Revised DNAPL Feasibility Study Fact Sheet

SDMS DOCID# 1144710

Revised DNAPL Feasibility Study Fact Sheet Montrose Superfund Site

Background What is the purpose of this fact sheet? This fact sheet describes the purpose, content and comments by the U.S. Environmental Protection Agency’s (EPA’s) Technical Assistance Services for Communities (TASC) Program on the Revised DNAPL Feasibility Study for the Montrose Superfund site. What is the TASC program? TASC is a program funded by EPA to provide independent educational and technical assistance to Superfund communities. The goal of this assistance is to help communities better understand and become involved in the cleanup process for hazardous waste sites. What is the Montrose Superfund Site? The Montrose Superfund site is a 13-acre site used by the Montrose Chemical Corporation of California from 1947 until 1982 to manufacture the pesticide DDT (dichlorodiphenyltrichloroethane). The site is located at 20201 S. Normandie Avenue in Los Angeles in a community known as Harbor Gateway or Del Amo. The Montrose Superfund Site is next to the Del Amo Superfund site.

Del Amo Superfund Site & Montrose Chemical Superfund Site

What is DNAPL? “DNAPL” stands for “Dense Non Aqueous Phase Liquid.” DNAPL is a liquid that is not water that sinks when put into water. A familiar example is pancake syrup. It is not water and if you pour it into water it will sink. At this site, instead of syrup, the DNAPL is a mixture of chemicals that were spilled onto the ground when Montrose made DDT. Some of those chemicals got into the water under the ground and is sinking as far as it can. What chemicals are in the Montrose DNAPL? The Montrose DNAPL is about 50 percent DDT and 50 percent MCB (monochlorobenzene). DDT is U.S. Environmental Protection Agency Technical Assistance Services for Communities 2013

DNAPL That Has Been Spilled Onto the Ground

a white powder and MCB is a liquid that very easily turns into a gas (like steam, except MCB does not have to boil to turn into a gas). This is an uncommon mixture of chemicals, found at only three other places in the country. What is a Feasibility Study? As shown in the diagram below, the Feasibility Study is the third of nine steps of EPA’s Superfund cleanup process.

1. Overall protection of human health and the environment. 2. Compliance with state and federal laws. 3. Long-term effectiveness and permanence. 4. Reduction of toxicity, mobility or volume. 5. Short-term effectiveness. 6. Implementability. 7. Cost. 8. State acceptance. 9. Community acceptance.

What is in the DNAPL Feasibility Study? Who wrote the Feasibility Study? A consulting firm in Long Beach, California, called AECOM, wrote the DNAPL Feasibility Study for the Montrose Chemical Corporation. EPA reviewed the consulting firm’s work. This Revised DNAPL Feasibility Study was completed in December 2011. Prior versions of this document were completed in 1999 and 2009. Isn’t there already a Feasibility Study for this Superfund Site? There is only one Montrose site. Because it has several environmental challenges being addressed by the Superfund program, EPA decided to treat it as if it were many sites (called “Operable Units” or “OUs”). The Montrose site has seven OUs. The Del Amo site, next door, has three OUs of its own. Each of these OUs had (or will have) its own Feasibility Study. This one is for the Montrose DNAPL only (which EPA calls OU 3-DNAPL). During the Feasibility Study step, Montrose Chemical Corporation—with oversight from EPA— determines what the goals of the cleanup effort will be and develops a list of all of the possible ways the goals can be met. The list is then analyzed to screen out ways that would cost too much or believed to not be as effective as other options. Then the remaining reasonable options are collected together to form what are called “Remedial Alternatives.” Finally, more information is collected about each Remedial Alternative to see how well each matches with nine requirements that are part of Superfund law:

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U.S. Environmental Protection Agency Technical Assistance Services for Communities 2013

What options have been considered for the removal of the DNAPL under the Montrose Superfund Site? The DNAPL Study reviewed nine Remedial Alternatives. Each alternative has two or more components. Some of the components are specific cleanup technologies. For detailed information on the alternatives and on the proposed cleanup technologies, please see Chapter 7 of the Revised DNAPL Feasibility Study which is available from EPA, the public information repositories listed on the last page of this fact sheet, and online at www.epa.gov/region09/montrose.

Will all the water pollution be removed? Not for a very long time. Even after the period of active DNAPL removal, EPA has determined that some of the contamination will remain in place because it is technically impossible to remove. In 1999 EPA established an area of the groundwater it calls a “Technical Impractibility Zone.” This means that in 1999 when EPA established the zone, it believed the technology did not exist that would allow complete DNAPL removal and groundwater cleanup. How long will the cleanup take? Montrose’s consultants think active DNAPL removal will take 3 to 7 years. After that, Montrose will have to continue to remove, treat and replace the water in the “Technical Impractibility Zone” for between 3,100 and 5,800 years. That treatment, called “Hydraulic Containment,” stops the contamination that will not be removed from spreading into the groundwater surrounding the “Technical Impracticability Zone.” Who pays for the cleanup? Montrose Chemical Corporation is responsible for the cleanup costs associated with the DNAPL.

TASC Review of the DNAPL Feasibility Study TASC comments on the DNAPL Feasibility Study At the request of the Del Amo Action Committee, a community group in the vicinity of the Del Amo and Montrose Superfund Sites, a technical advisor through the TASC program provided nine comments on the DNAPL Feasibility Study. The comments were largely focused on additional steps that EPA could consider that may significantly reduce the currently proposed 3,100 to 5,400 year cleanup period. In particular, the TASC technical advisor commented that EPA may have excluded useful cleanup options from consideration too early in the screening process. As a result, the proposed minimum cleanup time frame of 3,100 years may be longer than necessary. Further, of the Remedial Alternatives in the Feasibility Study examined only

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U.S. Environmental Protection Agency Technical Assistance Services for Communities 2013

by computer models, the TASC technical advisor suggested that real-world testing be completed as well because this proposed cleanup action is much larger and more complex than any ever attempted. Finally, the technical advisor recommended that EPA review the decision it made nearly 13 years ago to leave a large plume of contamination in place. This recommendation is based upon the recognition that there have been significant advances in cleanup technology in the 13 years since the decision was made and that the community would benefit from a reduction in the size of the contamination plume. As a general matter, TASC also recommended that EPA use renewable energy as a power source for equipment used to clean up the water. TASC’s complete comments on the DNAPL Feasibility Study can be found online here or from the Del Amo Action Committee.

Next Steps What will happen to the DNAPL Feasibility Study now? 1. In November 2012, EPA’s National Remedy Review Board (called the “NRRB”) reviewed this DNAPL Feasibility Study. The NRRB makes sure that the Remedial Alternatives in the Feasibility Study follow the requirements of federal law and EPA’s own policies. 2. EPA will work with Montrose and its consultants to review and revise the DNAPL Feasibility Study as needed to respond to comments from the NRRB, TASC and state and local agencies. 3. EPA will release an updated DNAPL Feasibility Study and give the public 30 days to comment on the document. This comment period is an important community participation opportunity because this is when EPA collects input to determine which of the proposed Remedial Alternatives meet the “Community Acceptance” requirement of Superfund law.

4. After the 30-day comment period, EPA will consider public comments and either modify the DNAPL Feasibility Study or issue a Record of Decision—the fourth step in the EPA Superfund cleanup process.

Public Information Repositories The public information repositories for the site are at the following locations: Carson Public Library 151 East Carson Street Carson, CA 90745 Torrance Public Library 3301 Torrance Blvd. Torrance, CA 90503 The most complete collection of documents is the official EPA site file, maintained at the following location: Superfund Records Center Mail Stop SFD-7C 95 Hawthorne Street, Room 403 San Francisco, CA 94105 (415) 820-4700

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U.S. Environmental Protection Agency Technical Assistance Services for Communities 2013

TASC Contact Information TASC Technical Advisor Markus B. Niebanck, P.G. 510-693-1241 [email protected] TASC Project Manager Angela Johnson Meszaros 323-341-5868 [email protected] Skeo Solutions Work Assignment Manager Krissy Russell-Hedstrom 719-256-6701 [email protected] Skeo Solutions Program Manager Michael Hancox 434-989-9149 [email protected]