Duchie McColl Site Group

0974 ENVIRON Corp

1040

1042

1095

William Duchie

McColl Site Group

Michael Montgomery Environmental Protection Agency - Region 9


Michael Montgomery


Ltr: Groundwater RI/FS workplan - transmits errata sheets re same,

w/encl

GW RI/FS workplan

Ltr: Task 10, phase 1

drilling schedule

1045 ENVIRON Corp

Results of CPT borings

3/24/94 to 4/4/94

Map: Preliminary BAT

sampling locations, phase 1 groundwater RI/FS,

w/marginalia

Ltr: Response to deliverables & MSG

requests, w/attchs

Caroline Rudolph Michael Montgomery Ltr: Transmits Dept of CA Envirormental Environmental Protection Toxic Substances Control

Protection Agency - Dept Agency - Region 9 (DTSC) draft comments on

of Toxic Substances remedial design docs,

Control w/attchs

Kent Rogers


Agency - Region 9

1048 Michael Montgomery

1056

David Harnish ENVIRON Corp

1105 ENVIRON Corp

1285 Kent Rogers

McColl Site Group

Verne Trinoskey Morrison-Knudsen Corp


Agency - Region 9

Michael Montgomery Environmental Protection

Agency - Region 9

Ltr: Field work summary, Phase I gw RI/FS, w/map & TL to M Montgomery fr K

rogers 5/12/94

Routine groundwater

monitoring anaIys i s/recommendst i ons

rpt & workplan, final

Ltr: Transmits Final

routine gw monitoring

ana I ys i s/ recommenda t i ons

rpt & workplan, w/o

attchs

94/05/19 AR 591 005 1288 ENVIRON Corp Environmental Protection Draft of phase I rpt, Agency - Region 9 task 10 - GW RI

Page 67




DATE

yy/mm/dd


94/05/19 AR 592 005

94/05/25 AR 593 005

94/06/06 AR 594 005

1589 Kent Rogers McColl Site Group

1591 Kathleen Considine CA Environmental Protection Agency - Dept of Toxic Substances

Control•

1593 Michael Montgomery Environmental Protection

Agency - Region 9

94/06/13 AR 595 005 1620 ENVIRON Corp


Caroline Rudolph CA Environmental Protection Agency - Dept of Toxic Substances

Control

Kent Rogers

Shell Oil Co

94/07/15 AR 596 005

94/07/20 AR 597 005

1624

1626


Agency - Region 9

Heidi Hansen CA Environmental


of Toxic Substances

Control

94/07/21 AR 598 005

94/08/04 • AR 599 005

94/08/05 AR 600 005

1631

1633

1638

Michael Montgomery


Agency - Region 9

Michael Wolfram Environmental Protection

Agency - Region 9

Kent Rogers McColl Superfund Site


Agency - Region-9

TL: Task 10, draft phase 1 rpt prepared by ENVIRON Corporation

Memo: DTSC review of

Final routine gw monitoring analysis rpt & workplan 5/13/94, w/TL to

M Montgomery fr K Considine (Privileged -

FOIA ex 5)

Ltr:Transmits EPA & DTSC comments re Draft phase I gw RI rpt,design rpt for air treatment system &

table for test method

identificati ion, w/marginalia

Map: Proposed pilot boring monitoring well &

neutron log access tube

locations, w/TL fr K Roger to M Wolfram

1/25/95

Mtg agenda: Risk assessment mtg, w/attchs

w/marginalia (Privileged

- FOIA ex 5)

Memo: Minutes of 7/11/94

interagency committee mtg, w/agenda for 8/22/94

mtg

Questions posed fr

previous R/A mtg

Handwritten notes: Mtg

with ICF-Kaiser re project oversight, action

items, location of wells

Ltr: Transmits Response

to agency comments on

Phase I rpt, task 10 - GW

RI

Page 68

03/01/96



CHRONOLOGICAL ORDER

DATE yy/mm/dd


94/08/18 AR 601 005 1677 David Bushey Resident --Fullerton Hills Community Assn

Memo: 8/23/94 community update mtg with agenda

94/10/12 AR 602 005

94/10/12 AR 603 005

94/10/13 AR 604 005

1679 Thermo Analytical, Inc ENVIRON Corp


1683 ENVIRON Corp

1st quarter sampling period 1994 gw laboratory data, case #09-028, v1 '

1st quarter sampling period 1994 gw laboratory

data, case #09-028, v2

1st quarter sampling

period 1994 gw laboratory

data, case #09-039 & 09-040, v1

94/10/19 AR 605 005 1685 ENVIRON Corp Environmental Protection

Agency - Region 9 Preliminary chemical test

results summary tables fr Phase II gw RI, task 10,

w/TL fr K Rogers to M

Wolfram

94/10/27 AR 606 005 1720 ENVIRON Corp 1st quarter sampling

period 1994 gw laboratory

data, case #09-039 & 09-

040, v2

94/11/01 AR 607 005 1722 Kent Rogers

McColl Site Group Michael Wolfram Ltr: Transmits waste

Environmental Protection analytical results, Agency - Region 9 w/attchs

95/00/00 AR 608 005 1740 ENVIRON Corp

95/00/00 AR 609 005 1742 ENVIRON Corp

4th quarter sampling period (1995), groundwater laboratory data, work order #L2403,

w/TL to V Trinoskey fr W

Ang 9/26/95

4th quarter sampling period (1995), gw

laboratory data, metals & general chemistry work order #L2221, L2227 &

L2229, w/TL to D Liu fr N

Roth 8/23/95

95/00/00 AR 610 005 1744 ENVIRON Corp 4th quarter sampling

period (1995), gw

laboratory data, organics

Page 69



DATE yy/mm/dd


95/01/17 AR 611 005 1746 Thermo Analytical, Inc Terra Tech Labs, Inc

work order #L2221, L2227

& L2229, w/TL to D Liu fr N Roth 8/18/95

1st quarter sampling period 1994 gw lab data,

case #12-002, v1 of 2 -results of analyses for

general chemistry & organics

95/01/17 AR 612 005 1748 Thermo Analytical, Inc Terra Tech Labs, Inc 1st quarter sampling period 1994 gw lab data, case #12-002, v2 of 2 -results of analyses for

general chemistry & organics

95/03/02 AR 613 005

95/03/02 AR 614 005

95/03/10 AR 615 005

95/03/13 AR 616 005

95/03/14 AR 617 005

95/03/15 AR 618 005

1750 ENVIRON Corp



1950 Charles McAuley McAuley LCX Corp

1952


Michael Uolfram Environmental Protection

Agency - Region 9

Michael Uolfram


Agency - Region 9


Agency - Region 9

1955 Thermo Analytical, Inc Tetra Tech, Inc

95/03/15 AR 619 005 1957 Thermo Analytical, Inc Tetra Tech, Inc

Quarterly gw monitoring rpt, 1st quarter sampling period (1994)

TL: Final 1st quarter sampling period 1994 rpt

TL: Final test results

for 2nd quarter gw

samples

Ltr: Planning for possible water damage

Mtg agenda: Task 10 gw

RI/FS, w/roster

2nd quarter sampling

period 1995 groundwater

lab data, case #01-022, v1 of 1 - data validation

rpt for 3 water samples

analyzed for organics

2nd quarter sampling


lab data, case #01-033,

v1 of 1 - data validation rpt for 5 water samples

analyzed for TCL organics

Page 70

03/01/96




95/03/15 AR 620 005 1959 Thermo Analytical, Inc Tetra Tech, Inc 2nd quarter sampling period 1995 groundwater

lab data, case #01-036, vl of 1 - data validation rpt for 15 water samples analyzed for dissolved metals



vl of 1 - data validation rpt for 20 water samples

analyzed for total metals

95/03/15 AR 622 005 1963 Thermo Analytical, Inc Tetra Tech, Inc 2nd quarter sampling



vl of 1 - data validation rpt for 14 water samples analyzed for TCL organics


lab data, case #01-051, v1 of 1 - data validation

rpt for 5 water samples

analyzed for TCL organics


period 1995 groundwater lab data, case #01-051 &

TOC results, v1 of 1 -data validation rpt


period 1995 gw lab data,

case #01-024 & 025, v1 of

1 - data validation rpt

for 10 water samples

analyzed for dissolved

metals



case #01-029, v1 of 2 -data validation rpt for 8 water samples analyzed

for TCL organics

Page 71



CHRONOLOGICAL ORDER

DATE yy/mm/dd


95/03/15 AR 627 005 1973 Thermo Analytical, Inc Tetra Tech, Inc

95/03/15 AR 628 005

95/03/24 AR 629 005

95/03/30 AR 630 005

95/03/31 AR 631 005

95/03/31 AR 632 005

95/04/05 AR 633 005

1975 K Rogers McColl Site Group

1977 Melitta Rorty I C F Technology, Inc

1995 Richard Bauer Environmental Protection Agency - Region 9

1999 Melitta Rorty I C F Technology, Inc

2017 Richard Bauer Environmental Protection

Agency - Region 9


Michael Wolfram Environmental Protection Agency - Region 9



Agency - Region 9



Agency - Region 9

2nd quarter sampling period 1995 gw lab data, case #01-029, v2 of 2 -data validation rpt for 8

water samples analyzed for TCL organics

TL: 2nd quarter sampling


analytical data

Ltr: Transmits Draft FSP for gw split sampling

activities, w/attch

Memo: Comments on FSP for

gw split sampling activities

Ltr: Transmits final FSP

for gw split sampling

activities, w/attch

Memo: Comments on rev FSP

for gw split sampling

activities

Weekly field oversight

rpt gw OU, 4/4/95 -

4/5/95

95/04/06 AR 634 005 2023

95/04/06 AR 635 005 2032

Marina West Orange County - Water

District

Mir Fattahi City of Fullerton -

Engineering & Community

Development Dept

Ltr: Request to access

Coyote 12A well for gw

sampling, w/attchs

w/marginalia

Mtg agenda: Groundwater

briefing, w/marginalia &

attchs (Privileged - FOIA

ex 5)

95/04/07 AR 636 005

95/04/11 AR 637 005

2034 Marina West Orange County - Water

District

2104 Melitta Rorty Davd Harnish I C F Technology, Inc ENVIRON Corp

Memo: Transmits Coyote 12A well data, w/attchs

w/marginalia

Ltr: Transmits gamma logs

for wells W-4 & W-8B, w/o

95/04/12 AR 638 005 2106 Charles McAuley Michael Wolfram Ltr: Reporting of Well

Page 72

03/01/96



DATE AR # ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT yy/nfn/dd

95/04/13 AR 639

95/04/14 AR 640

95/04/20 AR 641

McAuley LCX Corp

005 2109 Richard Bauer Environmental Protection Agency - Region 9

005 '2111 Richard Bauer


005 2113 Kent Rogers

McColl Site Group



Michael Wolfram


Michael Wolfram


P10 info & request to reclassify well as

perched water

Memo: Request for duplicate rather than

quadruplicate analysis of total organic carbon

split samples

Memo: Duplicate rather

than quaduplicate total organic carbon analysis

on split samples fr 4/95 gw sampling

Ltr: Transmits gw QC

sample list for 2nd

quarter sampling period 1995, w/attch

95/04/20 AR 642 005 2116 Kent Rogers

McColl Site Group

Michael Wolfram


Ltr: Transmits gw QC

sample list for 2nd quarter sampling period

1995, w/attch & fax TL to

M Wolfram fr A Mair

95/04/27 AR 643 005 2120 ENVIRON Corp Environmental Protection Agency - Region 9

Quarterly gw monitoring

rpt, 2nd quarter sampling period (1995), w/TL fr K

Rogers to M Wolfram

95/04/27 AR 644 005 2305 ENVIRON Corp McColl Site Group Rev summary tables for monitoring rpt, 2nd

quarter sampling period

1995, w/TL to M Wolfram

fr K Rogers 6/30/95

95/04/27 AR 645 005

95/05/08 AR 646 005

95/05/09 AR 647 005


2391 ENVIRON Corp

2424 Melitta Rorty





Ltr: Transmits final 2nd quarter sampling period

1995 rpt, w/o attch

Supplemental workplan gw

RI/FS, w/TL fr K Rogers

to M Wolfram

Memo: Review of 2nd quarter gw monitoring rpt

Page 73



CHRONOLOGICAL ORDER

DATE yy/imi/dd


95/05/10 AR 648 005 2427 Dina David I C F Kaiser Engineers,

Inc


Data validation rpt: Case #01-044, memo #03B, volatiles & semivolatiles for 26 water samples,

collected 1/19-1/20/95,

w/TL to M Wolfram fr M

Ueiner

95/05/10 AR 649 005

95/05/11 AR 650 005

2476 ENVIRON Corp

2482


Response to EPA technical rev comments, task 10 gw

RI/FS supplemental

workplan

Mtg minutes: Technical mtg, task 10, phase II gu RI, w/mtg agenda & roster

95/05/12 AR 651 005 2488 Mike Mcintosh I C F Kaiser Engineers,

Inc


Agency - Region 9

Quality assurance review

rpt. Case #950131, memo #02, total organic carbon

for 34 water samples, collected 1/12-1/23/95, w/TL to M Wolfram fr M

Weiner

95/05/12 AR 652 005 2498 Michael Mcintosh I C F Kaiser Engineers,

Inc


#R95S47, memo #03, Total

dissolved solids for 9 water samples, collected

4/4/95-4/5/95, w/TL to M

Wolfram fr M Weiner

95/05/15 AR 653 005 2505 Dina David I C F Kaiser Engineers,

Inc


Agency - Region 9


#01-044, memo #03A, various analyses for 12

water samples, collected

1/19,20823/95, w/TL to M

Wolfram fr M Weiner

95/05/15 AR 654 005 2523 Raimi Qui ton I C F Kaiser Engineers,

Inc


Agency - Region 9


#01-029, memo #05A,

various analyses for 7

water samples, collected

1/16&17/95, w/TL to M

Wolfram fr M Weiner

95/05/15 AR 655 005 2541 Raimi Qui ton I C F Kaiser Engineers,

Inc


Agency - Region 9


#01-029, memo #05B, volatiles & semivolatiles

for 8 water samples.

Page 74

03/01/96




yy/rrm/dd

collected 1/16/95, w/TL to M Wolfram fr M Weiner

95/05/15 AR 656 005 2567 Kathleen Considine CA Environmental Protection Agency - Dept of Toxic Substances Control

Caroline Rudolph CA Environmental Protection Agency - Dept of Toxic Substances Control

Memo: Comments on 2nd quarter 1995 gw monitoring rpt, w/TL to M Wolfram fr K Considine w/handwritten note

95/05/15 AR 657 005 2572 Kathleen Considine


of Toxic Substances

Control

Caroline Rudolph



Memo: Comments on 2nd

quarter 1995 gw monitoring rpt

95/05/15 AR 658 005 2576 Margie Weiner


Michael Wolfram


Agency - Region 9

Memo: Transmits

unvalidated data & data

reporting qualifiers for

metals data, case #23421, memo #01, w/attchs

95/05/19 AR 659 005 2582 Heidi Hansen CA Environmental Protection Agency - Dept of Toxic Substances

Control

McColl Interagency

Commi ttee

Memo: Minutes of interagency committee mtg, w/agenda for 6/14/95

mtg



Agency - Region 9

Memo: Transmits

unvalidated data & data

reporting qualifiers for

semivolatiles data, case

#R95S47, memo #05,

w/attchs

95/05/22 AR 661 005 2593 Kent Rogers McColl Site Group


Agency - Region 9

Ltr: Confirmation of telephone agreement of

5/17/95 to extend submittal date for gw development & screening of remedial alternatives

until 5/26/95

95/05/23 AR 662 005 2595 Melitta Rorty I C F Technology, Inc


Memo: Review of 5/10/95 Supplemental workplan, gw

RI/FS


Agency - Region 9

Development & screening

of remedial alternatives,

gw RI/FS

Page 75

03/01/96 McColl Superfond Site



CHRONOLOGICAL ORDER

DATE yy/mm/dd


95/05/25 AR 664 005 2678

95/05/26 AR 665 005 2680

Kent Rogers McColl Site Group

Mike Mcintosh I C F Kaiser Engineers,

Inc



Ltr: Transmits Development & screening of remedial alternatives rpt, w/o attch

Data validation rpt: Ca6e #A501036, memo #01, disssolved metals for 15 water samples, collected 1/18,19,20823/95, w/TL to

M Wolfram fr M Weiner

95/05/26 AR 666

95/05/26 AR 667

005 2711 Karen Pettit I C F Kaiser Engineers,

Inc

005 2746 Margie Weiner I C F Kaiser Engineers,

Inc


Agency - Region 9

Kenneth Hendrix Environmental Protection Agency - Region 9


#A501037, memo #04, total

metals for 20 water samples, collected 1/18,19,20823/95, w/TL to M Wolfram fr M Weiner

OA review of analytical data, case #R95S47, memo #02, anions by ion

chromatography for 9 water samples, w/TL to M Wolfram fr K Hendrix

6/2/95

95/05/29 AR 668 005

95/06/07 AR 669 005

2755 Michael Wolfram Kent Rogers Environmental Protection Shell Oil Co

Agency - Region 9


Ltr: Decision for EPA to

prepare gw risk

assessment

3rd quarter sampling


results of analyses, v1

of 4, w/TL to M Montgomery fr K Rogers

11/2/95

95/06/07 AR 670

95/06/09 AR 671

005 2759 Michael Wolfram Environmental Protection

Agency - Region 9


Inc

Kent Rogers

Shell Oil Co

Ltr: Review of 5/10/95 gw

RI/FS supplemental

workplan 8 approval to

construct replacement

well, w/attch

Michael Wolfram Memo: Review of volatile

Environmental Protection analytical data fr site,

Agency - Region 9 case #01-029, memo #05 8 /. meiTM

95/06/12 AR 672 005 2768 Thermo Analytical, Inc ENVIRON Corp 3rd quarter sampling

Page 76

03/01/96



DATE AR # yy/imi/dd


period 1995 gw lab data, results of analyses, v2 of 4

95/06/12 AR 673 005 2770 Thermo Analytical, Inc ENVIRON Corp 3rd quarter sampling period 1995 gw lab data, results of analyses, v3 of 4

95/06/13 AR 674 005 2772 Thermo Analytical, Inc ENVIRON Corp 3rd quarter sampling


results of analyses, v4

of 4

95/06/13 AR 675 005 2774 Michael Wolfram Environmental Protection

Agency - Region 9

Melitta Rorty

I C F Kaiser Engineers,

Inc

Ltr: Transmits EPA review

comments for 2nd quarter gw analytical data, w/o

attch


Michael Wolfram


Memo: Review of Development & screening

of remedial alternatives,

gw RI/FS

95/06/14 AR 677 005 2783 Melitta Rorty


Michael Wolfram


Agency - Region 9

Memo: Review of

Supplemental workplan gw

RI/FS & Development &

screening of remedial

alternatives gw RI/FS

95/06/16 AR 678 006 0001 Margie Weiner I C F Kaiser Engineers,

Inc

Kenneth Hendrix Environmental Protection Agency - Region 9

OA review of analytical data, case #R95S47, memo

#01 for volatiles for 9 water samples collected

4/444/5/95, w/TL to M Wolfram fr K Hendrix

6/23/95

95/06/19 AR 679 006 0023 Alan Mair

ENVIRON Corp

D i ana Wong


Inc

Ltr: Transmits diskettes

with 1st 4 2nd quarter gw

analytical data, w/o

attchs

95/06/20 AR 680 006 0025 ENVIRON Corp Rev summary tables for

monitoring rpt, 2nd quarter sampling period

1995, w/TL to M Wolfram to K Rogers 6/30/95

95/06/20 AR 681 006 0109 Kent Rogers Michael Wolfram Ltr: Remaining

Page 77



CHRONOLOGICAL ORDER

DATE yy/mm/dd


McColl Site Group Environmental Protection

Agency - Region 9

deliverables, task 10 gw RI/FS & request for extension of due date for Detailed analysis of alternatives, w/o attch

95/06/20 AR 682

95/06/21 AR 683

95/06/22 AR 684

95/06/22 AR 685

95/06/26 AR 686

95/06/28 AR 687

006 0112 Kathleen Considine CA Environmental Protection Agency - Dept of Toxic Substances

Control

006 0116 Caron Sontag I C F Kaiser Engineers,

Inc

006 0144 ENVIRON Corp

006 0191 Kent Rogers McColl Site Group

006 0193 Michael Wolfram Environmental Protection

Agency - Region 9


Inc


Control


Memo: Review of Supplemental workplan for

gw RI/FS

Data validation rpt: Case #23421, memo #01, total & dissolved metals for 18 water samples, collected

4/4S4/5/95, w/TL to M Wolfram fr M Weiner

Environmental Protection Supplemental workplan Agency - Region 9 (rev) gw RI/FS, w/TL &

EPA comments on 5/10/95

workplan

Michael Wolfram Ltr: Transmits rev

Environmental Protection Supplemental workplan gw

Agency - Region 9 RI/FS, w/o attchs

Kent Rogers


Agency - Region 9

Kenneth Hendrix Environmental Protection

Agency - Region 9

Ltr: Quantitation limits

above maximum contaminant

levels (MCLs) for gw

RI/FS supplemental

workplan 4th quarter

sampling, w/attch

QA rev of analytical data, case #R95S47, memo

#05 for semivolatiles for 9 water samples collected

4/4& 4/5/95, w/TL to M

Wolfram fr K Hendrix

7/7/95

95/06/28 AR 688 006 0219 Charles McAuley

McAuley LCX Corp

Michael Wolfram


Agency - Region 9

Ltr: Damage to golf

course & need for

aircraft landing matts

for drilling well P-10L

95/06/30 AR 689 006 1 0221 MarcSilva I C F Technology, Inc


rpt, 6/28/95 - 6/30/95

Page 78

03/01/96




95/07/05 AR 690 006 0224 Kathleen Considine CA Environmental Protection Agency - Dept of Toxic Substances Control

Caroline Rudolph CA Environmental Protection Agency - Dept of Toxic Substances Control

Memo: Review of Development & screening of remedial alternatives gw RI/FS, w/marginalia & TL to M Wolfram fr C

Rudolph


Michael Wolfram Envi ronmentaI Protect i on Agency - Region 9

Memo: Table of site contaminants that exceed

MCLs for gw fact sheet,

w/marginalia

95/07/07 AR 692 006 0231 Marc Silva




rpt, 7/5/95 - 7/7/95

95/07/08 AR 693 006 0234 Michael Wolfram


Agency - Region 9

Site RI/FS working

schedule, July/August/September, w/marginalia (Privileged

- FOIA ex 5)

95/07/10 AR 694 006 0236 Lynton Dicks McColl Site Group


Memo: Lab reevaluation &

delay of 3rd quarter data, & transmits draft of Itr fr gw contractor

in response to questions,

w/o attch

95/07/10 AR 695 006 0238 Lynton Dicks

McColl Site Group

Michael Wolfram


Agency - Region 9

Memo: Lab reevaluation &

delay of 3rd quarter

data, & transmits draft of Itr fr gw contractor

in response to questions,

w/handwritten notes &

attch

95/07/11 AR 696 006 0244 Michael Wolfram Environmental Protection Agency - Region 9

Richard Bauer


ROC: 7/6/95 memo fr Environ re quantitation limits for benzene'& 1,2-

dichloroethane for routine gw monitoring

95/07/11 AR 697 006 0246 Michael Wolfram Environmental Protection

Agency - Region 9

Lynton Dicks McColl Site Group

Ltr: Review of 7/6/95 memo re quantitation

limits for benzene & 1,2-

dichloroethane & approval

to lower limits, w/attch

95/07/12 AR 698 006 0252 Margie Weiner


Kenneth Hendrix QA rev of analytical

Environmental Protection data, case #R95S47, memo

Page 79




CHRONOLOGICAL ORDER

DATE yy/mm/dd


Inc

95/07/12 AR 699 006 0262 Sandra Haxfield ENVIRON Corp

Agency - Region 9


#04,Tetrahydrothi ophenes

for 9 water samples collected 4/4&4/5/95.W/TL to M Wolfram fr K Hendrix

7/20/95

Memo: Transmits tables & figures re construction

details for proposed well P-10L, w/attchs & TL

95/07/14 AR 700 006

95/07/18 AR 701 006

0270 Alan Mair ENVIRON Corp


Diana Wong I C F Kaiser Engineers,

Inc

Ltr: Transmits 3rd quarter gw analytical data, w/o attch

Michael Wolfram Ltr: Proposed changes to Enviromental Protection analytical procedures & Agency - Region 9 quantitation limits for

benzene & 1,2-dichloroethane

95/07/20 AR 702 006 0277 Mtg minutes: Technical mtg, phase II gw RI,

w/mtg agenda & attchs

95/07/20 AR 703 006 0285 Alan Mair

ENVIRON Corp

Diana wong I C F Kaiser Engineers,

Inc

Ltr: Transmits 3rd

quarter gw analytical

electronic data, w/o

attch

95/07/20 AR 704 006 0287


Agency - Region 9

Mtg agenda: Groundwater

mtg, Anaheim

Quarterly gw monitoring rpt, 3rd quarter sampling

period 1995, w/TL to M

Wolfram fr K Rogers

7/27/95


Michael Wolfram Ltr: Status rpt re Environmental Protection quarterly gw monitoring Agency - Region 9 program & construction of

monitoring well P-10L,

w/attch

95/08/02 AR 707 006 0622 Mtg agenda: Site

groundwater briefing, w/marginalia & attchs (Privileged - FOIA ex 5)

Page 80

03/01/96




95/08/04 AR 708 006 0624 Michael Wolfram Kent Rogers Environmental Protection McColl Site Group Agency - Region 9

Ltr: Revised RI/FS deliverables schedule

95/08/09 AR 709 006 0627 Michael Wolfram Environmental Protection Agency - Region 9

Melitta Rorty I C F Technology, Inc

Memo: Comments on Quarterly gw monitoring rpt, 3rd quarter sampling period (1995) 7/27/95, w/diskette of 3rd quarter data (Privileged - FOIA

ex 5)

95/08/09 AR 710 006 0629 Sandra Maxfield

ENVIRON Corp

95/08/10 AR 711 006 0631 Sandra Maxfield ENVIRON Corp

95/08/16 AR 712 006 0633

95/08/17 AR 713 006 0637

95/08/17 AR 714 006 0642

95/08/18 AR 715 006 0647 ENVIRON Corp

95/08/18 AR 716 006 0649 ENVIRON Corp

D iana Wong -I C F Kaiser Engineers,

Inc

Ltr: Transmits 3rd quarter analytical data

with revised quantitation

limits for 1,2-dichloroethane & benzene


Agency - Region 9

Memo: Scheduled 8/16/95 interagency mtg with MSG

re RI

Mtg minutes: Technical

mtg. Phase 2 gw RI, w/handwritten note

Mtg minutes: 8/16/95 technical mtg. Phase II

gw RI & 8/17/95 conference call

Mtg minutes: 8/16/95

technical mtg, Phase 2 gw RI & minutes of 8/17/95

conference call re

remedial action

objectives (RAOs)

4th quarter sampling

period (1995), gw

laboratory data, metals &

general chemistry work order #L2208 & L2216

4th quarter sampling period (1995), gw

laboratory data, organics & general chemistry work

order #L2208 & L2216

Page 81




DATE

yy/imi/dd


95/08/18 AR 717 006 0651 ENVIRON Corp


4th quarter sampling

period (1995), gw laboratory data, organics & general chemistry work

order #L2276

Michael Montgomery Memo: Delay of rev 1st & Environmental Protection 2nd quarter gw database &

Agency - Region 9 possible delay in submittal of draft risk

assessment

95/08/25 AR 719 006 0655 Alan Mair ENVIRON Corp

Robert Cheung I C F Kaiser Engineers,

Inc

Ltr: Transmits diskette of 1st & 2nd quarter rev gw analytical data, w/o

attch

95/08/28 AR 720 006 0657

95/08/28 AR 721 006 0683 McColl Site Group

95/08/28 AR 722 006 0709 Kent Rogers^ McColl Site Group


Agency - Region 9

Michael Montgomery


Agency - Region 9

Responses to EPA's 7/17/95 comments on Development & screening of remedial alternatives rpt, gw RI/FS, w/TL to M Montgomery fr K Rogers

Responses to EPA's 7/17/95 comments on Development & screening of remedial alternatives

rpt, groundwater RI/FS,

w/TL to M Montgomery fr K

Rogers

Ltr: 8/17/95 conference

call re involvement of

MSG in risk assessment

process & revision of deliverables schedule for

gw RI/FS

95/08/29 AR 723 006 0714 Al Hendricker Shell Chemical Co

Michael Montgomery


Agency - Region 9

Memo: Groundwater mtg

with RUQCB, w/handwritten

notes, agenda &

directions

95/08/30 AR 724 006 0718 Charles McAuley McAuley LCX Corp

Michael Montgomery


Agency - Region 9

Ltr: Comments re long-

range planning &

community desires


Michael Montgomery Memo: 2 mtgs scheduled Environmental Protection with EPA & MSG to discuss

Page 82

03/01/96




Agency - Region 9 gw activities

95/08/31 AR 726 006 0723

95/09/05 AR 727 006 0726

95/09/05 AR 728

95/09/07 AR 729

95/09/12 AR 730

006

006

006

0728

0730

95/09/13 AR 731 006

95/09/14 AR 732

95/09/22 AR 733

006

006

0795

0798

Kent Rogers

McColl Site Group

0787 Kent Rogers

McColl Site Group

0792 McColl Site Group

John Schroeter

ENVIRON Corp


Kathleen Considine


of Toxic Substances

Control

Alan Mair

ENVIRON Corp

Kent Rogers

McColl Site Group

Caroline Rudolph


of Toxic Substances

Control

Robert Cheung


Inc

Michael Montgomery


Michael Montgomery


Agency - Region 9

Ltr: Summary of 8/30/95

conference call re involvement of MSG in risk assessment, rev of schedule for RI/FS & ltr rpt for analysis of alternatives

Memo: Review of Quarterly

groundwater monitoring rpt, 3rd quarter sampling

period (1995) 7/27/95


Ltr: Transmits rev 3rd

quarter 1995 gw

analytical electronic

data, w/o attch

Ltr: Transmits field data sheets for task 10 drilling program, w/attchs

Ltr: Transmits rev p 4-3

& table 4-1 for Routine

gw monitoring

analysis/recommendations

rpt & workplan 5/13/94,

w/attchs

Technical memo 10-20 -

Update to gw RI/FS workplan, additional sampling & analysis,

w/marginalia & TL to M Montgomery fr K Rogers

Mtg minutes:

RI

Phase II gw

Michael Montgomery


Agency - Region 9

Memo: Transmits rev draft

tech memo 10-20, update

to gw RI/FS workplan, w/attch

95/09/25 AR 734 006 0802 David Chan

CA Environmental Caroline Rudolph CA Environmental

Memo: Risk assessment comments

Page 83

03/01/96





yy/mm/dd

95/09/27 AR 735

95/09/28 AR 736

006

006

0805

*0809

95/09/28 AR 737 006 0812

95/10/00 AR 738

95/10/00 AR 739

95/10/04 AR 789

95/10/05 AR 740

Protection Agency -Hazardous Waste Toxicology Section


Agency - Region 9

Keith Takata Environmental Protection Agency - Region 9

006 0816 ENVIRON Corp

006 1564 McColl Site Group

in binder Melitta Rorty I C F Technology, Inc

006 1583 Michael Montgomery


Agency - Region 9

Protection Agency - Dept of Toxic Substances Control

Rand Shulman Shell Oil Co

Rand Shulman

Shell Oil Co


Agency - Region 9

file

Caroline Rudolph

CA Environmental


of Toxic Substances

Control

Mtg minutes: Phase II gw RI

Ltr: Contingency remedy

of RCRA-equivalent closure as final decision & transmits app Z to 7/95

task 4 rpt (concurrence

copy), w/o attch

Ltr: Amendment to administrative order #93-21, revised schedule & SOW (concurrence copy), w/amendment (concurrence copy)

Draft RI rpt, gw operable

unit, v2 of 2 (appendices)

Descriptions of remedial

alternatives for gw, w/TL

to M Montgomery fr K Rogers 10/27/95

Memo: Recommendation for

EPA approval of

additional analyses on gw

samples fr wells P-21, P-41, P-9D, P-10D & P5L per

tecnical memo 10-20

Ltr: Request to identify

potential state ARARs for

gw FS

95/10/09 AR 741 006 1585 McColl Site Group Response to EPA's

comments on draft baseline risk assessment

for gw, w/TL to M

Montgomery fr R Scofield

95/10/12 AR 742 006 1593 South Coast Air Quality CA Environmental Ltr: List of Air Quality

Page 84

03/01/96



DATE AR # ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT yy/rtm/dd

Management District Protection Agency - Dept


Management' District (AQMD) rules &

regulations for ARARs, w/TL to M Montgomery fr C

Rudolph 10/26/95

95/10/13 AR 743 006 1596 ENVIRON Corp Environmental Protection Draft RI rpt, gw operable Agency - Region 9 unit, vl of 2

95/10/13 AR 744 006 1786 Kent Rogers

McColl Site Group

Michael Montgomery


Ltr: Transmits 2 copies

of Draft RI rpt gw OU,

w/o attch

95/10/19 AR 745 006 1788 I C F Technology, Inc Environmental Protection Mtg minutes: Technical

95/10/23 AR 790 ^ er.

Agency - Region 9

Michael Montgomery Melitta Rorty

Environmental Protection I C F Technology, Inc Agency - Region 9

mtg, phase 2 groundwater

RI, w/attchs

Technical direction memo

- Comments for revisions

to Draft baseline risk

assessment, w/o attch


Michael Montgomery


Agency - Region 9

Memo: Review of Draft RI

rpt gw OU

95/10/31 AR 747 006 1803

95/10/31 AR 748 006 1814

Kent Rogers

McColl Site Group


Michael Montgomery


Ltr: Transmits validated

results of 7/95 & 8/95

sampling of well P-10L, quarterly gw monitoring

program task 11, w/attchs

Michael Montgomery Ltr: Transmits Final gw Environmental Protection baseline risk assessment,

Agency - Region 9 w/o attch

95/11/00 AR 749 006 1816 I C F Technology, Inc Environmental Protection Final baseline risk Agency - Region 9 assessment for site gw OU

95/11/02 AR 750 006 2124 Kent Rogers

McColl Site Group

Michael Montgomery Ltr: Transmits changes to

Environmental Protection contract required

Agency - Region 9 quantitation limit (CRQL) for 1,2-dichloroethane &

benzene, 1st & 2nd quarter sampling 1994/1995, w/attchs

95/11/02 AR 751 006 2292 Kent Rogers

McColl Site Group

Michael Montgomery Ltr: Transmits EPA data

Environmental Protection validation results 2nd

Agency - Region 9 quarter 1995, w/attchs

Page 85



CHRONOLOGICAL ORDER

DATE

yy/rrm/dd




Ltr: Transmits revisions to gw analytical data for 1st, 2nd & 3rd quarter sampling periods, w/attch

95/11/03 AR 753

95/11/06 AR 754

007 0001 Kathleen Considine CA Environmental Protection Agency - Dept of Toxic Substances

Control

007 0006 Michael Montgomery Environmental Protection

Agency - Region 9


Control

Kent Rogers

McColl Site Group

Memo: DTSC comments on Draft RI rpt gw OU, w/TL to M Montgomery fr C

Rudolph 11/8/95

Ltr: Transmits electronic

summary of risk assessment & comments on

RI rpt & remedial alternatives descriptions, w/attchs w/o electronic summary

95/11/16 AR 755 007 0020 McColl Site Group Description of treatability studies for THTs gw FS, W/TL to M Montgomery fr K Rogers

11/20/95

95/11/21 AR 756

95/11/21 AR 757

007 0034 Marina West Michael Montgomery Orange County - Water Environmental Protection

District Agency - Region 9

007 0039 Marina West Michael Montgomery Orange County - Water Environmental Protection

District Agency - Region 9

Ltr: Transmits comments

on Draft FS rpt, groundwater operable unit

12/95, w/attchs

Ltr: Review of Draft FS rpt, groundwater operable

unit 12/95 & transmits

comments, w/attch (Redacted - FOIA ex 5)

95/11/22 AR 758 007 0045 Marina West Orange County - Water

District

Michael Montgomery


Ltr: Transmits OCWD

comments on Draft RI rpt, gw operable unit, w/o

comments w/attchs


Michael Montgomery


Agency - Region 9

Memo: Schedule of

deliverables, w/tech memo

#10-21 (signed)

w/handwritten note & TL

95/11/28 AR 760 007 0109 ENVIRON Corp Technical memo: #10-21 -

Update to gw RI/FS workplan, aquifer testing

at monitoring well P-10L,

Page 86

03/01/96




w/marginalia & TL to M Montgomery fr K Rogers

95/11/30 AR 761 007 0115 ENVIRON Corp Environmental Protection Agency - Region 9

Final annual groundwater monitoring rpt 1994 to 1995, w/TL to M Montgomery fr K Rogers

95/12/01 AR 762 007 0857 McColl Site Group Environmental Protection Agency - Region 9

Preliminary remediation goals for THT compounds,

w/TL to M Montgomery fr K

Rogers

95/12/01 AR 763 007 0869 ENVIRON Corp Description of attenuation/fate &

transport modeling

studies for tetrahydrothiophenes, w/marginalia & TL to M Montgomery fr K Rogers

95/12/01 AR 764 007

95/12/01 AR 765 007

95/12/01 AR 766 007

95/12/05 AR 767 007

95/12/06 AR 768 007

0881 Kent Rogers

McColl Site Group

0883 Kent Rogers

McColl Site Group

0885 Sandra Maxfield ENVIRON Corp

0888 ENVIRON Corp

1070 Kent Rogers

McColl Site Group



Agency - Region 9



Agency - Region 9

Michael Montgomery


TL: Groundwater

analytical data for 4th quarter sampling period (1995)

Ltr: Change in schedule for MSG due date for

submission of Draft FS

rpt, fr 12/1/95 to

12/6/95

Memo: 12/4/95 conference call to discuss tech memo

#10-21, w/TL to M West fr

S Maxfield

Draft FS rpt, groundwater

operable unit, w/TL to M Montgomery fr K Rogers

Ltr: Transmits table 5

(amended) - Summary of

prediction limits for

Final annual groundwater

monitoring rpt 11/30/95,

w/attch

95/12/07 AR 769 007 1074 Mtg agenda: Groundwater

status mtg, Anahiem,

Page 87




DATE yy/mm/dd


95/12/07 AR 791 binder- I c F Technology, Inc

95/12/12 AR 770 007 *1076

95/12/15 AR 771 007 1079

Ada Miu ENVIRON Corp


Agency - Region 9

w/marginalia

Mtg minutes: Phase II groundwater Rl/fS mtg, w/TL to M Montgomery fr M

Rorty 2/12/96

Memo: 12/13/95 conference

call. w/TL to M Montgomery fr J Schroeter

Charles Bennett Michael Montgomery Ltr: Comments re RI/FS

Fullerton Hills Community Environmental Protection plan due 12/15/95, w/TL Agency - Region 9 Assn

95/12/18 AR 772 007 1083 ENVIRON Corp

95/12/18 AR 773 007 1209 ENVIRON Corp

McColl Site Group

McColl Site Group

95/12/21 AR 774 007 1335

95/12/27 AR 775 007 1337

Thorn Coughran

City of Fullerton

Fate & transport of tetrahydrothiophenes at

site, w/TL to M Montgomery fr K Rogers

Fate & transport of tet rahydroth i ophenes, w/TL to M Montgomery fr K

Rogers

Michael Montgomery Ltr: Review of 12/95

Environmental Protection Draft FS rpt, groundwater

Agency - Region 9 operable unit

William Vance

CA Environmental

Caroline Rudolph

CA Environmental

Memo: Comments on Fate &

transport of

Protection Agency - Dept Protection Agency - Dept tetrahydrothiophenes at

of Toxic Substances of Toxic Substances site

Control Control

95/12/28 AR 776 007 1341

95/12/29 AR 777 007 1343

Kathleen Considine CA Environmental


of Toxic Substances

Control


Caroline Rudolph

CA Environmental

Protection Agency - Dept of Toxic Substances

Control

Michael Montgomery


Agency - Region 9

Memo: Comments on Draft

FS rpt, groundwater

operable unit 12/95, w/TL

to M Montgomery fr K Considine (Privileged -

FOIA ex 5)

Handwritten note: Transmits rev chapters

for gw FS, including app

A, w/handwritten post-it

notes & attchs w/marginalia (Privileged

Page 88

03/01/96



DATE AR # ROLL # FRAME # AUTHOR ADDRESSEE SUBJECT yy/nm/dd

95/12/29 AR 778 007 1345 ENVIRON Corp

95/12/29 AR 779 007 1559 ENVIRON Corp



Final RI rpt, groundwater operable unit, v1, w/TL to M Montgomery fr K Rogers

Final RI rpt, groundwater operable unit, v2 - app A-1

95/12/29 AR 780 007 2353 William Vance CA Environmental

Protection Agency -Office of Environmental

Health Hazard Assessment

Caroline Rudolph

CA Environmental



Memo: Draft FS rpt, groundwater operable

unit, w/attch memo to C Rudolph fr K Considine

96/01/15 AR 781 007 2363

96/01/16 AR 792 (D, n^r

Melitta Rorty


Michael Montgomery


Agency - Region 9


Agency - Region 9

Al Hendricker Shell Oil Co

Ltr: Transmits Draft FS rpt, groundwater operable

unit, w/attch

Ltr: Transmits comnents on Final RI rpt. Final annual gw monitoring rpt (with cover sheet), Fate

& transport of tetrahydrothiophenes, w/attchs

96/01/23 AR 782 007 2531

96/01/24 AR 783 007 2537

96/01/24 AR 784 007 2544

Al Hendricker

McColl Site Group

AI Hendricker McColl Site Group

Kathleen Considine

CA Environmental


Control

Michael Montgomery


Agency - Region 9

Michael Montgomery


Caroline Rudolph CA Environmental


Control

Ltr: Comments on Internal

draft FS, groundwater

operable unit 1/15/96, w/marginalia

Ltr: Transmits 4 errata sheets for Final RI rpt, groundwater operable

unit, w/attchs

Memo: Review of Groundwater draft FS

1/15/96 (2nd draft), w/handwritten note & TL

to M Montgomery fr C

Rudolph (Privileged -

FOIA ex 5)

96/01/29 AR 785 007 2546 Melitta Rorty

I C F Technology, Inc Michael Montgomery Memo: Comments on Final

Environmental Protection RI rpt, groundwater Agency - Region 9 operable unit 12/29/95

96/01/30 AR 786 007 2550 John Schroeter Michael Montgomery Ltr: Transmits rev tables

Page 89




CHRONOLOGICAL ORDER

DATE yy/mm/dd


96/02/02 AR 787 007 2556

ENVIRON Corp


Agency

Environmental Protection 2-3 & 2-4 fr Draft FS

Agency - Region 9 rpt, w/attchs

List of US EPA guidance docunents consulted during development &

selection of response action for site

96/02/07 AR 788 007 2563

96/02/07 AR 793 ^

96/02/07 AR 794 j ̂ binder"

96/02/09 AR 795 binder

96/02/13 AR 796 'm (oincler

96/02/13 AR 797 in binder


Agency - Region 9


Al Hendricker McColl Site Group

Caroline Rudolph

CA Environmental


FS rpt, groundwater

operable unit

Ltr: Transmits tabl-es with ICF calculations for

Summary of total carcinogenic risks, draft FS rpt 1/12/96, w/attchs w/marginalia

Michael Montgomery Ltr: Proposed schedule Environmental Protection for P-10L aquifer testing

Agency - Region 9

Michael Montgomery Ltr: Transmits DTSC

Protection Agency - Dept Agency - Region 9

of Toxic Substances

Control

Envirormental Protection comments to 2nd draft groundwater operable unit

FS, w/attch w/handwritten

note & TL to M Montgomery


Sandra Maxfield

ENVIRON Corp


Agency - Region 9

fr C Rudolph 1/29/96

Ltr: Request for Draft FS

rpt

Michael Montgomery Memo: Transmits Proposed

Environmental Protection plan fact sheet for site

Agency - Region 9 operable unit, w/handwritten note,

w/attch w/marginalia

No. of Records:797

\armicro2.rpt

ATTACHMENT B

MARCH 14, 1996 PUBLIC MEETING COMMENTS

Mr. Felter: I hereby declare the comment period open. Would anyone like to comment on the proposed plan?

Mr. Bushey:

Mr. Felter:

Mr. Bennett:

Mr. Felter:

Mr. Siegel:

Mr. Felter:

Mr. Olquin:

Mr. Felter:

Yes. My name is Dave Bushey, B-u-s-h-e-y. I live at 1819 Fairgreen Drive in Fullerton. And I agree with your plan as proposed. And I thank you for all your work.

Thank you. Do we have any other comments?

Yes. My name is Chuck Bennett, B-e-n-n-e-t-t. I'm a resident of Fullerton and part of the FHCA. I would like to make the comment that the selection of #3 or #1 would have been the fastest alternatives at implementation. And I'm pleased to see that the Agency has chosen one of the prompter remedial plans for the groundwater.

And I think - my sense of the community is that they are supportive of either #1 or #3 as the choices.

Thank you. Yes, sir?

My name is Gene Siegel, S-i-e-g-e-l. I live at 2617 Tiffany Place. Looking over four alternatives, I would agree with EPA that Alternative #3 does make the most sense. From looking at the factors of overall protection, long-term effectiveness, cost effectiveness, and short-term risk, if you look at all four of those factors, they seem to be the best overall of all the alternatives.

Thank you. Do I have another comment?

Yes. It's Alex Richard Olquin, O-l-q-u-i-n. My address is 1506 Baronet Place, City of Fullerton. I'm a member of FHCA. I agree with Alternative #3.

There is a concern I have regarding down the road that long-term maintenance and monitoring, that diligence is served. And that I would hope that in the issuing of the rod, that an explanation would be made and comments given by US EPA regarding that MSG will stand by and monitor the wells and that we will not have problems hereafter, once the 30-year period is over or maintenance of the cap and implementation of their orders.

I

Thank you. I've just been reminded that several times this evening during this period the initials FHCA have been used. For the record, that stands for the "Fullerton Hills Community Association."

Do I have any other comments?

All right. Well, hearing no others, I officially conclude the official comment period and turn the meeting over to Mike and Brian for general questions. Thank you.

ATTACHMENT C

RESPONSIVENESS SUMMARY

c:\on-disk\rorty_m\rod_1 .WD5 32 05/08/96

RESPONSIVENESS SUMMARY FOR THE

GROUNDWATER OPERABLE UNIT PROPOSED PLAN

MCCOLL SUPERFUND SITE

FULLERTON, CALIFORNIA

May 7,1996

U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IX 75 HAWTHORNE STREET

SAN FRANCISCO, CALIFORNIA 94105

ICF TECHNOLOGY, INC. 1800 HARRISON STREET

OAKLAND, CALIFORNIA 94612

Contract No. 68-W9-0059 Work Assignment No. 59-18-9L04

McColl Site Responsiveness Summary 5/96 Table of Contents

TABLE OF CONTENTS

Page

I. OVERVIEW 1-1

II. HISTORY OF COMMUNITY INVOLVEMENT 11-1

III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC

COMMENT PERIOD AND AGENCY RESPONSES 111-1

Exhibit A Proposed Plan Fact Sheet Exhibit B March 14, 1996 Public Meeting Transcript Exhibit C Public Comments Exhibit D Written Comments from the State of California and McColl Site Group

i

McColl Site Responsiveness Summary 5/96 Section I Overview

I. OVERVIEW

On March 6, 1996, the U.S. Environmental Protection Agency (EPA) issued a Proposed Plan

stating EPA's preference for the groundwater cleanup alternative for the McColl Superfund Site

in Fullerton, California. EPA's preferred remedy is Additional Infiltration Reduction Measures

(Alternative #3 presented in the Feasibility Study Report, Groundwater Operable Unit, McColl

Superfund Site (EPA, February 1996)). Under this alternative, engineered controls would be used

to reduce the infiltration of site surface water and thereby reduce the migration of perched

contaminated groundwater to the regional aquifer. The controls could include lining of major

drainage channels, reduction of infiltration through grading or placing low permeability materials

outside of channels, and onsite management of surface water running onto the site. This

alternative also includes long-term groundwater monitoring. A 30-day public comment period

followed the issuance of the Proposed Plan. This Responsiveness Summary is a written

summary of the comments EPA received during the public comment period and EPA's responses

to these comments. After consideration of the public comments and review of the administrative

record, EPA has selected Additional Infiltration Reduction Measures. This final remedy is

embodied in the Record of Decision (ROD).

All of the community's responses to the Proposed Plan were in favor of the selected remedy,

Alternative #3. The oil company PRPs, the McColl Site Group (MSG), support the selection of

Alternative #3 with some exceptions and comments that are presented in Section 3 of this

Responsiveness Summary. The State of California, Department of Toxic Substances Control

(DTSC), has commented in support of Alternative #3. The DTSC has some comments on the

Proposed Plan that are presented in Section 3 of this Responsiveness Summary.

1-1

McColl Site Responsiveness Summary 5/96 Section II History of Community Involvement

II. HISTORY OF COMMUNITY INVOLVEMENT

Community members have been involved with the McColl Superfund Site since the beginning of the

investigation process. Agencies initiated investigations at the Site as a result of odor and health

complaints received from residents beginning in July 1978. Community concern increased gradually

through 1980. The efforts of Campaign for Economic Democracy (CED), a statewide consumer and

environmental organization, and a speech given to residents by Lois Gibbs, president of the Love Canal

Homeowners Association, focused media attention on the Site and heightened community awareness

about McColl. Due to the increasing community concerns and potential border zone property

determinations, the California Department of Health Services (DHS), now the Department of Toxic

Substances Control (DTSC), organized a public hearing in the fall of 1980.

Individual members of the community continued to be involved in discussions and decisions related to

the Site through 1984, when EPA and DHS announced that the Site would be remediated using the

excavation and redisposal alternative. Community comments received at the first public hearing indicated

strong community support for this decision. Following the California State Court injunction blocking the

State from implementing the remedy, some community members expressed increasing frustration at

delays in the cleanup process. This frustration led to the formation of the McColl Action Group. This

neighborhood committee participated actively in decisions related to the Site from 1985 through 1991.

EPA and DHS were often invited to make presentations to the group. The group subsequently disbanded

in 1991. Another community group, the Fullerton Hills Community Association (FHCA), was founded in

1991. This group has had input into site-related decisions.

Elected officials also have expressed interest in the Site, most notably former Congressman Dannemeyer.

All elected officials in the area are on the mailing list for the Site, and receive all information related to site

activities. Starting in 1986, EPA and DTSC have held regular meetings as part of the Interagency

Committee. The committee is comprised of the following agencies: EPA, DTSC, the City of Fullerton,

South Coast Air Quality Management District, City of Buena Park, Orange County Environmental Health,

California Regional Water Quality Control Board, California Department of Health Services' Drinking Water

Branch, and California Environmental Protection Agency's Office of Environmental Health Hazard

Assessment.

Community participation has focused on the source operable unit, and there has been limited community

participation in groundwater issues.

The alternatives considered for protection of groundwater are described in the Proposed Plan Fact Sheet

included in Exhibit A. No written comments from the community were received during the public comment

period. All community comments that were made during the Public Meeting held on March 14,1996 were

in support of the selected remedy. Written comments on the Proposed Plan were received from MSG and

DTSC. Both MSG and DTSC support the selection of Alternative #3. EPA has taken community concerns

into account in selecting the remedy. EPA believes the selected remedy is protective of human health

11-1

McColl Site Responsiveness Summary 5/96 Section II History of Community Involvement

and the environment, will be completed in a reasonable amount of time with low risk to the community,

and is cost-effective.

Throughout the remedial process, EPA and DTSC have continued to conduct a variety of community

relations activities. Activities have included public meetings, small group meetings, regular mailings to

community members, a toll-free information line, an on-site open house, and regular contact with the

media to provide information.

EPA and DTSC will continue to work closely with the community throughout the entire remediation

process to keep residents informed of progress at the Site. EPA and DTSC will monitor community

interests and concerns, and will conduct community relations activities as needed to address those

concerns.

11-2

McColl Site Responsiveness Summary 5/96 Section III Summary and Response to Local Community Comments, Summary and Response to State and PRP Comments

III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD

AND AGENCY RESPONSES

PART I - SUMMARY AND RESPONSE TO LOCAL COMMUNITY COMMENTS

The local community expressed its support of the proposed remedial action at the public hearing on the

proposed plan held on March 14, 1996. No written comments on the proposed plan were received from

the community. EPA acknowledges and appreciates the input of the local community.

The public hearing had two components. The first part of the evening was a brief summary of the status

of the closure and containment system (source operable unit). There were some questions from the

audience, with responses from EPA. Those questions and answers will not be repeated here, but appear

in the transcript of the hearing. A copy of the hearing transcript is attached to the Responsiveness

Summary as Exhibit B.

The second part of the hearing was devoted to the groundwater proposed plan and was designed to

receive public comments on the proposed plan. Four people representing neighborhood residents spoke

in support of the proposed plan. Because all comments from the local community were in support of the

proposed plan, no EPA responses are given here. As previously stated, no written comments were

received from the local community during the public comment period. The public comments are

presented as Exhibit C.

PART II - SUMMARY AND RESPONSE TO STATE AND PRP COMMENTS

Written comments on the proposed plan were received from the State of California (DTSC) and the MSG.

Both parties support the selection of Alternative #3, with some comments.

A. State of California, Department of Toxic Substances Control

The State of California's comments, dated March 29,1996, are presented here in their entirety in standard

print. EPA responses are in italics. The complete letter is presented in Exhibit D.

The California Department of Toxic Substances Control (DTSC) has reviewed the United States

Environmental Protection Agency's (U.S. EPA) Proposed Plan (Plan) for the Ground Water

Operable Unit at the McColl hazardous waste site. U.S. EPA issued the Plan on February 27,

1996 in the form of a fact sheet titled 'EPA McColl Superfund Site', February 1996.

The DTSC has been given the opportunity to review and provide comments to U.S. EPA on draft

and final versions of the various documents U.S. EPA used in developing the Plan. The

documents reviewed included those of the remedial investigation, feasibility study (GWFS), and

ill-1


the baseline risk assessment, which were prepared by either U.S. EPA's contractor or the McColl

Site Group, the responsible parties. Also reviewed were the applicable or relevant and

appropriate requirements (ARARs), and the nine criteria analysis, both of which were included in

the GWFS. (A formal alternatives risk assessment document was not prepared). Individuals

reviewing the Plan and the various support documents include Dr. William Vance and Dr. David

Chan of the Office of Environmental Health Hazard Assessment, Ms. Kathleen Considine of

DTSC's Geological Services Unit and Ms. Caroline Rudolph, DTSC's project manager for the

McColl Site.

The DTSC's comments and concerns regarding the Plan are derived from review of the draft and

final documents along with that of the Plan. The Department's comments on the Plan are as

follows, with Ms. Considine's comments (related to the GWFS) provided as an attachment to

further clarify DTSC's primary concern with the presently proposed Plan:

Proposed Plan

Conceptually, U.S. EPA's Plan of infiltration reduction and long-term monitoring appears to be

realistic and implementable considering the minimal contamination currently found within the

existing monitoring system. The Plan, denoted as Alternative 3 in the fact sheet, does lack an

element of the alternative as it was previously described in the GWFS: that of institutional

controls. Institutional controls are a means of ensuring the efficiency and integrity of the long-term

monitoring system. DTSC recommends that U.S. EPA's final Plan include at a minimum the

contingency of placing appropriate institutional controls if data review of the completed long-term

monitoring system (i.e., including the additional one or two wells proposed as part of the Plan)

indicate that such controls are needed.

Response: EPA agrees that institutional controls should be a part of Alternative #3. The EPA Record of

Decision states, "EPA or the relevant state agency will implement institutional controls as a contingency measure. Specifically, if at the five year review the regional aquifer beyond the current site boundary is

found (in more than one offsite well) to contain site-specific contaminants above State or Federal Maximum

Contaminant Levels (MCLs) or above the recommended (3.6 parts per billion (ppb)) or revised preliminary remediation goal (PRG) for tetrahydrothiophene (THT) compounds, institutional controls will be implemented."

Ms. Considine's Memorandum:

As requested, I have reviewed the document Feasibility Study Report, Groundwater Operable Unit,

McColl Site (GWFS), dated February 7, 1996. The GWFS was prepared by ICF Technology

Incorporated (ICF) for the United States Environmental Protection Agency (U.S. EPA). The GWFS

presents the remedial alternatives for contaminated groundwater at the McColl Site.

III-2


CONCLUSIONS & RECOMMENDATIONS

The chosen Remedial Alternative 3 (RA 3) involves source controls, groundwater monitoring,

infiltration reduction measures, and institutional controls, according to the discussion on page

6-23 of the GWFS. The GWFS then makes the statement on page 6-41 that 0 ...Remedial

Alternative 3 would be the easiest to implement, in the event that the required area of institutional control is reduced or eliminated with remedial action." The RA 3, as presented to the public

makes no mention at all of institutional controls. I strongly recommend that Institutional controls

be retained as part of RA 3.

The reason why institutional controls should be retained is a follows. The total horizontal and

vertical extent of contamination has not been determined off-site in the down-gradient direction.

Additional groundwater monitoring wells are proposed to resolve this issue and the area of

institutional controls cannot be adequately defined at this time. A reduction in contaminant levels

is expected after the source control and infiltration reduction measures are in place. However,

since the Orange County groundwater basin is non-adjudicated, without institutional controls there

is no control on the possible installation and pumping of a private well(s) in the site vicinity. This

could change the groundwater flow direction and gradient and potentially pull more contamination

from the site.

Response: As stated above, EPA agrees with the State, and has retained institutional controls in the

Record of Decision as a contingency measure. (See page 6-38 of the GWFS which provides that, "While institutional controls are included as part of Remedial Alternative 3, the size of the area where institutional

controls may need to be implemented may be significantly reduced or become not necessary.")

B. The McColl Site Group

The MSG's written comments, dated April 5, 1996, are presented in their entirety in Exhibit D. Many of

MSG's comments do not pertain to Alternative #3 of the Proposed Plan and EPA does not necessarily

concur with those comments. However, this Responsiveness Summary applies only to Alternative #3 of

the Proposed Plan, therefore only those MSG comments that are applicable to Alternative #3 are

presented here in standard print. EPA responses are in italics.

The purpose of this letter is to provide the formal comments of the McColl Site Group ("MSG")

regarding the Remedial Investigation (Rl), Feasibility Study (FS), Risk Assessment (RA), and EPA's

Proposed Plan for the Groundwater Operable Unit at the McColl Site in Fullerton, California.

These comments are prepared in response to the U.S. EPA Public Comment Period which

extends to April 5, 1996.

III-3


••••••• -„|TI..,1 .MML-lHim

In response to Administrative Order 93-21, MSG has conducted routine groundwater monitoring

as part of a groundwater investigation which was begun by EPA in 1989. Based upon that

investigation, as well as the Remedial Investigation Report completed by MSG, the Risk

Assessment completed by EPA, and the Feasibility Study that was initiated by MSG and

subsequently completed by EPA, EPA has proposed a remedial action plan which has identified

Alternative #3 (described in the Feasibility Study Report) as the preferred alternative. MSG

supports the selection of Alternative #3 of the Feasibility Study Report. The following points

summarize the results of the overall groundwater program and clarify certain aspects of the

proposed alternative that should be reflected in the Record of Decision.

• EPA has raised concerns regarding potential difficulties in negotiating institutional controls

with adjacent landowners. However, institutional controls should be considered for the

McColl Site and the area immediately south of the site within the golf course property

where implementation hurdles should not pose a significant problem.

Response: EPA maintains that it may be difficult to negotiate institutional controls in residential areas south of the Ramparts sumps (i.e., along Tiffany and Fairgreen Drive). As previously stated, EPA has retained institutional controls as a contingency measure. At this time, there are insufficient data available to determine whether institutional controls are necessary and, if so, the scope and extent of such controls.

• Completion of the surface remedy, RCRA-equivalent cover, and subsurface barrier wall

system will significantly reduce the potential for the sumps to impact groundwater in the

future. Although construction of the surface remedy will provide the primary means of

reducing groundwater contaminants, MSG supports the additional infiltration controls

described in Alternative #3, with the exception of the use of imported low permeability

materials outside of drainage ditches and redirection of surface water running onto the

property.

Response: EPA concurs that imported low permeability materials outside of drainage ditches may not be necessary. The groundwater remedy is intended to work in conjunction with the source remedy, and together will achieve the anticipated goal of protection of groundwater resources.

• Continued monitoring and installation of up to two new monitoring wells in the regional

aquifer, lining of retention ponds and primary drainage ditches, and reduction of

infiltration through surface grading is appropriate for the site. Use of imported low

permeability materials outside of drainage ditches and redirection of surface water

running onto the property would not provide significant benefits relative to the cost of

implementing these actions. Accordingly, use of low permeability materials and

redirection of surface water should be eliminated from further consideration in the remedy.

III-4


Response: EPA agrees that the use of imported low permeability materials would not provide significant reduction in infiltration relative to the cost of purchase and placement of low permeability materials. Redirection of surface water may be addressed by onsite management of surface water running onto the property.

• EPA has chosen to identify Operable Unit #1 for groundwater separately from Operable

Unit #2 for the surface remedy. However, it is important that the remedial design for

Operable Unit #1 be integrated into the design for Operable Unit #2. If EPA does not

facilitate timely integration of these designs, the cost and schedule for both remedies will

be adversely impacted.

Response: EPA agrees that the groundwater remedy is intended to work in conjunction with the source remedy, and together will achieve the anticipated goal of protection of groundwater resources. EPA intends to facilitate integration of these designs.

• Comment #3: Under U.S. EPA's detailed analysis of the remedial alternative "Institutional

Controls" (Alternative #2), U.S. EPA states that "long term institutional control may be

constrained by the priorities of the enforcing agency." U.S. EPA further states in the FS

that institutional controls are "potentially difficult to implement in that it involves the often

complex subject of water rights and negotiations with private property owners." The

administration of limited Institutional Controls is a viable remedial element for both

Alternative #3 and for the remedial strategy outlined to address THT compounds

described in Appendix A of the FS report. Institutional controls would be useful, for

example, to assure that cross-contamination between flow units does not occur due to

well construction activities. Institutional controls are expected to be necessary only for

the McColl Site and a portion of the Los Coyotes Country Club property. Because only

two separate parcels are involved, implementation problems are not anticipated.

Response: EPA maintains that it may be difficult to negotiate institutional controls in residential areas south of the Ramparts sumps (i.e., along Tiffany and Fairgreen Drive). EPA agrees that institutional controls should be a part of Alternative #3. The EPA Record of Decision states,"EPA or the relevant state agency will implement institutional controls as a contingency measure. Specifically, if at the five year review the

regional aquifer beyond the current site boundary is found (in more than one offsite well) to contain site-specific contaminants above State or Federal Maximum Contaminant Levels (MCLs) or above the

recommended (3.6 parts per billion (ppb)) or revised preliminary remediation goal (PRG) for tetrahydrothiophene (THT) compounds, institutional controls will be implemented.' At this time, there are insufficient data available for the Los Coyotes Country Club property to determine whether institutional controls are necessary and, if so, the scope and extent of such controls.

III-5

McColl Site Responsiveness Summary 5/96 Section ill Summary and Response to Local Community Comments, Summary and Response to State and PRP Comments

• Comment #4: The Fate and Transport Study of THT Compounds (ENVIRON, December

18, 1995) indicates that THT compounds are being degraded, probably as a result of

biologically mediated processes. Additionally, the limited infiltration controls proposed in

Alternative #3 and the remedial action selected for Operable Unit #1 should effectively

isolate the THT compounds within the sump areas from groundwater. Given the

degradation of THT compounds in groundwater and the isolation of the sump areas form

groundwater, the existing concentrations of THT compounds in groundwater are not likely

to be a permanent condition.

Response: EPA agrees that, at the McColl Site, it appears that THT compounds are degrading as a result of biologically-mediated processes.

III-6

EXHIBIT A

PROPOSED PLAN FACT SHEET

<» EPA McColl Superfund Site Fullerton, California

February 1996

EPA announces proposed plan tor contaminated groundwater at the McColl Superfund Site

The US EPA, in cooperation with the McColl Site

Group (MSG), comprised of Shell, Unocal, Arco, and

Texaco), has completed the Feasibility Study Report

for groundwater1 under the McColl site. EPA evalu

ated four alternatives to address the limited ground

water contamination found under the McColl waste

sumps (pits). EPA recommends the following alter

native (Alternative 3) which includes:

• Reducing groundwater infiltration by lining major

drainage channels

• Redirecting water running onto the site

• Reducing infiltration in onsite areas which will be

outside the future closure and containment system

for the waste sumps

• Adding one or two new monitoring wells to

confirm the contaminants generated by the site do

not (unreasonably) extend beyond the current

monitoring network.

This plan would reduce the possibility of contaminated

shallow (not usable) groundwater migrating to the re

gional (usable) groundwater. Although the regional

groundwater beneath the site is not currently used. US

EPA and the State of California consider the protec

tion of current and future water supplies essential to

the health and welfare of the community.

OPPORTUNITIES FOR PUBLIC INVOLVEMENT

COMMUNITY MEETING

You are invited to attend a community meeting, EPA will present its preferred alternative for addressing groundwater contamination as well as the other alternatives. Questions and comments will also be taken at this time.

DATE: March 14, 1996

TIME: 7:00 pm

PLACE: Parks Junior High Music Room, Room 126 1710 Rosecrans Fullerton, CA 92633

PUBLIC COMMENT PERIOD

EPA will begin a 30 day public comment period on

March 6th, and requests your comments on the preferred alternative as well as the other groundwater alternatives for the site. Written comments are to be post-marked no later than April 5, 1996, and should be submitted to:

Michael Montgomery Remedial Project Manager U.S. EPA 75 Hawthorne Street, MS: H-6-1 San Francisco, CA 94105

1 Groundwater - Underground water that fills pores in soil or openings in nocks to the point of saturation. Where groundwater occurs in

significant quantity, it can be used as a water source.

1

BACKGROUND

Beneath the McColl waste sumps are a series of

tilted or slightly slanted layers of soils and clays.

Some of the soil layers are more permeable to water

than the clay layers. The McColl site has multiple

clay layers with low permeability. These layers

retard and spread the contaminated groundwater,

preventing it from migrating downward from the

perched zones. Perched water refers to a body of

groundwater above the main or regional aquifer2.

Water in the regional aquifer, which lies approxi

mately 160 to 200 feet below the surface of the

ground, stores and transmits more water than the

contaminated perched zones. Previous groundwater

investigations have found contaminants in several

perched groundwater zones beneath the McColl site.

In 1994 the groundwater investigation was expanded

to determine if contaminants had migrated beyond

the perched zones to the deeper regional aquifer and

if the potential exists for the migration of

contaminants to the regional aquifer. As part of the

investigation, eight new monitoring wells were

installed in the fall of 1994 and one well was

installed in the summer of 1995. These wells, along

with 15 pre-existing wells, form the current network

of 24 monitoring wells for the site. These 24 wells

W-9B i W-9C

W-10B Rosecrans Avenue

Ralph B, Clark Regional Park

jr

I P-2S _ ® _ J <^P-5S

P-4I

Los Coyotes Golf Course

®P-1°D

•P-10L

P-9D

P-5L L E G E N D

Perched Monitor Wells

• Regional Monitor Wells

— Site Boundary

0 100 200

tartzzj Scale in Feet

Figure I

McColl Site Map Showing Locations of Monitoring Wells

2 Aquifer - An underground formation of material such as sand or gravel that can store or supply water to wells and springs.

2

GROUNDWATER INVESTIGATION

Groundwater investigation results indicate that while

contaminants are entering the perched groundwater,

they do not appear to result in significant

contamination of the regional aquifer. Only very

low concentrations of tetrahydrothiophenes (THTs),

which cause the water to taste and smell bad, appear

to have reached a limited portion of the regional

aquifer.

The perched groundwater is not considered usable

because there is not enough water to supply a

regularly used well. The regional aquifer is

potentially usable although it is not currently used

near the site. The City of Fullerton provides

municipal water to all residents near the site. Your

household tap water is not affected by contaminants

in the groundwater under the McColl site. The

water supply well nearest to the site is the City of

Fullerton's well named "Coyote 12a," which is

located approximately 3,000 feet to the southeast of

the site.

TABLE 1 PERCHED AND REGIONAL GROUNDWATER ORGANIC ANALYTICAL RESULTS

Contaminants Detected Above Drinking Water Standards

Contaminant

Perched Well Regional Well Maximum Concentration Maximum Concentration

(ppb) (ppb)

California Drinking Water Standards

(PPb)

Benzene 800 (Well W-6A) NA 1

1,2-Dichloroethane 2 (Well P-51) 2 (Well P-5L) 0.5

Pollutants That Smell and Taste Bad

2-Methyltetrahydrothiophene 43,000 (Well-6A) 140 (Well P-5L) NA

3-Methyltetrahydrothiophene 31,000 (Well-6A) 140 (Well P-I0L) NA

Tetrahydrothiophene 17,000 (Well-6A) 150 (Well P-I0L) NA

NA = Not applicable

ppb - parts per billion; a volume unit of measure.

3

monitor shallow perched zones of groundwater (10

wells) and groundwater in the deeper regional .

aquifer (14 wells) (see Figure 1 for the locations of

these wells). The groundwater investigation was

completed by MSG.

U.S. EPA recently selected the contingency remedy

of closure and containment for the waste

sumps. This decision was made in September of

1995 and included significant community

involvement.

Since our last Groundwater Fact Sheet (August

1995), EPA has approved the Final Remedial

Investigation Report and the Final Feasibility Study

Report. The following information is a general

summary of the findings presented in those

documents.

PERCHED GROUNDWATER PUBLIC HEALTH RISK ASSESSMENT

The results of the Remedial Investigation Report

confirm the presence of McColl site contaminants in

the perched groundwater zones which underlie the

site. Organic (carbon-based) contaminants include

benzene, ethylbenzene, toluene, 1,2-dichloroethane

(1,2-DCA), 2-hexanone, total xylenes, phenol, and

pyrene.

Other McColl site organic contaminants called THTs

have migrated from the site to the perched

groundwater. Most residents recall from field tests

conducted last year the pungent smell of THTs,

which can be detected by the human nose at

concentrations as low as one part per billion. These

contaminants, while not a concern based on

available toxicological data, can render water

unusable by making it taste and smell bad. (See

Table 1 for concentrations detected).

In addition, inorganic contaminants are found in the

perched water immediately downgradient of the

sumps. These inorganics (also known as metals) are

most likely a result of the acidic water from the

waste sumps drawing, or "leaching", the metals out

of the native soils below the sumps. The impact of

these metals is likely to be limited to the area

directly beneath the waste sumps and is not likely to

pose a significant threat to the regional aquifer.

REGIONAL AQUIFER

McColl site contaminants (excluding the THTs) are

not present in the usable portion of the regional

aquifer. Some THTs may have reached the upper

(usable) portions of the regional aquifer and

additional monitoring wells will be installed to

confirm the limited extent of the THT contamination

(see Table 1).

EPA completed an evaluation of the public health

risks associated with the perched and regional

groundwater. Perched groundwater falls within the

range of risks that warrant EPA action. The majority

of the calculated risk associated with the perched

water is a result of the inorganics, which occur as a

result of the acidic nature of the McColl waste.

The regional groundwater presents a much lower

risk than the perched groundwater. EPA decided to

go forward with the Feasibility Study, due to the

concerns associated with:

• The risks calculated for the perched water

• The possibility of exceeding state or federal

drinking water standards in the regional aquifer

in the future

• The possibility of exceeding water quality

standards for taste and odor in the regional

aquifer.

FEASIBILITY STUDY

The purpose of the McColl Groundwater Feasibility

Study was to develop and screen potential cleanup

alternatives based on the type and extent of

contamination found during the investigation. A

range of four alternatives was considered to address

perched and regional groundwater contamination.

4

Each alternative was developed to meet the general

objectives of:

• Reducing the potential generation and migration

of McColl waste constituents in the shallower

perched water beneath the site at levels which

could migrate and cause an unacceptable risk in

the regional groundwater

• Preventing human exposure to all contaminants

at concentrations that could pose a health

concern, and reduce the potential beneficial use

of regional groundwater

The four alternatives were evaluated in the

Feasibility Study against nine criteria (see Figure 2).

EPA performed a comparative analysis of the four

alternatives using the results of each individual

criterion. The alternatives and a summary of the

detailed analysis are described below and presented

in the table.

ALTERNATIVES CONSIDERED

Alternative #1: NO-ACTION

EPA considered the no-action alternative. The no-

action alternative would include the present level of

groundwater monitoring but would otherwise take

no action.

The no-action alternative would meet the criteria of

not exceeding drinking water standards and being

protective of public health, based on the current

data, and assuming the perched groundwater is not

usable. The no-action alternative is easy to

implement. No significant difficulties are

anticipated in constructing or implementing the

groundwater monitoring system associated with this

alternative. Alternative 1 is relatively inexpensive

but would not be as effective as other options in

assuring that the regional aquifer is protected from

site contaminants. The cost for the no-action

alternative would be $1.5 million based on 20 years

of groundwater monitoring.

Alternative #2: INSTITUTIONAL CONTROLS

Institutional controls would preclude the use of

groundwater beneath the site for drinking water

supply purposes. This alternative relies upon

successful negotiations for water rights with

property owners adjacent to the site and would

include groundwater monitoring. The goal of these

controls would be to prevent the migration of

perched contaminated groundwater into the regional

aquifer that could result from access through wells

in the regional or perched aquifer (not addressed by

the no-action alternative).

This alternative would meet the criteria of not

exceeding drinking water standards and being

protective of public health, assuming the perched

groundwater is not usable. The long-term

effectiveness of this alternative is limited as it is

based on water rights agreements with property

owners. Since the outcome of negotiations cannot

be predicted, it is difficult to estimate if the

alternative is easy to implement. There are also

regulatory agency concerns on whether any future

institutional controls could actually be enforced. It

is also difficult to estimate the costs of this

alternative. However, it would be more expensive

than the no-action alternative ($1.5 million) and

could cost more than Alternative #3.

Alternative #3: ADDITIONAL INFILTRATION REDUCTION MEASURES

Alternative #3 would include engineered controls

that would reduce the infiltration of surface

water and thereby reduce the migration of perched

contaminated groundwater to the regional aquifer.

This reduction would include lining of drainage

channels, reduction of infiltration through grading or

5

placing low permeability materials outside of

channels, redirection of surface water running onto

the property and groundwater monitoring.

This is EPA's preferred alternative. It is more

permanent and effective than Alternatives #1 and #2

because it would reduce risk associated with the

perched groundwater and the possibility of shallow

contaminated water migrating to the regional aquifer

through natural or man-made pathways. In addition,

Alternative #3 would be simpler to implement

because it can be designed and constructed in

conjunction with the planned waste pit closure and

containment system. It is a more cost effective

alternative when compared to the extraction and

treatment option. The cost for this alternative, based

on an estimate of 20 years of operation, is $2 to $3

million.

Alternative #4 EXTRACTION AND TREATMENT

Alternative #4 would extract water from the deeper

aquifer and treat this water at the site surface. The

treated water would be reused (e.g., as irrigation

water), discharged to the sewer system, discharged

to surface water via storm drain systems, or

reinjected into the ground through wells. This

alternative would also include groundwater

monitoring.

This alternative, although effective, would produce

residuals from the treatment system and would be

more difficult to implement than other alternatives.

Alternative #4 is the most costly of the alternatives

and would take the longest to implement. While

Alternative #4 would treat the extracted water, the

volume of treated material is expected to be small as

would the overall reduction of contamination in

groundwater. The cost for this alternative is $5 to

$7 million, based on 20 years of operation.

Figure 2 SELECTING A CLEAN-UP REMEDY

The U.S. EPA uses nine criteria to evaluate alternatives for cleaning up a hazardous waste site. The nine criteria

are as follows:

1) Overall Protection of Human Health and the Environment

Addresses whether a remedy provides adequate protection of human health and the environment and describes how risks are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.

2) Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

Addresses whether a remedy will met all ARARs or federal and state environmental statutes and/or provide grounds for invoking a waiver.

6

3) Long-term Effectiveness

Refers to the ability of a remedy to maintain reliable protection of human health and the environment over time, once clean-up goals have been met.

4) Reduction of Toxicity, Mobility, and Volume and Treatment

Refers to the anticipated ability of a remedy to reduce the toxicity, mobility, and volume of the hazardous components present at the site.

5) Cost

Evaluates the estimated capital and operation and maintenance costs of each

alternative.

6) Short-term Effectiveness

Addresses the period of time needed to complete the remedy, and any adverse impacts on human health and the environment that may be posed during the construction and implementation period, until the clean-up goals are achieved.

£23 7) Implementability

Refers to the technical and administrative feasibility of a remedy, including the availability of materials and services needed to carry out a particular option.

8) State Acceptance

Indicates whether, based on its review of the information, the state concurs with, opposes, or has no comment on the preferred alternative.

9) Community Acceptance

Indicates whether community concerns are addressed by the remedy and whether the community has a preference for a remedy. Although public comment is an important part of the final decision, EPA is compelled by law to balance community concerns with all of the previously mentioned criteria.

7

For More Information

Documents for the McColl Superfund Site are located If you have questions about the Superfund cleanup in the information repository at: at McColl, please call or write EPA's Community

Relations Coordinator for the site: Fullerton Public Library Local History Room Fraser Felter, Community Relations Coordinator 353 W. Commonwealth Avenue U.S. EPA, Region 9 Fullerton, CA 92633 75 Hawthorne Street (H-1-1) (714) 738-6333 San Francisco, CA 94105

(415) 744-2181 Hours: Monday - Thursday 10 am - 9 pm You may also call EPA's toll-free Superfund hotline Friday 10 am - 6 pm and leave a message. Your call will be returned. Saturday 10 am - 5 pm The hotline number is: (800) 231-3075 Sunday Closed

Important McColl Superfund Site Telephone Numbers

McColl Security Office (714) 523-5310

California EPA Public Participation Section (916) 445-9543

U.S. EPA Media Contact: Paula Bruin (415) 744-1587

United States Environmental Protection Agency

Region 9

75 Hawthorne Street (H-1-1)

San Francisco, CA 94105

Attn: Fraser Felter

Official Business

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$300

PRESORTED

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U.S. POSTAGE PAID

U.S. EPA

Permit No. G-35

Printed on Recycled Paper

EXHIBIT B

MARCH 14, 1996

PUBLIC MEETING TRANSCRIPT

McColl Superfund Site Multi-Page™ Transcript of Proceedings, 3-14-9(

McCOLL SUPERFUND SITE

GROUNDWATER PROPOSED PLAN

Date: Thursday, March 14, 1996 i

Commenced at: 7:10 p.m. ! I

Concluded at: 8:20 p.m.

Place: Parks Junior High Music Room, Room 126 1710 Rosecrans Fullerton, CA 92633

Reporter: Elizabeth Volz

1

M & M CERTIFIED COLfRT REPORTERS

McColl Superfund Site Multi-Page1 Transcript of Proceedings, 3-14-9(

Page 2 APPEARANCES

MIKE MONTGOMERY, Team Leader, us EPA

BRIAN SWARTHOUT, Project Manager, us EPA

FRASER FELTER, community Relations Coordinator, us EPA

NATALIE GILMOUR, Community Relations Coordinator,

ICF Technology, Inc.

LINDA LEQUIRE, Administrative Assistant for Congressman Royce

Page 3

1 Fullerton, California, Thursday, March 14, 1996 2

3 MR. MONTGOMERY: can I ask folks to sit down, 4 please. We are going to get started. 5 Let's see if I can get some people to sit 6 down here. We are going to get started, it's about 7:10

7 and we're starting at 7:00 o'clock. Which means, that we

8 started ten minutes ago. 9 We are going to dim the lights so everybody

10 can fall asleep. Hopefully, people won't fall asleep. 11 And I think we will be able to run this meeting pretty 12 quickly. Hopefully, we'll get done fairly quickly. I'll

13 try to keep my comments brief. 14 The agenda, I'm going to go through a quick : 15 introduction, sort of give some recent background on the j

16 site. 17 My name is Mike Montgomery, by the way. I'm

18 a Team Leader and a Project Manager for the McColl Site

19 Team. I've been working on the McColl site project now

20 for a little over two years. And I'll do some 21 introductions. 22 Actually, if you could now raise your hands 23 because it's dark. I'll just do it real quick: Fraser 24 Felter with Community Relations; A1 Hendricker with Shell;

25 Brian Swarthout is the other us EPA Project Manager

Page 4 1 that will be presenting tonight; Linda Lequire is in the

2 third row. she's from Congressman Royce's office; and

3 Mr. McAuley here from the McAuley LCX corporation, owner

4 of the golf course; and Caroline Rudolph with the State of

5 California; and some other folks that work with her that

6 you may be familiar, Bill Vance, Steve Gaytan. 7 Okay. So with that, we'll get started with 8 the introduction. I'm going to go over some recent 9 history. Brian is going to talk briefly about the

10 closure — status of the closure and containment system

11 design. I'm going to go through a brief description of

12 EPA's proposed plan for the groundwater contamination, and

13 talk about the alternatives that we considered. 14 And then we're going to have a brief period 15 that's required by regulation that we allow people the 16 opportunity to comment on our proposed plan. And when we

17 get to that, if people could state their name and make 18 their comment with regards to what they think about our

19 plan for the groundwater contamination. And we'll have a

20 period for general questions after that for people that 21 have general questions. 22 We'll also have a short period after Brian's 23 talk on the status of the closure and construction for 24 people that have questions about that. But we may have to

25 cut that short, so that we can get on through the whole

Page 5 1 agenda. But I think that we will probably be able to get

2 through this fairly quickly. We have a small group 3 tonight and a lot of people who are familiar and know a

4 lot about the site already, so we won't have to do a lot

5 of background. 6 Recent history on the McColl site: 7 Everybody is familiar with back in September we made a

8 decision to go directly to the construction of a closure

9 and containment system for the waste pits at the McColl

10 site. Shortly after that decision we amended our 11 Enforcement Order with the McColl Site Group, which is a

12 collection of oil companies that EPA has performing the

13 work, and we will — in the process of amending that 14 order, they have been now performing the design for that

15 closure and containment system. And Brian will talk a

16 little bit more about that. 17 We also have sent a letter to a part of the 18 government that has been found by the courts to be 19 involved with the disposal at the site. It happened 20 during the war years, World War II. And we've recently

21 sent a letter to both the McColl Site Group companies and

22 the government to ask them to come to the table and 23 participate in negotiations with EPA for the actual 24 construction and the long-term maintenance of that closure

25 and containment system for the sumps.

M & M CERTIFIED COURT REPORTERS Page 2 - Page 5

Transcript of Proceedings, 3-14-96 Multi-Page1 McColl Superfund Site

Page 6 1 We've gotten responses back from both 2 groups, and we're in the process of considering how to

3 proceed, whether or not to do the negotiations, or whether

4 or not to use the Order Authority that we've used to do

5 the work up to the current date, and do the construction

6 and the maintenance under that. 7 We should have some information out to the 8 community in the next month or two as to how we are going

9 to proceed on that front. We're also in the process of 10 finalizing an agreement with the McAuley LCX corporation,

11 the owners of the golf course, to release them from 12 liability at the site. 13 And we've received comments from the McColl

14 Site Group on that agreement. And we've also received

15 responses from the McAuley LCX counsel responding to

16 comments that were raised by the oil companies. We're in

17 the process of considering both of those and deciding how

18 to move forward on that agreement between the us 19 Government and McAuley LCX corporation. 20 So that's a brief summary of what's been 21 happening recently. In terms of various talks, there has

22 also been support for an action towards having Orange

23 County put the Ramparts portion of the property up for

24 sale. And if there are any questions during the general

25 comments or question period, we might have Linda — she's

Page 7

1 been working on that. Linda, if you wouldn't mind 2 answering questions with regards to the status of the sale

3 on the Ramparts property. And EPA has been providing

4 letters to the county to assure them of the various things

5 and the status of that transfer. 6 So with that, Brian, why don't you come up 7 and give your talk on the closure and containment system?

8 MR. SWARTHOUT: okay. As Mike said, my name is

9 Brian Swarthout. I work for US EPA. And I'm the Project

10 Manager for the closure system operable unit or the 11 source-operable unit. I'm just going to be giving a quick

12 overview of the status of what's going on with the closure

13 system. As Mike said, I'll also be taking a few 14 questions. 15 We want to keep the questions kind of short, 16 because the purpose of the meeting is for the groundwater

17 proposed plan. We will be here after the meeting to 18 answer more questions. And we'll be having additional

19 meetings at a later date in the coming months to talk 20 specifically about the closure system and what's - I 21 guess just further meetings for the status of the closure

22 system. 23 I want to say that we're very happy because 24 the schedule - or the design for the closure system is 25 currently on schedule. In fact, we received the

Page 8 1 conceptual design from the McColl Site Group or the oil

2 companies on March 4th. And we are currently working on

3 commenting on that design. 4 The draft conceptual design contains two 5 components. The first component is a cap. And the cap is

6 going to be — there will be two separate caps. One cap

7 will be over the Los Coyotes area. It's shown here in the

8 pink (Slide #2). The second cap will be here over at the

9 Ramparts area (Slide #2). 10 The cap in the Los Coyotes area is going to 11 be approximately — excuse me, approximately five feet

12 thick. The cap in the Ramparts area is going to be a 13 lighter cap. It's going to be approximately three feet 14 thick. This cap is significantly thinner than caps that 15 were proposed in the past. As a result, we won't have to

16 be constructing any retaining walls adjacent to or along

17 this area adjacent to the homes in the Ramparts area. 18 MR. FELTER: Brian, may I interrupt for a moment?

19 Should someone in the audience be a little 20 concerned if their house is not shown on the map? 21 MR. SWARTHOUT: Right. This was brought up 22 earlier. This figure obviously - well, not obviously. 23 But this figure is an earlier figure that we used. It's 24 just kind of a generalized schematic. But you can see 25 that there are some houses missing here (indicating) and

Page 9

1 some houses missing here (indicating). That is just 2 because this is an earlier figure. 3 There was no intention to leave those houses 4 off for any particular reason or that the houses will all

5 have to be removed or anything like that. Those were just

6 left off from an earlier figure. And all the subsequent

7 figures, and the more detailed figures, actually show this

8 area and those houses are in place. 9 So as I said, there are going to be two

10 caps: One in the Los Coyotes area, one in the Ramparts

11 area. Another component of the caps will also be a 12 gas-collection system. So this gas-collection system will

13 be constructed under the cap and will be used for the 14 collection and treatment of the gases that come from the

15 sumps. 16 The second component of the closure system 17 is a soil bentonite slurry wall. And bentonite — what 18 that basically means is they are going to be mixing soil

19 with bentonite, which bentonite is a type of clay. And

20 this will cause the slurry wall to have a low 21 permeability, and it will be used for containing gas and

22 the waste at the site. 23 And there will be two slurry walls or soil 24 bentonite slurry walls. One is ~ they're shown here with

25 the red lines (Slide #2). So there will be one all the

Page 6 - Page 9 M & M CERTIFIED COURT REPORTERS

VlcColl Superfund Site Multi-Page™ Transcript of Proceedings, 3-14-96

Page 10 1 way around the Los Coyotes area, and one slurry wall all

: the way around the Ramparts area. 3 The slurry walls will be constructed under 4 the ground surface. So when the construction is complete,

5 the slurry wall will be flush with the ground surface. 6 They will not be sticking up above the ground surface.

7 The slurry walls will he approximately anywhere from 19 to

8 39 feet below the ground surface. 9 And the reason that we chose this particular

10 closure system, the cap in conjunction with the slurry 11 wall was that: One, this system will be good for keeping

12 waste and gas inside the sumps. And it will also be good

13 for keeping water out of the sumps. And Mike will talk a

14 little bit about that with the groundwater - with the 15 groundwater portion. 16 As 1 said, we're currently reviewing the 17 conceptual design. Our comments are due to the McColl

18 Site Group on April 1st. And the design will actually be

19 finalized on December, December 4th of this year. And

20 soon thereafter construction will begin at the site. 21 As part of the construction, we will 22 probably — or MSG will require access to the backyards of

23 some of the houses that are in this area that are directly

24 adjacent to the site. In addition, MSG will be also 25 offering some of the residents in this area or the

Page 11 1 residents in this area (indicating), temporary, voluntary

2 relocation as part of the construction. 3 The other thing that I was going to talk 4 about tonight is the compatibility studies that are going

5 on. Currently, MSG is performing a series of 6 compatibility studies. And the compatibility studies are

7 going to be used to test the compatibility of the waste 8 that is currently at the site with - to test the 9 compatibility of waste with the materials that are going

10 to be used as part of the closure system. This is the 11 slurry walls, the sand, the liner ~ there's going to be a

12 plastic liner that's going to be used as part of the cap.

13 Those tests will be testing the compatibility of the waste

14 with those components. And we will be receiving the

15 results of those tests from MSG in July of this year. So

16 that's one of the current things that is going on at this

17 time. 18 So at that, I'll take a few questions and 19 then we'll move on. 20 UNIDENTIFIED SPEAKER: why is there a difference

21 in the thickness in the two caps? 22 MR. SWARTHOUT: The cap in the Los Coyotes area is

23 thicker so that it can accommodate the golf course. The

24 cap in the Ramparts area is thinner because there won't be

25 a need for the golf course. The final vegetative layer

Page 12 1 won't need to be as thick. And, also, there is a lot of 2 drilling mud in the lower Ramparts area which won't 3 accommodate a thicker cap. But primarily it's for the 4 golf course. 5 UNIDENTIFIED SPEAKER: what is the depth of the 6 benzene contamination plume? 7 MR. SWARTHOUT: okay. Mike is going to talk 8 specifically about the groundwater plume and the 9 groundwater contamination during the rest of the meeting,

10 so he can address that question. So are there any other

11 questions? 12 Then I'll just turn it over to Mike. Turn 13 the mike over to Mike. 14 MR. MONTGOMERY: That question is actually an 15 excellent segue into what I'm going to talk about, which

16 is in the culmination of the 15 years of placing and 17 monitoring wells, and monitoring water quality data at the

18 McColl site, and what we've learned over the number of

19 years. And most important, most recently with the 20 placement of a number of additional wells off site, is 21 that there doesn't appear to be a significant amount of 22 groundwater contamination at the McColl site. 23 It's: important, also, for people to 24 understand that the water that you receive in your home

25 comes from a municipal water system which is served by

Page 13 1 wells which are not in the vicinity of the site. In fact,

2 there are not a lot of - the nearest municipal well is 3 quite a distance, and it's actually cross gradient from 4 the site. 5 I want to talk about gradient, it's the 6 direction the groundwater flows. And the arrows here

7 indicate the direction that the groundwater flows 8 (Slide #3). And the nearest municipal well is about a 9 quarter of a mile over this way (indicating) or 3000 feet

10 this way (indicating). So it's important that people 11 recognize that this is not ~ immediately in the adjacent

12 area there are not any municipal wells. 13 The groundwater contamination at the McColl

14 site — you can see here that 26 wells have been placed

15 over the years. And we've monitored some of these wells

16 historically back into the 80s. Some of them have just

17 been recently placed at this site. 18 Our understanding of the site, our 19 conceptual understanding of the site — and, Brian, can

20 you flip to the next one over here on the left, looks kind

21 of like this. You know, what we've done over the last

22 recent few years is we put in a lot more wells and we've

23 done a lot of borings. 24 And over there against the wall are some of 25 the actual drawings that were done by hydrologists working


Transcript of Proceedings, 3-14-96 Multi-Page™ McColl Superfund Site

Page 14 Page 15 1 for the McColl Site Group that show the detailed layers of 1 high concentrations of those Tetrahydrothiophenes, which

2 these low permeability clays where the water that comes 2 everybody is familiar with, not only because it's the 3 through the site sort of hangs out on top of it. We call 3 longest sounding chemical but because it smells really

4 it "perched water." It's not down in this deeper regional 4 bad. And everybody is familiar with it because it's the

5 aquifer, which is about 200 feet down. 5 smell that you smell when you smell the McColl site, for

6 And what we found, in general, is that this 6 those of you that live in the neighborhood. And it's 7 "perched water" which comes from the area around the sumps 7 generally these compounds. 8 is contaminated. And it's, you know — it's got benzene 8 And what we have found is that the 9 and DCA (1,2-Dichloroethane). So this shows the perched 9 tetrahydrothiophenes have actually reached the regional

10 water quality data (Slide #5). If you can read that, you 10 aquifer in some wells. They're not in other wells. And

11 have better sight than I do. 11 so what we — you know, generally, all the water quality

12 This shows the regional water quality data 12 data tells us is that we have got shallow contamination.

13 (Slide #5). And, generally, what you see is that in areas 13 But this regional aquifer hasn't been affected by the 14 in perched water, for these compounds, which would be of a 14 site, with the exception of a few areas where we have 15 concern, if you were to drink it for your whole life, they 15 these compounds which would make the water taste or smell

16 exceed these drinking water standards. You don't 16 bad. 17 generally see those in regional wells. This DCA doesn't 17 And so with that information, we went 18 exceed the drinking water standards in this case. 18 forward and developed a feasibility study. We looked at

19 But what we found is that DCA is generally 19 different options for how we can assure that this regional

20 not found at the site. That was an exception. And what 20 aquifer stays clean. That's really the Agency's 21 we are showing here is the highest concentrations that we 21 objective. 22 found. We have got reams of data that shows that there 22 So we considered four alternatives. And 23 has been no contaminants detected in that regional aquifer 23 these are all fairly simple, straightforward alternatives

24 for a number of wells. 24 relative to the very large and complex alternatives that

25 Now, what we do see is that we have fairly 25 were considered in the past on the sumps themselves.

Page 16 Page 17

1 And this is just for addressing that groundwater 1 But, you know, we look at this alternative, 2 contamination. 2 and I'll get into it a little bit later, it's a 3 The first one is no further action. And if 3 cost-effective, preventative measure to assure that we 4 we did that, we'd basically just continue to monitor the 4 protect that regional aquifer. 5 situation. 5 Alternative #4 is groundwater extraction and 6 And the next one is institutional controls. 6 treatment. A really common way to address groundwater

7 When we do monitoring and we ask for those properties that 7 contamination is groundwater extraction and treatment systems.

8 are adjacent to the site, but off of the site, that may 8 That would involve groundwater monitoring. But we would

9 have contamination in that regional aquifer, we would go 9 also hook up some of these monitoring wells with permanent

10 to them and negotiate agreements and restrictions on the 10 pumps. 11 use of their water. And that would be basically a way to 11 We'd have to dig trenches and pump the water

12 assure that that water didn't get used - that regional 12 back to the site. We would build a small treatment unit,

13 groundwater didn't get used. 13 and we'd treat that water in that treatment unit and 14 Alternative #3, which is the alternative 14 discharge it to the city sewer system or to a pond or

15 that we're proposing, is long-term monitoring of the wells 15 something like that. 16 and a reduction of infiltration of site surface water in 16 The amount of water that would be extracted 17 order to reduce concentrations of contaminants in the 17 would be very small, because we don't have a large area of

18 perched water, and therefore to protect that regional 18 contamination that we would want to draw out of the 19 aquifer from future contamination. 19 ground. The volume would be about six gMlons per minute,

20 So what we're really concerned about is that 20 a little bit more or less. And your garden hose on full

21 there is not a lot of risks posed by the site. You know, 21 blast is about four gallons, four to five gallons per

22 right now we don't have a big plume of contamination in 22 minute. So think of it as a little bit more water than 23 that regional aquifer. So from our perspective, the best 23 your garden hose can produce on a full stream. 24 thing we can do is try to prevent the situation from 24 Can I get the other slide over here? 25 getting any worse, which we don't expect that it would. 25 So what we did, to go through this fairly


McColl Superfund Site Multi-Page™ Transcript of Proceedings, 3-14-9'

Page 18 Page 19 1 quickly, and I know this looks like a pretty tedious l Now, granted, we do have the shallow T chart, and it can be a pretty tedious analysis system. 2 contamination. But those lenses of water occur in very

3 And most of you know the nine criteria because you've been 3 thin lenses. If you were to put a well in there, you 4 drug through the nine criteria a couple of times 4 wouldn't be able to pump enough water to use those shallow

5 (Slide #7). 5 perched contaminated units. And so therefore, that's not

6 These two, "State Acceptance" and "Community 6 really a significant concern of the Agency. 7 Acceptance." this is really why we're out here talking to 7 What we're concerned about is this regional 8 you. We are going through a formal public comment period 8 aquifer which people use down in the groundwater basin and

9 to hear what people think about these alternatives. 9 which someone might want to use in the future. So there

10 State Acceptance, Caroline's here, they have 10 is not a lot of difference between these alternatives with

11 also been intimately involved in the process. Feel free 11 regards to those two criteria. Long-term effectiveness is

12 to comment if you want to ask them about their feelings 12 where you begin to see some differences between 13 about the current proposed plan that EPA has. 13 alternatives. 14 I'll go through these real quickly. Overall 14 The no-action alternative, you wouldn't 15 protection of human health and the environment and 15 really do anything. So you wouldn't have any real 16 compliance with ARARS. YOU can kind of group these 16 long-term effectiveness realized. Alternative #2, it 17 together. And, because we don't have significant 17 would provide some long-term effectiveness in that you

18 contamination in that regional aquifer there's really not 18 would assure, by negotiating these agreements, that nobody

19 a big concern in terms of protection of public health. 19 would be using this water in the future. 20 In terms of compliance with ARARS, because 20 We see Alternative #3 as having a fairly 21 we haven't exceeded the federal drinking water standards, 21 high long-term effectiveness because you are going to put

22 with the exception of that one data point, which we 22 these controls in. And over time they would serve to 23 showed, there doesn't appear to be an exceedence of any 23 reduce the concentrations of contaminants in that perched

24 federal drinking or State drinking water standards in that 24 aquifer. And over time they would prevent contaminants

25 regional aquifer either. 25 from spreading to the regional aquifer if that were to

Page 20 Page 21 1 occur. 1 Putting restrictions on properties, some people might say,

2 Also, with Remedial Alternative #4, that 2 "Well, it's no big deal. I'm not going to use the water.

3 would have a fairly high result too. That "Reduction of 3 I have got city water." It may be a bigger deal to other

4 Toxicity. Mobility, & Volume," that's sort of how much of 4 folks. 5 this stuff are you really going to treat? How much of 5 Cost effectiveness in terms of Remedial 6 these chemicals are you going to reduce and eliminate? 6 Alternative #3, it's going to be relatively cheap. 7 None of the alternatives, none of these 7 Alternative #1 is about $1.5 million for monitoring. 8 first three consider any treatment. Alternative #4 does 8 Alternative #2 is about maybe $2 to $3 million. 9 consider treatment. But you have to consider that it's a 9 Alternative #3 is about $2 to $3 million. Alternative #4

10 very small amount of water that we're treating. And then 10 is about $5 to $7 million. So #4 is quite a bit more 11 the water that we're treating has very low concentrations 11 expensive than #2 and 03, because all of them include

12 of contaminants. 12 monitoring. 13 So you could operate that extraction 13 Really, Remedial Alternative 02 is kind of 14 treatment system for years and really only effectively 14 hard to gauge because you don't know how much money you

15 treat a couple of pounds of chemicals. Which you have got 15 are going to spend on legal fees and doing the 16 to ask yourself when we get into the cost-effectiveness 16 negotiations. 17 standpoint, "Is it really worth all that effort?" 17 Alternative #3 roughly comes out to 18 Minimization of short-term — cost 18 somewhere between three-quarters to half a million dollars

19 effectiveness, I almost jumped over it. Cost 19 of actual construction costs. The balance of it is 20 effectiveness, Alternative #1, doing nothing, is real 20 monitoring. And so what we are really proposing is, in

21 cheap. 21 fact, something that's going to cost potentially less than

22 Remedial Alternative #2 is very difficult to 22 a $1 million and, yet, it could result in some long-term

23 gauge how expensive that could be. Negotiating these 23 benefit in terms of reducing the amount of contaminants

24 agreements with adjacent properties could be complex; it 24 that could go to the regional aquifer. 25 could be very simple. It's kind of hard to gauge. 25 So I think from a cost-effectiveness

M & M CERTIFIED COURT REPORTERS Page 18 Page 21


Page 22 Page 23

1 standpoint when you consider these two together, that's 1 to go out into the streets along Fairgreen or on to the 2 really why we have selected Remedial Alternative #3. 2 golf course. So you are going to have, at least, the 3 Short-term risk. None of these alternatives 3 interaction of workers and the community, which can 4 would pose any risk to the community. What you see 4 sometimes cause hard feelings. For instance, it can be a

5 reflected here is risk to workers, the workers that you 5 nuisance to the residents to have trucks out in their 6 are going to have digging trenches and using large 6 neighborhood parked in front of their house. And that

7 equipment. 7 would come with this Remedial Alternative #4. 8 One advantage of Remedial Alternative #3 is 8 Implementability. Again, Alternative #\, 9 that we are going to be working way outside the sumps. We 9 the monitoring, would be fairly easy.

10 are going to be working in that drainage area over behind 10 Alternative #2, doing these negotiations, 11 Los Coyotes. You can't even really see it from the 11 deciding who you talk to, who you don't, could be a little

12 residences along Tiffany or Fairgreen. 12 bit complex. We're not really sure what to do if people

13 Lining that drainage area, since that is a 13 don't agree to restrictions on the use of the water. 14 low-lying area where a lot of water ponds and settles 14 Remedial Alternative #3 would be really easy 15 during high precipitation events would reduce infiltration 15 to implement. We could take these plans to reduce 16 of water into the subsurface in the areas outside of the 16 infiltration, integrate them right into the design that 17 cap such as that drainage area, and if it's necessary in 17 Brian talked about, and do the construction at the same

18 areas that are not low-lying areas. But I think we will 18 time. And so this work could be performed in conjunction

19 be able to effectively do it just by addressing those 19 with the design and the construction of the closure and

20 low-lying areas. 20 containment system. Which from an implementability

21 And, then, there's really more short-term 21 standpoint would be real easy for us to do. And it would

22 risk associated with #4. You are going to have people 22 get it done fairly quickly, as quickly as other source

23 constantly going out to the site dealing with the 23 work would be done. 24 treatment system. You are going to have to lay piping and 24 Remedial Alternative #4, implementability,

25 do trenching. Some of that trenching and piping may have 25 we'd have to get permits. We'd have to site the treatment

Page 24 Page 25

1 system. We'd have to get permits for the water that we 1 MR. MONTGOMERY: As an in-situ technology or as an

2 treat. We'd have to dig the trenches. It's fairly 2 ex-situ treatment system?

3 complex to do it relative to these other alternatives. 3 UNIDENTIFIED SPEAKER: Either-or.

4 It's easy to do; EPA has built extraction and treatment 4 MR. MONTGOMERY: okay. Well, we haven't really

5 systems, and so have the McColl Site Group partners at 5 decided if we were to do the extraction and treatment

6 different sites. But relative to the other alternatives 6 system, what type of treatment would work best. So I

7 it's not quite as easy. 7 think that we've talked about various options for a type

8 That's it. That's the overview. So, again, 8 of treatment system once you get the water up to the

9 Remedial Alternative #3 here is our preferred alternative. 9 surface of the site.

10 One thing that we recognize is that there may be some need 10 UNIDENTIFIED SPEAKER: I mean, the material itself

11 to incorporate some institutional controls further down 11 is relatively close to the surface, isn't it?

12 the line if, in fact, this didn't seem to be effective. 12 UNIDENTIFIED SPEAKER: oh, you are talking about

13 However, we sort of separated these out. So 13 for the sumps, not for the groundwater?

14 when you comment, please feel free to comment on any of 14 UNIDENTIFIED SPEAKER: well, that's - I'm talking

15 these or any combination of these that you feel may be an 15 about getting the contaminated material out and also

16 effective option for the site. 16 getting to the groundwater too as part of it.

17 We've talked about them individually, but 17 MR. MONTGOMERY: For the source.

18 they can be combined. And if there's any specific 18 UNIDENTIFIED SPEAKER: It's a long-term way to get

19 questions about combining them — yeah? 19 rid of the waste.

20 UNIDENTIFIED SPEAKER: why is there no option for 20 MR. MONTGOMERY: For the waste pits themselves.

21 bioremediation? 21 One of the reasons why we haven't considered

22 MR. MONTGOMERY: I'll repeat the question. The 22 bioremediation is that this is a sulfuric acid waste.

23 question is: Why is there no option for removal and 23 It's a very low pH waste. And you would have to

24 bioremediation? 24 effectively neutralize it before you could bioremediate

25 UNIDENTIFIED SPEAKER: Removal and bioremediation. 25 it. Because in general, the pH of this waste is


McColl Superfund Site Multi-Page™ Transcript of Proceedings, 3-14-96

Page 26 Page 27

1 fairly low, it's very acidic. And you would have to go l you are giving a formal comment. -> through a neutralization — well, first you would have to 2 MR. MONTGOMERY: well, right now we're not really

3 excavate it. 3 in the formal comment portion for the groundwater. As

4 We did a trial excavation at the site a 4 soon as we get these questions out, if they are

5 number of years ago. We found that excavating this waste 5 clarification questions, then we'll stop and we'll have

6 is very difficult to do. At a minimum, you have to do it 6 the formal comment period. Fraser has a mike and he'll

7 inside of an enclosure. And the time required to excavate 7 walk around and people can comment. And I'll sit down,

8 all the waste inside of an enclosure involves a lot of 8 because you are not really addressing your comments to me;

9 time and a lot of money. 9 you are addressing them to the recorder.

10 And I think that the residents who live near 10 UNIDENTIFIED SPEAKER: Do you have any idea when

1 1 the site also felt very strongly about the excavation and 11 you will start — and use your imagination, any idea at

12 enclosure at the time that we were considering it. So 12 all when you think this whole project will be completed?

13 there's a number of steps to consider in these processes. 13 MR. MONTGOMERY: Brian, do you want me to go ahead

14 You know, bioremediation would be a very good technology 14 and answer that, the construction?

15 if, in fact, excavation were simpler for the sumps 15 MR. SWARTHOUT: Sure.

16 themselves - were simpler and more cost effective, 16 MR. MONTGOMERY: The construction of the closure

17 and then the subsequent neutralization of that prior to 17 and containment system should start sometime early next

18 the bioremediation were, in fact, easy and effective and 18 year. So January, February, March. The design will be

19 cost effective. 19 completed in December. And that construction is scheduled

20 And so --1 mean, that's just my cut on 20 to take anywhere from ten months to a year, maybe a little

21 those technologies and how they would or would not be 21 bit more than a year. So, roughly, two years.

22 applied to the sources shown. We've already decided on a 22 UNIDENTIFIED SPEAKER: It could be completed in

23 remedy for the sumps themselves, and that's a closure and 23 two years?

24 containment system. 24 MR. MONTGOMERY: Done.

25 MS. GILMOUR: Can we get people's names, also, if 25 UNIDENTIFIED SPEAKER: You were talking about ...

Page 28 Page 29

1 MR. MONTGOMERY: with some additional stuff. Like 1 But, you know, we can under Superfund

2 I think, with the golf course, it may take some additional 2 authority not get permits. We have to comply with them,

3 time to do the landscaping and to sod it. 3 but we don't necessarily have to get them all the time.

4 UNIDENTIFIED SPEAKER: That's COSmetic. 4 So that's a good question.

5 UNIDENTIFIED SPEAKER: You were talking about 5 MR. BENNETT: Mike, one comment this year, your

6 permits and things of that nature and getting approvals. 6 visual aids have really improved over the last year or so.

7 EPA is the government, if you can't get permits, then nobody 7 They are really, compared to a couple years ago,

8 can get permits. 8 impressive.

9 MR. MONTGOMERY: There are other governments. I 9 I have a real comment, a question. Brian

10 think if you talk to any local businessman in Orange 10 talked about the cap design and you are doing the

11 County they'll probably tell you there are too many 11 underground water. They come together on that area just

12 government regulations. But you are basically correct. 12 north of Los Coyotes. Could you comment on some of the

13 UNIDENTIFIED SPEAKER: Let's be done with this. 13 design thinking that put the wall out there and how that

14 This has been going on for over 15 years. 14 combines with Alternative #3. You know - do you

15 MR. MONTGOMERY: Right. We see that as an 15 understand the question? Could you give us a little bit

16 advantage to our option in that we wouldn't have to get 16 more thinking that went into putting the wall out there?

17 any permits to do this. 17 How are you going to worry about the pooled water that's .

18 UNIDENTIFIED SPEAKER: Good. 18 going to be on top of it?

19 MR. MONTGOMERY: But if you are going to discharge 19 MR. MONTGOMERY: Yeah, it's more philosophy.

20 water, we don't actually have to get a permit, but we 20 Okay? People can generally see this.

21 might ask the oil companies to get a permit from the local 21 The sump caps are going to be here and here

22 Regional Water Quality Control Board just so that the 22 (indicating), right (Slide #3)? And everybody knows this

23 Regional Board knows that if we were to do an extraction 23 is all on a hillside. You have a lot of up-land area

24 option, that they would know that we were pumping water 24 here, right? And it's undeveloped. And it could become

25 into a creek or something like that. 25 developed. And if it were to become developed, you would



Page 30

1 have even more run off from this up-land area. And that

2 water runs from the up-land area under Rosecrans in a

3 culvert right about there (indicating) and on to the site.

4 And it eventually runs on to the golf course (Slide Wi).

5 And so you have a large area here that in

6 the winter season gets a lot of water. And you get

7 standing water. And you actually get a creek out there

8 during high-rain events. So philosophically, Chuck — you

9 have to listen to my answer if you ask a question. It's a

10 rule. We would line this area along here (Slide #3)

11 (indicating). Potentially look at diverting the water

12 that runs onto the site in really high-peak events, if

13 that makes sense. But for the most part, we just want to

14 keep this water from ponding up in here and getting into

15 the shallow perched units and moving solubilized

16 contamination, which is contaminants, not the hard, gooey

17 waste stuff that comes to the surface. But like sugar in

18 your tea when you stir it up, dissolves in water. The

19 chemicals that are in the tar do that to some degree.

20 They get into the water ~ you understand

21 these processes, but I'm generally answering the question

22 for everybody. They get into the water and that water

23 flows down. And sometimes those contaminants adsorb or

24 attach themselves to clean soil particles underneath the

25 pits themselves. And so you will get 40, maybe 30 feet

Page 31

1 underneath the bottom of that black, gooey stuff. And

2 you'll have soil that looks clean but smells bad.

3 And if you introduce - if you allow this

4 water to continue to filter through that area, it will

5 over time release these chemicals from those soil

6 particles and get back into the water and potentially go

7 down to the regional aquifer.

8 So, philosophically, the notion here is that

9 we are just going to dry out that whole area underneath

10 the sumps themselves, not let any water get in there so

11 that none of the waste that's down there, not the black,

12 gooey stuff but the absorbed low concentration

13 contaminants, gets into that regional aquifer. That's the

14 philosophical approach to that alternative.

15 UNIDENTIFIED SPEAKER: can I ask another one?

16 MR. MONTGOMERY: Yes, feel free.

17 UNIDENTIFIED SPEAKER: Even though the benzene

18 hasn't reached the aquifer yet, because it doesn't move as

19 fast as some of the other contaminants, right, so will it

20 reach it in 20 years even if you contain it as you

21 propose?

22 MR. MONTGOMERY: well, one thing that I think we

23 can consider here is that the waste has already been out

24 here for 50 years. And so we've had the sumps out there

25 generally in an unlined and uncapped condition for the

Page 32

1 last 50 years.

2 So I would expect that the potential

3 migration rates that would occur at the site, we would see

4 that migration of those contaminants. And benzene moves

5 fairly quickly relative to some of these other

6 contaminants.

7 So we would expect to see it. It also

8 degrades very quickly. And the spreading effect of these

9 perched units may have done a lot to effectively

10 allow dispersion and really just an overall dilution of

11 the concentrations of the benzene and the higher end

12 chemicals that would be of concern.

13 UNIDENTIFIED SPEAKER: But part of this is perched

14 and part of it isn't, right? So part of it-

15 MR. MONTGOMERY: No. The water is perched before

16 it reaches the regional aquifer. It has to go through a

17 couple of lenses. That's kind of a simplified diagram

18 (Slide #4). And I think if you can take a second and go

19 back and look at these charts back here, you can see those

20 tan layers are all lower permeability layers that the

21 water has to go through before it gets to that regional

22 aquifer.

23 So no matter what part of the site the water

24 goes through, it's got to go through some of those layers.

25 And that takes time and spreads it out and dilutes it and

Page 33

1 disperses it.

2 UNIDENTIFIED SPEAKER: Mike, can you state it

3 clearly? I'm confused, and there might be other people

4 too. Basically, you are going to issue a ROD (Record of

5 Decision) regarding groundwater that says, since you've

6 chosen Alternative #3, you follow the ROD or the solid

7 waste that is put on the cap. Is that what it is?

8 There's no real enforcement? There's nothing going on

9 other than what you are saying to follow the resolution

10 that you've decided already?

11 MR. MONTGOMERY: No. I think we will have to

12 after the remedy selection process, which is after this

13 public comment period which is going to end on April the

14 5th, so if you have comments that you want to give us in

15 writing and not here tonight, if you are bashful, or you

16 just want to put it in writing what it is you have to say,

17 send that to us before April 5th, and we will address

18 those comments in our Record of Decision. Most of you all

19 know that process, because you have commented before on

20 the decisions. 21 But then we would make the decision and then

22 we would potentially issue an order or negotiate that.

23 But we -- the advantage of this one is that we integrate

24 it right into the design work. So if there was an order,

25 we just say, "Hey, do this stuff right along with the



Page 34 Page 3:

1 other stuff you are doing." Or if we were negotiating it, 1 UNIDENTIFIED SPEAKER: what would there be to

2 then we would put it all on the table and negotiate it. 2 enforce?

3 UNIDENTIFIED SPEAKER: So your Record of Decision 3 MR. MONTGOMERY: Well, it would be an additional

4 is to follow through with Alternative #3? 4 scope. It would be a little extra work. We would be 5 MR. MONTGOMERY: Right. 5 tacking a little extra work on the work that we already

6 UNIDENTIFIED SPEAKER: Can you, therefore, speed 6 have in the order. And there's still a question out there

7 up the process at all by - 7 right now as to how we are going to do the construction

8 MR. MONTGOMERY: We can speed up Alternative #3 so 8 from an enforcement standpoint. I covered a little bit —

9 that it's integrated into that design. I have confidence 9 UNIDENTIFIED SPEAKER: who's going to pay the

10 we can speed it up so that it's integrated into that 10 bills?

11 design and done with the closure and containment system. 11 MR. MONTGOMERY: It's just a question of whether

12 So we can do a conceptual — Brian just said 12 or not we negotiate an agreement or whether or not we use

13 we just got the conceptual. If we get the remedy 13 an order like we've used.

14 selection soon, we can do it. And I think that in 14 MS. GILMOUR: would you please repeat the

15 general, the McColl Site Group has felt that this is an 15 question?

16 acceptable alternative. So from a sort of precedential 16 MR. MONTGOMERY: I'm sorry. I said I was going

17 standpoint 1 think we have got a good alternative in that 17 to do that and I didn't. Sorry.

18 all the parties agree. EPA, assuming the community agrees, 18 The last question was: How are we going to

19 MSG generally agrees that it's a good plan, or it's my 19 get this work done from an enforcement standpoint and when

20 understanding at this point that they do. 20 is it going to get done?

21 Then I think they would be open to 21 Okay. We can go to the official comment

22 integrating it into the ongoing work. We could get an 22 portion. I'm going to sit down. Fraser is going to stand

23 enforcement mechanism out there if we needed to do that, 23 up. If you could state your name, spell it if it's a

24 and have it done by December when the design is going to 24 difficult spelling. And what else was I supposed to say?

25 be done. 25 MR. FELTER: You're taking all my lines.

Page 36 Page 37 1 MR. MONTGOMERY: Sorry. 1 I live at 1819 Fairgreen Drive in Fullerton. And I agree

2 MR. FELTER: can you hear me? 2 with your plan as proposed. And I thank you for all your

3 All right. This is the officially required 3 work.

4 public comment period for this proposed plan for the 4 MR. FELTER: Thank you.

5 groundwater at this McColl site. The way this works is as 5 Do we have any other comments? Yes,

6 Mike had described. You are invited to comment and we 6 Mr. Bennett?

7 will be receiving those comments. The transcriptionist 7 MR. BENNETT: My name is Chuck Bennett,

8 will take it down. Again, she would appreciate you 8 B-e-n-n-e-t-t. I'm a resident of Fullerton and part of 9 spelling your name if it's an unusual spelling, and also 9 the FHCA. I would like to make the comment that the

10 your address if possible. 10 selection of #3 or #1 would have been the fastest

11 We will not respond this evening to your 11 alternatives at implementation. And I'm pleased to see

12 statements unless there is some matter of fact that is 12 that the Agency has chosen one of the prompter remedial

13 misstated. For instance, if someone says "black" is 13 plans for the groundwater.

14 "white," Mike or Brian will correct that. But that's the 14 And I think — my sense of the community is

15 only time we will respond. 15 that they are supportive of either #1 or #3 as the

16 The responses to your comments this evening 16 choices.

17 then will be incorporated in an official responsiveness 17 MR. FELTER: Thank you.

18 summary, and that will be filed as part of the 18 Yes, sir?

19 administrative record. 19 MR. SIEGEL: My name is Gene Siegel, S-i-e-g-e-1.

20 Any questions as far as the process this 20 I live at 2617 Tiffany Place. 21 evening? All right. I hereby declare the comment period 21 Looking over the four alternatives, I would 22 open. Would anyone like to comment on the proposed plan? 22 agree with EPA that Alternative #3 does make the most

23 Yes, Mr. Bushey? 23 sense. From looking at the factors of overall protection,

24 [Public comments begin.] 24 long-term effectiveness, cost effectiveness, and 25 MR. BUSHEY: My name is Dave Bushey, B-u-s-h-e-y. 25 short-term risk, if you look at all four of those factors,

M & M CERTIFIED COURT REPORTERS Page 34 Page 37


Page 38

1 they seem to be the best overall of all the alternatives.

2 MR. FELTER: Thank you.

3 Do I have another comment? Yes, Mr. Olquin?

4 MR. OLQUIN: It's Alex Richard Olquin,

5 O-l-q-u-i-n. My address is 1506 Baronet Place, City of

6 Fullerton. I'm a member of FHCA. I agree with

7 Alternative #3.

8 There is a concern I have regarding down the

9 road that long-term maintenance and monitoring, that

10 diligence is served. And that I would hope that in the

11 issuing of the ROD, that an explanation would be made and

12 comments given by US EPA regarding that MSG will stand by

13 and monitor the wells and that we will not have problems

14 hereafter, once the 30-year period is over or maintenance

15 of the cap and implementation of their orders.

16 MR. FELTER: Thank you.

17 I've just been reminded that several times

18 this evening during this period the initials "FHCA" have

19 been used. For the record, that stands for the "Fullerton

20 Hills Community Association."

21 Do I have any other comments?

22 All right. Well, hearing no others, I

23 officially conclude the official comment period and turn

24 the meeting over to Mike and Brian for general questions.

25 Thank you.

Page 39

1 [End of public comments.]

2 MR. MONTGOMERY: Thanks, Fraser.

3 So are there any other general questions

4 about the site status?

5 UNIDENTIFIED SPEAKER: I'm from Newport Beach and

6 the reason I came here is that I feel if it gets

7 contaminated into everybody's water, it's real difficult

8 to reverse it once it happens. And y'ou are playing with

9 something -- you're talking about $1, $2, $3 million, but

10 it's a big, big issue.

11 So what are you going to do when it gets

12 dangerous? How do you know when it gets dangerous?

13 MR. MONTGOMERY: That's a good question. The

14 important thing to keep in mind is that under the

15 Superfund program, we have a five-year review period. And

16 we go back every five years and review the remedies that

17 we select. They're not often changed.

18 But in the case of groundwater remedies,

19 they are quite often modified. And there would be an

20 opportunity to modify this decision during that five-year

21 review period.

22 And I think that we're real concerned. And

23 I think we have taken quite a long time to make

24 sure that we can make a decision like this. You know, it

25 almost takes a longer time to make a decision not to do a

Page 40

1 lot than it takes to make a decision to do a whole lot,

2 because we've got to say with confidence that we don't

3 think it's a real significant problem.

4 Now, built into these plans is $1.5 million

5 of monitoring that's intended to go into perpetuity.

6 UNIDENTIFIED SPEAKER: But it is Superfund, SO

7 it's not benign. It's a big deal.

8 MR. MONTGOMERY: it's a fairly big deal. But I

9 think what you have also got to take into account is that

10 even though there is a hundred thousand cubic yards of

11 waste out here, this is not the type of waste that often

12 serves as being a real problem for groundwater

13 contamination. That's a real generalization.

14 But in any community you have got leaking

15 underground storage tanks that have pure product that go

16 into regional aquifers where the water is real shallow.

17 You know, that could potentially pose a greater threat

18 than the McColl site as we know it. And it hasn't been

19 investigated yet.

20 So you have to weigh all these risks. And

21 even though Superfund, you know, it's a big deal, and I

22 can tell you the reason it's a big deal is because of the

23 hundred thousand cubic yards of waste that's at the site.

24 UNIDENTIFIED SPEAKER: That's why it's one of the

25 top five sites in the United States.

Page 41

1 MR. MONTGOMERY: But just because you have got

2 this big source, doesn't mean that you automatically have

3 a big groundwater contamination problem. You know —

4 that's why you spend a lot of time investigating it.

5 Gene Siegel had his hand up, I'm sorry.

6 MR. SIEGEL: AS I indicated earlier, I'm in favor

7 of Alternative #3. But just as a question, #2, you

8 indicated that there are negotiations. And naturally as

9 well, some people are going to be curious about that

10 (inaudible) point of view (inaudible) EPA is going to pay

11 everybody $100,000 to put a well in their backyard, you

12 may have everybody go into Alternative Wl. So that needs

13 some clarification.

14 MR. MONTGOMERY: well, I think that at the time

15 that we talked about this Alternative (#2), we would be

16 talking about ~ EPA would prefer not to implement these

17 remedies. And we're going to ask the McColl Site Group

18 and quite possibly the section of the government that's

19 found liable to implement the remedies, and so there would

20 be negotiations. 21 And we would have to address the fact that,

22 hey, maybe some people are going to say, "No way, I'm not

23 going to do this unless you give me a whole bunch of

24 money." Then we have to put a price tag on it and say,

25 "Well, what's it worth?" And this is difficult. I mean,



Page 42

1 that's sort of the problem with that Alternative (#2).

2 There's different ways to approach it. But

3 you know, do you want to have people have to deal with

4 restrictions on their deeds or how you enforce it with

5 time? You know, unless you have a deed restriction — if

6 you don't have a deed restriction then you are sort of

7 going on a hand shake and a promise.

8 And that's great for the residents that live

9 there now or whoever lives next to the site, but what

10 about in 50 years or 100 years? There's a lot of

11 hypothetical questions you can get into with that

12 particular option.

13 One of the reasons why we didn't pick it

14 also is that the Regional Board doesn't particularly like

15 it. And the Orange County Water District, they both said

16 that they weren't particularly fond of it.

17 And it may be something that would be

18 considered in a five-year review period. If you find

19 that, in fact, the concentrations of the regional aquifer

20 are getting worse or a little bit worse or they are not

21 getting any better, you might go out there and say, "Hey,

22 let's talk to the people that live next to the site, the

23 people that own property near the site to try and get them

24 to agree with us not to put any wells in." The likelihood

25 that people are going to put wells in is real low.

Page 43

1 UNIDENTIFIED SPEAKER: That's the question I

2 asked. Obviously, Alternative #3 makes sense. If you

3 look at — if you weigh the factors of high, medium and

4 low — you could put a point value of high, medium and

5 low. And the important fact is it comes up better than

6 the other alternatives.

7 But your assumption is predicated on that

8 fact that there are no wells in the area. And that's why

9 #2 is there to stop people from having wells. I don't

10 foresee putting wells there. I'm not sure anyone would

11 since you have the ability to get water from Fullerton.

12 But how do you restrict somebody — let's

13 say you have ten people in the area who want to put a well

14 in. Is there going to be some restrictions because they

15 put a well in? Aren't they going to be pulling up

16 contaminants?

17 MR. MONTGOMERY: Legally we can't. Legally you

18 can't. Legally people have the right to their — there's

19 a legal term for them. But, basically, your property line

20 goes down. And it includes all that stuff down there. So

21 if you really want to put a well in; you can do it.

22 It wouldn't make any sense for a residential

23 person living in that community to want to put a well in.

24 You are already served by water. It would only cost you

25 more money to install a well and operate a well.

Page 44

1 UNIDENTIFIED SPEAKER: So why have #2, because

2 Alternative #2 only pertains to -- you know, negotiating

3 people not to have a well. Other than that, #2 and #\

4 seem to be the same.

5 MR. MONTGOMERY: They're real similar. The only

6 difference is the agreement not to put the well in.

7 Next question?

8 UNIDENTIFIED SPEAKER: well, within the City of

9 Buena Park they would have to go through the city to get

10 permits, and that would be overlooked — that would take a

11 look at that for one.

12 The most obvious one is Mr. McAuley who

13 would like to have water out of the ground, then he

14 wouldn't have to pay the city to water the golf course.

15 But that would be ~ because he would be using more water

16 than any single resident within the whole area. But, you

17 know, he would still have to go through the city for

18 permits even though it's his property.

19 MR. MONTGOMERY: A well permit.

20 UNIDENTIFIED SPEAKER: A well permit, plus the

21 State.

22 MR. MONTGOMERY: Would they deny the permit, do

23 you think?

24 UNIDENTIFIED SPEAKER: it all depends on what

25 happens.

Page 45

1 MR. BENNETT: Mike, I think one of the aspects you

2 didn't raise is that in the groundwater study that's been

3 done, there's been a very intense risk assessment of the

4 contaminated water in both the amounts of contaminants and

5 the levels. And they have not been found to be a terrible

6 risk — I don't know what the right term is. But they are

7 not deemed particularly risky. The figures have been very

8 low in terms of risk.

9 And that's why the method of control is not

10 as extreme as, for instance, if there were high levels of

11 known carcinogens, that you'd say, "Well, we do have to

12 pump and treat," or something like that. So that's one

13 aspect of it. I think that's important.

14 MR. MONTGOMERY: sure, okay.

15 Go ahead, Richard.

16 MR. OLQUIN: I had a question for you, Mike.

17 Something that has been troubling me for a while with

18 regards - I know that there is a legal side of this

19 involvement or branch of the government. Currently MSG is

20 on the site doing the work.

21 Now, in regards to both the groundwater,

22 plus implementation of the cap, even though MSG is doing

23 the work now, if at a later time it's ruled in court that

24 culpability falls onto the government, in essence, the oil

25 companies then seek reimbursement from the government.



Page 46

1 What's going to happen to us if there is a problem 15

2 years from now as opposed to 30, and it's found that no

3 longer is it the case that MSG is found to have any

4 responsibilities as far as financially helping us with the

5 situation?

6 MR. MONTGOMERY: it's my understanding in the

7 process of that ruling that they're going to go through an

8 allocation hearing process, and then a judge is going to

9 determine a relative percentage of responsibility. And

10 that allocation and the ruling could subsequently be

11 appealed.

12 And so I think what you'll find is that the

13 parties are going to be arguing over whether or not the

14 ruling is fair. And then there will be allocations,

15 interim allocations. But what you won't find, because

16 this particular judge has already ruled that the McColl

17 Site Group Companies are responsible parties, they will

18 not be let off the hook.

19 In other words, the judge is not likely to

20 say, "I was wrong about my ruling about this group of

21 people being responsible and now this group of people is

22 responsible." He's going to throw all those people into a

23 pot and say, "Well, you know, you're responsible for "X"

24 percent and you're responsible for "Y" percent." And then

25 somebody is going to appeal it.

Page 47

1 So the fact of the matter is that a lot of

2 money is going to change hands between these parties. But

3 in the meantime, you know, we'll continue to do the work;

4 we'll continue to ask the McColl Site Group to do the

5 work.

6 UNIDENTIFIED SPEAKER: what I was asking more was,

7 if there's a problem down the road?

8 MR. MONTGOMERY: Like 15, 20 years?

9 MR. BENNETT: Yeah. We live in earthquake

10 country. If it cracks open and falls on the heads of

11 government, are we suddenly going to have to fight the 100

12 pound gorilla?

13 MR. MONTGOMERY: who knows in 15, 20 years, is

14 there going to be a Superfund?

15 MR. SIEGEL: l think he answered the question. I

16 just don't think it was understood, your answer.

17 What happens is (inaudible).

18 COURT REPORTER: Excuse me, I cannot hear you.

19 Can you please use the microphone?

20 MR. MONTGOMERY: Can you use the microphone?

21 MR. SIEGEL: Basically, you have a situation here

22 where the courts are going to determine that there's

23 multiple defendants in the case. The multiple defendants

24 are the McColl Site Group, maybe McAuley, it may be the

25 government. Whatever it is, it's multiple defendants.

Page 48

1 The court will then determine the percentage

2 of liability. That is what the McColl Site Group probably

3 has done by bringing the government into a federal case.

4 They want some declaratory relief. They want the court to

5 determine the rights and responsibilities of the parties.

6 They want some indemnification, money back.

7 They want contributions, some money back.

8 They want the court to determine the percentage of

9 liability; how much percent they have to pay, how much

10 percent the government has to pay.

11 When the court make its ruling, whatever

12 that ruling is, and after all the appeals, there will be a

13 determination of 100 percent liability. But it may be

14 prorated, 53/47, 60/40, some number, so that if something

15 occurs down the road, there is still a judgment.

16 And down the road, whoever's percentage of

17 liability is their percentage, then they'll have to absorb

18 their share. And if they pay 100 percent, they can go

19 after the other party for a contribution for that 50, 60

20 or 40 percent. And that's reciprocal back and forth,

21 whether it's the McColl Site Group or the government or

22 some other entity.

23 So whatever decision is made now, is the

24 decision forever. You just won't have to relitigate it

25 later on. You won't have to worry about relitigating it

Page 49

1 theoretically because there will be a final determination

2 now in the present court hearing.

3 MR. MONTGOMERY: It helps to have a judge in the

4 neighborhood. I couldn't have done that.

5 But basically, I think another aspect of

6 that question is who is going to be managing the

7 contractor? Who's going to be responsible for going out

8 there and doing the inspection and checking the wells?

9 And the answer to that is we haven't really found out yet.

10 We don't really know yet. That's an issue.

11 MR. SIEGEL: And that's a big problem whether it's

12 the private sector or public sector, whether it's the

13 government or MSG, different rules apply. And if the

14 government controls the hiring of the contractor, that

15 could take years because of the different bidding

16 processes and the different things that have to be done.

17 If the McColl Site Group does that, they can

18 handle it differently, and it can be done a lot faster.

19 So, hopefully, I think the public here, if there is any

20 comment to be made, I think the community here would

21 rather have the McColl Site Group retain the contract,

22 because it will be a lot faster. It's a different bidding

23 process. They can handle it a lot faster than going

24 through the government bidding. At least, that's my

25 understanding of the difference.

Page 46 Page 49 M & M CERTIFIED COURT REPORTERS


Page 50

1 UNIDENTIFIED SPEAKER: (inaudible).

2 MR. MONTGOMERY: Operations and maintenance, did 1

3 say "O" and "M"? Operations and maintenance.

4 UNIDENTIFIED SPEAKER: I get a feeling from the

5 comment from the gentleman from Newport Beach that he's

6 not real sure that the community here feels comfortable.

7 In other words, are we taking the short route out to the

s detriment of the entire county? 9 And you may want to go through how many

10 wells have been dug and tested, and the fact that the

11 majority of the wells, the vast majority of the wells,

12 show absolutely nothing, and that the amount of waste

13 that has been found is extremely small. And that that

14 amount has not been going up. In fact, there's been some

15 cases going down or almost nondetectable.

16 unidentified SPEAKER: can 1 make a comment? A

17 plume can be like this (indicating). A plume is a

is pyramid, inverted pyramid. You see nothing at the

19 beginning, and then all of a sudden you have got a lot.

20 MR. MONTGOMERY: 1 don't exactly follow you. I

21 mean, you know, it might be -- you know, if you want to

22 talk specifically about the hydrology of the site and you

23 want to take a second. Marina West with the Orange County

24 Water District, who is sitting behind you with the

25 glasses, has studied these maps. She knows the subsurface

Page 51

1 very well. Melitta Rorty is here with ICF. Both of them

2 are hydrologists, and both are very familiar with the

3 subsurface at the site. 4 We've put a lot of wells out there. We have

5 done a lot of analytical work and I think we have a pretty

6 good handle on it. 7 Feel free to investigate that work. It will

8 be good to know that somebody besides us has read it.

9 UNIDENTIFIED SPEAKER: Mike, we've been a little

10 bit - there haven't been very many groundwater meetings

11 in the last couple of months. And I think at the last

12 kinds of ones we were discussing the fourth quarter

13 monitoring results. And at the time the levels of

14 contamination that were seen, the low levels, were

15 declining in most wells I believe.

16 Is there a plan to continue that kind of

17 monitoring or an abridged version of monitoring or is that

18 going to be incorporated in the general monitoring of the

19 site? 20 MR. MONTGOMERY: we're going to continue to do

21 that monitoring. We might modify the monitoring plan a

22 little bit. And I think we are going to put one, quite

23 possibly two more wells further out here (Slide #3).

24 Because we are concerned that this well, P-10L, which is

25 in the upper portion of the regional aquifer has got some

Page 52

1 of these Tetrahydrothiophenes in the 100 to 200 range.

2 And we'd really like to see a clean or a

3 very close to clean well in that regional aquifer out

4 here, so that we can definitively say ~ and maybe a

5 couple of them. I think it has been pointed out to

6 complement these other clean wells that are in the

7 regional aquifer to assure that we are not missing the

8 plume. 9 In fact, we have got a clean well in the

10 regional aquifer, and the plume is going off over here or

11 is going off over here (indicating), between our

12 monitoring points. 13 And in this case, at the moment, we have got

14 two or three in that regional aquifer. And we'd like to

15 get a few more out here. 16 And if that shows something totally

17 different, then I don't want to be back up here saying we

18 made a big mistake. Okay.

19 Thank you all for coming tonight. We'll

20 hang around for a little while afterwards if you want to

21 ask any questions.

22 Linda, do you want to give a little

23 two-minute update on the status of the property transfer?

24 MS. LEQUIRE: well, real briefly. The property ir

25 question is the Rampart property. We're continuing to

Page 53

1 work with the County of Orange to get it on the Board of

2 Supervisors' agenda, so it can move forward. But in the

3 meantime, it actually is moving forward. There's a lot

4 of work being done between a lot of attorneys. The

5 attorneys representing Mr. McAuley, representing the

6 County of Orange and representing MSG.

7 But from all indications, I've had the

8 opportunity to talk to all the supervisors' offices. They

9 know that it's going to be coining forward, hopefully, in

10 the next couple of weeks to them. And I think it looks

11 real positive. I have felt that way for sometime. And I

12 do think that we have a real good opportunity to resolve

13 the Rampart property ~ ownership of the Rampart

14 property. 15 MR. MONTGOMERY: Great. Thank you.

16 Thanks everyone.

17 (END OF PROCEEDINGS.)

18

19

20

21

22

23

24

25


EXHIBIT C

MARCH 14, 1996

PUBLIC MEETING COMMENTS

Mr. Felter: I hereby declare the comment period open. Would anyone like to

comment on the proposed plan?

Yes. My name is Dave Bushey, B-u-s-h-e-y. I live at 1819 Fairgreen Drive

in Fullerton. And I agree with your plan as proposed. And I thank you for

all your work.

Thank you. Do we have any other comments?

Yes. My name is Chuck Bennett, B-e-n-n-e-t-t. I'm a resident of Fullerton

and part of the FHCA. I would like to make the comment that the selection

of #3 or #1 would have been the fastest alternatives at implementation.

And I'm pleased to see that the Agency has chosen one of the prompter

remedial plans for the groundwater.

And I think - my sense of the community is that they are supportive of

either #1 or #3 as the choices.

Thank you. Yes, sir?

My name is Gene Siegel, S-i-e-g-e-l. I live at 2617 Tiffany Place. Looking

over four alternatives, I would agree with EPA that Alternative #3 does

make the most sense. From looking at the factors of overall protection,

long-term effectiveness, cost effectiveness, and short-term risk, if you look

at all four of those factors, they seem to be the best overall of all the

alternatives.

Mr. Felter: Thank you. Do I have another comment?

Mr. Olquin: Yes. It's Alex Richard Olquin, O-l-q-u-i-n. My address is 1506 Baronet

Place, City of Fullerton. I'm a member of FHCA. I agree with Alternative

#3.

There is a concern I have regarding down the road that long-term

maintenance and monitoring, that diligence is served. And that I would

hope that in the issuing of the rod, that an explanation would be made and

comments given by US EPA regarding that MSG will stand by and monitor

the wells and that we will not have problems hereafter, once the 30-year

period is over or maintenance of the cap and implementation of their

orders.

Mr. Bushey:

Mr. Felter:

Mr. Bennett:

Mr. Felter:

Mr. Siegel:

Mr. Felter: Thank you. I've just been reminded that several times this evening during

this period the initials FHCA have been used. For the record, that stands

for the "Fullerton Hills Community Association."

Do I have any other comments?

All right. Well, hearing no others, I officially conclude the official comment

period and turn the meeting over to Mike and Brian for general questions.

Thank you.

v.

EXHIBIT D

WRITTEN COMMENTS FROM STATE OF

CALIFORNIA AND

MCCOLL SITE GROUP

STATE OF CALIFORNIA—CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY PETE WILSON. Governor

too P STREET. 4TH FLOOR P.O. BOX 806 SACRAMENTO. CA 95812-0806

DEPARTMENT OF TOXIC SUBSTANCES CONTROL

(916) 322-8046

March 29, 1996

Mr. Michael Montgomery Remedial Project Manager U.S. Environmental Protection Agenc Hazardous Material Division 75 Hawthorne Street, MS: H-6-1 San Francisco, CA 94105.

TopA.V^ Ffom(l(vyo\in-e

Cojoept.r-vjA \ 0,1 tVFSC

McCOLL GROUND WATER OPERABLE UNIT PROPOSED PLAN

Dear Mr. Montgomery:

The California Department of-Toxic Substances Control (DTSC) has reviewed the United States Environmental Protection Agency's (U.S. EPA) Proposed Plan (Plan) for the Ground Water Operable Unit at the McColl hazardous waste site. U.S. EPA issued the Plan on February 27, 1996 in the form of a fact sheet titled "EPA announces proposed plan for contaminated groundwater at the McColl Superfund Site", February 1996.

The DTSC has been given the opportunity to review and provide comments to U.S. EPA on draft and final versions of the various documents U.S. EPA used in developing the Plan. The documents reviewed included those of the remedial investigation, feasibility study (GWFS), and the baseline risk assessment, which were prepared by either U.S. EPA's contractor or the McColl Site Group, the responsible parties. Also reviewed were the applicable or relevant and appropriate requirements (ARARs), and the nine criteria analysis, both of which were included in the GWFS. (A formal alternatives risk assessment document was not prepared). Individuals reviewing the Plan and the various support documents include Dr. William Vance and Dr. David Chan of the Office of Environmental Health Hazard Assessment, Ms. Kathleen Considine of DTSC's Geological Services Unit and Ms. Caroline Rudolph, DTSC's project manager for the McColl Site.

The DTSC's comments and concerns regarding the Plan are derived from review of the draft and final documents along with that of the Plan. The Department's comments on the Plan are as follows, with Ms. Considine's comments (related to the GWFS) provided as an attachment to further clarify DTSC's primary concern with the presently proposed Plan:

NAR-29-1996 12=07 TOXIC SUESTANCES CONTROL A. 0^/04

Mr. Michael Montgomery March 29, 1996 Page 2

Proposed Plan

Conceptually, U.S. EPA's Plan of infiltration reduction and long-term monitoring appears to be realistic and implemented)le considering the minimal contamination currently found within the existing monitoring system. The Plan, denoted as Alternative 3 in the fact sheet, does lack an element of the alternative as it was previously described in the GWFS: that of institutional controls. Institutional controls are a means of ensuring the efficiency and integrity of the long-term monitoring system. OTSC recommends that U.S. EPA's final Plan include at a minimum the contingency of placing appropriate institutional controls if data review of the completed long-term monitoring system (i.e., including the additional one or two wells proposed as part of the Plan) indicates that such controls are needed.

If you have any questions regarding the DTSC's comments and concerns regarding the Plan please contact me at (916) 324-2857.

Enclosure

cc: Mr. Robert Holub Santa Ana Regional Water Quality Control Board 3737 Main Street, Suite 500 Riverside, California 92501-3339

Ms. Marina West Orange County Water District P.O. Box 8300 Fountain Valley, California 92728-8300

Mr. Lynton Baker California Air Resources Board P.O. Box 2815 Sacramento, California 95812-2815

Sincerely

Caroline Rudolph Sr. Hazardous Substances Scientist Special Projects Branch

_-nHK-^y-iyyfa TOXIC SUESTflNCES CONTROL

STATE OF CALIFORNIA—CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY

P.03/04 PETE WILSON, Govnrnvr

400 P STREET. 4TH FLOOR

P.O. 80X806

SACRAMENTO. CA 95812-0806

DEPARTMENT OF TOXIC SUBSTANCES CONTROL

M E M O R A N D U M

To: Caroline Rudolph Site Mitigation Division 301 Capitol Mali, Second Floor Mail: P.O. Box 806 Sacramento, California 95812-0806

m/trm From: Kathleen Considine

Site Mitigation Branch Geologic Services Unit 301 Capitol Mall, Fourth Floor Mail: P.O. Box 806 Sacramento, California 95812-0806

Reviewed by: Marie McCrink, RG, CHG Geologic Services Unit

Date: March 21,1996

Subject: McColl Final Groundwater Feasibility Study

INTRODUCTION

As requested, I have reviewed the document Feasibility Study Report, Groundwater Operable Unit, McColl Site (GWFS), dated February 7,1996. The GWFS was prepared by ICF

Technology Incorporated (ICF) for the United States Environmental Protection Agency (U.S.

EPA). The GWFS presents the remedial alternatives for contaminated groundwater at the McColl Site.

CONCLUSIONS & RECOMMENDATIONS

The chosen Remedial Alternative 3 (RA 3) involves source controls, groundwater monitoring, infiltration reduction measures, and institutional controls, according to the discussion on page 6-23 of the GWFS. The GWFS then makes the statement on page 6-41 that" ...Remedial Alternative 3 would be the easiest to implement, in the event that the required area of institutional control is reduced or eliminated with remedial action." The RA 3, as presented to the public makes no mention at all of institutional controls. 1 strongly recommend that institutional controls be retained as part of RA 3.

3UDOIHIXC3 l_UlN I KUL

Caroline Rudolph March 21, 1996 Page 2

The reason why institutional controls should be retained is as follows. The total horizontal and vertical extent of contamination has not been determined off-site in the down-gradient direction. Additional groundwater monitoring wells are proposed to resolve this issue and the area of institutional control cannot be adequately defined at this time. A reduction in contaminant levels is expected after the source control and infiltration reduction measures are in place. However, since the Orange County groundwater basin is non-adjudicated, without institutional controls there is no control on the possible installation and pumping of a private well(s) in the site vicinity. This could change the groundwater flow direction and gradient and potentially pull more contamination from the site"

If you have any questions concerning this memorandum, please call Kathleen Considine at (916) 323-3586 or CALNET 8-473-3586.

cc: Richard McJunkin, CEG., Chief Geologic Services Unit Site Mitigation Program

Robert Holub

Regional Water Quality Control Board, Region 8 3737 Main Street, Suite 500 Riverside, California 92501-3339

TOTAL P.04

April 5, 1996 Serial No: EPA/MSG-033

U.S. Environmental Protection Agency Region IX Attn: Michael Montgomery 75 Hawthorne Street San Francisco, CA 94105

Subject: Comments Provided byMcColl Site Group During U.S. Environmental Protection Agency (U.S.EPA) Public Comment Period, Groundwater Operable Unit, McColl Site, Fullerton, California

Dear Mr. Montgomery:

The purpose of this letter is to provide the formal comments of the McColl Site Group ("MSG") regarding the Remedial Investigation (RI), Feasibility Study (FS), Risk Assessment (RA), and EPA's Proposed Plan for the Groundwater Operable Unit at the McColl Site in Fullerton, California. These comments are prepared in response to the U.S.EPA Public Comment Period which extends to April 5, 1996.

In response to Administrative Order 93-21, MSG has conducted routine groundwater monitoring as part of a groundwater investigation which was begun by EPA in 1989. Based upon that investigation, as well as the Remedial Investigation Report completed by MSG, the Risk Assessment completed by EPA, and the Feasibility Study that was initiated by MSG and subsequently completed by EPA, EPA has proposed a remedial action plan which has identified Alternative #3 (described in the Feasibility Study Report) as the preferred alternative. MSG supports the selection of Alternative #3 of the Feasibility Study Report. The following points summarize the results of the overall groundwater program and clarify certain aspects of the proposed alternative that should be reflected in the Record of Decision.

Results of the groundwater monitoring conducted by both the EPA and MSG, the Remedial Investigation, the Risk Assessment, and the Feasibility Study Report, all indicate that adverse impacts to groundwater from waste sumps at the McColl site are minimal.

215 East Orangethorpe Avenue • Su i te 304 • Fu l le r ton, Cal i fo rn ia 92632 • 714/665-7391

The McColl Site Group is composed of: Shell Oil Company, ARCO. Phil l ips Petroleum, Texaco and UNOCAL

Michael Montgomery -2- April 5, 1996

The health risk assessment was based upon the assumption that perched groundwater would be used as drinking water. However, given that these perched zones have no potential for use as drinking water, that assumption was unnecessarily conservative.

EPA lias raised concerns regarding potential difficulties in negotiating institutional controls with adjacent landowners. However, institutional controls should be considered for the McColl site and the area immediately south of the site within the golf course property where implementation hurdles should not pose a significant problem.

Completion of the surface remedy, RCRA-equivalent cover and sub-surface barrier wall system, will significantly reduce the potential for the sumps to impact groundwater in the future. Although construction of the surface remedy will provide the primary means of reducing groundwater contaminants, MSG supports the additional infiltration controls described in Alternative #3, with the exception of the use of imported low permeability materials outside of drainage ditches and redirection of surface water running onto the property.

Continued monitoring and installation of up to two new monitoring wells in the regional aquifer, lining of retention ponds and primary drainage ditches, and reduction of infiltration through surface grading is appropriate for the site. Use of imported low permeability materials outside of drainage ditches and redirection of surface water running onto the property would not provide significant benefits relative to the cost of implementing these actions. Accordingly, use of low permeability materials and redirection of surface water should be eliminated from further consideration in the remedy.

EPA has chosen to identify Operable Unit #1 for groundwater separately from Operable Unit #2 for the surface remedy. However, it is important that the remedial design for Operable Unit #1 be integrated into the design for Operable Unit #2. If EPA does not facilitate timely integration of these designs, the cost and schedule for both remedies will be adversely impacted.

Well W-6A is screened within the largely unsaturated and perched portion of the "C"sand/silt packet. As such, groundwater retrieved from well W-6A is not considered to be representative of the continuously saturated portion of the "C" flow unit.

Mr. Michael Montgomery -3- April 5, 1996

The "C" flow unit located within the La Habra Formation is not considered to be a significant part of the regional groundwater system. As stated in the 1967 Department of Water Resources report Progress Report on Groundwater Geology of the Coastal Plain of Orange County, the shallower water-bearing deposits of the La Habra Formation consist of semiperched aquifers of limited extent. The limited recharge area and the lack of continuity of the coarse-grained deposits of the "C" flow unit indicate the extent of the "C"flow unit limited, and not anticipated to be regional in nature.

The presence of THT compounds in the "D" flow unit has not been verified by the quarterly monitoring program. THT was semi-quantified (0.6 ug/L "J" qualified) in one sample from well P-1D upgradient of the sumps; however, THT was not detected in the duplicate sample and was detected in quality control samples. These results indicate that this detection of THT was not valid. THT has not been detected in any "C"flow unit wells with the exception of wells P-5L and P-10L. The underlying "D"flow unit well P-5D indicates that the THT compounds detected in well P-5L have not migrated downward at this location. A "D"flow unit well is proposed to be constructed near well P-10L to confirm that THT compounds have not migrated downward at this location.

Groundwater extraction (Alternative #4 of the Feasibility Study) does not meaningfully reduce the toxicity, mobility, or volume of chemicals of concern in the regional aquifer in comparison to the No Further Action alternative, since data indicates constituents are naturally attenuated before reaching the regional aquifer. Groundwater extraction could increase flow velocities, and create downward hydraulic gradients between groundwater flow units which, in fact, could result in increased mobility. Furthermore, groundwater extraction would not be effective in reducing the concentrations of the chemicals of concern to below background levels or in addressing their concentrations at the source areas. Finally, treatment residuals would be generated that would require further off-site waste treatment and/or disposal.

The benefits of groundwater extraction (described in Alternative #4) are overstated in the FS report. In particular, Alternative #4 will not meaningfully increase long-term effectiveness, meaningfully reduce toxicity and mobility or volume through treatment or enhance compliance with ARARs.

MSG and U.S.EPA have developed a very productive and cooperative working

relationship which has resulted in effective resolutions to significant issues regarding the RI, FS, and RA. The following specific comments are provided to give EPA additional feedback.


Comment Ml : Performance of the health risk assessment on "unusable" perched groundwater continues to be inappropriate since no pathway for health risk exists, and any action by EPA on the basis of these risks is not warranted. Assuming the "unusable" groundwater is "usable" for purposes of exposure compromises the technical integrity of the risk assessment. Additionally, this approach could mislead the public regarding potential risks posed by the Site.

Comment Ml : MSG explained the inappropriateness of designating State Water Resources Control Board (SWRCB) Resolutions 68-16, 88-63 and 92-49 as applicable or relevant and appropriate requirements (ARARs) in its letter to EPA dated January 23, 1996. The reasons set forth in that letter that these Resolutions cannot be designated as ARARs still stand. MSG understands that U.S.EPA intends to choose Alternative #3 as the remedy for the McColl site and that the Resolutions will not be designated as ARARs or TBCs for Alternative M3 in the Record of Decision (ROD). MSG agrees that the Resolutions are not applicable to Alternative M3 and therefore should not be designated as ARARs or TBCs in the ROD.

In addition, it is important that EPA and other administrative agencies understand why the Resolutions cannot be designated as ARARs for any of the other alternatives either. As explained in that letter, EPA's own guidance provides that a state law or regulation "must be applicable to all circumstances covered by the requirement" to be considered as a potential ARAR. EPA, CERCLA Compliance With State Requirements (December 1989). In other words, a state requirement that does not apply generally cannot be designated as an ARAR for a Superfund site. Because SWRCB Resolution 92-49 is not being applied consistently in California at this time, it cannot be designated as an ARAR for the McColl site.

As it is currently adopted by the SWRCB, Section G of SWRCB Resolution 92-49 requires that groundwater be restored to background levels, unless background levels are determined not to be achievable, in which case groundwater must remediated to meet local basin plan objectives. Resolution 92-49 does not allow deviation from background levels or basin plan objectives under any circumstance. Recognizing that there are situations where it is not technically or economically feasible to restore groundwater to background levels or even to basin plan objectives, the SWRCB has proposed an amendment to Resolution 92-49 that would establish a containment zone strategy for sites where it is determined to be technically or economically infeasible to meet the requirements of Resolution 92-49. Within the containment zone, groundwater remediation would not be


required; instead, remedial efforts would be focused on containment rather than restoration in that area.

The proposed amendments have not been formally adopted by SWRCB, but the SWRCB has established an informal policy that allows Regional Water Quality Control Boards (RWQCBs) to exercise individual discretion to implement '' containment zone strategies. MSG is aware of the following sites within California, where a containment zone strategy has been applied by the RWQCB responsible for overseeing groundwater remediation, despite the fact Resolution 92-49, as currently promulgated, does not authorize such a approach. MSG has not conducted a survey of all RWQCBs within the State; accordingly, this list of containment zone sites should not be considered to be comprehensive.

Clorox Corporation, Oakland, California. The RWQCB adopted a containment zone for a groundwater plume involving mercury. The mercury was present at concentrations well in excess of the Maximum Concentration Limit (MCL) and extended to off-site properties. Although the groundwater in this area meets the quality to be classified MUN under Resolution 88-63, it is not a current source of groundwater municipal supply. A containment zone was adopted providing for long term monitoring of this groundwater plume.

Varian and Unysis sites, South San Francisco Bay Area. Containment zones were adopted at both of these sites involving chlorinated solvents in groundwater. Groundwater in these cases is classified as MUN and sits overtop potable water supply aquifers. The containment zones required long term monitoring of groundwater quality in zones where concentrations were well above MCLs. The monitoring programs were designed to ensure that there is no significant migration of VOCs from the affected groundwater zones to the deeper water supply aquifers. Remedial activities beyond monitoring and natural attenuation were apparently not required.

San Francisco Airport. Several containment zones have been approved at San Francisco Airport involving hydrocarbons, metals, and solvents. Separate containment zones were adopted depending on the point of discharge of the groundwater to the bay or deeper aquifer units. These containment zones provide for the long term monitoring of groundwater where concentrations of hazardous substances are many times in excess of MCLs.


Xerox Corporation in Irvine, California. This site involved contamination of shallow groundwater by chlorinated solvents. The site was remediated by a two-phase vapor extraction system to a point that concentrations reached an asymptote but did not materially lower with further remedial efforts. As a result, the Santa Ana RWQCB approved a closure of the remedial activities and removal of all remediation equipment. Long term groundwater monitoring was required with action levels for further remediation set in the range of approximately 1 ppm for several VOCs. The action level concentrations in this "containment zone" are approximately 200 times the MCL. Groundwater in the affected zone would be classified MUN under criteria outlined in Resolution 88-63. The approach that adopted at this site appears to be the equivalent of the containment zone as outlined under the proposed amendments to Resolution 92-49.

Clearly, implementation of Resolution 92-49 is in a state of flux in the State of California. RWQCBs currently have broad discretion to apply a containment zone approach or to follow the strict requirements set forth in Resolution 92-49. As a result, Resolution 92-49 is not being applied, consistently throughout California: Under the statutory requirements of CERCLA and EPA's own guidance, Resolution 92-49 cannot be designated as an ARAR.

Moreover, as a practical matter, EPA has not been consistent in its designation of SWRCB Resolutions 68-16, 88-63 and 92-49 as ARARs or "To Be Considered" (TBC) criteria. MSG reviewed several of the Feasibility Studies (FS) and Records of Decisions (ROD) prepared since 1992 for EPA-lead sites in California with groundwater contamination. Attached is a list of the sites reviewed and a summary of how the SWRCB Resolutions were applied at those sites. Of the 16 sites reviewed, SWRCB Resolution 92-49 was designated as an ARAR at only 2 sites and as a TBC at only one site. At no other site was SWRCB Resolution 92-49 designated as an ARAR or TBC.

SWRCB Resolution 68-16 was designated as ARAR at 9 sites, but in all cases the FS or ROD specified that Resolution 68-16 was being applied as an action-specific ARAR applicable only to the discharge of treated groundwater. At 3 sites, SWRCB Resolution 68-16 was designated as a TBC, rather than an ARAR, for the same limited purpose. At none of the sites was SWRCB Resolution 68-16 applied as an ARAR to set cleanup levels. Clearly, EPA has taken a flexible approach to its designation of SWRCB Resolutions in the past. At one site, the FS even reported that "EPA does not agree [with the RWQCB] that Resolution 68-16 is an ARAR."


Application of SWRCB Resolution 92-49 is currently in a state of transition; that resolution cannot now be designated as an ARAR for the McColl site. In conformance with statutory requirements and EPA's own guidance, Resolution 92-49 should be redesignated as a TBC criteria or eliminated from consideration. Moreover, as demonstrated by a review of other sites, EPA has clear flexibility to designate SWRCB Resolutions 68-16 and 88-63 as TBCs as well or to eliminate from the process entirely. To allow EPA and local agencies maximum flexibility to evaluate groundwater issues that may arise at the McColl site in the future, all of the SWRCB Resolutions should be designated as TBC criteria or eliminated from further consideration altogether.

Comment #3: Under U.S.EPA's detailed analysis of the remedial alternative "Institutional Controls" (Alternative #2), U.S.EPA states that "longterm institutional control may be constrained by the priorities of the enforcing agency." U.S.EPA further states in the FS that institutional controls are "potentially difficult to implement in that it involves the often complex subject of water rights and negotiations with private property owners." The administration of limited Institutional Controls is a viable remedial element for both Alternative #3 and for the remedial strategy outlined to address THT compounds described in Appendix A of the FS report. Institutional controls would be useful, for example, to assure that cross-contamination between flow units does not occur due to well construction activities. Institutional controls are expected to be necessary only for the McColl site and a portion of the Los Coyotes Country Club property. Because only two separate parcels are involved, implementation problems are not anticipated.

Comment #4 The Fate and Transport Study of THT Compounds (ENVIRON December 18, 1995) indicates that THT compounds are being degraded, probably as a result of biologically mediated processes. Additionally, the limited infiltration controls proposed in Alternative #3 and the remedial action selected for Operable Unit #1 should effectively isolate the THT compounds within the sump areas from groundwater. Given the degradation of THT compounds in groundwater and the isolation of the sump areas from groundwater, the existing concentrations of THT

compounds in groundwater are not likely to be a permanent condition.

The comments provided in this letter provide further support for the conceptual hydrogeologic model of the site developed in the RI and the selection of Remedial Alternative #3, which is described in detail in the FS.


MSG has previously submitted comments to EPA on various deliverables during the remedial investigation activities performed under the Administrative Order 93-21. Although MSG is providing supplemental comments in this letter, the absence of comments restating previous comments made to EPA should not be interpreted as an indication MSG has abandoned any prior comments or positions. On the contrary, MSG hereby reiterates its prior comments and provides this response to summarize key issues.

Yours truly,

mccou one uroup

ATH\SLM:lf p:\lf\mccoll\03-4575d\public.com

Attachment

cc: State of California Department of Toxic Substances Control

Caroline Rudolph (3) Parsons Engineering Science

Ken Fredianelli

ATTACHMENTTO MSG COMMENTS ON PROPOSED PLAN FOR GROUNDWATER REMEDIATION AT THE MCCOLL SITE

April 5,1996

Summary of EPA-lead Sites (1992-present)

Lawrence Livermore National Laboratory Site 300

Interim Record of Decision, September 1995.

Resolution 68-16 was designated as an action-specific ARAR for the discharge of treated ground water only. Resolution 92-49 was not designated as an ARAR or TBC.

Moffett federal Airfield - Operable Unit 5

FS Report prepared for Department of the Navy by PRC Environmental Management, Inc., June 1,1995.

Resolutions 68-16 and 92-49 were both designated as an action-specific ARARs to be applied to remedial actions that discharge treated water to surface water. Resolution 68-16 was not designated as a chemical-specific ARAR to be used to set cleanup goals for the contaminated aquifers. Section G of Resolution 92-49 was designated as a chemical-specific ARAR applicable to setting cleanup levels. Section G requires cleanup to background levels, unless background levels are not attainable, in which case cleanup levels must:

1. Be consistent with maximum benefit to the people of the state;

2. Not unreasonably affect present and anticipated beneficial use of such water; and

3. Not result in water quality less than that prescribed in the Water Quality Control Plans and Policies adopted by the State and Regional Water Boards.

Muscov Plum Operable Unit

RI/FS Report prepared for EPA by URS Consultants, Inc., December 1994.

Neither Resolution 92-49 nor Resolution 68-16 were designated as chemical-specific ARARs. Resolution 68-16 was designated as an action-specific ARAR "to the extent that treated water is reinjected into the aquifer." In other words, Resolution 68-16 was applied to the site to develop a reinjection standard, not to set cleanup levels.

9

Fort Ord Superfund Site

Record of Decision, November 1994

Resolution 68-16 "isapplicable to recharge of the treated water." Resolution 92-49 was not designated as an ARAR or TBC. *

United Heckathorn Superfund Site

FS Report prepared for EPA, July 1994.

"The SFBRWQCB has identified Resolution 68-16 as a potential ARAR for the United Heckathorn Site. Although EPA does not agree that Resolution 68-16 is an ARAR, EPA and the State of California agree that achieving the water quality criteria identified above would meet the requirements of 68-16, regardless of whether or not it is an ARAR." Resolution 92-49 was not designated as an ARAR or TBC.

Aircraft Control and Warning Site

Record of Decision, December 1993.

"Resolution 68-16, the water anti-degradation policy, is a State ARAR for the establishment of numerical limits for the reinjection of treated ground water into clean areas (i.e., high quality waters) of the aquifer, i.e.,outside of the contaminated plume." Resolution 92-49 was not designated as an ARAR or TBC.

Tracy Defense Depot

Record of Decision, August 1993.

Resolution 92-49 was designated as a TBC.

George Air Force Base

FS Report prepared by International Technology Corporation, August 1993.

Resolution 68-16 was designated as an action-specific ARAR, but 92-49 was not designated as an ARAR or TBC. The Report states that Resolution 68-16 applies to activities that produce waste and result in a discharges to waters of the State. Presumably, therefore, Resolution 68-16 was applied as a treatment standard. A two-step balancing approach was established to implement 68-16: (1) determine if a degradation may be allowed, and (2) establish the discharge that will meet the objectives of 68-16.

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Brown & Brvant Superfund Site

RI/FS Report prepared by EPA, May 28, 1993.

State Resolution 68-16 was designated as an ARAR, but the contaminated aquifer was determined not to be a potential source of drinking water under state or federal law. As a result, EPA stated that Resolution 68-16 would only be applicable to reinjection standards. Moreover, EPA determined that compliance with Maximum Contaminant Levels (MCLs) under the Safe Drinking Water Act would satisfy Resolution 68-16. Resolution 92-49 was not designated as an ARAR or TBC.

Baldwin Park Operable Unit

FS Report prepared for EPA by CH2M Hill, April 2, 1993.

Resolution 68-16 was designated as an action-specific ARAR "for remedial actions involving the recharge or reinjection of treated water into the basin." Resolution 92-49 was not designated as an ARAR or TBC.

Riverbank Army Ammunition Plant

FS Report prepared by U.S. Army by Weston Managers/Designers/Consultants, March 1993.

Resolution 68-16 was not designated as an ARAR because it is a "proactive mandate rather than a retroactive mandate." Resolution 68-16 was designated as a TBC. Resolution 92-49 was not designated as an ARAR or TBC.

Norton Air Force Base

FS Report prepared by Department of the Air Force. February 1993.

Resolution 68-16 was designated as a TBC for the discharge of treated groundwater to surface water or reinjection into the aquifer. Resolution 92-49 was not designated as an ARAR or TBC.

DDRW-Tracv Operable Unit No. 1

FS Report prepared for U.S. Army Corps of Engineers by Woodward-Clyde Consultants, December 1992.

Resolutions 68-16, 88-63 and 92-49 were all designated as ARARs.

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Glendale Study Area - South Operable Unit

FS Report prepared for EPA and City of Los Angeles by James M. Montgomery, August 1992.

Neither Resolution 68-16 nor 92-49 was designated an ARAR or TBC.

Sacramento Army Deport - Burn Pits

FS Report prepared for U.S. Corps of Engineers by Kleinfelder, Inc., May 15,1992.

Resolution 68-16 was designated as a TBC. Resolution 92-49 was not designated as an ARAR or TBC.

Iron Mountain Mine

RI/FS Report prepared for EPA by CH2M Hill, February 1992.

Neither Resolution 68-16 nor Resolution 92-49 was designated as an ARAR.

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