r" SFUND RECORDS CTR

2171288

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX

75 Hawthorne Street San Francisco, CA 94105

MEMORANDUM

DATE: October 30, 2008

SUBJECT: Request for a Time-Critical Removal Action at the Crown City Plating Site, El Monte, Los Angeles County, California

FROM:

TO:

Jason Musante, On-Scene Coordinator Emergency Response Section (SFD-9-2)

Daniel Meer, Assistant Director, Superfund Response, Planning & Assessment Branch (SFD-9)

THROUGH: Steve Calanog, Chief Emergency Response Section (SFD-9-2)

I. PURPOSE

The purpose of this Action Memorandum is to obtain approval to spend up to $714,000 in direct costs to mitigate threats to human health and the environment posed by the presence of uncontrolled hazardous substances (asbestos, cyanides, chromium, copper, lead, nickel, antimony, zinc, and corrosive liquids and solids) at the abandoned metal plating facility (the Site) formerly operated by Crown City Plating Company (CCPC). The proposed removal of hazardous substances would occur pursuant to Section 104(a)(1) ofthe Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1), and Section 300.415 of the National Oil and Hazardous : Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300. :

On June 11, 2008, the United States Environmental Protection Agency (EPA) initiated an emergency response action to mitigate the threats posed by , abandoned plating wastes. Pursuant to the delegated authority of the EPA On-Scene Coordinator (OSC), EPA incurred response costs of approximately $170,000 to conduct emergency actions to secure hazardous wastes at the Site. The actions proposed in this document provide a further time-critical response to remaining threats from hazardous substances. These time-critical actions

include re-containerlzation, off-Site transfer, and disposal of hazardous wastes presenting a release and direct contact exposure threat.

II. SITE CONDITIONS AND BACKGROUND

Site Status: Non-NPL Category of Removal: Time-Critical CERCLIS ID: CAD008305062 SITE ID: 09RR

A. Site Description

1. Physical location

The Site is located at 4350 Temple City Boulevard, in El Monte, Los Angeles County, California (91371). The Los Angeles County Assessor's , Identification Number for the Site is 8577-001-028. The coordinates for the Site , are 34° 05' 09.76" North latitude and 118° 03' 18.66" West longitude.

2. Site characteristics

The properties adjoining the Site are primarily light industrial in use, and the general area is a mix of light industrial and residential development. The Site is approximately 8.5 acres in size and is paved. Primary access to the Site is through gates along Temple City Boulevard. Structures oh the property ^ collectively cover a reported 278,000 square feet and include: two buildings utilized for parts plating, polishing, painting, anodizing, and molding; two buildings utilized for machinery maintenance; an administration building; a warehouse; and other support buildings (Appendix 1, Facility Map).

The privately-owned CCPC reportedly operated at the Site between 1955 and 2004. The company became one of the largest metal finishers in the United States, specializing in brass, chromium, copper, and nickel plating as well as plastics plating and organic finishing for the automotive, electronics, plumbing, and hardware industries. Some gold and silver plating also took place. On-Site treatment of some process-related solutions occurred at the facility wastewater treatment area (WWTA). The WWTA consisted of a ground-level treatment area as well as a below-grade treatment room (basement); bpth areas contain storage tanks, process vessels, and other treatment process equipment. WWTA operations included treating aqueous waste streams such as oily water, corrosive solutions, and solutions containing hexavalent chromium, other metals, and cyanide either for re-use or for discharge to the local sanitary sewer system operated by the Los Angeles County Sanitation District. Specific treatment processes varied, but for metal-bearing waste streams, the steps included precipitation, clarification, filtration, and sludge drying. Various chemicals^ such

as corrosives for pH adjustment and flocculent agents, were stored and used at the facility for WWTA operations.

The CCPC facility ceased operations in late 2004 and sought bankruptcy protection. Beginning late 2004 and reportedly extending into 2007, CCPC conducted closure activities at the Site, including the disposal or removal of all plating solutions and all equipment in the plating, polishing, painting, molding, and maintenance buildings. However, funding for closure activities was exhausted before the removal of all hazardous substances and wastes was complete or facility cleaning could occur. The representative for CCPC at the time of bankruptcy was Mr. Tod Rankin, President and Chief Executive Officer of the company. As a result of bankruptcy proceedings, fee title to the Site was transferred to Continental Business Credit, Inc. In late June/early July 2008. Please see the Enforcement Confidential for further information regarding property ownership and bankruptcy proceedings.

3. Removal site evaluation

On June 11, 2008, OSCs J. Musante and R. Wise met with El Monte Senior Deputy City Attorney David Gondek to discuss the Site. Mr. Gondek stated that, since being abandoned, the Site had become a public nuisance with a high volume of trespass leading to graffiti, vandalism, and theft of metals. Apparently, the Site had attained notoriety amongst graffiti "artists" who organized events at the Site and posted pictures advertising their activities on the internet. A number of small fires had been started at the Site by trespassers, requiring police and fire department response. On May 19, 2008, Mr. Gondek conducted an inspection of the facility with police department personnel and observed potentially hazardous wastes at the Site, which led to his contacting EPA.

Following the discussion, OSCs Musante and Wise conducted an inspection of the Site with Mr. Gondek. Also present were personnel from the El; Monte Police Department, Los Angeles County Fire Department (LACFD), and the California Department of Toxic Substances Control (DTSC). The inspection , consisted of a walk-through of the Site, noting general types and conditions of any containers or process areas that contained or potentially contained solid or liquid wastes. Container types present included drums, cylinders, vats, tanks, supersacks, sumps, and metal or concrete spill containment systems. Many containers held original waste or product material and were open to the environment. Several large buildings were empty, having been cleaned of process equipment during the facility closure. Other buildings or areas, such as the WWTA, showed signs of spilled or residual process-related waste on the floor, and several subsurface sumps around the Site were noted to be full of stagnant water. The contents of one above-ground storage tank (a 3,000-gallon tank labeled "sulfuric acid") were observed to have been released into the secondary containment basin.

OSC Wise contacted Mr. Rankin and niade arrangements to meet at the Site. On June 16, 2008, OSCs Wise and Musante and EPA Civil Investigator J. Jaros conducted a walk-through ofthe Site with Mr. Rankin and a former CCPC employee who was involved with the facility closure activities. Mr. Rankin • represented that many containers present at the Site contained hazardous wastes and that disposal of these wastes was not completed due to lack of resources. Additionally, Mr. Rankin stated that limited closure activities had been conducted in the WWTA and the system was basically left in place as it was when the facility was in operation. Site conditions prompted OSC Wise to give a general notice of CERCLA liability to Mr. Rankin. Mr. Rankin represented that CCPC was in bankruptcy and did not have the resources to secure the Site or, conduct any removal work associated with potentially hazardous wastes at the Site. This lack of immediate response capability by the apparent liable party, coupled with hazardous wastes in unsecured areas accessible to the public, resulted in OSC Wise initiating an emergency action to secure the Site. Emergency activities within the OSC's authority commenced on June 16, 2008, when OSC Wise made arrangements for the EPA Emergency and Rapid Response Services (ERRS) contractor to provide 24-hour security at the Site to prevent trespassers from entering the Site and being exposed to the hazardous ; wastes present.

On June 24, 2008, OSCs Musante and Wise conducted further Site reconnaissance, generally walking through the facility and noting the general types and conditions of any containers or process areas that contained or potentially contained solid or liquid wastes. Additionally, sampling locations and required analyses were identified by the OSCs. The EPA technical response • contractor (START) completed a container inventory during the reconnaissance, which included marking an inventory number on each container. The START • Container Inventory and Sample Summary listing: inventory ID number, lab sample ID, container/contents description, location, and analysis requested is ; contained in Appendix 2.

On June 26, 2008, the START implemented an approved Emergency Response Quality Assurance Sampling Plan at the Site. Field chemistry verified the presence of corrosive solutions in unsecured and compromised bulk containers. Twenty-six samples were collected from sumps, drums, process tanks or vessels, above-ground storage tanks, supersacks, and pipe insulation. The samples were submitted to accredited off-Site laboratories for one or more of the following analyses:

• pH via EPA Method 9040/9045 • total cyanide via EPA Method 9010/9014 • amenable cyanide via EPA Method 9010/9014 • Target Analyte List (TAL) Metals via EPA Method 6010B/7471A • Toxic Characteristic Leaching Procedure (TCLP) metals via EPA Method

1311/6010B/7470A

• Hexavalent chromium via EPA Method 7196A • Asbestos by polarized light microscopy via EPA Method 600/R-93-116.

4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant

The objective of the June 26, 2008 sampling event was to obtain an analytical data set meeting EPA Quality System guidelines that was representative of current Site conditions and that could be used to identify key hazardous substances of interest for project health and safety needs and future waste profiling purposes. Field testing and laboratory analytical data confirmed the presence of corrosive solutions, asbestos containing materials, high concentration cyanide residues, and numerous heavy metal contaminated waste streams associated with former electroplating and industrial wastewater treatment processes. A Validated Sample Results Table is contained in Appendix 3.

Analytical data indicate the presence of wastes at the Site exhibiting the Resource Conservation and Recovery Act (RCRA) hazardous waste characteristic of corrosivity under 40 CFR § 261.22; wastes exhibiting the RCRA hazardous waste characteristic of toxicity under 40 CFR § 261.24 for chromium, lead, and mercury; and wastes containing chromium, copper, lead, nickel, antimony, zinc, and hexavalent chromium in concentrations exceeding California Total Threshold Limit Concentrations waste determining values. Analytical results for Sample CCP-25 reported 20% asbestos content. Analytical results for numerous samples reported the presence of cyanide, with a maximum . concentration of 6,500 mg/kg. Chromium, lead, nickel, mercury, and cyanides are also listed hazardous constituents under 40 CFR Part 261, Appendix Vlll.

RCRA characteristic and listed wastes are hazardous substances as defined by Section 101(14) of CERCLA. Other hazardous substances or pollutants and contaminants not discovered to date or not specifically identified herein may exist at the Site. These substances may also pose a threat to human health and the environment.

There is limited security at the Site and the hazardous contents of containers and the WWTA are accessible to the general public. The potential for fire, vandalism and continuing deterioration of containers at the unmanaged Site may result in the combustion, physical exposure, or commingling of incompatible hazardous substances resulting in harm to the public health or welfare or the environment. Considering the proximity of nearby businesses and public roadways, the Site represents a significant threat of release affecting nearby populations and direct contact exposure to trespassers.

5. National Priorities List (NPL) status

The facility at the Site is not currently on or proJDOsed for inclusion on the NPL.

A portion of the San Gabriel Valley where the CCPC facility is located was added to the NPL in 1984. The NPL listing resulted from the discovery of contamination within aquifers forming the regional groundwater system known as the San Gabriel Valley Basin. The contamination source is attributed to the historic use and improper handling and disposal of industrial chemicals from numerous facilities over time. The Basin is subdivided into eight Operable Units (OUs). The CCPC Site is associated with the El Monte OU, which covers ', approximately 10 square miles. Contaminants detected in this OU included V perchlorate, hexavalent chromium, and 1,4-doixane. EPA identified CCPC as a liable party for contamination in the El Monte OU. Fifteen other liable parties for this OU formed the Northwest El Monte Community Task Force and entered into an Administrative Order on Consent with the EPA to perform required contamination studies. CCPC initially did not join the Task Force, but complied once EPA issued a Unilateral Administrative Order in May 1995. There are three groundwater monitoring wells on the CCPC property although it is unknown whether groundwater monitoring currently takes place.

B. Other Actions to Date

On June 11 and 16, 2008, the EPA Emergency Response Program conducted inspections of the Site. Based on the findings of the inspections and conditions at the Site, OSC Wise determined that the conditions at the Site presented ah emergency endangerment to human health and the environment. Acting within his delegated authority, the OSC spent approximately $170,000 to mitigate the emergency conditions. The response proposed in this memorandum is a further, time-critical response to the hazardous substances remaining at the Site.

C. State and Local Authorities' Roles

1. State and local actions to date

Since the facility was abandoned in May 2007, the El Monte Police Department has responded to numerous complaints of trespassing at the Site. In May 2008, the City of El Monte, Senioi" Deputy City Attorney inspected the Site and observed suspected hazardous wastes present Subsequently, a request was made to OSC Wise for EPA assistance at the Site. Additionally, the LACFD has responded to multiple small fires started by trespassers at the Site.

In June 2008, the DTSC Enforcement and Emergency Response Program, in coordination with EPA, arranged for the repair of perimeter fencing to help secure the Site from trespass. In late 2005, the DTSC Tiered Permitting

Corrective Action Branch, Hazardous Waste Management Program issued a Corrective Action Consent Agreement (Agreement) to CCPC to investigate the nature and extent of any releases of hazardous waste or hazardous constituents at multiple Areas of Concern at the site. The Agreement also called for Facility Investigation, Risk Assessment, Corrective Measures Study, and Corrective Measures Implementation steps. CCPC signed the Agreement, but reportedly did not conduct any of the agreed response actions.

In May 1992, Los Angeles Regional Water Quality Control Board issued a Cleanup and Abatement Order (Order) to CCPC to determine the presence or extent of onsite contamination. EPA understands that this Order was related to the investigation or remediation of groundwater contamination ofthe San Gabriel Valley Superfund Site. No CCPC action was reported to have been taken.

2. Potential for continued State/local response

Neither State nor local agencies appear to have the resources to undertake the proposed cleanup action at this time. The LACFD made a formal request for federal action to EPA on June 11, 2008. A copy of the request for federal assistance is included with this memorandum.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

Conditions at the Site represent a release, and potential threat of release, of CERCLA hazardous substances threatening to public health, or welfare, or the environment based on the factors set forth in the NCP, 40 CFR § 300.415(b)(2). These factors include:

1. Actual or potential exposure to nearby populations, animals or the food chain from hazardous substances or pollutants or contaminants.

There is an actual or potential exposure to nearby populations frorh hazardous substances at the Site, including asbestos; materials containing cyanides, chromium, copper, lead, nickel, antimony, and zinc. These hazardous; substances exist in liquid and solid wastes found throughout the facility and in the WWTA. There are also large quantities of corrosive wastes in drums and structurally compromised above ground-storage tanks at the Site.

Although the Site property is fenced, pedestrian access is relatively unimpeded. The facility remains a human health risk to ahy vandals or trespassers, including young children, who might enter the premises. Direct contact, inhalation or ingestion of the hazardous substances at the Site poses an acute health threat to these individuals. Toxic fumes and smoke may reach :

populations outside the Site in the event of a facility fire or the mixture of incompatible chemicals, such as sulfuric acid and cyanide. Based on these conditions, the threat of release and subsequent exposure appears high. Toxic threats from specific materials at the Site are discussed below,

Asbestos is a known human carcinogen; when inhaled it has bieen found to pose a significant health threat. The primary diseases that have been associated with asbestos exposure are respiratory ailments including asbestosis, lung cancer, and mesothelioma. The inhalation of airborne asbestos from physical disturbance of asbestos-containing materials present at the Site is the exposure pathway presenting the most significant risk to human health.

Cyanide is readily absorbed through the skin, mucous membrane, and by inhalation. Symptoms of cyanide poisoning include anxiety, confusion, vertigo, nausea, convulsions, paralysis, coma, cardiac arrhythmia, and transient • respiratory stimulation followed by respiratory failure or death.

Chromium is an ecotoxic heavy metal that is an inhalation, ingestion, and dermal exposure risk. Chromium bioaccumulates and targets the liver, kidneys, reproductive organs, circulatory system, and gastrointestinal system. Acute exposure to chromium can cause harmful effects to the gastrointestinal system. Chronic exposure can cause harmful effects to the skin, lungs, mucous membranes, and possibly cancer.

The EPA has determined that hexavalent chromium in air is a human . carcinogen. Hexavalent chromium can cause irritation to the nose, such as runny nose, nosebleeds, and ulcers and holes in the nasal septum. Skin contact with certain chromium compounds can cause skin ulcers. Ingesting large ^ amounts of hexavalent chromium can cause stomach upsets and ulcers, convulsions, kidney and liver damage, and even death.;

Lead is a heavy metal that bio-accumulates in human tissues. Short-term exposure to large amounts of lead can cause harmful effects on the nervous system, gastrointestinal system, kidneys, and circulatory system. Long-term exposure to low levels, such as those that may occur in the work place, can cause damage to the central nervous system, kidneys, blood, gastrointestinal tract, and gingival tissues. Children are particularly sensitive to the chronic effects of lead, with slowed cognitive development, reduced growth and other effects.

The EPA classifies lead as a class B-2 carcinogen, which means that it is a probable human carcinogen. Of greater concern are the non-carcinogenic effects of lead, which range from disruption of neurological and neurobehavioral development in fetuses and children to elevated blood pressure in middle-aged men.

Materials that exhibit the RCRA hazardous waste characteristic of corrosivity under 40 CFR § 261.22 are present at the Site. The corrosive nature of the acidic and caustic liquids and solids present a direct contact and inhalation threat that could cause severe burns of the skin, eyes, and respiratory tract.

Other hazardous substances or pollutants and contaminants not discovered to date or not specifically identified herein may exist at the Site. These substances may also pose a threat to human health and the environment.

2. Hazardous substances or pollutants or contaminants in drums, barrels, tanks, br other bulk storage containers, that may pose a threat of release.

A preliminary inventory of containers (Appendix 1) includes over 100 various sized drums, tanks, sumps, and clarifiers. Container conditions appear to range from good to poor and many are not properly marked. Most containers are not secured from the elements or from improper access. The outer shell of at least one above-ground storage tank (a 3,000-gallon "sulfuric acid" tank) was observed to have failed, releasing the contents into a secondary containment basin. Samples collected from containers at the Site by EPA documented the presence of the following hazardous substances at federal or state hazardous waste determining levels: cyanides, chromium, copper, lead, nickel, antimony, zinc, and corrosive liquids and solids.

3. Threat of fire or explosion

During initial EPA Site investigation activities, evidence of small fires started by trespassers at the Site were observed throughout the facility. The LACFD also reported responding numerous times to small fires started by vandals or trespassers at the Site. On June 6, 2008, the LACFD responded to a fire at the Site that involved an intermodal cargo container less than 50 feet from plastic "supersack" containers documented by EPA assessment to contain hazardous wastes.

4. Availability of other appropriate federal or state response mechanisms to respond to the release.

No other appropriate federal, local or state public funding source has been identified. The proposed action exceeds the asserted financial capability of the California State Emergency Reserve Account.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this Site, if ' not addressed by implementing the response action selected in this Action

Memorandum, may present an imminent and substantial endangerment to public health, or welfare, or the environment

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed action description

EPA proposes to characterize, segregate, bulk, re-containerize and remove for disposal all abandoned hazardous substances and pollutants in containers and at the WWTA at the Site. All wastes will be characterized using EPA approved methodologies and delivered to approved disposal facilities.

. All activities will be performed in conformance with prescribed health and safety procedures. Sampling and analysis activities will conform to EPA approved methodologies and mandatory specifications for quality assurance and quality control activities.

2. Contribution to remedial performance

EPA does not anticipate a long-term remedial action at this Site. This removal action should remove all immediate threats posed by uncontrolled hazardous substances at the Site.

The long-term cleanup plan for the Site:

It is expected that this removal action will eliminate any threat of direct or ' indirect contact with hazardous substances at the Site. Final reporting of this .. removal action will be provided to the DTSC, LACFD, City of El Monte, and Continental Business Credit, Inc. (current property title holder) for consideration in any further cleanup or redevelopment activities. I

Threats that will require attention prior to the start of a long-term cleanup:

There is no EPA long-term cleanup planned for this Site. The immediate threats that have been identified in this memorandum will be addressed by the proposed removal action.

The extent to which the removal will ensure that threats are adequately abated:

The removal of abandoned, above-ground hazardous substances and wastes is expected to abate the immediate threats from the Site.

Consistency with the long-term remedy:

10

As stated above, final reporting of this removal action will be provided to State and county agencies for consideration in any future activities at the Site.

Post Removal Site Control / ' . • •

y • , . • ,

The OSC has begun planning for the provision of post-removal Site ,; controls, consistent with the provisions of § 300.415(k) ofthe NCP. The nature of the removal, elimination of all accessible threats from hazardous substances, is, however, expected to eliminate or minimize the need for post-removal Site controls.

3. Description of alternative technologies

Alternative technologies are not considered for the proposed response action.

4. Applicable or relevant and appropriate requirements (ARARs)

Section 300.415(j) ofthe NCP provides that removal actions must attain ARARs to the extent practicable, considering the exigencies of the situation.

Section 300.5 of the NCP defines applicable reguirements as cleanup standards, standards of control, and other substantive environmental protection requirements, criteria or limitations promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location or other circumstances at a CERCLA site.

Section 300.5 of the NCP defines relevant and appropriate requirements as cleanup standards, standards of control and other substantive requirements, criteria, or limitations promulgated under federal environmental or state environmental or facility siting laws that, while not "applicable" to a hazardous substance, pollutant or contaminant remedial action, location, or other circumstances at a CERCLA site, address problems or situations sufficiently similar to those encountered at the CERCLA site and are well-suited to the particular Site.

Because CERCLA on-site response actions do not require permitting, only substantive requirements are considered as possible ARARs. Administrative requirements such as approval of, or consultation with administrative bodies, issuance of permits, documentation, reporting, record-keeping, and enforcement are not ARARs for the CERCLA response actions confined to the Site.

Applicable off-site requirements include 42 U.S.C. § 9621(d)(3) (see also the CERCLA Off-Site Disposal Rule OSWER Directive 9347.3-8FS) and the U.S.

11

Department of Transportation of Hazardous Materials Regulations 49 C.F.R. Part 171, 172and 173.

The following ARARs have been identified for the proposed response action. All can be attained.

State ARARs: Potential State ARARs are Hazardous Waste Regulations , found in the California Health and Safety Code, Title 22, § 66261.20, § 66261.22i § 66261.23, § 66261.24. All other State ARARs identified by the State in a timely manner will be met as feasible.

5. Project schedule

It is estimated that removal activities will take three weeks to complete.

B. Estimated Costs

Regional Removal Allowance Costs

Cleanup Contractor $545,000:

Extramural Costs Not Funded from the Regional Allowance ' • • • '

START Contractor $50,000

Extramural Subtotal $595,000

Extramural Contingency (20%) $ 119,000

TOTAL Removal Action Project Ceiling $714,000

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Given the Site conditions, the nature of the hazardous substances documented on-Site and the potential exposure pathways to nearby populations described in Sections III and IV above, actual or threatened releases of hazardous substances from the Site, if not addressed by implementing the ' response actions proposed in this Action Memorandum, present an imminent and substantial endangerment to public health, or welfare, or the environment.

I • . '• • • . • ' • • • . • I

VII. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues with the Site identified at this time.

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VIII. ENFORCEMENT

Please see the attached Confidential Enforcement Addendum for a discussion regarding Potentially Responsible Party (PRP) and enforcement. In : addition to the extramural costs estimated for the proposed action, a cost recovery enforcement action also may recover the following intramural costs:

Intramural Costs'

U.S. EPA Direct Costs $20,000

U.S, EPA Indirect Costs (36.588% of $714,000+ $20,000) $283,109

TOTAL Intramural Costs $323,109

The total EPA extramural and intramural costs for this removal action, , based on full-cost accounting practices that will be eligible for cost recovery, are estimated to be $1,037,109, including the approximately $170,000 incurred in the June 2008 emergency response to stabilize the Site. Of the costs proposed in this memorandum, an estimated $545,000 comes from the Regional removal allowance.

IX. RECOMMENDATION

This decision document represents an appropriate removal action for the Crown City Plating site. El Monte, Los Angeles County, California, as developed in accordance with CERCLA and not inconsistent with the NCP. This decision is based on the Administrative Record for the Site.

Because conditions at the Site meet the NCP criteria for a time-critical removal, I recommend that you concur on the determination of imminent and substantial endangerment and the removal action proposed in this Action Memorandum. The total removal action project ceiling if approved will be $714,000, of which an estimated $545,000 comes from the Regional removal allowance (the total costs, including indirect costs, that may be subject to cost recovery are $1,037,109). You may indicate your decision by signing below.

Approve: _yMsd^££. '^.'T/^.^.a....^.^ / o A ' h

' Direct costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on an estimated indirect cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgment ^ interest, do not take into account other enforcement costs, including Department of Justice costs, and may ' be adjusted during the course of a removal action. The estimates are for illustrative purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total cost estimate nor deviation of actual costs from this estimate will affect the United States', right to cost recovery!

13

^

Daniel Meer, Assistant Director Date Response, Planning and Assessment Branch

Disapprove: Daniel Meer, Assistant Director Date Response, Planning and Assessment Branch

14

Enforcement Addendum

Index to the Administrative Record

Appendices

1. Facility Map "Figure 3"

2. START Container Inventory, June 24, 2008

3. Validated Sample Results Table

4. Request for Federal Assistance

cc: Sherry Fielding, USEPA, OEM, HQ U.S. Department of the Interior Patrick Movlay, California Department of Toxic Substances Control David Gondek, City of El Monte Robert Carrick, The Carrick Law Group

15

bcc: Site File Jason Musante, SFD-9-2 Andrew Helmlinger, ORC-3 John Jaros, SFD-9-4 Celeste Temple, SFD-9-4

16

Index to the Administrative Record

• START Removal Assessment Report dated August 5, 2008.

• Request for Federal Action from LACFD dated June i 1, 2008.

• DTSC Corrective Action Consent Agreement.

22

Appendix 1

Facility Map "Figure 3"

23

Reference- P lan t Area Layout, Ctovm (lly Pljiing Compjny. Decwnbef 1981

r GENtRAL WfiWiVG

J

(OCCUPIED arOTHERSl

F E E T

(approximate scale)

I Ecology & Environment, Inc.

Figure 3

Facility Map Crown City Plating

4350 Temple City Blvd., El Monte, California.

0OH9).2OM 01MO}.< (SURI CD Ardihn Vol 1) 07/) l /nDt TDD: 0^«»I6-00(U / N « i HoL.OQ2M}im.01RAO)

Appendix 2

START Container Inventory, June 24, 2008

25

CONTAINER INVENTORY AND SAMPLE SUMMARY Crown City Plating Company, El Monte, Los Angeles County, CA

Data From START/EPA Removal Assessment - June 24 and 26,2008 Sampiine Date: June 26, 2008

Invt. ID

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15 -24

25

26

2 7 -48

49

5 0 -60

61 -82

83

84

85

86

87

ID for Lab Sample

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

CCP-16

CCP-15

N/A

N/A

CCP-14 .

N/A

CCP-17

CCP-18

CCP-19, CCP-19D*

N/A

CCP-11

CCP-12

CCP-7 (solids inside tank) CCP-24, CCP-24D* (water below tank)

Container and Contents Description

drum: 55-gallon blue metal, possible unused oil, approx. % full; "vegetable grade glycerine" drum: 55-gallon black metal, possible used oil, approx. 1/3 full

drum: 55-gallon red metal, possible used oil, approx. Vt full

drum: 55-gallon blue metal, possible used oil and sludge, approx. 1/4 full drum: 55-gallon green metal, possible unused oil, approx. 2/3 full; "castor oil"

drum: 55-gallon blue poly, possible unused oil, approx. 2/3 full; "castor oil" 5-gallon bucket, possible used oil, approx. 1/2 full

drum: 55-gal blue poly, possible unused oil, approx. 3/4 full

Compressed gas cylinder: labeled as carbon dioxide, approx. 656 cubic foot capacity, chained to concrete.

Compressed gas cylinder: labeled as carbon dioxide, approx. 656 cubic foot capacity, chained to concrete.

drum: 55-gallon steel black drum, did not open, appeared full

drum: 55-gallon steel black drum, did not open, appeared Vt full

drum: 55-gallon drum, open-top, on its side, yellow lumpy sludge spilled out onto concrete floor drum: 55-gallon blue poly drum, open-top, on its side, blue powdery substance spilled out onto concrete floor

10 supersacks: full of grayish powder, approx. 1 cubic yard per. sack. Sample is a composite from all 10 sacks. drum: 55-gallon blue poly, open top, approx. 1/2 full, solid material, possibly polishing dust u drum: 55-gal blue poly, covered, did not open, approx. V* full

22 drums: 55-gallon black metal, uncovered, each drum approx. 2/3 full of gray, powdery material, possibly floor sweepings. Sample is a composite from all drums. drum: 55-gallon blue poly, on its side, did not open, appeared full 11 drums: 55-gallon black metal, open-topped, rusted. Each is approx. 3/4 full of hardened, layered solids. Sample is a composite from all drums. 22 drums: 55-gal blue poly, open topped, approx. 3/4 full, filled with gray powder. Sample is a composite from all drums. drum: 55-gallon blue poly, open topped, gray powder, approx. 3/4 full

5-gallon blue poly bucket, did not open, possible oil, appears full Estimated 4,500-gallon capacity black poly tank, labeled "Sodium Hypochlorite"; approx. 1/3 full of liquid Estimated 6,000-gallon capacity while poly tank, labeled "Sodium Bisulfate," did not view contents. Sampled exterior solids residue

Blue, metal tank, square, estimated 3000-gallon capacity, labeled "Sand Filter," approx. ' A M of solids. Possibly 300 gallons of stormwater in impoundment below this tank.

Loca t i on

Covered area near

Maintenance building

Adjacent to Maintenance.

building

Inside Maintenance

building

Adjacent to Shipping Area

Shipping Area

Under roof ramp

In Anodizing Area

Adjacent to Anodizing Area

Outside -adjacent to Sump #S-3 Adjacent to

WWTA

WWTA

Lab Analysis

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A'

N/A' •

N/A

N/A

N/A

CN, TAL metals, TCLP metals, Cr VI

CN, TAL metals, TCLP metals, Cr VI

N/A

N/A

CN, TAL metals, TCLP metals

N/A

CN, TAL metals, TCLP metals

CN, TAL metals, TCLP metals

CN, TAL metals, TCLP metals

N/A

CN, TAL metals, TCLP metals, pH

pH, CN, TAL , metals, TCLP

metals CCP-7: CN, TAL

metals, TCLP metals CCP-24/24D: CN,

. TAL metals, TCLP metals, Cr VI

Page 1 of 2

88

89

90

91

92

93

94

95

96

97

98

99

100

S-1

S-2

S-3

**

** ** ** ** "

..

**

*•

CCP-5

N/A

CCP-9, CCP -9D* (solids); CCP-23 (liquid in

floor sump)

N/A

N/A

N/A

CCP-10

N/A

CCP-8

CCP-6

CCP-20

CCP-3

CCP-2

N/A

N/A

CCP-21 (water) CCP-26 (sediment)

CCP-25

N/A

N/A

N/A

N/A

CCP-4

CCP-13

CCP-1

CCP-22

Several open-top, beige metal hoppers, labeled "Clarifier #2," 12,649-gal capacity total, approx. Yi full of solid/sludge. Beige metal tank, square, estimated 5,000-gallon capacity, labeled "Neutralization Tank #3" Beige metal silo, approx. 20 feet tall, labeled "Lime Silo." Did not view silo interior inside; quantity present unknown. Red liquid present in sump. Sampled solid residue inside doorway at base of silo 12,649-gallon capacity, beige metal container, labeled "Clarifier #1," mostly empty with base and sidewall residue 4,562-gallon capacity beige tank, labeled 'Neutralizing Tank

8,476-gallon capacity, metal tank, empty, labeled "Sludge Holding Tank #2" 4,461-gallon capacity, metal tank, labeled "Sodium Hydroxide." Contains liquid; approx % full. 8,476-gallon capacity, metal tank, empty, labeled "Sludge Holding Tank #1" 3000-gallon capacity, green metal tank, labeled "Sulfuric Acid." Liquid contents leaked into containment system; containment approx. % full. Sample collected from containment system. Beige metal tank, estimated 3000-gallon capacity, labeled "Cyanide Destruct Tank." Contains liquid; approx. Vi full Blue, metal tank, estimated 3000-gallon capacity, labeled "Chrome Settling Tank," contains liquid, approx. 1/3 full. Haz. waste label: extra chrome from #6 Pit 8/22/04' drum: 10-gallon black poly, pulled out of standing water in the sub-floor; clear liquid, nearly empty drum: 55-gallon drum, blue poly, found on its side but later righted; labeled "acid"; liquid, full Sump #1

Sump #2

Sump #3. Possibly 1,000 gallons water and 2 drums of sediment present.

Scattered pieces of pipe insulation on the ground. Possibly 1 drum total volume present. Approx. 60 empty 55-gallon drums

Approx. 20 empty 30-gallon drums

Approx, 5 empty 20-gallon drums

Empty, estimated 200-gallon capacity poly container

Yellow-brown solids located atop equipment, possibly 1 drum total volume present Loose solids (approx 100 gallons total volume) on ground below Sand Filter container (#88), in concrete impoundment. Sump located in maintenance area near drums, holds green liquid, possibly 100 gallons present. Called Sump 1 but was not one of 3 originally-inventoried sumps (S-1 to S-3 above).

Standing water in sub-level floor area; appears to be stormwater. Possibly several thousand gallons present.

•

WWTA

WWTA basement

Shipping Area

Anodizing Area

Outside of the Anodizing Area

Boiler Room

Throughout site

WWTA basement

WWTA

West side of Maintenance

building

WWTA basement

CN, TAL metals, TCLP metals

N/A

pH, CN, TAL metals, TCLP

metals

• N/A

N/A •

N/A

CN, TAL metals, . TCLP metals, pH

N/A

, pH

CN, TAL metals, TCLP metals

pH, TAL metals, TCLP metals,

C r V I . CN, TAL metals, TCLP metals, pH

pH, CN, TAL metals, TCLP metals, CrVI

N/A

N/A CCP-21: pH.CN, TAL metals, TCLP metals. CCP-26: CN, TAL metals, TCLP metals, CrVI

Asbestos

N/A

"• : N/A

N/A .

• •N /A CN, TAL metals, TCLP metals, Cr VI

CN, TAL metals, TCLP metals, pH

pH, CN, TAL metals, TCLP '

metals CN, TAL metals,

TCLP metals, Cr VI

Key: CN = cyanide

Cr VI = hexavalent chromium N/A = Not Applicable

TAL = Target Analyte List Metals TCLP = Toxicity Characteristic Leaching Procedure

WWTA = Wastewater Treatment Area * = field duplicate samples

''"'• = not inventoried Page 2 of2

Appendix 3

Validated Sample Results Table

27

Val idated Sample Results Table 1 - Samples CCP-1 Through CCP-14

C r o w n Ci ty Plat ing Removal Assessment, E l Mon le , C A

.;v>-;-M.t«rfai ?•%

f f . --Tola l Meta ls :

Anl imony (Sb)

Arsenic (As)

Barium (Ba)

Beryl l ium (Be)

Cadmium (Cd)

Chromium (Cr)

Chromium V I

Coball (Co)

Copper

Lead (Pb)

Mercury ( l i s )

Molybdenum (Mo)

Nickel (Ni )

Selenium (Sc)

Silver (At;) Thal l ium (Tl)

Vanadium (Va)

Zinc (Zn)

CXP-I • Maint. A r w ; . ; -Sonq i»* ,

W U K -

CCP-2 . WWTA ^ ; . , K x t n i i s , - ' briim#10()

%-' '

Llqukl * Trvduct '^

.•CCP-3' WWTA • BasMtKitt, Dr<ini««

Lkiuld

* t - •'••"?'^ 0 638

<0 . l

0.0922

<0 . l

0.437

1.48

N A

2.4

103

1.16

0.00012

<0.5

1380

<0 . l

<0.1

<0.1

<0.1

1550

Ir-iiiliiil Arsenic (As)

Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb)

Mercury ( l l f l )

Selenium (Sc)

Silver (Ag)

Cyiuiidc£iS»5i«i; Toial Cyanide

Amenable Cyanide

<0.5

<0.5

0.486

<0.5

0.234

<0.005

<0.5

<0.5

1 44

0.453

0.752

0.079

<0.5

132

<5 .0UJ

0.635

5.48 J

0.363

0.0745

4.93

72.7

<0 . l

<0 . l

<0 . l

<0.1

4.72

<5 0

<0.5

<0.5

<0.5

0.0525

7.77 .

N A

<0.5

0.936 J

0.158

<0.0025

<2.5

9.57

<0.5

<0.5

<0.5

<0.5

9.29

' C C P - t l -WWTA Basemnt

YeSow-Brown

• SoUd

T CCP-5 WWTA CUri8(r«2, Container t m

Solid/ SliH^e

n ig /k f i

<100

<10

2.41

< I 0

< I 0

261 J

10.6

<10

36.3

< I 0

<0 . l

<50

5.61

<10

<10

<10

<10

<10

95 2 J

< I 0

986

< I 0

3.19

7830 J

NA

6.42

20,400

1.160

0.398

<50

34,300

11.4

< I 0

< I 0

<10

1,900

7 ^ % % : : M ^ & M'-fWM 0.495

2.16

<0.5

89.8

0.446

0.0762

<0.5

<0.5

<0.5

0.186

0.058

6.98

<0.5

<0.005

<0.5

<0.5

/,i*^¥*'^«m«/umil*i^*.S <0.0I

N A

<0.0I

N A

0.0592

N A

<0.5

0.775

<0.5

<0.5

<0.5

<0.005

<0.5

<0.5

i S K ™ <I .O

N A

<0.5

0.24

0.1

<0.5

11.5

<0.005

<0.5

<0.5

49.4

N A

. CCP-t WWTA Cyanide Dcstroct Tank, Container

U n f M Prodact

m g / L

< l 0

<0.1

0.115

<0. l

<0. l

0.471

N A

<0. l

5.71

<0. l

<0.0005

<0.5

28.1

<0.1

<0.1

<0.1

<0.1

0.679

CCP-7

WWTA Sand l-llter, Comafaier^

Solid

m g / k g

^100

< I 0

11.5

< I 0

<10

964 J

NA

< I 0

1,830

18.6

<0 . l

<50

2,050

< I 0

<10

< I 0

< I 0

93

CCP-« • WWTA '. •_' Sulfatfc'Acid'

contain.. - ^ , Container «w '

• : .UqnW , ' *Pn>da«

, N /A '. _.

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

N A

-CCP-* . | CCP-9D

. P U P L I C A I E S - . -• w w f A ; l | i ; e " a j o :

'.Conl«liiir'«90 -

.White, Solid Keildtie

. mg /kg :;.-..-

< I 0 0

< I 0

3.55

< I 0

<10

15.5 J

N A

< I 0

I 2 2 J

16.3 J

<0 . l

<50

27 J

< I 0

<10

< I 0

< I 0

I 6 9 J

< I 0 0

< I 0

4.45

<10

<10

9.99 J

N A

< I 0

81.8 J

8.84 J

<0 . l

<50

8.66 J

< I 0

< I 0

< I 0

< I 0

I 0 6 J

CCP-10 ;

*jyrA.. Sodium * ' HitTroxide -T.AlJ#-ConSilner KM » f :

: Liquid <> ; f t o d . c t .

v -CCF- l t

WWTA'C-Sodlurollypo-chbrl l tTanli , Contaltier*«85

• 'Uq^ id ' -Product •

^•'r "'i'f^ •--lOll

< I 0

<10

<10

< iO

< I 0

N A

< I 0

3.5.1

<10

<0.0025

<50

< I 0

< I 0

< I 0

< I 0

< I 0

110

<1 0

<0.1

0.21

<0. l

<0. l

0.137

NA

<0. l

0.0281 J

<0. l

<0.0005

<0.5

<0. l

<0. l

<0. l

<0.1

<0.1

0 0705

- CCP-12 WWTA^i- ̂ SodhubT* - i Bhuifale.. < Container »8« ' , . -!̂

* Ytllo» CDStai'ltne

Solid

CCP-13-M o w . : . p Container'/ wntSand' Flter) '"

1 ' •

Brown. Craj Solidi

CCP-14 Under n n f raoipiDnmi «'i 27-<«

l loor Sweepings

mg/kg

< I 0 0

< I 0

< I 0

< I 0

< I 0

4.06 J

N A

<10

3.16

< I 0

<0.1

<50

3.19

< I 0

<10

< I 0

<10

<10

6 1 3 J

< I 0

4250

< I 0

11.3

51000 J

NA

20

45.900

13,000

7.00

7.4

53,900

36.7

4.88

< I 0

11.6

8,100

47 3 J

11.3

101

< I 0

16.6

469 J

N A

11.7

11.000

534

<0.1

<50

1,310

< I 0

4.41

< I 0

7.81

56.100

j ^ : ^ - : . ^ . - * ^ \ ^ >'*/ ' - * '*^ .

<0.5

0.125

<0.5

.0.295

<0.5

<0.005

<0.5

<0.5

i -SmglV: : ! -

<0.0I

N A

<0.5

0.772

<0.5

2.03

<0.5

<0.00S

<0.5

<0.5

: ;v i i iR/k| j? ' 1.14

N A

N A

N A

N A

N A

N A

N A

N A

N A

'psmgma N A

N A

<0.5

0.639 J

<0.5

<0.5

<0.5

<0.005

<0.5

<0.5

<0.5

0.369 J

<0.5

<0.5

<0.5

<0.005

<0.5

<0.5

^ f^miH&:m <I.O

N A

<I.O

N A

<50

<50

<50

<50

<50

<0.005

<50

<50

<0.5

0292

<0.5

<0.5

<0.5

<0.005

<0.5

<0.5

ss*4gragntiee'isgg • <0.0I

N A

0.0109

NA

<0.5

<0.5

<0.5

<0.5

<0.5

<0.005

<0.5

<0.5

<0.5

0.137

<0.5

0.381

<0.5

0.0102

<0.5

<0.5

<0.5

0.678

0.307

0.233

1.75

<0.005

<0.5

<0.5

s<a?-v>'.- iBit*(!-: ' :-•; .••.-.••. ..•

<I.O

N A

538

533

<I.O

N A

OtKr5*:Mly«a^ggsg^s!^aSJ^iag«!S«lSaitS:I.A -̂ fe-'V.̂ .. -/,= ;,•,=-,..;• ^•• ;^n: iPi ; iVi f i ;Ka«i3^s|^. , . : „a i*NS^ie*SS&SsS;t^: f^^e •; ••J'v pll 1 4.96 1 <1 1 1.60 1 NA 1 NA 1 NA 1 NA 1 <l j 13J | I3J j 14J j 9.38 j 5.34 | 7.78 | NA

A d i n i U v e t

C A T T L C

(mg/kg)

500

500

10.000

75

100

2.500

500

8,000

2,500

1,000

20

3,500

2,000

100

500

700

2,400

5,000

U S E P A T C L P

5

100

1

5

5

0.2

1

5

: • - • : • • : W \ " : - i . -

N/A

N/A

; U S E P A ! R C R A S 2 o r s 1 2 . 5

Analyte results that exceed action level criteria appear in bold type

Key: CA = Califomia J = cslimatcd

mg/kg = milligrams per kilogram mg/L = milligrams per liter .

- - . NA = not analyzed -

N/A = noi applicable

RCRA = Rcsoucc Conservation and Recovery Act STLC = Solublc.Thrcshold Limit Concentration TCLP = Toxicity Characteristic Leaching Procedure TTLC = Total Threshold Limit Concentration

UJ = The material was analyzed for, but was not detcclcd. The associated value is an .estimate and may be inaccurate or imprecise.

WWTA = Waste Water Treatment Area -

Validated Sample Results Table 2 - Samples CCP-IS Through CCP-26 Crown City Plating Removal Assessment, El Monte, CA

• "S ' Samnit ID -li t

. ..ContAiner or. Source Arca^' '

Tetal Metals- • ^ •

Antimony (Sb) Arsenic (As)

Barium (Ba)

Beryllium (Be) Cadmium (Cd)

Chromium (Cr)

Chromium VI Cobalt (Co) Copper

Lead(Pb)

Mercury (HK) Molybdenum (Mo) Nickel (Ni)

Selenium (Se)

Silver (Ag) Thallium (Tl)

Vanadium (Va) Zinc (Zn)

:~CGPiI5. Supcraacks., Container ^ »'s lS-24 . m., Gray Powder.

CCP-16 Sbippinjaa^

.• CCP-ITP AiuKlbint' ' ^rea, bnutt «f S0-6e'..

:.Uardeiictl, ••Layered tSolids

l i CCP.18 Adjacent to AnodUng % Area, Drum i

Graf Powi^^

CCP-W iGGPrtSUff* C<3'-2B J- •••• HELD -T-V-SDUPLICATES -^dlacent to Sump

•iSl-3,\ DiTUll #113

S- Gray Powaer' •

• , . ^ ^ . • - - r \ * . g / . | 8 ^ . • " • • ^

494 J

9.06 J

1370

<10 7.27 J

37000 J 14,400 24.7

22.200

8.000 0.752

11.8 32.800

<I2 4.59

<I2 12.5

4.920

<100 8.84 J

81.5

<I0 2.22 J

351 J 22.9

2.98 J

70,100 61.6

0.222

<50 9.260

<I0

<I0 <I0

7.05 5,150

<100 <I0

45.7

< I0 < I0

26.2 J

NA 2.23 J

35.5 9.24 J

<0.1

<50 30.4

<IQ <I0

< I0 < I0

42.3

I I 9 J

15.6

2140

<I0

3.50 J

9 7 I 0 J NA

12.3

19,500 7.390 1.68

18.3 11.SOO

15.4

3.86 <I0

12.7 2.220

241 J

<I0

145

<10 4.27 J

20500 J

NA 7.16J

15,600 414

12.3

<50 6,020 <10

<10 <10

<I0

1,220

fe- • 373 J

< I0

142

<10 3.04 J

31500 J NA

8.85 J 11,900

510 12.6 5.92

6,760

<I0 <I0 <I0

5.93

1,230

WWIA

Cbrome ::..:̂ Se t t l i i i i i f^ Coot.«)g--¥

Li^iliil ^rodu^

CCP-21 Siiiiip#S-3 -outside br|' ; A»^fel4: | •

.' iw^jl

CCP-22 WWTA';» :

j . WoteS

CCP-23 CGP-24.1eCPiJ4l> WWTA-Ume : ' FIEtOlf : ; Silo Sump, D l 'PLICAm-CMtBioer «9D WWTA; Below

Sanil t w i t

M^^LillullI ^Piroduct

-. ' t i • . .

Watmiii:;.

., : : ' • ' • ' ' % ^ ' % . i j V ! l i 0.924 J

<0.l

0.208

<0.l

0.0180 J 78.9

<0.2 UJ 0.0774 J

72.9

6.61 0.00404

<0.5 69.8

<0.l

<0.1 <0.l <0.1

20.4

0.195 J

<0.1 0.141

<0.l 0.0341 J

16 NA

0.0343 J

2.35 0.0469 J 0.00527

<0.5 34.6

<0.1 .

<0.l <0.l

<0.l 2.94

0 . I I 9 J

<0.l

0.0469 J

<0.1 0.0541 J

9.45

7.25 J <0.l

1.10 0.112

<0.0005

<0.5 9.69

<0.l

<0.l <0.1

<0.l

10.0

<I.O <0.1

0.0650 J <0.l

<0.l

0.376 NA

<0.1 <0.l

0.0709 J <0.0005

<0.5 <0.1

<0.l

<0.1 <0.1

<0.1 0.0872

<l.0 <0.l

0.132

<0.1

0.0153 J 0.487

<0.l <0.l

19.6

0.509 0.0092

<0.5 40

<0.1 <0.l

<0.1 <0.l

5.78

<l .0 <0.l

0.136

•<0.l

0.0150 J

0.499 <0.0I <0.l

20.0

0.516 0.00918

<0.5 39.9

<0.1 <0.1

<0.1 <0.1

5.62

cep-25 Pieces OH Boiler Room Floor

• j i

•P ipe t f '{AsulatieA

%?iiiA

NA NA

NA

NA

NA

NA NA

NA NA

NA NA

. NA NA

NA

NA NA

NA

NA

fcti^^'-^f:%M^.,:--mac:,:,2'::.' -w '̂* mt̂ »̂««-. ,., ,:r ^̂ '̂ Arsenic (As) Barium (Ba)

Cadmium (Cd)

Chromium (Cr)

Lead (Pb) Mercury (Hg)

Selenium (Se) Silver ( A R )

a m d o L - i : , •• Total Cyanide

Amenable Cyanide

cmmAOfOyset pH Asbestos

<0.5

0.126

<0.5

251

<0.5 0.00491

<0.5 <0.5

<0.5

0.165 <0.5 1.79

<0.5 0.00955

<0.5

<0.5

<0.5

0.756 <0.5

<0.5

<0.5

<0.005 <0.5

<0.5

.•,••.•'•'•• ' ' M : i k r & s - mWks 5.410 5,371

NA NA

5,910 5,910

• • - J ^ ^ . - ; > ;

NA NA

2.65

NA :::r\" ."^'r^,'

NA NA

<0.5 0.179

0.278

20.7 <0.5

0.00998

<0.5

<0.5

<0.5

0.108 J 0.183

42 J

0.902 J 0.457

<0.5

<0.5

<0.5 0.227 J

0.169

58.6 J

0.292 J 0.472

<0.5

<0.5

s*.-£-- mf&sn-'-.. 6,500

6,458

; » - ? » NA NA

2.370 2,370

• . # : ' . ' • • ' '

NA NA

6.34

NA

:.:. :'. :... NA NA

0.346

0.1 II <0.5

82

5.41

<0.005 <0.5

<0.5

<0.5 <0.5

<0.5 14.7

<0.5

0.00477

-<0.5 <0.5

<0.5

<0.5 0.057 7.82

<0.5 <0.005

<0.5

<0.5

<0.5

0.266 <0.5

0.27

<0.5 <0.005

<0.5

<0.5

<0.5

0.168 <0.5

0.407

<0.5 0.00904

<0.5

<0.5

<0.5

0.177 <0.5

0.376

<0.5 0.00826

<0.5

<0.5

==v-.A-•.:••••" '• - ^ . . . y - : . ' ' m l i - : - " . - ' : . . - \ : : ' L . y . } y . . : : . : . , NA NA

3.75 NA

2.91

2.82

7.50 NA

0.0417

NA ••iw; »

NA NA

<0.0I

NA

e s t . :• •. -12

NA

<0.0I

NA • : •

NA NA

<0.01 NA

NA NA

NA

NA NA

NA

NA NA

NA

NA

• : N / A : - - '

NA

NA

m̂nm NA 20%

CCP.26: Boii<rf«i(|:

# s - 3 m . •

1* -..Iii ''SedimeotI

rag/kg

68.8 J 21.7

14,500

<I3 <I3

5,430

21.3 19.1

21.600

1,930 19.5

23.6 10,400

20.8

6.08 <13

9.35 3.280

l ^ f • • -.

<0.5

1.05 <0.5

1.86

1.04

0.153 <0.5

<0.5

ras*S 3,450

3,438

B ; . f - . ; . NA

•NA

•WtcJonlSvel*!

C A T T L C

(lufiflte) 500 500

10,000

75 100

2,500

500 8,000 2.500

1.000 20

3,500 2,000

100

500 700

2,400

5,000

* t rSEPA TCLS;

5

100

1 5

5 0.2

1

5

- y I*A .̂ A i •N/A-

• N/A

USEPA RCRAI < 2 or > 12.5

N/A

Analyte results that exceed action level criteria appear in bold type

- • -• "• Key: CA= Califomia . .. - , J = estimated

mg/kg = milligrams per kilogram

mg/L = milligrams per liter - . ' . . '

'•• NA ^ not analyzed . • N/A:= not applicable

STLC = Soluble Threshold Limit Concentration . -TCLP = Toxicity Characteristic Leaching Procedure -^ • .^ • TTLC = Total Threshold Limit Concentration

• UJ = The material was analyzed for, but was not detected! The associated value is an estimate and may be inaccurate or imprecise.

- WWTA "= Waste Water Treatment Area , : : " " .

Appendix 4

Request for Federal Assistance

29

R E Q U E S T F O R F E D E R A L A C T I O N

The I ^ A C P ^ - V - Q •__ ("Requesting Agency") requests assistance from the United States Environmental Protection Agency, Region 9 ("EPA") to conduct a removal action at the facility located at:

Street Address, Parcel Number or Other Property Description

^ U \hAo/)^^ _ ^ _ _ _ ^ ^ ^ City

L-c.S •̂ ^ ' ^ ' ^ . e , l e S County

CIA

^

State

By making this Request, the Requesting Agency recognizes that with respect to this removal . action EPA, or any other federal agency acting in conjimction with of on behalf of EPA, may use its authority under the Comprehensive Environmental Response Compensation and Liability Act ("CERCLA"), 42 U.S.C.A. §§ 9601, et se^., the National Contingency Plan ("NCP"), 40 C.F.R. Part 300, or any other federal statute, regnlation or response program, to respond to and recover costs incurred in response lo releases or threats of releases of pollutants and contaminants as • , deemed necessary in EPA's sole discretion to abate an imminent and substantial endangerment to public health or welfare or the environment at the location stated above. By making this Request, the Requesting Agency with respect to this removal action waives notice as otherwise: required by Section 128(b)(1)(D) of CERCLA, 42 U.S.C. § 9628(b)(1)(D). The signatory of this request is authorized to make this request on behalf of the State.

Executed on this the t l day of 0^^ -*^ , 200l

^^^^TXUsMk. Name

T i t l e • • • ; ^ _ • • • ; • - • •••' - V : ' • • '