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HomeMy WebLinkAboutMINUTES - 10091984 - 3.7 .3. i 0.45 J.a 3-6 13.3 3.7 THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA i Adopted this Order on October 9 , 1984 , by the following vote: AYES: Supervisors Powers , Schroder, McPeak, Torlakson NOES: None ABSENT: Supervisor Fanden ABSTAIN: None -------------------------------------------------------------------- -------------------------------------------------------------------- SUBJECT: Correspondence Agenda Item 3. 1 Letter dated September 25, 1984 from Lawrence G . Olson , Chief , Chairman , Contra Costa County Police Chiefs' Association , P .O . Box 2354, Castro Valley 94546 , in regard to appointment of District Attorney, requesting that a member of the California Peace Officers' Association be included on the Screening Board . ***REFERRED TO COUNTY ADMINISTRATOR AND PERSONNEL DIRECTOR 3 .2 Letter dated September 19 , 1984 from A . B. McNabney, Vice President-Conservation , Mt . Diablo Audubon Society , P .O . Box 53, Walnut Creek 94597, congratulating the Board for the positive steps taken to determine the connection between certain pollutants and reduction in numbers of various species of fish . ***RECEIVED AND FILED 3. 3 Letter dated September 26 , 1984 from David G . Houston , Regional Director , United States Department of the Interior , Bureau of Reclamation , Mid-Pacific Regional Office , 2800 Cottage Way, Sacramento 95825, inviting the Board to meet with him to discuss management of agricultural drainage water . ***REFERRED TO WATER COMMITTEE 3.4 Letter dated September 1984 from Zane G . Smith , Jr . , Regional Regional Forester , United States Department of Agriculture , 630 Sansome Street , San Francisco 94111 , transmitting copies of the Final Pacific Southwest Regional Guide and Environmental Impact Statement . ***REFERRED TO DIRECTOR OF PLANNING 3.5 Letters dated September 28, 1984 from Brian D . Coyne , Vice President , Televents , 2855 Mitchell Drive , Suite 250, Walnut Creek 94598, providing information on the company' s operation in Contra Costa County since 1981 , and giving notice of the company' s election (pursuant to Government Code Section 53066 . 1 (a) ) to be exempt from control of Contra Costa County as to rates , charges and rate structures within the franchise area identified in Board Resolution No . 5708. ***REFERRED TO PUBLIC WORKS DIRECTOR ®0-190 Continued on Page 2 Board Order 1 Page 2 Correspondence Agenda Item 3.6 Letter dated October 1 , 1984 from James Lunsford and Jeff Madrid , 675 Discovery Bay Blvd . , Byron 94514 , setting forth objectives and rates of the Discovery Bay Disposal Service . ***REFERRED TO HEALTH SERVICES DIRECTOR-ENVIRONMENTAL HEALTH PURSUANT TO ORDINANCE CODE CHAPTER 418-2 3.7 Public Agency Notice dated September 28, 1984 from D . W. Moore , Planning/Engineering Requirements Branch , Department of the Navy, Western Division , Naval Facilities Engineering Command , P .O . Box 727, San Bruno 94066, transmitting the Draft Environmental Impact Statement for the proposed explosive safety closure of the Port Chicago Highway and Waterfront Road , Naval Weapons Station , Concord . ***REFERRED TO DIRECTOR OF PLANNING AND PUBLIC WORKS DIRECTOR 3.8 Letter dated September 19 , 1984 from Loren D . Suter , Deputy Director , State Department of Social Services , 744 P Street , Sacramento 95814, transmitting a list of County Children' s Trust Fund contact persons for each county. ***REFERRED TO COUNTY WELFARE DIRECTOR 3.9 - Separate Board Order - IT IS BY THE BOARD ORDERED that the aforesaid actions as noted (***) are APPROVED . 1 hereby certify typo,t:;is ,is *r;�c r.r , . . .s... en action taken and entered Board of Supervisors on ttie .;zt< ATTESTED: lT�•��`� q /9 __� PH,L GATCHELoa, Cie--k of the f3o-st of Supervisors and Ccunty Administrator cc: Correspondents County Administrator By Deputy Personnel Director 61 Water Committee Director of Planning Public Works Director Director of Health Services t Environmental Health County Welfare Director 00101 I THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY , CALIFORNIA Adopted this Order on October 9, 1984 , by the following vote: AYES: Supervisors Powers , Fanden , McPeak , Torlakson NOES: None ABSENT: Supervisor Schroder ABSTAIN: None SUBJECT: Status of 13 State Superfund Hazardous Waste Disposal Sites in Contra Costa County The Board received an October 3, 1984 report from Health Services Department , Environmental Health Division, concerning the status of compliance efforts for the 13 State Superfund hazardous waste disposal sites (copy of which is attached and by reference incorporated herein) . Dan Bergman , Assistant Health Services Director , Environ- mental Health , stated that the report was basically a summary of his staff' s research through State Department of Health Services and the Regional Water Quality Control Board files on the 13 Superfund sites . Mr . Bergman noted that the State Department of Health Services and the Regional Water Quality Control Board are the primary regulatory agencies having jurisdiction over the Superfund sites and the responsibility for enforcing abatement and closure of the sites . Mr . Bergman stated that the 13 Superfund sites in Contra Costa County had been placed in three categories . The first category consists of sites for which highly complex characterization , mitiga- tion, and abatement plans are required and which will require several more years to achieve abatement . The second category consists of sites for which significant characterization work has been done and with a focused effort of the two responsible State agencies could be concluded in a timely manner . The third category lists the remaining nine (9) identified Superfund sites where major work has been done or where the perceived significance of risk is not great , or some combination of the two . Mr . Bergman informed the Board that in the opinion of his staff if one agency were to provide a coordinated focus on these particular sites and define additional effort required it would be possible to achieve abatement and closure and have them removed from the Superfund list . He recommended that the Board authorize the Environmental Health Division staff to act in such a coordinator role in order to expedite abatement and closure of the nine sites . Supervisor Sunne W. McPeak commented on the need for a specific time frame for abatement action on the Superfund sites , and questioned Mr . Bergman as to the feasibility of requiring an abatement plan to be developed within the next 3 months . Mr . Bergman stated that he felt that 3 months would be a reasonable amount of time to define an abatement strategy for each site and that a realistic closure plan could be developed in 6 months . Mr . Paul deFalco , Chairman , Hazardous Waste -Task Force , appeared before the Board , advised that the Task Force had this day filed' an interim report , and referred to the difficulties the Task Force has encountered in obtaining basic data from existing State files . He noted that they have had to request the Environmental Health staff to solicit the information from the State Health Services Department , which creates competition for the limited resources of Mr . Bergman' s staff . Mr . Bergman stated that his staff is committed to the abate- ment and closure of the Superfund sites and also to assisting the 1 Hazardous Waste Task Force in carrying out its objectives , and that in his opinion they could do both . There being no further discussion, IT IS BY THE BOARD ORDERED that the recommendations contained in the report from the Health Services Department , Environmental Health Division, with respect to the 13 State Superfund sites are APPROVED . IT IS FURTHER ORDERED that staff is DIRECTED to , within 3 months , define and identify an abatement strategy for those sites for which there is no plan , and within 6 months to develop an abatement plan for said sites . IT IS FURTHER ORDERED that the October 9 , 1984 Interim Report of the Contra Costa County Hazardous Waste Task Force is ACKNOWLEDGED and said Task Force is requested to proceed as originally charged . ec: Director of Health Services Environmental Health Division Hazardous Waste Task Force County Administrator i Ihereby certlfythaH;-Jsi tru• ^ndr..asr*:tcopyof ar action tairon at:d es:. :e i of the Board of Supervisors on the date skOINtt. ATTESTED: �J 9i—/984( PHIL BATCHELOR, Ctork of the Sc2rd of Supervisors andel County Administrator By. Deputy 2 October 9, 198+ Agenda Item 2.11 Mr. Chairman, members of the Board, I am Dan Bergman, Assistant Health Services Director of the Environmental Health Division. I would like to preface the report by saying that the 13 .hazardous waste sites that we are dealing with in this report are all on the State Superfund list. I think it's important, although I haven't expressly said this in the report, to understand that there is at least a presumption that when these sites are on the State Superfund list then they are significant sites in terms of either potential public health or environmental health impact, otherwise I wouldn't expect them to find their way onto this list. I think that in terms of the Environmental Health Division's position on these sites as subject matters of priority, that absent some kind of proof that they are not in fact public health or environmental health potential impact sites that we have to go forward and assume that there is some significant work to clean these sites up. I wanted to preface the report with that statement because I think that presumption is in fact important. I think the community generally views sites on the Superfund list in that manner and so does this department. The report I have presented is basically a compilation of staff's research by going through every file on these 13 sites in the Department of Health, the State Department of Health Services and the Regional Water Quality Control Board having jurisdiction. Those are the two primary regulatory agen- cies whose responsibility it is to deal with these sites. We have compiled a brief chronology from the volumes of material that exists on many of these sites indicating what the current status of effort is. We have also, in an effort to manage the different 13 sites, broken down into three different categories. The first category is basically a statement in our opinion of four sites from those 13 that are so complex that we wouldn't presume to indicate that they could be cleaned up in the foreseeable near future, that is to say in less than two years. We don't presume to have the expertise to say that on those four sites. We can only guess that it is going to take longer, and how much longer is conjecture only. In the second category we have listed three sites that there has been significant site characterization work done on and some litigation, and where we believe that with a focused effort the two State agencies with or without the local Department of Health Services could focus on what remains to be done on those sites and develop some kind of a reasonable strategy to conclude them in a timely manner. The third category lists the remaining identified Superfund sites where major work has been done or where the perceived significance of risk is not that great or some combination of the two. It is our position that if some agency was coordinating the process to focus on these sites that we could define what is reasonable additional effort to achieve abatement and closure on these sites, and in fact get it done and have them removed from the Superfund list. I have detailed a variety of reasons in the face sheet to the report indicating why it takes so long. In brief, because there are staff problems in the regulatory agencies as exist everywhere in Government I think. There are continuity interruptions by change of staff at the management levels. There is difficulty there as well as in other places in hiring seasoned technical people to focus on these sites. The have the same problems the rest of us do. There is also difficulty in that where there is more than one regulatory agency of jurisdiction, if the regulatory agencies do not concur in what is an acceptable abatement strategy, then the parties responsible in fact for cleaning up these sites will normally take a protractive position.. .they will wait and see because they„have real concerns that if they go forward with a site litigation plan and it is not concurred in by all of the agencies involved, then they will be left in the position where they in fact have not accomplished abatement and may even have compounded the problem in the eyes of one of the regulatory agencies that hasn't taken a position. So I think it is necessary that somebody, and it is recommended that the local Health Services Department provide a coordinated focus on this problem and attempt, if you will, to develop forms to define what needs to be done to conclude a reasonable abatement of at least Group 2 and Group 3 sites that we have defined here, and I have had, for the Board's information, brief discussions with both the chair of the local Regional Water Control Board and the Berkeley Office Director of the State Department of Health Services in charge of this, and neither of those individuals took a strong position against what we are suggesting here. I am not going to presume to speak for then, but they seemed to be in general agreement that this could be helpful. (Fanden) If the ranking, you have this Superfund ranking, is that in order of priority, I am.. . . .you have a facility State Superfund rank 68, they have that listed as the 68th one on their priority list? Or how do they do that? (Bergman) Supervisor Fanden, I don't know all of the criteria that the State uses to rank these sites. There are risk assessments that are made in terms of potential public health impacts, in terms of potential environmental health impacts, water, there are economic questions as well, and they prioritize these sites I believe by taking all of the criteria. . .there are numerical assessments for each one...and aggregating those and then placing them on the list, so the lower the number of a site the greater the potential for harm in terms of those State site criteria for the Superfund ranking. (Fanden) But it hasn't. .. .for the 13, are those all in the top priority? (Bergman) Is your question what determines who gets Superfund money for clean-up? (Fanderi) Yes, right.. .because if the one in Selby is 468 - I'd like to have that #1 , but... (Bergman) It is my understanding Superfund monies are available on the priority of these rankings but only after there is no one else available to pay the money to clean them up. And in this County with the 13 sites that we have it is our Division's opinion that we have identified site responsible par- ties for every one of them - they are large industrial organizations that have resources and none of them have taken a position that they will not or do not have the funds to clean them up. So we are not in a position where we can even really legitimately ask for that money. (Fanden) I know Sunne wants to ask a question but before I give up the floor. . . .can we go after them through the District Attorney's office on a possible nuisance complaint after you have given them so many days, months or whatever time to clean up and they haven't? (Bergman) Well... .a simple answer to your question is yes, we can. There are a variety of avenues for litigation we can pursue. I think the pre- sent requisite for filing litigation against these site operators or responsible parties is that the regulatory agency must first issue formal orders for abate- ment detailing what in the professional estimation of the regulatory agency requires yet to be done, and then have the site responsible parties refuse to do it. It is not productive to file a legal action against a party until you have reached an impasse on an order. If the site parties come into Court for example and say "we would do it if we only knew what we had to do" then that is a reason- ably good defense. So, you know, without getting into legal technicalities, you don't reach that point until you get a refusal on a formal mandate. (Torlakson) What you are advising, that the County can facilitate, maybe expedite that process of defining what needs to be done? (MePeak) On all of the individual site assessments there are recom- mended dispositions. There are nine for which there is not a filed plan of abate- ment, that is an agreement between the regulatory agencies as to what should be done. There are different degrees of stated threat to health and the environment but all 13 sites are on the list. I think we have to deal with the fact that the list, these 13 sites, and in the past meetings of this Board we discussed the fact that there may be some others, but these 13 sites have the focus. The nine that have no plan need to have a time frame attached to it and the recom- mendation that Dan has put on most of these that the local Health Services Department be authorized on behalf of our County to facilitate the interaction of the regulatory agencies in the development of a plan. I would like to ask Dan to comment on the feasibility of attaching a time frame because that is what I would like to see. I am actually thinking of something like 3 months, taking us to the end of the year, by which time we want to see those two regulatory agencies working with the local authorities and the owners to come up with the abatement plan. We can't just let it go indefinitely. I know that is a short time fram when you are involving several different parties. ..on the other hand it has gone too long as it is. So Dan, tell me the feasibility of us asking for those nine sites to have a plan developed within the next 3 months. -2- (Bergman) I think it is reasonable within the next 3 months to define everybody's position with regard to where those sites are and perhaps need to go. I think that it is reasonable for us in 90 days to take those 9, go to both of the regulatory agencies, find their position in fact or get them to say they don't have a position yet, and then do the same with the parties who are respon- sible for the site at the current time and have then take a position, and then we would know how to proceed with strategy on each one. I think it is reasonable to assume that unless we are refused cooperation by one of the interested par- ties, that we could have a very realistic closure plan on the majority of these in 6 months. (McPeak)- Okay, that's, I think that's, let's use that time frame which is the definition within the 3 month period and the closure plan within, clean-up, closure plan within 6 months, and work on that. (Bergman) Well. .. .subject to what my staff might do to me for that. .. (McPeak) Right, well...I have 3 and 6 written down here, when I listed out the 9 sites and I like that approach, and I think that is the critical step. Dan is also, I mean he has referenced the fact that there are multiple agencies, or the two lead agencies, and-at times we are involved locally, and we have run into similar problems with the Hazardous Waste Task Force and it is difficult working through turf issues and who's responsible for what. I think that, recognizing all of those constraints, we still have to put in the push for a time frame. (Torlakson) This is an excellent suggestion. ..I think Dan's suggestion that we offer a County role as a facilitator, expeditor, coordinator.. .we have to take an active role. Your suggestion pinning it down to a time frame is very good because it gives everybody something to operate within. I became aware of this in detail in just examining the one site which is in my district, the Shell Oil pond site in Pittsburg, and there were questions raised in the community, in fact there are petitions circulating wondering why something hasn't been done to proceed with the full clean-up and safety resoltuion of that particular site. There was a large fire that occurred in the area and there was some concern about the firefighters going in and fighting the fire on that because they dind't know exactly what was there and where. . .and it wasn't really defined, and so having a process where we can get in and help then define what needs to be done, get clean-up plans in place, then if there is foot dragging after that has been done, then appropriate legal actions can be considered, but I believe that what is being waited on is a coordinated proposal.. .this is what you have to do to take care of this site. I participated in a closure of the Industrial Tank site and that was one of the first hazardous waste sites officially in the area closed, in the country, under an ordinance from the Air Management District of the area and that proceeded very well, but it had been defined as to what was needed to be done and when and how.. .and having a schedule as Supervisor McPeak suggested and staff to be involved, I think is excellent. Dan, do you need Board approval to move ahead and some guidelines along the lines suggested by Supervisor McPeak for the time frame? (Bergman) Yes, I think it would be helpful. I feel that I am going to take staff resources to do this. We do have other priority programs.. .it is not our intent to let any of then go but it protracts time frams on some of the other things we are doing, and your Board, after all, has responsibility for all this in the final analysis as well. So I think it is important to confirm you position on this as a priority, you know, not only in terms of our staff resource allocation but also as far as the community is concerned. (Torlakson) Good. Mr. DeFalco, you have been patiently with us all day, and have headed up the Hazardous Waste Task Force. We would like to hear from you and then take some action as has been roughly outlined here in defining County involvement and the time schedule. Good evening. I was going to say good ,afternoon but it's headed the other way.. . Good morning, good afternoon, good evening. I am Paul DeFalco. I am the chairman of the Hazardous Waste Task Force and I gather you have in front of you a very short interim report. I am noot going to read it to you, I am just going to simply say that you have a list of things we have accomplished, hope we have accomplished in the last 8 months, and if you will skip to page 2 and the first real paragraph, you will find we have a problem, and the problem is, I think Sunne has referred to it, is we are having difficulty obtaining the basic data from the existing State files and it is becoming necessary for us to ask -3- County staff to solicit this information directly or we cannot accomplish any of the charges that the Board desire us to pursue. I would suggest that there is a certain degree of competition for resources now with the item you just discussed, and the need to develop this basic information for the broader plan, and there really needs to be some consideration on the part of the Board as to what to do with the very limited resources Dan has available. He can spend that time trying to get closure on these 9 sites or he can spend that time helping the Task Force trying to get the basic data so that we can draft a broader plan for the total problem of hazardous waste management. He can't do both things at the same time unless he, as he says, protracts the work, stretches it out. Now it is up to the Board to determine whether they want to stretch this out and if so, which or both, and to what extent? I do suggest that the Task Force has a crackerjack membership, you have got some very good people, but they are very rapidly becoming frustrated and they will be losing interest pretty soon if we can't get over this basic data hump and into something productive. That is my sense of the Task Force in chairing the meetings, and we really need some guidance from the Board as to what its priorities are and where we ought to be going. (Fanden) Paul, are you saying that. ..maybe we have to hear from Dan again, that we are.. .maybe Dan will have to clarify....Dan, can you, can the State do what you propose in your report without the needling of this County? I think what you are saying here is that the reason you want to be monitoring is because you want to keep jabbing them so it gets done, and I would. . . .Paul is saying that if you are doing that then there isn't any time to help facilitate the Task Force Committee. . .but I thought we were going to be getting additional monies from the 10% surcharge, that was to go to Dan to give him more in staff so we could do both. Is that correct or was I wrong? (Torlakson) Let's ask where that money.. . (Westman) put it in the General Fund, in fact, that is part of the requirements. .. (Torlakson) That is part of the budget. ..is that already considered in the budget? (Batchelor) The 10% was never really allocated because there is still, of course, there is concern as to what happens with Jarvis, looking at a November 1 date, we don't know if Jarvis is going to wipe it out, so it really wasn't seriously allocated anywhere as far as I know. (Bergman) I think I can respond reasonably well to your questions. (Fanden) In five minutes? Because I have to leave.. . (Bergman) Okay, five minutes then. I can do it, all I have to do is stonewall. In fact, the way our staff is current allocated, Godfrey Becks basi- cally currently manages the emergency response aspects of our responsibilities. I have Bruce Benike, who has been with us some time and is a veteran if you will, managing the enforcement aspect and the inspection of the hazardous waste generators which will lead to the development of the data from site inspection that Mr. DeFalco is referring to. We committed two additional staff positions out of five total that we have, and in fact, we only have four actively working now, because one of the staff members has been on maternity leave, so out of four actively working staff that we have in this program, two and virtually three with Bruce managing that, are committed to that effort and some of the other program areas that come up, like emergency responses where there is more than one event occurring or during working hours. In any case, what I am saying is we have committed 75% of our functional staff time to that now. I am not proposing to cut that back. What I am proposing to do here is, I and Godfrey Beeks will set up these forms and do this work, I am, I mean we both carry beepers anyway and we are available in the 9 Bay Area counties, we might just as well be doing it over in Berkeley or Oakland as here, and I don't intend to cut back on that effort. We are authorized in some form for two additional posi- tions not predicated on the tax from the IT sites, but predicated on generating revenue directly from the ------ Bill implementation and from the industries that were inspected for the hazardous waste generator program because your Board has already approved that fee ordinance. So it will take, as always, some time to put those two additional staff members on board. When we do, then we will get some relief, and we may be able to allocate more staff, but I am not pro- posing to steal anything from this program to what we have already committed to the Task Force effort and simultaneously getting, in fact, implementation of the State long-use hazardous waste generators. -4- (Fanden) So you are saying you can do both? (Bergman) That is what I am saying. (MePeak) Good. Okay, that is the right answer. That is good. (Fanden) Sunne, why don't you make a motion then. . . (Torlakson) Thank you, Mr. DeFalco. We believe the efforts you are undertaking in your Task Force are critical and important and want to see those proceed, and are hearing that they can proceed and will proceed. Sunne, do you want to formalize a motion to incorporate County involvement in the coordination role and schedule the time frame that you had raised? (McPeak) I would move that we receive the report from the Environmental Health Division regarding the 13 Superfund sites, and to adopt their recommendations with the addition that on those sites for which there has not yet been any abatement plan, that within 3 months there be identification of the issues, and within 6 months the development of such an abatement plan, that that position be communicated to the relevant State agencies that this is what we are requesting. Secondly, that we receive the report from the Hazardous Waste Management Task Force and accept the position from Environmental Health Division that they will continue to dedicate resources to carry out those objec- tives and the Task Force should proceed as originally charged. (Fanden) Second (Torlakson) There is a motion and second, all in favor say aye. That PASSES 4-0. -5- CONTRA COSTA COUNTY HEALTH SERVICES DEPARTMENT To: Phil Batchelor, Date: October 5, 1984 County Administrator 1 From:Mark Finucane, i'� "' Subject: Report to Board of Supervisors Health Services Director re: Status of 13 State Superfund Hazardous Waste Disposal Sites in Contra Costa County The attached report to the Board of Supervisors concerning the status of compliance efforts for the 13 State Superfund hazardous waste disposal sites in Contra Costa County is submitted for your review and approval . The report is on the Board of Supervisors ' Agenda for Tuesday, October 9, 1984 in response to a September 18, 1984 Board directive to the Assistant Director of Health Services, Environmental Health Division. I have reviewed the report and concur with the content of it. MF :DB:bgg attachment A-41 sJ8'_ CONTRA COSTA COUNTY HEALTH SERVICES DEPARTMENT To: Board of Supervisors Date: October 3, 1984 From: Da�n Subject: Thirteen State Superfund Sites 9 Assistant Health Services Director Contra Costa County Environmental Health Update and Status Report By: Godfrey Becks The following report is submitted for your Board' s consideration in response to the September 18, 1984 Board Directive that the Environmental Health Division staff review the thirteen (13) industrial sites within Contra Costa County that are listed among the State of California' s abandoned hazardous waste superfund sites; and to submit a current update of any enforcement activity which has occurred. This summary is based on Environmental Health Division staff' s research of available State of California Department of Health Services and the Regional Water Quality Control Board files. These are the two principle enforcement agencies whose responsibility it is to compel the characterization of the extent ,of contamination at the subject sites, to require the submission of plans for site mitigation from the site responsible parties and to approve and monitor cleanup progress. Finally, it is the responsibility of these regulatory agen- cies to approve closure of the site as an abandoned hazardous waste disposal site after abatement efforts are completed. In an effort to summarize the information that was acquired, and to facilitate policy recommendations pertaining to any future activity concerning mitigation, abatement and/or closure of these sites, three general groupings are presented for discussion purposes: I. The first group consists of State Superfund hazardous waste sites within the county, for which very complex characterization, mitigation and abatement plans are required. It is likely that resolution of these sites will require significant additional regulatory staff time and may extend several more years to achieve abatement. - American Smelting and Refining Co. (ASARCO) Selby, Ca. - Chevron Chemical/Ortho Division Richmond, Ca. - Liquid Gold (S.P. Transportation Co. ) - Santa Fe Land Improvement Co. (Point Isabel) Richmond, Ca. A-41 31K Board of Supervisors 2. October 4, 1984 II . The second group specifies those Superfund sites within the county for which accelerated efforts might be exerted by the various enforcement agencies to (a) evaluate and respond to mitigation proposals that have already been submitted by the site responsible pfrrties and/or, (b) to compel the submission of acceptable site miti- gation proposals by the site responsible parties involved in order to initiate cleanup activity. - Levin Metals (United Heckathorn) , Richmond - P. G. & E./Shell Oil Pond, Pittsburg - GELSAR (as part of Hercules Properties) III . The third group represents those State Superfund sites for which we believe considerable progress has been made toward reducing the risk to public health or the environment. Accordingly, with aggressive mitigation effort and cooperation on the part of the site responsible parties and the enforcing agencies, in our judgment final abatement of these sites can be accomplished thereby making these sites eligible for removal from the State Superfund listing. - F.M.C. Agricultural Chemicals Co. , Richmond, CA - Hercules Properties, Hercules, CA - BIORAD - D. & S. Developers - Forrest Knolls - Chemical and Pigment Co. , Richmond, CA - Point Pinole, Marwais/Bethlehem Steel, Richmond, CA - Cooper Chemical Co. (Wigman & Rose) , Richmond, CA - Bray Oil/Burmah Castrol Co., Richmond, CA - Centex Properties, Hercules, CA The remainder of this report contains a summary of the abatement activities to date for each of the 13 State Superfund hazardous waste disposal sites in Contra Costa County, the current enforcement posture of the Department of Health Services and the Regional Water Quality Control Board for each site, and conclu- sions and recommendations of the Contra Costa County Division of Environmental Health staff based on our staff 's review of the two State regulatory agencies files and recent discussions with their respective staffs. We would like to point out that significant site characterization, mitigation and abatement efforts have been proceeding in an effort to effect responsible compliance and cleanup strategy's for the majority of these sites since 1981 . Delays have, however, occurred in some instances as a result of inadequate regu- latory agency staffing, interruption of continuity as a result of turnovers in some key regulatory agency staff positions and due to allocation of limited State staff resources during this time period to priority sites in other coun- ties within this region. It also appears that compliance efforts are protracted when site characterization and mitigation plans are submitted to the various regulatory agencies and the site responsible parties are waiting to receive approval or additional information or clarification responses from all of the regulatory agencies having subject matter jurisdiction over these sites. The site responsible parties are understandably reluctant to proceed prior to Board of Supervisors 3. October 4, 1984 receiving concurrance or approval of their site abatement plans. We believe the time periods for regulatory agency approval or denial for cause of abatement plans can be reduced through closer coordination of all the concerned parties. We also wish to point out that responsible parties are identified and par- ticipating in site abatement efforts with the State regulatory agencies for all 13 of Contra Costa County' s hazardous waste disposal sites ranked on the State Superfund list. To the best of our knowledge, there is no instance to date where the site owners have refused outright to comply with formal enforcement orders or reached an intractable impass concerning site characterization and mitigation mandates from the respective regulatory agencies. Consequently, we are recommending to your Board that Contra Costa County Department of Health Services commit Environmental Health Division staff time to the State Superfund site abatement process in the role. of facilitating comple- tion of abatement efforts for those State Superfund sites specified in the Group II and Group III categories presented herein. We believe that a positive result can be achieved in a more timely manner if the State agencies are willing to accept our staff's efforts in a facilitator role. We can convene the appropriate forums for coordinating all concerned parties, clarifying remaining site abatement requirements as determined by the State agency' s staffs, and monitoring the remaining mandated abatement activities in the Group II and Group III sites. The complexities of those sites specified in the Group I category in this report clearly require additional sophisticated technical evaluation and staff resour- ces that are available within the two State regulatory agencies having primary jurisdiction over these sites. We are certainly willing to assist in their efforts to effectively manage the Contra Costa County Superfund site abatement effort in any reasonable manner at the request of these respective State agencies. ASARCO/WICKLAND OIL Selby (R.W.Q.C.B. file: #2119.1131) State Superfund Ranking: 68 Lead Enforcement Agency: California State Department of Health Services and Regional Water Quality Control Board Principle Contaminants: Lead, zinc, arsenic, cadmium and other heavy metals Current (1984) Status: To date, no cleanup or remedial action has occurred on any of the property at this hazardous waste site. The Department of Health Services has requested Wickland to initiate mitigation plans on the Wickland-owned portion (vis State-owned) of the site. Most Recent Correspondence and/or Activity: Letter dated February 15, 1984 from RWQCB to Wickland Oil Co., subject RWQCB' s acceptance of Wickland Oil Company ground water and surface water sampling plan. Letters dated August 17, 219 1984 from DOHS and RWQCB, respectively, to Wickland Oil Company, subject notification of deficiencies in the first round of sampling as prepared by Wickland' s consultants. ;Letter dated October 2, 1984 from RWQCB to I.T. Corporation (for Wickland Oil Co. ), subject approval of corrected Phase II sampling plan as presented. Conclusions: Environmental sampling and development of abatement strategies are being for- mulated, cleanup of this hazardous waste will be extended for an indeterminate period of time. Recommendations: Because of the complexities and the nature of heavy metal contamination that exists at this site, I recommend that Contra Costa County offers Environmental Health staff assistance to these respective agencies upon their request. -1- CHEVRON CHEMICAL ORTHO DIVISION Richmond (R.W.Q.C.B. file: #2119.1007) State Superfund Ranking: 31 Lead Enforcement Agency: California State Department of Health Services History: The mitigation plan as submitted by Chevron Chemical (10/83) was approved by both agencies (DHS and R.W.Q.C.B.) with contingencies and modifications. Approximately 50% of the affected property has been cleaned up. Four (4) monitoring wells were installed to monitor organic solvent and heavy metal (arsenic) on the property. 1984 Status: The demolition of the old (original ) arsenic plant is still scheduled for Spring 1985. Four additional monitoring wells will be installed on Santa Fe R.R. and Southern Pacific property (pending approval of R.R. companies). A new source of solvent contamination has been discovered in the Difolitan (pesticide) plant area which will have a significant impact upon early deter- minations of site mitigation plans (information received October 1, 1984) . R.W.Q.C.B. 's 1984 Status Report does not list Chevron Chemical 's Ortho site among the sites that it is currently monitoring. Conclusions: Although site characterization of the previously identified hazardous and extre- mely hazardous waste has been accomplished, recent discoveries of new source(s) of soil and groundwater contamination will undoubvtedly prolong mitigation and closure efforts. Determination by the regulatory agencies concerning the scope and significance of the recently disclosed solvent contamination should be reached and additional site abatement requirements should be mandated as deemed necessary. Recommendations: I recommend that Contra Costa County offers Environmental Health staff assistance to the respective regulatory agencies, upon their request. -2- LIQUID GOLD (Southern Paciis ransportation Co.) Richmond State Superfund Ranking: 9 Federal Superfund Ranking: 246 (of 538 Total ) dated 10/2/84 Lead Enforcement Agency: California State Department of Health Services Major Containments(s) : Polychlorinated Biphenyls, Organic solvents, heavy metals Most Recent Correspondence and/or Activity: R.W.Q.C.B. files contain the following items of correspondence: Letter dated April 7, 1983 From: S.P. Transportation Co. To: DHS Subject: - Copies of clean-up plan by I.T. Corp. - Notification of anticipated clean-up: May 183. Letter dated August 8, 1983 From: S.P. Transportation Co. To: DHS Subject: Notification of the proposed preparation of a mitigation plan for site abatement. Letter dated May 22, 1984 From: DHS To: S.P. Transportation Co. Subject: Request for further site characterization at the Liquid Gold site. Current (1984) Status: - Southern Pacific Transportation Co. has not resubmitted a mitigation plan (as of September, 1984). - All surface tanks have been removed from the property, and a significant amount of soil removal has been accomplished. - Ground water monitoring wells have been installed and water quality monitoring is ongoing. -3- • LIQUID GOLD (Continued) R.C.Q.C.B. 's 1984 Status Report indicates that: - Completion of the definition of the extent of contamination is expected to be complete, Fall '84. - Completion of hazardous soil removal is expected to be completed, Fall '85. - Gruund water clean-up is projected to begin, Spring ' 85. - Ground water plume containment is expected to be completed, Summer '86. Conclusions: Review of the correspondence and other information contained in the files of the respective regulatory agencies indicate that abatement proceedings to obtain clean-up of the property is proceeding in an orderly manner. Recommendations: I recommend that Contra Costa County offers Environmental Health staff assistance to the respective regulatory agencies, upon their request. -4- • i SANTA FE LAND IMPROVEMENT CO. (Point Isabel ) Richmond State Superfund Ranking: 56 Lead Enforcement Agency: Regional Water Quality Control Board Major Contaminant(s) : Heavy metals (lead, zinc) Current (1984) Status: - During 1983, a Statement of Facts and a Compliance Schedule for aba- tement was prepared by Contra Costa County Environmental Health and DHS staff and submitted to Mr. Gill Jensen for review and complaint draft. - Mid-1984, a clean-up and abatement order was issued to Santa Fe Land Improvement Co. (reference letter dated 2/84, State Attorney General ' s Office, to Santa Fe Industries). - July, 1984, a draft civil complaint was prepared by the California State Attorney General 's Office (Reid Sato). Most Recent Correspondence and/or Activity: Letter dated September 7, 1984 From: Woodward-Clyde Consultants To: Contra Costa County Environmental Health Services Subject: Submission of Draft Sampling Analysis Plan for Supplemental Site Investigation. Letter dated September 19, 1984 From: California State Attorney General 's Office To: Santa Fe Energy Co. Subject: Acknowledgement of receipt of notification of fencing of Point Isabel area. - Monthly tracking meetings are being conducted the R.W.Q.C.B. to coor- dinate abatement activity at this site with all parties involved. - R.W.Q.C.B. 1984 Status Report lists the following information: - Anticipated completion of site characterization, Winter '84. -5- SANTA FE LAND IMPROVEMENT CO. (Continued) Removal of contaminated soil to begin, Fall 186. - Ground water clean-up expected to begin, Fall 186. Conclusions: Review of the data and other information contained in the several regula- tory agency-files indicate that abatement measures are proceeding in an orderly manner. Recommendations: I recommend that Contra Costa County offers Environmental Health staff assistance to the respective regulatory agencies, upon their request. -6- LEVIN METALS (formerly United Heckathorn) Richmond State Superfund Ranking: 59 Lead Enforcement Agency: California State Department of Health Services Major Contaiinants: Pesticides: (Contamination by previous ownership.) Current (1984) Status: R.W.Q.C.B. 's 1984 Status Report indicates that: - Site characterization is being performed and is expected to be complete, Fall '84. - Contaminated soil removal has not occurred as yet, and no antici- pated date for soil removal was listed. - Projected dates for groundwater plume containment and ground water clean-up is expected Winter '87 and Spring 185, respectively. Most Recent Correspondence and/or Activity: Letter dated June-July 1984 From: Levin Metals (Harding-Lawson Assoc.) To: DHS (Charles White) Subject: Clean-up (soil removal ) . I.T. Corporation will begin soil removal during August, 1984 unless directed other- wise. Conclusions: Review of this R.W.Q.C.B. file and discussion with DHS representatives indicate that all of the issues regarding Phase II investigation, and site clean-up have not been resolved. Clearly, further development of abatement strategies and clean-up of this hazardous waste site will extend for an indeterminant period of time. Recommendations: Because of the complexities of the problems involved in this case, I recom- mend that Contra Costa County offer Environmental Health staff assistance to the respective regulatory agencies, upon their request. -7- P.G. & E. /SHELL OIL WASTE POND West Pittsburg Superfund Ranking: 88 Lead Enforcement Agency: Regional Water Quality Control Board 1984 Status PHASE I (i .e. site characterization) has been completed. Several meetings have been held between site responsible parties (P.G. & E. and Shell Oil Co. ), Department of Health Services and the Regional Water Quality Control Board concerning sampling results and the interpretation of those results. The property has been fenced off and the area posted with the appropriate public warnings. There has been a request recently from the property owner for approval to construct an overflow drain to the Bay in order to relieve excessive water pressure on the containment birms during the winter months. (ref. letter dated 3/16/84 from P.G. & E. to RWQCB) . Note: A written response to this request was not found in the RWQCB' s files. Because of the nature of the contaminant (lead and a lesser amount of organic compounds) and also the fact that the risk of public exposure only occurred in the past when the acreage was permitted to dry up, the site is considered to ;have a low potential for public health impact. Some consideration has been given by the Department of Health Services to removing the site from the State' s Superfund list of hazardous waste sites. Both P.G. & E and Shell Oil Company have petitioned the Department of Health Services to re-evaluate the present ranking of the West Pittsburg site. The Regional Water Quality Control Board in its 1984 Status Report anticipates that containment of ground water plume contamination will be complete by Winter 1986. Conclusions: Review of this specific file suggests that all of the parameters of ground water and soil contamination at this site have not been resolved. In the interim, however, to the extent that more extensive environmental contamination is possible should the forthcoming winter weather be severe enough to cause breakage of the levee/birm, every effort should -be made to respond to the site responsible party's request to construct overflow drains or to devise an alter- native plan. Recommendation: Continued evaluation of this site is indicated. -8- HERCULES PROPERTIES (Continued) GELSAR (R.W.Q.C.B. file: Not found) Principle Contaminant: Heavy metal Lead Enforcement Agency: California State Department of Health Services Current Status• Mr. Howard Hatayama, SDHS, reviewed this file with Contra Costa County represen- tative. Consultants are developing for the property owners a detailed mitigation plan for the removal of low levels of heavy metals from the property. Several options are being proposed: - Cleanup/soil removal - Encapsulation of the contaminated area - Allowing existing levels to remain, but placing deed restrictions on the affected property. However, State Department of Health Services is requiring that prior to any development of the property, post cleanup sampling must be performed. Conclusions: Information in this file and property is very sparse. Further investigation is indicated to determine if site characterization has been conducted and/or completed. Site mitigation in this case appears to be unresolved. Recommendation: (See prior page 4.) -9- F.M.C. AGRICULTURAL CHEMICAL GROUP Richmond (R.W.Q.C.B. file: #2119.1072) State Superfund Ranking: 93 Lead Enforcement Agency: California State Department of Health Services Major Contarm nants: Pesticide residues, arsenic History: F.M.C. has been working voluntarily with DHS to complete mitigation activity which was begun in 1981. 95% of all contaminates soil was removed from the property during 1982. In 1984, the Reginal Water Quality Control Board required FMC to submit a cost benefit analysis of trying to recover/remove the residual amount of con- taminants. 1984 Status: Letter dated April 30, 1984 From: DHS To: FMC Agric. Chemical Group Subject: Removal of the site from the list of hazardous waste sites. ,Conclusion• F.M.C. Agricultural Chemical Group, by reason of the above (letter citation) has formally been removed from DHS' s list of potentially hazardous waste sites. Recommendation: The 1984 Status Report as published by the Regional Water Quality Control Board should be amended to reflect changes in the above status, thereby facilitating the removal of this site from the State's list of Superfund sites. The above recommendation would not preclude the R.W.Q.C.B. 's objective to do additional long term ground water monitoring to evaluate aquifer contamination in the area. -10- i HERCULES PROPERTIES Hercules I. BIORAD II . D & S Developers III . Forrest Knolls IV. Hercules Manufacturing Site State Superfund Ranking: 55 Lead Enforcement Agency: California State Department of Health Services Principle Contaminants: Heavy metals General Information: The several properties described above comprise the general classification of "Hercules Properties". Each site above will be discussed individually. BIORAD (R.W.Q.C.B. file: None found) Letter dated March 12, 1984 From: California State Dept of (ref. RWQCB files) Health Services To: BIORAD Subject: Site Closure Summary: The Department of Health Services considers this site abated and cleaned up. (copy of this information submitted to Contra Costa County Environmental Health Division) . R.W.Q.C.B. Toxics Cleanup Status Report in agreement with the above statement. Recommendation: Encourage and support the removal of this site from the list of hazardous waste sites in Contra Costa County. -11- HERCULES PROPERTIES (Continued) Hercules Manufacturing Site (R.W.Q.C.B. file: #2119.1021) Lead Enforced ent Agency: California State Department of Health Services Environmental contamination is restricted to said contamination only. No (apparent) ground water contamination involved. Major Contaminants: - explosives (DNB, DNT, TNT) - heavy metals - fertilizers (nitrogen compounds) in high concentrations. 1984 Status: The Department of Health Services (DHS) has prepared documentation for an order requiring Hercules, Inc. to declare their intended use of the property and to submit to DHS a plan for final mitigation of the heavy metal contamination. R.W.Q.C.B. 1984 Status Report (Appendix) indicates that: - site characterization has begun, but will not be completed until the winter of 1985. - soil removal will be delayed as long as Spring 1987 (no reasons found in the file). - ground water plume containment will not be contained until Winter 1986 (in spite of agency statements that ground water contamination was not a problem) . Conclusion• It does not seem reasonable that if soil contamination is the principle problem, that mitigation measures to effect contaminated soil removal should be prolonged for an additional year (Winter 1985) . Recommendation: Efforts should be exerted by state/local agencies to reach consensus with respect to a site abatement strategy and to accelerate mitigation activity if warranted. -12- r HERCULES PROPERTIES (Continued) D & S Developers (R.W.Q.C.B. File #2119.1156) Principle Contaminant: Heavy metals Letter Mated February, 1984 From: D & S Developers To: R.W.Q.C.B. Subject: a. Notification of completion and review of the 4th quarter pre and post cleanup soil sampling results. b. Submission of a formal request by D & S Developers, Inc. for the property to be removed from the lists of abandoned hazardous waste sites in Contra Costa. Conclusion• This property has not been removed from the list of abandoned hazardous waste sites. At least, there is no entry in R.W.Q.C.B. 's files responding to the pro- perty owner's request. Apparently, this file is "on hold". Recommendation: Regulatory agencies should reach a consensus position with respect to the status of compliance of this site with respective abatement orders and specify and remaining abatement requirement or approve D & S Developer's request for site removal from list of abandoned hazardous waste sites. -13- HERCULES PROPERTIES (Continued) Forrest Knolls Principle Contaminant: Heavy metal (R.W.Q.C.B. File #2119.1156) Letter dated March, 1984 From: California State Department of Health Services To: Scott Cresy/Forrest Knolls Subject: Acceptance of preliminary determination of con- taminants existent in the soil , and also acceptance of proposed monitoring program. Other activity: None recorded. Conclusion• Apparently no decision has been reached regarding the status of this property ( 'ref., mitigation activity, post sampling, and /or site closure) - or even if the property is considered to be a hazardous waste site. Recommendation: Encourage a formal decision in this case by both State agencies so that an aba- tement strategy can be developed. -14- CHEMICAL & PIGMENT COMPANY Pittsburg (R.W.Q.C.B. file: #2119.1083) State Superfund Ranking: 80 Lead Enforcement Agency: Regional Water Quality Control Board Recent Correspondence and/or Activit: -None since November 1983 -A handwritten note appears in the RWQCB file dated January 25, 1984 suggesting that sampling strategies/analysis was incomplete. However, no formal response avaliable in file. 1984 Status: Department of Health Services does not consider this site to be a significant source of ground water contamination; and apparently the site has an extremely low potential for Bay water contamination. Regional Water Quality Control Board' s 1984 Status Report does not list this site among its active hazardous waste sites in San Francisco Bay Region. Conclusion: Considering the low order of magnitude of environmental contamination (copper and zinc as a heavy metal containment) neither State agency has serious concerns about this particular site. Considering also the minimal enforcement activity ;by the two State regulatory agencies with respect to site characterization, mitigation and abatement, the significance of this site as a Superfund site should be re-evaluated. Recommendation: The regulatory agencies should reach consensus on the priority of contaminants, potential for public health and environmental impacts and develop an abatement strategy. -15- POINT PINOLE/MARWAIS STEEL (Bethlehem Steel ) Richmond (R.W.Q.C.B. file: #2119.1063A) State Superfund Ranking: 66 Lead Enforcejent Agency: California State Department of Health Services Principle Contaminant: Heavy metal , primarily zinc, contained in a galvanizing waste pond. Background Information: Site characterization began in January 1981 and is now complete. A Draft cleanup plan and a site closure plan have been received from Marwais, Inc. and have been reviewed. A final plan for site closure has also been received by both the Department of Health Services and RWQCB. Environmental Studies of pond site and ground water in the area do not suggest that shellfish contamination is occurring in San Francisco Bay. 1984 Status: The waste pond area has been fenced off and the area has been posted with the appropriate public warning signs. ;According to Mr. Howard Hatayama, Department of Health Services, the site clo- sure plan has been approved for sediment treatment and encapsulation. The Department of Health Services does not plan any further action at this time. RWQCB's 1984 Status Report indicates that: Site Characterization is expected to be complete in the Fall 1984. Conclusion/Recommendation: Contingent upon the successful completion of the submitted closure plan by Marwais, Inc. and neutralization of the waste water, this facility should be eligible for removal from the State's Superfund list. Site closure should have no impact upon continued ground water monitoring by the RWQCB. -16- COOPER CHEMICAL COMPANY Wigman & Rose) Richmond State Superfund Ranking: 69 Lead Enforcement Agency: California State Department of Health Services Historical reformation: Principal Contaminants: Heavy metals (zinc), volatile organic solvents A ground water monitoring plan was submitted to the Regional Water Quality Control Board and the Department of Health Services for review and approval during 1983-84 (Todd Engineering) . The Department of Health Services will coordinate any action with the Regional Water Quality Control Board before final decision is made on the mitigation plan. Partial cleanup of the property (soil removal) was conducted in 1981 on the front half of the property. Currently, Wigman & Rose, Inc. is using the previously cleaned area. 1984 Status: State Department of Health Services is not actively pursuing mitigation activity on the back half of this site because of the contaminates low impact potential upon public health. ,•Note: The Regional Water Quality Control Board file for this property was not found at the time of file review. The Regional Water Quality Control Board' s 1984 Status Report indicates that Site characterization has begun and will be complete by Spring 1985. Soil removal has not been completed, however,characterization completion and remaining soil removal will begin during the winter of 1985. Ground water cleanup is anticipated to begin in the Fall of 1986. Conclusions• Information as reported in the Regional Water Quality Control Board' s 1984 Status Report does not agree with information obtained from the Health Services Department. If, in fact, this site is another case where public health and environmental impact is minimal , and only residual contaminent waste material remains, efforts should be exerted to seek final cleanup, site closure and/or initiation of any other lead action that might be indicated. -17- COOPER CHEMICAL COMPANY (Continued) Recommendation: This site is another hazardous waste site for which removal from the State Superfund list seems feasible once regulatory agency agreement can be reached with respect to remaining site abatement requirements. -18- Bray Oil/Burmah Castrol Company, Inc. Richmond (R.W.Q.C.B. file: #2119.1124) Superfund Ranking: 78 Enforcement Agency: Regional Water Quality Control Board (File #2119.1124) Most Recent Correspondence/Activity: Letter dated September 7, 1984 from the California State Department of Health Services to Burmah-Castrol , Inc., subject Department of Health Services' response to Progress Report by Burmah-Castrol (dated July 1984) Summary: The Department of Health Services has taken the position that existing levels of soil contamination does not constitute significant risk to public health; exception being contingent upon the future use/development of specific areas of the property with confined space - buildings. Report: Dated July 1984, from Regional Water Quality Control Board to Contra Costa County Environmental Health Services, subject Status of Toxics Cleanup Cases. Summary: The following data guidelines were submitted: Site characterization: completion date Spring 1985; said removal complete Spring-Fall 1985. Remove containment: Summer 1986 Ground water cleanup: Fall 1984 Regional Water Quality Control Board File Review: Letter dated January 14 1983 from Burmah-Castrol , Inc. to Regional Water Quality Control Board, subject water analysis report and a formal request for guidelines from the Regional Water Quality Control Board regarding remaining work to be done in order to complete the program. Departmental Conclusions: General comments in the files of both of the State enforcing agencies suggest that neither agency consider that existing levels of priority pollutants as volatile organic components do not constitute a significant environmental risk. Apparently the Regional Water Quality Control Board does not plan to pursue mitigation any further. And the Department of Health Services has already taken a position in the matter of not requiring any further soil removal . Recommendation: Support delisting of this site from the State Superfund list. -19- CENTEX PROPERTIES, INC. . Hercules State Superfund Ranking: 80 Lead Enforcement Agency: California State Department of Health Services Principle CU taminants: Heavy metals Most Recent Correspondence and/or Activity: California State Department of Health Services (DHS) files indicate that mitiga- tion activities (i .e., cleanup) have already been performed by the property owners (Centex Properties). An estimated twenty (20) cubic yards of con- taminated soil remains on the property that must be removed. According to Mr. Howard Hatayama, Division of Toxics, there is little, if any ground water involvement, and the removal of this remaining small amount of contaminated soil should facilitate the removal of the site from the Superfund list. Letter dated June 20, 1984 From: WESCO Consultants, Inc. To: Centex, Inc. Subject: Soils analysis and consultant's recommendation that further soil removal around the "concrete slab" be accomplished. Letter dated June 29, 1984 From: DHS To: Centex Properties, Inc. Subject: Final cleanup plan, as proposed, is acceptable, but post cleanup soil sampling must be performed. Conclusion: Site mitigation and cleanup measures that have been performed should qualify this site to be eligible for removal from the State Superfund list. Recommendation: Verification of the performance of post cleanup soil sampling should be done; and contingent upon analytical findings of contaminant levels being less than California Assessment Manual (CAM) values, this site should be. removed from the Superfund list. Note: Centex Properties, Inc. was not included on the Regional Water Quality Board' s Status Report, dated July, 1984. This suggests that there probably was no ground water involvement. -20-