Appendices to Draft Remedial Action Plan

751 Pages·2015·8.28 MB·English

APPENDIXA
Applicable or Relevant and Appropriate Requirements
Table A-1
Chemical Specific ARARs for Consideration

Requirements Description Media ARAR
Determination
Federal Resource Conservation and Recovery Act Defines RCRA hazardous waste. Based on Site data, some portion of excavated soils and extracted groundwater may be considered Soil and Relevant and
(RCRA) RCRA hazardous. Hazardous waste determinations would be made at the time the waste is generated. Soil cuttings and extracted Groundwater Appropriate
Title 22 California Code of Regulation (CCR) Sections groundwater will be considered as RCRA hazardous waste if sample results indicate that concentrations of TCE, PCE, or 1,1-DCE,
66261.21, 66261.22(a)(1), 66261.23, 66261.24(a)(1), exceed TCLP thresholds.
and 66261.100
Cal-EPA Department of Toxic Substances Control Soil cuttings and extracted groundwater may be considered as non-RCRA hazardous waste if sample results indicate that Soil and Relevant and
(DTSC) Definition of “Non-RCRA hazardous waste” concentrations of TCE exceed TTLC and/or STLC thresholds. Groundwater Appropriate
22 CCR 66261.22(a)(3) and (4), 66261.24(a)(2) to
(a)(8), 66261.101, 66261.3(a)(2)(C), or 66261.3(a)(2)(F)
Federal RCRA Land Disposal Restrictions (LDR) The applicable standard for land disposal is based on the Universal Treatment Standard (UTS). The land disposal standards for Soil Relevant and
Title 22 CCR Section 66268 hazardous waste soils were relaxed to 10-times the UTS. UTS for TCE is 6 mg/kg and the LDR level is 60 mg/kg. Appropriate
40 CFR Part 268
Residual waste in soils and groundwater does not allow This California regulation requires that deed restrictions or restrictive covenants be employed to restrict use of the property if there is Soil and Relevant and
unrestricted use. residual contamination above unrestricted use levels. Groundwater Appropriate
Title 22 CCR 67391.1 and Properties with environmental restrictions required to notify California EPA and place such information on the EPA website.
California Civil Code Section 1471
Federal Safe Drinking Water Act (SDWA) 42 USC 300f- Federal primary Maximum Containment Levels (MCLs) under the Safe Drinking Water Act (SDWA) protect the public from Groundwater Applicable
300j National Primary Drinking Water Standards contaminants that may be found in drinking water. The MCLs are only applicable “at the tap” for drinking water provided to 25 or more
40 CFR Part 141-143 people or water systems with 15 or more service connections. Because the groundwater underlying the Site has been identified as a
potential source of drinking water, the requirements are relevant and appropriate to the aquifer underlying the Site.
California Primary Drinking Water Standards Health and California primary MCLs are established to protect public health from contaminants “at the tap” that may be found in drinking water Groundwater Applicable
Safety Code (H&S Code) 4010 et seq. sources. The California MCL established for the primary contaminants are at least as stringent as the federal standard.
Title 22 CCR 64431 and 64444
State and Regional Water Quality Control Board Authorizes the State and Regional Water Boards to establish in Water Quality Control Plans beneficial uses and numerical and Groundwater Applicable
(RWQCB) California Water Code (CWC) Division 7, narrative standards to protect both surface and groundwater quality. Authorizes regional water boards to issue permits for discharges
Section 13241, 13243, 13263(a), and 13360 (Porter- to land or surface or groundwater that could affect water quality, including NPDES permits, and to take enforcement action to protect
Cologne Water Quality Control Act) water quality.
Substantive provisions are ARARs. Waste discharge Requirements (WDR) permits will be required from LARWQCB for in-situ
groundwater remediation.
Water Quality Control Plan for Los Angeles Region Establishes beneficial uses of ground and surface waters, establishes water quality objectives, including narrative and numerical Groundwater Applicable
(adopted 11\19\92) standards, establishes implementation plans to meet water quality objectives (WQOs) and protect beneficial uses, and incorporates
CWC 13240 et seq. statewide water quality control plans and policies. The WQOs for groundwater are based on the primary MCLs.
The Los Angeles plan designates the beneficial uses of groundwater in the Los Angeles coastal plain to be municipal and domestic,
agricultural, industrial service, and industrial process supplies. Any activity that may affect water quality must not result in the water
quality exceeding the WQOs. Discussion of the Basin Plan and discharge options are presented as action-specific ARARs.
State Water Resources Control Board (SWRCB) Establishes policies and procedures for oversight of investigations and cleanup and abatement activities resulting from discharges of Groundwater Applicable
Resolution No. 92-49 Policy and Procedures for waste which affect or threaten water quality.
Investigation and Cleanup and Abatement of Section III.G requires cleanup to attainment of either background water quality, or the best water quality that is reasonable if
Discharges under Water Code Section 13304 (amended background water quality cannot be restored. Alternative cleanup levels greater than chemical background concentration for the
4\21\94) aquifer will be consistent with maximum benefit to the public, present and anticipated future beneficial uses, and conform to water
CWC 13307 Title 23 CCR 2550.4 quality control plans and policies.
Safe Drinking Water and Toxic Enforcement Act The law was created through a state ballot initiative (Proposition 65) with the intent of providing warning about exposures to chemicals Groundwater To be
H&S Code §25249.5 et seq. that cause cancer, birth defects, or other reproductive harm, and protecting the drinking water from those chemicals. All agencies of considered
the federal, state, or local government, as well as entities operating public water systems, are exempt by definition. H&S Code
Title 22 CCR 12601, 12701, 12801, 12901 et seq.
25249.11.b.
Table A-1
Chemical Specific ARARs for Consideration

Requirements Description Media ARAR
Determination
Federal Clean Water Act (CWA) 33 USC 1251-1376 Stormwater runoff during remedial action may require control. Wastewater Relevant and
40 CFR 100-149 discharge to a Appropriate
water body
Los Angeles County Sanitation District (LACSD) No person shall discharge to the LACSD sewer facilities wastewater containing constituents in excess of effluent limitations defined by Wastewater Relevant and
Wastewater Ordinance, 1972 (amended in 1989) the LACSD in its wastewater ordinances. These criteria for discharges include temperature, pH, total toxics, etc. discharge to Appropriate
Potentially applicable to alternatives that involve discharge of treated wastewater or groundwater to the POTW/sewer system. sewer/POTW
Federal Clean Air Act (CAA), 40 USC 7401 et seq.* National Ambient Air Quality Standards (NAAQS): Primary and secondary standards for ambient air quality to protect public health and Air Relevant and
40 CFR 50.4 – 50.12 welfare (including standards for particulate matter and lead). Appropriate
Potentially applicable for response actions. These requirements will be discussed further in the action-specific ARARs.
Provisions of State Implementation Plan (SIP) approved Emission of air pollutants regulated by SIP is possible at the Site. This will be further evaluated under action-specific ARARs. Air Relevant and
by EPA under Section 110 of CAA. Appropriate
40 USC 7410; portions of 40 CFR 52.220 applicable to
South Coast Air Quality Management District
(SCAQMD)
SCAQMD Regulation XIV, Rule 1401 “New Source Review of Toxic Air Contaminants” specifies limits on maximum incremental cancer risk (MICR) and hazard index (HI) Air Relevant and
from new sources. This rule can result in specific concentration limits for contaminants such as TCE in the air discharge from Appropriate
treatment systems.
OSHA Permissible Exposure Limits Requirements for controlling employee exposure to airborne contamination during work operations; sets PELs for specified Air Relevant and
29 CFR 1910.1001/8 CCR 5155 contaminants and workplace monitoring requirements. Appropriate
Table A-2
Location Specific ARARs for Consideration

Requirements Description Media ARAR
Determination
Federal Endangered Species Act of 1973a Protects critical habitat upon which endangered species or threatened species depend. Action to conserve endangered species or Soil and Not Applicable
16 USC 1536(a) threatened species, including consultation with the Department of the Interior, would be required. There are no critical habitats in the Groundwater
immediate vicinity of the site and no federally listed threatened or endangered species protected under the Act have been identified on
the Site.
Federal Executive Order 11990, Protection of Wetlands Defines actions to minimize the destruction, loss, or degradation of wetlands. Soil and Not Applicable
40 CFR 6, Appendix A (excluding Sections 6[a][2], [4], There are no wetlands in the immediate vicinity. Groundwater
and [6]); 40 CFR 6.302
Federal Clean Water Act, Section 404a Actions to prohibit discharge of dredged or fill material into wetland without permit. Mitigation may be required to avoid net loss of Soil and Not Applicable
40 CFR 230.10; 40 CFR 231 (excluding 231.1, 231.2, wetlands. There are no wetlands in the immediate vicinity. Groundwater
231.7, and 231.8)
Fish and Wildlife Coordination Act, Section 662a Action taken should protection fish or wildlife. Soil and Not Applicable
16 USC 662 There are no fish or wildlife in the immediate vicinity. Groundwater
Migratory Bird Treaty Act of 1972 Protects almost all species of native birds in the United States from unregulated “take”, which can include poisoning at hazardous Soil and Not Applicable
16 USC 703 waste sites. There are no migratory birds in the immediate vicinity. None of the alternatives being evaluated affect migratory birds, Groundwater
nests, or eggs of any birds.
National Historic Preservation Act The requirements establish a National Register and advisory Council on Historic Preservation. Remedial activities that would affect a Soil and Not Applicable
16 U.S. Code (USC) §470 et seq. property on or eligible for the National Register are required to consult with the Advisory Council and the State Historic Preservation Groundwater
36 Code of Federal Regulations (CFR) §60.4 Officer. Surveys that may be required will result in the determination of adverse effects and the development of mitigation reports.
Historic sites have not been identified on or adjacent to the Site which would be affected by potential remedial activity at this location.
Floodplains Executive Order 11988 requires all federal agencies conducting activities in floodplains to minimize the impact of floods on human Soil and Not Applicable
Executive Order 11988 safety, health and welfare, and to restore and preserve the natural and beneficial values served by floodplains. Groundwater
The Site is located in a portion of the City of Los Angeles that has not been identified by the Federal Emergency Management Agency
(FEMA) to be within a 100-year floodplain. No further evaluation of this ARAR for flood hazards is necessary.
Hazardous Waste Floodplains Requirements The regulations require a facility constructed within a 100-year floodplain to minimize the adverse impacts to the facility from a Soil and Not Applicable
22 CCR §66264.18 potential washout. The Site is in an area of “minimal flood hazard,” where no part of the community would be inundated by a base Groundwater
flood.
California Endangered Species Act of 1984 The California Endangered Species Act and regulations require action to conserve state-listed rare, threatened, and endangered Soil and Not Applicable
California Fish & Game Code, Division 3, Chapter 1.5 species and the critical habitat. The Site is located in a developed urban community, and endangered species have not been identified Groundwater
Fish and Game Code 2050-2068; 2070-2079, 3000 et at the Site. This requirement is not identified as an ARAR, and further evaluation of this requirement is not necessary.
seq., 4000 et seq., 5000 et seq., 7050 et seq., and 8500
Archaeological Resources Protection Act, 16 USC Application to area where action may cause irreparable harm, loss, or destruction of significant artifacts. Construction of previously Not Applicable
Section 469 at seq. undisturbed land would require an archaeological survey of the area.
There are no known archaeological resources at the Site.
National Wildlife Refuge System Applicable to areas designated as part of the National Wildlife Refuge System. Only actions allowed under the provisions of 16 USC Not Applicable
50 CFR 27 668 dd© may be undertaken in these areas.
The Site is a densely developed urbanized area.
Coastal Zone Management Act Activities affecting the coastal zone, including lands thereunder and adjacent shoreland must be conducted in a manner consistent Not Applicable
Section 307(c) of 16 USC 1456(c); 15 CFR 930 and with approved State management programs. The Site is not within coastal zone.
923.45
Coastal Barrier Resources Act, Section 3501 Prohibits any new Federal expenditure within the Coastal Barrier Resource System. The Site is not within a coastal barrier region. Not Applicable
16 USC 3504
Historic Sites, Buildings, and Antiquities Act Avoid undesirable impacts on area designated as historic sites. There are no known historic landmarks at the Site. Not Applicable
16 USC 461-467
California Coastal Act of 1976 Regulates activities associated with development to control direct significant impacts on coastal waters and to protect State and Not Applicable
Public Resources Code Sections 30000-30900; national interests in California coastal resources. Requires a consistency determination for federal activities within a coastal zone.
14 CCR 13001-13666.4 The Site is not within coastal zone.
Table A-3
Action Specific ARARs for Consideration

Requirements Description Media ARAR
Determination
RCRA 42 USC 6901 et seq. Person who generates waste shall determine if that waste is a hazardous waste. Applicable for any operation where waste is Soil and Relevant and
22 CCR 66262.10(a), 66262.11 generated. Groundwater Appropriate
RCRA Hazardous waste accumulation Generator may accumulate waste onsite for 90 days or less or must comply with requirements for operating a storage facility. Soil and Relevant and
22 CCR Section 66262.34 Groundwater Appropriate
RCRA Recordkeeping Generator of hazardous waste must keep records. Soil and Relevant and
22 CCR Section 66262.40 Groundwater Appropriate
RCRA Container storage Containers of RCRA hazardous waste must be: Soil and Relevant and
22 CCR 66264.171, 172, 173 - Maintained in good condition. Groundwater Appropriate
- Compatible with hazardous waste to be stored.
- Closed during storage except to add or remove waste.
22 CCR 66264.174 Inspect container storage areas weekly for deterioration.
22 CCR 66264.175(a) and (b) Place containers on a sloped, crack-free base, and protect from contact with accumulated liquid. Provide containment system with a
capacity of 10 percent of the volume of containers of free liquids. Remove spilled or leaked waste in a timely manner to prevent
overflow of the containment system.
22 CCR 66264.176 Keep containers of ignitable or reactive waste at least 50 feet from the facility property line.
22 CCR 66264.177 Keep incompatible materials separate. Separate incompatible materials stored near each other by a dike or other barrier.
22 CCR 66264.178 At closure, remove all hazardous waste and residues from the containment system, and decontaminate or remove all containers,
liners.
RCRA Land Ban Treatment of waste subject to ban on land disposal must attain levels achievable by best demonstrated available treatment Soil and Relevant and
22 CCR 66268.40 and 42 technologies (BDAT) for each hazardous constituent in each listed waste, if residual is to be land disposed. Groundwater Appropriate
U.S Department of Transportation, 49 USC 1802, et Applicable to interstate carriers transporting hazardous waste and substances by motor vehicle and transportation of hazardous Soil and Relevant and
seq. Hazardous Materials Transportation material under contract with any department of the executive branch of the Federal government. Groundwater Appropriate
49 CFR 171.2(f) No person shall represent that a container or package is safe unless it meets the requirements of 49 USC 1802, et seq. or represent
that a hazardous material is present in a package or motor vehicle if it is not.
49 CFR 171.2(g) No person shall unlawfully alter or deface labels, placards or descriptions, packages, containers, or motor vehicles used for
transportation of hazardous materials.
Hazardous Materials Marking, Labeling, and Placarding Applicable to person who offers hazardous material for transportation; carries hazardous material; or packages, labels, or placards Soil and Relevant and
hazardous material. Groundwater Appropriate
49 CFR 172.300 Each person who offers hazardous material for transportation or each carrier that transports it shall mark each package, container,
and vehicle in the manner required.
49 CFR 172.301 Each person offering nonbulk hazardous materials for transportation shall mark the proper shipping name and identification number
(technical name) and consignee’s name and address.
49 CFR 172.302 Hazardous materials for transportation in bulk packages must be labeled with proper identification (ID) number, specified in 49 CFR
172.101 table, with required size of print. Packages must remain marked until cleaned or refilled with material requiring other marking.
49 CFR 172.303 No package marked with a proper shipping name or ID number may be offered for transport or transported unless the package
contains the identified hazardous material or its residue.
Table A-3
Action Specific ARARs for Consideration

Requirements Description Media ARAR
Determination
California Hazardous Waste Control Law The California law is more stringent than federal hazardous waste law and is applied to this Site. The following hazardous waste Soil and Relevant and
H&S Code Div. 20, Chap. 6.5 requirements are reviewed for application to the Site. Groundwater Appropriate
Identification and Listing of Hazardous Waste 22 CCR A generator must determine if the waste is classified as a hazardous waste in accordance with the criteria provided in these
Div. 4.5, Chap. 11 22 CCR §66264.13 22 CCR requirements. Waste characteristics of treated soil and groundwater will be defined prior to treatment and disposal. This methodology
§66260.200 to characterize waste has been used with the results showing wastes identified at the Site meet the characteristics of hazardous
waste.
Standards Applicable to Generators of Hazardous Waste transport off-site for treatment or disposal must obtain and use a hazardous waste manifest and comply with the Department of
Waste 22 CCR Div. 4.5, Chap. 12 Transportation packaging, labeling, marking, placarding requirements. Waste may be accumulated on site for 90 days without a
permit. Off-site actions and administrative requirements such as transport, manifesting, permitting, and record keeping are not
applicable or relevant since ARARs address on-site activities.
The purpose of the 90-day storage limit is to prevent creating a greater environmental hazard than already exists at the Site. Waste
contained on-site will be maintained in a container in good conditions (see Use and Management of Containers) prior to off-site
disposal. EPA Region IX-approved CERCLA disposal facility must be used to dispose of CERCLA waste.
Hazardous Waste Security 22 CCR §66264.14 Any proposed treatment facility is anticipated to maintain a fence in good repair which completely surrounds the active portion of the
facility. A locked gate at the facility should restrict unauthorized personnel entrance. The security standards to prevent entry from
unauthorized personnel for the proposed remedial treatment alternatives should be applied.
Hazardous Waste Facility General Inspection The hazardous waste facility standards require routine facility inspections conducted by trained hazardous waste facility personnel.
Requirements and Personnel Training 22 CCR Inspections are to be conducted at a frequency to detect malfunctions and deterioration, operator errors, and discharges which may be
§66264.15 - 66264.16 causing or leading to a hazardous waste release and a threat to human health or the environment. Relevant to the proposed treatment
facilities for this Site.
Ignitable, Reactive, or Incompatible Waste 22 CCR Requirements for prevention of accidental reaction or ignition of waste.
§66264.17
Preparedness and Prevention 22 CCR Div. 4.5, Chap. Facility design and operation to minimize potential fire, explosion, or unauthorized release of hazardous waste.
14, Art. 3
Contingency Plan and Emergency Procedures 22 CCR The requirements designation of an emergency coordinator to implement emergency response procedures for hazardous waste
Div. 4.5, Chap. 14, Art. 4 operations.
Manifest System, Recordkeeping, and Reporting 22 Administrative requirements for hazardous waste manifesting and recordkeeping.
CCR Div. 4.5, Chap. 14, Art. 5
SWRCB and RWQCB Authorizes the State and Regional Water Boards to establish in Water Quality Control Plans beneficial uses and numerical and Groundwater Relevant and
CWC, Division 7, Section 13241, 13243, 13263(a), and narrative standards to protect both surface and groundwater quality. Authorizes regional water boards to issue permits for discharges Appropriate
13360 (Porter-Cologne Water Quality Control Act) to land or surface or groundwater that could affect water quality, including NPDES permits, and to take enforcement action to
Resolution 68-16 Anti-degradation policy protection water quality.
Waste Discharge Requirements (WDR) WDR permits required for injection into groundwater.
22 CCR 66264.90(a) and (c), 66264.91(a) and (c), Owners/operators of RCRA surface impoundment, waste pile, land treatment unit, or landfill shall conduct a monitoring and response Groundwater Relevant and
66264.92-.95, 66264.97-.98 except as it cross- program for each regulated unit. monitoring Appropriate
references permit requirements
California Health and Safety Code Section 25208 (Toxic Authorizes the RWQCB to regulate surface impoundments containing hazardous waste as defined in 22 CCR, prohibits discharges to Groundwater Relevant and
Pits Cleanup Act) such surface impoundments unless they meet specified siting and design requirements. Requires compliance with specific Appropriate
investigation, remediation, and reporting requirements.
Stormwater NPDES Requirements Nonpoint sources address using best management practices for control of contaminants to stormwater run-off from construction Groundwater Relevant and
40 CFR §122.26 activities. SWRCB has established requirements for general construction activities, including clearing, grading, excavation Appropriate
reconstruction, and dredge and fill activities. Regulates pollutants in stormwater discharge from hazardous waste treatment plants,
landfills, land application sites, and spent dumps. These requirements are applicable to construction on sites greater than 1 acre.
Since alternatives that require any soil excavation is confined to less than 1 acre, the requirements are not applicable but may be
relevant.
Table A-3
Action Specific ARARs for Consideration

Requirements Description Media ARAR
Determination
NPDES treatment requirements Point sources are primarily end-of-pipe discharge points such as treated effluent from a groundwater treatment plant. Discharges of Groundwater Relevant and
40 CFR §125.3 treated effluent from a groundwater extraction system, monitoring well development and sampling, and treatment system maintenance Appropriate
are the primary sources. The RWQCB will designate the effluent limitations and monitoring conditions for discharges to surface water
including treated water conveyed to storm drains and ditches.
Technology-based treatment requirements represent the minimum level of control that must be imposed to meet the effluent limitations
using best professional judgment and best available technology economically achievable (BAT). For all toxic pollutants, the BAT is
applied to the Site.
Water Quality Control Plan for Los Angeles Region The Basin Plan presents numerical and narrative WQOs for maintaining a high quality of protection for the inland surface water and Groundwater Relevant and
(adopted 9\09\00) groundwater in the region. Groundwater underlying the Site has been identified by the Basin Plan as a potential drinking water aquifer. Appropriate
California Water Code §13240 et seq. Groundwater WQOs are provided for contaminants including bacteria, chemicals, radioactivity, minerals, nitrogen, taste, and odor. The
WQOs for the COCs at the Site are based on primary MCLs. The requirement is relevant to alternatives evaluating treated
groundwater re-injection to the aquifer.
Remediation of Pollution The Basin Plan recognizes the cleanup goals based on the State’s Antidegradation Policy as set forth in State Board Resolution No. Groundwater Applicable
68-16. Under the Antidegradation Policy, whenever the existing quality of water is better than that needed to protect present and
potential beneficial uses, such existing quality will be maintained. Accordingly, the Regional Board prescribes cleanup goals that are
based upon background concentrations. For those cases wherein dischargers have demonstrated that cleanup goals based on
background concentrations cannot be attained due to technological and economic limitations, State Board Resolution No. 92-49 sets
forth policy for cleanup and abatement based on the protection of beneficial uses. Under this policy, the Regional Board can, on a
case-by-case basis, set cleanup levels as close to background as technologically and economically feasible. Such levels must, at a
minimum, consider all beneficial uses of the waters. Furthermore, cleanup levels must be established in a manner consistent with
California Code of Regulations, Title 23, Chapter 15, Article 5; cannot result in water quality less than that prescribed in the Basin
Plans and policies adopted by the state and regional boards; and must be consistent with maximum benefit to the people of the state.
California Water Code §13140 - 13147, 13172, 13260, Wastes classified as a threat to water quality (designated waste) may be discharged to a Class I hazardous waste or Class II Soil and Relevant and
13263, 132267, 13304 designated waste management unit. Nonhazardous solid waste may be discharged to a Class I, II, or III waste management unit. Inert Groundwater Appropriate
27 CCR Div.2, Subdiv.1, Chap.3, Subchap.2, Art.2 waste would not be required to be discharged into a SWRCB-classified waste management unit (27 CCR §20200 et seq.). The
requirement is relevant because the CERCLA waste as a result of investigation-derived waste may be generated and would be
disposed at a EPA Region IX approved facility in accordance with CERCLA.
Concentration Limits Concentration limits must be established for groundwater, surface water, and the unsaturated zone. Must be based on background, Groundwater Relevant and
27 CCR §20400 equal to background, or for corrective actions, may be greater than background, not to exceed the lower of the applicable water quality Appropriate
objective or the concentration technologically or economically achievable. Specific factors must be considered in setting cleanup
standards above background levels.
Compliance Period Requires monitoring for compliance with remedial action objectives for three years from the date of achieving cleanup standards. Groundwater Relevant and
27 CCR §20410 Appropriate
Evaluation Monitoring Program Requires an assessment of the nature and extent of the release, including a determination of the spatial distribution and concentration Soil and Relevant and
27 CCR §20425 of each constituent. The nature and extent of contamination was conducted in the remedial investigation phase of the investigation Groundwater Appropriate
and is not relevant in the feasibility study phase.
Corrective Action Program Corrective action measures taken may be terminated when the discharger demonstrates that all the COCs concentrations are reduced Groundwater Relevant and
27 CCR §20430 to levels below their respective concentration limits throughout the entire zone affected by the release. Appropriate
Corrective action completed when:
- The concentration of each contaminant of concern in each sample from each monitoring point in the Corrective Action Program for
the Unit has remained at or below its respective concentration limit during a proof period of at least one year, beginning immediately
after the suspension of corrective action measures; and
- The individual sampling events for each monitoring point have been evenly distributed throughout the proof period and have
consisted of no less than eight sampling events per year per monitoring point.
The schedule to confirm attainment of cleanup levels appears relevant and appropriate.
Closure and Post-Closure The closure and post-closure requirements establish standards to minimize maintenance after facility closure to protect human health Groundwater Relevant and
22 CCR Div. 4.5, Chap. 14, Art. 7 and the environment. The closure and post-closure requirements may be dependent upon the treatment alternatives. Clean closure of Appropriate
the treatment facility through equipment decontamination and removal of any hazardous waste is anticipated.
Table A-3
Action Specific ARARs for Consideration

Requirements Description Media ARAR
Determination
Water Code §13140 The policy derives its authority to maintain the highest quality of water through waste discharge regulations to surface water and land Groundwater Relevant and
40 CFR §131.12 implemented through the federal NPDES or California’s Discharges of Waste to Land (27CCR Division 2, Chapter 3), respectively. Appropriate
Maintaining High Quality Water in California SWRCB Resolution No. 68-16 requires maintenance of existing state water quality using best practicable treatment technology unless
SWRCB Resolution No. 68-16 a demonstrated change will benefit the people of California, will not unreasonably affect present or potential uses, and will not result in
water quality less than that prescribed in other state policies.
Applies to the discharge of waste to waters, including alternatives that include reinjection into the aquifer that may affect surface water
or groundwater. In situ cleanup levels for contaminated groundwater must be set at background level, unless allowed. If degradation of
waters is allowed to remain, the discharge must meet best practical treatment or control standards, and result in the highest water
quality possible that is consistent with the maximum benefit to the people of the state. In no case may water quality objectives be
exceeded.
Sources of Drinking Water This policy specifies that ground and surface waters of the state are either existing or potential sources of municipal and domestic Groundwater Relevant and
SWRCB Resolution No. 88-63 supply except water supplies with: Appropriate
a. Total dissolved solids exceeding 3,000 milligrams per liter, or
b. Natural or anthropogenic contamination (unrelated to a specific pollution incident) that cannot reasonably be treated for domestic
use using either best management practices (BMPs) or best economically achievable treatment practices, or
c. The water source does not provide a sustained yield of 200 gallons per day.
The requirement appears to be applicable because groundwater underlying the Site meets the criteria as a potential source for
drinking water.
California Action Levels Action Levels (ALs) are health-based advisory levels established by the California Department of Health Services for contaminants Groundwater Relevant and
that lack primary MCLs. ALs are advisory levels and not enforceable standards. An AL is the level of a contaminant in drinking water Appropriate
that is considered not to pose a significant health risk to people ingesting that water on a daily basis. It is calculated using standard
risk assessment methods for noncancer and cancer endpoints, and typical exposure assumptions, including a 2-liter per day ingestion
rate, a 70-kilogram adult body weight, and a 70-year lifetime.
Tank Systems Minimum design standards (i.e., shell strength, foundation, structural support, pressure controls, seismic considerations) for tank and Groundwater Relevant and
22 CCR Div. 4.5, Chap. 14, Art. 10 ancillary equipment are established. The requirements for minimum shell thickness and pressure controls to prevent collapse or Appropriate
rupture is to not create a greater environmental hazard than already exists. The requirements are relevant and appropriate for the
proposed treatment alternatives (22 CCR§ 66264.193).
Miscellaneous Units Requirements Minimum performance standards are established for miscellaneous equipment to protect health and the environment. Although none Groundwater Relevant and
22 CCR Div. 4.5, Chap. 14, Art. 16 of the anticipated waste streams are classified as hazardous waste, treatment of hazardous waste through granulated activated Appropriate
22 CCR §66264.601 - 66264.603 carbon (GAC) or ion exchange would qualify as a RCRA miscellaneous unit if the contaminated water constituted a hazardous waste.
Therefore, the substantive requirements for miscellaneous units and related substantive closure requirements may be relevant and
appropriate for the Site.
SCAQMD Regulation IV, Rule 401 Limits visible emissions from any point source to Ringelmann No. 1 (or 20 percent capacity) for 3 minutes in any hour. Air Relevant and
Applicable to potential dust generation during system installation. Appropriate
SCAQMD Regulation IV, Rule 402 Prohibits the discharge or any air emissions in quantities that my cause injury, detriment, nuisance, or annoyance to the public. Air Relevant and
Applicable to potential dust generation during system installation. Appropriate
SCAQMD Regulation IV, Rule 403 Limits onsite activities so that the concentrations of fugitive dust at the property line shall not be visible and the downwind particulate Air Relevant and
concentration shall not be more than 100 micrograms per cubic meter, averaged over 5 hours, above the upwind particulate Appropriate
concentration. This rule also requires every reasonable precaution to minimize fugitive dust and the prevention and cleanup of any
material accidentally deposited on paved streets. These requirements do not apply if the wind speed, averaged over 15 minutes, is
above 15 miles per hour.
Applicable to potential dust generation during system installation.
SCAQMD Regulation IV, Rule 404 Limits particulate emissions from process equipment with exhaust stacks for gas flow depending on volumetric gas flow rates. Air Relevant and
Maximum amount is 450 mg/m3. Appropriate
SCAQMD Regulation IV, Rule 409 Limits particulate emission from a combustion source to 0.1 grain per standard cubic foot at 12% CO2 averaged over 15 minutes. Air Relevant and
Appropriate
SCAQMD Regulation IX New Source Performance Standards implemented at the local level. Air Relevant and
Appropriate
Table A-3
Action Specific ARARs for Consideration

Requirements Description Media ARAR
Determination
SCAQMD Regulation X Implements NESHAPs at the local level where specific process units that can discharge specific air toxics into the atmosphere. Air Relevant and
Appropriate
SCAQMD Regulation XIII, Rule 1303 New emissions source or modification of existing source will require new source review. Air Relevant and
Appropriate
SCAQMD Regulation XIII, Rule 1304 Impacts permits related to new remediation systems. Would likely require purchase of emission offsets where permit to construction Air Relevant and
rely on Rule 1304 exemption. Appropriate
SCAQMD Regulation XIV, Rule 1401 Rule specifies limits for cancer risk and excess cancer cases from new stationary sources and modifications to existing stationary Air Relevant and
sources. Rule specifies control technology requirements for BACT and when T-BACT would be required. Appropriate
California Health and Safety Code 25143.2 Prohibits the recycling of non-RCRA hazardous waste if it is used in a “use constituting disposal”. Prohibits recycling of RCRA- Soil and Relevant and
hazardous waste. Groundwater Appropriate
Emergency Response Plan Addresses manner in which operator of facility will address emergency response that could endanger human health or the Soil, Relevant and
27CCR 211430 environment Groundwater, Appropriate
and Air
Site Security Security and signage at the Site for protection of human health and safety. Relevant and
27CCR 21135 Appropriate
City of Los Angeles, Department of Building and Safety Sets requirements for parking per the City code where remedial action may restrict available parking on the property. Relevant and
Los Angeles Municipal Code Section 12.21A4 Appropriate
California Well Standards California Department of This is a supplement to Bulletin 74-81(domestic water well standards) that address minimum specifications for monitoring wells, Groundwater Relevant and
Water Resources Bulletin 74-90 extractions wells, injection wells, and exploratory borings. Design and construction specifications are considered for construction and Appropriate
destruction of wells and borings.
Department of Toxic Substances Control (DTSC) Provides the requirements for land use covenants (LUC) when contaminants will remain on land at levels that are not suitable for Groundwater Relevant and
Land Use Controls 22 CCR 67391.1 unrestricted use of land. Appropriate
DTSC Land Use Controls Authorizes DTSC to enter into an agreement with a land owner to restrict the present and future use of land. Soil and Relevant and
CHSC 25222.1 and 25355.5 Groundwater Appropriate
OSHA Hazardous Waste Operations and Emergency Worker training and health and safety plan requirements for site cleanup operations. Relevant and
Response Appropriate
29 CFR 1910.120/8 CCR 5192
OSHA Head, Eye, Face, and Hearing Protection Specific details regarding personal protective equipment and noise levels for hearing protection for workers. Relevant and
Standards Appropriate
29 CFR 1926 Subpart E/8 CCR 3381, 3382, 5144,
5162, and 5097.
OSHA Heavy Equipment Operation Standards Requirements for safe operation of haulage, earthmoving, industrial trucks and tractors. Relevant and
29 CFR 1926/8 CCR 1590 and 3649 Appropriate
OSHA Worker Protection Programs Written program requirements include hazard communication and an illness and injury prevention plan (IIPP) Relevant and
29 CFR 1910.1200/8 CCR 5194 and 3203 Appropriate
USEPA Respiratory Protection Standard Establishes standards and guidelines for respiratory protection. Relevant and
29 CFR Part 1910.134 Appropriate
DTSC California Hazardous Waste Control Act Provides standards for Construction Quality Assurance Programs. Relevant and
Construction Quality Assurance Appropriate
22 CCR § 66265.19
DTSC California Hazardous Waste Control Act Seismic Provides that all cover systems required by Chapter 15 (i.e., § 66265.1 et seq.) and all containment and control features that will Relevant and
and Precipitation Design Standards remain after closure must be designed, constructed and maintained to withstand the maximum credible earthquake without any Appropriate
22 CCR § 66265.25 decrease in the level of public health and environmental protection afforded by the original design.
APPENDIXB
Remedial Alternative Costs