On Monday September 29, 2014 the Technical Assistance for Communities Technical Advisor (TASC TA) participated in a meeting with EPA representatives, EPA’s contractor representatives, and representatives from the California Department of Toxic Substances Control (DTSC). The purpose of the meeting was to update DTSC on the Non-time Critical Removal Action being implemented at the AMCO Chemical Superfund Site and to obtain DTSC’s input for the EE/CA that EPA is preparing as part of the Non-time Critical Removal Action.
EPA discussed the following points regarding the Non-time Critical Removal Action process compared with the formal Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process:
- There is no DTSC cost share.
- There is no Record of Decision (ROD).
- Instead of a ROD, an EE/CA is done. The EE/CA can be thought of as a mini Feasibility Study (FS).
- Only three criteria (implementability, cost, and effectiveness) are used for the EE/CA. Applicable or Relevant and Appropriate Requirements (ARARs) and risk are also taken into account.
- The EE/CA project cost limit is $6,000,000 and funds come from a Remedial Action fund in the EPA.
- An EPA Priority Panel decides whether the project will be funded.
EPA discussed the following schedule items:
- The source area wells will be sampled on October 20. EPA hydrogeologist Terry Johnson will be present for the sampling of these wells.
- The Draft EE/CA will be issued for review in November.
- The public review period will end in early January.
- The Priority Panel will meet in March.
- Pending approval of funding by the Priority Panel, the remediation contractor will mobilize in the summer of 2015.
DTSC suggested that enhanced bioremediation using horizontal wells be considered in the EE/CA.
On October 1, 2014 the TA participated in a conference call meeting with EPA representatives and EPA’s contractor representatives. The EE/CA must examine the No Action alternative and at least two other alternatives. Based partly on DTSC input, the EE/CA will consider the following alternatives:
- Free Product Removal followed by In-Situ Chemical Reduction using zero-valent iron (ZVI) and/or Enhanced In-Situ Bioremediation
- Dual-Phase Extraction
- In-Situ Thermal Treatment (Electrical Resistance Heating or Thermal Conductive Heating)
- Excavation with Off-Site Disposal
- No Action
A number of factors affecting the selection of the preferred remedy were discussed. These included community concerns such as:
- Emissions from the remedy, including diesel emissions from trucks
- Desire not to dispose of wastes in a way that could cause problems for some other community
- Desire for sustainability of the remedy
- Traffic in the neighborhood