7.0 EVALUATION OF REMEDIAL ALTERNATIVES

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1 7.0 EVALUATION OF REMEDIAL ALTERNATIVES This section provides a description of the developed remedial alternatives based on viable remedial technologies and process options, as identified in Section 4.0, and evaluates remedial alternatives against criteria set forth in the NCP (U.S. EPA, 1993) and California Health and Safety Code Section (d). 7.1 Remedial Alternative Evaluation Criteria The following sections describe the nine federal criteria in the NCP and the six State of California factors used to evaluate remedial alternatives NCP Criteria The nine federal criteria in the NCP, listed below, are divided into three general categories: a) threshold criteria, b) primary balancing criteria, and c) modifying criteria. Threshold criteria are actually requirements, and the selected remedy must protect human health and the environment and must comply with identified ARARs. The primary balancing criteria determines how the alternatives compare with one another and identifies tradeoffs between them. The modifying criteria take into account acceptance by the State and by the local community. a. Threshold Criteria 1. Overall protection of human health and the environment: This criterion addresses whether a remedial alternative is protective of human health and the environment in the long-term and short-term. 2. Compliance with ARARs: The selected remedy must comply with ARARs unless a waiver is appropriate pursuant to 40 CFR Paragraph (f)(1)(ii)(c). b. Primary Balancing Criteria 3. Long-term effectiveness and permanence: This criterion addresses how well a remedy maintains protection of human health and the environment after RAOs have been initially met and the degree of certainty that the alternative will continue to meet RAOs. Components to be addressed include the magnitude of residual risk and the adequacy and long-term reliability of management controls. 4. Reduction of toxicity, mobility, or volume: This criterion assesses the anticipated amount of target chemical destroyed or treated and the amount remaining at the site along with the degree of expected reduction in chemical mobility, toxicity, or volume. 5. Short-term effectiveness: This criterion concerns protection of human health and the environment during construction and implementation of remedial actions. To be considered are the length of time required to achieve protection, the short-term reliability of remedial technologies, protection of Page 48 of 72

2 workers and the community during construction, and potential disruptions to nearby commercial and residential neighborhoods. 6. Implementability: This criterion is meant to assess implementability considering the technical and administrative feasibility of each alternative, as well as the availability of needed goods and services to perform the remedy. Other implementability considerations include the ability to construct and operate remedial facilities, ease of undertaking additional remedial actions, ability to monitor remedial effectiveness, and ability to obtain approvals and permits. 7. Cost: This criterion evaluates the cost of remedial alternatives, including both total long-term and short-term costs. c. Modifying Criteria Typically, these two criteria are evaluated based on formal comments received during the project comment period. However, a formal comment period has not yet occurred. Issues and concerns of the agencies and community will be addressed after the public comment period on the draft FS/RAP. 8. State acceptance: This criterion considers the acceptability of remedial alternatives to State and local agencies. 9. Community acceptance: This criterion considers the acceptability of remedial alternatives to the local residents and community State of California Factors A brief outline of the six State of California factors as delineated by California Health and Safety Code (d) are listed below. These State factors, although similar to the nine NCP criteria, are considered separately. 1. Health and safety risks: This factor considers health and safety risks posed by site conditions. 2. Effect of contamination upon beneficial uses of resource: This factor considers the effect of contamination upon present, future, and probable beneficial uses of contaminated, polluted, or threatened resources. 3. Effect on groundwater resources: This factor considers the effect of remedial alternatives on the availability of groundwater resources for present, future, and probable beneficial uses and the extent to which remedial alternatives use treatment to reduce the volume, toxicity, or mobility of hazardous substances. 4. Site-specific characteristics: This factor considers site-specific characteristics, including the potential for off-site migration of hazardous substances, surface or subsurface soil conditions, hydrogeologic conditions, and pre-existing background chemicals levels. Page 49 of 72

3 5. Cost effectiveness: This factor considers the cost-effectiveness of remedial alternatives, including both total long-term and short-term costs. 6. Potential environmental impacts of remedial action: This factor considers potential environmental impacts of remedial alternatives, including land disposal and treatment issues Compliance with TSCA Remedial alternatives involving excavation of soil containing PCBs will follow the requirements of TSCA. The three parts of TSCA under which PCB-impacted material may be remediated are: 40 CFR (a), Self-implementing on-site cleanup and disposal of PCB remediation waste; 40 CFR (b), Performance-based disposal; and, 40 CFR (c), Risk-based disposal approval. Soil removal activities for Alternatives 2 through 4 are proposed to be performed under (c). Under this section, any person wishing to sample, cleanup, or dispose of PCB-impacted material in a manner other than as prescribed in (a) or (b), must apply in writing to the U.S. EPA Regional Administrator in the Region where the site is located. Pursuant to (c) of TSCA, each application to assess PCBs under this section must contain the information described in the notification requirements of (a)(3). Following review of the application, U.S. EPA may issue a written decision on the request for risk-based remediation of PCBs. According to TSCA requirements, U.S. EPA will approve a risk-based remediation of PCBs if it finds that the remediation method will not pose an unreasonable risk of injury to health or the environment (40 CFR (c)). As discussed in further detail in Appendix F, this FS/RAP serves as the written application to U.S. EPA to assess and remediate PCBs under (c) for the recommended alternative. Including the application to U.S. EPA with this draft FS/RAP allows U.S. EPA to review and comment on the application in the draft phase, and approve the application with the final FS/RAP document. Thus, in accordance with the requirements of Section (c) of TSCA, and as discussed in Appendix F, this FS/RAP serves as the written application to U.S. EPA to assess and remediate PCBs under (c) for the recommended alternative (Section 8.0). Pursuant to (c) of TSCA, this FS/RAP contains the information described in the notification requirements of (a)(3). The location of information required by (a)(3) is described in Appendix F. Including the application to U.S. EPA with this draft FS/RAP allows U.S. EPA to review and comment on the application in the draft phase, and to approve the application with the final FS/RAP document. Page 50 of 72

4 Since all alternatives assessed in this draft FS/RAP would be implemented in compliance with TSCA, an evaluation of alternatives against TSCA requirements is not included in Section Summary of Remedial Alternative Evaluation Results The following sections summarize the results of the analysis of remedial alternatives against NCP criteria and State of California factors NCP Criteria Evaluation Results Table 6 includes a detailed analysis of the four remedial alternatives using the NCP criteria. The analysis is summarized below. Threshold Criteria Overall Protection of Human Health and the Environment: Alternatives 1 through 4 are protective of human health and the environment for the land use included for each alternative. All four alternatives are protective of human health from direct exposure to COPCs in soil and groundwater, and from COPCs in groundwater migrating to outdoor air (Alternative 1) and indoor air (Alternatives 2 through 4). Post-construction risk estimates for each alternative are summarized in Section 6.0 and Table 5. Because the estimated CR for On-Site Commercial/Industrial Workers under Alternative 2 is between 10-4 and 10-6, this alternative includes targeted groundwater treatment and construction of an SSVS to mitigate potential future risks. Compliance with ARARs: Alternatives 1 through 4 are expected to comply with ARARs. For all four Alternatives, groundwater is expected to attain drinking water-related ARARs over the long-term by natural attenuation. Attenuation under Alternative 2 is anticipated to be enhanced for certain risk-driving VOCs due to the injection of ORC (or other material for in situ treatment) prior to excavation activities. Primary Balancing Criteria Long-term Effectiveness and Permanence: All four alternatives are expected to provide long-term effectiveness and permanence at addressing protection of human health and the environment. For Alternative 1, chemicals in soil remain on-site above risk-based levels of concern (assuming no engineering controls); and as such, long-term effectiveness depends on maintenance of the existing cap and slurry wall. Therefore, Alternative 1 provides the least long-term reliability. Under Alternatives 2 through 4, impacted soil would be excavated, followed by backfill with clean soil and/or construction of a building on-site. As such, Alternatives 2 through 4 may be more reliable at protecting human health and the environment than Alternative 1. Additionally, Alternative 2 includes construction of an SSVS with ongoing monitoring of sub-slab soil vapor and/or stack emissions. Therefore, this alternative provides additional control and knowledge of the future conditions at the Site with respect to protecting human health. Under Alternative 4, to the extent practicable, Page 51 of 72

5 soil will be removed to attain risk-based Site cleanup, thus most reliably protects human health and environment. Under Alternatives 2 through 4, the building that is constructed following soil excavation will limit potential leaching of COPCs to groundwater. For Alternatives 2 and 3, where representative concentrations of COPCs in soil (e.g., PCBs) may be present at levels above risk-based goals developed for the Site cleanup alternative (i.e., Alternative 4), protection of human health will depend on long-term maintenance of the on-site structure, which will be acting as a physical barrier between on-site populations and the underlying soil. Reduction of Toxicity, Mobility, or Volume: No active treatment is associated with Alternative 1, and as such, it does not provide reduction of toxicity, mobility, or volume of COPCs. Alternative 2 provides the most reduction of toxicity and volume of COPCs through treatment, given the in situ groundwater treatment prior to excavation activities. Additionally, Alternatives 2 through 4 provide varying degrees of reduction in mobility and volume of COPCs by removing and disposing of soil off-site. Short-term Effectiveness: Alternative 1 is considered most effective in the short-term as no exposure to COPCs is associated with implementation of Alternative 1. For Alternatives 2 through 4, short-term exposures to COPCs and potential off-site impacts from dust, odor, and traffic would need to be addressed by available mitigation measures during excavation activities. Alternatives 3 and 4 may have a greater potential for off-site impacts due to longer excavation period and higher concentrations of some COPCs (e.g., PCBs) in soil to be excavated. Due to limited deeper soil data, the excavation period associated with Alternative 4 has a significant potential to increase from additional excavation activities required based on the results of confirmation soil sampling. Additional soil excavation under Alternative 4 would increase the potential for off-site impacts due to a longer excavation period. Alternative 2 has less potential to generate off-site impacts from dust, odor, and traffic than Alternatives 3 and 4 because significantly less soil will be removed from the Site under this alternative. Implementability: Alternative 1 is most implementable. Alternatives 2 through 4 are implementable, but may require extensive control measures to reduce on- and off-site exposures, potential noise, dust, and odor impacts during excavation activities. With the additional volumes of soil to be excavated, including excavation of saturated soil, Alternatives 3 and 4 are expected to be more difficult to implement than Alternatives 1 and 2. As discussed in Section 5.4, it may be technically infeasible to excavate soil in order to achieve the risk-based criteria for Site cleanup (Alternative 4). Therefore, a maximum excavation base elevation is established at 35 feet bgs or -17 feet msl. However, even at this depth, permanent tiebacks may be required which would reduce the developable area at the Site, making this alternative less implementable. Page 52 of 72

6 Cost: Capital costs and annual ongoing costs were estimated for Alternatives 1 to 4 based on descriptions of alternatives provided in Section 5.0 (Table 7). Appendix C presents cost estimates for components of alternatives and the basis and assumptions for these estimates. Modifying Criteria State Acceptance: State acceptance will be evaluated after the public comment period and incorporated into the final FS/RAP. Community Acceptance: Community acceptance will be evaluated after the public comment period and incorporated into the final FS/RAP State Factors Evaluation Results The evaluation results of State factors are summarized below. Health and Safety Risks: As stated in Section 6.1.2, based on current land use, health and safety risks posed by current Site conditions are below noncarcinogenic and carcinogenic the target risk levels of 1 and 10-6, respectively, and would remain at this level under Alternative 1. However, Alternative 1 would not address the inherent risks associated with leaving COPCs in soil at the Site. Under Alternatives 2 through 4, varying amounts of impacted soil would be removed from the Site. Potential risks during construction would be mitigated by through use of PPE, engineering controls, and monitoring with contingency plans. Under Alternative 2, if CR remains above the 10-6 target level following groundwater treatment and soil excavation, potential risk due to vapor intrusion would be managed through operation and maintenance of an SSVS. Risk estimates for Alternatives 3 and 4 are below non-carcinogenic and carcinogenic the target risk levels of 1 and 10-6, respectively (Table 5). Both Alternatives 2 and 3 include long-term institutional controls to limit exposure to soil. Under Alternative 4, to the extent practicable, soil will be excavated to meet risk-based cleanup requirements, so this alternative presents the least health and safety risks to future on-site populations. Effect of Contamination upon Beneficial Uses of Resource: Alternative 1 would not result in substantial reduction of COPC concentrations in soil, and would therefore, have little effect on the beneficial uses of the Site. Alternatives 2 through 4 include removal of COPC-impacted soil, which would substantially improve potential beneficial use, including allowing construction of commercial use buildings at the Site. For Alternatives 1 through 4, groundwater may attain ARARs over the long-term by natural attenuation. Effect on Groundwater Resources: As discussed in Section 6.1.2, risk estimates for the vapor intrusion pathway based on COPCs in groundwater at the Site are below non-carcinogenic and carcinogenic the target risk levels of 1 and 10-6, respectively for Alternatives 3 and 4. Additionally, representative concentrations of COPCs in groundwater are below risk-based goals developed for the most Page 53 of 72

7 conservative (i.e., health-protective) alternative (i.e., Alternative 4; Section 3.4.2). Therefore, there is currently no impact on groundwater resources with respect to human health concerns from the vapor intrusion pathway under Alternatives 3 and 4. Although representative concentrations of COPCs in groundwater are below riskbased goals developed for Alternative 4, due to the conservative assumptions regarding future fill soil used at the Site and shallow depth to groundwater, vapor intrusion modeling results estimate a greater than 10-6 CR to future On-Site Commercial/Industrial Workers occupying the first floor of an above-grade building (i.e., Alternative 2 scenario). Therefore, Alternative 2 includes preexcavation groundwater treatment and post-construction vapor mitigation measures (see Section 5.2). As discussed in Section 3.3, the probability of using Site groundwater for domestic and municipal supply is low, however, the domestic use beneficial use has not been de-designated at the Site. Alternatives 3 through 4 would have a positive impact on this beneficial use because under these alternatives, COPCimpacted saturated zone soils would be removed and disposed of off-site. As mentioned above, in situ groundwater treatment under Alternative 2 would also have a positive impact on this beneficial use. For all alternatives, groundwater concentrations are expected to attain drinking water-related ARARs over time by natural attenuation. A discussion of the empirical evidence supporting ongoing natural attenuation of the risk-driving chemicals under Alternative 2 (i.e., carbon tetrachloride and vinyl chloride) is provided in Section 5.2. Site-Specific Characteristics: The Site-specific characteristics include existing engineering controls (cap and slurry wall), the mixture of inorganic and organic COPCs in soil and groundwater, current and future Site use and development plans, and space limitations of the Site. These Site-specific characteristics were considered during the evaluation and development of remedial technologies and alternatives for the Site. Cost Effectiveness: Cost estimates for the four alternatives are summarized in Table 7. The cost associated with Alternative 1 is low, but this alternative is not considered cost effective because the Site use under Alternative 1 is not consistent with future development plans. The cost of Alternative 2 is moderate, and Alternative 2 is cost effective if future development plans are consistent with the development proposal under this alternative. The cost of Alternative 3 is higher than Alternative 2, but is cost effective if future development is consistent with the development proposal under Alternative 3. The cost to implement Alternative 4 is the highest and reflects the cost to remove soil to attain risk-based cleanup. Alternative 4 is not considered to be cost effective because the incremental protectiveness to human health and environment is not justified by the significantly higher costs and uncertainty associated with soil excavation to attain risk-based cleanup. Page 54 of 72

8 Potential Environmental Impacts of Remedial Action: Alternative 1 would have no new environmental impacts because remedial actions would not be implemented. Alternatives 2 through 4 include off-site disposal of soil containing COPCs and would result in the reduction of chemical volume, toxicity, and mobility in on-site soil. Excavated soils would be trucked to off-site permitted land disposal facilities that manage wastes containing COPCs in a manner that restricts mobility and toxicity in accordance with standards promulgated by the relevant regulatory authorities in the facilities operating permits. Potential environmental impacts from soil remediation activities include traffic impacts, near the Site and along selected transportation routes, from the estimated 20 to 40 trucks per day entering and leaving the Site. These excavation and truck loading activities would have associated potential air quality impacts from dust, vapor, and odor generation during soil excavation, and potential stormwater quality impacts, which will be monitored and controlled in accordance with project plans approved by the pertinent governmental agencies. Alternative 4 has the greatest potential for off-site impacts due to a longer excavation period and greater number of truck trips. Alternatives 2 through 4 include mitigation measures and plans to be implemented such that soil remediation activities would not adversely impact the surrounding community. Additionally, DTSC and U.S. EPA have expressed a preference for implementing green technologies and practices in remediation projects, where feasible. According to DTSC s green remediation website 26, remediation technologies and practices may be considered green if they are less disruptive to the environment, generate less waste, include recycling, and/or emit fewer pollutants and greenhouse gases to the atmosphere than other options. The use of excavators, other machinery, and the truck traffic associated with the excavation and off-site disposal of soil under Alternatives 2 through 4 will result in emission of greenhouse gasses to the atmosphere related to fuel consumption. These greenhouse gas emissions will be proportionately greater for remedial actions of longer duration and with more truck trips. Alternative 2 would be expected to have the least emission of green house gases, and Alternative 4 would have the most. Hence, Alternatives 2 and 3 may be considered the more green remedial alternatives compared with Alternative 4 because overall less soil would be excavated and transported off-site. Alternatives 2 and 3 would have more reliance given to the use of on-site engineered barriers and institutional controls that are compatible with future Site development and provide protection of human health and the environment with fewer greenhouse emissions Summary of Comparison of Alternatives This subsection presents a summary of the comparative analysis of each of the remedial alternatives described in Section 5.0. This analysis focuses on the relative performance of each alternative against the NCP criteria. The consideration of State factors is incorporated into these summary conclusions and judgments of relative performance. 26 Information from DTSC s green remediation website was obtained from the following location: Page 55 of 72

9 Based on the future land use scenarios proposed in Alternatives 1 through 4, all four alternatives meet the threshold criteria. However, the future land use scenario associated with Alternative 1 is not consistent with future development plans as it does not include construction of a building on-site. Therefore, Alternative 1 is eliminated from further consideration. Alternatives 2 through 4 meet the threshold criteria based on future development plans. Alternative 2 includes excavation to 5.5 feet bgs or 12.5 feet msl (i.e., unsaturated zone soil) for construction of an above-grade building. Alternatives 3 and 4 include excavation to 15 feet bgs or 3 feet msl for construction of a building with one floor below ground. For Alternative 4, additional soil would be excavated to attain risk-based goals. The greatest potential for short-term exposures to COPCs, and potential off-site impacts from dust, odor, and traffic, are associated with Alternatives 3 and 4. Additionally, due to limited deeper soil data, the excavation period associated with Alternative 4 has a significant potential to increase from additional excavation activities required based on the results of confirmation soil sampling. While the additional excavation under Alternatives 3 and 4 provides some enhanced reliability in protecting human health and the environment because more impacted soil is removed, the incremental protectiveness to human health and the environment is not justified by the higher costs and possible short-term effects associated with additional soil excavation. Alternative 2 includes in situ treatment of VOCs in groundwater. Additionally, vapor mitigation under Alternative 2 allows for additional control and knowledge of the future conditions at the Site with respect to protecting human health. Therefore, as it is protective of human health and the environment under the future development plans while minimizing the potential for short-term adverse effects and providing additional control and knowledge of future Site conditions, Alternative 2 has been selected as the proposed alternative. Page 56 of 72

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