15
Attachment SMMC Item 17 November 4, 2013
Attachment SMMC Item 17
November 4, 2013
Agenda Item 17
SMMC
11/4/13
DRAFT Remedial Action Plan
Taylor Yard Parcel G-2 Los Angeles, California
Prepared for: Union Pacific Railroad Company 951 Atkinson Street Suite 100 Roseville, WA 95747
July 10, 2013
555 17th Street, Suite 1100
Denver, Colorado 80202
tel: 303-383-2300
fax: 303-308-3003
July 10, 2013 TRANSMITTED VIA EMAIL AND HARD COPY Ms. Jessy Fierro Project Manager Department of Toxic Substances Control 9211 Oakdale Avenue Chatsworth, CA 91311
Subject: Submittal of Draft Remedial Action Plan
Taylor Yard Parcel G‐2 Los Angeles, California
Dear Ms. Fiero:
CDM Smith Inc. (CDM Smith), on behalf of Union Pacific Railroad (UPRR), is submitting the attached Draft Remedial Action Plan (RAP) for UPRR’s Taylor Yard Parcel G‐2 property located at 2800 Kerr Street in Los Angeles, California. This Draft RAP addresses the comments provided by the California Department of Toxic Substances Control (DTSC) on January 29 and May 24, 2012.
Should you have any questions regarding this document, please do not hesitate to contact the undersigned at 714-308-2945 or 303-383-2341 or via email at [email protected].
Very truly yours,
Ravi Subramanian, P.E. Associate and Project Manager CDM Smith Inc.
Attachments Cc: Jim Diel, UPRR
The information contained in this report has received appropriate technical review and approval. The approach and methodology are based upon professional judgments founded upon review of available reports, the interpretation of such data and upon our professional experience and background. This acknowledgment is made in lieu of all warranties, either expressed or implied.
Reviewed and Approved by:
Ravi Subramanian, P.E.
Associate and Project Manager
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F
Parcel J
(Commercial)
Parcel H (Commercial)
Parcel F
(Commercial Property)
Parcel G-1 (State Parks)
Parcel F (Central Los Angeles High School No. 13)
Parcel E (Federal Express)
Taylor Yard
(Parcel G-2)
Parcel D (State Park)
Metro Transit Authority Sale Parcel
Legend
Site Boundary
Former Taylor Yard Extent ³ 500
0 Feet
500
Union Pacific Railroad
Taylor Yard Remedial Action Plan Site Vicinity Map
Figure 1-1
"
"""
" AOPC
"
"
"
B2-D1 (14.2)
"G1-22 (42.7)
Former UST 4
4-2 (13.4)
" B32-D2 (290)
Tank "!!! G1-23 (13000) Former UST N Former UST M Paint Shop #1 IRM Power House
"
G1-35 (61.8) ! G1-35 (5360) G1-35 (25000)
!G1-32 (19000)
!G1!-24 (25000) !
"!D6 (5020)
D6 (25.6)
1-21 (10000) !
D10 (10300)
!
Area 4 - Former Debris Pile Area
G1-34 (25000)
AOPC 1
Former UST C
"! F10 (151)
Former UST 20
Oil House E22 (7830) !
! Power House
Filter Storage Former UST 16 Area 1 - Service Track Area
F7 (10500)
F9 (2800)
F10 (16.6) F10 (5380)
(1300
Dispenser Maintenance Building
Former Past Area
Area 3 - Diesel Shop Area !
1-7 (23000) ! 1-11 (12.9)
F10 0) ! !!! !
Auto Fueling Center
Wheel Drop Pit
1-11 (11560) 1-12 (12.1)
F11 (17.3) F24-D1 (28)
3-7 (132) 3-7 (20.7) !
"! " F11 (3030) Area 2 - South Turntable Area
"" 3-6 (11000) 3-7 (17500) !
1-14"(13.3)
"! G7 (15) G7 (9830)
! F8-D3
!W-17A 14000)
Active Turntable
V3-33 (23) " ! """! (13200)
" "
Former UST 18
!
G24 (23.6) !!
! Abandoned Former Pond
Excavation Storm Water
H8 (13.3!) H9 (43.3) H12 (8500)
Paint Locomotive Shed
3-9 (3600) 3-10 (8100)
3-11 (2420) HA-6 (72) ! !
Turntable Ponds AOPC 2 Wash Room Area
! Surface 2-1
(44000)
I21 (406)
Oil/Water
Diesel Shop "! V3-26 (18)
V3-26 (5400)
J254(15.4)
Oil/Water Separator Industrial Wastewater
Pre-Treatment Plant
AOPC 3
Separator
J25 (2280)
! "
3-14 (37.4) Railyard
Boundary
Vegetated Buffer Zone
Legend
Areas of Potential Concern
" Antimony (Sb) Greater Than > 71 mg/kg
" Arsenic (As) Greater Than > 12 mg/kg
! Total TPH (TPH) Greater Than 7,800 mg/kg
! Lead (Pb) Greater Than 2,280 mg/kg 200
0 Feet
200
Union Pacific Railroad Taylor Yard Remedial Action Plan
Areas of Potential Concern Based on Concentrations of Lead,
Total Petroleum Hydrocarbon (C12 C35+), Arsenic and Antimony
Figure 3-1
Union Pacific Railroad Taylor Yard Remedial Investigation
Soil AOPCs and Alternative 5C
Figure 1
B2-D1 (14.2) " " G1-22 (42.7)
4-2 (13.4)
"!!!
Tank G1-23 (13000) Former UST N Former UST M Paint Shop #1 IRM Power House "
G1-35 (61.8) G1-35 (5360)
G1-35 (25000)
! ! G1-32 (19000) ! G1-24 (25000) !
"! D6 (5020)
D6 (25.6)
1-21 (10000)
!
D10 (10300)
!
Area 4 - Former Debris Pile
Area G1-34 (25000)
AOPC 1 Former UST 4
E7 (12.6)
"
Former UST C F10 (151)
Oil House Former UST 20
E22 (7830) !
Power House
Filter Storage Former UST 16 Area 1 - Service Track Area
F10 (16.6) F10 (5380)
Dispenser Maintenance Building
Former Past Area
Area 3 - Diesel Shop Area !
1-7 (23000) F7 (10500)
!
F9 (2800) !
F10 (13000) "#!!! "!
Auto Fueling Center
Area 2 - South Turntable Area
Wheel Drop Pit
1-11 (12.9) 1-11 (11560) "! 1-12 (12.1) W-17A
F11 (17.3) F11 (3030) F24-D1 (28)
1-14 (13.3) "
"! G7 (15)
" !
F8-D3 (14000)
!
Active Turntable
""
V3-33 (23) 3-6 (11000)
" !
"#!
3-7 (132) 3-7 (20.7)
G7 (9830) (13200) Former UST 18 G24 (23.6) 3-10 (8100) !
3-7 (17500)
Abandoned Turntable
Former Pond Excavation Storm
Water "
H8 (13.3) H9 (43.3)
" AOPC 2 !
H12 (8500)
Paint Locomotive Shed
HA-6 (72)
! 3-11 (2420)
Ponds Wash Room Area
!
I21 (406)
#
Diesel Shop # V3-26 (18) "!
V3-26 (5400)
Oil/Water Separator Industrial Wastewater
Pre-Treatment Plant
Surface 2-1 (44000)
AOPC 3
Oil/Water Separator
AOPC 4
J25 (15.4) J25 (2280)
"!
"
3-14 (37.4)
Railyard
Boundary
Vegetated Buffer Zone
100
0 Feet
100
Legend
Soil Areas of Potential Concern (AOPCs)
2.5 foot Excavation Depth
5 foor Excavation Depth
# Antimony (Sb) Greater Than > 71 mg/kg ! Total TPH (TPH) Greater Than 7,800 mg/kg ! Lead (Pb) Greater Than 2,280 mg/kg " Arsenic (As) Greater Than > 12 mg/kg
Note: Soil Areas of Potential Concern (AOPCs) shown here are based on concentrations of Lead, Total Petroleum Hydrocarbons (C12 to C35+) Arsenic and Antimony.
Union Pacific Railroad Taylor Yard Remedial Action Plan
Soil AOPCs and Alternative 5 Figure 4-1
Asphalt Pavement
Passive Soil Bioventing
! W27 A
!
!
Free Product Removal
Asphalt Pavement
Asphalt Pavement
!
!
!
V3-33 !
V3-23
V3-22
V3-21
!
V3-24 !
V3-19
V3-20
V3-27
V3-26
!
Concrete Slab with Vapor Barrier and Passive Sub-slab Mitigation System
Asphalt
Pavement
Area 3 Soil Vapor Extraction
Asphalt
Pavement
Concrete Slab with Vapor Barrier and Passive Sub-slab Mitigation System
200 0 Feet
200
Legend
Remediation Areas
2.5-foot Excavation Depth
5-foot Excavation Depth
Passive Soil Bioventing Area of Potential Concern for Risk Assessment Area 3 Soil Vapor Extraction
Vapor Extraction Well ! Bioventing Well Location A Groundwater Monitoring Well
Union Pacific Railroad Taylor Yard Remedial Action Plan
Proposed Remedial Action
Figure 6-1
ES-1
EXECUTIVE SUMMARY
On behalf of Union Pacific Railroad (UPRR), CDM Smith Inc. (CDM Smith) has prepared this Remedial Action Plan (RAP) to address future remedial action of UPRR’s Taylor Yard Parcel G-2 property (the Site) located at 2800 Kerr Street in Los Angeles, California. This property is referred to as “the Site” in this RAP.
The purpose of this RAP is to summarize the remedial alternatives that were considered in the Feasibility Study (FS) and supporting documents, provide rationale for selection of the preferred remedial alternative, and describe the remedial activities that will be implemented at the Site under the preferred remedial alternative (Alternative 5). Alternative 5 was selected based on the results and conclusions of the remedial investigations, risk assessments, interim remedial measures conducted at the Site, and the FS.
UPRR and its predecessors have owned the Site since at least the early 1900s. Maintenance and fueling began in the 1930s and continued through 2006, when the yard was permanently closed. Former facilities at the Site include a diesel shop, a machine shop, a roundhouse, two turntables, underground and aboveground storage tanks (USTs and ASTs), a service track area, and miscellaneous buildings. A storm water collection system and associated industrial wastewater treatment plant (IWTP) were in operation at the Site until decommissioning in 2011. Materials previously used or stored at the Site included diesel fuel, Bunker C fuel oil, journal box lubrication oil, gasoline, other types of oils, greases, acids, alkaline cleaning soaps, water treatment chemicals, paints and thinners, pesticides and herbicides, compressed gases, lead, cleaning solvents, and chlorinated solvents. Since 1985, a number of soil and groundwater investigations have been conducted at the Site. Results of the several progressive phases of remedial investigation have identified constituents of potential concern (COPCs) in the Site soil to be lead, arsenic, petroleum hydrocarbons (TPH), volatile organic compounds (VOCs), and semi-volatile organic compounds (SVOCs). VOCs are also present in groundwater beneath the Site; however, groundwater impacts are generally attributed to the regional VOC groundwater plume and VOC sources located upgradient of the Site.
In 2004, CDM implemented a Focused Remedial Investigation (RI) to delineate the lateral and vertical extent of COPCs in Site soil. These data were used in preparation of a Human Health Risk Assessment (HHRA). The HHRA evaluated the COPCs and determined a subset to be constituents of concern (COCs) for the Site. COCs for soil include TPH total (C12 to C35+), antimony, arsenic, lead, benzo (a) pyrene equivalents, and tetrachloroethene. COCs for soil gas include benzene, 1,2-dichloroethane, cis- 1,2-dichlorothene, ethylbenzene, naphthalene, tetrachloroethene, trichloroethene, and vinyl chloride. The HHRA then determined human health risks under appropriate exposure scenarios and pathways, and concluded that unacceptable risks were present at the Site and a FS was warranted to address these risks. Results of the HHRA were used to delineate Areas of Potential Concern (AOPCs) at the Site requiring further evaluation. AOPCs were defined by comparing COC concentrations to site-specific preliminary remediation goals (PRGs) and delineating areas of the Site where concentrations exceed PRGs. AOPCs encompass Site areas where, if COCs could be removed or treated sufficiently, the resulting Site-wide upper confidence limit (UCL) concentrations (UCL95) of the COCs would be reduced to below their PRGs. Four AOPCs were developed for soil based on lead, arsenic, TPH, and
ES-2
Executive Summary
antimony concentrations in the upper ten feet of soil (designated AOPC 1, AOPC 2, AOPC 3, and AOPC 4) and three AOPCs were developed for VOCs in soil gas (designated AOPC A, AOPC B, and AOPC C). The combined areas of these seven AOPCs collectively constitute three noncontiguous remedial action areas within the Site.
The following activities were performed to evaluate remedial alternatives:
§ Development of Remedial Action Objectives (RAOs);
§ Identification of project-specific Applicable or Relevant and Appropriate Requirements (ARARs)
for the remediation; § Evaluation of technologies and process options that are potentially applicable for the planned
remediation; § Incorporation of retained process options into possible remedial alternatives.
Based on the conclusions from the RI and results from the aforementioned activities, five remedial alternatives were developed and evaluated in the final FS and FS technical memorandum:
§ Alternative 1 - No action (included as a baseline for comparison);
§ Alternative 2 – Continued operation of the Area 3 soil vapor extraction system (VES) and record
institutional controls; § Alternative 3 – Cap all remedial action areas with pavement, install vapor mitigation systems,
record institutional controls, reinstallation and continued operation of the Area 3 VES, and record institutional controls;
§ Alternative 4 – Excavation of soil to depths of 10 feet below grade, backfill remedial action
areas, off-site disposal of soil, recording of institutional controls, reinstallation and continued operation of the Area 3 VES, and record institutional controls; and
§ Alternative 5 – Excavation of soil to depths of 2.5 to 5 feet below grade, backfill remedial action
areas, off-site disposal of soil, free-product removal and installation of a passive bioventing system around W-27 area, capping of the excavation areas, recording of institutional controls, and, if needed, reinstallation and continued operation of the Area 3 VES.
All alternatives were evaluated against the nine criteria outlined in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and in the California Health and Safety Code §25356.1(d), which include:
§ Protection of Human Health and Environment
§ Compliance with ARARs
§ Long-Term Effectiveness and Permanence
§ Reduction of Toxicity, Mobility, or Volume through Treatment
ES-3
Executive Summary
§ Short-Term Effectiveness
§ Implementability
§ Cost
§ State Acceptance
§ Community Acceptance
DTSC solicited and received comments on the draft FS, dated March 23, 2011, from the Los Angeles River Project (City of Los Angeles Department of Public Works), Natural Resources Defense Council, Friends of the Los Angeles River, the River Project, the Los Angeles Sector California State Parks, and the Mountains Recreation and Conservation Authority Los Angeles River Center and Gardens. These public comments as well as DTSC comments on the draft FS were addressed in the September 2011 version of the FS. Although not required under the NCP, each remedial alternative was also evaluated for sustainability in accordance with the DTSC’s Interim Advisory for Green Remediation (DTSC, 2009).
Alternative 5 was developed after submittal of the September 2011 version of the FS, in response to comments from DTSC. Alternative 5 is a hybrid remedial alternative combining capping with excavation designed to achieve all of the RAOs developed in the FS while resulting in maximum reductions in risk and site-wide exposure point concentration (EPCs) with minimal localized excavation. To remediate the impacted site soil and groundwater present at the Site, Alternative 5 consists primarily of the following elements:
§ Data Gaps Investigation – A subsurface investigation will be conducted prior to remedial action
and Site development to address the six data gaps identified during the development of the FS. Drillings of borings, soil sample collection, field screening, laboratory analysis, soil gas survey, and a passive soil bioventing pilot study will be performed.
§ Shallow Soil Remediation – Hot spot excavation from 2.5 to 5 feet will be conducted to remove
the most impacted soil followed by backfilling with clean soil. Control measures associated with the excavation and backfilling activities will be implemented. Perimeter air monitoring and other safety precaution will be engineered during excavation.
§ Engineered Cap, Vapor Barrier, and Sub-Slab Venting System - A vapor barrier and passive sub-
slab venting system will be installed under the new building slab to prevent mitigate future vapor intrusion into Site buildings. The system will be engineered to allow the flexibility to be converted into an active system if warranted.
§ Operation of the Area 3 VES (Optional) – If necessary, based on the results of the Area 3 data
gaps investigation/soil gas survey, the Area 3 VES will be reinstalled and operated after Site redevelopment to mitigate elevated VOCs in soil gas at Area 3.
§ Passive Soil Bioventing - A passive soil bioventing system will be installed and operated in areas
where elevated concentrations of petroleum hydrocarbons are present in the deep vadose zone.
ES-4
Executive Summary
§ Free-Product Removal – A passive free-product recovery system will be installed at W-27 for
removal of free-product that has historically been detected at this well. § Monitoring and Reporting – Groundwater monitoring will be implemented to ensure the
effectiveness of the engineered remediation systems and to determine if any contingency plans and/or corrective actions are warranted.
§ Contingency for Groundwater Impacts - A groundwater contingency plan is included under
Alternative 5 for additional groundwater monitoring and/or mitigation in the event that site- specific risk based groundwater action levels are exceeded.
§ Institutional Controls – A land use covenant and groundwater use restriction will be prepared to
minimize the potential for human exposure to the impact Site soil and/or groundwater and to protect the integrity of the implemented remedy.
In addition to the aforementioned remedial activities, other elements of the remedial action including health and safety, the California Environmental Quality Act (CEQA), and public participation are also discussed.
Excavate to 10 feet
Tank Former UST 4
Former UST N Former UST M
Paint Shop #1 IRM
Power House
Area 4 - Former Debris Pile Area
Filter Storage Former UST 16 Area 1 - Service Track Area
Former UST C
Former UST 20 Dispenser
Oil House Maintenance
Building
Power House
Former Past Area
Area 3 - Diesel Shop Area
Excavate to 10 feet
Former Pond
Former UST 18
Auto Fueling Center
Active Turntable
Area 2 - South Turntable Area
Wheel Drop Pit and Operate Area 3 VES
Abandoned Turntable
Excavation Storm Water
Ponds
Oil/Water Separator Industrial Wastewater
Pre-Treatment Plant
Paint Locomotive Shed Wash Room Area
Excavate to 10 feet
Oil/Water Separator
Diesel Shop
Railyard
Boundary
Los Angeles River
Vegetated Buffer Zone
Excavate to 10 feet
Legend
Operate Area 3 Vapor Extraction System (VES)
Excavate to 10 feet
200
0 Feet
200
Union Pacific Railroad Taylor Yard Remedial Investigation
Alternative 4 Remedial Action Map Excavate to 10 Feet and Off-Site Disposal
Figure 6-4
