N PRO^0

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION VII901 NORTH 5TH STREET

KANSAS CITY, KANSAS 66101

1 g MAR 2005

ACTION MEMORANDUM

SUBJECT: Request for Removal Action at the Highway 275 and 28Sth Street Site, Douglas

County, Nebraska ' .

FROM:

THROUGH:

TO:

Randy Schademann, On-Scene Coordinator

Emergency Response and Removal Branch

Superfund Division

Scott Hayes, Chief (/T Emergency Response and Removal Branch

Cecilia Tapia, Director

Superfund Division

'■V

,5-0

I.

CERCLIS ID#:

' SITE ID#

REMOVAL CATEGORY:

NATIONALLY SIGNIFICANT:f

PURPOSE

NEN000704272

A74G

Time-Critical

No

30307743

Superfund

The purpose of this Action Memorandum is to request approval of a proposed removal action for the Highway 275 and 288th Street Site (the Site), located near Valley, Nebraska. The

proposed action includes the installation of whole-house carbon filtration units at the affected

residences and businesses in the area, with each receiving a 3-5 year supply of filters.

II. SITE CONDITIONS AND BACKGROUND

A. Site Description

1. Removal Site Evaluation

As part of a Resource Conservation and Recovery Act (RCRA) closure

investigation, the monitoring of Valmont Industries (Valmont), in 2000, by the Nebraska

Department of Environmental Quality (NDEQ) identified volatile organic compounds (VOCs) in

monitoring wells. Further investigation identified several private drinking water wells

contaminated with trichloroethylene (TCE) at.levels above the maximum contaminant level

RECYCLEPAFEH 0*ri.l.3 atC'CliO t BE»S

(MCL) of 5.micrograms per liter.(pg/l). The Nebraska Health and Human Services System

(NHHSS) subsequently identified TCE (currently below 5 pg/1) in a public water supply well for,

the Pines Homeowners Association, a small subdivision located due east of the Site.

The contractor for Valmont, HDR Engineering, Inc. (HDR), investigated the groundwater

VOC plume in 2001 and 2002 and concluded that the VOC plume was not originating from the

Valmont facility. This conclusion was based on the presence of VOCs cross-gradient of the Site

and up-gradient of the production process.

Subsequent investigations including a Preliminary Assessment/Site Inspection (PA/SI)

conducted by the NDEQ in 2002 and a Removal Site Evaluation/Expanded Site Inspection

(RSE/ESI) conducted by the U.S. Environmental Protection Agency (EPA) in 2004, indicate that

TCE concentrations near the MCL are limited to private wells at three residences and two

businesses. ~ Valmont has been supplying bottled water to two residences with the third

purchasing its own bottled water. One of the businesses supplies bottled water to its workers and

the second business is currently vacant. The results of the PA/SI and the RSE/ESI appear to

indicate a source more than a mile up-gradient of Valmont. Valmont has informed the EPA of its

plan to discontinue supplying bottled water, based on the analytical data. The EPA will resume

field work to identify the boundaries of the plume and identify a source in early 2005.

2. Physical Location

Valley is located in Douglas County, in eastern Nebraska, approximately

15 miles west of Omaha. The area of groundwater contamination is primarily northwest of the

Valley city limits and roughly runs parallel to Old Highway 275. The groundwater plume,

however, has not been fully described and is likely to include areas northwest of the known

impacted area. That area is largely rural and may not be impacting any other residential wells.

Additional sampling to determine the plume’s boundaries and identify additional impacted wells

is scheduled for February of 2005. '

There are an estimated 40-45 residences or commercial businesses (which utilize water ■

wells for drinking water or household usage) within 1 mile of the contaminant plume area. The

contaminant.plume extends to the northern city limits of Valley, Nebraska. Valley utilizes

groundwater for its public drinking water system. The population of Valley, Nebraska, (statistics

taken from the 2000 census) is 1,708.

3. Site Characteristics

There are no confirmed sources of the TCE contamination. Potential

sources include unreported spills from commercial traffic along Old Highway 275 and the

adjacently-located Union Pacific Railroad. No reported chlorinated solvent spills are identified

in state or EPA records.

2

Land use in the area is a mix of residential, commercial and agricultural. The current

location of the groundwater plume is parallel to Old Hwy 275 and extends into Valley’s city .

limits.

4. Release or threatened release into the environment of a hazardous

substance, or pollutant or contaminant

TCE has been detected in groundwater at the site. TCE is listed as a

hazardous substance pursuant to 40 C.F.R. §302.4. As such, it is a “hazardous substance” as

defined in Section 101(14) of the Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA), 42 U.S.C. §9601(14).

TCE is a nonflammable, colorless liquid that has had a wide array of industry uses

(solvent; precursor for other chemicals; and as a carrier in many products including paint

removers and adhesives). Health effects of moderate to high levels of TCE include liver and

kidney damage. The EPA lists TCE as a suspected carcinogen.

5. NPL Status '

This site is not on and is not currently proposed for listing on the National

Priorities List.

6. Maps, pictures and other graphic representations

A map of the Site is included as Attachment 1. A summary of well

sampling data is included as Attachment 2.

B. Other Actions to Date

1. Previous Actions

See subparagraph II.A. 1 above, “Removal Site Evaluation.”

2. Current Actions . ■ .

The EPA is assessing data and, in the future, will continue investigating

the area to determine possible sources of the TCE.

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c. State and Local Authorities' Role

1. .. State and Local Actions to Date

The NDEQ conducted the PA/SI in 2002 and has assisted with the

RSE/ESI. The NHHSS has conducted quarterly sampling of the area’s impacted public water

supply well and provided health risk information to affected residents;

2. Potential for Continued State/Local Response

The. NDEQ has asked to be kept informed of site activities; NHHSS may

provide additional risk assessment support.

D. Community Involvement Activities

hi late January 2005, the EPA mailed Data Transmittal letters to residences and

businesses that were sampled during the RSE/ESI. A Fact Sheet that summarizes current and

future EPA activities at the Site is under development.

The Administrative Record supporting this Action Memorandum will be placed in a local

repository and/or the EPA Region 7 Records Center.

The EPA has initiated and continues discussions with city leadership (city mayor,

superintendent of water department) regarding site activities.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT,

AND STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health or Welfare

Site conditions pose a significant threat to public health and welfare which meet

the criteria for a response action under 40 C.F.R. § 300.415(b)(2) of the National Oil and

Hazardous Substances Contingency Plan (NCP) and which are described as follows:

1. Actual or potential contamination of drinking water supplies or sensitive

ecosystems [40 C:F.R. § 300.415(b)(2)(ii)].

Three private drinking water wells and two business wells have been

shown to have TCE at concentrations exceeding the MCL. The length of

time that residents have been drinking water contaminated above threshold

concentrations is unknown. However, it is possible that residents have

been drinking contaminated water for a number of years, which would

increase the chance of human health risk. In addition, other VOCs

4

including vinyl chloride, cis-l,2-dichloroethylene (DCE) and

tetrachloroethylene (PCE) have been identified in the impacted wells.

Although these contaminants are not above their respective MCLs, the

synergistic effects of VOCs is poorly understood. And finally, indoor air

samples collected during the RSE/ESI have identified the same VOCs

present in residences served by the impacted wells. The additional impact

of drinking contaminated water and inhaling VOCs from non-drinking

water (i.e. showering, bathing, cooking) is also poorly understood.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this site, if not addressed by

implementing the response action selected in this Action Memorandum, may present an

imminent and substantial endangennent to public health, or welfare, or the environment.

I

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions .

1. Proposed Action Description

The proposed action is to offer carbon filtration systems (and any

necessary pre-filters or other hardware requirements) to residences or businesses where TCE has

been indicated above 5 ug/1 in drinking water, and where the residence or business utilizes a

significant amount of this water for purposes other than drinking (i.e, showering, bathing,

cooking). In addition, the residents will receive a 3-5 year supply of carbon filters and pre-filters

(along with written instructions on the filter change-out process). .

2. Health Consultation and Threshold Concentration Discussion

The proposed threshold concentration (i.e., the concentration of TCE in a

private well which, if exceeded, would allow a residence or business to be eligible for carbon

filtration installation) is 5.0 ug/1.

The EPA guidance for determining threshold concentrations in private drinking water

wells is provided in the document “Final Guidance on Numeric Removal Action Levels for

Contaminated Drinking Water Sites” (OSWER Directive 9360.1-02, October 1993). Removal

action levels, or RALs, are defined in this directive as “drinking water concentrations of

contaminants that are considered, along with other factors, in determining whether to provide

alternate water supplies under Superfund removal authority.” The directive further defines two

types of RALs: (1) numeric levels for individual substances, and (2) site-specific levels. The

numeric level for TCE is given as 300 ug/1. To date, the highest concentration of TCE found in

any private drinking water well at this site is 25 ug/1. .

5

Site-specific levels are described in the directive as follows: “A significant health threat

may exist at a site even if no substance, is currently present in drinking water at a concentration

exceeding its numeric RAL. A removal action may be initiated if the health risk at a site has.

been analyzed in detail and the analysis indicates that a serious risk is present due to site-specific

factors.” A site-specific health risk determination was performed at this site which suggests the

use of 5 ug/1 as an action level for providing alternative.water to affected residents in the City

of Valley.

3. Contribution to Remedial Performance :

Although no remedial actions are anticipated for this site, the proposed

actions should be consistent with remedial actions .which might subsequently prove to be.

necessary.

4. : Description of Alternative Technologies

Carbon filtration systems and bottled water are the most widely-used

short-term alternatives for addressing contaminated whole-house water at CERCLA sites.

Carbon filtration systems would cost approximately $1,000 per residence, which would

include purchase of the system, installation, and a 3-5 year supply of carbon filters and pre-filters.

Costs include initial sampling for efficacy of the filter system for reducing both indoor air and

water concentrations for VOCs. -t

Bottled water could be provided to the affected residences. This option would cost

approximately $600 per residence per year. This option, however, does not address the

inhalation or dermal contact exposure route associated with volatile organic contaminants. These

two routes of exposure can exceed the risk posed by the ingestion route above.

5. Applicable or Relevant and Appropriate Requirements (ARARs) '•

Federal - Waste Determination : ■

Wastes collected by the activated carbon for individual residences would

be considered household wastes in accordance with 40 C.F.R. §261.4(b), and, as such* would be

subject to control under RCRA Subtitle D regulations.

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Federal

. The.National Oil and Hazardous Substances Pollution Contingency Plan at 40 C.F.R. Part

300.415 requires that removal actions shall, to the extent practicable, considering the exigencies

of the situation, attain ARARs under federal environmental, state environmental, or facility­

citing laws. The following ARARs have been identified as being potentially applicable for this

action:

Action/Prerequ isite Requirement Citation

Disposal of spent

activated carbon

Disposal at RCRA Subtitle D facility—

Applicable

40 C.F.R. §257

Drinking Water Quality Treatment to achieve compliance with

MCLs- Relevant and appropriate

40 C.F.R. §141

State

By letter dated January 20, 2005, a written request for state ARARs was sent to

the NDEQ. Potential ARARs received by the EPA from the NDEQ will be considered in

accordance with 40 C.F.R. §300.400(g).

6. Project Schedule

This action can begin within 4-8 weeks of approval of this Action

Memorandum. Installation of filtration units is expected to require approximately 1 day per unit.

B. Estimated Costs

Costs presented below include the 3 residences and 2 businesses currently

identified and 3 additional residences/businesses under contingency.

' Extramural Costs • ■

ERRS Costs $ 5,000

START Costs ;$ 3,000

Extramural Cost Contingency $ 2.000

Subtotal, Extramural Costs $ 10,000

TOTAL, REMOVAL PROJECT CEILING $ 10,000

The EPA direct and indirect costs, although cost recoverable, do not count toward the

Total Removal Action. Refer to the Enforcement Addendum for a breakout of these costs.

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VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED

OR NOT TAKEN

The proposed actions for the.Highway 275 and 288th Street site should be taken

immediately. Should these actions be delayed, the potential, threats to. human health and the.

environment will increase.

VII. OUTSTANDING POLICY ISSUES

None. '

j ' _VIII. ENFORCEMENT

. There is an Enforcement Addendum for this Site (Attachment 3). For NCP consistency

■ purposes,, it is not a part of this Action Memorandum.

IX. RECOMMENDATION

This decision document represents the selected removal action for the Highway 275 and

288th Street site, near Valley, Nebraska.. It was developed in accordance with CERCLA as

amended, and is not inconsistent with the NCP. This decision is based on the Administrative

Record for the site. ..

Conditions at the site meet the NCP section 300.415(b)(2) criteria for a removal and I

recommend your approval of the proposed removal action. The removal project peiling, if .

approved, will be $10,000. This amount, comes from the Regional Removal Allowance.

Approved:

___________Date r

8

® * e

f

Legendotw Geoprobe® groundwater sample location (24-hour turn around time) and ID • Geoprobe® groundwater sample location (Standard turn around time) and ID

Soil sample location and ID ▲213 Air sample location and ID

29 Domestic well sample location and ID 2 Public water supply well sample location and ID

5 Irrigation well sample location and ID Approximate known extent of VOC plume

Highway 275 and 288th Street Site

Valley, Nebraska

Figure 2Sample Location Map

G3 Tetra Tech EM Inc.

ATTACHMENT 2

Well Data Summary for Hwy 275 and 288lh Street Site

Valley, Nebraska

Date: October 12, 2004

Residence 1

Residence 2

Residence 3

Business 1

TCE Concentration (ug/1)

3.1

25

21

5.8

ATTACHMENT 3

ENFORCEMENT CONFIDENTIAL

DO NOT RELEASE UNDER FOIA

ENFORCEMENT ADDENDUM Hwy 275 and 288th Street Site

VALLEY, NEBRASKA

A. Summary

Investigations to date have focused on identifying private drinking water wells

containing TCE above health-based levels for the purpose of installing carbon filtration systems

on a time-critical basis. We do not. currently have sufficient information about the potential

sources of the TCE contamination to assert potential liability for, or issue administrative orders

to, any person. It is anticipated that follow-up investigations will be conducted to obtain more

information about the sources of the contamination. In light of the number of individuals

exposed to contaminated water and the levels of contamination, we recommend installation of

the carbon filtration systems without waiting to complete the investigations necessary to identify

the sources of the groundwater contamination.x '

• B. Estimated Intramural Direct and Indirect Costs

The EPA estimates that the total Intramural Direct and Indirect Costs at the Site

will be.$22,604. Intramural costs have been included in this Enforcement Addendum in order to

give a more complete picture of the costs associated with this time-critical removal. The indirect

costs were calculated by multiplying the extramural total ($10,000) and the EPA direct cost

($5,000) by the current indirect percentage rate (50.69%). These costs are summarized as

follows:

Extramural Costs:

ERRS $ 5,000

START $ . 3,000

Extramural Contingency $ 2.000

Subtotal Extramural $ 10,000

Intramural Costs:

EPA Direct Costs $ 5,000

EPA Indirect Costs ($15,000 x 50.69%) i. 7.604

Subtotal Intramural Costs $ 12,604

TOTAL REMOVAL PROJECT COST $ 22.604

The EPA direct and indirect costs^ although cost recoverable, do not count

towards the total removal project ceiling for this removal action.