HomeMy Public PortalAbout10) 7.I. Notice from USEPA for installation of sample Vapor Probes and Ground water monitoring wellsAGENDA
ITEM 7. 1.
COMMUNITY DEVELOPMENT DEPARTMENT
DATE: April 16, 2013
MEMORANDUM
TO: The Honorable City Council
FROM: Jose E. Pulido, City Manager
Via: Mark Persico, AICP, Co unity Development Director
SUBJECT: NOTICE FROM UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY (EPA) FOR ACCESS TO INSTALL AND SAMPLE SOIL
VAPOR PROBES AND GROUNDWATER MONITORING WELLS NEAR
THE INTERSECTION OF LAS TUNAS DRIVE AND ROSEMEAD
BOULEVARD
RECOMMENDATION:
The City Council is requested to receive and file a notice from EPA to install soil vapor
probes and a groundwater monitoring well near the intersection of Las Tunas Drive and
Rosemead Boulevard.
BACKGROUND:
1. In 1984, a 19 square mile area of the central San Gabriel Valley — known as Area 3
— was declared a Superfund cleanup site due to decades of improper handling and
disposal of chemicals by businesses operating within the San Gabriel Valley. The
area includes: Alhambra, Rosemead, San Gabriel, San Marino, South Pasadena, -
and Temple City (Attachment "A").
2. In 2009, EPA completed a draft Remedial Investigation (RI) that determined
potential sources of contamination.
3. In April 2010, EPA distributed a bulletin to the community updating residents on the
status of the remediation project (Attachment "B").
4. In 2011, EPA began preparation of the Feasibility Study (FS) to evaluate potential
alternatives for cleaning up the contamination.
5. On January 29, 2013, the City received a letter from EPA informing us of the need to
City Council
April 16, 2013
Page 2
conduct additional testing in the vicinity of Las Tunas Drive and Rosemead
Boulevard (Attachment "C").
ANALYSIS:
Over the past three decades a significant amount of resources have been spent by EPA
in an effort to protect public health, safety and welfare. As part of the ongoing effort EPA
will be conducting additional soil vapor testing and potential groundwater monitoring to
determine the extent of soil and water contamination. The attached bulletin (Attachment
"B") from EPA dated April 2010 briefly outlines the history of tests conducted within Area
3 and the steps going forward toward remediation.
Chemicals from years of manufacturing and dry cleaning operations within the San
Gabriel Valley (Valley) have lead to the current situation. As chemicals were spilled or
dumped on the soil they migrated into the groundwater aquifer. The aquifer below the
Valley ranges from 40 to 200 feet below the earth's surface. The movement of
contaminants through the soil and into the groundwater aquifer is complex and
influenced by soil type and rock formations. Even the pumping of groundwater can
affect the spread of the contaminants within the aquifer. Mapping all of these variables
and developing remediation options is a lengthy process. While the aquifer below the
San Gabriel Valley is a major source of the drinking water, drinking water is pumped
from deep within the aquifer typically below the source of contamination. It should be
noted that all drinking water is required to be regularly tested by the water purveyor and
must meet safe standards before entering the drinking water system.
1. Remedial Investigation/Feasibility Study (RI/FS)
There are two major phases involved in identifying and remediating contamination
— Remedial Investigation and the Feasibility Study. Each of these phases includes
multiple steps and tasks.
EPA has collected samples from over 70 groundwater wells over the past two
decades in order to characterize the extent of the contamination. But there are still
a few gaps in the data, which necessitates additional test wells. The RI screened
groundwater in Area 3 for more than 300 contaminants of potential concern. A total
of seven contaminants were detected within Area 3 (see page 4 Attachment "B").
However, the contaminants with the highest concentrations are trichloroethene
(TCE) and tetrachloroethene (PCE). These chemical compounds are commonly
found in solvents, degreasers and dry cleaning fluid. Once the RI is final the FS
can also be finalized.
In the continuing effort to complete the Feasibility Study, EPA has hired CH2M
HILL, a local environmental remediation contractor, to install soil vapor probes that
City Council
April 16, 2013
Page 2
conduct additional testing in the vicinity of Las Tunas Drive and Rosemead
Boulevard (Attachment "C").
ANALYSIS:
Over the past three decades a significant amount of resources have been spent by EPA
in an effort to protect public health, safety and welfare. As part of the ongoing effort EPA
will be conducting additional soil vapor testing and potential groundwater monitoring to
determine the extent of soil and water contamination. The attached bulletin (Attachment
"B") from EPA dated April 2010 briefly outlines the history of tests conducted within Area
3 and the steps going forward toward remediation.
Chemicals from years of manufacturing and dry cleaning operations within the San
Gabriel Valley (Valley) have lead to the current situation. As chemicals were spilled or
dumped on the soil they migrated into the groundwater aquifer. The aquifer below the
Valley ranges from 40 to 200 feet below the earth's surface. The movement of
contaminants through the soil and into the groundwater aquifer is complex and
influenced by soil type and rock formations. Even the pumping of groundwater can
affect the spread of the contaminants within the aquifer. Mapping all of these variables
and developing remediation options is a lengthy process. While the aquifer below the
San Gabriel Valley is a major source of the drinking water, drinking water is pumped
from deep within the aquifer typically below the source of contamination. It should be
noted that all drinking water is required to be regularly tested by the water purveyor and
must meet safe standards before entering the drinking water system.
1. Remedial Investigation/Feasibility Study (RI/FS)
There are two major phases involved in identifying and remediating contamination
— Remedial Investigation and the Feasibility Study. Each of these phases includes
multiple steps and tasks.
EPA has collected samples from over 70 groundwater wells over the past two
decades in order to characterize the extent of the contamination. But there are still
a few gaps in the data, which necessitates additional test wells. The RI screened
groundwater in Area 3 for more than 300 contaminants of potential concern. A total
of seven contaminants were detected within Area 3 (see page 4 Attachment "B").
However, the contaminants with the highest concentrations are trichloroethene
(TCE) and tetrachloroethene (PCE). These chemical compounds are commonly
found in solvents, degreasers and dry cleaning fluid. Once the RI is final the FS
can also be finalized.
In the continuing effort to complete the Feasibility Study, EPA has hired CH2M
HILL, a local environmental remediation contractor, to install soil vapor probes that
City Council
April 16, 2013
Page 3
will evaluate contaminants of potential concern. The probes will be placed between
100 to 150 feet below grade; and based upon the sampling results, a groundwater
monitoring wells may also be installed. The four locations are: 9085 Las Tunas, -
9040 Las Tunas, 5676 Rosemead and alley between Sultana and Heart (see
Attachment "C," figure 1). If a monitoring well is installed, the only feature above
grade is a small 6 to 8 -inch diameter cap in the street.
2. Well Installation
Field work will be conducted between 7:00 a.m. and 5:00 p.m. and will last
approximately 15 days. The field work will include: drilling, installation of soil vapor -
probes, and testing; and a potential installation of a groundwater monitoring well.
While the work will be done at the edge of the street or within the alley, a parking
lane or travel lane may be closed to accommodate the equipment. All of this work
is also being coordinated with the on-going Rosemead Boulevard construction
project. If a groundwater monitoring well is deemed necessary, EPA will monitor
the well on a quarterly basis for up to two years. These soil vapor probes and the
groundwater monitoring well, if installed, will allow EPA to finalize the Feasibility
Study and begin the next phase of remediation which will ultimately lead to cleanup -
of the groundwater aquifer.
EPA is exempt from state and local permitting requirements under Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA). Similarly, federal
law exempts EPA from paying any associated local permit fees.
CONCLUSION:
While EPA is exempt from local permitting requirements, they have been working with
City staff to reduce any potential impacts and inconvenience caused by the project.
Staff is presenting this item to the City Council to advise Council members and the
public aware of the upcoming EPA testing.
FISCAL IMPACT:
This item does not have an impact on the Fiscal Year (FY) 2012-13 City budget.
ATTACHMENTS:
A. Map of Area 3 -
B. US EPA Superfund Bulletin April 2010
C. US EPA letter dated January 29, 2013
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ATTAOI IMENT B
SAN GABRIEL VALLEY
AREA 3 SUPERFUND SITE
U.S. EPA Completes Remedial Investigation for,
San Gabriel Valley Area 3 Superfund Site
The United States Environmental Protection Agency (EPA)
has released the final remedial investigation (RI) report on
ground water contamination for the San Gabriel Valley Area
3 Superfund Site (Area 3). A future feasibility study will
evaluate options for ground water cleanup in Area 3.
Highlights of This Fact Sheet
• Results from June 2009 RJ report for Area 3 .......... page 2
• Next steps in Superfund cleanup process...... pages 2 and 3
• Points of contact ...................................................... page 5
• List of information repositories, where you can review
technical information ............................................... naee 5
For further information, go to EPA's Web site:
www.epa.gov/region09/SanGabrietAlhaiilbra
Para ver y descargar esta hoja informativa en
espanol, visite el sitio web de la EPA indicada a
continuaci6n.
Para solicitar una copia impresa, (lame al nOmero
gratuito que se indica a continuaci6n.
ii�JA �7�71�AYN�I'�IT��7�11u °
De xem va lay trang th6ng tin nay bang tieng
Viet, xin vui 16ng vao trang mang cua Cd
quan EPA theo dia chi du'di day.
Xin vui 16ng goi so digin thoai mien phi du'di-
day de yeu cau ban in cua th6ng tin nay.
httD://www.ei)a.aovlreaionO9/SanGabrielAlhambra
Toll Free Message Line: (800)-231-3075
A remedial investigation (RI) is a process that evaluates
contaminants present at a site and assesses risk to human health
and the environment. A feasibility study is an analysis of potential
alternatives to dean up contamination at a site.
Please Join Us
EPA will host two public information sessions:
Wednesday, April 14, 2010
5.7:30 p.m., presentation 6:30.7 p.m.
Alhambra Civic Center Library
101 S. First Street
Alhambra, CA 91801
Saturday, April 17, 2010
2.4:30 p.m., presentation 3:30.4 p.m.
Rosemead Library
8800 Valley Boulevard
Rosemead, CA 91770
What about drinking
water?
Ground water underlying Area 3
o
is used for local water supplies.
Water suppliers ensure that water
❑
delivered to the public meets
federal and state drinking water
�
❑
CO]
standards. No untreated ground
water in Area 3 is supplied for
drinking water.
Terms in bold are defined in the Glossary on page 5.
Site Background
Decades of handling and disposal of chemicals by businesses
operating in Area 3 released volatile organic compounds
(VOCs) into soil and ground water. EPA initiated the
Superfund process, including the activities shown in Figure I
on page 2, after the discovery of ground water contamination.
EPA, with the State of California, is working to identify
responsible parties. The San Gabriel Basin provides
approximately 90 percent of the drinking water in the San
Gabriel Valley.
The Area 3 investigation area comprises 19 square miles
containing regions of ground water contamination in
Los Angeles County, California. Cities within Area 3 include
Alhambra, Rosemead, San Gabriel, San Marino, South
Pasadena, and Temple City. Figure 2 on page 3 shows the
location of Area 3.
Remedial Investigation
The RI lays the foundation for a FS, an analysis that will
help EPA to evaluate options and select a remedy for ground
water cleanup. Cleanup decisions will consider potential
risks the contamination may pose to human health and the
environment.
Results of the Remedial
Investigation
As illustrated in Figure 3 on page 4, ground water beneath
Area 3 shows the presence of contamination. Ground water
appears the most adversely affected in the southwestern and
northeastern portions of Area 3 as shown on Figure 2 on
page 3.
Soils and rocks within the ground water aquifers influence
the pathways through which contaminants move and spread.
Pumping of ground water to meet drinking water needs and
irrigation needs may further spread the contamination.
The RI screened ground water in Area 3 for more than 300
contaminants of potential concern (COPCs). Table l
on page 4 shows seven "Key COPCs": contaminants
detected repeatedly in ground water at levels that exceed the
evaluation concentrations (such as drinking water standards).
Table l on page 4 also includes information on common
industrial and commercial uses of the Key COPCs, and on
potential health risks.
Trichloroethene (TCE) and tetrachloroethene (PCE) — the
most prevalent Key COPCs in Area 3 — appear in the
highest concentrations and over the largest regions.
Investigations conducted by the State of California have
found ground water contamination below 12 properties.
Figure 2 on page 3 shows where in Area 3 concentrations of
TCE or PCE or both in ground water exceed the maximum
contaminant levels (MCLS).
I
Figure 1. The Superfund Process for
San Gabriel Valley Area 3 Superfund Site
Site
Discovery of contamination in ground
Discovery
water in Area 3 occurred in the 1980s,
Area 3 placed on National Priorities
Site
List (NPL) in 1984. Eligible for federal
Listing
funding to implement remedial action
(cleanup) under Superfund.
RI report issued in 2009 summarizes:
• Investigation of potential sources of
Remedial contamination by EPA and State of
Investigation California;
(R1) Evaluation of data from over 70
ground water wells; and
• Installation of eight ground water
monitoring wells by EPA.
Afeasibility study will evaluate cleanup
Feasibility alternatives for contamination in
Study ground water. Feasibility study report
scheduled for 2011.
Proposed Plan A proposed plan will explain
& Public alternatives for ground water cleanup
Comment and identify a preferred alternative.
Period
A record of decision will document
Record of selected remedy for ground water
Decision cleanup. A "responsiveness summary"
will address public comments.
Remedial Development of detailed design for
Design selected remedy.
Remedial Implementation of selected remedy.
Action
Long-term
Operation & Cleanup by remediation system
Maintenance
auperfuna rs nrA s prugrant w raenury, utvest
and clean up abandoned or uncontrolled haza
waste sites throughout the nation.
Terms in bold are defined in the Glossary on page 5.
Figure 2. Regions of Ground Water Contamination in the San Gabriel Valley Area 3 Superfund Site
�s asaden
Pasadena .d—
San Marino
Lm Ana
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Area 34 w
a ai y�
-East San Gabriel
w � < 9c a Lr , �yyua� oa toxcoeN'a�i •'�
REY Ro np -
�,� • SS` • WROSES R0 -
South Pasadena ° s WI TemAe
Ok
53
CJ
Alha nbra \
\ an Ge del
y • • l f • 1 Ro ead -•-
• I baa EAARKSA_V
t
TCE or PCE or both present at - Highway — Railway
a Soncentra)ons in ground water that I= Approximate Boundary of
imaatVan., Area 35uyerluntl 511s n
ereee! maximum contaminant levela(MC". Major Street Stream Sanayyroxo ons are
M
Human Health Risk Assessment
EPA evaluated the potential for harm from possible exposure
to contaminants in a study called a human health risk
assessment. The assessment asked whether the health of
residents is potentially at risk without measures to address
contamination in ground water. To answer this question,
EPA estimated potential health hazards and potential excess
cancer risks to residents. The risk assessment indicated that
COPCs could pose a health risk if people were to drink
untreated water from Area 3.
Ecological Risk Assessment
EPA performed an ecological risk assessment to evaluate
whether potential exposure to contaminants could harm
plants or animals. The assessment focused on contaminants
in ground water used for irrigation or stored in ponds. The
ecological risk assessment found no significant risks to plants
and animals, including amphibians and birds.
Conclusions and Next Steps
The results of the RI indicate a need to address ground water
contamination in Area 3 to protect human health. As shown
in Figure I on page 2, the next step in the Superfund cleanup
process is development of a feasibility study to evaluate
cleanup options for contaminated ground water.
During the feasibility study process, EPA will compare
techniques, costs, and challenges of various cleanup options
(called "remedial action alternatives") and recommend a
solution for ground water cleanup in Area 3. The feasibility
study will consider the potential effects of cleanup techniques
and drinking water pumping on each other. EPA projects
completion of the feasibility study report by 2011.
Terms in bold are defined in the Glossary on page 5.
Figure 3. Simplified Illustration of Subsurface - San Gabriel Valley Area 3 Superfund Site
us
Table 1. Key Contaminants in Ground Water in San Gabriel Valley Area 3 Superfund Site
Key Contaminants of Common Industrial Maximum Evaluational & Concentration Concentrations Excess Cancer Risk
Potential Concern Commercial Use (pglL) (p9/ ) for Humansb
Tetrachloroethene (PCE)
Trichloroethene (TCE)
cis-1,2-Dichloroethene
1,2,3-Trichloropropane
Carbon tetrachloride
Dry cleaning solution,
degreaser
Industrial solvent and
Qegreaser
Solvent, component in
medicines and perfumes
Solvent, soil fumigant,
sealant
Cleaning fluid
Perchlorate Component in rocket fuel
and highway fares
Component in agricultural
Nitrate° fertilizers
640 5
1.700 5
17
0.23
1.2
6.B
18,500
6
0.005
0.5
6
10,000
Yes
Yes
No
Yes
Yes
No
No
a Evaluation concentration is the most conservative guideline.
b "Yes" indicates that potential exposure to untreated ground water would increase the risk of cancer by more than one additional case of cancer in a
population of one million.
C Nitrate concentrations reported an nitrogen.
pg/L- micrograms per liter
4
aquifer—An underground geological formation, or group of human health risk assessment—A qualitative and quantitative
formations, containing water. Aquifers are sources of ground water evaluation of the risk posed to human health by the actual or
for wells and springs, potential presence of specific contaminants.
contaminants of potential concern (COPCs) — Contaminants
that, if present at levels of concern, potentially pose a risk to
human health or the environment, if exposures occur.
ecological risk assessment—A qualitative and quantitative
evaluation of the risk posed to plants or animals by the actual or
potential presence of specific contaminants.
ground water—The supply of fresh water found beneath the
Earth's surface, which supplies wells and springs.
ground water monitoring well —Awell used to collect
samples for measuring the amounts, types, and distribution of
contaminants in a ground water aquifer.
maximum contaminant level (MCL) — The maximum
permissible level of a contaminant in water delivered to any user
of a public drinking water system.
National Priorities List (NPL) — EPA's list of the most serious
uncontrolled or abandoned hazardous waste sites identified for
possible remedial action using federal funding.
State of California —The California Regional Water Quality
Control Board, Los Angeles Region (LARWQCB) and the
California Department of Toxic Substances Control (DTSC).
volatile organic compounds (VOCs) — Carbon -containing
compounds that evaporate at room temperature.
To learn more about Area 3, please visit one of the Information Repositories listed below or go to EPA's Web site: www.epa.gov/regionO9/
SanGabrielAlhambra. The RI report and other information about the investigation of ground water contamination in Area 3 are available for
public review.
Contacts
U.S. EPA
State of
California
Community
Outreach Group
Information
Repositories
Lisa Hanustak, Remedial Project Manager
(415) 972-3152
Hanusiak.Lisa@epa.gov
Toll free message line: (800) 231-3075
Jocelyn Spiszman, Ph.D., Senior Scientist
Department of Toxic Substances Control
(714)484-5460
JSpiszma@dtsc.ca.gov
Eric Snoods, Executive Director
San Gabriel Valley Oversight Group
(626) 589-0440
eric.sunada@sgvog.org
http:/Ywww.sgvog.org/
Alhambra Civic Center Library
101 S. Fust Street
Alhambra, CA 91801
(626)570-5008
http://www.alhambralibrary.org/
West Covina Library
1601 West Covina Parkway
West Covina, CA 91790
(626)962-3541
http://www.colapublib.org/libs/wcovina/
Svethma Zenkin, Community Involvement
Coordinator
(415)972-3085
Zenkin.Svetlana@epa.gov
Curt Charmley, Engineering Geologist
Regional Water Quality Control Board,
Los Angeles Region
(213)576-6774
ccharrnley@waterboards.ca.gov
Rosemead Library
8800 Valley Boulevard
Rosemead, CA 91770
(626)573-5220
http://www.colapublib.org/libs/rosemead/
Superfund Records Center
95 Hawthorne Street (SFD-7-C)
Room 403
San Francisco, CA 94105
(415)536-2000
ATTACHMENT C
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
L pq
29 January 2013
Mr. Bryan Ariizumi
Public Safety Officer
City of Temple City
9701 Las Tunas Drive
Temple City, California 91780
Subject: Request for Access to Install and Sample Soil Vapor Probes and Gro-mtd Water
Monitoring Well, San Gabriel Valley Area 3 Superfimd Site, Los Angeles Comity,
California
Dear Mr. Ariizumi:
The United States Environmental Protection Agency ("EPA") is conducting a remedial
investigation (RI) in the San Gabriel Valley Area 3 Superfimd Site ("Site") in Los Angeles County,
California. This work is necessary for EPA to assess the sources and extent of contamination in soil,
_soil gas, and ground water to support its responsibility to respond to contaminated sites pursuant to
the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or
"Superfiuid"), 42 United States Code (U.S.C.) §§ 9601, et seq., as amended. The contamination has
resulted from the release of chemicals that pose a threat to public health and the environment.
EPA is planning field investigation activities in the City of Temple City ("City") in late February
through May 2013 to evaluate the potential presence of contamination. EPA plans to collect soil,
soil gas, and ground water samples in the vicinity of Las Tunas Drive and Rosemead Boulevard hi
Temple City based on data collected in the area in 2007.
Figure 1 (attached) shows the proposed locations (SVP -1 through SVP -4) for installation of four
soil vapor probes (to depths ranging from 100 to 150 feet below ground surface [bgs]). Listed below
are the approximate. street addresses near the proposed locations. With the exception of the alley
location listed below, EPA proposes to drill in the street (away from parking lanes) so the wells will
be accessible for future sampling.
• Near 9085 East Las Tunas Drive
• Near 9040 East Las Tunas Drive
• Near 5676 North Rosemead Boulevard
• Alley between Sultana and Hart Avenues
EPA will collect and analyze soil and soil gas samples and then, as warranted, install one ground
water monitoring well in the area that shows the highest levels of contamination. A summary of
field investigation activities is provided below. Depending on evaluation results, EPA may wish to
install additional wells as part of response actions for the Site, and would notify the City in advance
of any proposed further well installation activities.
We will take care to restore the property to substantially the same condition that existed prior to the
work, however, the soil gas probes and the ground water monitoring well will remain in place for
additional sampling. All permanent fixtures will be finished with flush -mounted traffic -rated well
boxes.
Additionally, EPA will need to set up a staging area near the investigation site during well
installation activties to temporarily store investigation -derived (detailed in the summary below).
EPA would appreciate the City's assistance, as feasible, in identifying an available space for this
staging area.
Summary of Field investigation — Soil Vapor Probe and Monitoring Well Installation and
Sampling
• Well Locations: Figure I (attached) shows the proposed well locations.
• Field Work Schedule/Duration: Work likely will begin in late February 2013 and will take
approximately 15 days, including up to 10 days to install and sample the soil gas probes; and
up to five days to install and develop the ground water monitoring well. All work will be
performed by EPA's contractor, CH2M HILL.
• General Workine Hours: EPA's contractor generally will work on Monday through Friday
from 7 a.m. to 5 p.m., although minor variations from this schedule could occur if problems
are encountered during well installation.
• Utility Clearance: Utility clearance will involve requesting Underground Service Alert to
mark existing utilities and conducting a geophysical survey to identify other buried utilities.
After the geophysical survey, each location will be cleared by air knife to up to 15 feet bgs
to confirm the absence of buried utilities.
• Traffic Control: Traffic control will be conducted in accordance with the Traffic Control
Plan approved by the City.
• Investieation-derived Waste: The investigation will generate excavated soil,
decontamination water, and purged ground water. A staging area, ideally of 40 feet by 40
feet, will need to be set up near the investigation site to temporarily store a roll -off bin (of 22
feet long by 8 feet wide), drums, and a poly tank to hold water pending waste
characterization prior to disposal. EPA can work with a smaller staging area if necessary.
• Community Outreach: EPA will follow the general community involvement objectives
described in EPA's Community Involvement Plan for the San Gabriel Valley Area 3
Superfund Site (available at EPA's web site
htto://www.EPA.¢ov/reLion09/SaiiGabrielArea3 under "Community Involvement").
Approximately one week prior to the start of field work, EPA will distribute an
informational flyer specifying the work schedule and project contacts to businesses and
residences in the immediate vicinity of the proposed work and for use by the Community
Development/ Planning Division to share with staff.
" O n a o i n a M o n i t o r i n a : E P A w i l l c o l l e c t s a m p l e s f r o m t h e s o i l g a s p r o b e s a n d a n a l y z e t h e
s a m p l e s u s i n g a m o b i l e l a b o r a t o r y t o e v a l u a t e c o n t a m i n a t i o n . S a m p l i n g a c t i v i t i e s w i l l
r e q u i r e u p t o t h r e e d a y s a n d w i l l b e c o n d u c t e d b y t w o f i e l d p e r s o n n e l o p e r a t i n g o u t o f a v a n
o r s i m i l a r v e h i c l e .
T h e g r o u n d w a t e r w e l l , i f i n s t a l l e d , w i l l b e s a m p l e d q u a r t e r l y f o r a m i n i m u m o f t w o y e a r s ,
f o l l o w e d b y p e r i o d i c s a m p l i n g a t a n a n t i c i p a t e d r e d u c e d f r e q u e n c y d e p e n d i n g o n p r o j e c t
n e e d s . Q u a r t e r l y s a m p l e c o l l e c t i o n a c t i v i t i e s w i l l r e q u i r e f o u r h o u r s d u r i n g e a c h s a m p l i n g
e v e n t a n d w i l l b e c o n d u c t e d b y t w o f i e l d p e r s o n n e l o p e r a t i n g o u t o f a m i n i v a n ( o r s i m i l a r
v e h i c l e ) . A l l s a m p l i n g a c t i v i t i e s w i l l i n v o l v e i m p l e m e n t a t i o n o f t r a f f i c c o n t r o l i n a c c o r d a n c e
w i t h t h e T r a f f i c C o n t r o l P l a n a p p r o v e d b y t h e C i t y .
E P A r e q u e s t s t h e C i t y ' s a s s i s t a n c e i n a l l o w i n g E P A r e p r e s e n t a t i v e s a c c e s s t o C i t y p r o p e r t y t o i n s t a l l
a n d s a m p l e t h e s o i l g a s m o n i t o r i n g w e l l s a n d t h e g r o u n d w a t e r m o n i t o r i n g w e l l . W e w o u l d
a p p r e c i a t e y o u r s i g n i n g t h i s l e t t e r b e l o w a n d e i t h e r f a x i n g i t t o 4 1 5 - 9 4 7 - 3 5 2 8 o r e m a i l i n g a s c a n n e d
c o p y o f i t t o h a n u s i a l < . l i s u l i u c n a . a o v .
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R e g u l a t i o n s ( C . F . R . ) � 3 0 0 . 4 0 0 ( e ) ( 1 ) o f t h e N a t i o n a l C o n t i n g e n c y P l a n , E P A i s n o t r e q u i r e d t o
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u n d e r t h e a u t h o r i t y o f C E R C L A , i n c l u d i n g t h e i n s t a l l a t i o n a n d o p e r a t i o n o f g r o u n d w a t e r
m o n i t o r i n g a n d e x t r a c t i o n w e l l s . U n d e r C E R C L A , E P A m u s t c o m p l y w i t h s u b s t a n t i v e f e d e r a l , s t a t e ,
a n d l o c a l r e q u i r e m e n t s , b u t t h e p e r m i t e x e m p t i o n i s d e s i g n e d t o a s s u r e t h a t E P A c a n e x p e d i t i o u s l y
a d d r e s s c o n t a m i n a t i o n w i t h o u t b e i n g s l o w e d d o w n b y t h e n e e d t o f i l e p a p e r w o r k w i t h v a r i o u s
g o v e r n m e n t a l e n t i t i e s . S i m i l a r l y , f e d e r a l l a w e x e m p t s E P A f r o m p a y i n g a n y a s s o c i a t e d p e r m i t f e e s ,
e i t h e r d i r e c t l y o r t h r o u g h i t s c o n t r a c t o r . T h i s e x e m p t i o n d e r i v e s f r o m p r i n c i p l e s o f s o v e r e i g n t y . E P A
h a s c o m p i l e d t h e f o l l o w i n g g u i d a n c e d o c u m e n t t o p r o v i d e m o r e d e t a i l s o n t h e s e i s s u e s :
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p e n n i t s . I n t h e f e d e r a l g o v e r n m e n t , o n l y w a r r a n t e d C o n t r a c t i n g O f f i c e r s c a n b i n d t h e g o v e r n m e n t t o
a f i n a n c i a l c o m m i t m e n t , a n d C o n t r a c t i n g O f f i c e r s m u s t h a v e a d e q u a t e f u n d s s e t a s i d e f o r s u c h
c o m m i t m e n t s . M a k i n g a c o m m i t m e n t o r a g r e e m e n t t o a n y f i n a n c i a l l i a b i l i t y w i t h o u t f u n d i n g i s a
v i o l a t i o n o f t h e A n t i - D e f i c i e n c y A c t , 3 1 U . S . C . � 1 3 4 1 e t s e q . T h e r e f o r e , n o C o n t r a c t i n g O f f i c e r
c a n a g r e e t o a n o p e n e n d e d o r u n l i m i t e d i n d e m n i f i c a t i o n o f a n y p a r r y b e c a u s e t h e C o n t r a c t i n g
O f f i c e r w i l l n o t h a v e a d e q u a t e f u n d s t o s e t a s i d e t o c o v e r t h e p o t e n t i a l l i a b i l i t y . M o r e o v e r , t h e
U n i t e d S t a t e s i s c o n s i d e r e d a " s e l f - i n s u r e r . " E P A d o e s n o t m a i n t a i n l i a b i l i t y i n s u r a n c e a s s u c h . I f
t h e U n i t e d S t a t e s , o r E P A a s a n a g e n c y o r i n s t r u m e n t a l i t y o f t h e U n i t e d S t a t e s , i s f o u n d l i a b l e f o r
s o m e t y p e o f d a m a g e t o p r o p e r t y o r p e r s o n s , t h e p u b l i c f i s c i s t h e s o u r c e o f p a y m e n t . A l t h o u g h w e
c a n n o t p r o v i d e i n d e m n i f i c a t i o n o r a n i n s u r a n c e c e r t i f i c a t e , c l a i m s m a y b e m a d e a g a i n s t t h e U n i t e d
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c l a i m s m u s t b e f i l e d u n d e r t h e F e d e r a l T o r t C l a i m s A c t , 2 8 U . S . C . � � 2 6 7 1 - 2 6 8 0 , a n d E P A ' s
i m p l e m e n t i n g r e g u l a t i o n s , 4 0 C . F . R . � � 1 0 . 1 - 1 0 . 1 1 .
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r e q u i r e m e n t s o f l o c a l p e r m i t s a n d r e g u l a t i o n s i d e n t i f i e d b y t h e C i t y . A c c o r d i n g l y , C H 2 M H I L L w i l l
s u b m i t t h e f o l l o w i n g i n f o r m a t i o n f o r t h e C i t y ' s r e v i e w a n d a p p r o v a l :
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v i c i n i t y .
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t o g e t h e r t o e n s u r e t h e p r o j e c t p r o g r e s s e s s m o o t h l y . I f y o u h a v e q u e s t i o n s r e g a r d i n g t h i s l e t t e r o r
E P A ' s i n v e s t i g a t i o n , p l e a s e c o n t a c t m e a t ( 4 1 5 ) 9 7 2 - 3 1 5 2 o r J i m C o l l i n s o f E P A ' s O f f i c e o f
R e g i o n a l C o u n s e l a t ( 4 1 5 ) 9 7 2 - 3 8 9 4 .
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c c : J i m C o l l i n s ( O R C - 3 ) , c o l l i n s . i a m e s 6 b e o a . e o v
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S t e v e F r i e t , D T S C , S F r i e t r u d t s c . c a . a o v
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ACCESS AUTHORIZATION for CITY OF TEMPLE CITY MONITORING WELLS
SAN GABRIEL VALLEY AREA 3 SUPERFUND SITE,
LOS ANGELES COUNTY. CALIFORNIA
am the of the City of Temple City
and as such I have the authority to sign this authorization.
2. I grant authorization to the United States Environmental Protection Agency (EPA) and its
officers, employees, contractors and other authorized representatives to enter the property
located along Las Tunas Drive and Rosemead Boulevard, and in the alley between Sultana
and Hart Avenues ("Property"). The Property is currently owned by the City of Temple City
and comprises part of the San Gabriel Valley Area 3 Superfund Site ("Site") in Los Angeles
County, California. This authorization allows EPA and its officers, employees, contractors
and other authorized representatives to have access to the Property to install and sample soil
gas probes and ground water monitoring wells installed at the Site. EPA's activities at the
Property will include, but not be limited to, the following:
a. drilling of four (4) boreholes (at the approximate locations shown on attached Figure
1) for the installation of soil gas probes and one ground water monitoring well (of
which placement will be determined based on location of soil gas probes with the
highest concentrations of contamination) for subsurface investigation;
b. construction of soil gas monitoring wells consisting of multiple probes in each
borehole, to be installed at depths of ranging from approximately 10 to 150 ft bgs
depending on location;
c. construction of a ground water monitoring well consisting of a 4 -inch diameter well
casing that will be slotted below the water table to allow the entry of ground water;
d. transport of samples and wastes produced from the wells off the Property as
necessary to accomplish the above activities;
e. abandonment of the wells at the conclusion of all response activities; and
f. transport of equipment onto and about the Property as necessary to accomplish the
above activities.
3. The consent for access and use granted herein will commence in February 2013 and will
continue until EPA completes all response actions.
4. I realize that these actions by EPA are undertaken pursuant to its response and enforcement
responsibilities under the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA or Superfund), 42 U.S.C. §§ 9601 et sem, as amended.
Date:
2013 Signature:
Print Name: Title:
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