Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 166 of 381 Page ID EPA PUBLIC MEETING,#:13714 NOVEMBER 8, 2014
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9 EPA PUBLIC MEETING
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11 MONTROSE SUPERFUND SITE
12 DNAPL OPERABLE UNIT
13 PRESENTATION AND PUBLIC COMMENT
14 NOVEMBER 8, 2014
15 19800 SOUTH VERMONT AVENUE
16 TORRANCE, CALIFORNIA
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1 APPEARANCES:
2 Environmental Protection Agency:
3 U.S. EPA Region 9 BY: YARISSA A. MARTINEZ, Remedial Project Manager 4 600 Wilshire Blvd., Ste. 1460 Los Angeles, California 90017 5 Office of Community Involvement 6 BY: ALEJANDRO DIAZ, Community Involvement Coordinator 75 Hawthorne Street 7 San Francisco, California 94105 (415)972-3242 8
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10 Community Members:
11 Cynthia Babich
12 Florence Gharibian
13 Marlene Puentes
14 Philip Fernando
15 Cynthia Medina
16 Margaret Manning
17 Alfred Sattler
18 Savanna Medina
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1 I N D E X
2 SPEAKER PAGE
3 MR. DIAZ 4
4 MS. MARTINEZ 7
5 MS. BABICH 23, 54
6 MS. GHARIBIAN 29
7 MS. PUENTES 35, 51
8 MR. FERNANDO 49
9 MS. C. MEDINA 51
10 MS. MANNING 52
11 MR. SATTLER 58
12 MR. S. MEDINA 61
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Huntington Court Reporters256 & Transcription, Inc. 3 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 169 of 381 Page ID EPA PUBLIC MEETING,#:13717 NOVEMBER 8, 2014
1 TORRANCE, CALIFORNIA, SATURDAY, NOVEMBER 8, 2014
2 10:32 a.m.
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4 MR. DIAZ: Welcome, everybody. Thank you guys so
5 much for coming. I just wanted to thank everybody for
6 joining us today, and good morning, everyone, also. My name
7 is Alejandro Diaz. I'm with the U.S. Environmental
8 Protection Agency. I'm the community involvement
9 coordinator, and I have to my left here Yarissa Martinez who
10 you'll be hearing very shortly from about the DNAPL
11 contamination and the proposed plan itself, and then I also
12 wanted to give an opportunity for any local officials that
13 would wish to identify themselves to just really quickly
14 identify themselves. So I'm not sure --
15 MR. WARREN: I could say I'm Scott Warren. I'm a
16 geologist for the State of California.
17 MR. DIAZ: Great. Anyone?
18 MS. LY: Good morning, everybody. I'm Phunong Ly
19 with the Water Replenishment District. I'm an engineer, and
20 I manage the Groundwater Contamination Prevention Program.
21 MR. DIAZ: Great. Thanks. I also wanted to
22 introduce someone that's really important. We have been
23 working in the last couple of years with an independent
24 technical advisor, and he's here today. I just wanted him to
25 wave to us. Marcus, if you can just say hi to everyone.
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1 Thank you. Marcus, has been really great, and we like having
2 him here. If you guys have any questions for him, if you
3 kind of wanted to talk to him during any of the breaks,
4 you're more than welcome to, and he has agreed that he is
5 also willing to talk to any community members.
6 So finally we're here to talk about the Montrose
7 DNAPL proposed plan. We use the word -- term "DNAPL" a lot,
8 and we'll be explaining it in the presentation. I just
9 wanted to let everyone know we have restrooms just kind of
10 right around the corner. The sign-in sheet is also really
11 important. It's over on that table. So we're hoping that
12 everyone who has a chance can get to sign in. I am also
13 going to say something In Spanish really quickly in case we
14 have anyone who needs Spanish interpretation.
15 (Testimony in Spanish.)
16 MR. DIAZ: There's also some coffee and pastries
17 available in the back, and if you can please silence or turn
18 off your cell phones. I just want to give you guys a run
19 through of the agenda really quickly. This is a lot
20 different than normal public meetings. This is an official
21 meeting that's required by law. So there's a lot of things
22 that need to run in a particular order. The first thing that
23 you'll hear from is you'll here from me for about 10 minutes
24 which you're doing is now which I appreciate.
25 Secondly, Yarissa will talk about the plan for a few
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1 minutes, and then afterwards or during the presentation, if
2 you have any clarifying questions, feel free to ask those.
3 Clarifying questions are, you know, what is the area of
4 DNAPL, if it's not clear or things like that, and then
5 afterwards the formal public comments. We'll let everyone
6 who wants to say some public comments to come up to the
7 microphone here, and originally I had planned for three
8 minutes, but it doesn't look like there's a lot of folks
9 here. We'll kind of just let you run as long as you would
10 need to -- to make those formal comments. We're also not
11 going to do the public speaking cards because of the same
12 reasons. Sometimes there's a lot of people, and we want to
13 keep track of everyone. So we'll just kind of do it by raise
14 of hands when we get started with the public comment period.
15 Then also, just wanted to let you know that the
16 public comment period has been extended through February
17 13th, 2015. We announced that on the website, and we have a
18 postcard that will be coming to the community to the same
19 names on the list that everybody received letting people know
20 that the public comment period has been extended to February
21 13th, 2015, and in addition, one of the things that's
22 different in this public meeting is that we also have a court
23 reporter here to my right who is recording, who makes sure
24 that your comments are recorded accurately. So when you guys
25 do come up, the first thing I'm going to ask you guys to do
Huntington Court Reporters259 & Transcription, Inc. 6 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 172 of 381 Page ID EPA PUBLIC MEETING,#:13720 NOVEMBER 8, 2014
1 is approach the court reporter and just make sure she has
2 your name correctly.
3 Finally, there's these ways of submitting public
4 comments also. You don't have to submit them today if you're
5 not ready. There's e-mail. There's regular mail. There's
6 phone and fax, and also if you don't like speaking in public
7 but would rather just say something, then after the meeting,
8 you can approach the court reporter, and she can transcribe
9 your comments herself. So that being said, I'll go ahead and
10 turn it over to Yarissa who is going to talk a little bit
11 about DNAPL.
12 MS. MARTINEZ: Hello. Can everybody hear me? No?
13 Yes? I know that during the DNAPL workshop, a lot of people
14 complained that I wasn't using the mike correctly. So now I
15 have two. If anybody feels that I don't -- I'm not able to
16 express through the mike, let me know, and I can get the
17 other one, just double it. Okay. So good morning again.
18 Thanks for being here so early. As Alejandro said, I'm going
19 to be talking about DNAPL. I would like to talk to you about
20 the Montrose Superfund Site. I will start with what is
21 DNAPL. A quick summary of basic facts of the former Montrose
22 property and the previous activities that caused DNAPL to be
23 in this site. Followed by a description of components of the
24 DNAPL and how remediation of groundwater has been decided and
25 how it affects DNAPL. The differences between mobile and
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1 residual DNAPL, technology screens, remedies evaluated, and a
2 preferred remedy for DNAPL. So please bear with me through
3 this presentation.
4 So what is DNAPL? To give you a mental picture,
5 DNAPL looks like molasses. DNAPL is a term given to one or a
6 group of substances that do not dissolve in water easily and
7 are heavier than water. So it doesn't float. As the term
8 says, it is still considered a liquid, and it is not water.
9 It has its own characteristics and depending on the
10 contaminants is how you can treat it. DNAPL at the former
11 Montrose Plant Property happened as a result of the
12 production of DDT and management of the chemicals used to
13 make the pesticide. A little background about Montrose, it
14 was the largest manufacturer of DDT in the United States,
15 active from the '40s to the '80s and produced up to 7 million
16 pounds of DDT per month.
17 This means that approximately 80 million pounds per
18 year of technical grade DDT powders, which were manufactured
19 in this property and included a network of waste streams,
20 waste ponds, sanitary sewers, and even dumped in the open
21 ocean. Therefore, in this site we have groundwater, soil,
22 and surface water contamination from previous DDT
23 manufacturing activities. The Montrose Superfund Site was
24 included in the National Priority List, which is a list of
25 the most contaminated sites in the US in 1989. It has been
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1 divided in seven operational units to address all the media
2 that had been affected.
3 EPA, the lead agency, makes the final remedy
4 selection and documents it in a decision document. So this
5 slide will give you a snapshot of the chemistry behind DDT
6 activities in the Montrose Property. This is important
7 because you will see some of these chemicals later on in this
8 presentation. So you have the raw materials which are
9 Chloral and Monochlorobenzene, which we will refer to as
10 Chlorobenzene, which are mixed with Sulfuric Acid, which is a
11 very strong acid that is used as the catalyst to react and
12 produce DDT.
13 So as you saw in the previous slide, Chlorobenzene
14 was used to produce the pesticide. The DNAPL that we have in
15 this site is composed approximately half DDT and half
16 Chlorobenzene by weight. Let me talk a little big about
17 these two contaminants. DDT is a pesticide that was widely
18 used in the 1950s and '60s very effectively against malaria
19 and other insect carrying diseases before being banned in
20 1970s. DDT is a white waxy solid that attaches to soil
21 particulates and remains in the environment, without breaking
22 down easily. DDT is not soluble in water, but when it is
23 mixed with Chlorobenzene it forms DNAPL. Chlorobenzene is a
24 semi-volatile, meaning that it can evaporate easily and
25 dissolves little in groundwater.
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1 These two contaminants that make up the DNAPL when
2 looked at separately have the following characteristics:
3 DDT, pesticide, bioaccumulates, meaning that it stays in the
4 body of animals through the food chain. It is highly toxic
5 to wildlife even at low concentrations, affects the way the
6 human body deals with hormones, and it is a know carcinogen.
7 Chlorobenzene affects the liver, and it is not a carcinogen.
8 By the mid 1960s, the area saw additional industrial and
9 commercial growth. I want to point out where the central
10 processing area was, because that is where we found DNAPL.
11 The next picture shows an archive picture of the processing
12 equipment for technical grade grinding. So by 1982, Montrose
13 had discontinued the production of DDT, and in 1985 an
14 asphalt cover was installed on the surface. As you can see,
15 the former Montrose Plant Property is vacant, and it is
16 surrounded by commercial, industrial, and residential areas.
17 Currently the water treatment plant is being built here and
18 will be completed in a couple of weeks.
19 So now that we have seen the area and have a little
20 bit of story of the site, I would like to talk to you about
21 how DNAPL and groundwater are related. To give you an easy
22 example, if you have a gallon of milk in the fridge, and it
23 has a hole and you see milk everywhere and you start cleaning
24 up the milk, but you don't remove that gallon of milk or
25 empty it, you will still have a lot to clean up. So DNAPL is
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1 like that gallon of milk that you -- that we are seeing as a
2 source. So it would be the source of the groundwater plume.
3 Again, the DNAPL happens just -- and you'll see it in the
4 maps following this. It just happens inside the Montrose
5 Plant Property.
6 So I want to stress that the drinking water for all
7 Southern California from water purveyors, LADWP being one of
8 them in the area, and that there are not drinking water wells
9 in the contaminated water, and at least one mile away from
10 the plume, and they are sampled routinely. So let's talk a
11 little bit about the groundwater remedy. Around the 1980s
12 and '90s, EPA determined that due to the mixed groundwater
13 contamination from Del Amo and Montrose, a dual groundwater
14 remedy should be in place. In 1999, the record of decision
15 for this dual site groundwater was published to prevent
16 exposure and to address the various contaminants in the site.
17 One of the main active remedies of this decision is the
18 groundwater treatment plant. There's a picture just looking
19 towards Normandie of the new groundwater treatment plan. So
20 to put everything in perspective, here's -- I'm going to need
21 your pencil.
22 Here's Montrose and Del Amo. So you have Montrose
23 and then you have the Del Amo Superfund Site, and you have in
24 red, you can see the Benzene plume from Del Amo, groundwater
25 plume, and you can see green which is in the middle, the
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1 Chlorobenzene plume, and then you can see the blue blob or
2 the blue plume is the TCE that comes from different TCE
3 parties -- responsible parties. So one thing I want to point
4 out in this map is the dark blue area right there. So it has
5 two different parts of it. That's the DNAPL -- the mobile
6 DNAPL inside the Montrose property. The green boundary that
7 you can see very defined, that includes mobile and residual
8 DNAPL. Again, it just happens inside the Montrose Plant
9 Property. So this slide was included in the proposed plan.
10 NAPL occurs in two forms, LNAPL and DNAPL, and even
11 though the concepts are the same for this slide and related
12 to the slide, we'll refer to it as DNAPL. So in this figure
13 you can see a drawing of mobile and residual. The mobile
14 DNAPL is the mass that holds together and it's continuous.
15 Because of the properties of DNAPL, some portions get stuck
16 between the soil particles, and those portions are considered
17 the residual DNAPL. As we said -- and as we said in the
18 October workshop, once it becomes residual, it does not
19 become mobile. So DNAPL has been defined by more than 200
20 soil borings, which are holes in investigations we did in the
21 ground for over 10 years, and it was detected from a minimum
22 of seven feet below ground surface up to a maximum of 101.5
23 feet below ground surface.
24 This shows the extent -- the lateral extent of
25 DNAPL, which when you add up the two blue areas, it's almost
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1 half the area of a football field. Simply stated, the
2 revenue objectives for the DNAPL in this area are to prevent
3 human exposure to DNAPL, limit the migration and reduce
4 mobile DNAPL contamination as much as possible and to make
5 sure DNAPL does not continue to act as a source of
6 groundwater contamination. During the process of looking at
7 what technologies are able to address the DNAPL at the site,
8 we looked at many technologies. Some of the technologies
9 that we looked on at early stages included Hydraulic
10 extraction, bioremediation, or other injections to reduce
11 contaminants, excavations and slurry walls. However, due to
12 the contaminants, the location of the site, depth of the
13 contaminants, and the groundwater plume of the area, most of
14 these technologies were discarded because they were not the
15 right actions for the site.
16 The technologies that were right for the site were
17 when we looked a little bit further. In summary we have
18 eight remedial actions composed of four different
19 technologies, SVE, hydraulic displacement, steam injection,
20 and electrical resistance heating, and various institutional
21 controls are being considered in this plan. So going to the
22 technologies that were considered, one of the technologies
23 that was considered as part of all the different remedial
24 actions active is the soil vapor extraction. It mainly -- it
25 basically vacuums vapors out of the soil and treats the
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1 vapors on the site. With this technology, you would drill
2 extraction wells into the contaminated soil to a depth above
3 the water table and attached to the wells is equipment that
4 creates a vacuum. The vacuum pulls air and vapors through
5 the soil and up the well to the ground surface for treatment,
6 and this is what you would see at the site. In your -- you
7 see the Del Amo soil vapor extraction system.
8 The other technology that was considered was
9 hydraulic displacement. Hydraulic displacement, in summary,
10 uses injection and extraction wells of water to move
11 contaminants. Extraction and injection of the groundwater at
12 the same time to help control water flow and pull DNAPL
13 toward extraction wells, and this is what you would see at
14 the site. It's usually underground wells. Two of the active
15 technologies that can address DNAPL are thermal remedies. In
16 thermal remedies, heat is applied to the ground to turn
17 contaminants into vapors so as to collect and treat them. In
18 situ, which just means at the site, thermal treatment methods
19 heat chemicals and soil and groundwater to turn them into
20 vapors. The chemicals move through soil and groundwater
21 toward wells where they are collected and piped to the ground
22 service to be treated.
23 One of the thermal remedies is called steam
24 injection where steam is injected underground to help turn
25 contaminants into vapor to help collect and treat them. It
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1 injects steam underground by pumping it through wells drilled
2 in the contaminated area. The steam heats the area and
3 mobilizes and evaporates the contaminants. The electrical
4 resistance heating is another type of thermal remedy. It
5 delivers an electrical current between metal rods, called
6 electrodes, installed underground. So heat is generated as
7 movement of the current meets resistance from soil converts
8 groundwater. So it basically -- there's metal rods in the
9 ground that you apply electricity and this will heat the
10 contaminants and vaporize them, and then you can collect
11 them. So the proposed remedies are listed here. I'll go
12 through each of them individually.
13 EPA is required to look at this alternative, no
14 action, and the reason of it is to be able to compare what
15 would happen if we didn't do anything at the site. Our
16 second alternative will be just doing institutional controls.
17 Institutional controls are legal and administrative controls
18 that applies to properties to minimize the potential for
19 exposure. So in this case, it would be a land use covenant
20 that will restrict activities at the Montrose property for
21 industrial use. Our remedial alternative number three would
22 be to make sure of institutional controls and soil vapor
23 extraction. The remedial alternative four would be hydraulic
24 displacement. We have two different versions of the
25 alternative four which included with treated water or with
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1 untreated water.
2 Our remedial alternative five would be steam
3 injection and it's included steam injection only on the
4 mobile DNAPL or over the entire DNAPL area. And our sixth
5 remedial alternative would include electrical resistance
6 heating, or as we call it, ERH, over the mobile DNAPL area or
7 over the entire DNAPL area. So EPA, after -- after we go
8 through the technologies considered and we make up remedial
9 alternatives, we do a comparison, which is part of our
10 regulations and we look at if they're protective of human
11 health and the environment which determines whether the
12 alternative eliminates, reduces, or controls the threats to
13 human health. We take a look at the compliance which is,
14 does the remedy comply with local, state, and federal
15 regulations. We look at long-term effectiveness which is
16 considered an alternative ability to maintain reliable
17 protection of human health in the environment. We look at
18 the mobility reduction, quality of reduction, which means if
19 the treatment addresses or reduces the contaminants on site.
20 Then we look at short-term effectiveness which says
21 if during the implementation process, there's any adverse
22 effect to human health in the environment. So this is just a
23 pictorial graph of how we do this comparison. As you can see
24 here, our remedial alternative, the one that is preferred by
25 EPA, is the one that most complies with all of the different
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1 requirements. So looking at long-term effectiveness,
2 reduction of the mobility, the volume, and then comparing it
3 to cost, we have chosen ERH, focused treatment area as EPA's
4 preferred remedy. The duration of this ERA implementation
5 would be from three to seven years, and it would cost between
6 20 and 25 million. Again, I would like to say that the cost
7 presented here is basically a comparison tool. So it might
8 be up or down a little bit. It's not the actual cost for
9 implementation. So following the regulations that --
10 following the superfund regulations, we are required to
11 choose a remedy that is the most cost effective.
12 This would be a diagram of how the electrodes would
13 be put in the ground for electrical resistance heating
14 applied to the two areas that have mobile DNAPL. These are
15 just pictures of another ERH implementation in San Francisco.
16 Our estimated schedule for this, today is the proposed plan
17 meeting. We have extended the public comment period all the
18 way to February, and hopefully by 2015, we have a record of
19 the decision very late in 2015, and we can start the remedial
20 design and the remedial design would be starting in 2015,
21 2016. And then by 2018, hopefully the remedial construction
22 and clean up happens. And Alejandro will rap up this.
23 MR. DIAZ: So again, February 13th is the last day
24 to submit public comments. If you're sending them by mail,
25 they must be postmarked before or on February 13th, and in
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1 addition, what happens next is that the EPA takes the public
2 comments as a criteria for -- as one of the nine criteria for
3 finally making a decision, and EPA will provide a response to
4 those comments submitted when we publish the record decision
5 itself. So that concludes our meeting -- I mean, no. Not
6 our meeting. I'm sorry. That concludes the presentation.
7 Right now I just wanted to open the floor up if anybody had
8 any clarifying questions, if something wasn't clear, if you
9 would like one of the alternatives to be explained a little
10 bit more or anything like that. Anybody?
11 UNIDENTIFIED SPEAKER: Yes. Explain the
12 bioremediation more.
13 MS. MARTINEZ: So hello. So bioremediation, it was
14 not retained because of the high concentrations of
15 Chlorobenzene we have in the area. DNAPL are toxic to
16 Chlorobenzene in creating bacteria. So during the section
17 four of the FS, we do this because there was some returned
18 data that indicated a Chlorobenzene can be biodegraded to
19 some extent and also DDT is not biodegradable. So it was
20 ruled out.
21 MR. DIAZ: Did you have a follow-up to that, or did
22 you have something else?
23 UNIDENTIFIED SPEAKER: No.
24 MR. DIAZ: Yes?
25 MS. C. MEDINA: (Inaudible).
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1 MR. DIAZ: Yes. How will you handle the extracted
2 vapors?
3 MS. MARTINEZ: So everything will be on a vacuum
4 which is part of this whole vapor extraction system and
5 everything will be filtered.
6 MR. DIAZ: And can you clarify if we know how we
7 will be treating those? I think that was his question. What
8 type of treatment?
9 MS. MARTINEZ: So as of now, we're evaluating the
10 use of carbon. So we will not have any flames or any thermal
11 issues at the site. We will not.
12 MS. C. MEDINA: I don't know if this pertains to it,
13 but you mentioned that it was going to cost -- an estimated
14 cost of 20 to 25 million just for the DNAPL extraction. So
15 the (inaudible) clean up was 20 million -- or 10 million.
16 Sorry, and the water that construction is going on for the
17 water clean up now, wasn't there any discussion of how much
18 money is spent to clean up compared to just removing the
19 people, you know, get the people out of the way and just
20 cover it all up and just save all that money? It's -- that
21 is a lot of money.
22 MS. MARTINEZ: I understand.
23 MS. C. MEDINA: And during this whole process we're
24 still exposed. No matter how filtered or how clean
25 everything that you propose to do, we're still going to be
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1 exposed. It's still going to be there. When you use the
2 example of the gallon of milk spilling into a refrigerator --
3 so we have this contamination spilling into our soil and
4 where we live, and you're going to clean it up, but you're
5 not removing the gallon of milk. You're not removing the
6 DNAPL that's the -- the resistant one.
7 Anyway, this is not my expertise, but to compare the
8 money that you're spending on clean up is nothing compared to
9 just removing the people out of the danger. I mean, in my
10 opinion, it's (inaudible) to why would the government who was
11 always, always saying that, you know, they're stretched out
12 to the max, and they don't have money for this and for that
13 and they can just spend 20 million dollars like that to clean
14 up something that's not even guaranteed to be cleaned and
15 it's not going to guarantee that we're going to be safe. I'm
16 getting emotional here so here you go.
17 MR. DIAZ: So thank you, Cynthia. If you want to
18 come up during the comment period and say that again, you're
19 more than welcome to. If not, we'll consider that as a
20 comment.
21 MS. C. MEDINA: Thank you.
22 MR. DIAZ: So is it another clarifying question?
23 UNIDENTIFIED SPEAKER: In other words, will there be
24 a competitive cost comparison between removing people and the
25 cost of the clean up? Will there be a very clear cost
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1 comparison?
2 MS. MARTINEZ: I don't know if that was ever done.
3 I think, you know, following the superfund process -- and I'm
4 sorry. I have to go back to what I'm presenting here. We
5 just looked at the technologies available to mediate the
6 issue at hand.
7 MR. DIAZ: So it it looks like we're --
8 UNIDENTIFIED SPEAKER: Just a clarifying question.
9 I realize this is a DNAPL meeting, but you had a slide
10 covering the groundwater treatment system. Can you just
11 clarify on whether or not that groundwater treatment system
12 is in operation now? Are you done with the construction of
13 the treatment system?
14 MS. MARTINEZ: No. We're not. It should be --
15 construction should be completed in the next couple of weeks.
16 MR. DIAZ: Okay, and with that --
17 UNIDENTIFIED SPEAKER: And again, I guess it's
18 outside the scope of this public hearing, but, you know,
19 perhaps some greater understanding of the relationship of
20 that groundwater clean up system to this might well be
21 helpful in the group understanding here in the room.
22 MS. MARTINEZ: Okay. So can you put the slide of
23 the groundwater plumes? Okay. I'm going to try this, and
24 again, this is just a pictorial. I wanted to showcase how
25 DNAPL only happened in the Montrose property. We have
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1 various commingled plumes of groundwater in the area. The
2 DNAPL serves as a source of the Chlorobenzene in the
3 Chlorobenzene plume, and that's how it pertains to the DNAPL
4 removal here. If you wanted me to talk a little bit more --
5 MR. DIAZ: Maybe you can talk about all of the
6 sources that are known in the area of groundwater
7 contamination.
8 MS. MARTINEZ: Okay. So we -- again, this is not my
9 operational unit. So I would like to limit the discussion as
10 much as we can as to DNAPL. So for the Chlorobenzene, we
11 know what the source is which is the DNAPL. For Benzene,
12 there's a couple of (inaudible) and we also have the waste
13 piles and then for TCE, there's more than 10 responsible
14 parties that through the history of activities in the area
15 have discharged TCE to the groundwater. TCE is a soil vent
16 that is used in many industrial --
17 MR. DIAZ: Can you give the name of the chemical?
18 UNIDENTIFIED SPEAKER: Inaudible.
19 MR. DIAZ: Does that help clarify your question? I
20 want to make sure that you -- okay. Great. So with that,
21 we'll go ahead and get started with the formal public
22 comments. Again, I'll be calling you guys up one by one and
23 you guys can use the podium where Yarissa is. So Yarissa, if
24 you can clean up your stuff that you have there, and you can
25 go ahead and like I said, since there's not that many people
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1 here today, we'll just go ahead and go as long as you need to
2 talk. So with that, the first person that approached me and
3 requested to talk before was Cynthia Babich. So I want to go
4 ahead --
5 MS. BABICH: Good morning, everyone. Thank you for
6 coming. I'm Cynthia Babich, and I'm director of the Del Amo
7 action committee. The Del Amo action committee was formed by
8 community residents over 23 years ago to work specifically
9 on the contamination issues impacting our community from the
10 Del Amo and Montrose sites. I'd like to express our
11 thankfulness to the extension of the comment period until
12 February the 13th of 2015, and I would like to also make a
13 request that this type of a meeting is repeated closer to the
14 end of the comment period because the reason that we asked
15 for the extension of the comment period was so that we could
16 do appropriate education inside the committee door to door.
17 As you can see, there are people that have come
18 today, but in my thinking back of my 23 years of work in the
19 committee, there are people that I have been working with for
20 that long that were already in retirement when I started. So
21 I think that their input is key and valuable, but I do not
22 think that they would be able go make the truck even though
23 the hotel is very close to the community to this type of a
24 meeting. So we are hoping that through our outreach, we will
25 be able to take comment cards out with the EPA. So that we
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1 can capture people's comments that way as well.
2 So I think it is also very important again though
3 that this venue be repeated because a lot of people will want
4 to give their comments verbally, and I think having the asset
5 of somebody who types down their comments word for word is
6 very important rather than the retelling of their particular
7 story by somebody else's version. Which would lead me to my
8 first comment. Many years ago in a meeting similar to this
9 with an EPA person that, at that time, I would call a
10 visionary. His name is Mike Montgomery. We were talking
11 about accountability, and he had the strangest look on his
12 face and he said yes. Absolutely right. Accountability. In
13 fact, I'm going to print that out in big block letters, and
14 I'm putting that over my desk which then made me think a
15 little bit differently of what we were talking about.
16 I said well, what are you talking about, and he said
17 well, I have to be accountable to people in San Francisco and
18 on Washington on the decisions that we make in this
19 community, and so accountability is very important for me,
20 and I said well, that is clearly different than what I'm
21 thinking about accountability. I think that the
22 accountability that we are seeking through this process and
23 other processes that are before us with regards to this kind
24 of contamination is the accountability that needs to be made
25 to the impacted community. I think that what their needs are
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1 need to be put foremost and first, and I think that the
2 comments that Mrs. Medina made were very, very important, and
3 people would argue that this is not the time or place to talk
4 about relocation or moving people out of harms way.
5 I would argue that every opportunity that we have is
6 the time and place to remind people that this has been going
7 on for decades and the clean ups that are being planned are
8 going to occur for 3,000 to 5,000 years, and I make that
9 remark because over 15 years ago, somebody decided, not the
10 community, that they could have a technical impracticability
11 waiver for cleaning up contamination in this area. Meaning
12 that at that time 15 years ago, somebody decided that it was
13 technically impracticable to try to clean up the gross
14 contamination that has been heaped upon our community. I
15 would like to also point out that somebody else also had the
16 bright idea of actually including people's homes in this
17 containment zone.
18 I would think that would be against the law, and
19 that would be apart of taking -- you're taking somebody's
20 property, and so many years ago I asked the EPA about this
21 technical impracticability waiver sometimes called the
22 containment zone, and people looked at me curiously saying
23 well, don't you realize it's going to take 3,000 to 5,000
24 years to even get there as if I shouldn't really worry about
25 the fact that we're all going to be dead and our children are
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1 going to be dead and their children's children's children are
2 going to be dead by the time we actually see containment of
3 this contamination. And I think it is wrong on many levels
4 to leave people as genie pigs sitting on top of this
5 contamination. When we talk about pieces of contamination,
6 Yarissa mentioned that this wasn't her particular operable
7 unit when she was discussing some of the other plumes.
8 I'd just like to point out that Montrose has seven
9 operable units and Del Amo has three and they share one, and
10 how in the world with anybody who has a degree in common
11 sense like I do would think that, how are you going to fit
12 all those pieces together? Yet time after time and even in
13 the feasibility study, we're told that somehow magically this
14 removal action is going to impact that removal action, and I
15 think that was the question that was asked earlier. How are
16 you possibly going to measure the changes or any clean up
17 that's going to happen when you have all these operable units
18 that going on at different rates, and I think that to give
19 people an answer that somehow it's magically going to come
20 out really great at the end is not reasonable, and I don't
21 think it's an honest answer.
22 So I would like to say we are looking for
23 accountability for our community, and I think that everybody
24 in this room should be holding that for most as well. The
25 discussions that were made 15 years ago in 1999 need to be
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1 revisited. Had people made a decision and got right to work
2 on putting in the treatment system, we would have an up and
3 running treatment system and that system would require that
4 every five years we review new technologies and emerging
5 things that, you know, we didn't know about 15 years ago to
6 make sure that we are really getting this mess cleaned up in
7 the best way possible and that has not happened. In fact,
8 there would have been three five-year reviews. So we have
9 asked and we will continue to ask that the technical
10 impracticability waiver zone be revisited.
11 I think this needs to be done with all state holders
12 especially the community because while it's been presented
13 today that people have worked very hard for 15 years to come
14 to this conclusion that we want to stick electrodes in the
15 ground and fire those puppies up and start moving this
16 contamination, that I'm not clear we even know where it's at
17 now and yet we're going to start moving it around and somehow
18 magically it's not going to make things worse that we would
19 want to make sure that indeed there isn't something better
20 and the conversations that have gone on with different
21 agencies like the department of toxic substance control and
22 the water replenishment district, and there's probably others
23 that I'm not mentioning have probably all been very
24 fascinating and full of great information.
25 Again, the people who are being impacted by this
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1 contamination are left back at the starting gate trying to
2 somehow figure out how all those come together. Why people's
3 homes are in a technical impracticability waiver zone. Why
4 some promising technologies have been screened out and why
5 time is of such an essence that they can't wait for us to get
6 up to speed and utilize the technical advisors that have been
7 put at our disposal considering that we're talking about 3-
8 to 5,000 years to get to containment. I understand from the
9 documents that have been presented to us that as far as the
10 DNAPL portion of the remediation goes, they're estimating a
11 three- to seven-year timeline, but still as Mrs. Medina
12 pointed out, that's going to leave contamination behind.
13 If Angela Johnson was here who is one of our most
14 favorite people who loves and helps our community, she would
15 argue that if you thought that DNAPL was syrup, it would keep
16 giving its sugary goodness to us for decades to come. So we
17 think that when we look at these technologies, we really need
18 to look at actually removing the contamination, and when we
19 think about what's going to go on at the groundwater
20 treatment system that's being put into place now and being
21 tested and somebody mentioned about the carbon treatment
22 system that's going to happen, and that sounds really --
23 something that won't blow up which is always nice, but it
24 sounds something very passive and very nice, but really the
25 fact remains is that that carbon that becomes contaminated is
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1 going to go to native tribes around the Colorado River.
2 It's going to be burned and regenerated there in one
3 of their systems. So simply to remove it from our backyard
4 and put it in somebody else's is not always the answer and
5 that is why I believe and many others believe that you have
6 to have average community people at the table to look at some
7 of these concerns not with the lense of how much it costs. I
8 would like to request that the EPA do a formal technology
9 screening very quickly where we look at the technologies that
10 are at our disposal today, and before any decisions are made
11 on the technologies that EPA has screened so far. I would
12 also like to point out that doing anything is not the same as
13 doing something. Thank you.
14 MR. DIAZ: Thank you, Cynthia. It looks like
15 Florence here wants to make some comments.
16 MS. GHARIBIAN: My name is Florence Gharibian. The
17 first thing I want to say to the people in this room who are
18 empowered to do something about the Del Amo/Montrose
19 site -- I do not call it sites. I do not call it operating
20 units. I call it the Del Amo/Montrose site because the
21 co-mingled waste is the problem, and it needs to be solved
22 holistically. What I want to say to you is you really can
23 clean this up. You can clean it up, and you can clean it up
24 in our lifetime, and I want you to believe that it's possible
25 to do that and not accept impossibilities or discussions of
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1 how it's going to take 5,000 years. I want you to think you
2 can do it, and you can do it in our lifetime.
3 I want to do some time frames here. We had a draft
4 viability study that was published in 2011 and that study was
5 there and then commented on in December of 2012 by both the
6 department of toxic substances control and by the water
7 replenishment district, which is the organization that helps
8 ensure that all of us have clean drinking water. Then it
9 went to an EPA review board in 2013, and then they gave their
10 comments and now we're sitting here and it's November of 2014
11 and we're still working on it. So the timing of all these
12 things is really an issue. As Cynthia mentioned, work on the
13 site started in the early '80s and the groundwater treatment
14 system is going to go online recently soon, I guess.
15 Although the group has a very serious concern about that, and
16 just to let you know, I am honored to serve with Cynthia as
17 the chair of the Del Amo action committee. Something that I
18 am very privileged to do.
19 So timing is important, and now I want to get to my
20 first comment and say this is an identified comment to be
21 found in the comments that were prepared by our technical
22 advisor, and I'm going to do a quote. "In order to be more
23 transparent, EPA should clearly state that the proposed
24 remedy neither addresses DNAPL that could be practically
25 remediated outside the focus treatment area or the DNAPL
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1 below the residual saturation inside the treatment area. EPA
2 should also be more forthright and transparent with respect
3 to the decision namely that it is because it is still
4 believed that the most aggressive and expensive remedial
5 approach could not possibly remove all the DNAPL from the
6 Montrose site. So it is therefore acceptable to leave a
7 large residual fraction behind even if a potentially
8 significant fraction of this residual DNAPL could be
9 remediated."
10 So I'm saying remediate this DNAPL, and do that with
11 the belief that in remediating this, you are going to make a
12 big step forward in cleaning up the Del Amo/Montrose site. I
13 happened to know that there are wells on the Montrose site.
14 One well, if you pump it, you get DNAPL. It comes to the
15 surface. Another well that is really not very far away from
16 the first well, you can pump it, and you don't get DNAPL and
17 that caused me to believe that it's possible to do a removal
18 and make a big difference, and I have in the EPA response to
19 the comments that were made by the technical advisor, a
20 statement that excavation of the DNAPL impacted soils to a
21 depth of a 105 feet over a 160,000 square foot source area
22 would be infeasible and might cause a billion dollars.
23 I have a lot of trouble with all of those numbers
24 and trying to make them make sense when I see these two
25 concentrated areas of DNAPL on this map, and let's be clear
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1 about it. We're not talking about molasses or syrup. We're
2 talking about toxic chemicals that are in our area and in our
3 groundwater that ought to be cleaned up. Another thing I
4 want to say is that in order to achieve this goal, you need
5 the best minds at the table, and I would like to suggest that
6 there be a convening of a group that includes the department
7 of toxic substances control, the water replenishment
8 district, the regional water quality control board and others
9 possibly even from academic settings to look at these issues
10 holistically, and see if we can't come up with a better
11 approach.
12 I would also want our technical advisors to be part
13 of that group. Great minds can come up with great things,
14 and that's what we need here and the community needs to be
15 partnered in that effort. The department of toxic substances
16 control prepared written comments, our advisor prepared
17 written comments, the water replenishment district provided
18 written comments on this plan. I want to see them in the
19 public record and responded to in the public record. So
20 they're not a letter somewhere in a file. Believe me, I have
21 spent hours and hours trying to find all this information and
22 make sense out of it. It's a big job and having these
23 materials available to the public and in the public record
24 and part of the process is an important step.
25 Now, I also want to ask -- I also want to talk a
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1 little bit about another chemical that wasn't mentioned in
2 the charts. We talked about how DDT is not water soluble.
3 We talked about how Chlorobenzene is not water soluble, but
4 they did use a solvent and that solvent is water soluble and
5 possibly was used at the Montrose site because it's water
6 soluble and I know for sure three places where that solvent,
7 which is called PCBSA, turns up in this great United States
8 of America and one of them is right here at Montrose and one
9 of them is a little town in Michigan called Saint Louis,
10 Michigan, where they have their drinking water wells
11 contaminated with their material and another one is a string
12 fellow acid pits in Riverside County, and there was one point
13 when I thought I was going to have -- she worked on the
14 string wallow acid pits on my grave stone, but that was
15 another day and another time.
16 I want to know if PCBSA is in this DNAPL because I
17 remain concerned that it is enabling this material to be more
18 mobile. I want to know that it's not in our drinking water,
19 and I read some documents that suggested that EPA would be
20 monitoring the drinking water to make sure it wasn't in it.
21 I want to know they have actually done that work. PCBSA is
22 not something that drinking water companies routinely monitor
23 for when you get your drinking water, and I want to make sure
24 that we understand the extent of the pollution that was
25 caused by that chemical. There's another issue related to
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1 the wastewater treatment system related to PCBSA as well and
2 that is, will it be removed sufficiently because the water
3 that's treated in that groundwater treatment unit will
4 ultimately go into the clean portion of our groundwater
5 basin, and I see that as something we need to be very careful
6 about and very concerned about.
7 So I hope I haven't used too many technical terms or
8 gotten into too many territories that may not be actually
9 related to DNAPL, but I'm saying you got to look at the big
10 picture. I also want to make another very important point
11 that I make whenever I have any conversation about this
12 subject. When they test the human health effects of
13 chemicals, they test them individually. So there's data on
14 the harm caused by TCE, and there's data on the harm caused
15 by Chlorobenzene and there is some very, very limited data on
16 the health problems cause by CPSA.
17 Of the data that is available on what happens when
18 all of those materials are all present in one place, what is
19 the potential health effect on people of those combined
20 co-mingled chemicals that is really rough science and there's
21 not really a lot of information known about that, and that
22 makes doing the most careful -- the most conservative thing
23 possible to solve this problem, a really important thing. So
24 thank you for listening, and I'm glad I can be here today.
25 MR. DIAZ: Thank you, Florence. Marlene, you're
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1 next.
2 MS. PUENTES: Sorry I was late. I had my son. My
3 daughter was here earlier. I live at 1072 West Torrance. I
4 lived at 20430 Catalina Street right there in the
5 neighborhood. I lived at -- on Budlong. I lived on Kenwood.
6 My grandfather lived on 204 Street. My grandfather was an
7 employee at Montrose Chemical. He came from Colorado,
8 Denver, Colorado. They were healthy. All my family was very
9 healthy, abundant and healthy. He was working at Montrose
10 Chemical, and his first child that was born during that time
11 was my aunt Gloria, and she was born a dwarf, and our family
12 with all our numerous children that we have in my mom's
13 immediate family, my sister and I have, two of my sisters and
14 also I have 12 autistic children. My two are nonverbal.
15 One is 19 and the other one is 13. It's been a lot
16 of work, I'll tell you that right now. I'm suffering from a
17 terminal brain tumor, and I know about all these figures, but
18 I know what's going on in the community straightforward.
19 We're getting brutalized by the police department. We have
20 got yellow school busses in and out all day long. Now they
21 got this thing going on in the street right in front of my
22 house, and these ungrateful people. I gave them on the
23 hottest days of the year, lemonade, twice a day. I put a
24 little stand out there and I put lemonade, and I would always
25 serve them twice a day because I thought to appreciate what
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1 they were doing.
2 I actually at first wanted to make the biggest signs
3 I could ever make and just torture these people to stop them
4 because what in the heck is going on, and what I thought was
5 going on is that we're getting new pipes. We're not getting
6 new pipes. We're getting the same pipes that were parallel
7 to the pipes that were already there. So if you think those
8 pipes aren't contaminated, you're wrong, and all we're doing
9 is putting a band aid over a big thing that's bigger than 3-
10 to 5,000 years. It's happening now. It's filling up our
11 jail systems with people would have brain damage, people that
12 are born with autism.
13 In 1999, I just heard that the first meeting of this
14 sort was taken place, and I'd like to know -- or no. I do
15 know that Mary Bradley was instrumental in this and Angela
16 Back from Eyewitness News, and it was amazing to see it local
17 like that, and I was just a little girl, kind, and I was kind
18 of polite so I didn't do what I would do now. I would be all
19 over that. In 1999 is when I got my son's diagnosis. He was
20 the cutest little baby, the best little baby, you know, just
21 beautiful. And when he was diagnosed, I didn't know what
22 autism was, and I'm a smart person. I had already worked for
23 a real estate corporation. I was the young agent at 24. I
24 had two children. My daughter was very smart.
25 She was just here a little while ago. She has been
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1 to USC. I heard in third grade that when she took her first
2 test and it was a really big one that it was all downhill
3 from here because there's nothing as extraordinary as that
4 test score. Then I look at my son, and he's been going to
5 school since he was two and his backpack when he got on that
6 yellow school bus was bigger than him, but when I learned
7 what autism was at the beginning, I didn't know what it was.
8 I thought he could draw good. That's how uninformed and how
9 unrament was. Now, we went from one in 800 kids being born
10 with autism to one in 60.
11 We're not just talking aspergers and maybe this kid
12 might have AD -- whatever that's called. This is a life
13 form. This is not something that will go away because what
14 you're saying is ratify autism. These are individuals just
15 like -- I'm not for or against homosexuality, but they were
16 born like that. They have got laws protecting them. These
17 kids were born like that, and we look at ourselves and when
18 you hear the words it's environmental. You think was I not
19 eating enough nuts in the beginning of the first semester?
20 Was I doing something wrong through my pregnancy? Was I not
21 doing something right? Did I make a mistake? No. It's
22 already built within my family, and I personally am stuck at
23 home every single day. I have got this young, beautiful
24 husband, and he's so willing to try.
25 He's amazing because he knows so much more, and I'm
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1 just pouring it into him because I'm on my way out. I won't
2 see 3- to 5,000 years, but who's to say that kids are not
3 going to be important then? What if we're a society -- if
4 you look at this in the spectrum of what's going on, it feels
5 like when these kids are born in this manner, it's one in 60
6 now. We're going to be nation of people taking care of
7 people with autism because I have counted the people that
8 take care of my kids on an individual basis. There's 15
9 people every day that work for these kids, and I just can't
10 image why -- if a child was dying in a hospital, every 60 of
11 them, there would be an investigation. There would be
12 something going on, but they're alive and healthy and walking
13 around in society, and they're saying get rid of autism
14 speaks. It doesn't speak.
15 It's quiet. The people taking care of them are
16 quiet because we're stuck in the house because I call it
17 glassy glass. Everywhere you go everything is made of glass
18 and they're going to shatter it, and they're going to run.
19 I'm not feeling as well as I used to. I can catch if I need
20 to, and I have saved their lives a couple of times, and I
21 will continue to do that (inaudible). Children in schools
22 and senior citizens with Alzheimer's because they're like
23 little children too (inaudible). We could give free art
24 lessons to kids with autism in special needs units. We
25 created the slogan "don't do that." DDT. What's the first
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1 thing that we learn when we're born? Don't do that. DDT.
2 Dumping dangerous toxins. The problem here is that the
3 people that need the help most can't help themselves. They
4 don't know how to reach out. They have got POs chasing them
5 down.
6 They have got all these behavioral problems.
7 There's no social (inaudible) with these guys, and it's
8 really not even their fault. This is what I call zombie
9 warfare. We're going to have -- I have seen my kids, and I'm
10 not calling them zombies, but when your kids are born and
11 they're not going to talk, they're just going to walk up and
12 down throughout your house and flapping their hands in the
13 air, moaning. It looks like that and these guys know what's
14 going on, but I'll tell you what's even harder then getting
15 rid of DDT, getting social workers to get off your back and
16 help.
17 All of this matters and these kids are so hard
18 sometimes because I got two. They're opposites. When one is
19 good, the other is bad, but I'll tell you one thing. They're
20 my little angels. The 19-year-old, he is -- he's like a
21 little guy. He's been dummied down at his school because LA
22 Unified is running out, I see see-through walls being put
23 into the bank stuff. You know when you can't touch the
24 banker no more because that acrylic stuff? I see that at
25 school and I'm think this is a really bad South Park joke and
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1 I ask what that's for and they say it's for security.
2 It says on the top of the door "do not lock during
3 business hours" and they're locking that door. So what is
4 the door there for, and why is it important to have that door
5 there when we need therapy in therapy room environments when
6 they're giving speech lessons in class when everybody else is
7 doing morning circle, they got to go to their desk and try to
8 listen to someone they have never seen before, they're in and
9 out, these employees, they're totally inexperienced. I have
10 been doing this a long time and I talk a lot. Trust. I'm
11 running out of things to say. I'm running out of reasons to
12 make it more possible to show you a day in the life of
13 Marlene because it's really difficult. A lot of people say
14 you should go out more. A lot of people like Jenny McCarthy
15 talk about things like, well, if you see someone with a kid
16 with autism, go and babysit for them. We can't allow that
17 because it's dangerous.
18 We have to be there for safety reasons and when
19 we're warn out, then we have got social workers saying you
20 didn't fill out this paper, you didn't do that right, or
21 they're just not doing what you asked them to do, and you're
22 fighting with the school. You're fighting with the people
23 that you used to encourage. I volunteered for seven to 10
24 years walking these kids from the classroom to the McDonald's
25 down the street in San Pedro off Western, and I, to this day,
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1 appreciate people that do that. I can't go in the sun. I
2 just came from radiation. I give them $1 lottery tickets,
3 and if they win, maybe I'll see them again on TV or
4 something.
5 The thing is, I think we should appreciate care
6 providers. We're going to deal with the DDT one day in
7 5,000, 10,000 years, or we're going to find something worse I
8 bet, but you know what? Right now we got to deal with this,
9 and they say what do you want, Marlene? I believe I talked
10 to someone from the EPA that called my house, and I said I
11 want to be relocated. Why is the plumage area at the door of
12 the hospital? Because they don't want that kind of a public
13 cry out because everybody gets sent over there. God forbid
14 you should drink water from there or be bathed in it.
15 It's going in our showers. It's in our skin. It's
16 not like we're sitting there -- I have seen footage today,
17 just today, on the little cell phone that my daughter has.
18 1946 was advertising and showing that some expert in
19 toxicology or whatever it was, showing these African tribe
20 men how to spray DDT over their food and eat it, and they
21 were going through towns with big trucks and they were
22 spraying it all over the community with people walking
23 around. So now, the government -- this has totally been
24 federally funded. They have -- they could have done what
25 they wanted to do, and that's what they did.
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1 What they thought was, we were far away from
2 everybody that was rich, and this was just a bunch of
3 strawberry fields. Yeah. There's 100 foot wells. I know
4 this because in my backyard where I own my home, I was
5 terrified for, like, three months because there was a crack
6 in my backyard, and I went to fill it up with water thinking
7 well, it's just a shift change or a little bit shaking earth.
8 About four hours later the water never filled up. I don't
9 know where it went. I thought we were just going to
10 disappear in the backyard one day. Well, it has filled up.
11 Out of side, out of mind. I still have things to worry
12 about. The guy across the street was building an extra house
13 on his property. He got stopped by 100 (inaudible) the fire
14 department found it. I don't think they filled it up
15 (inaudible).
16 So that brings me to my next point. This thing
17 going on in the street. I have the greatest feeling in my
18 heart because I know sinister people that they created this
19 thing to sidetrack us from going on Normandie, from even
20 going on Normandie. If you try to drive down Normandie right
21 now -- first of all, they're going to have police all over.
22 Second of all, they're going to have trucks in and out, going
23 in and out. They have cones. They have a bunch of --
24 everything blocking it off so that we avoid going that way
25 because we're residents. we know better than that. Guess
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1 what? I think that's the whole plot, and I also happen to
2 know -- because it goes right across my street in front of my
3 house on Torrance. It sounds like a bomb or a tank has gone
4 off every time these trucks go by.
5 It's rattling. I had a friend spend the night. He
6 came from Louisiana, and you know how they talk. It was
7 like, I can't believe that. I can't believe it, and I did
8 verbatim what you're doing and wrote down everything he had
9 to say, and unfortunately I didn't have a printer to print it
10 out today, but he was like how do you live like this, and
11 he's holding onto his chair and the coffee is rattling and he
12 is saying how do you do that because I have to listen for my
13 kids. I have cameras all over the house. I have got video
14 as well as audio and the amazing thing is we had an incident.
15 We had an incident where they were doing the flushing in the
16 middle of the street, and my husband was doing his business
17 in the bathroom, and I was doing laundry and I was also in
18 the kitchen, you know, doing kitchen things so the water was
19 running. We didn't get forewarning that this was just going
20 to happen. They just went down the middle of the street and
21 starting flushing.
22 Well, my husband comes running out of the bathroom
23 saying I just got a mushroom bomb came up from the toilet.
24 So he was exposed that day to raw sewage, possibly Hepatitis
25 C, definitely DDT. We know that's already in there, but all
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1 of this raw sewage came up on him. After that, we had a leak
2 in our pipes. So we went outside and we talked about it to
3 the workers. They sent it to the city. The city said they
4 didn't have permission to go there and start digging, but
5 they did it anyway. After two -- and by the way, did I
6 mention I have a terminal brain tumor? I had to use a water
7 bucket to use my water because when we turn the water on, it
8 starts squirting out of the water heater because of the
9 pressure when we turned off the main valve, it caused a
10 little leak in the little water hose there. So there I am,
11 fixed income, social security for my kids. I am working not
12 getting paid, not feeling well, carrying these buckets, and
13 you know what, it made me so mad. I feel a little better.
14 I didn't want to come today because I just got out
15 of the hospital, but I came because I think the real story
16 here is not what happened and pointing fingers. I think it's
17 about the human aspect of this, if I correctly read
18 everybody's faces. The human aspect of it is this is in our
19 DNA. The people of this community have been greatly
20 affected. I always grew up thinking, like, I know all my
21 neighbors, and we love it here. We're not going anywhere.
22 We love it here, but I think we have been contained with
23 circumstances and parole offices and jail cells and no
24 church, liquor stores on every corner. Billboards don't say
25 anything great. They said tequila. They say need a lawyer.
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1 Things like that. There's no youth functions for them.
2 There's nothing.
3 Even when they come out there and they offer this
4 little health expo, that's ridiculous. They need to get
5 people in there with MRIs. You guys got to really, really
6 dig deep into their DNA to figure out how bad it's going to
7 get for them because even if they tried, they don't have the
8 capacity because of the brain damage because of the people
9 around them that they got to deal with that died. Just last
10 year, I lost two friends to leukemia. The lady sitting back
11 there in the back row, her son almost died a couple of times
12 on her, and I know that Kenwood is the worst. It's the
13 worst.
14 By the way, we should mention that farmers
15 brothers -- I have been around the world a little bit. I
16 have traveled, and I was amazed to see that the coffee that I
17 was getting in Hawaii was from farmers brothers. They're
18 contaminated too. So we're passing it around. It's not just
19 like right here, and everybody stay there and they're letting
20 us die off. Yeah. They're letting us die off, and they're
21 putting us in a situation where we don't see a way out. I
22 was complaining about the pipe problem and guess what they
23 told me? It was my fault, and they didn't do anything wrong.
24 They let it go. That's how Mr. Alejandro right here got my
25 letter, and I guess they have a committee that has to report
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1 problems, incidents, and stuff. Do you remember that letter?
2 Wasn't it really good?
3 MR. DIAZ: Yes.
4 MS. PUENTES: He says yes. He doesn't know.
5 MR. DIAZ: No. I have read the letter.
6 MS. PUENTES: Yeah. It was kind of rude and wrong,
7 and I was amazed when I tried to talk to these people, they
8 didn't care about me giving them lemonade for, like, three
9 weeks straight. They didn't care about not being able to
10 wash their hands. I have two autistic kids. One of them is
11 walking around flapping all day long and moaning which is
12 cool. It's a community that's inflicted with problems that I
13 think have occurred because brain damage, and he does look
14 like a little gangster, quote on quote, because I cut his
15 hair. He doesn't go to a barber and I have to use the
16 clippers and he's flapping and I call it Chinese gang signs.
17 Sorry about that, but it's real fast. I'm afraid my son is
18 going to get shot out there. I think we should be protecting
19 the community more in training officers to deal with people
20 that have survived DDT poisoning.
21 If it was something else, like (inaudible) disease,
22 they dealt with it. They gave them medical help. They gave
23 them a form. Everyone knows about it that. It was one
24 weekend in a hotel, and it got all these people sick. 29
25 people have died from that poisoning right there. I don't
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1 know how long that I can keep being ignored on phone calls
2 and keep telling my story over and over and over to LA
3 Unified to state workers to just dealing with people that
4 aren't -- I feel as smart as I am, and they're in such high
5 positions and they're not accountable. They're not
6 accountable. As a matter of fact, their secretaries will be
7 rude to you, and they're just administrative assistants,
8 paper pushers. We're doing the actual job. We're raising
9 these victims of this poisoning, and we're being affected by
10 it. I have no social (inaudible).
11 It doesn't take me to go from zero to pissed off in
12 no time flat and that's because I'm fed up. I have asked
13 them time and time again to relocate. They won't fix pipes.
14 We have got bombs going off all day long with these trucks
15 going over this one spot, and I seen the crowd. People
16 waving their hands. It's loud. It is like living in a war
17 zone. So if we got to get used to that already living in
18 California, earthquake and all, we're prepared, but we don't
19 want to be like that all day long with the shaking of our
20 houses. I don't know how long it's going to take before it
21 falls down, you know. We don't have money to fix anything,
22 but I don't think it's about fixing it. I think it's about
23 realizing this is a hazardous waste area. The plumage means
24 that just like with (inaudible), there's a plumage area and
25 everything needs to go in that area. There's no one living
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1 over there.
2 There's sweeping under the rug of things like this
3 but that seems ridiculous. I'm not moving to (inaudible) and
4 I don't want to live Southern California, but I will if
5 somebody helps me get out of here because I want -- it's not
6 going to help me and my daughter and my son, but it will help
7 somebody else's daughter or maybe somebody else's that
8 doesn't know about this, and they're just going to re-label
9 the neighborhood, like they took the dirt out and put new
10 dirt in it. And they always talk about when they're digging
11 these pipes that it's 100 feet down, and I'm only going 10
12 feet and this and that. It's all over the place. It's all
13 over the place, and it's going to pass state lines which will
14 make it a federal problem. It should already be that way,
15 but it really needs to be handled. I have been to this
16 meeting before just like this and nothing happened. We're
17 being told what they're going to do, ask to give comments,
18 and our comments are ignored.
19 As far as it goes, nobody in this community is
20 really going to get up and try because they feel that there
21 was (inaudible) there was going to be a soccer field put
22 there a few years ago, but they were actually bated along to
23 believe that there was going to be a soccer field there.
24 That's ridiculous. That was never on the table, but they
25 wasted years on that project. They made them believe that it
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1 was okay. That was smoke and mirrors, and right now we need
2 to get to the situation of what are we going to do for the
3 people in the community? How are we going to get them out
4 there? How are we going to make them accountable with the
5 relocation process and put a big fence around this area and
6 make people drive around it? Get guards to guard it. Don't
7 let people in here. There's not going to be a soccer field
8 there. There is not going to be houses here in 100 years if
9 anybody does anything right. So that's how I feel about it.
10 I wish I was more prepared. Sorry I was late. I
11 don't feel well, but I want people to start looking at the
12 human aspect of this, and my shirt says DDT. Don't do that.
13 Dumping dangerous toxins. Stop that. I don't know what to
14 say except for I want to be relocated, and that's the only
15 thing I want to hear about, and I don't want to move
16 someplace where it's vaporized and then it moves over there
17 like acid rain. What comes up -- what goes up, must come
18 down. So I don't want to be any further in the hole than I
19 already am with nowhere to go. All right. Thank you.
20 Sorry.
21 MR. DIAZ: Thank you. So thanks, Marlene. We'll go
22 ahead and go with the next person. Go ahead.
23 MR. FERNANDO: My name is Philip Fernando. I live
24 on 20512 Bernando Avenue, Torrance, 90502. I will listen to
25 my neighbor, who like me, has been here for about 30 or 40
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1 years. I would like to put this on the record. The
2 community here is greatly affected by the contamination. So
3 whatever remedial action has been done so far we appreciate.
4 However, in view of the 3,000 year span that is being talked
5 about all the time, it is imperative that a plan to relocate
6 the residents of the area should get top priority. As just
7 said by my previous speaker, the previous speaker, my
8 neighbor.
9 That plan should be a part of the over all action
10 plan. I think it has to be taken seriously because of the
11 human factor. How the people are affected, how the kids are
12 affected, the number of cases that is going to rise in time
13 to come. The kids with autism and cancer and so on. So
14 that's my main concern that we incorporate the cost, a
15 realistic cost, of relocation as a part of this plan. Thank
16 you.
17 MR. DIAZ: Thank you very much. Is there anybody
18 else who would like to come up and make comments?
19 MS. C. MEDINA: My name is Cynthia Medina. Okay.
20 I'd like to make a comment for my mother, Lydia Valdez, who
21 is just not able to come up here. I'm going to read it. "So
22 I have lived in my home for about 27 years on Kenwood Avenue.
23 When I learned about all the contamination and the cleanups
24 that were going on and being removed from my home for a
25 period of time when they did the clean up on Kenwood Avenue,
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1 it makes me wonder about all the money being spent by a
2 government that doesn't have any money, and they can spend
3 millions of dollars on a cleanup when you can clean and
4 remove the most important thing, the people for much less.
5 Think about it. If you are spending -- spending, sure. I
6 can sell my house and move, but I can't do that and put
7 another family in danger by being exposed to chemicals that
8 will never be guaranteed clean and safe to live in." Thank
9 you.
10 MR. DIAZ: The next --
11 MS. PUENTES: I just have one last thing to say.
12 When I was 18, I worked for (inaudible) real estate and they
13 were a prominent company that was located in Manhattan Beach.
14 We have a lot of properties. Anyway, when we joined up
15 forces with an international company, one of the owners of
16 Honda, we had (inaudible) we built country clubs, and when we
17 went through the planning (inaudible) and we did things like
18 that, we also had relocation for wild life. That means the
19 rats, the squirrels, the birds, the mountain lions,
20 everything in the country club area as we were building it,
21 but we don't have a relocation program for human beings that
22 are being affected in this community, and that's what I just
23 wanted to say because it was my job to work with wildlife
24 people to relocate rats and squirrels and I don't like rats
25 or squirrels, but we sure did what we had to do. That's all
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1 I wanted to say. Thank you.
2 MR. DIAZ: Thank you. Is there anyone else who
3 would like to --
4 MS. MANNING: My name is Margaret Manning, and I'm a
5 resident. I will be brief. I think the big picture here is
6 that it's been 15 years since the TI waiver zone was approved
7 by the APA and that we -- it has already been stated by
8 Cynthia and Florence that it needs to be revisited. In the
9 15 years, a lot of things have happened as we are now aware
10 of chemicals, the potential for vapor intrusion, and as
11 Florence said that these chemicals can interact and this is
12 all mingling under our feet and our homes. I have got a very
13 strange smell in the middle of my house. So I have
14 volunteered to be one of the very first people for soil vapor
15 intrusion which I hope will start soon.
16 I had a plumber under the house to make sure there
17 was no leaks and no dead animals, but every morning when I
18 get up, I can smell that smell. I think one of the things
19 that we need to recognize about why this area hasn't received
20 the attention that it should, it's unincorporated. If it was
21 Torrance, it would have the city all over it. People
22 wouldn't be able to sell homes to unsuspecting buyers and get
23 away with it. They wouldn't be able to build things in this
24 neighborhood, and it certainly didn't happen in a place like
25 Malibu or Beverly Hills. This has been a working class
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1 neighborhood for all of its life, and it's an orphan. I
2 looked at the services provided by the LA County, and there's
3 a public health webpage and it's got an environmental place
4 where you can look at and it doesn't even talk about any of
5 the stuff that we have got.
6 It talks about lead and educating your kids on lead.
7 So who do we -- and we don't have any politicians here today.
8 Somebody just got elected in area 66, which I believe is the
9 assembly district here. If it's not, then it's in between 66
10 and 64. We should have somebody here, a brand-new guy or
11 else it's Gibson from the other side of 64. Why aren't they
12 here? It should be -- if this was on the Torrance side of
13 Western Avenue, you bet they would know about it, and I think
14 that this is the big picture that we should be looking at. I
15 think we are probably spinning our wheels here right now
16 dealing with individual problems, soil vapor, DNAPL, PC,
17 whatever it is, BS or something. These are all new things
18 popping out. Although the DNAPL seems like it's been a
19 (inaudible) for a while. So this is a human issue, yes, but
20 I think that in the end, that TI waiver gave a lot of the,
21 quote, responsible parties a free pass.
22 That was the war. That battle and war has been
23 fought and won. So we're all here having these discussions
24 on a regular basis, and we don't seem to be making much
25 progress at all and in the end everybody getting tired and
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1 worn out. To me, 20 million is not a lot of money. I mean,
2 I'd like to have it personally, but that is not a lot of
3 money for this cleanup with the rods heated in the ground.
4 That is a very small amount. I mean, you could buy a couple
5 of apartment buildings in Hawthorn for that kind of money
6 because I know, but we should be looking at the big picture
7 and go back and revisit the TI waiver because we have so much
8 more information in 15 years, and this is -- this isn't even
9 going to start if we did approve and go along with these rods
10 in the ground. It's still not going to start for a couple
11 more years. So that's what I have to say. Thank you.
12 MR. DIAZ: Thank you very much. Is there any other
13 person who would like to speak? Anybody else before this
14 gentleman here or anyone want to clarify a comment?
15 MS. BABICH: You know, it just really -- well, I
16 would say it breaks my heart to hear the stories from the
17 community, but my heart was broken a long time ago, and the
18 Del Amo action committee and myself -- I don't mind spending
19 the rest of my life probably maybe another 20 years sitting
20 around and trying to help figure out the best way to clean up
21 the messes that were made by the polluters. But I really do
22 mind that the community is being treated like a guinea pig
23 and it's wrong. We were able to get 65 homes relocated where
24 the park is going to be, and we're not saying that we want
25 the EPA to come in and relocate people because what will
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1 happen is they will use a way called imminent domain where
2 you won't get full value for your home and you won't be able
3 to relocate to another, like, area without the contamination,
4 but we do have the plan that we worked out with the
5 responsibility party.
6 It was a private buy out. It was not ordered by
7 court. It was because our congresswomen at the time, Jane
8 Harmon, thought that there was some common ground between the
9 community's needs and the responsible parties, and she
10 insisted that we all go in a room and try to figure this out
11 and we did and it's been the best relocation in the country.
12 And at the time when only half of 204 Street was offered a
13 relocation and that's not to say that we thought that the
14 contamination was confined to that area, but even way back
15 15, 23 years ago, we knew that that was a ground zero and
16 there was a meeting where Montrose would not come to the
17 table and negotiate and the homeowner's that were left behind
18 on 204 Street graciously stepped back so that the other
19 portion of 204 Street could be relocated and the commitment
20 that (inaudible) made at that time that we still hold to us
21 is to get the rest of our community up and out of there.
22 So I know we have responsible party representatives
23 here today, and I know that I'm not always as nice as I
24 should probably be like my grandmother taught me to be, but I
25 am indeed very angry. Unfortunately since I don't have maybe
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1 the ground (inaudible) as Montrose to poke in the eye, I
2 continue to attack their consultants and maybe that's a harsh
3 word. I don't really attack them, but I am very stern with
4 our messages. And again, I give you another message to take
5 back to the person who ensures that you have a paycheck
6 coming in and that you have hopefully a good retirement and
7 that you can provide and care for your family in the way that
8 we all try to provide in our families and come to the table
9 and do the right thing.
10 The land use for this area is not appropriate for
11 people but it's certainly appropriate for trucks. It's not
12 like we have this area that needs to be written off as
13 unusable, and certainly if, I guess, we had more time and
14 capacity, we could pull all the resources of all the
15 residents and we could probably finance our own relocation.
16 We could all probably get pretty rich when we sell it to the
17 goods movement folks to move goods from the (inaudible), but
18 that's not what we're asking. We have lives and we struggle
19 with our lives and we struggle to make a difference, and I
20 really appreciate Marlene. I have heard her speak twice at a
21 similar meeting, and thankfully at this meeting she was not
22 told this is not the place for her to make her comments like
23 she was before.
24 MS. PUENTES: That was before I was diagnosed.
25 MS. MANNING: And I'm so sorry, Marlene. So we have
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1 an opportunity to be compassionate and be part of the human
2 race and do the right thing, and so please take that message
3 back to whomever makes the decisions for the Montrose
4 chemical corporation, and we will reach out to (inaudible)
5 but you can't leave people as genie pigs as I have said
6 before on top of this. We have new people who have testified
7 today that they had no knowledge of this and they are recent
8 home owners in the committee. That's not right, and you have
9 Lydia who has lived here for 40-plus years who doesn't want
10 to sell her property because she knows the cycle that's going
11 on. So we have got a very complicated cleanup problem in
12 front of us and, you know, maybe electrical resistance
13 heating is a good idea if there aren't people living around
14 it, but we're going to have to stop and oppose things that
15 are going to further put our community in danger.
16 So there's a real opportunity, and we are handing
17 out the green leaf as we always do, but to really try and
18 figure out a way so that people can move on and the people
19 who have chosen to do as a profession, cleaning up toxic
20 waste, can get on with what they like to do. But we really
21 need to do something, and I can only tell you that we're
22 being very polite now, but it's only going to get worse as
23 the desperation sets in. People are really understanding
24 what's going on now that these pipelines have gone in. It's
25 really touching home. It's not just something that's going
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1 on over there.
2 People have waited for a park to come in, and a lot
3 of people want to know why in the world we would put a park
4 so close to a toxic waste site, but on the other hand
5 generations are growing up and having their own families with
6 no place for their children to be that safe. So we are
7 moving forward with the park area, and we hope to have a
8 meeting with the community in the next couple months to tell
9 them where we are with the plans, but really we don't need to
10 be there. So, you know, arguing is going to come down the
11 road, but it would really be nice.
12 I used to have brown hair when I started doing this
13 work. I'm very proud of my gray hair. I worked really hard
14 for it, but it's only going to get -- we're only going to get
15 more (inaudible) in our positions if we don't find a way to
16 come forward. So I would -- I'll leave you with that today,
17 and I appreciate the compassion and respect that you have
18 shown to people in the community. It's very hard to come
19 here over and over again when you feel like you're not being
20 heard. So please hear us today. Thank you.
21 MR. SATTLER: Good day. My name Alfred Sattler. I
22 am speaking just for myself at this point. I may be
23 associated with formal comments later on. Okay. Just for
24 you who don't know me, I am chair of the Sierra Club, but I
25 am not speaking -- as I said, I am speaking for myself at
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1 this point. To a certain extent, I have more questions than
2 answers. My understanding is that this DNAPL cleanup that's
3 being proposed is just to give the biggest lump -- biggest
4 amount of the Chlorobenzene contamination out so that it
5 doesn't continue contaminating the rest of the groundwater
6 that's present; is that correct? Can we have a -- is it
7 possible to do it -- I'm just supposed to talk.
8 Okay. An alternative 6A seems like it will get the
9 biggest amount of DNAPL per dollar, but 6B gets a greater
10 amount of DNAPL out. So I think that 6B should be further
11 considered to avoid having further lingering problems there.
12 As for impact on residents living in the area, I think that
13 there should be continual monitoring of the residents of the
14 air that they are breathing, and if there's shown to be
15 contamination as a result of this process, the residents
16 should be evacuated and the process should be stopped.
17 As a separate note, as I was -- you know, just
18 October 24th, science magazine had a very interesting article
19 about biologic (inaudible) and some recent research where
20 they have found more fundamental information about the
21 structures in the microbes that makes this possible and that
22 is why I ask whether bioremediation had been considered.
23 (inaudible) told me today that the DNAPL itself is too
24 concentrated for the microbes to work on it. Once the DNAPL
25 is removed, the concentrations may be low enough to
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1 bioremediate, and that should be strongly considered as a
2 follow on so that we are not hopefully faced with 3,000 years
3 of lingering contamination.
4 Somebody should be making grants to biological,
5 biochemical researchers to see if they can find some bacteria
6 that can biodegrade these chemicals and make sure the
7 biodegradation compounds are also benign or not themselves
8 toxic. (inaudible) and the comment was made that DDT is not
9 biodegradable. That may be well old information on the --
10 where it went out through the pipe, there is some evidence
11 that there is now a (inaudible) of the DDT in the (inaudible)
12 there. It's been a long time coming, but there seems to be
13 some compounds there, and again, I don't even know whether
14 those are better or worse than DDT at this point, but I do
15 know that ongoing research is going -- is happening on that
16 so I definitely want to correct that point about DDT not
17 being biodegradable.
18 This is just dealing with the big lump of really
19 concentrated stuff that's down under there. It's not -- as I
20 understand, once the biggest amount of stuff is removed from
21 down there at least, presumedly things will start getting
22 better, but my gosh. The local residents have suffered so
23 much. If there could be someway to buy them out and move
24 them, that is somebody to strongly consider.
25 MR. DIAZ: Thank you, all. Is there anyone else
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1 that would like to formally make any comments? If not, we'll
2 be closing the meeting. Going once? Going twice?
3 MS. PUENTES: My husband and I would like anybody
4 that wants to put a sign in front of their house, there's a
5 couple of signs that I thought might be illegal. We might
6 need some legal advice on it, but I would just like you guys
7 to know you can come to my house at 1072 West Torrance
8 Boulevard. You guys can pick up some canvasses. We have
9 many that are bigger than me so we could just make it loud
10 and clear. Every time I put a sign up somewhere, somebody
11 comes along and takes it because it's really pretty or
12 whatever and some are not done as well as others.
13 I will donate to anybody who wants to put a sign in
14 front of their house, any type of thing that they want on a
15 canvass or a weather proofed item. It's going to be a long
16 time, but we need to start verbalizing with words that people
17 can read and say what are these signs everywhere. I live on
18 Torrance Boulevard. I flip them around when the traffic is
19 coming in off the 110, and I flip them the other way in the
20 afternoon when they're going out so that they don't miss my
21 message. I'll try to make them more legible but yeah. DDT.
22 Don't do that. Dumping dangerous toxins. That's it.
23 MR. DIAZ: Thank you, Marlene. So yes. Would you
24 like to come, Savanna? Great.
25 MS. S. MEDINA: My name is Savanna Medina. I am 17
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1 years old. I was born in this community on 20501 on Kenwood
2 Avenue. My family, my uncle at the age of nine was diagnosed
3 with diabetes. My mom as arthritis. At the age of 19, my
4 other uncle has allergies and bone pain off and on. We need
5 you guys to do something about this. Move us out, please.
6 MR. DIAZ: Thank you, Savanna. At this time, any
7 last calls of anybody? Okay. Going once? Going twice? So
8 as a reminder, if you go to the last slide, there's -- this
9 slide, there's some contact information that's not too late
10 obviously to submit comments, and there's all these different
11 ways that you can do so. So please do, and if we have any
12 updates you'll be hearing from us in terms of this
13 proposed plan. Yes?
14 UNIDENTIFIED SPEAKER: You can send in, you know,
15 two or three times, 20 times, 100 times, you know, go to your
16 neighbors and, you know, give them the information and have
17 them send something in. It all helps.
18 MS. MARTINEZ: Thanks for everybody who came here.
19 I've been listening, and I don't want you to think that
20 because I had to go to the restroom real quick that I was not
21 listening to everybody who spoke. I am pretty available.
22 The only request that I make is if you're going to give me a
23 comment, please state it. I will be around doing hopefully
24 door-to-door soon. Let me know if this is my comment, and I
25 can take -- you can tell me. I'm write it. I'll make sure
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1 to write it as you want to say it, and that's another way you
2 can provide comments.
3 MR. DIAZ: Great. Thank you, Yarissa, for
4 clarifying that. If there's anything else that needs to be
5 clarified, we can have informal conversations after the
6 meeting, but at this time, the meeting is now adjourned, and
7 thank you again.
8 (At 12:38 p.m. the meeting was concluded.)
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1 STATE OF CALIFORNIA ) ) ss. 2 COUNTY OF LOS ANGELES )
3
4 I, BRITTANY SILVA, CSR No. 13940, do hereby certify:
5 That said public meeting was taken before me at the
6 time and place therein set forth and was taken down by me in
7 shorthand and thereafter was transcribed into typewriting
8 under my direction and supervision, and I hereby certify the
9 foregoing transcript is a full, true and correct transcript
10 of my shorthand notes so taken.
11 I further certify that I am neither counsel for nor
12 related to any party to said action, nor in any way
13 interested in the outcome thereof.
14 IN WITNESS WHEREOF, I have hereunto subscribed my
15 name this 24th day of November, 2014.
16
17
18
19
20 ______
21 BRITTANY SILVA, CSR #13940
22
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Huntington Court Reporters317 & Transcription, Inc. 64 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 230 of 381 Page ID EPA PUBLIC MEETING,#:13778 NOVEMBER 8, 2014 WORD INDEX 20430 35:4 90s 11:12 afternoon 61:20 APA 52:7 20501 62:1 94105 2:7 age 62:2, 3 apart 25:19 < $ > 20512 49:24 972-3242 2:7 agencies 27:21 apartment 54:5 $1 41:2 23 3:5 23:8, 18 Agency 2:2 4:8 APPEARANCES 55:15 < A > 9:3 2:1 < 1 > 24 36:23 a.m 4:2 agenda 5:19 applied 14:16 10 5:23 12:21 24th 59:18 64:15 ability 16:16 agent 36:23 17:14 19:15 22:13 25 17:6 19:14 able 7:15 13:7 aggressive 31:4 applies 15:18 40:23 48:11 27 50:22 15:14 23:22, 25 ago 23:8 24:8 apply 15:9 10,000 41:7 29 3:6 46:24 46:9 50:21 52:22, 25:9, 12, 20 26:25 appreciate 5:24 10:32 4:2 23 54:23 55:2 27:5 36:25 48:22 35:25 41:1, 5 100 42:3, 13 < 3 > Absolutely 24:12 54:17 55:15 50:3 56:20 58:17 48:11 49:8 62:15 3 28:7 36:9 38:2 abundant 35:9 agreed 5:4 approach 7:1, 8 101.5 12:22 3,000 25:8, 23 academic 32:9 ahead 7:9 22:21, 31:5 32:11 105 31:21 50:4 60:2 accept 29:25 25 23:1, 4 49:22, approached 23:2 1072 35:3 61:7 30 49:25 acceptable 31:6 22 appropriate 23:16 110 61:19 35 3:7 accountability aid 36:9 56:10, 11 12 35:14 24:11, 12, 19, 21, air 14:4 39:13 approve 54:9 12:38 63:8 < 4 > 22, 24 26:23 59:14 approved 52:6 13 35:15 4 3:3 accountable 24:17 ALEJANDRO 2:6 approximately 13940 64:4, 21 40 49:25 47:5, 6 49:4 4:7 7:18 17:22 8:17 9:15 13th 6:17, 21 40-plus 57:9 accurately 6:24 45:24 archive 10:11 17:23, 25 23:12 40s 8:15 achieve 32:4 Alfred 2:17 58:21 area 6:3 10:8, 10, 1460 2:4 415 2:7 Acid 9:10, 11 alive 38:12 19 11:8 12:4 15 25:9, 12 26:25 49 3:8 33:12, 14 49:17 allergies 62:4 13:1, 2, 13 15:2, 2 27:5, 13 38:8 acrylic 39:24 allow 40:16 16:4, 6, 7 17:3 52:6, 9 54:8 55:15 < 5 > act 13:5 alternative 15:13, 18:15 22:1, 6, 14 160,000 31:21 5,000 25:8, 23 action 15:14 23:7, 16, 21, 23, 25 16:2, 25:11 30:25 31:1, 17 61:25 28:8 30:1 36:10 7 26:14, 14 30:17 5, 12, 16, 24 59:8 21 32:2 41:11 18 51:12 38:2 41:7 50:3, 9 54:18 alternatives 16:9 47:23, 24, 25 49:5 19 35:15 62:3 51 3:7, 9 64:12 18:9 50:6 51:20 52:19 1946 41:18 52 3:10 actions 13:15, 18, Alzheimer's 38:22 53:8 55:3, 14 1950s 9:18 54 3:5 24 amazed 45:16 56:10, 12 58:7 1960s 10:8 58 3:11 active 8:15 11:17 46:7 59:12 1970s 9:20 13:24 14:14 amazing 36:16 areas 10:16 12:25 19800 1:15 < 6 > activities 7:22 37:25 43:14 17:14 31:25 1980s 11:11 60 37:10 38:5, 10 8:23 9:6 15:20 America 33:8 argue 25:3, 5 1982 10:12 600 2:4 22:14 Amo 11:13, 22, 23, 28:15 1985 10:13 60s 9:18 actual 17:8 47:8 24 14:7 23:6, 7, arguing 58:10 1989 8:25 61 3:12 AD 37:12 10 26:9 29:18, 20 art 38:23 1999 11:14 26:25 64 53:10, 11 add 12:25 30:17 31:12 54:18 arthritis 62:3 36:13, 19 65 54:23 addition 6:21 amount 54:4 59:4, article 59:18 19-year-old 39:20 66 53:8, 9 18:1 9, 10 60:20 asked 23:14 6A 59:8 additional 10:8 Angela 28:13 25:20 26:15 27:9 < 2 > 6B 59:9, 10 address 9:1 11:16 36:15 40:21 47:12 20 17:6 19:14, 15 13:7 14:15 Angeles 2:4 64:2 asking 56:18 20:13 54:1, 19 < 7 > addresses 16:19 angels 39:20 aspect 44:17, 18 62:15 7 3:4 8:15 30:24 angry 55:25 49:12 200 12:19 75 2:6 adjourned 63:6 animals 10:4 aspergers 37:11 2011 30:4 administrative 52:17 asphalt 10:14 2012 30:5 < 8 > 15:17 47:7 announced 6:17 assembly 53:9 2013 30:9 8 1:14 4:1 adverse 16:21 answer 26:19, 21 asset 24:4 2014 1:14 4:1 80 8:17 advertising 41:18 29:4 assistants 47:7 30:10 64:15 800 37:9 advice 61:6 answers 59:2 associated 58:23 2015 6:17, 21 80s 8:15 30:13 advisor 4:24 anybody 7:15 attached 14:3 17:18, 19, 20 23:12 30:22 31:19 32:16 18:7, 10 26:10 attaches 9:20 2016 17:21 < 9 > advisors 28:6 49:9 50:17 54:13 attack 56:2, 3 2018 17:21 9 2:3 32:12 61:3, 13 62:7 attention 52:20 204 35:6 55:12, 90017 2:4 afraid 46:17 Anyway 20:7 audio 43:14 18, 19 90502 49:24 African 41:19 44:5 51:14 aunt 35:11
Huntington Court Reporters318 & Transcription, Inc. 1 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 231 of 381 Page ID EPA PUBLIC MEETING,#:13779 NOVEMBER 8, 2014 autism 36:12, 22 believed 31:4 brain 35:17 care 38:6, 8, 15 city 44:3, 3 52:21 37:7, 10, 14 38:7, benign 60:7 36:11 44:6 45:8 41:5 46:8, 9 56:7 clarified 63:5 13, 24 40:16 50:13 Benzene 11:24 46:13 careful 34:5, 22 clarify 19:6 21:11 autistic 35:14 22:11 brand-new 53:10 carrying 9:19 22:19 54:14 46:10 Bernando 49:24 breaking 9:21 44:12 clarifying 6:2, 3 available 5:17 best 27:7 32:5 breaks 5:3 54:16 case 5:13 15:19 18:8 20:22 21:8 21:5 32:23 34:17 36:20 54:20 55:11 breathing 59:14 cases 50:12 63:4 62:21 bet 41:8 53:13 brief 52:5 Catalina 35:4 class 40:6 52:25 AVENUE 1:15 better 27:19 bright 25:16 catalyst 9:11 classroom 40:24 49:24 50:22, 25 32:10 42:25 brings 42:16 catch 38:19 clean 10:25 17:22 53:13 62:2 44:13 60:14, 22 BRITTANY 64:4, cause 31:22 34:16 19:15, 17, 18, 24 average 29:6 Beverly 52:25 21 caused 7:22 20:4, 8, 13, 25 avoid 42:24 59:11 big 9:16 24:13 broken 54:17 31:17 33:25 21:20 22:24 25:7, aware 52:9 31:12, 18 32:22 brothers 45:15, 17 34:14, 14 44:9 13 26:16 29:23, 34:9 36:9 37:2 brown 58:12 cell 5:18 41:17 23, 23 30:8 34:4 < B > 41:21 49:5 52:5 brutalized 35:19 cells 44:23 50:25 51:3, 8 Babich 2:11 3:5 53:14 54:6 60:18 BS 53:17 central 10:9 54:20 23:3, 5, 6 54:15 bigger 36:9 37:6 bucket 44:7 certain 59:1 cleaned 20:14 baby 36:20, 20 61:9 buckets 44:12 certainly 52:24 27:6 32:3 babysit 40:16 biggest 36:2 59:3, Budlong 35:5 56:11, 13 cleaning 10:23 back 5:17 21:4 3, 9 60:20 build 52:23 certify 64:4, 8, 11 25:11 31:12 57:19 23:18 28:1 36:16 Billboards 44:24 building 42:12 chain 10:4 cleanup 51:3 39:15 45:10, 11 billion 31:22 51:20 chair 30:17 43:11 54:3 57:11 59:2 54:7 55:14, 18 bioaccumulates buildings 54:5 58:24 cleanups 50:23 56:5 57:3 10:3 built 10:17 37:22 chance 5:12 clear 6:4 18:8 background 8:13 biochemical 60:5 51:16 change 42:7 20:25 27:16 backpack 37:5 biodegradable bunch 42:2, 23 changes 26:16 31:25 61:10 backyard 29:3 18:19 60:9, 17 burned 29:2 characteristics 8:9 clearly 24:20 42:4, 6, 10 biodegradation bus 37:6 10:2 30:23 bacteria 18:16 60:7 business 40:3 charts 33:2 clippers 46:16 60:5 biodegrade 60:6 43:16 chasing 39:4 close 23:23 58:4 bad 39:19, 25 biodegraded 18:18 busses 35:20 chemical 22:17 closer 23:13 45:6 biologic 59:19 buy 54:4 55:6 33:1, 25 35:7, 10 closing 61:2 band 36:9 biological 60:4 60:23 57:4 club 51:20 58:24 bank 39:23 bioremediate 60:1 buyers 52:22 chemicals 8:12 clubs 51:16 banker 39:24 bioremediation 9:7 14:19, 20 coffee 5:16 43:11 banned 9:19 13:10 18:12, 13 < C > 32:2 34:13, 20 45:16 barber 46:15 59:22 CALIFORNIA 51:7 52:10, 11 collect 14:17, 25 basic 7:21 birds 51:19 1:16 2:4, 7 4:1, 60:6 15:10 basically 13:25 bit 7:10 10:20 16 11:7 47:18 chemistry 9:5 collected 14:21 15:8 17:7 11:11 13:17 17:8 48:4 64:1 child 35:10 38:10 Colorado 29:1 basin 34:5 18:10 22:4 24:15 call 16:6 24:9 children 25:25 35:7, 8 basis 38:8 53:24 33:1 42:7 45:15 29:19, 19, 20 26:1 35:12, 14 combined 34:19 bated 48:22 blob 12:1 38:16 39:8 46:16 36:24 38:21, 23 come 6:6, 25 bathed 41:14 block 24:13 called 14:23 15:5 58:6 20:18 23:17 bathroom 43:17, blocking 42:24 25:21 33:7, 9 children's 26:1, 1 26:19 27:13 28:2, 22 blow 28:23 37:12 41:10 55:1 Chinese 46:16 16 32:10, 13 battle 53:22 blue 12:1, 2, 4, 25 calling 22:22 Chloral 9:9 44:14 45:3 49:17 Beach 51:13 Blvd 2:4 39:10 Chlorobenzene 50:13, 18, 21 bear 8:2 board 30:9 32:8 calls 47:1 62:7 9:10, 13, 16, 23, 23 54:25 55:16 56:8 beautiful 36:21 body 10:4, 6 cameras 43:13 10:7 12:1 18:15, 58:2, 10, 16, 18 37:23 bomb 43:3, 23 cancer 50:13 16, 18 22:2, 3, 10 61:7, 24 beginning 37:7, 19 bombs 47:14 canvass 61:15 33:3 34:15 59:4 comes 12:2 31:14 behavioral 39:6 bone 62:4 canvasses 61:8 choose 17:11 43:22 49:17 61:11 beings 51:21 borings 12:20 capacity 45:8 chosen 17:3 57:19 coming 4:5 6:18 belief 31:11 born 35:10, 11 56:14 church 44:24 23:6 56:6 60:12 believe 29:5, 5, 24 36:12 37:9, 16, 17 capture 24:1 circle 40:7 61:19 31:17 32:20 41:9 38:5 39:1, 10 62:1 carbon 19:10 circumstances co-mingled 29:21 43:7, 7 48:23, 25 Boulevard 61:8, 18 28:21, 25 44:23 34:20 53:8 boundary 12:6 carcinogen 10:6, 7 citizens 38:22 COMMENT 1:13 Bradley 36:15 cards 6:11 23:25 6:14, 16, 20 17:17
Huntington Court Reporters319 & Transcription, Inc. 2 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 232 of 381 Page ID EPA PUBLIC MEETING,#:13780 NOVEMBER 8, 2014 20:18, 20 23:11, composed 9:15 continue 13:5 Cynthia 2:11, 15 30:17 31:12 54:18 14, 15, 25 24:8 13:18 27:9 38:21 56:2 20:17 23:3, 6 delivers 15:5 30:20, 20 50:20 compounds 60:7, 59:5 29:14 30:12, 16 Denver 35:8 54:14 60:8 62:23, 13 continuous 12:14 50:19 52:8 department 27:21 24 concentrated control 14:12 30:6 32:6, 15 commented 30:5 31:25 59:24 60:19 27:21 30:6 32:7, < D > 35:19 42:14 comments 6:5, 6, concentrations 8, 16 damage 36:11 depending 8:9 10, 24 7:4, 9 10:5 18:14 59:25 controls 13:21 45:8 46:13 depth 13:12 14:2 17:24 18:2, 4 concepts 12:11 15:16, 17, 17, 22 danger 20:9 51:7 31:21 22:22 24:1, 4, 5 concern 30:15 16:12 57:15 description 7:23 25:2 29:15 30:10, 50:14 convening 32:6 dangerous 39:2 design 17:20, 20 21 31:19 32:16, concerned 33:17 conversation 34:11 40:17 49:13 61:22 desk 24:14 40:7 17, 18 48:17, 18 34:6 conversations dark 12:4 desperation 57:23 50:18 56:22 concerns 29:7 27:20 63:5 data 18:18 34:13, detected 12:21 58:23 61:1 62:10 concluded 63:8 converts 15:7 14, 15, 17 determined 11:12 63:2 concludes 18:5, 6 cool 46:12 daughter 35:3 determines 16:11 commercial 10:9, conclusion 27:14 Coordinator 2:6 36:24 41:17 48:6, diabetes 62:3 16 cones 42:23 4:9 7 diagnosed 36:21 commingled 22:1 confined 55:14 corner 5:10 44:24 day 17:23 33:15 56:24 62:2 commitment 55:19 congresswomen corporation 36:23 35:20, 23, 25 diagnosis 36:19 committee 23:7, 7, 55:7 57:4 37:23 38:9 40:12, diagram 17:12 16, 19 30:17 conservative 34:22 correct 59:6 25 41:6 42:10 DIAZ 2:6 3:3 45:25 54:18 57:8 consider 20:19 60:16 64:9 43:24 46:11 4:4, 7, 17, 21 5:16 common 26:10 60:24 correctly 7:2, 14 47:14, 19 58:21 17:23 18:21, 24 55:8 considered 8:8 44:17 64:15 19:1, 6 20:17, 22 Community 2:4, 6, 12:16 13:21, 22, cost 17:3, 5, 6, 8, days 35:23 21:7, 16 22:5, 17, 10 4:8 5:5 6:18 23 14:8 16:8, 16 11 19:13, 14 DDT 8:12, 14, 16, 19 29:14 34:25 23:8, 9, 23 24:19, 59:11, 22 60:1 20:24, 25, 25 18, 22 9:5, 12, 15, 46:3, 5 49:21 25 25:10, 14 considering 28:7 50:14, 15 17, 20, 22 10:3, 13 50:17 51:10 52:2 26:23 27:12 construction costs 29:7 18:19 33:2 38:25 54:12 60:25 28:14 29:6 32:14 17:21 19:16 counsel 64:11 39:1, 15 41:6, 20 61:23 62:6 63:3 35:18 41:22 21:12, 15 counted 38:7 43:25 46:20 die 45:20, 20 44:19 46:12, 19 consultants 56:2 country 51:16, 20 49:12 60:8, 11, 14, died 45:9, 11 48:19 49:3 50:2 contact 62:9 55:11 16 61:21 46:25 51:22 54:17, 22 contained 44:22 County 33:12 dead 25:25 26:1, difference 31:18 55:21 57:15 58:8, containment 53:2 64:2 2 52:17 56:19 18 62:1 25:17, 22 26:2 couple 4:23 10:18 deal 41:6, 8 45:9 differences 7:25 community's 55:9 28:8 21:15 22:12 46:19 different 5:20 companies 33:22 contaminants 8:10 38:20 45:11 54:4, dealing 47:3 6:22 12:2, 5 company 51:13, 15 9:17 10:1 11:16 10 58:8 61:5 53:16 60:18 13:18, 23 15:24 compare 15:14 13:11, 12, 13 court 6:22 7:1, 8 deals 10:6 16:25 24:20 20:7 14:11, 17, 25 15:3, 55:7 dealt 46:22 26:18 27:20 62:10 compared 19:18 10 16:19 covenant 15:19 decades 25:7 differently 24:15 20:8 contaminated cover 10:14 19:20 28:16 difficult 40:13 comparing 17:2 8:25 11:9 14:2 covering 21:10 December 30:5 dig 45:6 comparison 16:9, 15:2 28:25 33:11 CPSA 34:16 decided 7:24 25:9, digging 44:4 23 17:7 20:24 36:8 45:18 crack 42:5 12 48:10 21:1 contaminating created 38:25 decision 9:4 direction 64:8 compassion 58:17 59:5 42:18 11:14, 17 17:19 director 23:6 compassionate contamination creates 14:4 18:3, 4 27:1 31:3 dirt 48:9, 10 57:1 4:11, 20 8:22 creating 18:16 decisions 24:18 disappear 42:10 competitive 20:24 11:13 13:4, 6 criteria 18:2, 2 29:10 57:3 discarded 13:14 complained 7:14 20:3 22:7 23:9 crowd 47:15 deep 45:6 discharged 22:15 complaining 45:22 24:24 25:11, 14 cry 41:13 defined 12:7, 19 discontinued 10:13 completed 10:18 26:3, 5, 5 27:16 CSR 64:4, 21 definitely 43:25 discussing 26:7 21:15 28:1, 12, 18 50:2, curiously 25:22 60:16 discussion 19:17 compliance 16:13 23 55:3, 14 59:4, current 15:5, 7 degree 26:10 22:9 complicated 57:11 15 60:3 Currently 10:17 Del 11:13, 22, 23, discussions 26:25 complies 16:25 continual 59:13 cut 46:14 24 14:7 23:6, 7, 29:25 53:23 comply 16:14 cutest 36:20 10 26:9 29:18, 20 disease 46:21 components 7:23 cycle 57:10 diseases 9:19
Huntington Court Reporters320 & Transcription, Inc. 3 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 233 of 381 Page ID EPA PUBLIC MEETING,#:13781 NOVEMBER 8, 2014 displacement due 11:12 13:11 24:9 25:20 29:8, face 24:12 fingers 44:16 13:19 14:9, 9 dummied 39:21 11 30:9, 23 31:1, faced 60:2 fire 27:15 42:13 15:24 dumped 8:20 18 33:19 41:10 faces 44:18 first 5:22 6:25 disposal 28:7 Dumping 39:2 54:25 fact 24:13 25:25 23:2 24:8 25:1 29:10 49:13 61:22 EPA's 17:3 27:7 28:25 47:6 29:17 30:20 dissolve 8:6 duration 17:4 equipment 10:12 factor 50:11 31:16 35:10 36:2, dissolves 9:25 dwarf 35:11 14:3 facts 7:21 13 37:1, 19 38:25 District 4:19 dying 38:10 ERA 17:4 falls 47:21 42:21 52:14 27:22 30:7 32:8, ERH 16:6 17:3, families 56:8 58:5 fit 26:11 17 53:9 < E > 15 family 35:8, 11, 13 five 16:2 27:4 divided 9:1 earlier 26:15 35:3 especially 27:12 37:22 51:7 56:7 five-year 27:8 DNA 44:19 45:6 early 7:18 13:9 essence 28:5 62:2 fix 47:13, 21 DNAPL 1:12 30:13 estate 36:23 51:12 far 28:9 29:11 fixed 44:11 4:10 5:7, 7 6:4 earth 42:7 estimated 17:16 31:15 42:1 48:19 fixing 47:22 7:11, 13, 19, 21, 22, earthquake 47:18 19:13 50:3 flames 19:10 24, 25 8:1, 2, 4, 5, easily 8:6 9:22, 24 estimating 28:10 farmers 45:14, 17 flapping 39:12 5, 10 9:14, 23 easy 10:21 evacuated 59:16 fascinating 27:24 46:11, 16 10:1, 10, 21, 25 eat 41:20 evaluated 8:1 fast 46:17 flat 47:12 11:3 12:5, 6, 8, 10, eating 37:19 evaluating 19:9 fault 39:8 45:23 flip 61:18, 19 12, 14, 15, 17, 19, educating 53:6 evaporate 9:24 favorite 28:14 float 8:7 25 13:2, 3, 4, 5, 7 education 23:16 evaporates 15:3 fax 7:6 floor 18:7 14:12, 15 16:4, 4, effect 16:22 34:19 everybody 4:4, 5, feasibility 26:13 Florence 2:12 6, 7 17:14 18:15 effective 17:11 18 6:19 7:12 February 6:16, 20 29:15, 16 34:25 19:14 20:6 21:9, effectively 9:18 26:23 40:6 41:13 17:18, 23, 25 23:12 52:8, 11 25 22:2, 3, 10, 11 effectiveness 42:2 45:19 53:25 fed 47:12 flow 14:12 28:10, 15 30:24, 16:15, 20 17:1 62:18, 21 federal 16:14 flushing 43:15, 21 25 31:5, 8, 10, 14, effects 34:12 everybody's 44:18 48:14 focus 30:25 16, 20, 25 33:16 effort 32:15 evidence 60:10 federally 41:24 focused 17:3 34:9 53:16, 18 eight 13:18 example 10:22 feel 6:2 44:13 folks 6:8 56:17 59:2, 9, 10, 23, 24 elected 53:8 20:2 47:4 48:20 49:9, follow 60:2 document 9:4 electrical 13:20 excavation 31:20 11 58:19 Followed 7:23 documents 9:4 15:3, 5 16:5 excavations 13:11 feeling 38:19 following 10:2 28:9 33:19 17:13 57:12 expensive 31:4 42:17 44:12 11:4 17:9, 10 21:3 doing 5:24 15:16 electricity 15:9 expert 41:18 feels 7:15 38:4 follow-up 18:21 29:12, 13 34:22 electrodes 15:6 expertise 20:7 feet 12:22, 23 food 10:4 41:20 36:1, 8 37:20, 21 17:12 27:14 Explain 18:11 31:21 48:11, 12 foot 31:21 42:3 40:7, 10, 21 43:8, eliminates 16:12 explained 18:9 52:12 footage 41:16 15, 16, 17, 18 47:8 else's 24:7 29:4 explaining 5:8 fellow 33:12 football 13:1 58:12 62:23 48:7, 7 expo 45:4 fence 49:5 forbid 41:13 dollar 59:9 e-mail 7:5 exposed 19:24 Fernando 2:14 forces 51:15 dollars 20:13 emerging 27:4 20:1 43:24 51:7 3:8 49:23, 23 foregoing 64:9 31:22 51:3 emotional 20:16 exposure 11:16 field 13:1 48:21, foremost 25:1 domain 55:1 employee 35:7 13:3 15:19 23 49:7 forewarning 43:19 donate 61:13 employees 40:9 express 7:16 fields 42:3 form 37:13 46:23 door 23:16, 16 empowered 29:18 23:10 fighting 40:22, 22 formal 6:5, 10 40:2, 3, 4, 4 41:11 empty 10:25 extended 6:16, 20 figure 12:12 28:2 22:21 29:8 58:23 door-to-door 62:24 enabling 33:17 17:17 45:6 54:20 55:10 formally 61:1 double 7:17 encourage 40:23 extension 23:11, 15 57:18 formed 23:7 downhill 37:2 engineer 4:19 extent 12:24, 24 figures 35:17 former 7:21 8:10 draft 30:3 ensure 30:8 18:19 33:24 59:1 file 32:20 10:15 draw 37:8 ensures 56:5 extra 42:12 fill 40:20 42:6 forms 9:23 12:10 drawing 12:13 entire 16:4, 7 extracted 19:1 filled 42:8, 10, 14 forth 64:6 drill 14:1 environment 9:21 extraction 13:10, filling 36:10 forthright 31:2 drilled 15:1 16:11, 17, 22 24 14:2, 7, 10, 11, filtered 19:5, 24 forward 31:12 drink 41:14 Environmental 13 15:23 19:4, 14 final 9:3 58:7, 16 drinking 11:6, 8 2:2 4:7 37:18 extraordinary 37:3 finally 5:6 7:3 fought 53:23 30:8 33:10, 18, 20, 53:3 eye 56:1 18:3 found 10:10 22, 23 environments 40:5 Eyewitness 36:16 finance 56:15 30:21 42:14 59:20 drive 42:20 49:6 EPA 1:9 2:3 9:3 find 32:21 41:7 four 13:18 15:23, dual 11:13, 15 11:12 15:13 16:7, < F > 58:15 60:5 25 18:17 42:8 25 18:1, 3 23:25
Huntington Court Reporters321 & Transcription, Inc. 4 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 234 of 381 Page ID EPA PUBLIC MEETING,#:13782 NOVEMBER 8, 2014 fraction 31:7, 8 45:24 46:15 greater 21:19 happening 36:10 holds 12:14 frames 30:3 47:11, 25 49:19, 59:9 60:15 hole 10:23 49:18 Francisco 2:7 21, 22, 22 54:7, 9 greatest 42:17 happens 11:3, 4 holes 12:20 17:15 24:17 55:10 62:8, 15, 20 greatly 44:19 50:2 12:8 17:22 18:1 holistically 29:22 free 6:2 38:23 goal 32:4 green 11:25 12:6 34:17 32:10 53:21 God 41:13 57:17 hard 27:13 39:17 home 37:23 42:4 fridge 10:22 goes 28:10 43:2 grew 44:20 58:13, 18 50:22, 24 55:2 friend 43:5 48:19 49:17 grinding 10:12 harder 39:14 57:8, 25 friends 45:10 going 5:13 6:11, gross 25:13 harm 34:14, 14 homeowner's front 35:21 43:2 25 7:10, 18 11:20 ground 12:21, 22, Harmon 55:8 55:17 57:12 61:4, 14 13:21 19:13, 16, 23 14:5, 16, 21 harms 25:4 homes 25:16 28:3 FS 18:17 25 20:1, 4, 15, 15 15:9 17:13 27:15 harsh 56:2 52:12, 22 54:23 full 27:24 55:2 21:23 24:13 25:6, 54:3, 10 55:8, 15 Hawaii 45:17 homosexuality 64:9 8, 23, 25 26:1, 2, 56:1 Hawthorn 54:5 37:15 functions 45:1 11, 14, 16, 17, 18, Groundwater Hawthorne 2:6 Honda 51:16 fundamental 59:20 19 27:17, 18 4:20 7:24 8:21 hazardous 47:23 honest 26:21 funded 41:24 28:12, 19, 22 29:1, 9:25 10:21 11:2, health 16:11, 13, honored 30:16 further 13:17 2 30:1, 14, 22 11, 12, 13, 15, 18, 17, 22 34:12, 16, hope 34:7 52:15 49:18 57:15 31:11 33:13 19, 24 13:6, 13 19 45:4 53:3 58:7 59:10, 11 64:11 35:18, 21 36:4, 5 14:11, 19, 20 15:8 healthy 35:8, 9, 9 hopefully 17:18, 37:4 38:3, 4, 6, 12, 21:10, 11, 20, 23 38:12 21 56:6 60:2 < G > 18, 18 39:9, 11, 11, 22:1, 6, 15 28:19 heaped 25:14 62:23 gallon 10:22, 24 14 41:6, 7, 15, 21 30:13 32:3 34:3, hear 5:23 7:12 hoping 5:11 23:24 11:1 20:2, 5 42:9, 17, 19, 20, 21, 4 59:5 37:18 49:15 hormones 10:6 gang 46:16 22, 22, 24 43:19 group 8:6 21:21 54:16 58:20 hose 44:10 gangster 46:14 44:21 45:6 46:18 30:15 32:6, 13 heard 36:13 37:1 hospital 38:10 gate 28:1 47:14, 15, 20 48:6, growing 58:5 56:20 58:20 41:12 44:15 generated 15:6 8, 11, 13, 17, 20, 21, growth 10:9 hearing 4:10 hotel 23:23 46:24 generations 58:5 23 49:2, 3, 4, 7, 8 guarantee 20:15 21:18 62:12 hottest 35:23 genie 26:4 57:5 50:12, 21, 24 54:9, guaranteed 20:14 heart 42:18 54:16, hours 32:21, 21 gentleman 54:14 10, 24 57:10, 14, 51:8 17 40:3 42:8 geologist 4:16 15, 22, 24, 25 guard 49:6 heat 14:16, 19 house 35:22 getting 20:16 58:10, 14, 14 guards 49:6 15:6, 9 38:16 39:12 27:6 35:19 36:5, 60:15 61:2, 2, 15, guess 21:17 30:14 heated 54:3 41:10 42:12 43:3, 5, 6 39:14, 15 20 62:7, 7, 22 42:25 45:22, 25 heater 44:8 13 51:6 52:13, 16 44:12 45:17 good 4:6, 18 7:17 56:13 heating 13:20 61:4, 7, 14 53:25 60:21 23:5 37:8 39:19 guinea 54:22 15:4 16:6 17:13 houses 47:20 49:8 Gharibian 2:12 46:2 56:6 57:13 guy 39:21 42:12 57:13 human 10:6 13:3 3:6 29:16, 16 58:21 53:10 heats 15:2 16:10, 13, 17, 22 Gibson 53:11 goodness 28:16 guys 4:4 5:2, 18 heavier 8:7 34:12 44:17, 18 girl 36:17 goods 56:17, 17 6:24, 25 22:22, 23 heck 36:4 49:12 50:11 give 4:12 5:18 gosh 60:22 39:7, 13 45:5 Hello 7:12 18:13 51:21 53:19 57:1 8:4 9:5 10:21 gotten 34:8 61:6, 8 62:5 help 14:12, 24, 25 husband 37:24 22:17 24:4 26:18 government 20:10 22:19 39:3, 3, 16 43:16, 22 61:3 38:23 41:2 48:17 41:23 51:2 < H > 46:22 48:6, 6 Hydraulic 13:9, 56:4 59:3 62:16, graciously 55:18 hair 46:15 58:12, 54:20 19 14:9, 9 15:23 22 grade 8:18 10:12 13 helpful 21:21 given 8:5 37:1 half 9:15, 15 13:1 helps 28:14 30:7 < I > giving 28:16 40:6 grandfather 35:6, 55:12 48:5 62:17 idea 25:16 57:13 46:8 6 hand 21:6 58:4 Hepatitis 43:24 identified 30:20 glad 34:24 grandmother handing 57:16 hereunto 64:14 identify 4:13, 14 glass 38:17, 17 55:24 handle 19:1 hi 4:25 ignored 47:1 glassy 38:17 grants 60:4 handled 48:15 high 18:14 47:4 48:18 Gloria 35:11 graph 16:23 hands 6:14 39:12 highly 10:4 illegal 61:5 go 7:9 15:11 grave 33:14 46:10 47:16 Hills 52:25 image 38:10 16:7 20:16 21:4 gray 58:13 happen 15:15 history 22:14 immediate 35:13 22:21, 25 23:1, 1, Great 4:17, 21 26:17 28:22 43:1, hold 55:20 imminent 55:1 3, 22 28:19 29:1 5:1 22:20 26:20 20 52:24 55:1 holders 27:11 impact 26:14 30:14 34:4 37:13 27:24 32:13, 13 happened 8:11 holding 26:24 59:12 38:17 40:7, 14, 16 33:7 44:25 61:24 21:25 27:7 31:13 43:11 impacted 24:25 41:1 43:4 44:4 63:3 44:16 48:16 52:9
Huntington Court Reporters322 & Transcription, Inc. 5 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 235 of 381 Page ID EPA PUBLIC MEETING,#:13783 NOVEMBER 8, 2014 27:25 31:20 input 23:21 19:6, 12, 19 20:11 leukemia 45:10 looked 10:2 13:8, impacting 23:9 insect 9:19 21:2, 3, 18 22:11 levels 26:3 9, 17 21:5 25:22 imperative 50:5 inside 11:4 12:6, 27:5, 5, 16 30:16 life 37:12 40:12 53:2 implementation 8 23:16 31:1 31:13 33:6, 16, 18, 51:18 53:1 54:19 looking 11:18 16:21 17:4, 9, 15 insisted 55:10 21 35:17, 18 lifetime 29:24 13:6 17:1 26:22 important 4:22 installed 10:14 36:14, 15, 20, 21 30:2 49:11 53:14 54:6 5:11 9:6 24:2, 6, 15:6 37:7 39:4, 13, 23 limit 13:3 22:9 looks 8:5 21:7 19 25:2 30:19 institutional 13:20 41:8 42:3, 9, 18, limited 34:15 29:14 39:13 32:24 34:10, 23 15:16, 17, 22 25 43:2, 6, 18, 25 lines 48:13 Los 2:4 64:2 38:3 40:4 51:4 instrumental 36:15 44:13, 20 45:12 lingering 59:11 lost 45:10 impossibilities interact 52:11 46:4 47:1, 20, 21 60:3 lot 5:7, 19, 21 6:8, 29:25 interested 64:13 48:8 49:13 53:13 lions 51:19 12 7:13 10:25 impracticability interesting 59:18 54:6, 15 55:22, 23 liquid 8:8 19:21 24:3 31:23 25:10, 21 27:10 international 51:15 57:12 58:3, 10, 24 liquor 44:24 34:21 35:15 28:3 interpretation 5:14 59:17 60:13, 15 list 6:19 8:24, 24 40:10, 13, 14 impracticable introduce 4:22 61:7 62:14, 15, 16, listed 15:11 51:14 52:9 53:20 25:13 intrusion 52:10, 15 24 listen 40:8 43:12 54:1, 2 58:2 Inaudible 18:25 investigation 38:11 knowledge 57:7 49:24 lottery 41:2 19:15 20:10 investigations known 22:6 34:21 listening 34:24 loud 47:16 61:9 22:12, 18 38:21, 12:20 knows 37:25 62:19, 21 Louis 33:9 23 39:7 42:13, 15 Involvement 2:4, 46:23 57:10 little 7:10 8:13 Louisiana 43:6 46:21 47:10, 24 6 4:8 9:16, 25 10:19 love 44:21, 22 48:3, 21 51:12, 16, issue 21:6 30:12 < L > 11:11 13:17 17:8 loves 28:14 17 53:19 55:20 33:25 53:19 LA 39:21 47:2 18:9 22:4 24:15 low 10:5 59:25 56:1, 17 57:4 issues 19:11 23:9 53:2 33:1, 9 35:24 lump 59:3 60:18 58:15 59:19, 23 32:9 LADWP 11:7 36:17, 20, 20, 25 LY 4:18, 18 60:8, 11, 11 item 61:15 lady 45:10 38:23 39:20, 21 Lydia 50:20 57:9 incident 43:14, 15 its 8:9 28:16 53:1 land 15:19 56:10 41:17 42:7 44:10, incidents 46:1 large 31:7 10, 13 45:4, 15 < M > include 16:5 < J > largest 8:14 46:14 mad 44:13 included 8:19, 24 jail 36:11 44:23 late 17:19 35:2 live 20:4 35:3 magazine 59:18 12:9 13:9 15:25 Jane 55:7 49:10 62:9 43:10 48:4 49:23 magically 26:13, 16:3 Jenny 40:14 lateral 12:24 51:8 61:17 19 27:18 includes 12:7 32:6 job 32:22 47:8 laundry 43:17 lived 35:4, 5, 5, 6 mail 7:5 17:24 including 25:16 51:23 law 5:21 25:18 50:22 57:9 main 11:17 44:9 income 44:11 Johnson 28:13 laws 37:16 liver 10:7 50:14 incorporate 50:14 joined 51:14 lawyer 44:25 lives 38:20 56:18, maintain 16:16 independent 4:23 joining 4:6 lead 9:3 24:7 19 making 18:3 indicated 18:18 joke 39:25 53:6, 6 living 47:16, 17, 53:24 60:4 individual 38:8 leaf 57:17 25 57:13 59:12 malaria 9:18 53:16 < K > leak 44:1, 10 LNAPL 12:10 Malibu 52:25 individually 15:12 keep 6:13 28:15 leaks 52:17 local 4:12 16:14 manage 4:20 34:13 47:1, 2 learn 39:1 36:16 60:22 management 8:12 individuals 37:14 Kenwood 35:5 learned 37:6 located 51:13 Manager 2:3 industrial 10:8, 16 45:12 50:22, 25 50:23 location 13:12 Manhattan 51:13 15:21 22:16 62:1 leave 26:4 28:12 lock 40:2 manner 38:5 inexperienced 40:9 key 23:21 31:6 57:5 58:16 locking 40:3 Manning 2:16 infeasible 31:22 kid 37:11 40:15 left 4:9 28:1 long 6:9 23:1, 20 3:10 52:4, 4 56:25 inflicted 46:12 kids 37:9, 17 38:2, 55:17 35:20 40:10 manufactured 8:18 informal 63:5 5, 8, 9, 24 39:9, 10, legal 15:17 61:6 46:11 47:1, 14, 19, manufacturer 8:14 information 27:24 17 40:24 43:13 legible 61:21 20 54:17 60:12 manufacturing 32:21 34:21 54:8 44:11 46:10 lemonade 35:23, 61:15 8:23 59:20 60:9 62:9, 50:11, 13 53:6 24 46:8 long-term 16:15 map 12:4 31:25 16 kind 5:3, 9 6:9, lense 29:7 17:1 maps 11:4 injected 14:24 13 24:23 36:17, lessons 38:24 40:6 look 6:8 15:13 Marcus 4:25 5:1 injection 13:19 17 41:12 46:6 letter 32:20 45:25 16:10, 13, 15, 17, Margaret 2:16 14:10, 11, 24 16:3, 54:5 46:1, 5 20 24:11 28:17, 52:4 3 kitchen 43:18, 18 letters 24:13 18 29:6, 9 32:9 Marlene 2:13 injections 13:10 knew 55:15 letting 6:19 45:19, 34:9 37:4, 17 34:25 40:13 41:9 injects 15:1 know 5:9 6:3, 15, 20 38:4 46:13 53:4 49:21 56:20, 25 19 7:13, 16 10:6 61:23
Huntington Court Reporters323 & Transcription, Inc. 6 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 236 of 381 Page ID EPA PUBLIC MEETING,#:13784 NOVEMBER 8, 2014 MARTINEZ 2:3 microphone 6:7 morning 4:6, 18 night 43:5 ought 32:3 3:4 4:9 7:12 mid 10:8 7:17 23:5 40:7 nine 18:2 62:2 outcome 64:13 18:13 19:3, 9, 22 middle 11:25 52:17 nonverbal 35:14 outreach 23:24 21:2, 14, 22 22:8 43:16, 20 52:13 mother 50:20 normal 5:20 outside 21:18 62:18 migration 13:3 mountain 51:19 Normandie 11:19 30:25 44:2 Mary 36:15 mike 7:14, 16 move 14:10, 20 42:19, 20, 20 owners 51:15 mass 12:14 24:10 49:15 51:6 56:17 note 59:17 57:8 material 33:11, 17 mile 11:9 57:18 60:23 62:5 notes 64:10 materials 9:8 milk 10:22, 23, 24, movement 15:7 NOVEMBER < P > 32:23 34:18 24 11:1 20:2, 5 56:17 1:14 4:1 30:10 p.m 63:8 matter 19:24 47:6 million 8:15, 17 moves 49:16 64:15 PAGE 3:2 matters 39:17 17:6 19:14, 15, 15 moving 25:4 number 15:21 paid 44:12 max 20:12 20:13 54:1 27:15, 17 48:3 50:12 pain 62:4 maximum 12:22 millions 51:3 58:7 numbers 31:23 paper 40:20 47:8 McCarthy 40:14 mind 42:11 54:18, MRIs 45:5 numerous 35:12 parallel 36:6 McDonald's 40:24 22 mushroom 43:23 nuts 37:19 Park 39:25 54:24 mean 18:5 20:9 minds 32:5, 13 58:2, 3, 7 54:1, 4 mingling 52:12 < N > < O > parole 44:23 meaning 9:24 minimize 15:18 name 4:6 7:2 objectives 13:2 part 13:23 16:9 10:3 25:11 minimum 12:21 22:17 24:10 obviously 62:10 19:4 32:12, 24 means 8:17 14:18 minutes 5:23 6:1, 29:16 49:23 occur 25:8 50:9, 15 57:1 16:18 47:23 51:18 8 50:19 52:4 58:21 occurred 46:13 particles 12:16 measure 26:16 mirrors 49:1 61:25 64:15 occurs 12:10 particular 5:22 media 9:1 mistake 37:21 names 6:19 ocean 8:21 24:6 26:6 mediate 21:5 mixed 9:10, 23 NAPL 12:10 October 12:18 particulates 9:21 medical 46:22 11:12 nation 38:6 59:18 parties 12:3, 3 Medina 2:15, 18 moaning 39:13 National 8:24 offer 45:3 22:14 53:21 55:9 3:9, 12 18:25 46:11 native 29:1 offered 55:12 partnered 32:15 19:12, 23 20:21 mobile 7:25 12:5, need 5:22 6:10 Office 2:4 parts 12:5 25:2 28:11 50:19, 7, 13, 13, 19 13:4 11:20 23:1 25:1 officers 46:19 party 55:5, 22 19 61:25, 25 16:4, 6 17:14 26:25 28:17 32:4, offices 44:23 64:12 MEETING 1:9 33:18 14 34:5 38:19 official 5:20 pass 48:13 53:21 5:21 6:22 7:7 mobility 16:18 39:3 40:5 44:25 officials 4:12 passing 45:18 17:17 18:5, 6 17:2 45:4 49:1 52:19 Okay 7:17 21:16, passive 28:24 21:9 23:13, 24 mobilizes 15:3 57:21 58:9 61:6, 22, 23 22:8, 20 pastries 5:16 24:8 36:13 48:16 molasses 8:5 32:1 16 62:4 49:1 50:19 58:23 paycheck 56:5 55:16 56:21, 21 mom 62:3 needs 5:14 24:24, 59:8 62:7 PC 53:16 58:8 61:2 63:6, 6, mom's 35:12 25 27:11 29:21 old 60:9 62:1 PCBSA 33:7, 16, 8 64:5 money 19:18, 20, 32:14 38:24 once 12:18 59:24 21 34:1 meetings 5:20 21 20:8, 12 47:21 47:25 48:15 52:8 60:20 61:2 62:7 Pedro 40:25 meets 15:7 51:1, 2 54:1, 3, 5 55:9 56:12 63:4 ongoing 60:15 pencil 11:21 Members 2:10 monitor 33:22 negotiate 55:17 online 30:14 people 6:12, 19 5:5 monitoring 33:20 neighbor 49:25 open 8:20 18:7 7:13 19:19, 19 men 41:20 59:13 50:8 OPERABLE 1:12 20:9, 24 22:25 mental 8:4 Monochlorobenzen neighborhood 26:6, 9, 17 23:17, 19 24:3, 17 mention 44:6 e 9:9 35:5 48:9 52:24 operating 29:19 25:3, 4, 6, 22 26:4, 45:14 Montgomery 24:10 53:1 operation 21:12 19 27:1, 13, 25 mentioned 19:13 month 8:16 neighbors 44:21 operational 9:1 28:14 29:6, 17 26:6 28:21 30:12 months 42:5 58:8 62:16 22:9 34:19 35:22 36:3, 33:1 MONTROSE neither 30:24 opinion 20:10 11, 11 38:6, 7, 7, 9, mentioning 27:23 1:11 5:6 7:20, 21 64:11 opportunity 4:12 15 39:3 40:13, 14, mess 27:6 8:11, 13, 23 9:6 network 8:19 25:5 57:1, 16 22 41:1, 22 42:18 message 56:4 10:12, 15 11:4, 13, never 40:8 42:8 oppose 57:14 44:19 45:5, 8 57:2 61:21 22, 22 12:6, 8 48:24 51:8 opposites 39:18 46:7, 19, 24, 25 messages 56:4 15:20 21:25 new 11:19 27:4 order 5:22 30:22 47:3, 15 49:3, 6, 7, messes 54:21 23:10 26:8 29:18, 36:5, 6 48:9 32:4 11 50:11 51:4, 24 metal 15:5, 8 20 31:6, 12, 13 53:17 57:6 ordered 55:6 52:14, 21 54:25 methods 14:18 33:5, 8 35:7, 9 News 36:16 organization 30:7 56:11 57:5, 6, 13, Michigan 33:9, 10 55:16 56:1 57:3 nice 28:23, 24 originally 6:7 18, 18, 23 58:2, 3, microbes 59:21, 24 55:23 58:11 orphan 53:1 18 61:16
Huntington Court Reporters324 & Transcription, Inc. 7 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 237 of 381 Page ID EPA PUBLIC MEETING,#:13785 NOVEMBER 8, 2014 people's 24:1 plumage 41:11 27:12 28:9 protective 16:10 rats 51:19, 24, 24 25:16 28:2 47:23, 24 presenting 21:4 proud 58:13 rattling 43:5, 11 period 6:14, 16, 20 plumber 52:16 pressure 44:9 provide 18:3 56:7, raw 9:8 43:24 17:17 20:18 plume 11:2, 10, 24, presumedly 60:21 8 63:2 44:1 23:11, 14, 15 50:25 25 12:1, 2 13:13 pretty 56:16 provided 32:17 reach 39:4 57:4 permission 44:4 22:3 61:11 62:21 53:2 react 9:11 person 23:2 24:9 plumes 21:23 prevent 11:15 providers 41:6 read 33:19 44:17 36:22 49:22 22:1 26:7 13:2 PUBLIC 1:9, 13 46:5 50:21 61:17 54:13 56:5 podium 22:23 Prevention 4:20 5:20 6:5, 6, 11, 14, ready 7:5 personally 37:22 point 10:9 12:3 previous 7:22 16, 20, 22 7:3, 6 real 36:23 44:15 54:2 25:15 26:8 29:12 8:22 9:13 50:7, 7 17:17, 24 18:1 46:17 51:12 perspective 11:20 33:12 34:10 print 24:13 43:9 21:18 22:21 57:16 62:20 pertains 19:12 42:16 58:22 59:1 printer 43:9 32:19, 19, 23, 23 realistic 50:15 22:3 60:14, 16 Priority 8:24 50:6 41:12 53:3 64:5 realize 21:9 25:23 pesticide 8:13 pointed 28:12 private 55:6 publish 18:4 realizing 47:23 9:14, 17 10:3 pointing 44:16 privileged 30:18 published 11:15 really 4:13, 22 Philip 2:14 49:23 poisoning 46:20, probably 27:22, 30:4 5:1, 10, 13, 19 phone 7:6 41:17 25 47:9 23 53:15 54:19 Puentes 2:13 3:7 25:24 26:20 27:6 47:1 poke 56:1 55:24 56:15, 16 35:2 46:4, 6 28:17, 22, 24 phones 5:18 police 35:19 42:21 problem 29:21 51:11 56:24 61:3 29:22 30:12 Phunong 4:18 polite 36:18 57:22 34:23 39:2 45:22 pull 14:12 56:14 31:15 34:20, 21, pick 61:8 politicians 53:7 48:14 57:11 pulls 14:4 23 37:2 39:8, 25 pictorial 16:23 polluters 54:21 problems 34:16 pump 31:14, 16 40:13 45:5, 5 21:24 pollution 33:24 39:6 46:1, 12 pumping 15:1 46:2 48:15, 20 picture 8:4 10:11, ponds 8:20 53:16 59:11 puppies 27:15 54:15, 21 56:3, 20 11 11:18 34:10 popping 53:18 process 13:6 purveyors 11:7 57:17, 20, 23, 25 52:5 53:14 54:6 portion 28:10 16:21 19:23 21:3 pushers 47:8 58:9, 11, 13 60:18 pictures 17:15 34:4 55:19 24:22 32:24 49:5 put 11:20 17:13 61:11 pieces 26:5, 12 portions 12:15, 16 59:15, 16 21:22 25:1 28:7, reason 15:14 pig 54:22 POs 39:4 processes 24:23 20 29:4 35:23, 24 23:14 pigs 26:4 57:5 positions 47:5 processing 10:10, 39:22 48:9, 21 reasonable 26:20 piles 22:13 58:15 11 49:5 50:1 51:6 reasons 6:12 pipe 45:22 60:10 possible 13:4 produce 9:12, 14 57:15 58:3 61:4, 40:11, 18 piped 14:21 27:7 29:24 31:17 produced 8:15 10, 13 received 6:19 pipelines 57:24 34:23 40:12 59:7, production 8:12 putting 24:14 52:19 pipes 36:5, 6, 6, 7, 21 10:13 27:2 36:9 45:21 recognize 52:19 8 44:2 47:13 possibly 26:16 profession 57:19 record 11:14 48:11 31:5 32:9 33:5 Program 4:20 < Q > 17:18 18:4 32:19, pissed 47:11 43:24 51:21 quality 16:18 32:8 19, 23 50:1 pits 33:12, 14 postcard 6:18 progress 53:25 question 19:7 recorded 6:24 place 11:14 25:3, postmarked 17:25 Project 2:3 48:25 20:22 21:8 22:19 recording 6:23 6 28:20 34:18 potential 15:18 prominent 51:13 26:15 red 11:24 36:14 48:12, 13 34:19 52:10 promising 28:4 questions 5:2 6:2, reduce 13:3, 10 52:24 53:3 56:22 potentially 31:7 proofed 61:15 3 18:8 59:1 reduces 16:12, 19 58:6 64:6 pounds 8:16, 17 properties 12:15 quick 7:21 62:20 reduction 16:18, places 33:6 pouring 38:1 15:18 51:14 quickly 4:13 5:13, 18 17:2 plan 4:11 5:7, 25 powders 8:18 property 7:22 19 29:9 refer 9:9 12:12 11:19 12:9 13:21 practically 30:24 8:11, 19 9:6 quiet 38:15, 16 refrigerator 20:2 17:16 32:18 50:5, preferred 8:2 10:15 11:5 12:6, quote 30:22 regards 24:23 9, 10, 15 55:4 16:24 17:4 9 15:20 21:25 46:14, 14 53:21 regenerated 29:2 62:13 pregnancy 37:20 25:20 42:13 57:10 Region 2:3 planned 6:7 25:7 prepared 30:21 propose 19:25 < R > regional 32:8 planning 51:17 32:16, 16 47:18 proposed 4:11 race 57:2 regular 7:5 53:24 plans 58:9 49:10 5:7 12:9 15:11 radiation 41:2 regulations 16:10, Plant 8:11 10:15, present 34:18 17:16 30:23 59:3 rain 49:17 15 17:9, 10 17 11:5, 18 12:8 59:6 62:13 raise 6:13 re-label 48:8 please 5:17 8:2 PRESENTATION protecting 37:16 raising 47:8 related 10:21 57:2 58:20 62:5, 1:13 5:8 6:1 8:3 46:18 rap 17:22 12:11 33:25 34:1, 11, 23 9:8 18:6 Protection 2:2 rates 26:18 9 64:12 plot 43:1 presented 17:7 4:8 16:17 ratify 37:14 relationship 21:19 reliable 16:16
Huntington Court Reporters325 & Transcription, Inc. 8 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 238 of 381 Page ID EPA PUBLIC MEETING,#:13786 NOVEMBER 8, 2014 relocate 47:13 researchers 60:5 routinely 11:10 31:24 32:10, 18 sign 5:12 61:4, 10, 50:5 51:24 54:25 resident 52:5 33:22 34:5 36:16 38:2 13 55:3 residential 10:16 row 45:11 39:22, 24 40:15 significant 31:8 relocated 41:11 residents 23:8 rude 46:6 47:7 41:3 45:16, 21 sign-in 5:10 49:14 54:23 55:19 42:25 50:6 56:15 rug 48:2 60:5 signs 36:2 46:16 relocation 25:4 59:12, 13, 15 60:22 ruled 18:20 seeing 11:1 61:5, 17 49:5 50:15 51:18, residual 8:1 12:7, run 5:18, 22 6:9 seeking 24:22 silence 5:17 21 55:11, 13 56:15 13, 17, 18 31:1, 7, 8 38:18 seen 10:19 39:9 SILVA 64:4, 21 remain 33:17 resistance 13:20 running 27:3 40:8 41:16 47:15 similar 24:8 56:21 remains 9:21 15:4, 7 16:5 39:22 40:11, 11 see-through 39:22 Simply 13:1 29:3 28:25 17:13 57:12 43:19, 22 selection 9:4 single 37:23 remark 25:9 resistant 20:6 sell 51:6 52:22 sinister 42:18 Remedial 2:3 resources 56:14 < S > 56:16 57:10 sister 35:13 13:18, 23 15:21, respect 31:2 safe 20:15 51:8 semester 37:19 sisters 35:13 23 16:2, 5, 8, 24 58:17 58:6 semi-volatile 9:24 SITE 1:11 7:20, 17:19, 20, 21 31:4 responded 32:19 safety 40:18 send 62:14, 17 23 8:21, 23 9:15 50:3 response 18:3 Saint 33:9 sending 17:24 10:20 11:15, 16, remediate 31:10 31:18 sampled 11:10 senior 38:22 23 13:7, 12, 15, 16 remediated 30:25 responsibility 55:5 San 2:7 17:15 sense 26:11 31:24 14:1, 6, 14, 18 31:9 responsible 12:3 24:17 40:25 32:22 15:15 16:19 remediating 31:11 22:13 53:21 55:9, sanitary 8:20 sent 41:13 44:3 19:11 29:19, 20 remediation 7:24 22 Sattler 2:17 3:11 separate 59:17 30:13 31:6, 12, 13 28:10 rest 54:19 55:21 58:21, 21 separately 10:2 33:5 58:4 remedies 8:1 59:5 saturation 31:1 serious 30:15 sites 8:25 23:10 11:17 14:15, 16, restrict 15:20 SATURDAY 4:1 seriously 50:10 29:19 23 15:11 restroom 62:20 Savanna 2:18 serve 30:16 35:25 sitting 26:4 30:10 remedy 8:2 9:3 restrooms 5:9 61:24, 25 62:6 serves 22:2 41:16 45:10 54:19 11:11, 14 15:4 result 8:11 59:15 save 19:20 service 14:22 situ 14:18 16:14 17:4, 11 retained 18:14 saved 38:20 services 53:2 situation 45:21 30:24 retelling 24:6 saw 9:13 10:8 set 64:6 49:2 remember 46:1 retirement 23:20 saying 20:11 sets 57:23 sixth 16:4 remind 25:6 56:6 25:22 31:10 34:9 settings 32:9 skin 41:15 reminder 62:8 returned 18:17 37:14 38:13 seven 9:1 12:22 slide 9:5, 13 12:9, removal 22:4 revenue 13:2 40:19 43:12, 23 17:5 26:8 40:23 11, 12 21:9, 22 26:14, 14 31:17 review 27:4 30:9 54:24 seven-year 28:11 62:8, 9 remove 10:24 reviews 27:8 says 8:8 16:20 sewage 43:24 44:1 slogan 38:25 29:3 31:5 51:4 revisit 54:7 40:2 46:4 49:12 sewers 8:20 slurry 13:11 removed 34:2 revisited 27:1, 10 schedule 17:16 shaking 42:7 small 54:4 50:24 59:25 60:20 52:8 school 35:20 37:5, 47:19 smart 36:22, 24 removing 19:18 rich 42:2 56:16 6 39:21, 25 40:22 share 26:9 47:4 20:5, 5, 9, 24 28:18 rid 38:13 39:15 schools 38:21 shatter 38:18 smell 52:13, 18, 18 repeated 23:13 ridiculous 45:4 science 34:20 sheet 5:10 smoke 49:1 24:3 48:3, 24 59:18 shift 42:7 snapshot 9:5 Replenishment right 5:10 6:23 scope 21:18 shirt 49:12 soccer 48:21, 23 4:19 27:22 30:7 12:4 13:15, 16 score 37:4 shorthand 64:7, 10 49:7 32:7, 17 18:7 24:12 27:1 Scott 4:15 shortly 4:10 social 39:7, 15 report 45:25 33:8 35:4, 16, 21 screened 28:4 short-term 16:20 40:19 44:11 47:10 reporter 6:23 7:1, 37:21 40:20 41:8 29:11 shot 46:18 society 38:3, 13 8 42:20 43:2 45:19, screening 29:9 show 40:12 soil 8:21 9:20 representatives 24 46:25 49:1, 9, screens 8:1 showcase 21:24 12:16, 20 13:24, 55:22 19 53:15 56:9 second 15:16 showers 41:15 25 14:2, 5, 7, 19, request 23:13 57:2, 8 42:22 showing 41:18, 19 20 15:7, 22 20:3 29:8 62:22 rise 50:12 Secondly 5:25 shown 58:18 22:15 52:14 53:16 requested 23:3 River 29:1 secretaries 47:6 59:14 soils 31:20 require 27:3 Riverside 33:12 section 18:16 shows 10:11 solid 9:20 required 5:21 road 58:11 security 40:1 12:24 soluble 9:22 33:2, 15:13 17:10 rods 15:5, 8 54:3, 44:11 sick 46:24 3, 4, 6 requirements 17:1 9 see 9:7 10:14, 23 side 42:11 53:11, solve 34:23 research 59:19 room 21:21 26:24 11:3, 24, 25 12:1, 12 solved 29:21 60:15 29:17 40:5 55:10 7, 13 14:6, 7, 13 sidetrack 42:19 solvent 33:4, 4, 6 rough 34:20 16:23 23:17 26:2 Sierra 58:24
Huntington Court Reporters326 & Transcription, Inc. 9 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 239 of 381 Page ID EPA PUBLIC MEETING,#:13787 NOVEMBER 8, 2014 somebody 24:5, 7 ss 64:1 stuff 22:24 39:23, 10:20 11:10 22:4, thing 5:22 6:25 25:9, 12, 15 28:21 stages 13:9 24 46:1 53:5 5 23:2, 3 25:3 12:3 29:17 32:3 29:4 48:5, 7, 7 stand 35:24 60:19, 20 26:5 32:25 39:11 34:22, 23 35:21 53:8, 10 60:4, 24 start 7:20 10:23 subject 34:12 40:10, 15 43:6 36:9 39:1, 19 61:10 17:19 27:15, 17 submit 7:4 17:24 46:7 48:10 53:4 41:5 42:16, 19 somebody's 25:19 44:4 49:11 52:15 62:10 59:7 43:14 49:15 51:4, someplace 49:16 54:9, 10 60:21 submitted 18:4 talked 33:2, 3 11 56:9 57:2 someway 60:23 61:16 submitting 7:3 41:9 44:2 50:4 61:14 son 35:2 37:4 started 6:14 subscribed 64:14 talking 7:19 things 5:21 6:4, 45:11 46:17 48:6 22:21 23:20 substance 27:21 24:10, 15, 16 28:7 21 27:5, 18 30:12 son's 36:19 30:13 58:12 substances 8:6 32:1, 2 37:11 32:13 40:11, 15 soon 30:14 52:15 starting 17:20 30:6 32:7, 15 talks 53:6 42:11 43:18 45:1 62:24 28:1 43:21 suffered 60:22 tank 43:3 48:2 51:17 52:9, sorry 18:6 19:16 starts 44:8 suffering 35:16 taught 55:24 18, 23 53:17 21:4 35:2 46:17 State 4:16 16:14 sufficiently 34:2 TCE 12:2, 2 57:14 60:21 49:10, 20 56:25 27:11 30:23 47:3 sugary 28:16 22:13, 15, 15 34:14 think 19:7 21:3 sort 36:14 48:13 62:23 64:1 suggest 32:5 technical 4:24 23:21, 22 24:2, 4, sounds 28:22, 24 stated 13:1 52:7 suggested 33:19 8:18 10:12 25:10, 14, 21, 25 25:1, 18 43:3 statement 31:20 Sulfuric 9:10 21 27:9 28:3, 6 26:3, 11, 15, 18, 21, source 11:2, 2 States 8:14 33:7 summary 7:21 30:21 31:19 23 27:11 28:17, 13:5 22:2, 11 stay 45:19 13:17 14:9 32:12 34:7 19 30:1 36:7 31:21 stays 10:3 sun 41:1 technically 25:13 37:18 39:25 41:5 sources 22:6 Ste 2:4 SUPERFUND technologies 13:7, 42:14 43:1 44:15, SOUTH 1:15 steam 13:19 1:11 7:20 8:23 8, 8, 14, 16, 19, 22, 16, 22 46:13, 18 39:25 14:23, 24 15:1, 2 11:23 17:10 21:3 22 14:15 16:8 47:22, 22 50:10 Southern 11:7 16:2, 3 supervision 64:8 21:5 27:4 28:4, 51:5 52:5, 18 48:4 step 31:12 32:24 supposed 59:7 17 29:9, 11 53:13, 15, 20 span 50:4 stepped 55:18 sure 4:14 6:23 technology 8:1 59:10, 12 62:19 Spanish 5:13, 14, stern 56:3 7:1 13:5 15:22 14:1, 8 29:8 thinking 23:18 15 stick 27:14 22:20 27:6, 19 tell 35:16 39:14, 24:21 42:6 44:20 speak 38:14 stone 33:14 33:6, 20, 23 51:5, 19 57:21 58:8 third 37:1 54:13 56:20 stop 36:3 49:13 25 52:16 60:6 62:25 thought 28:15 SPEAKER 3:2 57:14 62:25 telling 47:2 33:13 35:25 36:4 18:11, 23 20:23 stopped 42:13 surface 8:22 tequila 44:25 37:8 42:1, 9 55:8, 21:8, 17 22:18 59:16 10:14 12:22, 23 term 5:7 8:5, 7 13 61:5 50:7, 7 62:14 stores 44:24 14:5 31:15 terminal 35:17 threats 16:12 speaking 6:11 7:6 stories 54:16 surrounded 10:16 44:6 three 6:7 15:21 58:22, 25, 25 story 10:20 24:7 survived 46:20 terms 34:7 62:12 17:5 26:9 27:8 speaks 38:14 44:15 47:2 SVE 13:19 terrified 42:5 28:11 33:6 42:5 special 38:24 straight 46:9 sweeping 48:2 territories 34:8 46:8 62:15 specifically 23:8 straightforward syrup 28:15 32:1 test 34:12, 13 TI 52:6 53:20 spectrum 38:4 35:18 system 14:7 19:4 37:2, 4 54:7 speech 40:6 strange 52:13 21:10, 11, 13, 20 tested 28:21 tickets 41:2 speed 28:6 strangest 24:11 27:2, 3, 3 28:20, testified 57:6 time 14:12 24:9 spend 20:13 43:5 strawberry 42:3 22 30:14 34:1 Testimony 5:15 25:3, 6, 12 26:2, 51:2 streams 8:19 systems 29:3 Thank 4:4, 5 5:1 12, 12 28:5 30:3 spending 20:8 Street 2:6 35:4, 6, 36:11 20:17, 21 23:5 33:15 35:10 51:5, 5 54:18 21 40:25 42:12, 29:13, 14 34:24, 40:10 43:4 47:12, spent 19:18 32:21 17 43:2, 16, 20 < T > 25 49:19, 21 13, 13 50:5, 12, 25 51:1 55:12, 18, 19 table 5:11 14:3 50:15, 17 51:8 54:17 55:7, 12, 20 spilling 20:2, 3 stress 11:6 29:6 32:5 48:24 52:1, 2 54:11, 12 56:13 60:12 spinning 53:15 stretched 20:11 55:17 56:8 58:20 60:25 61:10, 16 62:6 spoke 62:21 string 33:11, 14 take 16:13 23:25 61:23 62:6 63:3, 7 63:6 64:6 spot 47:15 strong 9:11 25:23 30:1 38:8 thankfully 56:21 timeline 28:11 spray 41:20 strongly 60:1, 24 47:11, 20 56:4 thankfulness 23:11 times 38:20 45:11 spraying 41:22 structures 59:21 57:2 62:25 Thanks 4:21 7:18 62:15, 15, 15 square 31:21 struggle 56:18, 19 taken 36:14 49:21 62:18 timing 30:11, 19 squirrels 51:19, 24, stuck 12:15 37:22 50:10 64:5, 6, 10 therapy 40:5, 5 tired 53:25 25 38:16 takes 18:1 61:11 thereof 64:13 today 4:6, 24 7:4 squirting 44:8 study 26:13 30:4, talk 5:3, 5, 6, 25 thermal 14:15, 16, 17:16 23:1, 18 4 7:10, 19 9:16 18, 23 15:4 19:10 27:13 29:10
Huntington Court Reporters327 & Transcription, Inc. 10 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 240 of 381 Page ID EPA PUBLIC MEETING,#:13788 NOVEMBER 8, 2014 34:24 41:16, 17 48:20 55:10 56:8 33:4 44:6, 7 47:19 48:4, 5 10 43:14, 22 43:10 44:14 53:7 57:17 61:21 46:15 55:1 56:10 49:11, 14, 15, 15, 44:12 49:11 55:23 57:7 58:16, trying 28:1 31:24 uses 14:10 18 54:14, 24 57:9 54:15 60:9 61:12 20 59:23 32:21 54:20 usually 14:14 58:3 60:16 61:14 wells 11:8 14:2, 3, toilet 43:23 tumor 35:17 44:6 utilize 28:6 62:19 63:1 10, 13, 14, 21 15:1 told 26:13 45:23 turn 5:17 7:10 wanted 4:5, 12, 21, 31:13 33:10 42:3 48:17 56:22 59:23 14:16, 19, 24 44:7 < V > 24 5:3, 9 6:15 went 30:9 37:9 tool 17:7 turned 44:9 vacant 10:15 18:7 21:24 22:4 42:6, 9 43:20 top 26:4 40:2 turns 33:7 vacuum 14:4, 4 36:2 41:25 51:23 44:2 51:17 60:10 50:6 57:6 TV 41:3 19:3 52:1 we're 5:6, 11 TORRANCE 1:16 twice 35:23, 25 vacuums 13:25 wants 6:6 29:15 6:10 19:9, 23, 25 4:1 35:3 43:3 56:20 61:2 62:7 Valdez 50:20 61:4, 13 20:15 21:7, 14 49:24 52:21 two 7:15 9:17 valuable 23:21 war 47:16 53:22, 25:25 26:13 53:12 61:7, 18 10:1 12:5, 10, 25 value 55:2 22 27:17 28:7 30:10, torture 36:3 14:14 15:24 valve 44:9 warfare 39:9 11 32:1, 1 35:19 totally 40:9 41:23 17:14 31:24 vapor 13:24 14:7, warn 40:19 36:5, 5, 6, 8 37:11 touch 39:23 35:13, 14 36:24 25 15:22 19:4 Warren 4:15, 15 38:3, 6, 16 39:1, 9 touching 57:25 37:5 39:18 44:5 52:10, 14 53:16 wash 46:10 40:19 41:6, 7, 16 town 33:9 45:10 46:10 62:15 vaporize 15:10 Washington 24:18 42:25 44:21 towns 41:21 type 15:4 19:8 vaporized 49:16 waste 8:19, 20 45:18 47:8, 8, 9, toxic 10:4 18:15 23:13, 23 61:14 vapors 13:25 22:12 29:21 18 48:16 53:23 27:21 30:6 32:2, types 24:5 14:1, 4, 17, 20 19:2 47:23 57:20 58:4 54:24 56:18 7, 15 57:19 58:4 typewriting 64:7 various 11:16 wasted 48:25 57:14, 21 58:14 60:8 13:20 22:1 wastewater 34:1 West 35:3 61:7 toxicology 41:19 < U > vent 22:15 Water 4:19 8:6, 7, Western 40:25 toxins 39:2 49:13 U.S 2:3 4:7 venue 24:3 8, 22 9:22 10:17 53:13 61:22 ultimately 34:4 verbalizing 61:16 11:6, 7, 8, 9 14:3, wheels 53:15 track 6:13 uncle 62:2, 4 verbally 24:4 10, 12 15:25 16:1 WHEREOF 64:14 traffic 61:18 underground verbatim 43:8 19:16, 17 27:22 white 9:20 training 46:19 14:14, 24 15:1, 6 VERMONT 1:15 30:6, 8 32:7, 8, 17 widely 9:17 transcribe 7:8 understand 19:22 version 24:7 33:2, 3, 4, 5, 10, 18, wild 51:18 transcribed 64:7 28:8 33:24 60:20 versions 15:24 20, 22, 23 34:2 wildlife 10:5 transcript 64:9, 9 understanding viability 30:4 41:14 42:6, 8 51:23 transparent 30:23 21:19, 21 57:23 victims 47:9 43:18 44:6, 7, 7, 8, willing 5:5 37:24 31:2 59:2 video 43:13 10 Wilshire 2:4 traveled 45:16 unfortunately view 50:4 wave 4:25 win 41:3 treat 8:10 14:17, 43:9 55:25 visionary 24:10 waving 47:16 wish 4:13 49:10 25 ungrateful 35:22 volume 17:2 waxy 9:20 WITNESS 64:14 treated 14:22 UNIDENTIFIED volunteered 40:23 way 10:5 17:18 won 53:23 15:25 34:3 54:22 18:11, 23 20:23 52:14 19:19 24:1 25:4 wonder 51:1 treating 19:7 21:8, 17 22:18 27:7 38:1 42:24 word 5:7 24:5, 5 treatment 10:17 62:14 < W > 44:5 45:14, 21 56:3 11:18, 19 14:5, 18 Unified 39:22 wait 28:5 48:14 54:20 55:1, words 20:23 16:19 17:3 19:8 47:3 waited 58:2 14 56:7 57:18 37:18 61:16 21:10, 11, 13 27:2, unincorporated waiver 25:11, 21 58:15 61:19 63:1 work 23:8, 18 3 28:20, 21 30:13, 52:20 27:10 28:3 52:6 64:12 27:1 30:12 33:21 25 31:1 34:1, 3 uninformed 37:8 53:20 54:7 ways 7:3 62:11 35:16 38:9 51:23 treats 13:25 UNIT 1:12 22:9 walk 39:11 weather 61:15 58:13 59:24 tribe 41:19 26:7 34:3 walking 38:12 webpage 53:3 worked 27:13 tribes 29:1 United 8:14 33:7 40:24 41:22 46:11 website 6:17 33:13 36:22 tried 45:7 46:7 units 9:1 26:9, 17 wallow 33:14 weekend 46:24 51:12 55:4 58:13 trouble 31:23 29:20 38:24 walls 13:11 39:22 weeks 10:18 workers 39:15 truck 23:22 unrament 37:9 want 5:18 6:12 21:15 46:9 40:19 44:3 47:3 trucks 41:21 unsuspecting 52:22 10:9 11:6 12:3 weight 9:16 working 4:23 42:22 43:4 47:14 untreated 16:1 20:17 22:20 23:3 Welcome 4:4 5:4 23:19 30:11 35:9 56:11 unusable 56:13 24:3 27:14, 19 20:19 44:11 52:25 true 64:9 updates 62:12 29:17, 22, 24 30:1, well 14:5 21:20 workshop 7:13 Trust 40:10 ups 25:7 3, 19 32:4, 12, 18, 24:1, 16, 17, 20 12:18 try 21:23 25:13 USC 37:1 25, 25 33:16, 18, 25:23 26:24 world 26:10 37:24 40:7 42:20 use 5:7 15:19, 21 21, 23 34:10 41:9, 31:14, 15, 16 34:1 45:15 58:3 19:10 20:1 22:23 11, 12 44:14 38:19 40:15 42:7, worn 54:1
Huntington Court Reporters328 & Transcription, Inc. 11 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 241 of 381 Page ID EPA PUBLIC MEETING,#:13789 NOVEMBER 8, 2014 worry 25:24 42:11 worse 27:18 41:7 57:22 60:14 worst 45:12, 13 write 62:25 63:1 written 32:16, 17, 18 56:12 wrong 26:3 36:8 37:20 45:23 46:6 54:23 wrote 43:8
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Huntington Court Reporters329 & Transcription, Inc. 12 301 N. Lake Avenue, Suite 150, Pasadena, CA 91101 1-800-586-2988 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 242 of 381 Page ID #:13790
APPENDIX C WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
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330 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 243 of 381 Page ID #:13791
February 13, 2015 Yarissa Martinez, P. E. United States Environmental Protection Agency Southern California District Office Region 9, Superfund Division
Staff 600 Wilshire Blvd., Suite 1460 Cynthia Babich Los Angeles, California 90017 Director Cynthia Medina Assistant Director Del Amo Action Committee’s Comments on Proposed Plan for the Montrose Superfund Site Dense Non-Aqueous Phase Liquid Remediation Sofia Carrillo Promotora Dear Yarissa Martinez, Thank you for extending the public comment period. Additionally, we Board of Directors Florence Gharibian appreciate that EPA will accept additional comments and not move forward Chair of the Board with finalizing the ROD until an EPA supported technology screening occurs, Nick Blanco prior to September 30, 2015 as stated in your email of February 7, 2015. Homeowner/Resident Barbara Stockwell We remain concerned that there is not a clear understanding of the extent of Homeowner contamination in the groundwater underneath the communities adjacent to the Lydia Valdez Homeowner/Resident Montrose property. We are extremely anxious about the increasing Brenda Bibee contamination levels in the shallow groundwater. We believe there is a real Volunteer Coordinator possibility that these cancer causing chemicals could be seeping into the air Lizabeth Blanco under and in homes in the community, which EPA is currently investigating. Homeowner/Resident The thought of using a technology that will encourage this very concentrated Robina Suwol thick mass of chlorobenzene to volatize so it can be captured and treated is truly Board Member frightening considering the uncertainties. We believe that more needs to be Advisory Board * done to work with the community so we can understand the scenarios of what Jane Williams could happen if the treatment does not go as planned. There are families living California Communities Against Toxics on top of these plumes and adjacent to these DNAPL masses. Families that Martha Dina Arguello have endured decades of exposure to the various operable units of this site Physicians for Social which are undergoing various remediation associated activities. We feel there is Responsibility, L. A. a clear lack of coordination between these operable units, in some instances it Linda Kite seems the “cart has been put in front of the horse”. Healthy Homes Collaborative * Affiliations Provided for The Technical Impracticability (TI) Waiver Zone needs to be revisited. We Identification Purposes Only believe it is a clear environmental injustice and has created parts of the community which are now sacrifice zones. We believe that there could be ways to clean groundwater in these areas and to not even try makes members of the community feel like their lives are not valued the same as others. To emotionally inflict harm by creating this zone of containment is cruel and un- necessary. We would like to know when EPA will look at this issue with us, as we have made many requests for a firm date to do so.
We remain confused about why many possible useful technologies were screened out early on in the process. Since the Record of Decision (ROD) for the groundwater remediating was signed in 1999, over 15 years ago we believe
P. O. Box 549 Rosamond, 331California 93560 Office: 661-256-7144 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 244 of 381 Page ID #:13792
that there could be options available to us today that were not back then. Had the treatment plant been built soon after the ROD was signed we would have undergone three five-year reviews which I believe would have had a component to them to revisit current technology practices to see if the treatment system was doing the best it can.
The concerns we have raised here and that we have repeatedly stated verbally are why we remain terrified that impacts to our health, which we believe are due in some part to the exposure and combined effects of these chemicals, in our groundwater, soil, air, homegrown produce, chicken and eggs will increase. The community is not as healthy and vibrant as it should be. The Del Amo Acton Committee was formed by community residents in response to the diminished health conditions we observed back in 1993 and we have dedicated the past 23 years to make our community a healthier place to live, work and play. A vision many of us believe may not be attainable for our community which is living at ground zero, we deserve better. Relocation is a serious goal for us. A plan to contain contamination under our homes over the next 5,000 years is not an option we can support.
A holistic approach that pulls all the operable units back together so we can look at the whole picture and not the piece meal approach which is overly complicated and hard to grasp needs to be developed. Until this time the pieces as proposed, like the DNAPL proposed plan, are fragmented and overwhelming to those that will be most impacted by the decisions made yesterday and today, the residents of this community.
Our technical advisor, Markus Niebanck, has reviewed EPA documents for this piece of the puzzle and has made several comments which we are including here:
1. The technical advisor recommends that EPA more clearly state that the groundwater remedy selected to contain DNAPL outside the focused treatment areas is estimated to take over 3,000 years at this site.
2. The advisor recommends that EPA state clearly that the proposed remedy will not remove the residual DNAPL trapped between soil particles, or the DNAPL located outside the “focused treatment area.”
3. The advisor recommends that the Proposed Plan reference all California agencies, including the Water Replenishment District, that have been engage in the Proposed Plan preparation to assure stakeholders that relevant agencies have been given an opportunity to participate in this important process. Just doing anything is not the same as doing something. Precious lives are living on top the toxic soup created by the Montrose Chemical responsible parties. We are not safe living here and are scared things will get worse if “heated up”.
Cynthia Babich Cynthia Medina Director, Del Amo Action Committee Assistant Director, Del Amo Acton Committee
Florence Gharibian Chair of the Del Amo Action Committee Board of Directors
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333 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 246 of 381 Page ID #:13794
334 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 247 of 381 Page ID Attachment 1: Montrose Comments#:13795 on DNAPL Proposed Plan Montrose Chemical Superfund Site
Executive Summary
Montrose Chemical Corporation of California (“Montrose”) supports a remedy for remediation of Dense Nonaqueous Phase Liquid (“DNAPL”) at the Montrose Superfund Site (“Site”) that is green, effective, safe, cost-effective, and that provides the best balance among the National Contingency Plan (“NCP”) factors for remedy selection.
Of all the potential remedies for the Site, Hydraulic Displacement provides the best balance among the NCP factors and is effective at eliminating risks to human health and the environment in a reliable and cost-effective manner. Focused Electrical Resistance Heating (“ERH”) is also a reasonable remedy, which satisfies the NCP factors. The other thermal remedies, studied in the DNAPL Feasibility Study including full scale thermal and steam injection, are not implementable, not cost- effective, and may result in irreparable, catastrophic harm to human health and the environment.
What is the Site? A 13-acre property located at 20201 S. Normandie Avenue in the Harbor Gateway area of Los Angeles that was used for the manufacture of technical grade DDT from 1947 until 1982.
What type of contamination is being addressed at the Site? DDT contaminated soil and groundwater, as well as DNAPL composed of DDT and monochlorobenzene (“MCB”), a raw material used in the DDT manufacturing process, have been detected in certain areas at and beneath the Site.
How is the Site unique? The Site exhibits a unique lithology, consisting of highly layered heterogeneous silt with low permeability, with DNAPL at depths of more than 100 feet below ground surface. The Del Amo Site, which is located across the street from the Site, has a nearly identical lithology. At the Del Amo Site, EPA did not select thermal remediation because such unique lithology is not well-suited for application of thermal technologies: “the low permeability and heterogeneous character of soils at the former plant site would interfere with the uniform transmission of the steam through the subsurface.”
Additionally, as explained in the 1999 Record of Decision for the Site (“ROD”), EPA has recognized that it is technically infeasible to remove enough DNAPL to attain drinking water standards in the immediate vicinity of the DNAPL. As a result, EPA has issued a waiver of the in-situ groundwater standards in that area (the “TI Waiver Zone”). How is the contamination at the Site Unique? The DNAPL found at the Site differs from DNAPLs commonly found at other sites. Only three other sites in the country contain similar DNAPL and the DNAPL remedies at those sites involved hydraulic containment and/or extraction. Due to the infrequent occurrence of similar DNAPL, the behavior of such DNAPL is not well-documented. There is a limited basis to evaluate the effectiveness of thermal remedies at remediating Montrose DNAPL, but several factors suggest that full-scale thermal technologies would not be implementable: Montrose DNAPL exhibits a boiling point that is approximately 19 degrees higher than other typical DNAPLs, Montrose DNAPL exhibits low vapor pressure, and the DDT in Montrose DNAPL precipitates when MCB is removed. These factors lead to reduced mass removal efficiencies when thermally treated. 335 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 248 of 381 Page ID #:13796
Executive Summary
What are the possible remedies for DNAPL at the Site? In detail, the DNAPL Feasibility Study analyzed Hydraulic Displacement with untreated water injection, Hydraulic Displacement with treated water injection, Focused Steam Injection, Full Scale Steam Injection, Focused ERH, and Full Scale ERH. Other remedies were also studied and rejected including bioremediation, cosolvent injection, conductive heating, and polymer flooding. Additionally, Montrose conducted numerous laboratory and field pilot tests to evaluate all feasible and effective candidate technologies as thoroughly as possible.
Hydraulic Displacement is a safe and cost-effective remedy: Hydraulic Displacement is a green, safe, simple, and cost-effective remedy for the Site that would protect human health and the environment by removing the majority of mobile DNAPL mass within the saturated zone, removing more mobile DNAPL mass than any other proposed remedy (the primary threat to groundwater), desaturating and significantly demobilizing any remaining DNAPL, limiting the potential for migration of DNAPL, and limiting the potential for human exposure to contaminants with significantly lower energy consumption and resulting GHG emissions.
Full-scale thermal remediation poses unnecessary and irreversible risks to human health and the environment and is not cost-effective:
• Full-scale thermal remediation is potentially a $100 million complex remedy that poses risks of catastrophic explosion, fugitive emissions, contaminant migration to neighboring properties, soil weakening and diminished structural stability of nearby buildings, and threatens to introduce as much greenhouse gas (“GHG”) into the surrounding community as a large power plant (see page 6).
• The safety risks associated with full-scale thermal remediation are magnified by the proximity of neighboring properties. The industries north of the Site share a near-zero lot line with Montrose, there is a chlorine plant located immediately south of the Site that supplies chlorine to all municipal water supplies in the Los Angeles area, and there are residential homes across the street from the Site (see page 1). Therefore, contaminant migration, fugitive emissions, decreased structural stability, or explosion could therefore have devastating effects.
• Steam injection poses a significant risk for downward migration of contaminants. Presently, no DNAPL has been found in the Bellflower Sand, the aquitard that lies underneath the Upper Bellflower Aquitard. However, due to increased saturation and mobility of DNAPL and weakening of capillary barriers caused by thermal remediation, DNAPL can migrate along the top of low permeability silt layers in the Upper Bellflower Aquitard and when the DNAPL intercepts a discontinuity in a silt layer, the DNAPL can migrate down to an underlying aquitard.
• The massive environmental and safety risks and the immense cost of thermal remediation are not justified by any considerable benefits. While full-scale thermal remedies have the potential to remove more DNAPL mass than Hydraulic Displacement or Focused ERH, full-scale thermal remedies will not remove more mobile mass -- the principle DNAPL threat -- and like all other remedies, including Hydraulic Displacement, thermal remedies will still require over 3,000 years of groundwater containment within the TI Waiver Zone. • Moreover, the unique character of Montrose DNAPL and the unique lithology of the Site are not suited for thermal remedies, thus making the effectiveness of a thermal remedy uncertain and increasing the risks of contaminant migration and fugitive emissions. 2 336 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 249 of 381 Page ID #:13797
Executive Summary
DNAPL Is Completely Contained Within TI Waiver Zone
(Chlorine Plant)
3 337 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 250 of 381 Page ID #:13798
Summary of Available Remedies
Increasing Risks to Human Health & the Environment
Increasing Complexity
Increasing Costs
- Groundwater is - ERH is accomplished by - Pressurized steam is - Same as Focused - Same as Focused simultaneously installing electrodes injected into subsurface (in ERH, except treatment Steam except treatment extracted and injected to throughout the treatment the mobile DNAPL area) to would occur over entire would occur over entire induce hydraulic zone (mobile DNAPL vaporize contaminants for DNAPL-impacted area, DNAPL-impacted area, gradients that mobilize area) and transmitting an SVE recovery. Steam will rather than just the area rather than just the area electric current between condense in the subsurface DNAPL towards and can displace or flush containing mobile containing mobile extraction wells. them to heat the soil by DNAPL. DNAPL. electrical resistance. contaminants towards - The extracted recovery wells. A hot floor may be needed to reduce - 456 electrodes and 203 - 186 injection, DNAPL/ groundwater - The electrodes are potential for downward extraction wells would extraction, and requires separation, typically spaced from 12 migration. be required to treat the monitoring wells would followed by off-Site to 25 feet apart depending entire DNAPL- be necessary to treat the disposal of the DNAPL upon soil resistivity, and - Steam Injection and multi- impacted area. entire DNAPL- and reinjection of the are installed within soil phase extraction wells are groundwater. borings using standard positioned throughout the impacted area. methods. DNAPL-impacted zone. - There is a possibility Vapor-phase contaminants of treating groundwater - The vapors generated by are removed by SVE and prior to reinjection, but this process are recovered liquid-phase contaminants are removed by direct it should not be by SVE for ex-situ treatment. extraction. DNAPL is necessary in the TI separated and disposed off- Waiver Zone. - 102 electrodes and 66 Site. A total of 55 injection, extraction wells would be extraction and monitoring - 69 extraction and needed. wells would be required. injection wells would be required. 4 338 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 251 of 381 Page ID #:13799
Effectiveness of Available Remedies
Hydraulic Displacement ERH Steam Injection
• Predicted to remove 36,000-43,000 gallons of • Predicted to remove 42,000-55,000 (Focused) • Predicted to remove 42,000-55,000 (Focused) total MCB, and 9,000-13,000 gallons of or 53,000-59,000 (Full Scale) gallons of total or 53,000-59,000 (Full Scale) gallons of total saturated zone total DDT. MCB, and 0 gallons of saturated zone DDT. MCB, and 0 gallons of saturated zone DDT. • Predicted to remove 80% of the mobile • However, effectiveness is uncertain: ERH • However, effectiveness is uncertain: Steam DNAPL mass. has not been implemented at a site comparable Injection has not been implemented at a to a full-scale ERH remedy at Montrose and has comparable site and has not been proven at this • Effectiveness is certain: Hydraulic not been proven at this Site. Multiple factors Site. Numerous factors suggest that the remedy Displacement was field pilot tested at the Site suggest that remedy may encounter may encounter remedy problems: effectiveness problems: in 1991, 2005/2005, and 2008. o Preferential steam flow through higher o Some DNAPLs are not readily o Desaturated soils, boiling of the permeability soils will make achieving mobilized for extraction by Hydraulic groundwater may result in higher necessary target temperatures Displacement. Although residual resistivity soils, inhibiting transmission of problematic. The complex lithology of saturations of DNAPL would be left in electricity through soils. This may result the Site cannot be easily engineered to place, such DNAPL poses little or no in inefficient and non-uniform heating control steam distribution. under full-scale ERH. risk of mobilization. o The highly layered nature of the UBA o The 45-feet thick interval at the Site can may limit the ability to recover volatized o Discontinuous sand layers which are not pose challenges to uniform heating. A MCB. If volatilized MCB vapors are not in hydraulic communication with the longer electrode will be needed, which effectively recovered, they have the extraction and injection wells may limit may not effectively heat soils in the potential to condense and accumulate in the effectiveness of this and other middle of the treatment interval under other parts of the UBA. displacement technologies such as full-scale. Steam Injection. o Steam Injection increases the saturation o The depth of the water in the BFS is only and thus mobility of DNAPL. Downward slightly deeper than the UBA, so some mobilization may exacerbate cooling from the BFS may occur, thus environmental impacts rather than increasing the required heating duration. mitigating them. o • However, ERH presents fewer effectiveness The high boiling point of Montrose risks than Steam Injection because ERH heats DNAPL and the low vapor pressure of resistively and does not rely on soil MCB may result in reduced mass removal permeability for heat distribution, and has a efficiencies. higher well density thus increasing the potential o Reinjection of treated groundwater into for recovering MCB vapors. ERH is more the UBA may potentially cool the commonly applied at sites like the Montrose subsurface, reducing the effectiveness of Site, where soils exhibit lower permeability. the remedy.
Environmental Risks of Full Scale Thermal Remediation and Steam Injection 5 339 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 252 of 381 Page ID #:13800
“Green “To protect remedia tion is the human health and practice of the environment, considering all policy makers, environmental remediation effects of remedy practitioners, and implementation the public should
and incorporating be aware of wider options to potential impacts minimize the of remedial
environmental options and footprints of incorporate this cleanup actions” information into
U.S. EPA, Superfund the remedy- & Green Remediation. selection process.” California DTSC Interim Advisory for Green Remediation.
• Full Scale Thermal Remedies Require a Massive Amount of Energy and are Inconsistent With State and Federal Goals: o An enormous amount of energy is required to heat the entire DNAPL impacted area to the target temperatures necessary for effective implementation of a Full Scale Thermal Remedy. Accordingly, the energy-based carbon footprint of Full Scale Thermal Remediation is exceptionally high. Full Scale Thermal Remediation has the potential to produce up to 500 million pounds of GHGs- a 3 to 15 times larger carbon footprint than Hydraulic Displacement or Focused ERH. o Full Scale Thermal Remediation would likely trigger both state and federal reporting requirements, is inconsistent with EPA and California green remediation initiatives, and would not advance the goals outlined in the California Global Warming Act of 2006. • Steam Injection is an Energy Intensive Technology: The amount of energy required to treat even the focused treatment area with Steam Injection would be large. The resulting carbon footprint may be up to 3 times the footprint of Focused ERH, or almost 10 times the footprint of Hydraulic Displacement. • Hydraulic Displacement Has the Lowest Carbon Footprint of All Effective Remedies: Hydraulic Displacement will produce only 4 to 11 million pounds of GHGs, and will comply with EPA and California green remediation initiatives.
“With the recognition of a global warming trend and significant estimated carbon dioxide (CO2) emissions at federal Superfund sites (USEPA/OSWER, April 2008), the United States Environmental Protection Agency (USEPA), numerous state environmental regulatory agencies, and a variety of organizations are developing policies, practices, and evaluation methods aimed at reducing the environmental footprint of cleanup sites.” California DTSC Interim Advisory for Green Remediation. 6 340 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 253 of 381 Page ID #:13801
Environmental Risks of Full Scale Thermal Remediation
GHG emissions from Full Scale Thermal Remediation at the Site would be greater than the GHG 7 emissions reported at 40% o341f California’s power plants Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 254 of 381 Page ID #:13802
Safety Risks of Steam Injection
Steam Injection Poses Severe Risks to the Surrounding Community: • Risk of Lateral and Vertical Migration: Significant risk of vertical • Steam Injection May Cause Pollutants to Migrate to Previously Uncontaminated Areas: Steam Injection increases DNAPL saturation. Because the mobility of DNAPL is highly dependent on its saturation levels, an increase in DNAPL saturation makes the DNAPL more prone to lateral and vertical migration. Additionally, Steam Injection desaturates capillary barriers in soils, thus reducing their ability to support DNAPL pools and prevent downward migration. o The risks of lateral and vertical migration are very real: ° Lateral migration of DNAPL occurred at Route 44 Taunton Site and up to 8 feet of DNAPL was found in downgradient extraction wells after thermal treatment. ° Downward mobilization through a desaturated capillary barrier was observed during bench-scale testing of Montrose DNAPL. Steam Release at Cape Fear Site, Fayetteville, NC ° Hot floors do not amply prevent migration- they have been utilized at only 7 sites and failed almost 30% of the time. Additionally, the wells required for hot floors create vertical conduits that increase the chance of DNAPL migration. o The complex lithology of the Site increases the chance of vertical migration: ° In rejecting Steam Injection at the neighboring Del Amo site, the FS states “the low permeability and heterogeneous character of soils at the former plant site would interfere with the uniform transmission of the steam through the subsurface” and thus “the source areas at this site are generally not well suited for application of this technology . . .” If uncontrolled steam distribution occurs near the northern Site boundary, DNAPL may migrate under buildings on the GLJ Holdings Property that are constructed on the lot line. Thermal Remedy Well Failure at Visalia Pole Yard Site, Visalia, CA • Steam Injection May Cause Explosion and Fugitive Emissions o Catastrophic failure and fugitive emissions have occurred at similar sites: ° For example, catastrophic failure occurred at the Visalia site and fugitive emissions occurred at the Cape Fear site. At this Site, contaminated vapors may escape through more than 200 borings and wells at the Site that are unable to withstand the elevated temperatures of Steam Injection. ° EPA rejected Steam Injection at the Del Amo Site across the street because “heating of the ground could cause uncontrolled vapor migration and explosions if not properly designated, constructed, and operated.”
8 342 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 255 of 381 Page ID #:13803
Safety Risks of ERH and Hydraulic Displacement
Focused ERH Poses Significantly Less Risk to the Surrounding Community:
• ERH Carries Some Risk of Migration: The potential for mobilization during ERH treatment is a concern; heated vapors must be effectively recovered in order to prevent migration. The layered and heterogeneous nature of the saturated UBA may reduce the effectiveness of recovering MCB that is volatized by ERH in a full-scale remedy. Additionally, the drilling of numerous ERH wells creates conduits for migration. o However, the risk of migration is less problematic for ERH than Steam Injection, and significantly less for focused EHR. ERH does not hydraulically displace DNAPL and does not rely on mobilization of the DNAPL for recovery, so there is a reduced risk of uncontrolled contaminant migration as compared with Steam Injection. Further, a “bottom up” heating approach may be used to reduce the potential for downward migration. • ERH Carries Some Risk of Fugitive Emissions and Explosion, But Focused ERH Can Better Control Those Risks: With all thermal remediation projects, there is an increased potential for accidental release of heated vapors or contaminated steam. However, the high density of ERH wells (relative to steam injection) reduces the risk of vapor migration. Additionally, the risks under focused ERH are less than for Steam Injection due to lower operating pressures and a more gradual heating process.
9 343 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 256 of 381 Page ID #:13804
Remedial Action Objectives
Remedial Action Objectives (“RAOs”) for the Site:
1) Prevent human exposure to DNAPL constituents (via ingestion, inhalation, or dermal contact) that would pose Remedial Action Objectives identify an unacceptable health risk to on- or off-property remediation goals that “establish receptors under industrial land uses of the Montrose plant acceptable exposure levels that are property and adjacent properties; protective of human health and the 2) To the extent practicable, limit uncontrolled lateral and environment.” 40 C.F.R. 430 vertical migration of mobile NAPL under industrial land use and hydraulic conditions in groundwater;
3) Increase the probability of achieving and maintaining containment of dissolved-phase contamination to the extent practicable, as required by the existing groundwater ROD, for the time period that such “to the extent practicable means the containment remains necessary; remedy that provides “the best 4) Reduce mobile NAPL mass to the extent practicable; balance of trade-offs” among the NCP Criteria. It does not mean to the 5) To the extent practicable, reduce the potential for maximum extent possible. EPA, A Guide recontamination of aquifers that have been restored by to Preparing Superfund Proposed Plans, Records of the groundwater remedial actions, as required by the Decision, and Other Remedy Selection Decision groundwater ROD, in the event containment should fail; Documents at 6-51, OSWER 9200.1-23P (July 1999) and
6) To the extent practicable, reduce the dissolved-phase concentrations within the containment zone over time.
10 344 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 257 of 381 Page ID #:13805
Compliance with RAOs
Remedial Action Objectives Hydraulic Displacement Remedy Steam Injection/ Full Scale Thermal 1. Prevent human exposure to Hydraulic Containment is Effective at Preventing Human Steam Injection is Not Effective at Preventing Human Exposure: DNAPL. Exposure to DNAPL: Limited risk for migration, explosion, or Due to the high risk of fugitive emissions, migration, and explosion, fugitive emissions; effective at removing DNAPL mass. thermal creates a significant risk to nearby neighbors. 2. To the extent practicable, limit Hydraulic Displacement Limits Lateral and Vertical Steam Injection May Increase Risk of Lateral and Vertical uncontrolled lateral and vertical Migration of DNAPL: Removes enough DNAPL that it is Migration: Steam Injection saturates and mobilizes DNAPL and migration of mobile NAPL. unlikely a large enough pool would accumulate to create the weakens capillary barriers that would otherwise prevent migration; 2-D pressure required for vertical migration. Additionally, Hydraulic studies confirm. Displacement desaturates DNAPL, therefore reducing the mobility of any remaining DNAPL so that it is unlikely to pose a significant threat. 3. Increase the probability of Hydraulic Displacement Increases the Probability of Full Scale Thermal Presents No Benefits for Containment: & achieving and maintaining Achieving and Maintaining Containment and Reducing the Thermal remediation removes less mobile DNAPL than Hydraulic 5. containment to the extent Potential for Recontamination: The removal of mobile Displacement and does not have a pumping system to act as a practicable; To the extent DNAPL will eliminate much of the continuing source of secondary containment system. practicable, reduce the potential groundwater contamination and Hydraulic Displacement for recontamination of aquifers. pumping will act as a secondary containment system. 4. Reduce mobile NAPL mass to the Hydraulic Displacement is Effective at Removing Mobile Steam/Full Scale are Potentially Effective at Removing Mobile extent practicable. DNAPL Mass to the Extent Practicable: Removes the DNAPL Mass: Steam Injection and Full Scale may potentially majority (80%) of all mobile DNAPL mass (more mobile remove approximately 64% of mobile and residual MCB mass. DNAPL mass than thermal remediation) -- which is the principle However: DNAPL threat, and also removes a large quantity of DDT mass. - The highly layered and heterogeneous nature of the UBA - DNAPL in low permeability layers of UBA will (same lithology as the Del Amo Site) presents challenges for not be remediated by Hydraulic Displacement, but controlling steam distribution, heating less permeable layers, such DNAPL has a low risk of migration. and recovering heated MCB vapors, which may result in decreased effectiveness and spreading of contamination The Effectiveness of Hydraulic Displacement is Certain: during steam treatment. Hydraulic Displacement was performed successfully in a 2004/2005 pilot test and at the most similar DNAPL sites in the Effectiveness of Steam/ Full Scale Thermal is Uncertain: DDT and county. the Site lithology are unique, and unlike the successful pilot test for Hydraulic Displacement, thermal remediation has not been proven at the Site. 6. To the extent practicable, reduce Containment Timeframe: Hydraulic Displacement does not Containment Timeframe: No thermal remedy meaningfully the dissolved-phase concentrations meaningfully reduce the timeframe for long-term hydraulic decreases the timeframe for long-term hydraulic containment (between within the containment zone over containment (between 4,300 and 4,900 years). However, 3,100 and 4,900 years). However, technological advances in the future time. technological advances in the future may significantly reduce this may significantly reduce this timeframe. timeframe.
Effective and Compliant Effectiveness Uncertain 11 with RAOs 345 and Not Compliant Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 258 of 381 Page ID #:13806
NCP Factors: Compliance with ARARs and Protection of Health and Environment
Hydraulic Displacement Focused ERH Steam Injection and Full Scale Thermal Remediation
• ARARs: Likely fully • ARARs: May be fully compliant with all ARARs. compliant with all ARARs. • Human Health and the Environment: o In order to be eligible for selection, a remedy • Human Health and the Environment: By must achieve overall protection of human health and removing the majority the environment. Numerous legislative and of the DNAPL mass, administrative actions by the federal, State, and local focused ERH controls governments have recognized that GHG emissions migration of present a significant risk to human health and the contaminants, removes environment. Due to the significant GHG emissions • ARARs: Reinjection of treated the source of VOCs, from thermal remediation, it is not protective of human groundwater is compliant; reinjection of and limits the chance of health and the environment. human exposure, thus untreated water is conditionally compliant o The high risks for upset conditions, fugitive protecting human health with ARARs. emissions, and contaminant migration also decrease the and the environment. protectiveness of a Steam Injection remedy. o A waiver of in-situ groundwater While there are some standards is appropriate. Reinjection mobilization risks and of treated groundwater that does not upset risks associated meet MCLs would occur fully within with ERH that make the the TI Waiver Zone, will not remedy less protective adversely affect water quality, will not than Hydraulic violate anti-degradation policies Displacement, those which apply only to “high quality risks are far lower than waters”, and would not violate the risks associated with environmental regulations: a waiver Full Scale Thermal was previously approved for the Remediation or Steam 2004/2005 pilot tests. Injection. • Human Health and the Environment: By preventing human exposure to DNAPL, limiting migration of DNAPL, and removing significant DNAPL mass without any large risk to the environment or the community, Hydraulic Displacement meets all ARARs and RAOs and is, overall, protective of human health and the environment.
12 346 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 259 of 381 Page ID #:13807
NCP Factors: Cost
Hydraulic Displacement Remedy Focused ERH Full Scale Thermal Remedy and Steam Injection
• Cost is half to six times less expensive • While the cost of ERH • A Full Scale Thermal Remedy would be the largest than the cost of thermal remedies. may be double the cost of privately funded thermal remediation project ever Hydraulic Displacement implemented in the United States and the financial • Lowest cost per pound of contaminants due to energy and burden to Montrose is prohibitive. removed. equipment costs, the costs High costs of Full Scale Thermal Remediation and Steam of ERH are reasonable and • Injection derive from expensive equipment, soil vapor and are half to four times less groundwater extraction, high energy demand, waste expensive than Full Scale disposal, and a necessary hot floor. Cost-Effectiveness: means “costs Thermal Remediation. proportional to its overall effectiveness.” • High cost is grossly disproportionate to the limited benefits gained by Full Scale Thermal Remediation: o The additional amount of MCB removal by Full Scale EPA Policy declares that cost is a critical factor in Thermal Remediation will not provide environmental remedy selection. EPA, The Role of Cost in the Superfund benefits that are ten times greater than HD; the Remedy Selection Process (September 1986). benefits are at best, marginal.
Failure to consider cost-effectiveness could be “arbitrary and capricious.” US v. Hardage, 982 F.2d 1436 (10th Cir. 1992); Ohio v. EPA, 997 F.2d 1520 (D.C. Cir. 1993).
13 347 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 260 of 381 Page ID #:13808 NCP Factors: Implementability Hydraulic Displacement Remedy Focused ERH Steam Injection/ Full Scale Thermal • Equipment/Maintenance: • Equipment/Maintenance: • Equipment/Maintenance: o Hydraulic Displacement requires the least o A significant amount of o Steam Injection and Full Scale Thermal maintenance of all effective remedies. complex above and below Remedies require intricate and sizeable o No specialized equipment is required. ground infrastructure infrastructure to heat the entire subsurface Extraction wells can be installed using standard would be required to to depths of more than 100 feet, recover drilling methods and equipment, and ordinary generate and deliver contaminants and water, and treat water. techniques can be used to separate DNAPL electricity. o Steam Injection and Full Scale Thermal from groundwater. Remedies require considerable o ERH requires skilled maintenance, highly skilled field o Remedy has been successfully pilot-tested at the operators and high level of operators, and specialized technology Site. maintenance. vendors. • Technical Issues: Injection well fouling is a common o Unlike Steam Injection, o Steam Injection would require problem and could increase difficulty of implementation. three qualified vendors are incorporation of a hot floor, which A routine well development program would be required to available and ERH is more requires sophisticated drilling methods, abate the effects. frequently implemented and considerable maintenance. than Steam Injection. o A lack of adequate commercial Steam • Potential for Implementability Challenges: Treating Additionally, ERH would Injection vendors may limit the water to ISGS prior to reinjection would require more not require use of steam implementability of Steam Injection. highly skilled operators, a higher level of maintenance, boilers or general boiler and more infrastructure. However, consistent with TI emissions and brine waste. • Technical Issues: Reinjection of groundwater Waiver policies, injection limits in the ROD do not apply would cool the subsurface, reducing the ability for injection of treated water that does not meet MCLs, so to implement Steam Injection. treatment is unlikely to be required: Size and Complexity: o Temporary and limited reinjection of untreated • water into the already heavily contained TI o A Full Scale Thermal Remedy would Waiver Zone will not negatively affect likely be the largest remedy of this kind. groundwater or pose health risks. There are no comparable sites of this size. o The extraction and injection pumping under HD o Due to the highly layered nature of the will act to contain the injected groundwater saturated aquitard and the uniqueness of within the TI Waiver Zone, therefore creating Montrose DNAPL, a Full Scale Thermal “double containment” when combined with the Remedy would be the most complex groundwater treatment system. thermal remedy ever conducted. For the same reasons, thermal remedies were o This has been approved at other large DNAPL rejected at the neighboring Del Amo site. sites and a waiver was granted for 2004/2005 testing at the Site without an adverse impact on groundwater. o Reinjection of untreated water will still achieve RAOs.
14 348 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 261 of 381 Page ID #:13809
NCP Factors: Comparative Analysis
NCP Criterion Hydraulic Hydraulic ERH Focused Steam Focused Full Scale ERH Full Scale Steam Displacement No Displacement Treatment Treatment
Protective of Human Yes Yes Yes Yes Questionable Questionable Health & Environment
ARAR Compliance Yes (Conditional) Yes Yes Yes Yes Yes
Theoretically Theoretically Theoretically Theoretically effective, but effective, but effective, but effective, but Effectiveness Effective Effective untested at unique untested with unique untested at unique untested at unique Site/DNAPL Site/DNAPL Site/DNAPL Site/DNAPL
Hydraulic Containment 4700-5400 4700-5400 4300-4900 4300-4900 3100-4900 3100-4900 Timeframe (years)*
Vadose Zone Volume Reduction (1,000 gallons of 27-30 27-30 27-30 27-30 27-30 27-30 MBC)
Saturated Zone Volume 9-13 MCB 9-13 MCB 15-25 MCB 15-25 MCB 26-29 MCB 26-29 MCB Reduction (1,000 gallons of 9-13 DDT 9-13 DDT limited DDT limited DDT limited DDT limited DDT mobile DNAPL)
Highly Moderately Moderately Moderately Difficult to Difficult to Implementability Implementable Implementable Implementable Implementable Implement Implement
Cost ($million NPV) $13.2 $21.4 $21.2-$26.1 $25.2-$33.6 $53.7-$70.6 $57.6-$85.3
Public Acceptance Likely Likely Potentially Unlikely Unlikely Unlikely
GHG Emissions (million 11 26 33-61 51-106 143-227 189-412 lbs)3
Safety & Environmental Limited Limited Moderate High High Very High Risks
*Hydraulic containment involves pumping groundwater to contain and isolate the dissolved phase contamination surrounding the DNAPL at the Site so that it cannot escape the containment zone, thus assuring that the contamination will not move downward or sideways in response to hydraulic extraction of contaminated groundwater. The hydraulic containment timeframe is the number of years that containment will be required so as to prevent recontamination of the clean groundwater after treatment and reinjection. 15 349 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 262 of 381 Page ID #:13810
Comparative Analysis: Drawbacks of Full Scale Compared to Focused Treatment
Significant Risks For Minimal Increased Effectiveness
• A thermal remedy of the Full Scale size and complexity is Because the treatment area for Full Scale is six • unprecedented and untested. times larger than Focused Remedies, the potential for uncontrolled migration of DNAPL is increased. • Only approximately 13- 40% of the total DNAPL mass occurs outside the focused treatment area. • The large size of Full Scale Remediation makes it more difficult to implement than a Focused • Full Scale Remediation does not remove more mobile Remedy and increases the cost by almost a four- DNAPL (the principal threat) than Focused Thermal fold (cost prohibitive). Remedies.
• Because a larger area is heated, more energy is • Long-term hydraulic containment time would not be required and Full Scale Remediation produces 77% meaningfully reduced: containment would still be more GHG emissions than Focused Thermal required for between 3,100 and 4,900 years. Remediation. • The ability of a Full Scale Remedy to reduce the potential • Due to the increased capacity of a Full Scale for recontamination of the aquifers is identical to that of Thermal Remedy, the risk for catastrophic failure, remedies that involve only the focused treatment area. fugitive emissions, explosions, and soil weakening is higher for Full Scale Remedies than Focused Remedies.
DNAPL recovered from UBE-5 at the Site
16 350 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 263 of 381 Page ID #:13811 Conclusion: Hydraulic Displacement and Focused ERH Provide a Reasonable Balance of Nine NCP Factors
Hydraulic Displacement Thermal: Focused ERH Thermal: Steam Injection
Hydraulic Displacement removes 80% of all Focused ERH treatment provides a better balance of Steam Injection has the potential to remove the mobile DNAPL at the Site (the principal threat), the NCP factors than Steam Injection and removes most DNAPL mass more than any other remedy, and removes total the majority of DNAPL mass DNAPL mass to the extent practicable. However: Because: And: - ERH does not rely on soil permeability for heat - Effectiveness is highly uncertain given the Effectiveness of the remedy is certain. distribution and is not a displacement technology, complexities of the Site lithology and the Hydraulic Displacement was successfully pilot- thus lowering the risk of DNAPL migration. unique nature of Montrose DNAPL; the actual tested at the Site. Further, ERH may utilize a bottoms-up approach, amount of mass that thermal remedies can thus reducing the need for an expensive, hard to remove has not been verified. implement hot floor. ERH is also easier to - Hydraulic Displacement is the least complex implement than steam because it requires no steam remedy, and standard equipment, personnel, boilers/boiler emissions, or brine waste disposal. - The primary benefit of removing DNAPL and drilling practices can be utilized. Similarly, However: mass is to reduce the duration required for it is the most cost-effective remedy evaluated. hydraulic containment of contaminated - Effectiveness of the remedy is uncertain and has groundwater. However, Steam Injection cannot never been tested or implemented at a similar site; - Because Hydraulic Displacement does not meaningfully reduce the duration of the the high boiling point of this DNAPL approaches the involve heating the soils and creating vapors, containment system operation. upper limit for effectiveness of ERH and the boiling the risk for fugitive emissions, catastrophic of groundwater can desaturate soils and reduce the failure, and soil weakening are eliminated. By transmission of electrical current. Non-uniform not heating the soils, Hydraulic Displacement - The increased mass efficiency is costly: Full heating may also occur, and vapor recovery may be uses less energy and produces the lowest levels Scale Steam Injection may cost ten times as an issue at the Site. of GHGs, complying with EPA and California much as other effective remedies. green remediation initiatives. - The remedy is moderately implementable but more difficult to implement than Hydraulic Displacement, - The remedy may harm human health and the - Hydraulic Displacement will not threaten requiring a large number of electrodes and environment more than it benefits them: Full human health or the environment: The considerable energy. Due to high energy, CO2 Scale Steam Injection would require 5600 acres procedure for implementing Hydraulic output may be relatively high. Displacement and the removal of the majority of trees to offset its CO2 emissions and has a of mobile DNAPL mass ensure that migration serious risk of DNAPL migration, fugitive of DNAPL at the Site will be nearly impossible. - There is still some risk for uncontrolled migration, emissions, and explosion. soil weakening, and release of heated vapors
Conclusion: Hydraulic Displacement provides Conclusion: Focused ERH is a reasonable remedy Conclusion: The minimal, unconfirmed the best balance of the NCP factors, meets all that removes the majority of DNAPL, but it does not benefits of Steam Injection are far outweighed RAOs, removes mobile DNAPL mass to the provide the best balance among the NCP factors and by the costs, effectiveness uncertainties, and extent practicable, and is fully protective of 17 still includes considerable effectiveness351 uncertainties risks to human health and the environment. human health and the environment. and some risks to human health and the environment. Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 264 of 381 Page ID #:13812
February 13, 2015
Comments from Sierra Club on DNAPL (Dense Non-Aqueous Phase Liquid) cleanup from the Montrose DDT Superfund site in Los Angeles near Torrance:
The determination of a Technical Impracticability (TI) Waiver Zone needs to be revisited. Leaving large quantities of DDT and chlorobenzene underground puts groundwater resources forever at risk of contamination. If the DDT were a valuable resource like gold, it would already have been dug up. Water in California is a precious resource that should not be put at risk. The public should be offered the alternative of responsible parties removing the contamination and relocating it where it will not put ground water and human health at risk while being treated.
There are two important objectives for the DNAPL (Dense Non-Aqueous Phase Liquid) cleanup from Montrose DDT facility in Los Angeles near Torrance. The first objective is safeguarding groundwater from contamination, especially groundwater used for drinking water. The second objective is safeguarding the health of people living and working in the area.
The so-called "lower cost" alternatives, especially Alternative 1, No Action, are only lower cost if water quality and human health are assigned no value. In reality, water is precious in California, and human health is precious everywhere. The less stringent cleanup methods, by allowing continuing and expanding contamination of groundwater, would only be postponing and making more expensive the groundwater cleanup that would eventually be necessary.
Alternative 6A, Electrical Resistance Heating for a Focused Treatment Area, is stated to be most effective in protecting groundwater from contamination, but it is not clear why Alternative 6B, Electrical Resistance Heating for the Entire Treatment Area, would be less effective. Alternative 6B would seem to do more cleanup, and if so, should be preferred.
In either case, treatment to reduce the concentration of pCBSA (p-chlorobenzenesulfonic acid) in re-injected groundwater needs to be adequate to protect groundwater from contamination, in order to protect public health. If it is necessary to promptly start operation of the DNAPL cleanup system to protect groundwater from contamination by chlorobenzene, a larger, more effective treatment process to remove/degrade pCBSA (p- chlorobenzenesulfonic acid) needs to be constructed and put into operation as soon as possible.
352 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 265 of 381 Page ID #:13813 To safeguard the health of people living and working in the area, there needs to be sampling and analysis of air beneath and in homes in the area to establish a baseline before DNAPL cleanup treatment begins, with frequent repeat sampling and analysis of air while treatment is occurring. If air beneath and in the homes has a significantly increased concentration of volatile contaminants after DNAPL cleanup treatment has begun, the DNAPL cleanup treatment process must stop to allow troubleshooting or the residents must be relocated.
To address the issue of remaining DDT and chlorobenzene within the Technical Impracticability (TI) Waiver Zone, the EPA should solicit proposals and make grants for further treatment methods. In particular, consideration should be given to biological forms of treatment, although of course this could introduce its own set of problems, which should be carefully investigated before implementation. There reportedly is some biological degradation of DDT in sediments on the Palos Verdes Shelf, showing that microbes can degrade this material.
Sincerely,
/s Alfred Sattler Chair Palos Verdes-South Bay Regional Group Sierra Club
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The Proposed Plan for Montrose Superfund Site hinges on the removal of mobile DNAPL within the focused treatment area (~26,000 square feet) in the Upper Bellflower Aquiclude (UBA). The Proposed Plan states the fundamental assumption on page 7 under Summary and Risk and Basis for Action that “Removing mobile DNAPL, therefore, is a critical component in preserving the groundwater resource and ensuring protection of human health and the environment. Residual DNAPL is trapped in pore spaces between soil particles and cannot migrate in the subsurface under natural conditions. Therefore, only mobile DNAPL is considered to be a principle threat.” Subsequently, it points out the preferred remedial alternative discussed in this Proposed Plan is focused on preventing uncontrolled migration and spreading of mobile DNAPL to ensure (1) protection of human health and the environment, and (2) the success of groundwater remedy at the Montrose Superfund Site.
Basically, the Proposed Plan assumes the majority of mobile DNAPL only exists at UBA within the small area at central processing area and neglects mobile DNAPL that may have migrated vertically into deeper B-Sand, C-Sand and Gage aquifers, and horizontally to a larger area outside the focused treatment area due to historical releases. The proposed plan also ignores the dissolved phase plume originating from residual DNAPL (acting as continuous contamination source). They anticipate the groundwater remedy for OU-3 Dual Site Groundwater is designed to contain and remediate the dissolved plume coming from the DNAPL source.
The following section briefly describes the main goal for the Proposed Plan mentioned above in (1) and (2).
1. Protection of Human Health and the Environment In our opinion, the protection of human health by preventing either soil vapor emissions to surface inhabitants (VI potential) or direct contact with contaminated soils will be manageable and less an issue, especially since the site is unoccupied. The potential remains for vapor intrusion to be an issue of concern in the downgradient residential area. Currently, the USEPA Remedial Project Manager (RPM: Kevin Mayer) is dealing with this issue as required. Therefore, the evaluation for human health risk protection appears to be moving towards a reasonable resolution.
However, the protection of groundwater and drinking water resources remains. A few outstanding issues that should be resolved include:
A. How to ensure DNAPL mass won’t continuously spread outside TI waiver zone? B. No continuous vertical migration to deeper aquifers, especially to Gage and Lynwood zones. C. Whose responsibility it is to maintain the hydraulic containment extraction wells to capture outgoing plume (Proposed Plan or Groundwater Remedy), and where they are located? D. The groundwater remedy is expected to shut down in 50-years, and the hydraulic containment system is expected to operate for thousands of years. Discontinuation of
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the groundwater remedy is contingent upon the hydraulic containment extraction wells stopping plume migration and capturing the plume from the DNAPL source before it migrates to downgradient areas. The interconnectivity between the DNAPL removal and containment wells, and the containment wells and the groundwater remedy must be clearly specified. Additionally, performance metrics must be established upfront with a contingency plan in place in case of failure. E. Monitoring and Contingency Plan (MACP) for mobile DNAPL depletion and MACP for dual-site groundwater remedy should be integrated as a holistic MACP for the entire groundwater medium, instead of each MACP acts independently without linking to each other. F. How to ensure the Proposed Plan can remove mobile DNAPL at the source area and how to effectively measure the system performance and effectiveness? Will the hydraulic containment wells design to be part of DNAPL removal or groundwater remedy? G. If the Proposed Plan does not meet the designated objective (i.e. leaking DNAPL mass detected), then what is the corrective action or mitigation measures to be implemented? H. Will the dissolved plume emanating from the DNAPL source be contained and remediated by OU-3 Dual Site groundwater remedy?
2. Success of Groundwater Remedy at the Montrose Superfund Site: Success of groundwater remedy depends on the successful resolution of outstanding issues outlined above. In particular, how to meaningfully shorten the estimated 5,000 years of operation for the hydraulic containment wells is critical because it remains unreasonably long. Funding source and complete operation costs are unclear and ill-defined. There is an undeniable link between the groundwater remedy, hydraulic containment and DNAPL removal. Currently, the Proposed Plan is dependent on 5,000 years of hydraulic containment to contain the DNAPL mass within the TI zone without operating the groundwater remedy (which will be shut down after 50 years of operation if the Chlorinated Volatile Organic Constituent (CVOC) concentrations in groundwater reach Maximum Contaminant Levels (MCLs) in groundwater in the area surrounding the containment zone. A virtually impossible task if the dissolved phase CVOCs are not contained within the containment zone.
DNAPL removal is scheduled to take 4 to 7 years. Clearly monitoring should extend beyond the DNAPL removal period and it may take decades to understand whether the DNAPL removal was successful and did not push DNAPL deeper and wider that it currently exists. It seems highly unlikely the groundwater remedy will be completed in proposed 50-year duration.
In order to document conditions during and after the DNAPL removal; the performance of DNAPL removal should be extensively monitored at all concerned aquifers (UBA, B-Sand, C-Sand, Gage and Lynwood) to monitor changes in concentration and to ensure there is no significant amount of DNAPL mass capable to dissolve into groundwater and migrate away from containment zone. The DNAPL mass includes mobile (under gravity) and residual DNAPL mass together. The only way to quantify the mass is through the groundwater sampling results in the dissolved form. The MACP for DNAPL removal in the Proposed Plan must be able to indicate the
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system performance of DNAPL removal and its effectiveness based on dissolved phase concentration changes. Unless proven otherwise; the Proposed Plan should be revised to include additional remediation measures to augment the remedy by not allowing both DNAPL and dissolved mass discharge downward or downgradient. Otherwise, the groundwater remedy will be required to operate until it cleans up the groundwater at concentration less than MCL.
Therefore, the success of groundwater remedy depends on satisfying the above conditions. If these conditions are not met, the Proposed Plan should be considered incomplete.
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Technical Assistance Services for Communities Contract Number: EP-W-13-015 TASC WA Number: 1 OSRTI-Multi-Regions & HQ Technical Directive Number: R9 TD #8 Del Amo-Montrose
September 2014 Review of the technical document “EPA Request for Comments on Proposed DNAPL Cleanup Plan” Montrose Superfund Site, Los Angeles, CA
1.0 Introduction In September 2014 the United States Environmental Protection Agency (EPA) published the technical document “EPA Requests Comments on Proposed DNAPL Cleanup Plan” (DNAPL Proposed Plan). The DNAPL Proposed Plan describes EPA’s preferred remediation alternative among the several considered in the September 27, 2013 Dense Non-Aqueous Phase Liquid (DNAPL) Feasibility Study (FS) prepared for the Montrose Chemical Corporation of California (Montrose) by EPA’s environmental consultant, AECOM. These alternatives are also described again in the DNAPL Proposed Plan.
This review and comment document provides a brief summary of site history and environmental conditions, a description of the remedial alternative considerations and stakeholder comment process associated with the FS development, and comments on the EPA DNAPL Proposed Plan.
This review and comment document is provided by EPA’s Technical Assistance Services for Communities (TASC) program, which is implemented by independent technical and environmental consultants. Its contents do not necessarily reflect the policies, actions or positions of EPA. This report is provided to the Del Amo Action Committee (DAAC) and other members of the community neighboring the Montrose site.
2.0 Purpose of the Proposed DNAPL Cleanup Plan Environmental response activities have been under way at the Montrose facility since the discovery of process-related contamination in the early 1980s. EPA proposed the Site for the Superfund National Priorities List (NPL) in 1984, and the listing was finalized in 1989.
The DNAPL at Montrose has been designated its own “Operable Unit” by EPA, and is managed essentially as a project unto itself. Other aspects of Montrose contamination, including soil and groundwater, have been designated by EPA as separate Operable Units. In September 2013, EPA released the FS for the Montrose site, which identifies and evaluates potentially viable alternatives for the remediation of the DNAPL portion of site-related contamination. The DNAPL Proposed Plan selects a preferred cleanup for public comment before finalizing a Record of Decision (ROD) establishing the remedy for the Operable Unit.
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3.0 Site and Environmental Summary The 13-acre Montrose site is located at 20201 South Normandie Avenue in unincorporated Los Angeles County, just south of the Los Angeles County line near the town of Torrance. The Montrose site is neighbored to the east by the Del Amo Superfund Site. A residential community occupies the land immediately southeast of the Montrose site.
Montrose began operations at the property in 1947, and until termination of operations in 1982 produced large quantities of the chemical DDT (dichlorodiphenyltrichloroethane) for off-site transportation and sale. DDT was detected in soil and groundwater beneath the former industrial operation at about the time plant operations were discontinued.
Contamination beneath the Montrose site consists primarily of DDT production-related raw material and wastes detected in soil, soil vapor and groundwater. DNAPL contamination is the subject of the FS and DNAPL Proposed Plan. As noted above, DNAPL is an abbreviation for Dense Non-Aqueous Phase Liquid, which in simpler terms means a liquid that is not water that sinks when mixed in water or sediments that are saturated with water. The DNAPL beneath the Montrose site was shown by laboratory testing to consist of approximately 50 percent monochlorobenzene (MCB) by weight and 50 percent DDT. The FS indicates that the DNAPL is present in the unsaturated sediments above the water table aquifer that is first encountered at about 60 feet below the ground surface and to depths of at least 105 feet below grade (in water- saturated sediments).
4.0 The Technical Impracticability Zone A fundamental element of the Montrose DNAPL remedy selection process is the Technical Impracticability Zone (TI Zone). Sometimes also referred to as a “containment zone,” the TI Zone was established at the Montrose site in the 1999 EPA Record of Decision (ROD) for the Joint Groundwater Feasibility Study (JGWFS), which was conducted in conjunction with the nearby Del Amo Superfund site.
The TI Zone was proposed by the authors of the JGWFS as an administrative tool for the management of NAPL (DNAPL at Montrose and LNAPL, or light non-aqueous phase liquid, at Del Amo), as its complete removal at the time was said to be “impracticable.” In establishing the TI Zone at the Montrose and Del Amo sites, EPA relied upon its 1993 technical document entitled “Guidance for Evaluating Technical Impracticability of Groundwater Restoration (U.S. EPA OSWER Directive 9234.2-25). The 1993 guidance relies on studies and data produced in the years prior to 1993.
EPA described the rationale for the TI Zone in the 1999 ROD, stating:
“EPA has recognized that much of the groundwater at the Joint Site can be restored ... In order to do so, a zone of dissolved phase contamination in groundwater surrounding the NAPL must be contained, thereby isolating the NAPL.”
The rationale was further described in ROD Section 10.2 (Summary of Why NAPL Areas Cannot Be Restored to Drinking Water Standards):
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“… it will not be practicable to remove enough (virtually all) DNAPL so as to attain drinking water standards in the immediate vicinity of the DNAPL.”
In ROD Section 10.4 (Extent and Configuration of the TI Waiver Zone), EPA describes proposals by parties to extend the boundaries of the TI Zone (TI Zone and “TI Waiver” are used interchangeably in the technical documents) to encompass the entire dissolved contaminant plume. EPA rejected these proposals, stating in the ROD that this “clearly would have been an inappropriate use of a TI waiver because, regardless of any relative difficulties or risks which might exist in attempting to restore groundwater in the downgradient portions of the plume, it is technically practicable to do so and to do so without compromising the objectives of the remedial action.”
Finally, with respect to the remedial alternatives evaluated by the FS, the FS states:
“The lateral extent of the TI Waiver Zone was selected to be as small as possible without causing adverse migration due to containment pumping (EPA, 1999). Since the groundwater ROD requires a containment zone downgradient of the DNAPL-impacted area to contain MCB- impacted groundwater, the TI Waiver zone must be sufficiently large to ensure that DNAPL would not be mobilized by containment pumping. Thus, the TI Waiver zone is larger than the known extent of the DNAPL (Figure 1.21).”
5.0 Remedial Action Objectives (RAO) The objectives for the remedy proposed in the DNAPL Proposed Plan are the basis and framework for the remedy selection process. In the case of Montrose, EPA makes assumptions with respect to the ability to actually restore the local environment to its pre-Montrose condition, and these assumptions frame a decision-making process that results in a recommendation to remove only a portion of the DNAPL mass that is present in the subsurface.
As described in the FS:
“… the generalized objectives for remediation within the DNAPL-impacted zone are to remove mobile DNAPL mass to the extent practicable, to reduce the mobility of mobile DNAPL in the subsurface, and to decrease the uncertainty associated with the groundwater remedy and containment requirements. As a result, RAOs for DNAPL are more appropriately specified in terms of contaminant mobility and mass reduction than they would be in terms of contaminant concentrations. Accordingly, the RAOs for DNAPL at the Site are as follows:
1. Prevent human exposure to DNAPL constituents (via ingestion, inhalation, or dermal contact) that would pose an unacceptable health risk to on- or off-property receptors under industrial land uses of the Montrose plant property and adjacent properties; 2. To the extent practicable, limit uncontrolled lateral and vertical migration of mobile NAPL under industrial land use and hydraulic conditions in groundwater; 3. Increase the probability of achieving and maintaining containment of dissolved-phase contamination to the extent practicable, as required by the existing groundwater ROD, for the time period that such containment remains necessary; 4. Reduce mobile NAPL mass to the extent practicable;
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5. To the extent practicable, reduce the potential for recontamination of aquifers that have been restored by the groundwater remedial actions, as required by the groundwater ROD, in the event containment should fail; and 6. To the extent practicable, reduce the dissolved-phase concentrations within the containment zone over time.”
6.0 Proposed Remedy As described in the DNAPL Proposed Plan, after review of the proposed alternatives, EPA selected Electrical Resistance Heating (ERH) over a focused treatment area as the technology best suited to satisfy the project remedial objectives. As described previously and in the following sections – these objectives do not include the removal of all DNAPL from beneath the Montrose site or that fraction that is practicably recoverable. The objectives are restricted to the removal of the “mobile fraction” of DNAPL only. The preferred remedy is presented in the DNAPL Proposed Plan as follows:
Electrical Resistance Heating (ERH) over a focused treatment area would be implemented for vaporizing DNAPL. This would be done by installing electrodes throughout the treatment zone and transmitting an electric current between them to heat the soil by electrical resistance. The ERH process would remove chlorobenzene from the DNAPL by vaporizing it. The vapors generated by this process would then be recovered by SVE wells for above-ground vapor treatment. The DDT component of DNAPL will then precipitate out of DNAPL and will remain immobile and adsorbed to soil particles at depths exceeding 40 to 60 feet bgs [below ground surface]. As discussed above, DDT is not soluble in water and will “stick” to soils deep below the surface and will therefore be immobilized. Therefore, DDT does not pose a risk to groundwater resources and/or human health and the environment. A total of 102 ERH electrodes for heating the subsurface and 66 multiphase extraction wells for removing DNAPL vapors and contaminated groundwater would be required for this alternative. Each location will include multiple electrode segments stacked in a common hole to allow heating at the bottom of the treatment zone, and then gradually heating upper intervals. This “bottom up” heating approach is similar to conditions in the “hot floor” methodology integrated into the steam injection alternatives; creating a heated soil barrier at the bottom of the DNAPL treatment zone to prevent DNAPL from moving into deeper zones. Heated soil vapors would be extracted from the multiphase extraction wells for onsite treatment using a regenerable carbon/resin system. Groundwater extracted from the multiphase extraction wells would be treated by a combination of GAC to remove chlorobenzene and other VOCs, and HiPOx to destroy pCBSA by oxidation. Treated groundwater would be transferred to the treatment system for the Dual Site Groundwater for reinjection. [GAC stands for Granular Activated Carbon and HiPOx is a trade name for a groundwater treatment technology]
7.0 Review and Comment Process for the Draft DNAPL FS The September 2014 DNAPL Proposed Plan presents a remedial recommendation that is the result of the FS publication and review process.
A draft FS was published in December 2011 by AECOM for Montrose. The draft document was circulated to selected stakeholder groups, including the Department of Toxic Substance Control (DTSC) and DAAC. DTSC and DAAC submitted comments to the EPA in August and
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September 2012 respectively. The DTSC submittal included comments from the Water Replenishment District of Southern California as an attachment (WRD). The WRD is the manager of groundwater resources in this area of Southern California. EPA arranged a meeting with DTSC for discussion of comments in October and November 2012. Agreement reached between EPA and DTSC is documented in a March 26, 2013 letter from DTSC to EPA, though the topics discussed and the substance of the agreement is not presented in the letter. There is no mention in the letter of attendance or participation by the WRD.
Pursuant to protocol, EPA also submitted the DRAFT FS to the National Remedy Review Board (NRRB) for review and comment. The purpose of the NRRB is described in their response to EPA as follows:
The Administrator established the Board as one of the October 1995 Superfund Administrative Reforms to help control response costs and promote consistent and cost-effective remedy decisions. The Board furthers these goals by providing a cross-regional, management-level, "real time" review of high cost proposed response actions prior to their being issued for public comment. The Board reviews all proposed cleanup actions that exceed its cost-based review criteria.
The Board review is intended to help control remedy costs and to promote both consistent and cost effective decisions. Consistent with CERCLA and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), in addition to being protective, all remedies are to be cost-effective. The Board considers the nature of the site; risks posed by the site; regional, state, tribal and potentially responsible party (PRP) opinions on proposed actions; the quality and reasonableness of the cost estimates; and any other relevant factors or program guidance in making our advisory recommendations. The overall goal of the review is to ensure sound decision making consistent with current law, regulations, and guidance.
The NRRB provided comments to EPA in February 2013; EPA responded to these comments in March 2013.
Again, as noted above, DAAC submitted comments to EPA in September 2012. A response to these comments was received in April 2014.
8.0 Comments on the EPA DNAPL Proposed Plan and Stakeholder Involvement In association with the information presented in the preceding pages, TASC comments on the EPA September 2014 DNAPL Proposed Plan are provided below. The aspect of the remedy or process presented in the DNAPL Proposed Plan is described for context before each comment.
Remedial Action Objectives (Two Comments) RAO Comment 1 The FS evaluated remedial options within the context of assumptions and parameters deemed relevant by report authors and EPA. One assumption is that the groundwater beneath the Montrose Superfund site is not used for drinking water, and is as such, a less sensitive resource
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than if it were in current production. As stated on Page 3 of the 2014 EPA DNAPL Proposed Plan:
Although the State of California designates all of the water-bearing units beneath the Montrose property as having potential potable beneficial use, there are currently no known municipal or private potable production wells in use within the area of DNAPL distribution and/or dissolved groundwater contamination at the Montrose Superfund Site. The nearest municipal supply wells are located more than 2 miles from the Montrose Property, and about 0.5 to 1 mile southeast from the furthest extent of groundwater contamination related to the Montrose and Del Amo Superfund Sites.
A second assumption is that the complete removal of DNAPL from the subsurface is technically impossible. This assumption, documented in the 1999 Record of Decision for the Dual Site Groundwater Operable Unit, is described in the context of the TI waiver zone on Page 3 of the DNAPL Proposed Plan as follows:
What is a TI Waiver Zone? The groundwater remedy includes long-term hydraulic containment of the DNAPL-contaminated area and a buffer around this area referred to as the “Technical Impracticability (TI) Waiver Zone.” The TI Waiver Zone was established because, as documented in the groundwater ROD, EPA determined that removal of all DNAPL was not practicable, given current technologies. This area will be evaluated for protection again in 2015.
Essentially, the assumptions make a foundation for the conclusion that because it is impossible to remove all DNAPL from the subsurface, it is therefore acceptable to remove only a portion of it (the “mobile fraction”), irrespective the fact that the removal of a significant amount of what is presently planned to be left behind (the DNAPL that exists below saturation concentrations) could also be removed using the same technology as that used in the proposed remedial alternative.
The DNAPL Proposed Plan recommends removing mobile DNAPL, a process that is expected to take between four and seven years and allowing the residual DNAPL to be addressed over time by the network of extraction wells designed to remove contamination dissolved in migrating groundwater. Technical documents prepared for the Dual-Site Groundwater OU indicate that containment pumping will be required for at least 3,000 years.
For members of the public that have not studied the documents in the technical record, the DNAPL Proposed Plan use of the words “long-term” may not accurately convey the actual contemplated duration of the containment portion of the groundwater remedy. For the sake of transparency, it is recommended that EPA state clearly the 3,000-year duration that containment is presently estimated to be required.
RAO Comment 2
The FS restricts the ERH remedial action to the “focused treatment area” because deployment over the entire area of DNAPL occurrence is seen as technically challenging and expensive.
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Regarding the cost of an expanded remedy designed to address the entire area of DNAPL occurrence (Remedial Alternative 6b), the FS states:
Cost. The estimated cost of RA 6b is $46.2 to $69.5 MM ... The estimated cost of this full-scale ERH RA is very high. If implemented, this RA would be the largest and probably the most expensive ERH RA ever implemented in the United States and highly financially burdensome for Montrose. The financial burden to Montrose would be far more significant, if not prohibitive, than the financial burden to the Federal Government or State agencies funding many of the large-scale thermal remediation projects as described in Appendix K. Montrose does not possess the financial resources comparable to those government agencies, and therefore, the very high cost of this full-scale ERH RA must be given serious consideration during remedy evaluation.
Additionally, general and somewhat unsubstantiated statements are made in the technical documents regarding the effect aggressive residual DNAPL removal will have on the overall length of the groundwater containment/remediation remedy. As described in the EPA DNAPL Proposed Plan:
While more aggressive thermal Alternatives 5B and 6B would remove the greatest mobile and residual DNAPL mass, even these alternatives cannot remove all DNAPL and/or sufficient DNAPL mass to meaningfully [emphasis added] reduce the time required for long-term hydraulic containment that will be performed as part of the OU-3 Groundwater remedy. Therefore, treatment of the entire area by thermal alternatives (5B and 6B) offers little advantage over the focused treatment area alternatives (5A and 6A) in terms of the long-term effectiveness and permanence.
The NRRB addresses this issue as well:
The package presented to the Board identified several remedial action objectives (RAOs) that included language "to the extent practicable" for addressing the mobile nonaqueous phase liquid (NAPL). The Board notes that this language does not provide measurable criteria typically used to define when treatment is no longer necessary for either the proposed thermal treatment or SVE remedy components.
In addition, the package presented limited remediation goals, including: 1) reduction in mobility and mass, 2) reduction of NAPL saturation to residual levels in the saturated zone (i.e., goal for the ERH remedy), and 3) achieving asymptotic mass reduction in the unsaturated zone (i.e., goal for the SVE remedy). The package also indicated that a performance verification program would be implemented to assess if remediation goals are met. The Board recommends that the Region more clearly define the RAOs and remediation goal/treatment end points for the proposed remedy in the decision documents.
In their response to the NRRB, the EPA states:
The decision documents will better define the remediation objectives, goals and treatment end points for the proposed remedy, including the goals of reducing NAPL saturation to residual levels for the saturated zone, achieving asymptotic mass reduction in the unsaturated zone
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[emphasis added], temperature goals, and other remedy- and technology specific goals, as appropriate. We are currently evaluating additional performance measures.
The remediation of DNAPL outside the treatment area would require an expansion of the treatment system or a phased deployment of treatment if one sub-area is completed at a time. However, remediation of DNAPL mass inside the treatment area to asymptotic levels (the point at which no DNAPL can be practicable remediated), could conceivably be accomplished with the same equipment and configuration deployed in the proposed alternative. The proposed remedy stops short of achieving asymptotic levels, and instead proposes only to reduce DNAPL to “residual” levels.
In order to be more transparent, EPA should state clearly that the proposed remedy neither addresses DNAPL that could be practicably remediated outside the focused treatment area nor that DNAPL present below residual saturation inside the treatment area. EPA should also be more forthright and transparent with respect to the decision – namely that because it is still believed that even the most aggressive and expensive remedial approach could not possibly remove all the DNAPL from beneath the Montrose site, it is therefore acceptable to leave a large residual fraction behind, even if a potentially significant fraction of this residual DNAPL could actually be remediated.
It is noted and appreciated that EPA uses the word “meaningfully” in an effort to convey this information. However, providing a more thorough treatment of the issue in place of this word would eliminate interpretation of the word “meaningful” differently by different audiences.
Stakeholders (One Comment)
As described earlier in this document, EPA engaged selected stakeholders in the review of the draft FS. The DTSC review and letter of agreement is available on the Department’s online database, Envirostor. There is no record of Regional Water Quality Control Board (RWQCB) tracking or involvement visible on the State Water Resources Control Board database (Geotracker). No comments or responses to comments are posted to the EPA online Superfund Site Overview.
The DNAPL Proposed Plan makes reference to process participation by the California Department of Toxic Substance Control (DTSC). As described above, the WRD submitted comments in concert with the DTSC (as an attachment to DTSC comments). Given the WRD role as the manager of groundwater resources in this basin, and considering the increasing importance of groundwater for potable supply during the California drought, we believe that the follow-on participation by the WRD should be described in the DNAPL Proposed Plan in addition to that of DTSC.
Additionally, as the RWQCB has more direct regulatory oversight with respect to water resources, they should also have the opportunity to comment on the DNAPL Proposed Plan, irrespective the designation of DTSC as the lead California state representation (if this designation was ever formally made). Again, this seems especially important in light of the record low rainfall and increasing reliance on groundwater resources for domestic, industrial and agricultural water supply. The regional perspective of the RWQCB would supplement the local insight of the WRD.
We understand that the RWQCB had historic involvement with aspects of the Dual-Site Groundwater OU and ROD. We expect they have been engaged in some capacity more recently, either in association with the Dual-Site remedy or the DNAPL FS. As with the WRD,
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the engagement could be referenced in the DNAPL Proposed Plan to assure stakeholders that all relevant California agencies have been given an opportunity to participate in this important process.
TASC Contact Information
TASC Technical Advisor Markus B. Niebanck, P.G. 510-693-1241 [email protected]
Skeo Solutions Project Manager Miranda Maupin 434-975-6700, x227 [email protected]
Skeo Solutions Task Order Manager Krissy Russell-Hedstrom 719-256-6701 [email protected]
Skeo Solutions Program Manager Michael Hancox 434-989-9149 [email protected]
Skeo Solutions Director of Finance and Contracts Briana Branham 434-975-6700 ext. 232 [email protected]
Skeo Solutions Quality Control Monitor Eric Marsh 512-505-8151 [email protected]
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Department of Toxic Substances Control
Deborah 0. Raphael, Director Matthew Rodriquez 1001 "I" Street Edmund G. Brown Jr. Secretary for Governor Environmental Protection P.O. Box 806 Sacramento, California 95812-0806
March 26, 2013
Ms. Jane Diamond Director, Superfund Division United States Environmental Protection Agency Region IX 75 Hawthorne Street San Francisco, California 94105-3901
Dear Ms. Diamond:
Thank you for your letter of March 14, 2014, regarding the Montrose Dense Non Aqueous Phase Liquid (DNAPL) Feasibility Study (FS). In your letter you accurately summarized the agreements reached between the Department of Toxic Substances Control (DTSC) and the United States Environmental Protection Agency (U.S. EPA) over the six issues that were raised by DTSC in a letter dated August 21, 2012. These issues were discussed in meetings between the two agencies on October 26, 2012 and November 9, 2012.
DTSC appreciates the efforts you and your staff have made to resolve DTSC's concerns over the proposed DNAPL remedy for the Montrose Superfund Site. DTSC agrees with the summary of issues and resolution described in your letter and concurs with the FS.
DTSC looks forward to working with the U.S. EPA on implementation of the Montrose DNAPL remedy and on developing a performance monitoring program for that remedy. We also look forward to working. with the U.S.EPA to develop a monitoring and compliance plan for the Montrose and Del Amo Dual Site remedy that will prevent migration of DNAPL outside the containment zone set forth in the Operable Unit 3 Record of Decision.
If you have any questions, please do not hesitate to contact me at (916) 322-3148 or · John Scandura at (714) 484-5456.
Sincerely,
Stewart W. Black, P.G.
cc: See next page.
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Ms. Jane Diamond March 26, 2013 Page 2
cc: (via e-mail)
Mr. John Scandura Brownfields and EnVironmental Restoration Program Department of Toxic Substances Control [email protected]
Mr. Safouh Sayed Brownfields and Environmental Restoration Program Department of Toxic Substances Control [email protected]
Mr. Roberg Senga Brownfields and Environmental Restoration Program Department of Toxic Substances Control [email protected]
Mr. Ted Peng Brownfields and Environmental Restoration Program Department of Toxic Substances Control [email protected] .
Mr. Scott Warren Brownfields and Environmental Restoration Program Department of Toxic Substances Control scott. warren@dtsc. ca.gov
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105-3901
March 14, 2013
Mr. Stewart Black Deputy Director California Department of Toxic Substances Control 1001 “I” Street P.O. Box 806 Sacramento, CA 95812-0806
Re: Montrose DNAPL Feasibility Study
Dear Mr. Black:
This letter is in follow up to the U.S. EPA (EPA) and DTSC meetings of October 26, 2012 and November 9, 2012, regarding the revised Feasibility Study (FS) for Dense Non- Aqueous Phase Liquids (DNAPL) at the Montrose Superfund Site. We appreciate your participation and attention to this important milestone in cleanup of the Montrose site. The purpose of these meetings was to discuss issues raised by DTSC on the DNAPL FS.
DTSC submitted comments to EPA regarding the revised DNAPL FS on August 21, 2012. The main issues in the DTSC comments focused on: 1) estimates of DNAPL and chlorobenzene mass and extent, 2) scope of remedial alternatives and consideration of additional actions, 3) cost estimates and time frames used in the FS, 4) delineation of DNAPL, 5) vertical migration of DNAPL, and 6) the need for DDT removal.
This letter summarizes EPA’s responses to the issues raised in DTSC’s August 2012 comments. On the basis of the conclusions summarized below, EPA intends to finalize the FS and propose a remedy for the mobile DNAPL detected in the Upper Bellflower Aquitard (UBA).
1. The DNAPL mass estimates in the FS are based on multiple lines of evidence collected during rounds of DNAPL reconnaissance and other site-specific investigations and testing focused primarily on Upper Bellflower Aquitard where DNAPL is documented. The lines of evidence included visible staining, odor, soil headspace, FLUTe™ ribbon staining, and soil sample results. The DNAPL mass estimates developed based on the results of these investigations provide a reliable basis for the analysis of alternatives in the FS. EPA and DTSC agree that these mass estimates will be further refined in the design process.
2. In the detailed comments from last summer, DTSC suggested that additional alternatives be considered (such as excavation, slurry walls, DDT isolation, and/or a combination of physical and chemical remedial actions). The alternatives in the
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revised DNAPL FS are based on a comprehensive process of screening technologies in consultation with the leading experts in the field of NAPL remediation. As we discussed, the specific technologies mentioned by DTSC were considered at earlier stages of the FS process and screened out because they were difficult to implement or not effective for conditions at the Montrose site (i.e., heterogeneity of subsurface sediments, depth to groundwater, DNAPL distribution and properties, etc.). EPA and DTSC agree that sufficient evaluation of the available technologies has been conducted and the FS should be finalized.
3. EPA will include in the FS a cost estimate at a discount rate of 7% for the anticipated DNAPL mass removal period estimated at 3 to 7 years. As agreed during the October 26th meeting, the reference to the cost of groundwater containment included in the current version of the DNAPL FS will be removed to avoid confusion over long-term O&M costs of the remedy. Hydraulic containment was selected in the 1999 Record of Decision for the Dual Site Groundwater Operable Unit and associated O&M costs were addressed in the FS for that ROD.
4. For the Montrose site, mobile DNAPL was estimated as a residual DNAPL saturation of greater than 18.9 percent measured in a sandy sample collected at the site. The area of mobile DNAPL in the UBA was delineated, after numerous soil borings were drilled during the DNAPL reconnaissance, using the equivalent threshold concentration of 53 grams per kilogram (g/kg). EPA, with DTSC input, may further refine this measurement in the remedial design and remedial action phases, as we work together to modify remedy performance criteria.
5. DTSC remains concerned that currently there is inadequate data and analysis on DNAPL presence in the Bellflower Sands (BFS). EPA and DTSC agree that additional monitoring of the BFS is necessary as the project moves forward. The remedy will be designed to minimize/eliminate the potential downward migration of DNAPL into the BFS. Additionally a comprehensive monitoring program will be implemented in coordination with DTSC to ensure that adverse DNAPL migration into the BFS is not occurring during cleanup. Post-remediation soil samples will be collected to demonstrate that DNAPL saturations are reduced to meet the measurement criteria used to define the performance in the future ROD.
6. DTSC is concerned that removal of DDT within the DNAPL is not an explicit remedial action objective. In the absence of a solvent such as chlorobenzene, DDT will be relatively immobile in the saturated zone. DDT solubility in groundwater is very low and, when adsorbed to deep soils (depths exceeding 40 to 60 feet bgs), does not pose a risk to groundwater resources and/or human health and the environment.
EPA appreciates DTSC’s careful examination of the technical information presented in the FS. In the meetings between EPA and DTSC on October 26 and November 9, 2012, DTSC agreed that EPA may proceed with finalizing the DNAPL Feasibility Study. EPA agreed to involve DTSC in the development of the Monitoring and Compliance Plan for
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I. GENERAL COMMENTS
WRD strongly supports all of EPA’s remediation objectives for the DNAPL remedy, as described in the DNAPL Proposed Plan:
1) Prevent human exposure to DNAPL constituents (via ingestion, inhalation, or dermal contact) that would pose an unacceptable health risk to on or off property receptors under industrial land uses of the Montrose Property and adjacent properties; 2) To the extent practicable, limit uncontrolled lateral and vertical migration of mobile DNAPL under industrial land use and hydraulic conditions in groundwater; 3) Increase the probability of achieving and maintaining containment of dissolved-phase contamination to the extent practicable, as required by the existing groundwater ROD, for the time period that such containment remains necessary; 4) Reduce mobile DNAPL mass to the extent practicable; 5) To the extent practicable, reduce the potential for recontamination of aquifers that have been restored by the groundwater remedial actions, as required by the groundwater ROD, in the event containment should fail; and 6) To the extent practicable, reduce the dissolved-phase concentrations within the containment zone over time.
As discussed in the DNAPL Proposed Plan, EPA selected Alternative 6A – Electrical Resistance Heating (ERH) treatment for a limited area (i.e. Focused Treatment Area) of the Montrose Site as the Preferred Alternative, based on the review of six remediation alternatives for DNAPL cleanup. EPA reported that this Preferred Alternative only address the mass removal/reduction of “mobile” DNAPL and thus, the proposed cleanup will not address the full extent of all DNAPL (i.e. mobile and residual) at the Montrose Site. On page 4 of the DNAPL Proposed Plan, EPA states, “The extent of mobile DNAPL may be further refined, if needed, during the remedial design and remedial action phases of work, with input from the State.” No other details were provided to describe how and when the extent of mobile DNAPL would be further refined. As a public agency entrusted with protecting and preserving groundwater resources in the West Coast Basin, WRD is very concerned about the limited extent of DNAPL cleanup at the Montrose Site, as further explained below.
A. Soil and groundwater beneath the Montrose Site is contaminated with DNAPL that reportedly consists of both DDT and chlorobenzene (also called monochlorobenzene or MCB). However, EPA’s Preferred Alternative (6A) only addresses mobile chlorobenzene beneath the Focused Treatment Area of the Montrose Site and leaves DDT in place. Because the chlorobenzene is only being remediated at a limited area of the site, there remains the potential for the entrained DDT to be remobilized in the future. Thus, if Alternative 6A is implemented, EPA should consider mass removal of both chlorobenzene and DDT beneath the Montrose Site; otherwise, Alternative 6B should be implemented.
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B. WRD is very concerned about the volume/mass of contamination beneath the Site, especially since it has been confirmed that chlorobenzene has been detected as deep as the Lynwood Aquifer, a major water supply aquifer in the region. Groundwater monitoring by the responsible party should resume as soon as possible in order to continuously assess DNAPL migration both laterally and vertically in the subsurface, including the Gage and Lynwood Aquifers. Given the extent of documented contamination beneath the Montrose Superfund Site, as well as the adjacent Del Amo Superfund Site, and the significant known and potential impacts to the quality of groundwater in the West Coast Basin, WRD recommends that a full public participation process be implemented and that the Draft Monitoring and Aquifer Compliance Plan (MACP) be circulated for a minimum 45-day public review and that a public meeting be held by the EPA to explain the monitoring plan and to receive public comment for consideration. At a minimum, the MACP should describe a groundwater monitoring program that designates adequate monitoring points laterally and vertically and a monitoring frequency that not only evaluates the overall performance of the Dual Site Groundwater Treatment System and drinking water protection, but also complete capture of all DNAPL that can migrate off site.
C. The distinction between mobile and residual DNAPL serves as EPA’s entire basis for the limited DNAPL cleanup at the Montrose Site. On page 4 of the DNAPL Proposed Plan, EPA states, “DNAPL at the Montrose Property occurs in both “mobile” and “residual” forms. Mobile DNAPL is a continuous mass of DNAPL that can flow with groundwater and/or sink under gravitational forces. Residual DNAPL is trapped in the pore spaces of soil particles and cannot move laterally and/or vertically under natural conditions.” According to the FS Report, mobile DNAPL was defined based on physical properties testing of one soil core sample collected from Boring 2DSB-1 at the site and the lateral and vertical extent of mobile DNAPL was based on sampling conducted in 2004 (and prior) and 2008, respectively. Given the current extent of groundwater contamination downgradient of the site and the confirmed detection of chlorobenzene in the Lynwood Aquifer, it is possible and likely that mobile DNAPL has extended beyond the Focused Treatment Area, as defined by EPA in the DNAPL Proposed Plan. Additionally, residual DNAPL may become mobile as groundwater levels continue to rise. WRD nested groundwater monitoring well Carson 2 (approximately 2 miles southeast and downgradient of the Montrose and Del Amo Superfund Sites) show groundwater levels rising an average of 15 feet over the last 12 years in all underlying aquifers (Gage, Lynwood, Silverado, and Sunnyside Aquifers).
As a result, WRD recommends that EPA reconsider the Preferred Alternative and select a treatment alternative that covers the entire 160,000-square foot DNAPL-impacted area. WRD believes this more conservative approach could not only ensure the success of the Dual Site Groundwater Remedy, but also better address areas that may now, or expect to, contain mobile DNAPL should groundwater levels continue to rise in the region. On page 15 of the DNAPL Proposed Plan, EPA states, “Alternative 6B, ERH treatment of the entire treatment area [i.e. full extent of both mobile and residual DNAPL at the Montrose
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Site], was ranked lower because it is more difficult to implement due to the larger treatment volume, and because of the considerably higher cost of this alternative compared to Alternative 6A [ERH, Focused Treatment Area].” Although Alternative 6B may cost more than Alternative 6A, Alternative 6B may be conducted in multiple phases of work, starting with the Focused Treatment Area, and allow EPA the flexibility to refine the remedial design based on the current full extent of DNAPL. Experience at many contaminated sites has shown that the best approaches for remediation often contain a combination of remedial technologies and that within these suites of technologies, some may be multi-phased in order to neutralize all identified chemicals of concern.
D. The DNAPL Proposed Plan does not describe the vertical extent of mobile DNAPL, so it is unclear how deep the Electrical Resistance (ERH) electrodes and multiphase extraction wells that will be installed as part of the Preferred Alternative – 6A. According to the FS Report, DNAPL has been found to a total depth of 101.5 feet below ground surface. As such, the ERH electrodes and extraction wells should be installed at least to depths of 101.5 feet below ground surface.
E. WRD agrees with the following statements on page 5 of the DNAPL Proposed Plan, “. . . mobile DNAPL that is present at the former Montrose Plant Property remains a threat to groundwater and soil vapor, because it is capable of continued vertical and/or lateral migration outside the TI Waiver Zone. This potential migration of mobile DNAPL may result in failure of the Groundwater remedy. Removing mobile DNAPL, therefore, is a critical component in preserving the groundwater resource and ensuring protection of human health and the environment.” To meet EPA’s remediation objective to prevent uncontrolled migration and the spread of mobile DNAPL, WRD recommends preparation of a contingency plan to address other areas of the site that may be identified in the future to contain mobile DNAPL, especially since residual DNAPL may become mobilized due to rising groundwater levels. It would be very helpful if the contingency plan also summarized how the Montrose Site will continue to be monitored in the future for mobile DNAPL and how newly identified mobile DNAPL areas will be remediated.
F. WRD agrees with EPA that the Preferred Alternative should include institutional controls that restrict future activities at the entire Montrose property for industrial use only, as described under Alternative 2 in the DNAPL Proposed Plan. In addition to implementing a formal site inspection and maintenance program that would continuously monitor the land use and access restrictions, WRD recommends that the institutional controls also prohibit the use of any chemical, including chlorobenzene, that could re-mobilize or solubilize the DDT that will remain in place on site.
G. As EPA is aware, the West Coast Basin has complexities with regards to pumping rights, replenishment needs, replenishment assessments, watermaster duties, and the interests of the various cities and public/private utilities that supply groundwater to residents and businesses, in addition to concerned stakeholder groups. As the agency responsible for
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groundwater replenishment and water quality and protection within the West Coast Basin and Central Basin, WRD requests to be included in future stakeholder discussions and copied on all technical correspondence regarding the cleanup of the Montrose and Del Amo Superfund Sites.
II. SPECIFIC COMMENTS
A. Revise Document Title to Accurately Reflect the Scope of the Proposed Plan The Proposed Plan only addresses confirmed, free phase, mobile chlorobenzene DNAPL in the Upper Bellflower Aquitard beneath a significantly smaller area of the Site (i.e. Focused Treatment Area). Based on the limited scope of the DNAPL Proposed Plan, WRD requests the current title be revised as follows, to more accurately reflect EPA’s current remediation objectives: “Proposed Plan for the Cleanup of Confirmed Mobile Chlorobenzene DNAPL in the Upper Bellflower Aquitard Beneath a Limited Area of the Montrose Chemical Superfund Site.”
B. Add Section to Proposed Plan Describing the Dual Site Groundwater Operable Unit EPA’s current design of the Preferred Alternative only address the chlorobenzene component of mobile DNAPL. Thus, residual DNAPL beneath the site, including DDT and those existing outside the Focused Treatment Area, will remain in place and potentially could continue to migrate further southeast (downgradient) beyond the limits of the TI Waiver Zone. As such, the Dual Site Groundwater Treatment System will be a necessary component of the DNAPL cleanup since it will need to be relied upon to capture all contaminants that will be migrating off site. WRD recommends that a section be added to the DNAPL Proposed Plan to describe how the current design of the Dual Site Groundwater Treatment System will accommodate any contamination, in particular residual chlorobenzene and DDT, that is anticipated to continue to migrate off site.
C. Duration of Preferred Alternative is Inconsistent On page 9 of the DNAPL Proposed Plan where Alternative 6A is discussed, the duration of this treatment is described as “4 to 7 years,” while the duration of Alternative 6A is described as “4 years” on page 14 of the Proposed Plan. Please provide an explanation on why the duration is inconsistently referenced for the same Alternative. Secondly, WRD recommends adding a section to the DNAPL Proposed Plan to describe the measures that will be in place to ensure that all mobile DNAPL has been completely removed from the Montrose Site, how residual DNAPL will continue to be monitored throughout the entire site to confirm that it has not become mobilized, and how on-site areas that are identified to contain mobile DNAPL in the future will be remediated.
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D. Nearest Drinking Water Wells On page 3 of the DNAPL Proposed Plan, it states the following, “Although the State of California designates all of the water-bearing units beneath the Montrose property as having potential potable beneficial use, there are currently no known municipal or private potable production wells in use within the area of DNAPL distribution and/or dissolved groundwater contamination at the Montrose Superfund Site. The nearest municipal supply wells are located more than 2 miles from the Montrose Property, and about 0.5 to 1 mile southeast from the furthest extent of groundwater contamination related to the Montrose and Del Amo Superfund Sites.” As a clarification, the second sentence should be revised to add “downgradient,” so that the sentence is revised as follows: “The nearest downgradient municipal supply wells are located more than 2 miles . . . .” Secondly, EPA may want to consider designating a buffer zone around the Montrose and Del Amo Superfund Sites and establishing formal notification procedures for future production wells that may be installed in the area, which could potentially impact future operations of the Dual Site Groundwater Treatment System.
E. Figures 5 and 8 Are Exactly the Same Figures 5 and 8 have different titles, but the figures are exactly the same. Based on the title of Figure 8 (“ERH in the Focused Treatment Area”) and the description of Figure 8 under the Preferred Alternative – 6A, it appears that the wrong Figure 8 was inserted into the DNAPL Proposed Plan. Currently, Figure 8 does not depict or reference ERH within the figure. Please issue a Revised DNAPL Proposed Plan with the correct Figure 8.
F. Permitting for Reinjection of Treated and Untreated Water Waters of the State beneath the Site, including the Upper Bellflower Aquitard (UBA), Middle Bellflower Sand (BFS), Lower Bellflower Aquitard (LBA), Gage Aquifer, and Lynwood Aquifer, are designated for beneficial use, and therefore must be protected. WRD strongly opposes the discharge of untreated water into the subsurface that could further degrade the water quality of these aquifers. With regards to reinjection of treated water, WRD recommends that the EPA and Los Angeles Regional Water Quality Control Board adopt limits of “nondetect” for anthropogenic chemicals of concern where no scientific or regulatory criteria exist, which is in accordance with the State Antidegradation Policy (Resolution No. 68-16 adopted by the State Water Resources Control Board on October 28, 1968). The State Antidegradation Policy was established to maintain aquifers with the “highest water quality consistent with the maximum benefit to the people of the State” and protect the designated beneficial uses. All reinjection activities should comply with State Waste Discharge Requirements.
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APPENDIX D DETAILED COSTS FOR THE SELECTED REMEDY
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This appendix provides Detailed Cost Estimates for the selected remedy for DNAPL OU at the Montrose Superfund Site. The following tables were originally provided in Appendix J of the Final DNAPL Feasibility Study (AECOM, 2013) and include: Appendix J Table 1.0 — Cost Summary Institutional Controls Appendix J Table 5.0 (5.1 through 5.9) — Cost Summary Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal ‐ 2.5 UBA PVs or 200 kW‐hrs/cubic yard Appendix J Table 7.0 (7.1 through 7.9) — Cost Summary Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal ‐ 6 UBA PVs or 400 kW‐hrs/cubic yard Appendix J Table 13.0 (13.1 through 13.9) — Cost Summary ERH (200 kW‐hrs/cubic yard) Focused Treatment Area Appendix J Table 14.0 (14.1 through 14.9) — Cost Summary ERH (400 kW‐hrs/cubic yard) Focused Treatment Area
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Final DNAPL Feasibility Study Montrose Superfund Site Institutional Controls Los Angeles, California June 2013 Appendix J Table 1.0 Cost Summary Institutional Controls
Cost (NPV) Cost Year Activity DR = 4% DR = 7% (Undiscounted) Deed Restriction and Sign Installation - On Property $100,000 1 $ 110,577 $ 107,477 Deed Restriction $15,000 2 $ 5,000 $ 4,623 $ 4,367 3 $ 5,000 $ 4,445 $ 4,081 4 $ 5,000 $ 4,274 $ 3,814 5 $ 5,000 $ 4,110 $ 3,565 6 $ 5,000 $ 3,952 $ 3,332 7 $ 5,000 $ 3,800 $ 3,114 8 $ 5,000 $ 3,653 $ 2,910 9 $ 5,000 $ 3,513 $ 2,720 10 $ 5,000 $ 3,378 $ 2,542 11 $ 5,000 $ 3,248 $ 2,375 12 $ 5,000 $ 3,123 $ 2,220 13 $ 5,000 $ 3,003 $ 2,075 14 $ 5,000 $ 2,887 $ 1,939 15 $ 5,000 $ 2,776 $ 1,812 Deed Restriction Renewal (On and Off Property) 16 $ 5,000 $ 2,670 $ 1,694 and Fence/Signage Maintenance 17 $ 5,000 $ 2,567 $ 1,583 18 $ 5,000 $ 2,468 $ 1,479 19 $ 5,000 $ 2,373 $ 1,383 20 $ 5,000 $ 2,282 $ 1,292 21 $ 5,000 $ 2,194 $ 1,208 22 $ 5,000 $ 2,110 $ 1,129 23 $ 5,000 $ 2,029 $ 1,055 24 $ 5,000 $ 1,951 $ 986 25 $ 5,000 $ 1,876 $ 921 26 $ 5,000 $ 1,803 $ 861 27 $ 5,000 $ 1,734 $ 805 28 $ 5,000 $ 1,667 $ 752 29 $ 5,000 $ 1,603 $ 703 30 $ 5,000 $ 1,542 $ 657
Net Present Value at 30 Years = $ 192,229 $ 164,849
Notes DR = Discount rate NPV = Net present value
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Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.0 Cost Summary Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard
Cost (NPV) Cost Year Activity Detailed Cost Table DR= 4% DR= 7% (Undiscounted) 1 Design J-5.1 Design $ 94,359 $ 90,729 $ 88,186 J-5.2 Well Construction $ 188,329 J-5.3 Well Field Equipment Installation $ 60,013 2 System Construction $ 447,218 $ 422,492 J-5.4 Treatment Equipment Installation $ 189,831 J-5.5 Construction Management $ 45,538 3 Operation and Maintenance - Year 1 J-5.6 Annual O&M - Carbon Regen for Vapor Treatment $ 449,164 $ 399,305 $ 366,651 4 Operation and Maintenance - Year 2 $ 653,591 $ 558,692 $ 498,621 5 Operation and Maintenance - Year 3 J-5.7 Annual O&M - Disposable Carbon for Vapor Treatment $ 586,491 $ 482,053 $ 418,160 6 Operation and Maintenance - Year 4 $ 539,411 $ 426,304 $ 359,432 J-5.8 Well Abandonment $ 60,764 7 Verification and Abandonment $ 117,372 $ 96,186 J-5.9 Demobilization $ 93,690
Totals$ 2,961,178 $ 2,521,673 $ 2,249,728
Notes DR = Discount rate NPV = Net present value
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Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.1 Detailed Cost, Unsatured Zone SVE Coupled with Focused Treatment Area Thermal (2.5 UBA PVs or 200 kW-hrs/cubic yard) Design
Item Consultant Labor Quantity Unit Cost Cost 1 Project Manager 90 150$ /Hour $ 13,467 2 Senior Engineer/Geologist 180 125$ /Hour $ 22,446 3 Mid-Level Engineer/Geologist 360 100$ /Hour $ 36,000 4 Junior/Field Engineer/Geologist 180 75$ /Hour $ 13,467 5 Field Technician 0 75$ /Hour $ - 6 Clerical/Drafting 180 50$ /Hour $ 8,978 Consultant Labor $ 94,359
TOTAL DESIGN COST $ 94,359
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Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.2 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Well Construction
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 24 150$ /Hour $ 3,600 2 Senior Engineer/Geologist 24 125$ /Hour $ 3,000 3 Mid-Level Engineer/Geologist 52 100$ /Hour $ 5,200 4 Junior/Field Engineer/Geologist 120 75$ /Hour $ 9,000 5 Field Technician 42 75$ /Hour $ 3,150 6 Clerical/Drafting 24 50$ /Hour $ 1,200 Total Consultant Labor Cost $ 25,150
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 HSA Rig Mobilization 1 1,200$ /Each $ 1,200 1
8 Palos Verdes Sands SVE Wells (12" HSA Drilling to 45' bgs) a Install Well Constructed of 6" LCS Casing w/ 20' of SS Screen 1 8,500$ /Each $ 8,500 1 b Forklift and Hopper Rental for Waste Handling 0.5 250$ /Day $ 125 1 c Drill Crew per Diem 0.5 450$ /Night $ 225 1 d Vehicle Usage 0.5 100$ /Day $ 50 e Equipment Rental and Supplies 0.5 500$ /Day $ 250 f Other Direct Costs 0.5 300$ /Day $ 150 Cost per Well $ 9,300 Number of Wells (2 Wells Installed per Day) 7 Subtotal - PVS Wells $ 65,100
J-5.2 Well Construction Cost Page 3 of 16 383 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 296 of 381 Page ID #:13844
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.2 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 9 UBA SVE Wells (12" HSA Drilling to 60 bgs) a Install Well Constructed of 6" LCS Casing w/ 15' of SS Screen 1 9,700$ /Each $ 9,700 1 b Forklift and Hopper Rental for Waste Handling 0.5 250$ /Day $ 125 1 c Drill Crew per Diem 0.5 450$ /Night $ 225 1 d Vehicle Usage 0.5 100$ /Day $ 50 e Equipment Rental and Supplies 0.5 500$ /Day $ 250 f Installation Permit 1 201$ /Each $ 201 g Other Direct Costs 0.5 300$ /Day $ 150 Cost per Well $ 10,701 Number of Wells (2 Wells Installed per Day) 5 Subtotal - UBA Wells $ 53,505
10 Lab Analytical (Three PVS Borinngs and Four UBA Borings) a Soil Analysis - Pesticides (EPA Method 8081A) 10 90$ /Sample $ 900 2 b Soil Analysis - VOCs (EPA Method 8260B) 10 95$ /Sample $ 950 2 c Soil Analysis - pCBSA (Modified EPA Method 314.0) 10 80$ /Sample $ 800 2 d Water Analysis - Pesticides (EPA Method 8081A) 2 90$ /Sample $ 180 2 e Water Analysis - VOCs (EPA Method 8260B) 2 95$ /Sample $ 190 2 f Water Analysis - pCBSA (Modified EPA Method 314.0) 2 80$ /Sample $ 160 2 Total Lab Analytical (Extraction Wells) $ 3,180
J-5.2 Well Construction Cost Page 4 of 16 384 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 297 of 381 Page ID #:13845
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.2 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 11 Waste Management a Waste Tank Rental 36 38$ /Day $ 1,368 3 b Waste Tank Rental Delivery - Mob and Demob 1 900$ /Each $ 900 3 c Waste Bin Rental 60 15$ /Day $ 900 3 d Waste Bin Rental Delivery - Mob and Demob 2 500$ /Each $ 1,000 3 e Transport of Hazardous Soil Cuttings 2 1,100$ /Each $ 2,200 3 f Disposal of Hazardous Soil Cuttings 29 550$ /Ton $ 15,932 3 g Transport of Hazardous Water 1 1,100$ /Each $ 1,100 3 h Disposal of Hazardous Water 1200 0.8$ /Gal $ 960 3 i Waste Characterization/Profiling 2 500$ /Each $ 1,000 Subtotal - Waste Management $ 25,360 Total Subcontractor Cost w/10% Markup $ 163,179
TOTAL WELL CONSTRUCTION COST $ 188,329
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Verbal Quote from Test America 3 Verbal Quote from NRC Environmental
J-5.2 Well Construction Cost Page 5 of 16 385 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 298 of 381 Page ID #:13846
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.3 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Well Field Equipment Installation
Cost Item Unit Cost Consultant Labor and Direct Costs Quantity Cost Ref.
1 Extraction Well Assemblies a Static Pressure Gage 12 $ 48 /Each $ 576 1 b Temperature Indicator 12 $ 127 /Each $ 1,524 1 c Flow Sensor 12 $ 121 /Each $ 1,452 2 d Differential Pressure Gage 12 $ 315 /Each $ 3,780 2 Total Extraction Well Assemblies $ 7,332
3 SVE Piping a 8-Inch Carbon Steel Pipe and Fittings 320$ 94.71 LF$ 30,307 3 b 6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 120$ 67.65 LF $ 8,118 3 Total SVE Piping $ 38,425
4 Pipe Supports 44 $ 200 LF $ 8,800 DIRECT COSTS w/10% MARKUP $ 60,013 TOTAL WELL FIELD EQUIPMENT INSTALLTION COST $ 60,013
Cost Source Reference 1 Grainger Catalog Price 2 Dwyer Instruments, Inc. Catalog Price 3 Cost in 2008 dollars based on 2006 RS Means and an assumed inflation rate if 3% per year
J-5.3 Well Field Equipment Installation Cost Page 6 of 16 386 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 299 of 381 Page ID #:13847
Final DNAPL Feasibilty Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.4 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Treatment Equipment Installation
Cost Unit Cost Item Direct Costs Quantity Cost Ref. Carbon Regen System Upgrade (from 5000-lb to vessels to 10000-lb vessels) 1$ 46,000 /LS $ 46,000 1 Polishing Carbon Vessel Upgrade (from 5000-lb to 10000-lb) 2$ 16,000 /Each$ 32,000 2 Additional Initial Carbon Fill (Virgin Coconut) 10,000$ 1.07 /lb $ 10,700 2 Oriface Plate and Transmitter 1$ 10,000 /Each$ 10,000 Moister Separator 1 $ 4,000 /Each$ 4,000 3 Transfer Pump (50 gpm) 1 $ 536 /Each $ 536 4 1000 SCFM Positive Displacement Blower (for PVS) 1$ 30,000 /Each$ 30,000 5 300 SCFM Liquid Ring Blower (Hi Vac for UBA) 0$ 45,980 /Each $ - 5 Inline Stack PID 0 $ 3,775 /Each $ - 6 Static Pressure Gage 34$ 8 /Each $ 144 4 Temperature Indicator 3 $ 127 /Each $ 381 4 Interconnecting Piping (10% of Blower, KO Tank, and Regen and Polishing Carbon Vessel Upgrade) 1$ 12,598 LS $ 12,598 Electrical Allowance (20% of elec components) 1 $ 8,107 LS $ 8,107 Control System Allowance (20% of elec components) 1 $ 8,107 LS $ 8,107 Treatment Plant Pad and Building 0-$ LS $ - 7 Subcontractor Installation Cost 1$ 10,000 LS$ 10,000 TOTAL TREATMENT EQUIPMENT INSTALLATION COST w/10% MARKUP$ 189,831
Cost Source Reference 1 Based on MEGTEC Systems, Inc. Quote Dated April 20, 2008 2 Based on July 1 2008 BakerCorp Quote 3 Verbal Quote from Enviro Supply and Services 4 Grainger Catalog Price 5 Yardley Pump and Vacuum Quote Dated July 16, 2008 6 Verbal Quote from RAE Systems 7 Based on Building/Lab Site Improvements Cost for 350 gpm LGAC Adsorber System in 1998 Joint Groundwater Feasibility Study for the Montrose and Del Amo Sites
J-5.4 Treatment Equipment Installation Cost Page 7 of 16 387 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 300 of 381 Page ID #:13848
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.5 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal (2.5 UBA PVs or 200 kW-hrs/cubic yard) Construction Management
Item Consultant Labor Quantity Unit Cost Cost 1 Project Manager 20$ 150 /Hour$ 3,000 2 Senior Engineer/Geologist 45 $ 125 /Hour $ 5,625 3 Mid-Level Engineer/Geologist 90 $ 100 /Hour $ 8,978 4 Junior/Field Engineer/Geologist 180 $ 75 /Hour $ 13,467 5 Field Technician 180 $ 75 /Hour $ 13,467 6 Clerical/Drafting 20 $ 50 /Hour $ 1,000 TOTAL CONSTRUCTION MANAGEMENT COST$ 45,538
J-5.5 Construction Management Cost Page 8 of 16 388 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 301 of 381 Page ID #:13849
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.6 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Annual Operations and Maintenance (Year 1)
Cost Unit Cost Item Consultant Labor (Operations) Quantity Cost Ref. 1 Project Manager 65 150$ /Hour $ 9,750 2 Senior Engineer/Geologist 65 125$ /Hour $ 8,125 3 Mid-Level Engineer/Geologist 130 100$ /Hour $ 13,000 4 Junior/Field Engineer/Geologist 260 75$ /Hour $ 19,500 5 Field Technician 075$ /Hour $ - 6 Clerical/Drafting 050$ /Hour $ - Consultant Labor Cost for Operations $ 50,375
Cost Unit Cost Item Consultant Labor (Reporting, H&S, and Data Mngt) Quantity Cost Ref. 7 Project Manager 40 150$ /Hour $ 6,000 8 Senior Engineer/Geologist 80 125$ /Hour $ 10,000 9 Mid-Level Engineer/Geologist 160 100$ /Hour $ 16,000 10 Junior/Field Engineer/Geologist 160 75$ /Hour $ 12,000 11 Field Technician 075$ /Hour $ - 12 Clerical/Drafting 160 50$ /Hour $ 8,000 Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance $ 52,000
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 13 Waste Management
a Additional Polishing VGAC and regen system VGAC change-outs 45,000 1.53$ /lb $ 68,625 1
b Additional Carbon Regen System Solvent i Transportation 4 3,650$ /load $ 14,600 2 ii Disposal (Listed Waste for Incineration) 159,870 0.5$ /lb $ 79,935 2
c Additional Boiler Water Pre-Treatment Brine and Blowdown i Transportation 7 950$ /10,000 gals $ 6,650 3 ii Disposal (non-Haz) 63,009 0.14$ /gal $ 8,821 3
Total Waste Management $ 178,631
J-5.6 Annual Operations and Maintenance (Year 1) Cost Page 9 of 16 389 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 302 of 381 Page ID #:13850
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.6 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Annual Operations and Maintenance (Year 1)
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 14 Lab Analytical and Monitoring a Summa Can Rental 48 40$ /Each $ 1,920 4 b Vapor VOCs Analysis (EPA TO-15) 48 200$ /Each $ 9,600 4 c Tedlar Bags 12 10$ /Each $ 120 Total Lab Analytical and Monitoring $ 11,640
15 Miscellaneous - Year 1 a Miscellaneous Parts 12 1,000$ /Month $ 12,000 b Fed Ex and Deliveries 12 100$ /Month $ 1,200 Total Miscellaneous - Year 1 $ 13,200 Cost Unit Cost Item Direct Cost Quantity Cost Ref. 16 Utilities a Natural Gas (additional Steam for Carbon Regen Unit) 77,740 1.14$ /therm $ 88,624 5 b Municipal Water (additional steam for Carbon Regen Unit) 750,528$ 0.0029 /gal $ 2,177 c Electricity - PD Vacuum Blower 489,925 0.1045$ /kWh $ 51,197 6 Total Utilities $ 141,997
CONSULTANT LABOR COST $ 102,375 SUBCONTRACTOR COST w/10% MARKUP - YEAR 1 $ 204,791 UTILITIES COST (NO MARKUP) $ 141,997 TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 1 $ 449,164
Cost Source Reference 1 Based on carbon costs associated with the Montrose Henderson SVE System 2 Clean Harbors Quote Dated October 10, 2007 3 NRC Environmental Services, Inc. Email Quote Dated June 30, 2008 4 Verbal Quote from Calscience 5 GN-10, Tier III, SoCal Gas Co. Rate (Effective May 1, 2008) 6 Shedule A-3 LADWP Rate (Second Quarter 2008)
J-5.6 Annual Operations and Maintenance (Year 1) Cost Page 10 of 16 390 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 303 of 381 Page ID #:13851
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.7 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Annual Operations and Maintenance (Years 2 through 4)
Cost Unit Cost Item Consultant Labor (Operations) Quantity Cost Ref. 1 Project Manager 52$ 150 /Hour$ 7,800 2 Senior Engineer/Geologist 52$ 125 /Hour$ 6,500 3 Mid-Level Engineer/Geologist 208$ 100 /Hour$ 20,800 4 Junior/Field Engineer/Geologist 520$ 75 /Hour$ 39,000 5 Field Technician 1,040$ 75 /Hour $ 78,000 6 Clerical/Drafting 050$ /Hour $ - Consultant Labor Cost for Operations $ 152,100
Cost Unit Cost Item Consultant Labor (Reporting, H&S, and Data Mngt) Quantity Cost Ref. 7 Project Manager 40$ 150 /Hour$ 6,000 8 Senior Engineer/Geologist 80$ 125 /Hour$ 10,000 9 Mid-Level Engineer/Geologist 160$ 100 /Hour$ 16,000 10 Junior/Field Engineer/Geologist 160$ 75 /Hour$ 12,000 11 Field Technician 075$ /Hour$ - 12 Clerical/Drafting 160$ 50 /Hour $ 8,000 Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance $ 52,000
J-5.7 Annual Operations and Maintenance (Years 2 through 4) Cost Page 11 of 16 391 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 304 of 381 Page ID #:13852
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.7 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Annual Operations and Maintenance (Years 2 through 4)
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 13 Turnkey VGAC Change-Out Service (incl. fresh VGAC and T&D of spent VGAC as Haz) a Year 2 140,000$ 1.53 /lb VGAC$ 213,500 1 b Year 3 100,000$ 1.53 /lb VGAC$ 152,500 1 c Year 4 60,000$ 1.53 /lb VGAC$ 91,500 1
14 Final Spent VGAC (40,000 lbs) Transportation and Disposal 40,000$ 0.46 /lb VGAC $ 18,200 1 Total VGAC (Year 2) $ 213,500 Total VGAC (Year 3) $ 152,500 Total VGAC (Year 4) $ 109,700
15 Lab Analytical and Monitoring a Summa Can Rental 84$ 40 /Each $ 3,360 2 b Vapor VOCs Analysis (EPA TO-15) 84$ 200 /Each $ 16,800 2 c Tedlar Bags 12$ 10 /Each $ 120 Total Lab Analytical and Monitoring $ 20,280
J-5.7 Annual Operations and Maintenance (Years 2 through 4) Cost Page 12 of 16 392 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 305 of 381 Page ID #:13853
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.7 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Annual Operations and Maintenance (Years 2 through 4)
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 16 Miscellaneous - Years 2 through 4 a Temporary Office 24'x60' Rental 12$ 1,030 /Month$ 12,356 3 b Temporary Storage Trailer 12$ 149 /Month$ 1,784 4 c Portable Toilet Rental 12$ 76 /Month$ 908 5 d Miscellaneous Parts 12$ 1,000 /Month$ 12,000 e Fed Ex and Deliveries 12$ 100 /Month$ 1,200 f Temporary office comm. (internet, telephone, fax) 12$ 1,000 /Month$ 12,000 g Operator Truck Usage (One Truck per Operator) 260$ 100 /Day/Truck $ 26,000 Total Miscellaneous - Years 2 through 4 $ 66,248 Total Subcontractor Cost - Year 2 $ 300,028 Total Subcontractor Cost - Year 3 $ 239,028 Total Subcontractor Cost - Year 4 $ 196,228
Cost Unit Cost Item Utilities Quantity Cost Ref. 17 Utilities Electricity - PD and Liquid Ring Vacuum Blowers 1,143,158$ 0.1045 /kWh $ 119,460 6 Total Utilities $ 119,460
CONSULTANT LABOR COST $ 204,100 SUBCONTRACTOR COST w/10% MARKUP - YEAR 2 $ 330,031 SUBCONTRACTOR COST w/10% MARKUP - YEAR 3 $ 262,931 SUBCONTRACTOR COST w/10% MARKUP - YEAR 4 $ 215,851 UTILITIES COST (NO MARKUP) $ 119,460 TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 2 $ 653,591 TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 3 $ 586,491 TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 4 $ 539,411
Cost Source Reference 1 Based on carbon costs associated with the Montrose Henderson SVE System 2 Verbal Quote from Calscience 3 Mobile Mini, Inc. Quote Dated October 11, 2007 4 Verbal Quote from Mobile Mini, Inc. 5 Verbal Quote from A-1 Coast Port-A-Toilet 6 Shedule A-3 LADWP Rate (Second Quarter 2008)
J-5.7 Annual Operations and Maintenance (Years 2 through 4) Cost Page 13 of 16 393 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 306 of 381 Page ID #:13854
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.8 Detailed Cost, Unsatuared Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Well Abandonment
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 10 150$ /Hour $ 1,500 2 Senior Engineer/Geologist 20 125$ /Hour $ 2,500 3 Mid-Level Engineer/Geologist 20 100$ /Hour $ 2,000 4 Junior/Field Engineer/Geologist 80 75$ /Hour $ 6,000 5 Field Technician 20 75$ /Hour $ 1,500 6 Clerical/Drafting 20 50$ /Hour $ 1,000 Total Consultant Labor Cost $ 14,500
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref.
7 Mobilization/Demobilization of Drill Rig 1$ 2,000 /LS $ 2,000 1
8 Abandon PVS SVE Wells a Drill out well materials 5 65$ /Foot $ 325 1 b Pressure grout well 45 30$ /Foot $ 1,350 1 c Forklift and mini-hopper 0.5 500$ /Day $ 250 1 d Abandonment Crew per Diem 0.5 200$ /Night $ 100 1 e Vehicle Usage 0.5 100$ /Day $ 50 f Equipment Rental and Supplies 0.5 150$ /Day $ 75 g Other Direct Costs 0.5 150$ /Day $ 75 Cost per Well $ 2,225 Number of Wells (2 Wells Abandoned per Day) 7 Total for Extraction Well Adandonment 15,575
J-5.8 Well Abandonment Cost Page 14 of 16 394 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 307 of 381 Page ID #:13855
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 5.8 Detailed Cost, Unsatuared Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Well Abandonment
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 9 Abandon UBA SVE Wells a Drill out well materials 5 65$ /Foot $ 325 1 b Pressure grout well 60 30$ /Foot $ 1,800 1 c Forklift and mini-hopper 0.5 500$ /Day $ 250 1 d Abandonment Crew per Diem 0.5 200$ /Night $ 100 1 e Vehicle Usage 0.5 100$ /Day $ 50 f Equipment Rental and Supplies 0.5 150$ /Day $ 75 g Other Direct Costs 0.5 150$ /Day $ 75 Cost per Well $ 2,675 Number of Wells (2 Wells Abandoned per Day) 5 Total for Injection Well Abandonment 13,375 Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 10 Waste Management a Waste Tank Rental 36 38$ /Day $ 1,368 2 b Waste Tank Rental Delivery - Mob and Demob 1 900$ /Each $ 900 2 c Waste Bin Rental 36 15$ /Day $ 540 2 d Waste Bin Rental Delivery - Mob and Demob 2 500$ /Each $ 1,000 2 e Transport and Disposal/Recycling of Steel 1$ 1,100 /Load $ 1,100 f Transport of Hazardous Soil Cuttings 1$ 1,100 /Each $ 1,100 2 g Disposal of Hazardous Soil Cuttings 3.71 550$ /Ton $ 2,040 2 h Transport of Hazardous Water 1$ 1,100 /Each $ 1,100 2 i Disposal of Hazardous Water 1200 0.8$ /Gal $ 960 2 j Waste Characterization/Profiling 2 500$ /Each $ 1,000 Total Waste Management $ 11,108 Total Subcontractor Cost w/10% Markup $ 46,264
TOTAL WELL ABANDONMENT COST $ 60,764
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Verbal Quote from NRC Environmental Services
J-5.8 Well Abandonment Cost Page 15 of 16 395 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 308 of 381 Page ID #:13856
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (Coupled with Thermal Remedy) Los Angeles, California June 2013 Appendix J Table 5.9 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 2.5 UBA PVs or 200 kW-hrs/cubic yard Demobilization
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 8$ 150 /Hour $ 1,200 2 Senior Engineer/Geologist 20$ 125 /Hour $ 2,500 3 Mid-Level Engineer/Geologist 40$ 100 /Hour $ 4,000 4 Junior/Field Engineer/Geologist 120$ 75 /Hour $ 9,000 5 Field Technician 50$ 75 /Hour $ 3,750 6 Clerical/Drafting 20$ 50 /Hour $ 1,000 Consultant Labor Cost $ 21,450
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 Remove Purchased Treatment Equipment 1 41,000 /LS $ 41,000
8 Demob Office Trailer 1$ 1,746 LS $ 1,746 1
9 Close-Out Borings a Drilling and backfilling (6-Inch Sonic to 45 feet bgs at $65/foot) 3$ 2,925 /Boring $ 8,775 2 b Drilling and backfilling (6-Inch Sonic to 60 feet bgs at $65/foot) 2$ 3,900 /Boring $ 7,800 2 c Disposal of Hazardous Soil Cuttings 3.0 $ 550 /Ton $ 1,651 3 d Transportation of Hazardous Soil Cuttings 1$ 1,100 /Each $ 1,100 3 e Waste Bin Rental Delivery - Mob and Demob 1 $ 500 /Each $ 500 3 f Waste Bin Rental 30 $ 15 /Day $ 450 3 g Soil Pesticides (EPA Method 8081A) 10 $ 90 /Sample $ 900 4 h Soil VOCs (EPA Method 8260B) 10 $ 95 /Sample $ 950 4 i Soil pCBSA (Modified EPA Method 314.0) 10 $ 80 /Sample $ 800 4 Total for Close-Out Borings $ 22,926
Total Subcontractor Cost w/10% Markup $ 72,240
TOTAL DEMOBILIZATION COST $ 93,690
Cost Source Reference 1 Mobile Mini, Inc. Quote Dated October 11, 2007 2 Water Development Corporation Quote Dated 10/09/08 3 Verbal Quote from NRC Environmental Services 4 Verbal Quote from Test America
J-5.9 Demobilization Cost Page 16 of 16 396 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 309 of 381 Page ID #:13857
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.0 Cost Summary Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard
Cost (NPV) Cost Year Activity Detailed Cost Table DR= 4% DR= 7% (Undiscounted) 1 Design J-7.1 Design $ 94,359 $ 90,729 $ 88,186 J-7.2 Well Construction $ 188,329 J-7.3 Well Field Equipment Installation $ 60,013 2 System Construction $ 447,218 $ 422,492 J-7.4 Treatment Equipment Installation $ 189,831 J-7.5 Construction Management $ 45,538 3 Operation and Maintenance - Year 1 J-7.6 Annual O&M - Carbon Regen for Vapor Treatment $ 468,191 $ 416,220 $ 382,183 4 Operation and Maintenance - Year 2 J-7.6 Annual O&M - Carbon Regen for Vapor Treatment $ 387,467 $ 331,209 $ 295,597 5 Operation and Maintenance - Year 3 J-7.7 Annual O&M - Disposable Carbon for Vapor Treatment $ 586,491 $ 482,053 $ 418,160 6 Operation and Maintenance - Year 4 J-7.7 Annual O&M - Disposable Carbon for Vapor Treatment $ 539,411 $ 426,304 $ 359,432 J-7.8 Well Abandonment $ 60,764 7 Verification and Abandonment $ 117,372 $ 96,186 J-7.9 Demobilization $ 93,690
Totals$ 2,714,082 $ 2,311,104 $ 2,062,235
Notes DR = Discount rate NPV = Net present value
J-7.0 Cost Summary Page 1 of 16 397 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 310 of 381 Page ID #:13858
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.1 Detailed Cost, Unsatured Zone SVE Coupled with Focused Treatment Area Thermal (6 UBA PVs or 400 kW-hrs/cubic yard) Design
Item Consultant Labor Quantity Unit Cost Cost 1 Project Manager 90 150$ /Hour $ 13,467 2 Senior Engineer/Geologist 180 125$ /Hour $ 22,446 3 Mid-Level Engineer/Geologist 360 100$ /Hour $ 36,000 4 Junior/Field Engineer/Geologist 180 75$ /Hour $ 13,467 5 Field Technician 0 75$ /Hour $ - 6 Clerical/Drafting 180 50$ /Hour $ 8,978 Consultant Labor $ 94,359
TOTAL DESIGN COST $ 94,359
J-7.1 Design Cost Page 2 of 16 398 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 311 of 381 Page ID #:13859
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.2 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Well Construction
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 24 150$ /Hour $ 3,600 2 Senior Engineer/Geologist 24 125$ /Hour $ 3,000 3 Mid-Level Engineer/Geologist 52 100$ /Hour $ 5,200 4 Junior/Field Engineer/Geologist 120 75$ /Hour $ 9,000 5 Field Technician 42 75$ /Hour $ 3,150 6 Clerical/Drafting 24 50$ /Hour $ 1,200 Total Consultant Labor Cost $ 25,150
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 HSA Rig Mobilization 1 1,200$ /Each $ 1,200 1
8 Palos Verdes Sands SVE Wells (12" HSA Drilling to 45' bgs) a Install Well Constructed of 6" LCS Casing w/ 20' of SS Screen 1 8,500$ /Each $ 8,500 1 b Forklift and Hopper Rental for Waste Handling 0.5 250$ /Day $ 125 1 c Drill Crew per Diem 0.5 450$ /Night $ 225 1 d Vehicle Usage 0.5 100$ /Day $ 50 e Equipment Rental and Supplies 0.5 500$ /Day $ 250 f Other Direct Costs 0.5 300$ /Day $ 150 Cost per Well $ 9,300 Number of Wells (2 Wells Installed per Day) 7 Subtotal - PVS Wells $ 65,100
J-7.2 Well Construction Cost Page 3 of 16 399 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 312 of 381 Page ID #:13860
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.2 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 9 UBA SVE Wells (12" HSA Drilling to 60 bgs) a Install Well Constructed of 6" LCS Casing w/ 15' of SS Screen 1 9,700$ /Each $ 9,700 1 b Forklift and Hopper Rental for Waste Handling 0.5 250$ /Day $ 125 1 c Drill Crew per Diem 0.5 450$ /Night $ 225 1 d Vehicle Usage 0.5 100$ /Day $ 50 e Equipment Rental and Supplies 0.5 500$ /Day $ 250 f Installation Permit 1 201$ /Each $ 201 g Other Direct Costs 0.5 300$ /Day $ 150 Cost per Well $ 10,701 Number of Wells (2 Wells Installed per Day) 5 Subtotal - UBA Wells $ 53,505
10 Lab Analytical (Three PVS Borinngs and Four UBA Borings) a Soil Analysis - Pesticides (EPA Method 8081A) 10 90$ /Sample $ 900 2 b Soil Analysis - VOCs (EPA Method 8260B) 10 95$ /Sample $ 950 2 c Soil Analysis - pCBSA (Modified EPA Method 314.0) 10 80$ /Sample $ 800 2 d Water Analysis - Pesticides (EPA Method 8081A) 2 90$ /Sample $ 180 2 e Water Analysis - VOCs (EPA Method 8260B) 2 95$ /Sample $ 190 2 f Water Analysis - pCBSA (Modified EPA Method 314.0) 2 80$ /Sample $ 160 2 Total Lab Analytical (Extraction Wells) $ 3,180
J-7.2 Well Construction Cost Page 4 of 16 400 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 313 of 381 Page ID #:13861
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.2 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 11 Waste Management a Waste Tank Rental 36 38$ /Day $ 1,368 3 b Waste Tank Rental Delivery - Mob and Demob 1 900$ /Each $ 900 3 c Waste Bin Rental 60 15$ /Day $ 900 3 d Waste Bin Rental Delivery - Mob and Demob 2 500$ /Each $ 1,000 3 e Transport of Hazardous Soil Cuttings 2 1,100$ /Each $ 2,200 3 f Disposal of Hazardous Soil Cuttings 29 550$ /Ton $ 15,932 3 g Transport of Hazardous Water 1 1,100$ /Each $ 1,100 3 h Disposal of Hazardous Water 1200 0.8$ /Gal $ 960 3 i Waste Characterization/Profiling 2 500$ /Each $ 1,000 Subtotal - Waste Management $ 25,360 Total Subcontractor Cost w/10% Markup $ 163,179
TOTAL WELL CONSTRUCTION COST $ 188,329
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Verbal Quote from Test America 3 Verbal Quote from NRC Environmental
J-7.2 Well Construction Cost Page 5 of 16 401 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 314 of 381 Page ID #:13862
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.3 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Well Field Equipment Installation
Cost Item Unit Cost Consultant Labor and Direct Costs Quantity Cost Ref.
1 Extraction Well Assemblies a Static Pressure Gage 12 $ 48 /Each $ 576 1 b Temperature Indicator 12 $ 127 /Each $ 1,524 1 c Flow Sensor 12 $ 121 /Each $ 1,452 2 d Differential Pressure Gage 12 $ 315 /Each $ 3,780 2 Total Extraction Well Assemblies $ 7,332
3 SVE Piping a 8-Inch Carbon Steel Pipe and Fittings 320$ 94.71 LF$ 30,307 3 b 6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 120$ 67.65 LF $ 8,118 3 Total SVE Piping $ 38,425
4 Pipe Supports 44 $ 200 LF $ 8,800 DIRECT COSTS w/10% MARKUP $ 60,013 TOTAL WELL FIELD EQUIPMENT INSTALLTION COST $ 60,013
Cost Source Reference 1 Grainger Catalog Price 2 Dwyer Instruments, Inc. Catalog Price 3 Cost in 2008 dollars based on 2006 RS Means and an assumed inflation rate if 3% per year
J-7.3 Well Field Equipment Installation Cost Page 6 of 16 402 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 315 of 381 Page ID #:13863
Final DNAPL Feasibilty Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.4 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Treatment Equipment Installation
Cost Unit Cost Item Direct Costs Quantity Cost Ref. Carbon Regen System Upgrade (from 5000-lb to vessels to 10000-lb vessels) 1$ 46,000 /LS $ 46,000 1 Polishing Carbon Vessel Upgrade (from 5000-lb to 10000-lb) 2$ 16,000 /Each$ 32,000 2 Additional Initial Carbon Fill (Virgin Coconut) 10,000$ 1.07 /lb $ 10,700 2 Oriface Plate and Transmitter 1$ 10,000 /Each$ 10,000 Moister Separator 1 $ 4,000 /Each$ 4,000 3 Transfer Pump (50 gpm) 1 $ 536 /Each $ 536 4 1000 SCFM Positive Displacement Blower (for PVS) 1$ 30,000 /Each$ 30,000 5 300 SCFM Liquid Ring Blower (Hi Vac for UBA) 0$ 45,980 /Each $ - 5 Inline Stack PID 0 $ 3,775 /Each $ - 6 Static Pressure Gage 34$ 8 /Each $ 144 4 Temperature Indicator 3 $ 127 /Each $ 381 4 Interconnecting Piping (10% of Blower, KO Tank, and Regen and Polishing Carbon Vessel Upgrade) 1$ 12,598 LS $ 12,598 Electrical Allowance (20% of elec components) 1 $ 8,107 LS $ 8,107 Control System Allowance (20% of elec components) 1 $ 8,107 LS $ 8,107 Treatment Plant Pad and Building 0-$ LS $ - 7 Subcontractor Installation Cost 1$ 10,000 LS$ 10,000 TOTAL TREATMENT EQUIPMENT INSTALLATION COST w/10% MARKUP$ 189,831
Cost Source Reference 1 Based on MEGTEC Systems, Inc. Quote Dated April 20, 2008 2 Based on July 1 2008 BakerCorp Quote 3 Verbal Quote from Enviro Supply and Services 4 Grainger Catalog Price 5 Yardley Pump and Vacuum Quote Dated July 16, 2008 6 Verbal Quote from RAE Systems 7 Based on Building/Lab Site Improvements Cost for 350 gpm LGAC Adsorber System in 1998 Joint Groundwater Feasibility Study for the Montrose and Del Amo Sites
J-7.4 Treatment Equipment Installation Cost Page 7 of 16 403 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 316 of 381 Page ID #:13864
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.5 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal (6 UBA PVs or 400 kW-hrs/cubic yard) Construction Management
Item Consultant Labor Quantity Unit Cost Cost 1 Project Manager 20$ 150 /Hour $ 3,000 2 Senior Engineer/Geologist 45 $ 125 /Hour $ 5,625 3 Mid-Level Engineer/Geologist 90 $ 100 /Hour $ 8,978 4 Junior/Field Engineer/Geologist 180 $ 75 /Hour $ 13,467 5 Field Technician 180 $ 75 /Hour $ 13,467 6 Clerical/Drafting 20 $ 50 /Hour $ 1,000 TOTAL CONSTRUCTION MANAGEMENT COST$ 45,538
J-7.5 Construction Management Cost Page 8 of 16 404 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 317 of 381 Page ID #:13865
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.6 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Annual Operations and Maintenance (Years 1 through 2)
Cost Unit Cost Item Consultant Labor (Operations) Quantity Cost Ref. 1 Project Manager 65 150$ /Hour $ 9,750 2 Senior Engineer/Geologist 65 125$ /Hour $ 8,125 3 Mid-Level Engineer/Geologist 130 100$ /Hour $ 13,000 4 Junior/Field Engineer/Geologist 260 75$ /Hour $ 19,500 5 Field Technician 075$ /Hour $ - 6 Clerical/Drafting 050$ /Hour $ - Consultant Labor Cost for Operations $ 50,375
Cost Unit Cost Item Consultant Labor (Reporting, H&S, and Data Mngt) Quantity Cost Ref. 7 Project Manager 40 150$ /Hour $ 6,000 8 Senior Engineer/Geologist 80 125$ /Hour $ 10,000 9 Mid-Level Engineer/Geologist 160 100$ /Hour $ 16,000 10 Junior/Field Engineer/Geologist 160 75$ /Hour $ 12,000 11 Field Technician 075$ /Hour $ - 12 Clerical/Drafting 160 50$ /Hour $ 8,000 Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance $ 52,000
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 13 Waste Management
a Additional Polishing VGAC and regen system VGAC change-outs Year 1 45,000 1.53$ /lb $ 68,625 1 Year 2 45,000 1.53$ /lb $ 68,625
b Additional Carbon Regen System Solvent Year 1 i Transportation 4 3,650$ /load $ 14,600 2 ii Disposal (Listed Waste for Incineration) 159,870 0.5$ /lb $ 79,935 2
Year 2 Transportation 1 3,650$ /load $ 3,650 Disposal (Listed Waste for Incineration) 35,000 0.5$ /lb $ 17,500
c Additional Boiler Water Pre-Treatment Brine and Blowdown i Transportation 7 950$ /10,000 gals $ 6,650 3 ii Disposal (non-Haz) 63,009 0.14$ /gal $ 8,821 3
Total Waste Management - Year 1 $ 178,631 Total Waste Management - Year 2 $ 105,246
J-7.6 Annual Operations and Maintenance (Years 1 and 2) Cost Page 9 of 16 405 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 318 of 381 Page ID #:13866
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.6 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Annual Operations and Maintenance (Years 1 through 2)
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 14 Lab Analytical and Monitoring a Summa Can Rental 48 40$ /Each $ 1,920 4 b Vapor VOCs Analysis (EPA TO-15) 48 200$ /Each $ 9,600 4 c Tedlar Bags 12 10$ /Each $ 120 Total Lab Analytical and Monitoring $ 11,640
15 Miscellaneous - Years 1 and 2 a Miscellaneous Parts 12 1,000$ /Month $ 12,000 b Fed Ex and Deliveries 12 100$ /Month $ 1,200 Total Miscellaneous - Years 1 and 2 $ 13,200 Cost Unit Cost Item Direct Cost Quantity Cost Ref. 16 Utilities a Natural Gas (additional Steam for Carbon Regen Unit) 77,740 1.14$ /therm $ 88,624 5 b Municipal Water (additional steam for Carbon Regen Unit) 750,528 0.0029$ /gal $ 2,177 c Electricity - PD Vacuum Blower 489,925 0.1045$ /kWh $ 51,197 6 Total Utilities $ 141,997
CONSULTANT LABOR COST $ 102,375 SUBCONTRACTOR COST w/10% MARKUP - YEAR 1 $ 223,818 SUBCONTRACTOR COST w/10% MARKUP - YEAR 2 $ 143,095 UTILITIES COST (NO MARKUP) $ 141,997 TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 1 $ 468,191 TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 2 $ 387,467
Cost Source Reference 1 Based on carbon costs associated with the Montrose Henderson SVE System 2 Clean Harbors Quote Dated October 10, 2007 3 NRC Environmental Services, Inc. Email Quote Dated June 30, 2008 4 Verbal Quote from Calscience 5 GN-10, Tier III, SoCal Gas Co. Rate (Effective May 1, 2008) 6 Shedule A-3 LADWP Rate (Second Quarter 2008)
J-7.6 Annual Operations and Maintenance (Years 1 and 2) Cost Page 10 of 16 406 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 319 of 381 Page ID #:13867
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.7 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Annual Operations and Maintenance (Years 3 through 4)
Cost Unit Cost Item Consultant Labor (Operations) Quantity Cost Ref. 1 Project Manager 52$ 150 /Hour$ 7,800 2 Senior Engineer/Geologist 52$ 125 /Hour$ 6,500 3 Mid-Level Engineer/Geologist 208$ 100 /Hour$ 20,800 4 Junior/Field Engineer/Geologist 520$ 75 /Hour$ 39,000 5 Field Technician 1,040$ 75 /Hour $ 78,000 6 Clerical/Drafting 050$ /Hour $ - Consultant Labor Cost for Operations $ 152,100
Cost Unit Cost Item Consultant Labor (Reporting, H&S, and Data Mngt) Quantity Cost Ref. 7 Project Manager 40$ 150 /Hour$ 6,000 8 Senior Engineer/Geologist 80$ 125 /Hour$ 10,000 9 Mid-Level Engineer/Geologist 160$ 100 /Hour$ 16,000 10 Junior/Field Engineer/Geologist 160$ 75 /Hour$ 12,000 11 Field Technician 075$ /Hour$ - 12 Clerical/Drafting 160$ 50 /Hour $ 8,000 Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance $ 52,000
J-7.7 Annual Operations and Maintenance (Years 3 through 4) Cost Page 11 of 16 407 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 320 of 381 Page ID #:13868
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.7 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Annual Operations and Maintenance (Years 3 through 4)
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 13 Turnkey VGAC Change-Out Service (incl. fresh VGAC and T&D of spent VGAC as Haz)
b Year 3 100,000$ 1.53 /lb VGAC$ 152,500 1 c Year 4 60,000$ 1.53 /lb VGAC$ 91,500 1
14 Final Spent VGAC (40,000 lbs) Transportation and Disposal 40,000$ 0.46 /lb VGAC $ 18,200 1
Total VGAC (Year 3) $ 152,500 Total VGAC (Year 4) $ 109,700
15 Lab Analytical and Monitoring a Summa Can Rental 84$ 40 /Each $ 3,360 2 b Vapor VOCs Analysis (EPA TO-15) 84$ 200 /Each $ 16,800 2 c Tedlar Bags 12$ 10 /Each $ 120 Total Lab Analytical and Monitoring $ 20,280
J-7.7 Annual Operations and Maintenance (Years 3 through 4) Cost Page 12 of 16 408 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 321 of 381 Page ID #:13869
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.7 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Annual Operations and Maintenance (Years 3 through 4)
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 16 Miscellaneous - Years 3 through 4 a Temporary Office 24'x60' Rental 12$ 1,030 /Month$ 12,356 3 b Temporary Storage Trailer 12$ 149 /Month$ 1,784 4 c Portable Toilet Rental 12$ 76 /Month$ 908 5 d Miscellaneous Parts 12$ 1,000 /Month$ 12,000 e Fed Ex and Deliveries 12$ 100 /Month$ 1,200 f Temporary office comm. (internet, telephone, fax) 12$ 1,000 /Month$ 12,000 g Operator Truck Usage (One Truck per Operator) 260$ 100 /Day/Truck $ 26,000 Total Miscellaneous - Years 2 through 4 $ 66,248
Total Subcontractor Cost - Year 3 $ 239,028 Total Subcontractor Cost - Year 4 $ 196,228
Cost Unit Cost Item Utilities Quantity Cost Ref. 17 Utilities Electricity - PD and Liquid Ring Vacuum Blowers 1,143,158$ 0.1045 /kWh $ 119,460 6 Total Utilities $ 119,460
CONSULTANT LABOR COST $ 204,100
SUBCONTRACTOR COST w/10% MARKUP - YEAR 3 $ 262,931 SUBCONTRACTOR COST w/10% MARKUP - YEAR 4 $ 215,851 UTILITIES COST (NO MARKUP) $ 119,460
TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 3 $ 586,491 TOTAL OPERATIONS AND MAINTENANCE COST - YEAR 4 $ 539,411
Cost Source Reference 1 Based on carbon costs associated with the Montrose Henderson SVE System 2 Verbal Quote from Calscience 3 Mobile Mini, Inc. Quote Dated October 11, 2007 4 Verbal Quote from Mobile Mini, Inc. 5 Verbal Quote from A-1 Coast Port-A-Toilet 6 Shedule A-3 LADWP Rate (Second Quarter 2008)
J-7.7 Annual Operations and Maintenance (Years 3 through 4) Cost Page 13 of 16 409 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 322 of 381 Page ID #:13870
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.8 Detailed Cost, Unsatuared Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Well Abandonment
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 10 150$ /Hour $ 1,500 2 Senior Engineer/Geologist 20 125$ /Hour $ 2,500 3 Mid-Level Engineer/Geologist 20 100$ /Hour $ 2,000 4 Junior/Field Engineer/Geologist 80 75$ /Hour $ 6,000 5 Field Technician 20 75$ /Hour $ 1,500 6 Clerical/Drafting 20 50$ /Hour $ 1,000 Total Consultant Labor Cost $ 14,500
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref.
7 Mobilization/Demobilization of Drill Rig 1$ 2,000 /LS $ 2,000 1
8 Abandon PVS SVE Wells a Drill out well materials 5 65$ /Foot $ 325 1 b Pressure grout well 45 30$ /Foot $ 1,350 1 c Forklift and mini-hopper 0.5 500$ /Day $ 250 1 d Abandonment Crew per Diem 0.5 200$ /Night $ 100 1 e Vehicle Usage 0.5 100$ /Day $ 50 f Equipment Rental and Supplies 0.5 150$ /Day $ 75 g Other Direct Costs 0.5 150$ /Day $ 75 Cost per Well $ 2,225 Number of Wells (2 Wells Abandoned per Day) 7 Total for Extraction Well Adandonment 15,575
J-7.8 Well Abandonment Cost Page 14 of 16 410 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 323 of 381 Page ID #:13871
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (with Thermal) Los Angeles, California June 2013 Appendix J Table 7.8 Detailed Cost, Unsatuared Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Well Abandonment
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 9 Abandon UBA SVE Wells a Drill out well materials 5 65$ /Foot $ 325 1 b Pressure grout well 60 30$ /Foot $ 1,800 1 c Forklift and mini-hopper 0.5 500$ /Day $ 250 1 d Abandonment Crew per Diem 0.5 200$ /Night $ 100 1 e Vehicle Usage 0.5 100$ /Day $ 50 f Equipment Rental and Supplies 0.5 150$ /Day $ 75 g Other Direct Costs 0.5 150$ /Day $ 75 Cost per Well $ 2,675 Number of Wells (2 Wells Abandoned per Day) 5 Total for Injection Well Abandonment 13,375 Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 10 Waste Management a Waste Tank Rental 36 38$ /Day $ 1,368 2 b Waste Tank Rental Delivery - Mob and Demob 1 900$ /Each $ 900 2 c Waste Bin Rental 36 15$ /Day $ 540 2 d Waste Bin Rental Delivery - Mob and Demob 2 500$ /Each $ 1,000 2 e Transport and Disposal/Recycling of Steel 1$ 1,100 /Load $ 1,100 f Transport of Hazardous Soil Cuttings 1$ 1,100 /Each $ 1,100 2 g Disposal of Hazardous Soil Cuttings 3.71 550$ /Ton $ 2,040 2 h Transport of Hazardous Water 1$ 1,100 /Each $ 1,100 2 i Disposal of Hazardous Water 1200 0.8$ /Gal $ 960 2 j Waste Characterization/Profiling 2 500$ /Each $ 1,000 Total Waste Management $ 11,108 Total Subcontractor Cost w/10% Markup $ 46,264
TOTAL WELL ABANDONMENT COST $ 60,764
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Verbal Quote from NRC Environmental Services
J-7.8 Well Abandonment Cost Page 15 of 16 411 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 324 of 381 Page ID #:13872
Final DNAPL Feasibility Study Montrose Superfund Site Unsaturated Zone SVE (Coupled with Thermal Remedy) Los Angeles, California June 2013 Appendix J Table 7.9 Detailed Cost, Unsaturated Zone SVE Coupled with Focused Treatment Area Thermal - 6 UBA PVs or 400 kW-hrs/cubic yard Demobilization
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 8$ 150 /Hour $ 1,200 2 Senior Engineer/Geologist 20$ 125 /Hour $ 2,500 3 Mid-Level Engineer/Geologist 40$ 100 /Hour $ 4,000 4 Junior/Field Engineer/Geologist 120$ 75 /Hour $ 9,000 5 Field Technician 50$ 75 /Hour $ 3,750 6 Clerical/Drafting 20$ 50 /Hour $ 1,000 Consultant Labor Cost $ 21,450
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 Remove Purchased Treatment Equipment 1 41,000 /LS $ 41,000
8 Demob Office Trailer 1$ 1,746 LS $ 1,746 1
9 Close-Out Borings a Drilling and backfilling (6-Inch Sonic to 45 feet bgs at $65/foot) 3$ 2,925 /Boring $ 8,775 2 b Drilling and backfilling (6-Inch Sonic to 60 feet bgs at $65/foot) 2$ 3,900 /Boring $ 7,800 2 c Disposal of Hazardous Soil Cuttings 3.0 $ 550 /Ton $ 1,651 3 d Transportation of Hazardous Soil Cuttings 1$ 1,100 /Each $ 1,100 3 e Waste Bin Rental Delivery - Mob and Demob 1 $ 500 /Each $ 500 3 f Waste Bin Rental 30 $ 15 /Day $ 450 3 g Soil Pesticides (EPA Method 8081A) 10 $ 90 /Sample $ 900 4 h Soil VOCs (EPA Method 8260B) 10 $ 95 /Sample $ 950 4 i Soil pCBSA (Modified EPA Method 314.0) 10 $ 80 /Sample $ 800 4 Total for Close-Out Borings $ 22,926
Total Subcontractor Cost w/10% Markup $ 72,240
TOTAL DEMOBILIZATION COST $ 93,690
Cost Source Reference 1 Mobile Mini, Inc. Quote Dated October 11, 2007 2 Water Development Corporation Quote Dated 10/09/08 3 Verbal Quote from NRC Environmental Services 4 Verbal Quote from Test America
J-7.9 Demobilization Cost Page 16 of 16 412 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 325 of 381 Page ID #:13873
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.0 Cost Summary ERH (200 kW-hrs/cubic yard) Focused Treatment Area
Cost (NPV) Cost Year Activity Detailed Cost Table DR = 4% DR = 7% (Undiscounted) 1 Focused Treatment Design J-13.1 Design and Permitting Cost $ 1,160,300 $ 1,115,673 $ 1,084,393 J-13.2 Well Construction $ 3,996,515 J-13.3 Well Field Equipment Installation $ 2,170,154 2 Focused Treatment Build J-13.4 Instrumentation and Controls Installation $ 64,124 $ 9,050,943 $ 8,550,529 J-13.5 Treatment Equipment Installation $ 3,160,979 J-13.6 Construction Management $ 397,728 3 Focused Treatment Operation and Maintenance J-13.7 Operations and Maintenance $ 6,063,104 $ 5,390,077 $ 4,949,299 J-13.8 Well Abandonment $ 1,411,846 4 Verification and Abandonment $ 1,819,759 $ 1,624,098 J-13.9 Demobilization $ 717,015
Totals $ 19,141,765 $ 17,376,453 $ 16,208,318
Notes DR = Discount rate NPV = Net present value
J-13.0 Cost Summary Page 1 of 24 413 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 326 of 381 Page ID #:13874
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.1 Detailed Cost, ERH (200 kW-hrs/cubic yard) Design and Permitting
Cost Unit Cost Item Consultant Labor Quantity Cost Ref. 1 Project Manager 790 150$ /Hour$ 118,500 2 Senior Engineer/Geologist 1,170 125$ /Hour$ 146,250 3 Mid-Level Engineer/Geologist 4,600 100$ /Hour$ 460,000 4 Junior/Field Engineer/Geologist 3,310 75$ /Hour$ 248,250 5 Field Technician 0 75$ /Hour $ - 6 Clerical/Drafting 1,106 50$ /Hour $ 55,300 Consultant Labor $ 1,028,300
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 1 Outside Thermal Expert 1$ 120,000 /LS $ 120,000
Subcontractor Cost w/10% Markup $ 132,000
TOTAL DESIGN AND PERMITTING COST$ 1,160,300
J-13.1 Design and Permitting Cost Page 2 of 24 414 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 327 of 381 Page ID #:13875
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 13.2 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Construction
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 507 150$ /Hour $ 76,050 2 Senior Engineer/Geologist 507 125$ /Hour $ 63,375 3 Mid-Level Engineer/Geologist 1,352 100$ /Hour$ 135,200 4 Junior/Field Engineer/Geologist 3,050 75$ /Hour$ 228,750 5 Field Technician 482 75$ /Hour $ 36,150 6 Clerical/Drafting 507 50$ /Hour $ 25,350 Total Consultant Labor Cost $ 564,875
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 Abandon Existing Site Wells Prior to Thermal Treatment a Drill out well materials 90 65$ /Foot $ 5,850 1 b Grout resulting boring 90 30$ /Foot $ 2,700 1 c Forklift and mini-hopper 1 500$ /Day $ 500 1 d Excavate and remove well box 1 2,000$ /LS $ 2,000 1 e Abandonment Crew per Diem 1 200$ /Night $ 200 f Vehicle Usage 1 100$ /Day $ 100 g Equipment Rental and Supplies 1 150$ /Day $ 150 h Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 11,650 Number of Wells 5 Total for Existing Site Well Abandonment $ 58,250
J-13.2 Well Construction Cost Page 3 of 24 415 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 328 of 381 Page ID #:13876
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 13.2 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 8 UBA Multi-Phase Extraction Wells (12" HSA Drilling to 108' bgs) a Install Well Constructed of 6" LCS Casing w/ 60' of SS Screen and 3-foot Sump, Type II Cement Grout, and Sand Pack 1$ 12,000 /Each$ 12,000 2 b Forklift and Hopper Rental for Waste Handling 1 250$ /Day $ 250 2 c Drill Crew per Diem 1 450$ /Night $ 450 2 d Vehicle Usage 1 100$ /Day $ 100 e Equipment Rental and Supplies 1 500$ /Day $ 500 f Installation Permit 1 201$ /Well $ 201 g Other Direct Costs 1 300$ /Day $ 300 Cost per Well $ 13,801 Number of Wells (1 Well Installed per Day) 66 Subtotal - UBA Multi-Phase Extraction Wells $ 910,866
9 Lab Analytical (Sixteen UBA Multi-Phase Extraction Well Borings) a Soil Analysis - Pesticides (EPA Method 8081A) 54 90$ /Sample$ 4,860 3 b Soil Analysis - VOCs (EPA Method 8260B) 54 95$ /Sample$ 5,130 3 c Soil Analysis - pCBSA (Modified EPA Method 314.0) 54 80$ /Sample$ 4,320 3 d Water Analysis - Pesticides (EPA Method 8081A) 9 90$ /Sample $ 810 3 e Water Analysis - VOCs (EPA Method 8260B) 9 95$ /Sample $ 855 3 f Water Analysis - pCBSA (Modified EPA Method 314.0) 9 80$ /Sample $ 720 3 Total Lab Analytical (UBA Extraction Wells) $ 16,695
J-13.2 Well Construction Cost Page 4 of 24 416 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 329 of 381 Page ID #:13877
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 13.2 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 10 Electrode Wells (15" HSA Drilling to 105' bgs) a Drill Rig, Crew, and Support Equipment 1 4,000$ /Each $ 4,000 4 b Cement Backfill Material 54 30$ /Foot $ 1,620 4 c Sand Backfill Material 51 20$ /Foot $ 1,020 4 d Drill Crew per Diem 1 450$ /Night $ 450 4 e Forklift and Hopper Rental for Waste Handling 1 250$ /Day $ 250 4 f Plastic Sheeting and Hole Prep 125$ /Well $ 25 4 g 5% Fuel Surcharge 1 368$ /Day $ 368 4 h Vehicle Usage 1 100$ /Day $ 100 i Equipment Rental and Supplies 1 500$ /Day $ 500 j Installation Permit 1 201$ /Well $ 201 k Other Direct Costs 1 300$ /Day $ 300 Cost per Well $ 8,834 Number of Wells (1 Well Installed per Day) 102 Subtotal - Electrode Wells $ 901,094
11 Develop UBA Multi-Phase Extraction Wells a Development Rig 1 2,000$ /Day $ 2,000 2 b Development Crew per Diem 1 200$ /Night $ 200 2 Cost per Well $ 2,200 Number of Wells (1 Well Developed per Day) 66 Subtotal - Develop UBA Wells $ 145,200
J-13.2 Well Construction Cost Page 5 of 24 417 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 330 of 381 Page ID #:13878
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 13.2 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 12 Mobilization/Demobilization of Mud Rotary Drill Rig 1$ 12,000 /Each $ 12,000 4
13 Hot Floor Multi-Phase Extraction Wells a Move Between Well Locations 1 2,000$ /Each $ 2,000 5 b Install 14", .25" Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout 110 220$ /Foot $ 24,200 5 c Mud Change-Out and Pit Decon 1 2,000$ /Each $ 2,000 5 d 12" Boring Under Conductor 8.5 80$ /Foot $ 680 5 e Install 6" Low Carbon Steel Sched. 40 Casing 110.5 88$ /Foot $ 9,724 5 f Install 6" Type 304 Stainless Steel Screen with 3' Sump 8 175$ /Foot $ 1,400 5 g Type II Cement Grout and Sand Pack 118.5 30$ /Foot $ 3,555 5 h Forklift and Hopper Rental for Waste Handling 4 400$ /Day $ 1,600 5 i Standby for Cement Curing 6 550$ /Hour $ 3,300 5 j Well Development 10 165$ /Hour $ 1,650 5 k Vehicle Usage 4 100$ /Day $ 400 l Equipment Rental and Supplies 4 500$ /Day $ 2,000 m Installation Permit 1 201$ /Well $ 201 n Other Direct Costs 4 300$ /Day $ 1,200 Cost per Well $ 53,910 Number of Wells (4 Days per Well for Installation and Development) 0 Subtotal - Hot Floor Multi-Phase Extraction Wells $ -
J-13.2 Well Construction Cost Page 6 of 24 418 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 331 of 381 Page ID #:13879
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 13.2 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 14 Hot Floor Steam Injecton Wells a Move Between Well Locations 1 2,000$ /Each $ 2,000 5 b Install 10", .25" Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout 110 180$ /Foot $ 19,800 5 c Mud Change-Out 1 1,500$ /Each $ 1,500 5 d 9" Boring Under Conductor 5.5 75$ /Foot $ 413 5 e Install 2" Low Carbon Steel Sched. 40 Casing 110.5 45$ /Foot $ 4,973 5 f Install 2" Type 304 Stainless Steel Screen 5 90$ /Foot $ 450 5 g Type II Cement Grout and Sand Pack 115.5 20$ /Foot $ 2,310 5 h Forklift and Hopper Rental for Waste Handling 4 400$ /Day $ 1,600 5 i Standby for Cement Curing 5 550$ /Hour $ 2,750 5 j Well Development 6 165$ /Hour $ 990 5 k Vehicle Usage 4 100$ /Day $ 400 l Equipment Rental and Supplies 4 500$ /Day $ 2,000 m Installation Permit 1 201$ /Well $ 201 n Other Direct Costs 4 300$ /Day $ 1,200 Cost per Well $ 40,586 Number of Wells (4 Days per Well for Installation and Development) 0 Subtotal - Hot Floor Steam Injecton Wells $ -
J-13.2 Well Construction Cost Page 7 of 24 419 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 332 of 381 Page ID #:13880
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 13.2 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 15 Temperature Monitoring Points (7" HAS Drilling to 105' bgs) a Move Between Well Locations 1 4,000$ /Each $ 4,000 b Install 10", .25 Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout 0 180$ /Foot $ - c Mud Change-Out 0 1,500$ /Each $ - d 8" Boring Under Conductor 075$ /Foot $ - e Install 1.5" Low Carbon Steel Casing with Bottom Cap 105 40$ /Foot $ 4,200 f Type II Cement Grout 105 20$ /Foot $ 2,100 g Forklift and Hopper Rental for Waste Handling 1 250$ /Day $ 250 h Standby for Cement Curing 0 550$ /Hour $ - i Vehicle Usage 1 100$ /Day $ 100 j Equipment Rental and Supplies 1 500$ /Day $ 500 k Installation Permit 1 201$ /Well $ 201 i Other Direct Costs 1 300$ /Day $ 300 Subtotal $ 11,651 Number of Wells (3 Days per Point - no Development Needed) 14 Subtotal - Temperature Monitoring Points $ 163,114
16 BFS Monitoring Wells a Well Installation (4 Days per Well for Installation and Development) 2$ 54,000 /Well $ 108,000 1 b Installation Permit 2 201$ /Well $ 402 Subtotal - BFS Monitoring Wells $ 108,402
J-13.2 Well Construction Cost Page 8 of 24 420 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 333 of 381 Page ID #:13881
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 13.2 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 17 Waste Management a Waste Tank Rental 290 38$ /Day $ 11,020 6 b Waste Tank Rental Delivery - Mob and Demob 1 900$ /Each $ 900 6 c Waste Bin Rental 1762 15$ /Day $ 26,430 6 d Waste Bin Rental Delivery - Mob and Demob 58 500$ /Each $ 29,000 6 e Transport of Hazardous Soil Cuttings 58 1,100$ /Each $ 63,800 6 f Disposal of Hazardous Soil Cuttings 1178 550$ /Ton $ 647,900 6 g Transport of Hazardous Mud 0 500$ /Each $ - 6 h Disposal of Hazardous Mud 0 1.1$ /Gal $ - 6 i Transport of Hazardous Water 6 1,100$ /Each $ 6,600 6 j Disposal of Hazardous Water 21753 0.8$ /Gal $ 17,402 6 k Waste Characterization/Profiling 2 500$ /Each $ 1,000 Subtotal - Waste Management $ 804,052 Total Subcontractor Cost w/10% Markup $ 3,431,640
TOTAL WELL CONSTRUCTION COST $ 3,996,515
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Cascade Drilling, Inc. Quote Dated 7/15/08 3 Verbal Quote from Test America 4 Cascade Drilling, Inc. Quote Dated 8/01/08 5 Water Development Corporation Quote Dated 4/25/08 6 Verbal Quote from NRC Environmental
J-13.2 Well Construction Cost Page 9 of 24 421 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 334 of 381 Page ID #:13882
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.3 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Field Equipment Installation
Cost Item Unit Cost Consultant Labor and Direct Costs Quantity Cost Ref. 1 Electrical Service Upgrade 1$ 50,000 LS $ 50,000
2 Natural Gas Pipeline 1$ 200,000 LS $ 200,000
3 Electrode Well Equipment and Piping a Electrodes (3 per Electrode Well) 306 $ 1,500 Each $ 459,000 1 b Armored Electrical Cable 2380$ 4.89 Foot $ 11,638 2 c 1.5-Inch Carbon Steel Pipe and Fittings for Recirc Water Delivery 2380$ 12.00 LF $ 28,560 Total Electrode Well Equipment$ 499,198
4 Groundwater Extraction Assemblies a Well Head Assemblies 66$ 1,000 Each$ 66,000 b Extraction Pump (High Temperature Hammerhead Pro) 66$ 3,070 Each$ 202,620 3 c Downwell Air Supply Hose (3/8" SS Brainded, Teflon Lined) 6600$ 11 LF$ 72,600 3 d Downwell Air Exhaust Hose (1/2" SS Brainded, Teflon Lined) 6600$ 16 LF$ 105,600 3 e Downwell Discharge Hose (1/4" SS Brainded, Teflon Lined) 6600 $ 22 LF$ 145,200 3 Total Groundwater Extraction Assemblies $ 592,020
5 Steam Injection Well Head Assemblies 0$ 7,000 Each $ -
6 Field Technician - Pump and Well Head Assembly Construction and Installation (Consultant Labor - Not Subject to Markup) 1,370$ 75 Hour $ 102,750
7 Steam Injection Piping a 6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 0 $ 67.65 LF$ - 4 b 4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 0$ 43.45 LF$ - 4 c 2-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 0$ 34.10 LF$ - 4 Total Steam Injection Piping $ -
8 Vapor Extraction Piping a 8-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 605$ 94.71 LF$ 57,300 5 b 6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 1810$ 67.65 LF$ 122,447 4 c 4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 677$ 43.45 LF$ 29,416 4 Total Vapor Extraction Piping $ 209,162
J-13.3 Well Field Equipment Installation Cost Page 10 of 24 422 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 335 of 381 Page ID #:13883
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.3 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Field Equipment Installation
Cost Item Unit Cost Consultant Labor and Direct Costs Quantity Cost Ref.
9 Groundwater Extraction Piping a 4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 605$ 43.45 LF$ 26,287 4 b 2-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 1810$ 34.10 LF$ 61,721 4 c 1.5-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 677$ 31.45 LF$ 21,292 4 d Total Piping Length 3092 LF e Piping Heat Trace, VLBTV Wire 3092$ 15.75 LF$ 48,699 6 f Misc fittings and heat trace elements (30% of Groundwater Extraction Piping cost) 1$ 47,399.67 LS$ 47,400 Total Groundwater Extraction Piping $ 205,399
10 Compressed Air Pipe and Fittings (2-Inch Carbon Steel) 3092$ 20.00 LF $ 61,840 4
11 Pipe Supports 309.2 $ 200 LF $ 61,840
CONSULTANT LABOR COST $ 102,750 DIRECT COSTS w/10% MARKUP $ 2,067,404 TOTAL WELL FIELD EQUIPMENT INSTALLTION COST $ 2,170,154
Cost Source Reference 1 Verbal Quote from McMillan-McGee Corp. 2 McMaster-Carr Catalog Price 3 QED Environmental Systems, Inc. Quote Dated May 16, 2008 4 2007 RS Means Database. Unit price shown includes 10% inflation rate and local area cost factor. 5 Unit rate assumed to be approximately 40% higher than rate for 6-inch carbon steel pipe and fittings with fiberglass insulation and aluminum jacket. 6 2006 Raychem quote obtained by CH2MHILL
J-13.3 Well Field Equipment Installation Cost Page 11 of 24 423 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 336 of 381 Page ID #:13884
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.4 Detailed Cost, ERH (200 kW-hrs/cubic yard) Instrumentation and Controls Installation
Cost Unit Cost Item Consultant Labor and Direct Costs Quantity Cost Ref.
1 Steam Injection Wells a Pressure Gage (0-300 PSI) 04$ 8 /Each -$ 1 b Temperature Indicator 0$ 127 /Each -$ 1 c Orifice Plate and Transmitter 0$ 10,000 /Each -$ Total Steam Injection Wells and Piping I&Cs -$
2 Groundwater Exraction Pressure Gage (0-300 PSI) 66 $ 48 /Each 3,168$ 1
3 Vapor Extraction Vacuum Gage (30 in Hg) 66$ 50 /Each 3,326$ 1
4 Thermocouple String a Type T Thermocouple Wire (24 Gauge w/Fiberglass Insulation and Jacket) 1,400$ 0.75 /Foot 1,050$ 2 b Analog Decoder 1$ 500 /Each 500$ Cost per Temp Monitoring Point 1,550$ Number of Temperature Monitoring Points 14 Total Thermocouple String 21,700
5 Field Technician - Installation of Items 1 Through 4 (Instrumentation and Controls) 152 $ 75 /Hour 11,400$ (Consultant Labor - Not Subject to Markup)
6 Electrical Allowance (20% of Instrumentation and Controls cost) 1$ 8,458 /LS 8,458$
7 Control System Allowance (30% of Instrumentation and Controls cost) 1$ 11,278 /LS 11,278$
CONSULTANT LABOR COST 11,400$ DIRECT COSTS w/10% MARKUP 52,724$ TOTAL INSTRUMENTATION AND CONTROLS INSTALLATION COST 64,124$
Cost Source Reference 1 Grainger Catalog Price 2 McMaster-Carr Catalog Price
J-13.4 Instrumentation and Controls Installation Cost Page 12 of 24 424 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 337 of 381 Page ID #:13885
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.5 Detailed Cost, ERH (200 kW-hrs/cubic yard) Treatment Equipment Installation
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 1 Vapor Treatment a 12,000-gallon Brine Holding Tank 1$ 18,538 /Each$ 18,538 1 b Fin-Fan Heat Exchanger 1$ 14,306 /Each$ 14,306 2 c Steam-Regenerable Carbon System (incl. two 5,000-lb GAC vessels, condenser, separator, and inline stack PID) 1$ 750,000 /LS$ 750,000 3 d 2MM BTUs/Hr Steam Generator (Gas Fired) 1$ 5,000 /Each$ 5,000 e Water Softening Unit for Steam Generator 1$ 5,000 /Each$ 5,000 f Interconnecting Piping (20% of Steam-Regen Carbon System cost) 1$ 150,000 /LS$ 150,000 g 5000-lb Polishing Vapor-Phase GAC Vessel 2$ 16,000 /Each$ 32,000 4 h Orifice Plate and Transmitter 2$ 10,000 /Each$ 20,000 i 1000 SCFM Liquid Ring Vacuum Blower (standard cast iron construction) 2$ 80,000 /Each$ 160,000 5 j Moisture Separator 1$ 4,000 /Each$ 4,000 6 k 500-Gallon Collection Tank 1$ 2,078 /Each$ 2,078 1 l Transfer Pump (50 gpm) 9 $ 536 /Each$ 4,820 7 Total for Vapor Treatment $ 1,165,742
2 Groundwater Exraction and Treatment a Shell and Tube Heat Exchanger 1$ 22,112 /Each$ 22,112 8 b DNAPL/Water Separator 2$ 56,450 /Each$ 112,900 9 c Groundwater Holding Tank 1$ 50,000 /Each$ 50,000 d Two 3,000-lb Liquid-Phase GAC Vessels Each w/Initial Virgin Coconut Shell GAC Fill 1$ 16,830 LS $ 16,830 10 e Air Compressor 1$ 20,000 /Each$ 20,000 11 f 500-Gallon Collection Tank 1$ 2,078 /Each$ 2,078 1 g Cooling Tower (540 gpm Recirculation Rate) 1$ 37,713 /Each$ 37,713 12 h Transfer Pump (50 gpm) 8 $ 536 /Each$ 4,284 7 i Transfer Pump (540 gpm) 2$ 2,756 /Each$ 5,513 13 j Transfer Pump (145 gpm) 2$ 1,348 /Each$ 2,696 7 k HiPOx System (50 gpm) 1$ 768,750 /Each$ 768,750 14 Total for Groundwater Exraction and Treatment Equipment $ 1,042,876
J-13.5 Treatment Equipment Installation Cost Page 13 of 24 425 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 338 of 381 Page ID #:13886
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.5 Detailed Cost, ERH (200 kW-hrs/cubic yard) Treatment Equipment Installation
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 3 Equipment Pads and Containment 1$ 150,000 /LS $ 150,000 11 4 80' X 110' Treatment Plant Building 1$ 150,000 /LS $ 150,000 5 Subcontractor Installation Cost 1$ 365,000 /LS $ 365,000 15
TOTAL TREATMENT EQUIPMENT INSTALLATION COST w/10% MARKUP $ 3,160,979
Cost Source Reference 1 Harrington Plastic Catalog Price 2 Heat Exchanger Sales and Engineering Company, LLC Quote Dated July 17, 2008 3 MEGTEC Systems, Inc. Quote Dated April 20, 2008 4 BakerCorp Quote Dated July 1, 2008 5 Yardley Pump and Vacuum Quote Dated July 18, 2008 6 Verbal Qoute from Enviro Supply and Services 7 Grainger Catalog Price 8 SEC Heat Exchanger Quote Dated July 1, 2008 9 Pan America Environmental Quote Dated July 28, 2008 10 BakerCorp Quoted Dated July 23, 2008 11 McMillan-McGee November 2006 Feasibility Study for Steam Injection, Page 34 12 Cooling Tower Systems Quote Dated July 2, 2008 13 McMaster-Carr Catalog Price 14 Unit price scaled down to a 75 gpm system from $2,050,000 quote from Applied Process Technologies (June 6, 2006) for a 200 gpm system. 15 Verbal Quote from J.C. Palomar Construction, Inc.
J-13.5 Treatment Equipment Installation Cost Page 14 of 24 426 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 339 of 381 Page ID #:13887
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.6 Detailed Cost, ERH (200 kW-hrs/cubic yard) Construction Management
Item Consultant Labor Quantity Unit Cost Cost 1 Project Manager 195$ 150 /Hour$ 29,250 2 Senior Engineer/Geologist 400$ 125 /Hour$ 50,000 3 Mid-Level Engineer/Geologist 1,062$ 100 /Hour$ 106,200 4 Junior/Field Engineer/Geologist 1,365$ 75 /Hour$ 102,375 5 Field Technician 1,365$ 75 /Hour$ 102,375 6 Clerical/Drafting 151$ 50 /Hour 7,528$ TOTAL CONSTRUCTION MANAGEMENT COST $ 397,728
J-13.6 Construction Management Cost Page 15 of 24 427 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 340 of 381 Page ID #:13888
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.7 Detailed Cost, ERH (200 kW-hr/cubic yard) Operations and Maintenance
Cost Unit Cost Item Consultant Labor (Operations) Quantity Cost Ref. 1 Project Manager 520 150$ /Hour $ 78,000 2 Senior Engineer/Geologist 520 125$ /Hour $ 65,000 3 Mid-Level Engineer/Geologist (One Full Time Mid-Level Engineer) 2,080 100$ /Hour $ 208,000 4 Junior/Field Engineer/Geologist (One Full Time Junior Engineer) 2,080 75$ /Hour $ 156,000 5 Field Technician (Three Full Time Operators - 40 Hours per Week Each) 6,240 75$ /Hour $ 468,000 6 Clerical/Drafting 520 50$ /Hour $ 26,000 Consultant Labor Cost for Operations $ 1,001,000
Cost Unit Cost Item Consultant Labor (Reporting, H&S, Data Mngt, and Website Maintenance) Quantity Cost Ref. 7 Project Manager 20 150$ /Hour $ 3,000 8 Senior Engineer/Geologist 80 125$ /Hour $ 10,000 9 Mid-Level Engineer/Geologist 1,300 100$ /Hour $ 130,000 10 Junior/Field Engineer/Geologist 2,080 75$ /Hour $ 156,000 11 Field Technician 075$ /Hour $ - 12 Clerical/Drafting 180 50$ /Hour $ 9,000 Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance $ 308,000
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 13 Equipment Rentals a 12-million BTUs/hr Low NOx Steam Generator (incl. water softening package) 0 18,500$ /Month $ - 1 Total Equipment Rentals $ -
14 Consumables (Excluding Utilities) a Salt for Steam Generator Feed Water Treatment 52 100$ /Week $ 5,200 b Virgin Coconut Shell Vapor-Phase Carbon (7,000-lbs of polishing GAC per month plus 10,000 lbs of regen system carbon changed-out after six months) 94,000 1.07$ /lb $ 100,580 2 c Vapor-Phase Carbon Change-Out Service 10 1,739$ /Change-Out $ 17,390 2 d Hydrogen Peroxide for HiPOx 166,650 3.00$ /Gal $ 499,950 e Oxygen for HiPOx 1,165,100 0.35$ /100 SCF $ 407,785 f 3000-lb Liquid-Phase Carbon Change-Out (Includes T&D as Hazardous Waste) 48 6,746$ /Each $ 323,808 3 Total Consumables $ 1,354,713
J-13.7 Operations and Maintenance Cost Page 16 of 24 428 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 341 of 381 Page ID #:13889
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.7 Detailed Cost, ERH (200 kW-hr/cubic yard) Operations and Maintenance
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 15 Waste Management a Vapor-Phase GAC Disposal (Listed Waste for Incineration) (incl. 10,000 lbs of regen system carbon at year end) 80,000 0.71$ /lb $ 56,800 4 b Vapor-Phase GAC Transportation 5 4,286$ /Load $ 21,430 4 c Carbon Regen System Solvent Waste Disposal (Listed Waste for Incineration) 169,500 0.50$ /lb $ 84,750 5 d Carbon Regen System Solvent Waste Transportation - inlcude pre heat transport 5 3,650$ /Load $ 18,250 5 e Filtration Generated Waste Disposal (Listed Waste for Incineration) 39,300 0.25$ /lb $ 9,825 5 f Filtration Generated Waste Transportation 3 2,800$ /Load $ 8,400 5 g Boiler Water Pre-Treatment Brine and Blowdown Off-Site Disposal (non-Haz) 43,526 0.14$ /Gal $ 6,094 6 h Boiler Water Pre-Treatment Brine and Blowdown Transportation 5 950$ /10,000 Gals $ 4,750 6 Total Waste Management $ 210,299
16 Lab Analytical and Monitoring a Summa Can Rental 288 40$ /Each $ 11,520 7 b Vapor VOCs Analysis (EPA Method TO-15) 288 200$ /Each $ 57,600 7 c Liquid Pesticides (EPA Method 8260B) 288 90$ /Each $ 25,920 8 d Liquid VOC Analysis (EPA Method 8081A) 288 95$ /Each $ 27,360 8 e Liquid pCBSA Analysis (Modifed EPA Method 314.0) 24 80$ /Each $ 1,920 8 f Tedlar Bags 240 10$ /Each $ 2,400 g TVA-1000B PID/FID Rental 12 1,200$ /Month $ 14,400 9 Total Lab Analytical and Monitoring $ 141,120
17 Miscellaneous a Temporary Office 24'x60' Delivery and Setup 1 2,939$ /Each $ 2,939 10 b Temporary Office 24'x60' Rental 12 1,030$ /Month $ 12,356 10 c Temporary Office 24'x60' Demobilization 1 1,746$ /Each $ 1,746 10 d Temporary Storage Trailer 12 149$ /Month $ 1,784 11 e Portable Toilet Delivery 12$ 2 /Each $ 22 12 f Portable Toilet Rental 12 76$ /Month $ 908 12 g Standby Generator (800 kW) 12 8,775$ /Month $ 105,300 13 h Maintenance Parts 12 1,000$ /Month $ 12,000 i Fed Ex and Deliveries 260 150$ /Day $ 39,000 j Temporary office comm. (internet, telephone, fax) 12 1,000$ /Month $ 12,000 k Operator Truck Usage (One Truck per Operator) 780 100$ /Day/Truck $ 78,000 Total Miscellaneous $ 266,055
J-13.7 Operations and Maintenance Cost Page 17 of 24 429 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 342 of 381 Page ID #:13890
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.7 Detailed Cost, ERH (200 kW-hr/cubic yard) Operations and Maintenance
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 18 Steam License for UBA 0 0.50$ /CY Treated $ - 14 Total Subcontractor Cost (O&M Year 1) $ 1,972,186
Cost Unit Cost Item Utilities Quantity Cost Ref. 19 Electricity Usage a Electrodes in UBA 11,680,994 0.1045$ /kWh $ 1,220,664 15 b HiPOx and other Treatment Equipment 10,148,151 0.1045$ /kWh $ 1,060,482 15 Total Electricity Usage $ 2,281,146
20 Natural Gas for Steam Generation 53,702 1.14$ /Therm $ 61,220 16
21 Municipal Water a Cooling Tower Makeup Water (5 GPM) 2,628,000 0.0029$ /Gal $ 7,621 b Municipal Water for Steam Generation 518,457 0.0029$ /Gal $ 1,504 c water for electrodes 80,416,800 0.0029$ /Gal $ 233,209 Total Municipal Water Usage $ 242,333
Total Utilities $ 2,584,699
FULL SCALE CONSULTANT LABOR COST $ 1,309,000 FULL SCALE SUBCONTRACTOR COST w/10% MARKUP $ 2,169,405 UTILITIES COST (NO MARKUP) $ 2,584,699 TOTAL OPERATIONS AND MAINTENANCE COST $ 6,063,104
J-13.7 Operations and Maintenance Cost Page 18 of 24 430 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 343 of 381 Page ID #:13891
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.7 Detailed Cost, ERH (200 kW-hr/cubic yard) Operations and Maintenance
Cost Source Reference 1 Nationwide Boiler Quote Dated July 30, 2008 2 BakerCorp Quote Dated June 30, 2008. Unit price for carbon change-out services is scaled down for a 9,400-lb change-out from BakerCorp quote of $1,850 per change-out for 10,000 lbs. 3 BakerCorp Quote July 23, 2008 4 NRC Environmental Services, Inc. Quote Dated June 30, 2008 5 Clean Harbors Quote Dated October 10, 2007 6 NRC Environmental Services, Inc. Email Quote Dated July 18, 2008 7 Verbal Quote from Calscience Environmental Laboratories, Inc. 8 Verbal Quote from Test America 9 Verbal Quote from Ashtead Technology Rentals 10 Mobile Mini, Inc. Quote Dated October 11, 2007 11 Verbal Quote from Mobile Mini, Inc. 12 Verbal Quote from A-1 Coast Port-A-Toilet 13 Kohler Rental Quote Dated June 30, 2008 14 McMillan-McGee November 2006 Feasibility Study for Steam Injection, Page 33 15 Shedule A-3 LADWP Rate (Second Quarter 2008) 16 GN-10, Tier III, SoCal Gas Co. Rate (Effective May 1, 2008)
J-13.7 Operations and Maintenance Cost Page 19 of 24 431 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 344 of 381 Page ID #:13892
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.8 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Abandonment
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 70 150$ /Hour $ 10,500 2 Senior Engineer/Geologist 420 125$ /Hour $ 52,500 3 Mid-Level Engineer/Geologist 170 100$ /Hour $ 17,000 4 Junior/Field Engineer/Geologist 1,872 75$ /Hour$ 140,400 5 Field Technician 70 75$ /Hour $ 5,250 6 Clerical/Drafting 70 50$ /Hour $ 3,500 Total Consultant Labor Cost $ 229,150
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref.
1 Mobilization/Demobilization of Drill Rig 1$ 2,000 /LS $ 2,000 1
2 Abandon UBA Multi-Phase Extraction Wells a Drill out well materials (upper 15 feet) 15 65$ /Foot $ 975 1 b Pressure grout well 108 30$ /Foot $ 3,240 1 c Forklift and mini-hopper 1 500$ /Day $ 500 1 d Abandonment Crew per Diem 1 200$ /Night $ 200 e Vehicle Usage 1 100$ /Day $ 100 f Equipment Rental and Supplies 1 150$ /Day $ 150 g Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 5,315 Number of Wells (1 Well Abandoned per Day) 66 Total for UBA Multi-Phase Extraction Well Adandonment 350,790
J-13.8 Well Abandonment Cost Page 20 of 24 432 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 345 of 381 Page ID #:13893
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.8 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Abandonment
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 3 Abandon Electrode Wells a Drill out well materials (upper 15 feet) 15 65$ /Foot $ 975 1 b Pressure Grout Electrodes 105 30$ /Foot $ 3,150 1 c Forklift and mini-hopper 1 500$ /Day $ 500 1 d Abandonment Crew per Diem 1 200$ /Night $ 200 e Vehicle Usage 1 100$ /Day $ 100 f Equipment Rental and Supplies 1 150$ /Day $ 150 g Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 5,225 Number of Wells (1 Well Abandoned per Day) 102 Total for Electode Well Adandonment 532,950
4 Abandon Hot Floor Multi-Phase Extraction Wells a Pressure grout well 118.5 30$ /Foot $ 3,555 1 b Forklift and mini-hopper 1 500$ /Day $ 500 1 c Abandonment Crew per Diem 1 200$ /Night $ 200 d Vehicle Usage 1 100$ /Day $ 100 e Equipment Rental and Supplies 1 150$ /Day $ 150 f Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 4,655 Number of Wells (1 Well Abandoned per Day) 0 Total for Hot Floor Multi-Phase Extraction Well Abandonment $ -
J-13.8 Well Abandonment Cost Page 21 of 24 433 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 346 of 381 Page ID #:13894
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.8 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Abandonment
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 5 Abandon Hot Floor Steam Injection Wells a Pressure grout well 115.5 30$ /Foot $ 3,465 1 b Forklift and mini-hopper 1 500$ /Day $ 500 1 c Abandonment Crew per Diem 1 200$ /Night $ 200 d Vehicle Usage 1 100$ /Day $ 100 e Equipment Rental and Supplies 1 150$ /Day $ 150 f Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 4,565 Number of Wells (1 Well Abandoned per Day) 0 Total for Hot Floor Steam Injection Well Abandonment $ -
6 Abandon Temperature Monitoring Points a Pressure grout well 105 30$ /Foot $ 3,150 1 b Forklift and mini-hopper 1 500$ /Day $ 500 1 c Abandonment Crew per Diem 1 200$ /Night $ 200 d Vehicle Usage 1 100$ /Day $ 100 e Equipment Rental and Supplies 1 150$ /Day $ 150 f Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 4,250 Number of Wells 14 Total for Temperature Monitoring Point Abandonment $ 59,500
J-13.8 Well Abandonment Cost Page 22 of 24 434 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 347 of 381 Page ID #:13895
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.8 Detailed Cost, ERH (200 kW-hrs/cubic yard) Well Abandonment
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 Waste Management a Waste Tank Rental 0 38$ /Day $ - b Waste Tank Rental Delivery - Mob and Demob 0 900$ /Each $ - c Waste Bin Rental 360 15$ /Day $ 5,400 2 d Waste Bin Rental Delivery - Mob and Demob 12 500$ /Each $ 6,000 2 e Transport of Hazardous Soil Cuttings 12$ 1,100 /Each $ 13,200 2 f Disposal of Hazardous Soil Cuttings 186 550$ /Ton $ 102,025 2 g Transport of Hazardous Mud 0 500$ /Each $ - h Disposal of Hazardous Mud 0 1.1$ /Gal $ - i Transport of Hazardous Water 1$ 1,100 /Each $ 1,100 2 j Disposal of Hazardous Water 1517 0.8$ /Gal $ 1,214 2 k Waste Characterization/Profiling 2 500$ /Each $ 1,000 Total Waste Management $ 129,939 Total Subcontractor Cost w/10% Markup $ 1,182,696
TOTAL WELL ABANDONMENT COST $ 1,411,846
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Verbal Quote from NRC Environmental Services
J-13.8 Well Abandonment Cost Page 23 of 24 435 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 348 of 381 Page ID #:13896
Final DNAPL Feasibility Study Montrose Superfund Site ERH (200 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 13.9 Detailed Cost, ERH (200 kW-hrs/cubic yard) Demobilization
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 55$ 150 /Hour $ 8,250 2 Senior Engineer/Geologist 180$ 125 /Hour $ 22,500 3 Mid-Level Engineer/Geologist 572$ 100 /Hour $ 57,200 4 Junior/Field Engineer/Geologist 720$ 75 /Hour $ 54,000 5 Field Technician 380$ 75 /Hour $ 28,500 6 Clerical/Drafting 125$ 50 /Hour $ 6,250 Consultant Labor Cost $ 176,700
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 Remove Purchased Treatment Equipment 1$ 317,000 /LS $ 317,000
8 Close-Out Borings a Drilling 9$ 12,000 /Boring$ 108,000 1 b Waste Disposal 9$ 5,500 /Boring $ 49,500 2 c Soil Pesticides (EPA Method 8081A) 54 $ 90 /Sample $ 4,860 3 d Soil VOCs (EPA Method 8260B) 54 $ 95 /Sample $ 5,130 3 e Soil pCBSA (Modified EPA Method 314.0) 54 $ 80 /Sample $ 4,320 3 f Liquid Pesticides (EPA Method 8081A) 9 $ 90 /Sample $ 810 3 g Liquid VOCs (EPA Method 8260B) 9 $ 95 /Sample $ 855 3 h Liquid pCBSA (Modified EPA Method 314.0) 9 $ 80 /Sample $ 720 3 Total for Close-Out Borings $ 174,195
Total Subcontractor Cost w/10% Markup $ 540,315
TOTAL DEMOBILIZATION COST $ 717,015
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Verbal Quote from NRC Environmental Services 3 Verbal Quote from Test America
J-13.9 Demobilization Cost Page 24 of 24 436 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 349 of 381 Page ID #:13897
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.0 Cost Summary ERH (400 kW-hrs/cubic yard) Focused Treatment Area
Cost (NPV) Cost Year Activity Detailed Cost Table DR= 4% DR= 7% (Undiscounted) 1 Focused Treatment Design J-14.1 Design and Permitting Cost $ 1,160,300 $ 1,115,673 $ 1,084,393 J-14.2 Well Construction $ 3,996,515 J-14.3 Well Field Equipment Installation $ 2,170,154 2 Focused Treatment Build J-14.4 Instrumentation and Controls Installation $ 64,124 $ 9,050,943 $ 8,550,529 J-14.5 Treatment Equipment Installation $ 3,160,979 J-14.6 Construction Management $ 397,728 3 J-14.7 Operations and Maintenance $ 6,063,104 $ 5,390,077 $ 4,949,299 Focused Treatment Operation and Maintenance 4 J-14.7 Operations and Maintenance $ 6,063,104 $ 5,182,767 $ 4,625,513 J-14.8 Well Abandonment $ 1,411,846 5 Verification and Abandonment $ 1,749,769 $ 1,517,848 J-14.9 Demobilization $ 717,015
Totals $ 25,204,869 $ 22,489,229 $ 20,727,582
Notes DR = Discount rate NPV = Net present value
J-14.0 Cost Summary Page 1 of 24 437 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 350 of 381 Page ID #:13898
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.1 Detailed Cost, ERH (400 kW-hrs/cubic yard) Design and Permitting
Cost Unit Cost Item Consultant Labor Quantity Cost Ref. 1 Project Manager 790 150$ /Hour$ 118,500 2 Senior Engineer/Geologist 1,170 125$ /Hour$ 146,250 3 Mid-Level Engineer/Geologist 4,600 100$ /Hour$ 460,000 4 Junior/Field Engineer/Geologist 3,310 75$ /Hour$ 248,250 5 Field Technician 0 75$ /Hour $ - 6 Clerical/Drafting 1,106 50$ /Hour $ 55,300 Consultant Labor $ 1,028,300
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 1 Outside Thermal Expert 1$ 120,000 /LS $ 120,000
Subcontractor Cost w/10% Markup $ 132,000
TOTAL DESIGN AND PERMITTING COST$ 1,160,300
J-14.1 Design and Permitting Cost Page 2 of 24 438 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 351 of 381 Page ID #:13899
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 14.2 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Construction
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 507 150$ /Hour $ 76,050 2 Senior Engineer/Geologist 507 125$ /Hour $ 63,375 3 Mid-Level Engineer/Geologist 1,352 100$ /Hour$ 135,200 4 Junior/Field Engineer/Geologist 3,050 75$ /Hour$ 228,750 5 Field Technician 482 75$ /Hour $ 36,150 6 Clerical/Drafting 507 50$ /Hour $ 25,350 Total Consultant Labor Cost $ 564,875
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 Abandon Existing Site Wells Prior to Thermal Treatment a Drill out well materials 90 65$ /Foot $ 5,850 1 b Grout resulting boring 90 30$ /Foot $ 2,700 1 c Forklift and mini-hopper 1 500$ /Day $ 500 1 d Excavate and remove well box 1 2,000$ /LS $ 2,000 1 e Abandonment Crew per Diem 1 200$ /Night $ 200 f Vehicle Usage 1 100$ /Day $ 100 g Equipment Rental and Supplies 1 150$ /Day $ 150 h Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 11,650 Number of Wells 5 Total for Existing Site Well Abandonment $ 58,250
J-14.2 Well Construction Cost Page 3 of 24 439 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 352 of 381 Page ID #:13900
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 14.2 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 8 UBA Multi-Phase Extraction Wells (12" HSA Drilling to 108' bgs) a Install Well Constructed of 6" LCS Casing w/ 60' of SS Screen and 3-foot Sump, Type II Cement Grout, and Sand Pack 1$ 12,000 /Each$ 12,000 2 b Forklift and Hopper Rental for Waste Handling 1 250$ /Day $ 250 2 c Drill Crew per Diem 1 450$ /Night $ 450 2 d Vehicle Usage 1 100$ /Day $ 100 e Equipment Rental and Supplies 1 500$ /Day $ 500 f Installation Permit 1 201$ /Well $ 201 g Other Direct Costs 1 300$ /Day $ 300 Cost per Well $ 13,801 Number of Wells (1 Well Installed per Day) 66 Subtotal - UBA Multi-Phase Extraction Wells $ 910,866
9 Lab Analytical (Sixteen UBA Multi-Phase Extraction Well Borings) a Soil Analysis - Pesticides (EPA Method 8081A) 54 90$ /Sample$ 4,860 3 b Soil Analysis - VOCs (EPA Method 8260B) 54 95$ /Sample$ 5,130 3 c Soil Analysis - pCBSA (Modified EPA Method 314.0) 54 80$ /Sample$ 4,320 3 d Water Analysis - Pesticides (EPA Method 8081A) 9 90$ /Sample $ 810 3 e Water Analysis - VOCs (EPA Method 8260B) 9 95$ /Sample $ 855 3 f Water Analysis - pCBSA (Modified EPA Method 314.0) 9 80$ /Sample $ 720 3 Total Lab Analytical (UBA Extraction Wells) $ 16,695
J-14.2 Well Construction Cost Page 4 of 24 440 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 353 of 381 Page ID #:13901
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 14.2 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 10 Electrode Wells (15" HSA Drilling to 105' bgs) a Drill Rig, Crew, and Support Equipment 1 4,000$ /Each $ 4,000 4 b Cement Backfill Material 54 30$ /Foot $ 1,620 4 c Sand Backfill Material 51 20$ /Foot $ 1,020 4 d Drill Crew per Diem 1 450$ /Night $ 450 4 e Forklift and Hopper Rental for Waste Handling 1 250$ /Day $ 250 4 f Plastic Sheeting and Hole Prep 125$ /Well $ 25 4 g 5% Fuel Surcharge 1 368$ /Day $ 368 4 h Vehicle Usage 1 100$ /Day $ 100 i Equipment Rental and Supplies 1 500$ /Day $ 500 j Installation Permit 1 201$ /Well $ 201 k Other Direct Costs 1 300$ /Day $ 300 Cost per Well $ 8,834 Number of Wells (1 Well Installed per Day) 102 Subtotal - Electrode Wells $ 901,094
11 Develop UBA Multi-Phase Extraction Wells a Development Rig 1 2,000$ /Day $ 2,000 2 b Development Crew per Diem 1 200$ /Night $ 200 2 Cost per Well $ 2,200 Number of Wells (1 Well Developed per Day) 66 Subtotal - Develop UBA Wells $ 145,200
J-14.2 Well Construction Cost Page 5 of 24 441 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 354 of 381 Page ID #:13902
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 14.2 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 12 Mobilization/Demobilization of Mud Rotary Drill Rig 1$ 12,000 /Each $ 12,000 4
13 Hot Floor Multi-Phase Extraction Wells a Move Between Well Locations 1 2,000$ /Each $ 2,000 5 b Install 14", .25" Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout 110 220$ /Foot $ 24,200 5 c Mud Change-Out and Pit Decon 1 2,000$ /Each $ 2,000 5 d 12" Boring Under Conductor 8.5 80$ /Foot $ 680 5 e Install 6" Low Carbon Steel Sched. 40 Casing 110.5 88$ /Foot $ 9,724 5 f Install 6" Type 304 Stainless Steel Screen with 3' Sump 8 175$ /Foot $ 1,400 5 g Type II Cement Grout and Sand Pack 118.5 30$ /Foot $ 3,555 5 h Forklift and Hopper Rental for Waste Handling 4 400$ /Day $ 1,600 5 i Standby for Cement Curing 6 550$ /Hour $ 3,300 5 j Well Development 10 165$ /Hour $ 1,650 5 k Vehicle Usage 4 100$ /Day $ 400 l Equipment Rental and Supplies 4 500$ /Day $ 2,000 m Installation Permit 1 201$ /Well $ 201 n Other Direct Costs 4 300$ /Day $ 1,200 Cost per Well $ 53,910 Number of Wells (4 Days per Well for Installation and Development) 0 Subtotal - Hot Floor Multi-Phase Extraction Wells $ -
J-14.2 Well Construction Cost Page 6 of 24 442 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 355 of 381 Page ID #:13903
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 14.2 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 14 Hot Floor Steam Injecton Wells a Move Between Well Locations 1 2,000$ /Each $ 2,000 5 b Install 10", .25" Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout 110 180$ /Foot $ 19,800 5 c Mud Change-Out 1 1,500$ /Each $ 1,500 5 d 9" Boring Under Conductor 5.5 75$ /Foot $ 413 5 e Install 2" Low Carbon Steel Sched. 40 Casing 110.5 45$ /Foot $ 4,973 5 f Install 2" Type 304 Stainless Steel Screen 5 90$ /Foot $ 450 5 g Type II Cement Grout and Sand Pack 115.5 20$ /Foot $ 2,310 5 h Forklift and Hopper Rental for Waste Handling 4 400$ /Day $ 1,600 5 i Standby for Cement Curing 5 550$ /Hour $ 2,750 5 j Well Development 6 165$ /Hour $ 990 5 k Vehicle Usage 4 100$ /Day $ 400 l Equipment Rental and Supplies 4 500$ /Day $ 2,000 m Installation Permit 1 201$ /Well $ 201 n Other Direct Costs 4 300$ /Day $ 1,200 Cost per Well $ 40,586 Number of Wells (4 Days per Well for Installation and Development) 0 Subtotal - Hot Floor Steam Injecton Wells $ -
J-14.2 Well Construction Cost Page 7 of 24 443 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 356 of 381 Page ID #:13904
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 14.2 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 15 Temperature Monitoring Points (7" HAS Drilling to 105' bgs) a Move Between Well Locations 1 4,000$ /Each $ 4,000 b Install 10", .25 Wall, Low Carbon Steel Conductor Casing with Type II Cement Grout 0 180$ /Foot $ - c Mud Change-Out 0 1,500$ /Each $ - d 8" Boring Under Conductor 075$ /Foot $ - e Install 1.5" Low Carbon Steel Casing with Bottom Cap 105 40$ /Foot $ 4,200 f Type II Cement Grout 105 20$ /Foot $ 2,100 g Forklift and Hopper Rental for Waste Handling 1 250$ /Day $ 250 h Standby for Cement Curing 0 550$ /Hour $ - i Vehicle Usage 1 100$ /Day $ 100 j Equipment Rental and Supplies 1 500$ /Day $ 500 k Installation Permit 1 201$ /Well $ 201 i Other Direct Costs 1 300$ /Day $ 300 Subtotal $ 11,651 Number of Wells (3 Days per Point - no Development Needed) 14 Subtotal - Temperature Monitoring Points $ 163,114
16 BFS Monitoring Wells a Well Installation (4 Days per Well for Installation and Development) 2$ 54,000 /Well $ 108,000 1 b Installation Permit 2 201$ /Well $ 402 Subtotal - BFS Monitoring Wells $ 108,402
J-14.2 Well Construction Cost Page 8 of 24 444 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 357 of 381 Page ID #:13905
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focued Treatment Area Appendix J June 2013 Table 14.2 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Construction
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 17 Waste Management a Waste Tank Rental 290 38$ /Day $ 11,020 6 b Waste Tank Rental Delivery - Mob and Demob 1 900$ /Each $ 900 6 c Waste Bin Rental 1762 15$ /Day $ 26,430 6 d Waste Bin Rental Delivery - Mob and Demob 58 500$ /Each $ 29,000 6 e Transport of Hazardous Soil Cuttings 58 1,100$ /Each $ 63,800 6 f Disposal of Hazardous Soil Cuttings 1178 550$ /Ton $ 647,900 6 g Transport of Hazardous Mud 0 500$ /Each $ - 6 h Disposal of Hazardous Mud 0 1.1$ /Gal $ - 6 i Transport of Hazardous Water 6 1,100$ /Each $ 6,600 6 j Disposal of Hazardous Water 21753 0.8$ /Gal $ 17,402 6 k Waste Characterization/Profiling 2 500$ /Each $ 1,000 Subtotal - Waste Management $ 804,052 Total Subcontractor Cost w/10% Markup $ 3,431,640
TOTAL WELL CONSTRUCTION COST $ 3,996,515
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Cascade Drilling, Inc. Quote Dated 7/15/08 3 Verbal Quote from Test America 4 Cascade Drilling, Inc. Quote Dated 8/01/08 5 Water Development Corporation Quote Dated 4/25/08 6 Verbal Quote from NRC Environmental
J-14.2 Well Construction Cost Page 9 of 24 445 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 358 of 381 Page ID #:13906
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.3 Detailed Cost, ERH Well Field Equipment Installation
Cost Item Unit Cost Consultant Labor and Direct Costs Quantity Cost Ref. 1 Electrical Service Upgrade 1$ 50,000 LS $ 50,000
2 Natural Gas Pipeline 1$ 200,000 LS $ 200,000
3 Electrode Well Equipment and Piping a Electrodes (3 per Electrode Well) 306 $ 1,500 Each $ 459,000 1 b Armored Electrical Cable 2380$ 4.89 Foot $ 11,638 2 c 1.5-Inch Carbon Steel Pipe and Fittings for Recirc Water Delivery 2380$ 12.00 LF $ 28,560 Total Electrode Well Equipment$ 499,198
4 Groundwater Extraction Assemblies a Well Head Assemblies 66$ 1,000 Each$ 66,000 b Extraction Pump (High Temperature Hammerhead Pro) 66$ 3,070 Each$ 202,620 3 c Downwell Air Supply Hose (3/8" SS Brainded, Teflon Lined) 6600$ 11 LF$ 72,600 3 d Downwell Air Exhaust Hose (1/2" SS Brainded, Teflon Lined) 6600$ 16 LF$ 105,600 3 e Downwell Discharge Hose (1/4" SS Brainded, Teflon Lined) 6600 $ 22 LF$ 145,200 3 Total Groundwater Extraction Assemblies $ 592,020
5 Steam Injection Well Head Assemblies 0$ 7,000 Each $ -
6 Field Technician - Pump and Well Head Assembly Construction and Installation (Consultant Labor - Not Subject to Markup) 1,370$ 75 Hour $ 102,750
7 Steam Injection Piping a 6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 0 $ 67.65 LF$ - 4 b 4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 0$ 43.45 LF$ - 4 c 2-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 0$ 34.10 LF$ - 4 Total Steam Injection Piping $ -
8 Vapor Extraction Piping a 8-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 605$ 94.71 LF$ 57,300 5 b 6-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 1810$ 67.65 LF$ 122,447 4 c 4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 677$ 43.45 LF$ 29,416 4 Total Vapor Extraction Piping $ 209,162
J-14.3 Well Field Equipment Installation Cost Page 10 of 24 446 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 359 of 381 Page ID #:13907
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.3 Detailed Cost, ERH Well Field Equipment Installation
Cost Item Unit Cost Consultant Labor and Direct Costs Quantity Cost Ref. 9 Groundwater Extraction Piping a 4-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 605$ 43.45 LF$ 26,287 4 b 2-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 1810$ 34.10 LF$ 61,721 4 c 1.5-Inch Carbon Steel Pipe and Fittings (incl. Fiberglass Insulation and Aluminum Jacket) 677$ 31.45 LF$ 21,292 4 d Total Piping Length 3092 LF e Piping Heat Trace, VLBTV Wire 3092$ 15.75 LF$ 48,699 6 f Misc fittings and heat trace elements (30% of Groundwater Extraction Piping cost) 1$ 47,399.67 LS$ 47,400 Total Groundwater Extraction Piping $ 205,399 10 Compressed Air Pipe and Fittings (2-Inch Carbon Steel) 3092$ 20.00 LF $ 61,840 4 11 Pipe Supports 309.2 $ 200 LF $ 61,840
CONSULTANT LABOR COST $ 102,750 DIRECT COSTS w/10% MARKUP $ 2,067,404 TOTAL WELL FIELD EQUIPMENT INSTALLTION COST $ 2,170,154
Cost Source Reference 1 Verbal Quote from McMillan-McGee Corp. 2 McMaster-Carr Catalog Price 3 QED Environmental Systems, Inc. Quote Dated May 16, 2008 4 2007 RS Means Database. Unit price shown includes 10% inflation rate and local area cost factor. 5 Unit rate assumed to be approximately 40% higher than rate for 6-inch carbon steel pipe and fittings with fiberglass insulation and aluminum jacket. 6 2006 Raychem quote obtained by CH2MHILL
J-14.3 Well Field Equipment Installation Cost Page 11 of 24 447 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 360 of 381 Page ID #:13908
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.4 Detailed Cost, ERH (400 kW-hrs/cubic yard) Instrumentation and Controls Installation
Cost Unit Cost Item Consultant Labor and Direct Costs Quantity Cost Ref.
1 Steam Injection Wells a Pressure Gage (0-300 PSI) 04$ 8 /Each -$ 1 b Temperature Indicator 0$ 127 /Each -$ 1 c Orifice Plate and Transmitter 0$ 10,000 /Each -$ Total Steam Injection Wells and Piping I&Cs -$
2 Groundwater Exraction Pressure Gage (0-300 PSI) 66 $ 48 /Each 3,168$ 1
3 Vapor Extraction Vacuum Gage (30 in Hg) 66$ 50 /Each 3,326$ 1
4 Thermocouple String a Type T Thermocouple Wire (24 Gauge w/Fiberglass Insulation and Jacket) 1,400$ 0.75 /Foot 1,050$ 2 b Analog Decoder 1$ 500 /Each 500$ Cost per Temp Monitoring Point 1,550$ Number of Temperature Monitoring Points 14 Total Thermocouple String 21,700
5 Field Technician - Installation of Items 1 Through 4 (Instrumentation and Controls) 152 $ 75 /Hour 11,400$ (Consultant Labor - Not Subject to Markup)
6 Electrical Allowance (20% of Instrumentation and Controls cost) 1$ 8,458 /LS 8,458$
7 Control System Allowance (30% of Instrumentation and Controls cost) 1$ 11,278 /LS 11,278$
CONSULTANT LABOR COST 11,400$ DIRECT COSTS w/10% MARKUP 52,724$ TOTAL INSTRUMENTATION AND CONTROLS INSTALLATION COST 64,124$
Cost Source Reference 1 Grainger Catalog Price 2 McMaster-Carr Catalog Price
J-14.4 Instrumentation and Controls Installation Cost Page 12 of 24 448 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 361 of 381 Page ID #:13909
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.5 Detailed Cost, ERH (400 kW-hrs/cubic yard) Treatment Equipment Installation
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 1 Vapor Treatment a 12,000-gallon Brine Holding Tank 1$ 18,538 /Each$ 18,538 1 b Fin-Fan Heat Exchanger 1$ 14,306 /Each$ 14,306 2 c Steam-Regenerable Carbon System (incl. two 5,000-lb GAC vessels, condenser, separator, and inline stack PID) 1$ 750,000 /LS$ 750,000 3 d 2MM BTUs/Hr Steam Generator (Gas Fired) 1$ 5,000 /Each$ 5,000 e Water Softening Unit for Steam Generator 1$ 5,000 /Each$ 5,000 f Interconnecting Piping (20% of Steam-Regen Carbon System cost) 1$ 150,000 /LS$ 150,000 g 5000-lb Polishing Vapor-Phase GAC Vessel 2$ 16,000 /Each$ 32,000 4 h Orifice Plate and Transmitter 2$ 10,000 /Each$ 20,000 i 1000 SCFM Liquid Ring Vacuum Blower (standard cast iron construction) 2$ 80,000 /Each$ 160,000 5 j Moisture Separator 1$ 4,000 /Each$ 4,000 6 k 500-Gallon Collection Tank 1$ 2,078 /Each$ 2,078 1 l Transfer Pump (50 gpm) 9 $ 536 /Each$ 4,820 7 Total for Vapor Treatment $ 1,165,742
2 Groundwater Exraction and Treatment a Shell and Tube Heat Exchanger 1$ 22,112 /Each$ 22,112 8 b DNAPL/Water Separator 2$ 56,450 /Each$ 112,900 9 c Groundwater Holding Tank 1$ 50,000 /Each$ 50,000 d Two 3,000-lb Liquid-Phase GAC Vessels Each w/Initial Virgin Coconut Shell GAC Fill 1$ 16,830 LS $ 16,830 10 e Air Compressor 1$ 20,000 /Each$ 20,000 11 f 500-Gallon Collection Tank 1$ 2,078 /Each$ 2,078 1 g Cooling Tower (540 gpm Recirculation Rate) 1$ 37,713 /Each$ 37,713 12 h Transfer Pump (50 gpm) 8 $ 536 /Each$ 4,284 7 i Transfer Pump (540 gpm) 2$ 2,756 /Each$ 5,513 13 j Transfer Pump (145 gpm) 2$ 1,348 /Each$ 2,696 7 k HiPOx System (50 gpm) 1$ 768,750 /Each$ 768,750 14 Total for Groundwater Exraction and Treatment Equipment $ 1,042,876
J-14.5 Treatment Equipment Installation Cost Page 13 of 24 449 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 362 of 381 Page ID #:13910
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.5 Detailed Cost, ERH (400 kW-hrs/cubic yard) Treatment Equipment Installation
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 3 Equipment Pads and Containment 1$ 150,000 /LS $ 150,000 11 4 80' X 110' Treatment Plant Building 1$ 150,000 /LS $ 150,000 5 Subcontractor Installation Cost 1$ 365,000 /LS $ 365,000 15
TOTAL TREATMENT EQUIPMENT INSTALLATION COST w/10% MARKUP $ 3,160,979
Cost Source Reference 1 Harrington Plastic Catalog Price 2 Heat Exchanger Sales and Engineering Company, LLC Quote Dated July 17, 2008 3 MEGTEC Systems, Inc. Quote Dated April 20, 2008 4 BakerCorp Quote Dated July 1, 2008 5 Yardley Pump and Vacuum Quote Dated July 18, 2008 6 Verbal Qoute from Enviro Supply and Services 7 Grainger Catalog Price 8 SEC Heat Exchanger Quote Dated July 1, 2008 9 Pan America Environmental Quote Dated July 28, 2008 10 BakerCorp Quoted Dated July 23, 2008 11 McMillan-McGee November 2006 Feasibility Study for Steam Injection, Page 34 12 Cooling Tower Systems Quote Dated July 2, 2008 13 McMaster-Carr Catalog Price 14 Unit price scaled down to a 75 gpm system from $2,050,000 quote from Applied Process Technologies (June 6, 2006) for a 200 gpm system. 15 Verbal Quote from J.C. Palomar Construction, Inc.
J-14.5 Treatment Equipment Installation Cost Page 14 of 24 450 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 363 of 381 Page ID #:13911
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.6 Detailed Cost, ERH (400 kW-hrs/cubic yard) Construction Management
Item Consultant Labor Quantity Unit Cost Cost 1 Project Manager 195$ 150 /Hour$ 29,250 2 Senior Engineer/Geologist 400$ 125 /Hour$ 50,000 3 Mid-Level Engineer/Geologist 1,062$ 100 /Hour$ 106,200 4 Junior/Field Engineer/Geologist 1,365$ 75 /Hour$ 102,375 5 Field Technician 1,365$ 75 /Hour$ 102,375 6 Clerical/Drafting 151$ 50 /Hour 7,528$ TOTAL CONSTRUCTION MANAGEMENT COST $ 397,728
J-14.6 Construction Management Cost Page 15 of 24 451 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 364 of 381 Page ID #:13912
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.7 Detailed Cost, ERH (400 kW-hrs/cubic yard) Operations and Maintenance
Cost Unit Cost Item Consultant Labor (Operations) Quantity Cost Ref. 1 Project Manager 520 150$ /Hour $ 78,000 2 Senior Engineer/Geologist 520 125$ /Hour $ 65,000 3 Mid-Level Engineer/Geologist (One Full Time Mid-Level Engineer) 2,080 100$ /Hour $ 208,000 4 Junior/Field Engineer/Geologist (One Full Time Junior Engineer) 2,080 75$ /Hour $ 156,000 5 Field Technician (Three Full Time Operators - 40 Hours per Week Each) 6,240 75$ /Hour $ 468,000 6 Clerical/Drafting 520 50$ /Hour $ 26,000 Consultant Labor Cost for Operations $ 1,001,000
Cost Unit Cost Item Consultant Labor (Reporting, H&S, Data Mngt, and Website Maintenance) Quantity Cost Ref. 7 Project Manager 20 150$ /Hour $ 3,000 8 Senior Engineer/Geologist 80 125$ /Hour $ 10,000 9 Mid-Level Engineer/Geologist 1,300 100$ /Hour $ 130,000 10 Junior/Field Engineer/Geologist 2,080 75$ /Hour $ 156,000 11 Field Technician 075$ /Hour $ - 12 Clerical/Drafting 180 50$ /Hour $ 9,000 Consultant labor for Reporting, H&S, Data Mngt, and Website Maintenance $ 308,000
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 13 Equipment Rentals a 12-million BTUs/hr Low NOx Steam Generator (incl. water softening package) 0 18,500$ /Month $ - 1 Total Equipment Rentals $ -
14 Consumables (Excluding Utilities) a Salt for Steam Generator Feed Water Treatment 52 100$ /Week $ 5,200 b Virgin Coconut Shell Vapor-Phase Carbon (7,000-lbs of polishing GAC per month plus 10,000 lbs of regen system carbon changed-out after six months) 94,000 1.07$ /lb $ 100,580 2 c Vapor-Phase Carbon Change-Out Service 10 1,739$ /Change-Out $ 17,390 2 d Hydrogen Peroxide for HiPOx 166,650 3.00$ /Gal $ 499,950 e Oxygen for HiPOx 1,165,100 0.35$ /100 SCF $ 407,785 f 3000-lb Liquid-Phase Carbon Change-Out (Includes T&D as Hazardous Waste) 48 6,746$ /Each $ 323,808 3 Total Consumables $ 1,354,713
J-14.7 Operations and Maintenance Cost Page 16 of 24 452 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 365 of 381 Page ID #:13913
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.7 Detailed Cost, ERH (400 kW-hrs/cubic yard) Operations and Maintenance
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 15 Waste Management a Vapor-Phase GAC Disposal (Listed Waste for Incineration) (incl. 10,000 lbs of regen system carbon at year end) 80,000 0.71$ /lb $ 56,800 4 b Vapor-Phase GAC Transportation 5 4,286$ /Load $ 21,430 4 c Carbon Regen System Solvent Waste Disposal (Listed Waste for Incineration) 169,500 0.50$ /lb $ 84,750 5 d Carbon Regen System Solvent Waste Transportation - inlcude pre heat transport 5 3,650$ /Load $ 18,250 5 e Filtration Generated Waste Disposal (Listed Waste for Incineration) 39,300 0.25$ /lb $ 9,825 5 f Filtration Generated Waste Transportation 3 2,800$ /Load $ 8,400 5 g Boiler Water Pre-Treatment Brine and Blowdown Off-Site Disposal (non-Haz) 43,526 0.14$ /Gal $ 6,094 6 h Boile Water Pre-Treatment Brine and Blowdown Transportation 5 950$ /10,000 Gals $ 4,750 6 Total Waste Management$ 210,299
16 Lab Analytical and Monitoring a Summa Can Rental 288 40$ /Each $ 11,520 7 b Vapor VOCs Analysis (EPA Method TO-15) 288 200$ /Each $ 57,600 7 c Liquid Pesticides (EPA Method 8260B) 288 90$ /Each $ 25,920 8 d Liquid VOC Analysis (EPA Method 8081A) 288 95$ /Each $ 27,360 8 e Liquid pCBSA Analysis (Modifed EPA Method 314.0) 24 80$ /Each $ 1,920 8 f Tedlar Bags 240 10$ /Each $ 2,400 g TVA-1000B PID/FID Rental 12 1,200$ /Month $ 14,400 9 Total Lab Analytical and Monitoring $ 141,120
17 Miscellaneous a Temporary Office 24'x60' Delivery and Setup 1 2,939$ /Each $ 2,939 10 b Temporary Office 24'x60' Rental 12 1,030$ /Month $ 12,356 10 c Temporary Office 24'x60' Demobilization 1 1,746$ /Each $ 1,746 10 d Temporary Storage Trailer 12 149$ /Month $ 1,784 11 e Portable Toilet Delivery 12$ 2 /Each $ 22 12 f Portable Toilet Rental 12 76$ /Month $ 908 12 g Standby Generator (800 kW) 12 8,775$ /Month $ 105,300 13 h Maintenance Parts 12 1,000$ /Month $ 12,000 i Fed Ex and Deliveries 260 150$ /Day $ 39,000 j Temporary office comm. (internet, telephone, fax) 12 1,000$ /Month $ 12,000 k Operator Truck Usage (One Truck per Operator) 780 100$ /Day/Truck $ 78,000 Total Miscellaneous $ 266,055
J-14.7 Operations and Maintenance Cost Page 17 of 24 453 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 366 of 381 Page ID #:13914
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.7 Detailed Cost, ERH (400 kW-hrs/cubic yard) Operations and Maintenance
Cost Unit Cost Item Subcontractor Cost Quantity Cost Ref. 18 Steam License for UBA 0 0.50$ /CY Treated $ - 14 Total Subcontractor Cost (O&M Year 1) $ 1,972,186
Cost Unit Cost Item Utilities Quantity Cost Ref. 19 Electricity Usage a Electrodes in UBA 11,680,994 0.1045$ /kWh $ 1,220,664 15 b HiPOx and other Treatment Equipment 10,148,151 0.1045$ /kWh $ 1,060,482 15 Total Electricity Usage $ 2,281,146
20 Natural Gas for Steam Generation 53,702 1.14$ /Therm $ 61,220 16
21 Municipal Water a Cooling Tower Makeup Water (5 GPM) 2,628,000 0.0029$ /Gal $ 7,621 b Municipal Water for Steam Generation 518,457 0.0029$ /Gal $ 1,504 c water for electrodes 80,416,800 0.0029$ /Gal $ 233,209 Total Municipal Water Usage $ 242,333
Total Utilities $ 2,584,699
FULL SCALE CONSULTANT LABOR COST $ 1,309,000 FULL SCALE SUBCONTRACTOR COST w/10% MARKUP $ 2,169,405 UTILITIES COST (NO MARKUP) $ 2,584,699 TOTAL OPERATIONS AND MAINTENANCE COST $ 6,063,104
J-14.7 Operations and Maintenance Cost Page 18 of 24 454 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 367 of 381 Page ID #:13915
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.7 Detailed Cost, ERH (400 kW-hrs/cubic yard) Operations and Maintenance
Cost Source Reference 1 Nationwide Boiler Quote Dated July 30, 2008 2 BakerCorp Quote Dated June 30, 2008. Unit price for carbon change-out services is scaled down for a 9,400-lb change-out from BakerCorp quote of $1,850 per change-out for 10,000 lbs. 3 BakerCorp Quote July 23, 2008 4 NRC Environmental Services, Inc. Quote Dated June 30, 2008 5 Clean Harbors Quote Dated October 10, 2007 6 NRC Environmental Services, Inc. Email Quote Dated July 18, 2008 7 Verbal Quote from Calscience Environmental Laboratories, Inc. 8 Verbal Quote from Test America 9 Verbal Quote from Ashtead Technology Rentals 10 Mobile Mini, Inc. Quote Dated October 11, 2007 11 Verbal Quote from Mobile Mini, Inc. 12 Verbal Quote from A-1 Coast Port-A-Toilet 13 Kohler Rental Quote Dated June 30, 2008 14 McMillan-McGee November 2006 Feasibility Study for Steam Injection, Page 33 15 Shedule A-3 LADWP Rate (Second Quarter 2008) 16 GN-10, Tier III, SoCal Gas Co. Rate (Effective May 1, 2008)
J-14.7 Operations and Maintenance Cost Page 19 of 24 455 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 368 of 381 Page ID #:13916
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.8 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Abandonment
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 70 150$ /Hour $ 10,500 2 Senior Engineer/Geologist 420 125$ /Hour $ 52,500 3 Mid-Level Engineer/Geologist 170 100$ /Hour $ 17,000 4 Junior/Field Engineer/Geologist 1,872 75$ /Hour$ 140,400 5 Field Technician 70 75$ /Hour $ 5,250 6 Clerical/Drafting 70 50$ /Hour $ 3,500 Total Consultant Labor Cost $ 229,150
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref.
1 Mobilization/Demobilization of Drill Rig 1$ 2,000 /LS $ 2,000 1
2 Abandon UBA Multi-Phase Extraction Wells a Drill out well materials (upper 15 feet) 15 65$ /Foot $ 975 1 b Pressure grout well 108 30$ /Foot $ 3,240 1 c Forklift and mini-hopper 1 500$ /Day $ 500 1 d Abandonment Crew per Diem 1 200$ /Night $ 200 e Vehicle Usage 1 100$ /Day $ 100 f Equipment Rental and Supplies 1 150$ /Day $ 150 g Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 5,315 Number of Wells (1 Well Abandoned per Day) 66 Total for UBA Multi-Phase Extraction Well Adandonment 350,790
J-14.8 Well Abandonment Cost Page 20 of 24 456 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 369 of 381 Page ID #:13917
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.8 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Abandonment
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 3 Abandon Electrode Wells a Drill out well materials (upper 15 feet) 15 65$ /Foot $ 975 1 b Pressure Grout Electrodes 105 30$ /Foot $ 3,150 1 c Forklift and mini-hopper 1 500$ /Day $ 500 1 d Abandonment Crew per Diem 1 200$ /Night $ 200 e Vehicle Usage 1 100$ /Day $ 100 f Equipment Rental and Supplies 1 150$ /Day $ 150 g Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 5,225 Number of Wells (1 Well Abandoned per Day) 102 Total for Electode Well Adandonment 532,950
4 Abandon Hot Floor Multi-Phase Extraction Wells a Pressure grout well 118.5 30$ /Foot $ 3,555 1 b Forklift and mini-hopper 1 500$ /Day $ 500 1 c Abandonment Crew per Diem 1 200$ /Night $ 200 d Vehicle Usage 1 100$ /Day $ 100 e Equipment Rental and Supplies 1 150$ /Day $ 150 f Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 4,655 Number of Wells (1 Well Abandoned per Day) 0 Total for Hot Floor Multi-Phase Extraction Well Abandonment $ -
J-14.8 Well Abandonment Cost Page 21 of 24 457 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 370 of 381 Page ID #:13918
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.8 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Abandonment
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 5 Abandon Hot Floor Steam Injection Wells a Pressure grout well 115.5 30$ /Foot $ 3,465 1 b Forklift and mini-hopper 1 500$ /Day $ 500 1 c Abandonment Crew per Diem 1 200$ /Night $ 200 d Vehicle Usage 1 100$ /Day $ 100 e Equipment Rental and Supplies 1 150$ /Day $ 150 f Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 4,565 Number of Wells (1 Well Abandoned per Day) 0 Total for Hot Floor Steam Injection Well Abandonment $ -
6 Abandon Temperature Monitoring Points a Pressure grout well 105 30$ /Foot $ 3,150 1 b Forklift and mini-hopper 1 500$ /Day $ 500 1 c Abandonment Crew per Diem 1 200$ /Night $ 200 d Vehicle Usage 1 100$ /Day $ 100 e Equipment Rental and Supplies 1 150$ /Day $ 150 f Other Direct Costs 1 150$ /Day $ 150 Cost per Well $ 4,250 Number of Wells 14 Total for Temperature Monitoring Point Abandonment $ 59,500
J-14.8 Well Abandonment Cost Page 22 of 24 458 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 371 of 381 Page ID #:13919
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.8 Detailed Cost, ERH (400 kW-hrs/cubic yard) Well Abandonment
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 Waste Management a Waste Tank Rental 0 38$ /Day $ - b Waste Tank Rental Delivery - Mob and Demob 0 900$ /Each $ - c Waste Bin Rental 360 15$ /Day $ 5,400 2 d Waste Bin Rental Delivery - Mob and Demob 12 500$ /Each $ 6,000 2 e Transport of Hazardous Soil Cuttings 12$ 1,100 /Each $ 13,200 2 f Disposal of Hazardous Soil Cuttings 186 550$ /Ton $ 102,025 2 g Transport of Hazardous Mud 0 500$ /Each $ - h Disposal of Hazardous Mud 0 1.1$ /Gal $ - i Transport of Hazardous Water 1$ 1,100 /Each $ 1,100 2 j Disposal of Hazardous Water 1517 0.8$ /Gal $ 1,214 2 k Waste Characterization/Profiling 2 500$ /Each $ 1,000 Total Waste Management $ 129,939 Total Subcontractor Cost w/10% Markup $ 1,182,696
TOTAL WELL ABANDONMENT COST $ 1,411,846
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Verbal Quote from NRC Environmental Services
J-14.8 Well Abandonment Cost Page 23 of 24 459 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 372 of 381 Page ID #:13920
Final DNAPL Feasibility Study Montrose Superfund Site ERH (400 kW-hrs/cubic yard) Los Angeles, California Focused Treatment Area Appendix J June 2013 Table 14.9 Detailed Cost, ERH (400 kW-hrs/cubic yard) Demobilization
Cost Item Consultant Labor Quantity Unit Cost Cost Ref. 1 Project Manager 55$ 150 /Hour $ 8,250 2 Senior Engineer/Geologist 180$ 125 /Hour $ 22,500 3 Mid-Level Engineer/Geologist 572$ 100 /Hour $ 57,200 4 Junior/Field Engineer/Geologist 720$ 75 /Hour $ 54,000 5 Field Technician 380$ 75 /Hour $ 28,500 6 Clerical/Drafting 125$ 50 /Hour $ 6,250 Consultant Labor Cost $ 176,700
Cost Item Subcontractor Cost Quantity Unit Cost Cost Ref. 7 Remove Purchased Treatment Equipment 1$ 317,000 /LS $ 317,000
8 Close-Out Borings a Drilling 9$ 12,000 /Boring$ 108,000 1 b Waste Disposal 9$ 5,500 /Boring $ 49,500 2 c Soil Pesticides (EPA Method 8081A) 54 $ 90 /Sample $ 4,860 3 d Soil VOCs (EPA Method 8260B) 54 $ 95 /Sample $ 5,130 3 e Soil pCBSA (Modified EPA Method 314.0) 54 $ 80 /Sample $ 4,320 3 f Liquid Pesticides (EPA Method 8081A) 9 $ 90 /Sample $ 810 3 g Liquid VOCs (EPA Method 8260B) 9 $ 95 /Sample $ 855 3 h Liquid pCBSA (Modified EPA Method 314.0) 9 $ 80 /Sample $ 720 3 Total for Close-Out Borings $ 174,195
Total Subcontractor Cost w/10% Markup $ 540,315
TOTAL DEMOBILIZATION COST $ 717,015
Cost Source Reference 1 Verbal Quote from Water Development Corporation 2 Verbal Quote from NRC Environmental Services 3 Verbal Quote from Test America
J-14.9 Demobilization Cost Page 24 of 24 460 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 373 of 381 Page ID #:13921
APPENDIX E ARARS FOR THE SELECTED REMEDY
363 461 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 374 of 381 Page ID #:13922 APPENDIX E DNAPL ARARs and TBCs Montrose Superfund Site
Authority Citation Synopsis of Requirement Action to be Taken to Attain Requirement Applicable Relevant and Appropriate TBC
Porter-Cologne California Water Code Establishes water quality objectives, including narrative and Restoration of groundwater associated with the Montrose Site X Water Act (CWA), numerical standards and establishes implementation plans to was addressed by the 1999 Groundwater ROD. A Technical §13140-13147 California Water meet objectives and protect beneficial uses. Incorporates state- Impracticability (TI) Waiver Zone was established for Code wide water quality control plans and policies. groundwater underlying the Site and extends beyond the extent of the DNAPL operable unit. The DNAPL remedy will
remove mobile DNAPL and protect waters of the State outside of the TI waiver zone.
Any contaminants reinjected from the DNAPL treatment system will be conveyed to the groundwater treatment system for treatment and reinjection pursuant to the 1999 Groundwater ROD and its ARARs, except as waived in the TI waiver zone.
South Coast Air SCAQMD Permit SCAQMD has established screening emission levels for various Chloroform is a site-related VOC that may be generated by the X Quality Management Application Package toxic air contaminants to determine if a screening risk DNAPL remedy. An assessment of emissions in comparison to District (SCAQMD), “L”, Table 1A, assessment should be performed. The screening emission levels these screening levels is used to determine if a more detailed Permit Screening September 10, 2010 for chloroform, at three distances from the emission source, are screening risk assessment is required under SCAQMD Rule Emission Level for as follows (may vary based upon cumulative health risk of all 1401. Chloroform toxic air contaminants being emitted):
Acute:
25 Meters: .0852 pounds per year
50 Meters: .17 pounds per year
100 Meters: .456 pounds per year
Chronic:
25 Meters: 6.01 pounds per year
50 Meters: 15.8 pounds per year
100 Meters: 47.0 pounds per year
Migratory Bird Title 16 USC Except as permitted by regulations, it is unlawful to pursue, hunt, No migratory birds, nests, or eggs are currently present at the X Treaty Act take, capture, offer to sell, barter, purchase, or deliver any Site; however, these regulations would be applicable if §703-712 migratory bird, nest, or egg. migratory birds were discovered at the site during DNAPL remedy implementation.
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462 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 375 of 381 Page ID #:13923 APPENDIX E DNAPL ARARs and TBCs Montrose Superfund Site
Authority Citation Synopsis of Requirement Action to be Taken to Attain Requirement Applicable Relevant and Appropriate TBC
Endangered Species Title 16 USC §1531 et. Requires action to conserve endangered species and critical No known endangered species are currently present at the X Act of 1973; seq.; habitats upon which endangered species depend. Includes site; however, these regulations will be considered and Protection of consultation with the Dept. of the Interior. followed if endangered or threatened species are discovered. 50 CFR Parts 17 and Endangered and 402 Activities at all remedial sites must be performed in such a Remedial actions should avoid disturbance of terrain which is Threatened Species manner as to identify the presence of and protect endangered or habitat for endangered species. threatened plants and animals at the site.
State Water Resolution No. 68-16 State Anti-degradation Policy sets forth in State Board Resolution Within the TI Waiver Zone, the 1999 Groundwater ROD X Resources Control No. 68-16, which has been incorporated into all Regional Board requires groundwater treatment in compliance with the Statement of Policy Board (SWRCB) Basin Plans. The resolution requires protection of the existing conditions established for the TI Waiver Zone. with Respect to quality of water whenever it is better than that necessary to Maintaining High Any contaminants reinjected from the DNAPL treatment protect present and potential beneficial uses. Applies to the Quality of Waters in system will be conveyed to the groundwater treatment discharge of waste to waters, including re-injection into the California; Water system for treatment and reinjection pursuant to the 1999 aquifer. Code §13140 Groundwater ROD and its ARARs, except as waived in the TI waiver zone.
State Water Resolution No. 92-49 To protect groundwater, the resolution requires cleanup to Restoration of groundwater quality associated with the X Resources Control III.G either background water quality or the best water quality that is Montrose Site was addressed by the 1999 Groundwater ROD. Board (SWRCB) reasonable if background water quality cannot be restored. Non- A TI Waiver Zone was established for groundwater underlying 23 CCR §2550.4 background cleanup levels must be consistent with maximum the Site and extends beyond the extent of the area impacted Background Water benefit to the public, present and anticipated future beneficial by the DNAPL remedy. Quality; Policy and uses, and conform to water quality control plans and policies. Any contaminants reinjected from the DNAPL treatment Procedures for system will be conveyed to the groundwater treatment system Investigation and for treatment and reinjection pursuant to the 1999 Cleanup and Groundwater ROD and its ARARs, except as waived in the TI Abatement of waiver zone. Discharges under Water Code §13304
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463 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 376 of 381 Page ID #:13924 APPENDIX E DNAPL ARARs and TBCs Montrose Superfund Site
Authority Citation Synopsis of Requirement Action to be Taken to Attain Requirement Applicable Relevant and Appropriate TBC
Code of Federal 40 CFR Part 261 et Defines wastes that are subject to regulation as a RCRA (or These regulations establish provisions for characterizing X Regulations and seq. California) hazardous waste. Contaminated soil and groundwater wastes as hazardous (characteristic or by rule) and are California Code of (solid wastes), once extracted for treatment, must be managed applicable to DNAPL solid wastes. The determination of 22 CCR §66261 et Regulations as state and federal hazardous waste if such soil or groundwater whether wastes generated during remedial activities are seq. contains levels of hazardous substances that meet or exceed hazardous will be made at the time the wastes are generated.
state and federal hazardous waste toxicity criteria for specific Some contaminated media treated to specified cleanup levels Identification and hazardous wastes and/or contains one or more RCRA-listed will no longer need to be managed as a hazardous waste; Characterization of hazardous wastes. applicable to toxicity characteristic wastes (e.g., Hazardous Waste 40 CFR §261.24 identifies waste containing >100 mg/L chlorobenzene, federal waste code D021). chlorobenzene as hazardous under the toxicity characteristic (waste code D021).
40 CFR 261.33 identifies waste containing DDT, as a discarded commercial product, as hazardous (waste code U061).
In addition to federal hazardous waste standards, California also has specific state-regulated hazardous wastes. DNAPL exhibits the characteristic of “toxicity” if representative samples have:
> 100.0 mg/L chlorobenzene by Toxicity Characteristic Leaching Potential (TCLP)
> 1.0 mg/kg wet-weight DDT
> 0.1 mg/L DDT by Soluble Threshold Limit Concentration (STLC)
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464 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 377 of 381 Page ID #:13925 APPENDIX E DNAPL ARARs and TBCs Montrose Superfund Site
Authority Citation Synopsis of Requirement Action to be Taken to Attain Requirement Applicable Relevant and Appropriate TBC
Solid Waste Disposal 40 CFR Part 262 et Under 42 USC §6901 et seq., RCRA mandates “cradle-to-grave” DNAPL associated with the former operations of the Montrose X Act and Resource seq. 22 CCR §66262 et management of hazardous waste, and regulates three types of plant may be classified as a California and/or RCRA hazardous Conservation and seq. Ch 12 hazardous waste handlers: (1) generators, (2) transporters, and waste, if the source of any toxic constituents (such as MCB) in Recovery Act (RCRA) incorporates by (3) owners and operators of treatment, storage, or disposal the DNAPL is known (i.e., a listed waste). If the source of the reference: facilities (TSDFs). Only the substantive requirements of RCRA toxic constituents is not generally known, the DNAPL may still must be met if a CERCLA action is to be conducted on-site (does be classified as a characteristic hazardous waste (e.g., toxicity, • 49 CFR parts 172, Code of Federal not require RCRA permits, nor compliance with the flammability, etc.). If the source of the toxic constituents is 173, 178, and Regulations and administrative requirements). generally not known and the DNAPL and/or DNAPL-related 179 California Code of waste (e.g., filters or PPE) is not characteristically hazardous, Standards applicable to generators include requirements for Regulations • 40 CFR part 265, then the waste will not be classified as hazardous. In the waste determination, reporting, shipment, packaging, labeling, Subparts C, D, I, course of remediating the DNAPL contamination, DNAPL accumulation, documentation, and recordkeeping. J, AA, BB, CC and/or DNAPL- related waste will be generated, accumulated Generators of In California, the State’s promulgated regulations replace the and possibly stored, and transported for off-site disposal. • 22 CCR Chapter Hazardous Waste equivalent Federal regulations as potential ARARs. See RCRA 15, Articles 3, 4, 3006(b), and 40 CFR §271. See Chapter 6.5 of H&S Code (HWCA), 9, 10, 27, 28, and §25100 et seq. 28.5
Resource 42 U.S.C. § 6939b(b) Under 42 U.S.C. §6939b(b), for actions under CERCLA, Hazardous constituents in extracted groundwater will be X Conservation and contaminated groundwater must be treated to substantially substantially reduced prior to reinjection either through Recovery Act (RCRA) reduce hazardous constituents prior to reinjection into the removal of separate-phase DNAPL and/or through removal of aquifer from which it was withdrawn, if the water-bearing units dissolved-phase constituents. The degree of reduction that will Interim Control of beneath the site are a underground source of drinking water. be considered “substantial” will be determined on a case-by- Hazardous Waste case basis. Injection
Code of Federal 40 CFR Part 268 et Chapter 18 of both 40 CFR and 22 CCR identifies hazardous “Disposal” means: X Regulations and seq., 22 CCR §66268 wastes that are restricted from land disposal and defines those (a) the discharge, deposit, injection, dumping, spilling, leaking California Code of et seq. limited circumstances under which an otherwise prohibited or placing of any waste or hazardous waste into or on any Regulations waste may continue to be land disposed. This chapter includes land or water so that such waste or any constituent thereof regulations governing various aspects of land disposal may enter the environment or be emitted into the air or requirements, including waste analysis, treatment, and storage discharged into any waters, including groundwaters; Land Disposal and recordkeeping. (b) the abandonment of any waste. Restrictions 22 CCR §66268.100 establishes land disposal prohibitions for Hazardous waste generated from the DNAPL remedy is non-RCRA hazardous wastes. required to comply with the applicable provisions of these regulations. Land disposal restrictions would not be triggered if the media is treated to reduce contaminant concentrations in compliance with the treatment standards.
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465 Case 2:90-cv-03122-DOC-GJS Document 3050-2 Filed 01/15/21 Page 378 of 381 Page ID #:13926 APPENDIX E DNAPL ARARs and TBCs Montrose Superfund Site
Authority Citation Synopsis of Requirement Action to be Taken to Attain Requirement Applicable Relevant and Appropriate TBC
California Hazardous California Health and HWCA has many elements that control hazardous wastes from Wastes generated during DNAPL remedy implementation is X Waste Control Act Safety Code §25100, their point of generation through handling, treatment, and required to meet these standards as noted in the regulations (HWCA) et seq. ultimate destruction or disposal. referred to herein.
South Coast Air Rule 201 and 201.1 Requires that any person building, erecting, installing, altering or DNAPL remedy must have vapor control and treatment X Quality Management replacing any equipment which may cause the discharge of air systems, designed to comply with the substantive portions of District (South Coast contaminants obtain a permit and construct/operate the South Coast Air Quality Management District requirements. AQMD) equipment in accordance with the permit conditions.
Regulation II
South Coast AQMD Rule 401 Limits the discharge of visible emissions. Vapor control and treatment systems associated with the X Regulation IV DNAPL remedy must be designed and operated to comply with these regulations to the extent applicable.
Rule 402 Prohibits discharge of pollutants that (i) cause injury, detriment, Vapor control and treatment systems associated with the X nuisance, or annoyance, (ii) endanger the health or safety of the DNAPL remedy must be designed and operated to comply with public, or (iii) cause (or tend to cause) injury or damage to these regulations to the extent applicable. business or property.
Rule 403 Requires actions to prevent, reduce, or mitigate fugitive dust. Soil handling during remedy construction and implementation X will need to comply with these requirements. Fugitive dust would need to be controlled using water spray or other common methods. Measurement of dust levels would be performed to document compliance with this rule.
Rule 404 Prohibits discharge of particulate matter in excess of certain Vapor control and treatment systems associated with the X concentrations. DNAPL remedy must be designed and operated to comply with these regulations to the extent applicable.
Rule 405 Prohibits discharge of solid particulate matter in excess of certain Vapor control and treatment systems associated with the X rates. DNAPL remedy must be designed and operated to comply with these regulations to the extent applicable.
Rule 408 Cannot build, install or use any equipment that reduces or Vapor control and treatment systems associated with DNAPL X conceals an emission that would otherwise be a violation. remedy must be designed and operated to comply with these regulations to the extent applicable.
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Authority Citation Synopsis of Requirement Action to be Taken to Attain Requirement Applicable Relevant and Appropriate TBC
South Coast AQMD Rule 409 Limits the emission of particulate matter from a combustion Vapor control and treatment systems associated with DNAPL X Regulation IV (cont.) source to 0.10 grain per standard cubic foot, at 12% carbon remedy must be designed and operated to comply with these dioxide, averaged over 15 minutes. regulations to the extent applicable. This rule is potentially applicable to natural gas fired steam boilers or thermal oxidizers.
Rule 466 Any pump, compressor, valve, etc exposed to reactive organic Vapor control and treatment systems associated with the X compounds must be equipped with adequate seals and in good DNAPL remedy must be designed and operated to comply with working order, except for equipment that is exempted from the these regulations to the extent applicable. requirements for reasons listed in the rule, including equipment in contact with liquid with greater than 80% water content.
Rule 474 Limits the concentration of oxides of nitrogen to a range of 125 If the Vapor control and treatment systems associated with X to 300 ppm for gaseous fuels and 225-400 ppm for solid and the DNAPL remedy meets applicable equipment size, then the liquid fuels depending on equipment size. DNAPL remedy must be designed and operated to comply with these regulations.
This rule includes provisions for steam generating equipment using steam boilers subject to the rule. This rule would additionally apply to natural gas-fired thermal oxidizers for treatment of vapor-phase contaminants if applicable.
Rule 476 Steam generating equipment: Prohibits discharge into the Steam generating equipment used for the DNAPL treatment X atmosphere of certain combustion contaminants from system would need to comply with this rule if rated at more equipment having a heat input rate of more than 50 million than 50 million BTUs. BTUs.
South Coast AQMD Rule 1146 Prohibits discharge of certain limits of nitrogen dioxide from Vapor control and treatment systems associated with the X Regulation XI steam generators and process heaters rated greater than 5 DNAPL remedy (e.g., steam generators used for thermal million BTUs per hour (or between 2-5 million for small treatment) must be designed and operated to comply with the operators). substantive requirements of these regulations to the extent applicable.
Rule 1166 Regulates volatile organic compound (VOC) emissions from More than one cubic yard of VOC-impacted soils (e.g., X decontamination of soil. This rule establishes requirements for chlorobenzene) will be subject to this rule. Soil cuttings excavation, grading, or handling of soil containing VOCs (i.e., to generated during remedy construction (i.e., well installation) prevent uncontrolled evaporation of VOCs to the atmosphere). would be subject to this rule and must be handled in a manner consistent with the provisions of this rule to minimize evaporation of VOCs to atmosphere during soil handling.
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Authority Citation Synopsis of Requirement Action to be Taken to Attain Requirement Applicable Relevant and Appropriate TBC
South Coast AQMD Rule 1166 (cont.) This rule includes requirements for monitoring, odor control, Regulation XI (cont.) stockpiling, segregation, loading, and transporting VOC-impacted soils. Handling of less than one cubic yard of VOC-impacted soil is exempt from this rule.
Rule 1176 Regulates volatile organic compound leaks and emissions from Vapor control and treatment systems associated with DNAPL X facilities. remedy alternatives must be designed and operated to comply with these regulations to the extent applicable.
South Coast AQMD Rule 1301 Sets forth pre-construction review requirements for new, Vapor control and treatment systems associated with DNAPL X Regulation XIII modified, or relocated sources/facilities, to ensure that the remedial alternatives must be designed and operated to operation of such facilities does not interfere with progress in comply with these regulations by using the Best Available attainment of the national ambient air quality standards. Control Technology (BACT).
South Coast AQMD Rule 1401 New source review of toxic air contaminants. This rule specifies This rule establishes the primary air emission limits for site- X Regulation XIV limits for maximum individual cancer risk (MICR), cancer burden, related toxic air contaminants including chlorobenzene and non-cancer acute, and chronic hazard index. This rule limits chloroform. emissions of toxic air contaminants to: Chloroform contributes to the MICR and cancer burden. (a) an MICR less than 1x10-6 for systems without best Chlorobenzene is not a carcinogen and only contributes to the available control technology (BACT); hazard index.
(b) an MICR less than 1x10-5 for systems with BACT; Vapor control and treatment systems associated with DNAPL remedy must be designed and operated to comply with this (c) a cancer burden less than 0.5; rule. (d) a chronic hazard index less than 1.0;
(e) a non-cancer acute hazard index less than 1.0.
South Coast AQMD Rule 1470 Requirements for Stationary Diesel-Fueled Internal Combustion During implementation of the DNAPL remedy (primarily during X and Other Compression Ignition Engines. This rule applies to any construction), large diesel engines may be used for specific person who owns or operates a stationary IC engine in the South tasks, e.g., drilling rigs, air compressor, or mobile generator. Coast Air Quality Management District with brake horsepower For diesel engines with greater than 50 brake horsepower, greater than 50. This rule controls the particulate matter only engines with valid and current SCAQMD emission emissions from such engines by establishing fuel requirements, certificates will be used. operating requirements, emission standards, and reporting and Any large diesel engines without a valid emissions certification monitoring requirements. will be prohibited from working at the site.
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Authority Citation Synopsis of Requirement Action to be Taken to Attain Requirement Applicable Relevant and Appropriate TBC
Land Use Covenant 22 CCR §67391.1 (a), Establishes substantive requirements for land use restrictive A response action decision document which includes X Regulation (d) covenants. limitations on land use or other institutional controls, requires that the limitations or controls are clearly set forth and Since hazardous materials, hazardous wastes, or constituents, or defined in the response action decision document, specifies hazardous substances will remain at the property after that the limitation or controls will be incorporated into an implementation of the remedy at levels which are not suitable or appropriate land use covenant as required by Section 67391.1, unrestricted use of the land, this requirement is relevant and and includes an implementation and enforcement plan. The appropriate. DNAPL remedy will be subject to these standards.
Environmental CA Civil Code §1471 Specifies manner by which environmental covenants are Since hazardous materials, hazardous wastes or constituents, X Covenant recorded and binding on successors to the land restricted by the or hazardous substances will remain at the property after Requirements covenant. implementation of the remedy at levels which are not suitable for unrestricted use of the land, this requirement is relevant and appropriate. The DNAPL remedy will be subject to these standards.
Mandatory 40 CFR Part 98 Establishes reporting requirements for sources generating in Estimated emissions of greenhouse gases, certified by a third X Greenhouse Gas excess of 25,000 metric tons per year of greenhouse gases. party, must be submitted to EPA. Reporting Rule
TO BE CONSIDERED (TBCs)
California Well Bulletins 74-90 and Provides minimum construction and destruction/abandonment Design, construction, and destruction of wells or borings into X Standards, 74-81 criteria and specifications for groundwater monitoring wells, the saturated zone must comply with the substantive portions Department of extraction wells, injection wells, and exploratory borings. of these standards. Hydraulic displacement and thermal Water Resources remediation technologies would include wells installed within the saturated zone at the Site and would be subject to these The standards are meant to be a model of minimum standards standards. and are enforced locally through Los Angeles County, but are not enforced by the State.
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