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Mohsen Nazemi MS PE Deputy DirectorBrownfields and Environmental Restoration Program
DTSC Site Mitigation PresentationDTSC Independent Review Panel Meeting ndash Part II
CalEPA Building SacramentoFebruary 8 2017
Agenda1 DTSC Coordination
bull Air Monitoringbull Radiological Contamination
2 Site Mitigation Decision-Making Process3 Five-Year Review Process4 Communications 5 Site Mitigation Funding
bull National Priorities List and State Orphan Sitesbull Program Funding and Expenditures
6 Program Improvements ndash Implemented and Underway7 Polychlorinated Biphenyls (PCB) Sample Analysis8 Exide Update
DTSCSite Mitigation Program Coordination
Federal Agenciesbull United States Environmental Protection Agency (EPA)bull Others (Department of Defense Fish and Wildlife)bull Tribal Outreach and ConsultationState AgenciesCalifornia Environmental Protection Agencybull California State Water Resources Control Board and Regional Water Quality
Control Boardsbull California Air Resources Boardbull California Office of Environmental Health Hazard AssessmentCalifornia Department of Public HealthCalifornia Fish and WildlifeLocal Agenciesbull Water Districtsbull Air Quality Management and Air Pollution Control Districtsbull County Agencies (eg Public Health and Certified Unified Program Agencies)bull School Districts
Federal Agency Coordination
United States Environmental Protection Agency (EPA)bull National Priorities List (Superfund) Site Cleanupsbull Corrective Action (Resource Conservation and
Recovery Act Facilities)bull Grants Othersbull MilitaryUS Dept of Defense Site Cleanupsbull US Dept of Energy Site Cleanups
Tribal Outreach and ConsultationExecutive Liaison
bull Executive Tribal Liaison established with the new Office of Environmental Justice (EJ) amp Tribal Affairs
bull Signals Department commitment to meaningful and respectful consultation across projects
bull Current and new projects are transitioning to include tribal outreach and consultation requests in coordination with the Executive Tribal Liaison
Tribal Outreach and ConsultationMandates
bull Executive Order B-10-11 requires state agencies to encourage and permit representatives of Tribal governments to provide meaningful input into the development of legislation regulations rules and policies on matters that may affect Tribal communities
bull Assembly Bill (AB) 52 (Public Resources Code Section 2108031 ndash 210803) requires lead agencies to consult with California Native American Tribes before conducting an environmental review of agency activities to ensure Tribal communities who may be impacted are informed and actively involved in mitigating any potential impacts
Tribal Outreach and ConsultationBuilding Relationships
bull Tribal consultation activities which rely on building and maintaining trusted relationships have previously been limited and lacked effective coordination within DTSC
bull DTSC is consulting with Tribes in developing a Department Tribal Consultation Policy scheduled to be finalized in early 2018
State and Local Agency Coordination
California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) amp Water Districtsbull DTSC Lead or Regional Water Quality Control Board Lead Projects
California Air Resources Board (ARB)Local Air Districtsbull Air dispersion modelingPermittingbull Ambient monitoringbull Health Risk Assessments (Air Toxics Hot Spots)
California and County Departments of Public Health (CDPH)bull Radiological contaminants bull Public Health Impacts for Toxicsbull Certified Unified Program Agencies
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Agenda1 DTSC Coordination
bull Air Monitoringbull Radiological Contamination
2 Site Mitigation Decision-Making Process3 Five-Year Review Process4 Communications 5 Site Mitigation Funding
bull National Priorities List and State Orphan Sitesbull Program Funding and Expenditures
6 Program Improvements ndash Implemented and Underway7 Polychlorinated Biphenyls (PCB) Sample Analysis8 Exide Update
DTSCSite Mitigation Program Coordination
Federal Agenciesbull United States Environmental Protection Agency (EPA)bull Others (Department of Defense Fish and Wildlife)bull Tribal Outreach and ConsultationState AgenciesCalifornia Environmental Protection Agencybull California State Water Resources Control Board and Regional Water Quality
Control Boardsbull California Air Resources Boardbull California Office of Environmental Health Hazard AssessmentCalifornia Department of Public HealthCalifornia Fish and WildlifeLocal Agenciesbull Water Districtsbull Air Quality Management and Air Pollution Control Districtsbull County Agencies (eg Public Health and Certified Unified Program Agencies)bull School Districts
Federal Agency Coordination
United States Environmental Protection Agency (EPA)bull National Priorities List (Superfund) Site Cleanupsbull Corrective Action (Resource Conservation and
Recovery Act Facilities)bull Grants Othersbull MilitaryUS Dept of Defense Site Cleanupsbull US Dept of Energy Site Cleanups
Tribal Outreach and ConsultationExecutive Liaison
bull Executive Tribal Liaison established with the new Office of Environmental Justice (EJ) amp Tribal Affairs
bull Signals Department commitment to meaningful and respectful consultation across projects
bull Current and new projects are transitioning to include tribal outreach and consultation requests in coordination with the Executive Tribal Liaison
Tribal Outreach and ConsultationMandates
bull Executive Order B-10-11 requires state agencies to encourage and permit representatives of Tribal governments to provide meaningful input into the development of legislation regulations rules and policies on matters that may affect Tribal communities
bull Assembly Bill (AB) 52 (Public Resources Code Section 2108031 ndash 210803) requires lead agencies to consult with California Native American Tribes before conducting an environmental review of agency activities to ensure Tribal communities who may be impacted are informed and actively involved in mitigating any potential impacts
Tribal Outreach and ConsultationBuilding Relationships
bull Tribal consultation activities which rely on building and maintaining trusted relationships have previously been limited and lacked effective coordination within DTSC
bull DTSC is consulting with Tribes in developing a Department Tribal Consultation Policy scheduled to be finalized in early 2018
State and Local Agency Coordination
California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) amp Water Districtsbull DTSC Lead or Regional Water Quality Control Board Lead Projects
California Air Resources Board (ARB)Local Air Districtsbull Air dispersion modelingPermittingbull Ambient monitoringbull Health Risk Assessments (Air Toxics Hot Spots)
California and County Departments of Public Health (CDPH)bull Radiological contaminants bull Public Health Impacts for Toxicsbull Certified Unified Program Agencies
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
DTSCSite Mitigation Program Coordination
Federal Agenciesbull United States Environmental Protection Agency (EPA)bull Others (Department of Defense Fish and Wildlife)bull Tribal Outreach and ConsultationState AgenciesCalifornia Environmental Protection Agencybull California State Water Resources Control Board and Regional Water Quality
Control Boardsbull California Air Resources Boardbull California Office of Environmental Health Hazard AssessmentCalifornia Department of Public HealthCalifornia Fish and WildlifeLocal Agenciesbull Water Districtsbull Air Quality Management and Air Pollution Control Districtsbull County Agencies (eg Public Health and Certified Unified Program Agencies)bull School Districts
Federal Agency Coordination
United States Environmental Protection Agency (EPA)bull National Priorities List (Superfund) Site Cleanupsbull Corrective Action (Resource Conservation and
Recovery Act Facilities)bull Grants Othersbull MilitaryUS Dept of Defense Site Cleanupsbull US Dept of Energy Site Cleanups
Tribal Outreach and ConsultationExecutive Liaison
bull Executive Tribal Liaison established with the new Office of Environmental Justice (EJ) amp Tribal Affairs
bull Signals Department commitment to meaningful and respectful consultation across projects
bull Current and new projects are transitioning to include tribal outreach and consultation requests in coordination with the Executive Tribal Liaison
Tribal Outreach and ConsultationMandates
bull Executive Order B-10-11 requires state agencies to encourage and permit representatives of Tribal governments to provide meaningful input into the development of legislation regulations rules and policies on matters that may affect Tribal communities
bull Assembly Bill (AB) 52 (Public Resources Code Section 2108031 ndash 210803) requires lead agencies to consult with California Native American Tribes before conducting an environmental review of agency activities to ensure Tribal communities who may be impacted are informed and actively involved in mitigating any potential impacts
Tribal Outreach and ConsultationBuilding Relationships
bull Tribal consultation activities which rely on building and maintaining trusted relationships have previously been limited and lacked effective coordination within DTSC
bull DTSC is consulting with Tribes in developing a Department Tribal Consultation Policy scheduled to be finalized in early 2018
State and Local Agency Coordination
California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) amp Water Districtsbull DTSC Lead or Regional Water Quality Control Board Lead Projects
California Air Resources Board (ARB)Local Air Districtsbull Air dispersion modelingPermittingbull Ambient monitoringbull Health Risk Assessments (Air Toxics Hot Spots)
California and County Departments of Public Health (CDPH)bull Radiological contaminants bull Public Health Impacts for Toxicsbull Certified Unified Program Agencies
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Federal Agency Coordination
United States Environmental Protection Agency (EPA)bull National Priorities List (Superfund) Site Cleanupsbull Corrective Action (Resource Conservation and
Recovery Act Facilities)bull Grants Othersbull MilitaryUS Dept of Defense Site Cleanupsbull US Dept of Energy Site Cleanups
Tribal Outreach and ConsultationExecutive Liaison
bull Executive Tribal Liaison established with the new Office of Environmental Justice (EJ) amp Tribal Affairs
bull Signals Department commitment to meaningful and respectful consultation across projects
bull Current and new projects are transitioning to include tribal outreach and consultation requests in coordination with the Executive Tribal Liaison
Tribal Outreach and ConsultationMandates
bull Executive Order B-10-11 requires state agencies to encourage and permit representatives of Tribal governments to provide meaningful input into the development of legislation regulations rules and policies on matters that may affect Tribal communities
bull Assembly Bill (AB) 52 (Public Resources Code Section 2108031 ndash 210803) requires lead agencies to consult with California Native American Tribes before conducting an environmental review of agency activities to ensure Tribal communities who may be impacted are informed and actively involved in mitigating any potential impacts
Tribal Outreach and ConsultationBuilding Relationships
bull Tribal consultation activities which rely on building and maintaining trusted relationships have previously been limited and lacked effective coordination within DTSC
bull DTSC is consulting with Tribes in developing a Department Tribal Consultation Policy scheduled to be finalized in early 2018
State and Local Agency Coordination
California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) amp Water Districtsbull DTSC Lead or Regional Water Quality Control Board Lead Projects
California Air Resources Board (ARB)Local Air Districtsbull Air dispersion modelingPermittingbull Ambient monitoringbull Health Risk Assessments (Air Toxics Hot Spots)
California and County Departments of Public Health (CDPH)bull Radiological contaminants bull Public Health Impacts for Toxicsbull Certified Unified Program Agencies
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Tribal Outreach and ConsultationExecutive Liaison
bull Executive Tribal Liaison established with the new Office of Environmental Justice (EJ) amp Tribal Affairs
bull Signals Department commitment to meaningful and respectful consultation across projects
bull Current and new projects are transitioning to include tribal outreach and consultation requests in coordination with the Executive Tribal Liaison
Tribal Outreach and ConsultationMandates
bull Executive Order B-10-11 requires state agencies to encourage and permit representatives of Tribal governments to provide meaningful input into the development of legislation regulations rules and policies on matters that may affect Tribal communities
bull Assembly Bill (AB) 52 (Public Resources Code Section 2108031 ndash 210803) requires lead agencies to consult with California Native American Tribes before conducting an environmental review of agency activities to ensure Tribal communities who may be impacted are informed and actively involved in mitigating any potential impacts
Tribal Outreach and ConsultationBuilding Relationships
bull Tribal consultation activities which rely on building and maintaining trusted relationships have previously been limited and lacked effective coordination within DTSC
bull DTSC is consulting with Tribes in developing a Department Tribal Consultation Policy scheduled to be finalized in early 2018
State and Local Agency Coordination
California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) amp Water Districtsbull DTSC Lead or Regional Water Quality Control Board Lead Projects
California Air Resources Board (ARB)Local Air Districtsbull Air dispersion modelingPermittingbull Ambient monitoringbull Health Risk Assessments (Air Toxics Hot Spots)
California and County Departments of Public Health (CDPH)bull Radiological contaminants bull Public Health Impacts for Toxicsbull Certified Unified Program Agencies
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Tribal Outreach and ConsultationMandates
bull Executive Order B-10-11 requires state agencies to encourage and permit representatives of Tribal governments to provide meaningful input into the development of legislation regulations rules and policies on matters that may affect Tribal communities
bull Assembly Bill (AB) 52 (Public Resources Code Section 2108031 ndash 210803) requires lead agencies to consult with California Native American Tribes before conducting an environmental review of agency activities to ensure Tribal communities who may be impacted are informed and actively involved in mitigating any potential impacts
Tribal Outreach and ConsultationBuilding Relationships
bull Tribal consultation activities which rely on building and maintaining trusted relationships have previously been limited and lacked effective coordination within DTSC
bull DTSC is consulting with Tribes in developing a Department Tribal Consultation Policy scheduled to be finalized in early 2018
State and Local Agency Coordination
California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) amp Water Districtsbull DTSC Lead or Regional Water Quality Control Board Lead Projects
California Air Resources Board (ARB)Local Air Districtsbull Air dispersion modelingPermittingbull Ambient monitoringbull Health Risk Assessments (Air Toxics Hot Spots)
California and County Departments of Public Health (CDPH)bull Radiological contaminants bull Public Health Impacts for Toxicsbull Certified Unified Program Agencies
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Tribal Outreach and ConsultationBuilding Relationships
bull Tribal consultation activities which rely on building and maintaining trusted relationships have previously been limited and lacked effective coordination within DTSC
bull DTSC is consulting with Tribes in developing a Department Tribal Consultation Policy scheduled to be finalized in early 2018
State and Local Agency Coordination
California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) amp Water Districtsbull DTSC Lead or Regional Water Quality Control Board Lead Projects
California Air Resources Board (ARB)Local Air Districtsbull Air dispersion modelingPermittingbull Ambient monitoringbull Health Risk Assessments (Air Toxics Hot Spots)
California and County Departments of Public Health (CDPH)bull Radiological contaminants bull Public Health Impacts for Toxicsbull Certified Unified Program Agencies
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
State and Local Agency Coordination
California State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) amp Water Districtsbull DTSC Lead or Regional Water Quality Control Board Lead Projects
California Air Resources Board (ARB)Local Air Districtsbull Air dispersion modelingPermittingbull Ambient monitoringbull Health Risk Assessments (Air Toxics Hot Spots)
California and County Departments of Public Health (CDPH)bull Radiological contaminants bull Public Health Impacts for Toxicsbull Certified Unified Program Agencies
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Use of Health Protective PracticesIn Site Mitigation
During site remediationndash Goal is containment of hazardous
substancesndash Focus on mitigation measuresndash Effective source control onsitendash Perimeter air monitoring for confirmation
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Regulatory Oversight Components
bull Follow local Air District rules
bull Develop site and chemical specific risk-
based action levels
bull Mitigation MeasuresAir Monitoring
bull Field oversight
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Local Air District Rules
bull Fugitive Dust Emissionsbull Volatile Organic Compound Emissionsbull Soil Excavation Stockpiling and
Transportation(eg South Coast Air Quality Management District Rules 403 and 1166)
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Action LevelsMonitoring
bull On-Site Worker Health and Safety
bull Off-Site Resident Protection
bull Perimeter Air Monitoring
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Field Oversight
Watering for Dust Control Soil Sampling
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Overview ndash DTSC Role Disposal of Radiological Contamination
Presented by Ray Leclerc ndash Division Chief
Regulatory Authoritybull Soil and Groundwater
ndash Potential radiological-impacted soil and groundwater evaluated under Remedial Investigation Process by DTSC with California Department of Public Health (Radiological Branch) and in some cases EPA assistance
bull Buildings and Debrisndash DTSC has no direct statutory authorityndash US Nuclear Regulatory Commission and California Department of
Public Health (Radiological Branch) provide licensing and decommissioning approvals
ndash US Department of Energy has decision authority on Department of Energy closures
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Disposal Optionsbull Material classified as Low-Level Radioactive Waste must be
disposed at Low-Level Radioactive Waste-licensed facilitybull Decommissioned buildings cleared by the US Nuclear
Regulatory Commission and California Department of Public Health for unrestricted use may legally be disposed or recycled without restrictions
bull US Nuclear Regulatory Commission and California Department of Public Health ndash unrestricted use if the residual radioactivity that is distinguishable from background radiation does not exceed 25 mremyr
bull Governorrsquos 2002 moratorium prohibits municipal landfill disposal (httpswwwcdphcagovcertlicradquipDocumentsRHB-HT-EO-D-62-02htm)
bull Buildings and structures with no prior radiological use have no legal disposal restrictions
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Debris Surveys and Disposal Decisions
bull Buildings and structures surveyed by Responsible Party contractors prior to demolition
bull Surveys consist of surface scans and wipe samples analyzed in conformance with existing laws regulations guidance and established standards
bull Debris with confirmed or suspected elevated radiological activity sent to Low-Level Radioactive Waste landfills
bull Non-impacted debris associated with radiological operations may be sent to Class I landfills if it meets landfill disposal criteria
bull Recycling of non-impacted debris (concrete and steel) allowable under law
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Mitigation Decision-Making Process
Presented by Dot Lofstrom ndash Division Chiefbull Initial Discoverybull Site Assessmentbull Selecting Remedies
ndash Identifying Optionsndash Selection Process
bull Overseeing Remedial and Removal Actionsndash Implementationndash Long-Term Remedies
bull End of Projects
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Cleanup Process Steps
Process StepCorrective Action Facilities
(California Health amp Safety Code Division 20 Chapter 65)
State Superfund Sites(California Health amp Safety Code
Division 20 Ch 68)
EVALUATION
Resource Conservation and Recovery Act Facility Assessment
Preliminary Endangerment Assessment
Resource Conservation and Recovery Act Facility Investigation
Remedial Investigation
REMEDY SELECTION
Corrective Measures Study Feasibility Study
Remedy SelectionStatement of Basis Remedial Action Plan
IMPLEMENTATIONCorrective Measures Implementation Remedial Action Implementation
Operations amp Maintenance Operations amp Maintenance
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Discovery
Sites discovered byndash Emergency responsesndash Agency referralsndash Voluntary cleanupsndash EPA Preliminary AssessmentSite Investigation
Grant ndash Orphan Programndash Citizen complaints
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Initial Site Assessment
bull Verify hazardous substance releases and existence of threatndash Sample soil soil vapor groundwater surface waterndash Preliminary assessment of risks
bull Sites with gt 1 in million cancer risk or gt 10 hazard index require further assessment
bull Identify potential responsible parties and order cleanup
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Characterization
bull Conceptual Site Model ndash framework for investigation
bull Define nature and extent of contaminationndash Soilndash Soil gasndash Groundwaterndash Surface water
bull Risk assessment to quantify health risk
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Selection ndash Identifying Remedial Options
bull Feasibility study to identify remedial (cleanup) options
bull Based onndash The Nine Criteria in the National Oil and
Hazardous Substances Pollution Contingency Planndash Health amp Safety Code Division 20 Chapter 68
Section 253561 for state superfund sites
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
National Contingency Plan Nine Criteria
Threshold Criteria1 Overall protection of human health and the environment2 Compliance with applicable or relevant and appropriate requirements Primary Balancing Criteria3 Long-term effectiveness and permanence4 Reduction of toxicity mobility or volume5 Short-term effectiveness6 Implementability7 CostModifying Criteria8 State acceptance9 Community acceptance
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
California Health amp Safety Code Section 253561 (Six Criteria)
bull Site health and safety risksbull Effect of contamination on resourcesbull Effect on groundwater and availability of
treatment bull Site contamination and ability to move off-sitebull Cost effectiveness of measures consideredbull Environmental impacts of land disposal versus
treatment options
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Remedy Selection
bull State Superfund Sites ndash Remedial Action Plans (interim and final remedies)ndash Removal Action Workplans (removals lt $2 million)
bull Hazardous Waste Facility Corrective Actionndash Corrective measures proposal and selection
bull Decision documents subject tondash Public review and commentndash California Environmental Quality Act analysis
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Remedy Selection (continued)
bull Cleanup Goals based onndash Backgroundndash Acceptable Health Risk National Contingency Plan
defines bull 1 in 10000 to 1 in a million excess cancer riskbull Hazard Index generally lt10 non-cancer risk
bull Selection based on ndash Ability to satisfy Nine Criteria and California Health
and Safety Code Division 20 Chapter 68 Criteriandash Ability to meet cleanup goals
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Remedy Implementation
bull Review and approval of ndash Remedy design plansndash Monitoring plans
bull Must obtain State and local agency permits if required
bull Field oversight to ensurendash Meets design workplans applicable regulationsndash Work conducted in safe protective manner
bull Confirmation sampling to verify cleanup levels attained
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Sites with Long-Term Remedies
bull Operations and Maintenance Agreement ndash Description of operations monitoring shut downndash Financial assurancendash Inspections and Five-Year Reviews
bull Land use restrictions ndash Enforced via land use covenant with site owner
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
End of Projectbull Unrestricted Land Use
ndash Meets all cleanup levels and remedy goalsbull Restricted Land Use
ndash Long term remedies operating properly and successfully
ndash Land use covenant with property ownerndash Operations and Maintenance Plans and financial
assurance in place if requiredndash DTSC monitors for duration of remedy or
restrictions
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Five-Year Review ProcessPresented by Ray Leclerc Division Chief
bull DTSC reviews remedies approximately every five years where hazardous substances is left in placendash Exclusions
bull Consistent with the Federal National Contingency Plan
bull Include estimate of future costs and associated financial assurance
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Five-Year Review Process
Evaluatebull Is the remedy still protective and is it
operating as intendedbull Are the cleanup levels and remedial objectives
still currentvalidbull Is there any new information that would affect
the protectiveness of the original remedybull Is financial assurance adequate going
forward
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Five-Year Review Process -Components
bull Technical reviewbull Financial assurance reviewbull Community Involvement bull Conclusionsactions
ndash Determine that remedy still protectivendash Determine that financial assurance still adequatendash If not change remedyupdate financial assurance
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
DTSC CommunicationsPresented by Dot Lofstrom ndash Division Chief
bull Each site hasndash Project manager who manages DTSC oversight functions
bull Includes additional support staff as appropriatendash Toxicologist Geologist Engineer Attorney Public
Participation Specialistbull Project Manager Activities Supervised by
ndash Unit Supervisorndash Branch Chiefndash Division Chief
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Communicating Progress to the Public
bull Community Involvement Planndash Defines affected community and their concernsndash Informs elected officials and city councilsndash Plan for communicating progress
bull Fact sheets mailed out to inform community as neededndash Milestone completionsndash Project timelinesndash Public meeting announcements
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Mitigation Funding - Orphan SitesPresented by Charlie Ridenour ndash
Chief Sacramento Cleanup Branch
bull Fund-Lead National Priority List (NPL) Sites (Superfund)
bull State Orphan Site
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Selma Treating Company ndashNational Priorities List Site
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Selma Treating Company - Excavation
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Selma Treating Company
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Hexavalent Chromium in the Groundwater One Mile Away
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
KlauBuena Vista Mercury Mine
bull NPL Sitebull Orphanbull Mine Drainage
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Orphan Site ndash Plating Shop
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Orphan Site ndash Plating Shop
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Orphan Site - Wood Treatment FacilityChromic Acid Contaminated Concrete
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Abandoned Mine Waste
bull Acid Soilbull Arsenicbull Between Residential
and High School
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Fund-Lead National Priorities List and State Orphan Background
bull Laws require responsible party to cleanupbull No responsible partybull Imminent threat - response needed nowbull Responsible party fails to comply with a
cleanup orderbull California Health and Safety Code ndash revised to
establish the Site Remediation Account
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Remediation Accountbull Funding is appropriated annually from Toxic
Substances Control Accountbull Only available for ldquoDirect Site Remediation
Costsrdquobull Not for state staffingbull Historically - ldquoFixed Formulardquo bull ~$10 million per yearbull Need in Fiscal Year 201617 =gt $23 million
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Remediation Account (continued)
bull Appropriation can be used for four yearsbull Funding allocated by prioritybull Documented in expenditure planbull Fund approximately 50 activities each year
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Remediation Account (continued)
Account funds allowed to be used forndash Pay state share at Fund-Lead National Priorities List
sitesndash Discover sitesFind responsible partiesndash Removal or Remedial Action
bull When there is imminent or substantial endangermentbull Where there is no responsible partybull Where responsible party fails to comply with
enforcement order
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Remediation Account (continued)
bull 107 projects bull 22 listed on National Priorities List ndash ldquoFund-Lead
National Priorities Listrdquobull Remainder are ldquoState Orphanrdquobull Wood treatment facilities chemical formulators
landfills mines dry cleaners plating shops radiator shops etcetera
bull Bankrupt company dissolved abandoned or ldquoMom and Poprdquo operation
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
NPLOrphan Demands
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Assembly Bill 2891 ndash Site Remediation Account
bull Changed funding process starting Fiscal Year 2017bull Report to Legislaturebull Direct site remediation costs
ndash Fund-Lead National Priorities List obligationsndash State Orphan sitesndash Three-Year Cost Estimate
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Sources of Site Mitigation Program FundingPresented by Jennifer Black ndash
Chief Grants and Program Support Branch
Major Funding Sources (gt75 of Cleanup Expenditures)bull General Fundbull Toxic Substances Control Accountbull Federal Trust FundOther Funding Sourcesbull Reimbursementsbull Site Remediation Accountbull Local Assistance (Federal and State Funding)bull Settlement Fundsbull Illegal Drug Lab Cleanup Account
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Cleanup Program Funding Split
$43669000 32
$10503000 8
$828000 lt1$3718000 3
$39478000 29
$22014000 16
$4027000 3
$11433000 8
Budgeted Expenditures Fiscal Year 2016172016 Budget Act - Dollars
General Fund
Site Remediation Account
Illegal Drug Lab Cleanup Account
Settlement Funds
Toxic Substances Control Account(TSCA)Federal Trust Fund
Local Assistance (Loan Programs)
Reimbursements
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
SITE MITIGATION PROGRAM IMPROVEMENTS
bull Process Improvementsndash Enhanced Remedy Selectionndash Spatial Prioritization Geographic Information Tool
bull Other Improvements Underwayndash Voluntary Cleanupsndash Toxicity Criteria Rulemaking
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Mitigation Program Improvements Enhanced Remedy Selection (Corrective Action)
Presented by Ajit Vaidya Unit Chief Engineering and Special Projects Office
bull Goal Reduce time for remedy selection process at Resource Conservation and Recovery Act corrective action sites whilendash Protecting human health and the environment ndash Ensuring cleanup goals are metndash Maintaining public participation and California Environmental Quality Act
compliance
bull Two concurrent DTSC initiatives in 2016ndash Remedy Selection Process Improvement Projectndash Univar Remedy Selection Streamlining Pilot
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Remedy Selection Process Improvement
bull Project features ndash Lean Principles Eliminate WasteData Drivenndash Evaluate EnviroStor data for DTSCrsquos existing processndash Identify root causes of delay for remedy selectionndash Develop ways to streamline remedy selection process
bull Proposed process improvementsndash Agree on conceptual site model and cleanup goals upfrontndash Eliminate duplicative workre-work
bull Front-end coordinationbull Elevate decisions quickly
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Corrective Measures Study 84
California Environmental Quality Act 9
Decision Document 7
Identifying Process Steps With Long Completion Times
Breakdown of Process Times
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Remedy Selection Streamlining Pilot Project
Univar Success Storybull Pilot Project at Univar site in Commerce
ndash Stalled groundwater cleanup sitendash Applied United States Environmental Protection Agencyrsquos
Resource Conservation and Recovery Act streamlining concepts (RCRA FIRST)
ndash Remedy Selection kick-off meeting held in February 2016bull Breakthrough momentbull Reached decisions on critical issues
bull Streamlined Corrective Measures Study ndash Resource Conservation and Recovery Act allows flexibilityndash One-size fits all approach not appropriatendash May consider single or few remedial alternatives
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Remedy Selection Corrective Measures Study Process
Define Conceptual Site Model amp Cleanup
Objectives
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Remedy Selection Streamlining PilotUnivar Success Story - RESULT
bull Final remedy selected in nine months (December 2016)bull Off-site groundwater cleanup to begin in 2018 two
years ahead of schedule
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Enhanced Remedy Selection Process Improvements Next Steps
bull Select three additional pilot sites in 2017ndash Apply enhanced remedy selection process consistent with
above identified streamlining principlesndash Track critical milestones for selected pilot sites
bull Provide training to project managersstaff
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Site Mitigation Program ImprovementsRick Fears Senior Engineering Geologist
Geological Services Branch
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Spatial Prioritization Geographic Information Tool Factors
Factor Weight
A Health Risk ndash Contaminated Drinking Water Well Count 8
B Potential Risk ndash Generator Density 3
C Environmental Justice ndash Cal EnviroScreen 2
D Environmental Work Completed 1
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Future Improvements
bull Voluntary Cleanup Programndash Streamline decision-making processndash Reduce time for DTSCrsquos review of workplans and reports
bull Proposed Toxicity Criteria Rulemakingndash Develop regulation establishing uniform more predictable
process to select toxicity criteria for risk-based remediation ndash Prioritize established and peer-reviewed sources of risk-
based criteria to develop protective cleanup levelsndash DTSC held informational workshop on the pre-rulemaking
draft regulation and provided opportunity for public input
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Investigation of Why Different Labs Reported Different Results
Bruce La Belle Ph DDTSC
Environmental Chemistry Laboratory
66
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
What Wersquoll CoverWhat are PCBs and ldquoAroclorsrdquo ndash mixtures of
closely-related chemicals (ldquocongenersrdquo)
EPA Method 8082 for reporting PCBs as Aroclors -has inherent variability
Labs used different methods to extract the PCBs from the soil samples ndash can affect results
Aroclor mixtures ldquoweatherrdquo over time in the environment ndash needs to be considered
Labs use different PCB congeners to determine the amount of Aroclors present ndash can affect results
67
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
What are PCBs and Aroclors
68
bull PCB = ldquoPolychlorinated biphenylrdquo
bull 1-10 chlorines on ldquobiphenylrdquo rings
bull 209 ldquocongenersrdquo with different numbers and locations of chlorines
bull Sold as mixtures of congeners called ldquoAroclorsrdquo 1248 1254 1260 etc
bull Excellent properties oily liquids heat stable electrical resistor fire resistant
bull Electrical transformers fluorescent light ballasts plasticizer in caulk fire-resistant coatings
bull Fire-resistant high-pressure hydraulic fluids
Biphenyl
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
BackgroundDTSC sent soil samples from Ag Park to a
commercial lab (A) for PCB analysis by EPA Method 8082 (reported as Aroclors)
EPA Region 9rsquos Lab analyzed soil samples collected at adjacent locations EPA sent split samples to a different commercial lab (B) for testing as well
Results from Lab A appeared to be 2-3 times lower than the results from EPA
ECL was asked to investigate the reasons for the differences
69
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
The IssueEPA Results Lab A Results
Collection Date 912015 912015 Diff RPDCollector ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg) RivAg-F8-Surf 2 046 5 017 029 92RivAg-G8-Surf 1 034 5 0099 0241 110RivAg-F7-Surf 1 016 1 0057 0103 95RivAg-D7-Surf 1 0034 1 0011 0023 102RivAg-B7-Surf 1 0056 1 0021 0035 91RivAg-C6-Surf 1 014 1 0062 0078 77RivAg-E6-Surf 5 084 5 042 042 67RivAg-G6-Surf 1 011 1 0043 0067 88RivAg-F5-Surf 2 042 1 012 03 111RivAg-D5-Surf 2 041 1 013 028 104RivAg-C5-Surf 5 095 1 029 066 106RivAg-C55-Surf 5 12 5 035 085 110RivAg-D4-Surf 10 19 5 08 11 81RivAg-F3-Surf 20 37 10 18 19 69RivAg-D3-Surf 1 029 1 013 016 76RivAg-C2-Surf 1 012 1 0066 0054 58
Lab A results were lower than those from EPArsquos lab
70
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
What ECL DidReviewed ldquoLevel 4 data packagesrdquo from Lab A and
EPA Lab
Discussed with Lab A and EPA lab personnel
Conducted experiments to compare Soxhlet and sonication soil extraction methods
Reviewed a spreadsheet EPA provided that listed split sample results from their lab and those from a different commercial lab (Lab B)
71
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
Steps to Analyzing a Sample
72
1 Receive soil sample
2 Extract small portion ldquoaliquotrdquo of the sample Method 8082 references several other EPA methods for extracting the sample including ldquoSoxhletrdquo (Method 3540) and Sonication (Method 3550) The ldquoextractrdquo is cleaned-up to remove impurities and prevent instrument contamination
3 EPA Method 8082 analyze the sample extract on a ldquoGas Chromatographrdquo instrument
4 Identify what PCB Aroclors are present
5 Calculate amount of each Aroclor present in the sample
Calibration Curve
y = 102509x + 18101R2 = 09975
0
500000
1000000
1500000
2000000
2500000
3000000
0 5 10 15 20 25 30
Concentration (ppb)
Inst
rum
ent R
esp
on
se
73
Example Your Cup of Coffeebull Same beansbull Different extractionbull Some variability in taste but within tolerances of coffee
Percolator Presse Drip
Extraction Method Can Make A Difference but Within Tolerances of the Method
EPA Method 8082 References Various Methods for Soil Extraction
74
Soxhlet extraction(EPA Method 3040)
Reflux for 16-24 hours so solvent continuously drips through soil in
porous thimble (filter)
Sonication (EPA Method 3550)
Sonicate three times for three minutes each with ultrasonic probe
EPA Method 8082 PCBs by Gas Chromatography
75
5Each PCB congener shown as a peak on a ldquochromatogramrdquo
Time
Gas Chromatograph
1Sample extract injected
2PCBs pass through hollow 30 meter ldquocolumnrdquoAt different rates depending on size and shape
3Different PCBs come out at different times
4PCBs detected
Helium gas
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
| Concentration | Response | ||
| 1 | 99555 | ||
| 5 | 500101 | ||
| 10 | 1100201 | ||
| 20 | 2120500 | ||
| 25 | 2523201 |
| 1 | |
| 5 | |
| 10 | |
| 20 | |
| 25 |
73
Example Your Cup of Coffeebull Same beansbull Different extractionbull Some variability in taste but within tolerances of coffee
Percolator Presse Drip
Extraction Method Can Make A Difference but Within Tolerances of the Method
EPA Method 8082 References Various Methods for Soil Extraction
74
Soxhlet extraction(EPA Method 3040)
Reflux for 16-24 hours so solvent continuously drips through soil in
porous thimble (filter)
Sonication (EPA Method 3550)
Sonicate three times for three minutes each with ultrasonic probe
EPA Method 8082 PCBs by Gas Chromatography
75
5Each PCB congener shown as a peak on a ldquochromatogramrdquo
Time
Gas Chromatograph
1Sample extract injected
2PCBs pass through hollow 30 meter ldquocolumnrdquoAt different rates depending on size and shape
3Different PCBs come out at different times
4PCBs detected
Helium gas
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
| Concentration | Response | ||
| 1 | 99555 | ||
| 5 | 500101 | ||
| 10 | 1100201 | ||
| 20 | 2120500 | ||
| 25 | 2523201 |
73
Example Your Cup of Coffeebull Same beansbull Different extractionbull Some variability in taste but within tolerances of coffee
Percolator Presse Drip
Extraction Method Can Make A Difference but Within Tolerances of the Method
EPA Method 8082 References Various Methods for Soil Extraction
74
Soxhlet extraction(EPA Method 3040)
Reflux for 16-24 hours so solvent continuously drips through soil in
porous thimble (filter)
Sonication (EPA Method 3550)
Sonicate three times for three minutes each with ultrasonic probe
EPA Method 8082 PCBs by Gas Chromatography
75
5Each PCB congener shown as a peak on a ldquochromatogramrdquo
Time
Gas Chromatograph
1Sample extract injected
2PCBs pass through hollow 30 meter ldquocolumnrdquoAt different rates depending on size and shape
3Different PCBs come out at different times
4PCBs detected
Helium gas
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
73
Example Your Cup of Coffeebull Same beansbull Different extractionbull Some variability in taste but within tolerances of coffee
Percolator Presse Drip
Extraction Method Can Make A Difference but Within Tolerances of the Method
EPA Method 8082 References Various Methods for Soil Extraction
74
Soxhlet extraction(EPA Method 3040)
Reflux for 16-24 hours so solvent continuously drips through soil in
porous thimble (filter)
Sonication (EPA Method 3550)
Sonicate three times for three minutes each with ultrasonic probe
EPA Method 8082 PCBs by Gas Chromatography
75
5Each PCB congener shown as a peak on a ldquochromatogramrdquo
Time
Gas Chromatograph
1Sample extract injected
2PCBs pass through hollow 30 meter ldquocolumnrdquoAt different rates depending on size and shape
3Different PCBs come out at different times
4PCBs detected
Helium gas
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
73
Example Your Cup of Coffeebull Same beansbull Different extractionbull Some variability in taste but within tolerances of coffee
Percolator Presse Drip
Extraction Method Can Make A Difference but Within Tolerances of the Method
EPA Method 8082 References Various Methods for Soil Extraction
74
Soxhlet extraction(EPA Method 3040)
Reflux for 16-24 hours so solvent continuously drips through soil in
porous thimble (filter)
Sonication (EPA Method 3550)
Sonicate three times for three minutes each with ultrasonic probe
EPA Method 8082 PCBs by Gas Chromatography
75
5Each PCB congener shown as a peak on a ldquochromatogramrdquo
Time
Gas Chromatograph
1Sample extract injected
2PCBs pass through hollow 30 meter ldquocolumnrdquoAt different rates depending on size and shape
3Different PCBs come out at different times
4PCBs detected
Helium gas
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
73
Example Your Cup of Coffeebull Same beansbull Different extractionbull Some variability in taste but within tolerances of coffee
Percolator Presse Drip
Extraction Method Can Make A Difference but Within Tolerances of the Method
EPA Method 8082 References Various Methods for Soil Extraction
74
Soxhlet extraction(EPA Method 3040)
Reflux for 16-24 hours so solvent continuously drips through soil in
porous thimble (filter)
Sonication (EPA Method 3550)
Sonicate three times for three minutes each with ultrasonic probe
EPA Method 8082 PCBs by Gas Chromatography
75
5Each PCB congener shown as a peak on a ldquochromatogramrdquo
Time
Gas Chromatograph
1Sample extract injected
2PCBs pass through hollow 30 meter ldquocolumnrdquoAt different rates depending on size and shape
3Different PCBs come out at different times
4PCBs detected
Helium gas
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
EPA Method 8082 References Various Methods for Soil Extraction
74
Soxhlet extraction(EPA Method 3040)
Reflux for 16-24 hours so solvent continuously drips through soil in
porous thimble (filter)
Sonication (EPA Method 3550)
Sonicate three times for three minutes each with ultrasonic probe
EPA Method 8082 PCBs by Gas Chromatography
75
5Each PCB congener shown as a peak on a ldquochromatogramrdquo
Time
Gas Chromatograph
1Sample extract injected
2PCBs pass through hollow 30 meter ldquocolumnrdquoAt different rates depending on size and shape
3Different PCBs come out at different times
4PCBs detected
Helium gas
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
EPA Method 8082 PCBs by Gas Chromatography
75
5Each PCB congener shown as a peak on a ldquochromatogramrdquo
Time
Gas Chromatograph
1Sample extract injected
2PCBs pass through hollow 30 meter ldquocolumnrdquoAt different rates depending on size and shape
3Different PCBs come out at different times
4PCBs detected
Helium gas
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Aroclor Identification and Quantitation
76
bull As each PCB congener comes out of the GC over time it is detected as a ldquopeakrdquobull Each Aroclor has a unique pattern of peaks and their relative comparative sizesbull The size (area) of a peak relates to how much of the PCB congener is presentbull The sum of the areas of all the peaks is the amount of the Aroclor present
bull First the analyst identifies which Aroclor(s) are presentbull Aroclor 1248 was identified in samples from site
bull Then the analyst determines how much of that Aroclor is present
Time
Aroclor 1248 Analytical Standard
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Identifying Which Aroclor is Present
77
Aroclor 1248
Aroclor 1254
Aroclor 1242
From Method 8082 Figures 4 5 amp 6
All labs identified PCBs from site as Aroclor 1248
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Aroclor Quantitation
78
bull Area under all the peaks relates to the amount of Aroclor present bull Potentially gt100 overlapping peaks so difficult to actually measure them allbull Inject a known amount (eg 100 ppm) of the Aroclor 1248 Analytical Standardbull Measure ldquoarea countsrdquo of a characteristic peak in the chromatogrambull Relate ldquoarea countsrdquo of that peak to the amount of Aroclor injected bull Repeat for 3-5 peaks and average the results
Time
Aroclor 1248 Analytical Standard
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Aroclor Quantitation
79Time
1 Inject eg 100 ppm of Aroclor 1248 Analytical Standard into the GC2 Select a characteristic peak 3 For 100 ppm of the AroclorStandard this peak happens to show 60 ldquoarea countsrdquo 4 We inject an unknown sample this peak shows 120 area counts how much Aroclor1248 does that correspond to 5 Answer (12060)x100ppm= 200 ppm Aroclor 1248 in the sample
6 Repeat the process for a total of 3-5 peaks7 Average the results The average is what you report
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Method 8082 has significant inter-
laboratory variability even when all use
spiked soil samples and Soxhlet extraction
80
Study published in Method 8082 itself (Table 9) Multiple-lab precision amp accuracy data from Soxhlet extraction of spiked soil Soil samples spiked with 5 50 or 500 ppb Aroclor 1254 or 1260 sent to eight labs Labs tested each sample 3-6 times
For Aroclor 1254 (closest to 1248) average percent recovery for individual labs ranged from 383 to 1443
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Level 4 Data Package All the raw data and calculations such that a
reviewer can re-create the results Labs used quality assurancequality control samples to
confirm that they can adequately extract the PCBs and detect them (LCS spikes Matrix spikes surrogate spikes etc)
Method 8082 allows for options in the specific procedures that a lab may follow Lab A (the lab used by DTSC) used sonication and the EPA Lab
used Soxhlet to extract the PCBs from the soil
The labs used different peaks to calculate the concentration of PCBs in the samples
81
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Inter-laboratory Variability for Samples from Ag Park EPA Region 9 sent split samples from Ag Park to a different commercial lab (Lab B) EPA and Lab B each used Soxhlet extraction Results from the two labs often varied by plusmn50 and sometimes by a factor of 2 The variability between labs appears to be random
Sample ID Commercial Lab Total PCBs (mgkg) Soxhlet
EPA Total PCBs (mgkg) Soxhlet
Diff Mean RPD RPD
C5-1666 0369 0814 0445 05915 -075232 -75D4-1687 0288 0525 0237 04065 -058303 -58E6-1003 0404 0562 0158 0483 -032712 -33FG75-1606 0319 02 0119 02595 0458574 46F8-1600 0180 0195 0015 01875 -008 -8G7-1610 0315 0596 0281 04555 -06169 -62GH6-1635 032 0181 0139 02505 055489 55GH5-1657 0078 004 0038 0059 0644068 64H2-1002 151 1143 0367 13265 0276668 28H2b-1002 130 1566 0266 1433 -018562 -19G35-1700 0289 0304 0015 02965 -005059 -5G55-1655 836 63 2060 733 0281037 28G65-1633 028 0447 0167 03635 -045942 -46FG7-1609 0199 0223 0024 0211 -011374 -11GH4-1680 NDlt00098 0016GH3-1702 NDlt00098 0025
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
ECL Did Study Comparing Soxhlet to Sonication Using Samples from the Site
ECL extracted aliquots of six samples from the site using Soxhlet and sonication
ECL analyzed the extracts side-by-side to eliminate effects of instrument variability
Sonication gave slightly lower results but within Method tolerances
Ag Park Samples - Soxhlet Compared to Sonication - Analyzed on the Same Day
Soxhlet Extraction 5050 DCMAcetone
Sonication 14 tip 5050 DCMAcetone
Run Date 226-272016 226-272016
Extraction Date 119 -112015 11516
Prep Batch Codes Original 94 R3 QT Diff RPD
Collector ID ECL ID Dil Conc (mgkg) Dil Conc (mgkg) Conc (mgkg)
RIVAG-B4N20-S AZ01327 50 341 50 337 04 1
RIVAG-B4E10-S AZ01330 100 996 100 812 184 20
RIVAG-B4W10-S AZ01332 10 104 10 108 -04 -4
RIVAG-F3S10-S AZ01338 5 611 5 475 136 25
RIVAG-F3E20-S AZ01341 1 088 1 0491 0389 57
RIVAG-F3W10-S AZ01342 5 288 5 252 036 13 83
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Weathering of Aroclors in the Environment
84
PCB Aroclors ldquoweatherrdquo over time in the environment
Lighter less chlorinated PCB congeners tend to be lost more quickly by evaporation degradation etc
As a PCB Aroclor weathers the peak pattern changes
Early-eluting peaks (left side of chromatogram) tend to be reduced in size relative to late-eluting peaks
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Comparison of Fresh and Weathered Aroclor 1248A
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
85
Letrsquos look at two peaks that happen to be about the same size one earlier- and one later-eluting
Look at the same two peaks in a weathered sample Note how the early-eluting PCB congener has weathered more and so is reduced in size relative to the other peak
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Lab A Tended to Use Earlier-Eluting Characteristic PeaksA
rocl
or12
48
Ana
lytic
al S
tand
ard
Wea
ther
ed
Sam
ple
A
EA
A
AE
E
E
AE
Peaks used by Lab A (A) and EPA (E)
86
A
A E
EE
E E
A
A
A
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Conclusions When reporting PCBs as Aroclors using EPA Method 8082
there is variability within and between labs
PCB Aroclor results by Method 8082 can be affected by Inherent variability of the method Extraction method Choice of peaks for weathered samples Sample heterogeneity
Both labs followed the Method Key factor in differences between Lab A and EPA lab was choice of peaks for weathered samples
87
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Exide Update - Facility BackgroundExide Technologies was one of only two Lead Acid Battery Recycling Plants West of the Rockies
Exide was a class 2 lead smelter in Vernon CA
bull 1922 - The original facility began operations
bull 2000 - The facility was acquired by Exidebull March 2014 - Exide temporarily stopped operations
bull February 2015 - DTSC informed Exide that it would not approve the Resource Conservation and Recovery Act permit for the facility
bull March 2015 - DTSC issued an order to close the facility
bull Currently - Undergoing closure process
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Exide Update
Facility Closurebull Final Closure Planbull Final Environmental Impact ReportResidential Cleanupbull Draft Residential Cleanup (Remedial Action)
Planbull Draft Environmental Impact Report
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Exide Update
Exide Closure and On-Site Corrective Actionndash Suhasini Patel Branch Chief ExideCorrective ActionData Management
Exide Residential Corrective Actionndash Tamara Zielinski Branch Chief ExideOff-siteResidential Corrective Action
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
DTSCrsquos Commitment
Ensure Closure Implementation willbull Safeguard community and environmentbull Continue to engage the communitybull Maintain financial assuranceAir Monitoring Planbull On-site Worker Health and Safetybull Off-site Resident Protection
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Fugitive Dust Emissions
bull Compliance Plan for Closure Activities -Reviewed by both DTSC and Local Air District (South Coast Air Quality Management District) ndash Tent the Enclosure Building and conduct work
under negative pressurendash Maintain air pollution control equipmentndash Ambient air monitoring for metals and dust
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Residential Cleanup Timeline
bull 2013 Samplingndash Exide Heath Risk Assessment ndash Initial Assessment Areas
bull 2014 Sampling and Cleanupndash Expanded Area North and Southndash Cleanup
bull 2015 Sampling and Cleanupndash Preliminary Investigation Area
bull 20162017ndash Remedial Action Plan and California Environmental
Quality Act
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Exide Health Risk Assessment
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Residential Sampling and Cleanup
In 2014 DTSC ordered Exide to sample and cleanup contaminated properties in two residential neighborhoods (Initial Assessment Area) and Expanded Area near the facility
bull 186 homes in the affected area sampled and cleaned upbull Additional Sampling was conducted in the Expanded Area
to the North and South of the facilitybull Time period 20142015
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Initial Assessment Area
Initial Assessment Area
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Expanded Area
Expanded Area
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Residential Sampling and Cleanup Funding
In 2015 the Governor approved $7 millionbull DTSC sampled 1500 homes in the affected
areabull DTSC cleaned 50 homes in the affected areabull Time period July 2015 - June 2016
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Preliminary Investigation Area
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Residential Sampling and Cleanup
In April 2016 the Governor signed legislation for a $1766 million loanbull For DTSC to continue to test homes in the affected
area (test approximately 10000 properties)bull For DTSC to clean 2500 properties in the affected
areaDTSC also prepared a Draft Remedial ActionCleanup Plan and a Draft Environmental Impact Report for the Cleanup Project
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Current Sampling Status
236 Properties Cleaned Up To-Date
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Soil Sampling Results Preliminary Investigation Area (PIA)
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Remedial ActionCleanup Plan Environmental Impact Report Timeline
bull Draft Remedial Action Plan (DRAP) amp Draft Environmental Report (DEIR) released December 15 2016
bull Public Comment Period on DRAPDEIR December 15 2016 through February 15 2017
bull DTSC will evaluate all comments prepare response to comments and prepare Final Cleanup Plan and Environmental Impact Report
bull DTSC to Finalize Cleanup Plan and certify Final Environmental Impact Report June 2017
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
Train and promote hiring of residents in communities near the former Exide Technologies Facility Environmental Skills Health amp Safety Training Job Readiness
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