FINAL Removal Action Workplan

Former Mercury Dry Cleaners 2714 Pinole Valley Road Pinole, C:alifornia 94564

May 14,2002 002-07741-00-12

Prepared for Bank of America Realty Finance, Inc.

4820 Itvine Boulevard Irvine, California 92620

LFR LEV INE-FR ICKE

May 14,2002 002-07741-00-12

M s Remedios Sunga Depa~tment of Toxic Substance Cont~.ol/Berkeley 700 Heinz Avenue, Suite 200 Berkeley, California 94710

Subject: Final Removal Action Workplan and Evaluation of Remedial Technologies for Source Area Remediation, Former Mercu~y D I ~ Cleaners, Pinole. California

Dear Ms. Sunga:

On behalf of Bank of America Realty Finance, Inc (BARFI), LFR LevineFricke (LFR) is pleased to submit the above-referenced document addressing source area remediation in the vicinity of the former Mercury Dry Cleaners facility located at 2714 Pinole Valley Road, Pinole, Califbrnia ("the Site") This document, which was prepxed in response to OUI meeting on April 18, 2001, lists and evaluates the different technologies that might be used for remediation of impacted soil and groundwater at the Site, and presents a workplan fbr the proposed remedial action

If you have any questions concerning this document, please call eithe~ of the undersigned at (714) 444-0111

Senior Prqj{ct Geologist

Enclosure

cc: MI Evan Henry, Bank of America Realty Fmance, Inc MI Eric Forsberg, Bank of America Realty Finance, Inc Ms Nancy Kivelson, The Kivelstadt Group

David Paks, P E Senior Civil Enginee~

3150 Bristol Street, Suite 250, Costa Mesa, California 92626 (714) 444-0111 fax (714) 444-0117. wwwlfr. corn

Offices Worldwide

LFR LevineFricke

CON'TENTS

CERTIFICATIO v

EXECUTIVE SUMMARY vii

INTRODUCTION 1

1 1 Site Descriptio 1

1 2 Geology and Hydrogeology 1

BACKGROUND 2

2 , l Previous Investigations 2

2 2 P~evious Treatability Study 4

REMOVAL ACTION OBECTIVE 5

3 1 Applicable or Relevant and App~opriate Requirements and Guidance To Be Considered 5

3 , 1 1 ARARs , , , , , , ,, ,, ,, , , ,, , ,, . ,, , ,, ,, , , . ,, . . , , ,, . . ,, ,. . , , ,. , , ,, , , , ,, , ,, ,, , ,, ,, , , ,, . , , ,, . . 5

3 1 2 TBCs , , , , , , , , , , , , , , , , , , 6

3 2 Removal Action Goals , ,, , ,, , , , , , , , , , , ,, , , , ,, . . . , , , , , , , ,, , , , ,, , , ,, , , ,, ,, ,, , , , , , , , , , , , , 6

REMOVAL ACTION ALTERNATIVE 7

4 1 Site Conditions Related to the Remediation of VOC-Aff'ected Soil and Groundwater , , , ,, ,, , , , , , , , , , , , , , ,, , , , ,, , , , , , , , , , ,, , ,, ,, , ,, , , , , , 7

4 2 Development of Removal Action Alternatives 8

4 2.1 Alternative 1 - No F u ~ t h e ~ Action , . , , . , . ,, , ,, . , , , , . . . , , . , ,, , , , . . . , , 8

4 2 2 Alternative 2 - Passive Biodegradatio 9

4 2 3 Alte~native 3 - Chemical Oxidation ,, . , . ,, , . . , , , , , ,, , , , , , , , , , ,, , ,, ,, , ,, ,, . 9

4 2 4 Alte~native 4 - Excavation, Disposal, and Enhanced Biodegradation ,, , , ,, 9

4 2 5 Alte~native 5 - Pump and Treat , ,, , ,, ,, , ,, , , , , , . , . , , , , , ,, , , , , . . , , ,, , 10

4 3 Evaluation of Removal Action Alternative 10

4 3.1 Alte~native 1 - No fur the^. Action 10

4.3 2 Alte~native 2 - Passive Biodegradatio 11

4 3 3 Alte~native 3 - Chemical Oxidation , , , ,, , , ,, , . ,, , , , . , , , , , . , ,, , , , , , , , ,, ,, 11

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4 .3 4 Alte~native 4 - Excavation, Disposal, and Enhanced Biodegradation ,, ,, . . . , 1 1

4 3 5 Alte~native 5 - Pump and T~.eat , . , . . ,, . , , , ,, . . ,, . ,, ,, . . ,, . . , . . ,, . , ,, . ,, ,, . . , , , , , , 12

5 0 RECOMMENDED REMOVAL ACTION ALTERNATIVE . , . . , , , , , , , ,, . . ,, ,, . , , , , , , ,, 12

5 1 Contingency Alte~native ,, , ,, ,, , ,, , ,, , ,, , ,, ,, ,, . ,, , . ,, ,, ,, . . ,, , ,, . . . . ,, , . , ,, , , , , , ,, , , ,, . ,, ,, , , ,, , , , , . 13

6 0 REMOVAL ACTION IMPLEMENTATION 13

6 , 1 Permitting ,, , . , ,, . , ,, . , . ,, , . , . , . . , . ,, , . , . , ,, . , , . , , . ,, . , . , , , , . ,, ,, . ,, ,, . . , ,, , , . . , , . . , , , , , , ,, ,, . , ,, , . , ,, 13

6 2 Health and Safety P1

6 3 Utilities Clearance

6 4 Excavation and Disposal

6 4 1 Excavation

6 4 2 Disposal

6 5 Enhanced Anaerobic Biodegradation

6 6 Groundwater Monitoring

6 7 Removal Action Completion Rep01

6 8 Califbrnia Environmental Quality Act

7 0 SCHEDULE , , , , , , , , , , , ,, , , ,, , ,, . , , , , , , , , ,, , , , . , . , ,, , . . , . , , , , , ,, , , , , , , , , , , 17

8 0 ADMINISTRATIVE RECORDS LIST ,, , ,, , , , , , , , , 18

8 1 Site-Specific Record 18

8 .2 Regu1ator.y Records 19

8 , 2 1 Federal 19

8 2 2 State, , , , , , , , , , , , , , , , , 19

8 3 Other Records , , , , , , , , , , , , , , , , ,, ,, , , , ,, ,, , ,, ,, , ,, , ,, ,, . ,, , , , ,, ,, , , ,, , , ,, , 20

TABLES

1 Summary of Historical Analytical Results - Soil

2 Summary of Historical Analytical Results - Monitoring Well Samples

3 Summary of Historical Analytical Results - Grab Groundwater Samples

4 Analytical Results - Discrete Depth Groundwater Samples

5 Volatile Organic Compounds Detected in G~oundwatei Samples

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6 Potentially Applicable or Relevant and Appropriate Requirements (ARARs) and To Be Considered (TBCs) Regulations - Federal

7 Potentially Applicable or Relevant and Appropriate Requirements (ARARs) and To Be Considered (TBCs) Regulations - State and Local

FIGURES

1 Site Vicinity

2 Site Location Map

3 Site Plan Showing Monitoring Well Locations

4 P~evious Soil and Groundwater Sampling Locations

5 G~oundwater Sampling Locations

6 Historical PCE Concentrations in Soil above EPA Residential PRGs

7 Excavation Area and Soil Data

8 Graph of VOC Concentrations in MW-1

9 G~aph of VOC Concentxations in MW-2

10 Graph of VOC Concent~ations in MW-10

APPENDICES

A Notice of Exemption

B Responsiveness Summaly

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CERTIFICATION

All hydrogeologic and geologic information, conclusions, and ~ecommendations in this document have been prepzed under the supervision of and reviewed by an LFR Levine Fricke California Registered Geologist

Rodney A CIO Senior P~oject Hydrogeologist Califo~nia Registered Geologist (6869) Califo~nia Certified Hydrogeologist (722)

* A registered geologist's certification of conditions comprises a declaration of his or her p~.ofessional judgment It does not constitute a warranty or guarantee, expressed or implied, nos does it relieve any other party of its responsibility to abide by contract documents, applicable codes, standards, regulations, and ordinances

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EXECUTIVE SUMMARY

The former Mexcury Dry Cleaners facility ("Site") is located at 2714 Pinole Valley Road, at the western edge of the Pinole Valley Shopping Centel, in a mixed ~esidential and commercial area of Pinole, California (Figu~e 1) The Site is zoned for commercial use and is expected to continue to be used as a shoppmg center The Site is bounded to the northwest by a California Department of Transportation (Caltxans) right-of-way (Interstate SO), to the northeast by Pinole Valley Road, to the southwest by Pinole Creek, and to the southeast by adjacent commercial p~operties

Alluvial deposits beneath the Site consist primarily of well-compacted silt and clay with thin lenses of sand and gravelly sand. Groundwater is f i s t encountered at approximately 8 feet below ground surface (bgs) and goes down to about 20 feet bgs (shallow zone) Groundwater is produced mainly from the coarser-grained lenses A deeper, confined aquifer (deep zone) is located directly above the basement rock, at approximately 70 feet bgs,,

Various consultants conducted subsurface environmental investigations at the Site on behalf of Bank of America in 1992, 1994, 1995, 1997, and 1999 LFR Levine Fricke (LFR) took over quarterly groundwater sampling in March 2000 and has continued to the present Currently, 14 shallow monitoring wells, .3 deep wells, and 1 piezometer are used for groundwater monitoring (Figure 4 ) Site investigation results indicated that volatile organic compounds (VOCs), primarily tetrachloroethene 01 perchloroethene (PCE) and its breakdown products, were present in soil and groundwater at the Site

In November 2000 and February 2001, a chemical oxidation pilot study using a potassium permanganate solution was conducted fbr in-situ remediation of contaminants The solution was injected into the vadose and saturated zones of the PCE plume Groundwater sampling results showed that VOC concentrations in groundwater declined directly after injection but gradually ~ebounded to near pre-injection levels,, Soil sampling results showed that VOC concentrations were significantly reduced from the elevated levels detected in p~evious sampling events, and that VOC concentrations in soil were reduced below the U S E,nvironmental Protection Agency's Preliminary Remediation Goals (PRGs) fbr residential land use Soil removal is proposed to reduce the source of contamination in groundwater

This Removal Action Workplan (RAW) was prepared to remediate the groundwater to Maximum Contaminant Levels (MCLs) for d~inking water Five remedial alternatives were evaluated in the RAW: 1) No Further Action; 2) Passive Biodegradation; 3) Chemical Oxidation; 4) Excavation/Disposal and Enhanced Biodegradation; and 5) Groundwater Pump and Treat These alternatives were evaluated against effectiveness, implementability, and cost Alternative 4 is recommended; this involves removing approximately 450 cubic yards of contaminated soils in the source area and treating the groundwater with a hydrogen releasing compound (HRCQ) HRCQ is a patented biodegradable food grade compound used to enhance the growth of microorganisms that destroy organic contaminants

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1.0 INTRODUCTION

On behalf of Bank of Ame~ica Realty Finance, Inc (BARFI), LFR Levine F~icke (LFR) has p~epaxed this document evaluating technologies f o ~ souIce area ~emediation of soil and g~oundwate~ affected by volatile o~ganic compounds (VOCs) at the fo~mei M e ~ c u ~ y D I ~ Cleaners facility, 2714 Pinole Valley Road, Pinole, Califonnia ("the Site"; Figure 1)

1.1 Site Description

The Site is located in the Pinole Valley Shopping Center, in a mixed residential and commercial area of Pinole (Figure 2 ) The Site is zoned for commercial use and is expected to continue to be used as a shopping center. The Site is bounded to the northwest by a California Department of Transportation (Caltrans) right-of-way (Interstate 80), to the northeast by Pinole Valley Road, to the southwest by Pinole Creek, and to the southeast by adjacent commercial properties

The Site is located in the hills of Pinole approximately 1.5 miles from San Pablo Bay, at an elevation of approximately 40 feet above mean sea level (msl) . The shopping center area is relatively flat A steep embankment to the eastbound Interstate 80 off-lamp to Pinole Valley Road lies approximately 35 feet no~th of the Site boundary Pinole Creek flows through an approximately 10-foot-deep gully immediately west of' the Site

The shopping center consists of buildings surrounded by asphalt pavement The fo~mer M e ~ c u ~ y Dry Cleaners occupied the northernmost end space of the cenbal shopping complex Mercu1.y D I ~ Cleaners ope~ated in the Pinole Valley Shopping Center from 1959 to 1993 The location has been vacant since their departuxe

The dry cleaning solvent tetrachlo~oethene (PCE) was the p ~ i m a ~ y chemical used during ope~ations at Me1.cu1.y DIN Cleaners No underground tanks have been ~eported at the Site (Geomatrix, 1997)

In F e b ~ u a ~ y 1989, an anonymous callel filed a complaint with the Contra Costa County Environmental Health Division, stating that Mercu~y Dry Cleaners had left solvent filters outside the back door of the facility The County's follow-up inspection noted that the facility generated ten solvent filters and four gallons of PCE waste per month, which was stored inside the facility Site investigations found soil and g~oundwate~ contamination in a pa~king area near a garbage disposal shed behind the facility, whexe solvent filters had allegedly been discarded

1.2 Geology and Hydrogeology

The Site is located in the Coast Range geomo~phic p~ovince, on the east side of San Pablo Bay The Site is unde~lain by 15 to 70 feet of alluvial deposits above Textia~y-

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age siltstone and mudstone bedmk (Dibblee 1980) The alluvial deposits consist p~imarily of well-compacted silt and clay with thin lenses of sand and g~avelly sand

G~oundwater is f i s t encountered at approximately 8 feet below ground su~face (bgs) and goes down to about 20 feet bgs (shallow zone) G~oundwater is produced mainly from the coxser-grained lenses A deeper, confined aquifer (deep zone) is located di~ectly above the basement ~ o c k , at approximately 70 feet bgs

In the shallow zone, the potentiomehic surface ranges from 31 62 feet above msl in the west (P-I) to 38 57 feet above msl in the no~th (MW-3), as measu~ed in March 2001

Groundwater flows toward the westlnorthwest at an approximate gradient of 0.09 foot per foot (ftlft) There is local influence from Pinole Creek and a freeway culve~t that drains into the creek Data from well MW-8 suggest a potential groundwate~ divide at the northeast corner of the Site The groundwater gradient increases rapidly as it neaI s the creek and culvert. The gravel backfill around the culve~t may divert shallow groundwater flow in this area (Geomatrix 1999)

The deep zone potentiomehic su~face Ianges f ~ o m 33 42 feet above msl in DZ-3 to 37 77 feet above msl in DZ-1 The gradient is 0 02 Wft toward the southwest

BACKGROUND

Previous Investigations

Va~ious consultants have conducted subsu~face envi~onmental investigations at the Site on behalf of Bank of America

In 1992, McLasedHart conducted a limited soil and groundwate~ investigation in the rear of the Mercury D1.y Cleaners facility McLaredHart advanced three soil borings (SB-1, SB-2, and SB-3) near a sanita~y sewer drain and took groundwate~ grab samples (Figure 2) Analytical results showed VOC contamination in both soil and groundwater (Table 1 ) The highest soil concentration (0 3 1 milligrams per kilogram [mglkg] of PCE) was found in SB-I at 5 feet bgs The highest VOC concentration in g~oundwater (1,100 micrograms per liter [pgll] cis-l,2-dichloroethene [cis-1,2-DCE]) was found in SB-1 (McLa~edHart, 1992)

In 1994, McLaredHart installed five groundwater monitoring wells (MW-1, MW-2, MW-3, MW-4, and MW-5) at the Site (Figu~e 3). Analytical results confirmed the presence of VOCs in soil and groundwater (Table 2 ) The highest soil concent~ation (730 mglkg PCE) was found in MW-2 at 5 5 feet bgs The highest VOC concentration in groundwater (27,000 pgll PCE) was in MW-2 (McLaredHart, 1994)

In 1995, McLaredHart advanced 11 soil bo~ings (SB-4 through SB-14). collected 11 g~oundwater grab samples, and installed 3 g~oundwater monito~ing wells (MW-6,

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MW-7, and MW-8) at the Site (Figwe 4). Analytical results confirmed the expanded presence of VOCs in the soil and groundwater The highest soil concentration (079 mglkg PCE) was found in SB-14 at 6 feet bgs (Table 1 ) The highest VOC concentration in groundwater (71,000 pgll PCE) was in MW-2 (Table 2). Soil samples within the dry cleaning facility contained relatively low concentrations of VOCs, indicating that the source of the contamination is not within the facility (McLarenIHart, 1995),,

In 1995 and 1996, Geraghty and Miller and collected eight surface soil samples (HS-1 through HS-8) around monitoring well MW-2, advanced 6 soil borings (B-1 through B6), and installed 2 temporary well points (CTP-I and CTP-2) across 1-80 (Figure 4) The surface soil sampling confirmed the limits of the shallow contamination The highest PCE concentrations were detected at boring B-4 (Figure 6); PCE was detected at 920 mglkg in soil at 6 feet bgs (Table 1) Only 1,2-DCA (0 64 pgll at CTP-I) was detected in groundwater samples from the temporary well points (Table 3)

In 1997, Geomatrix Consultants, Inc (Geomatrix) investigated the lateral and horizontal extent ofthe VOC plume, and modeled the surface and groundwater flow patterns of the Site and nearby properties. Six soil borings (S-1 through S-6) were advanced in the Caltrans right-of-way, and depth-discrete groundwater samples were collected from nine locations (CPT-I through CPT-9) at and in the vicinity ofthe Site (Figures 4 and 5 ) Groundwater was determined to be flowing to the southwest with a slight vertical gradient in the vicinity of well DZ-1 (Geomatrix, 1997) The ground surface of the Caltrans property (unpaved) slopes away from Pinole Cr.eek At the time of this investigation, Pinole Creek was a losing stream

The investigation results indicated that VOCs in groundwater are confined primarily to depths of less than 20 feet bgs The maximum VOC concentrations in the deep zone were detected in CPT-I (located approximately 50 feet f ~ o m MW-2) at60 feet bgi>, PCE, TCE, and cis-1,2 DCE concentrations were 16 pgll, 4 8 pgll, and4 pgll, respectively (Table 4) The vertical and lateral extent of VOCs in groundwater was fbund to be limited PCE and TCE were found 500 feet west of Pinole Creek (CPT-5) at concentrations of31 pgll and 2 9 pg/l, respectively (Table 4) No VOCs were fbund west-southwest of the Site up to 900 feet distant, and no VOCs were detected in groundwater collected north of 1-80

In May 1999, Geomatrix collected four hydropunch grab groundwater samples (G-1 through G-4), took surface water elevations from Pinole Creek, and installed two shallow wells (MW-9 and MW-lo), two deep wells (DZ-2 and DZ-3), and a piezometer (P-I) at boring G-l (Figure 3) Results showed that groundwater is diverted due to the gravel backfill around the freeway culvert of Pinole Creek Deep groundwater was not significantly affected by VOCs,

In September 1999, Geomatrix collected creek water samples upstream, adjacent and downstream of the Site (UC, MC, DC), and installed two wells along Pinole Creek (MP-1 and MP-2) to observe the amount of VOCs entering the creek (Figure 5 ) VOCs were not detected in the stream samples Analytical results fbr initial and subsequent

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quarterly sampling showed no detectable VOCs in either of the two wells (Table 5) The hydraulic evaluation indicated that at the time of the investigation, water in the creek was recharging groundwater,,

LFR took over quarterly groundwater sampling in March 2000 and has continued to the pIesent. Currently, 14 shallow monitoring wells, 3 deep wells, and 1 piezometer are used for groundwater monitoring (Figwe 3 ) Table 5 summarizes recent groundwater monitoring results,,

The results of previous site investigations indicated that detectable concentrations of PCE and its breakdown products (TCE, cis- 1,2-DCE, trans-l,2-dichloroethene [trans-1,2-.DCE], 1,1,2-trichloroethane [I, 1,2-TCA], chlorobenzene, 1,1,2,2-tetrachloroethane [I, 1,2,2-PCA], 1,4-dichlorobenzene [1,4-DCB], vinyl chloride WC] , and 1,2-dichloroethane [I ,2-DCA]) are present in soil and groundwater at the Site,,

The highest PCE concentrations detected at the Site were 920 mglkg in soil (B-4, June 1996; Figure 4) and 110,000 pgll in g~oundwater (MW-2, .June 1999) The recent shallow zone groundwater sample fiom well MW-2 (September 2001) showed concentrations of PCE, TCE, and cis-1,2-DCE) at 27,000 pgll, 14,000 pgll, and 7,800 pgll, respectively The highest VOC concentrations in deep zone groundwater samples weIe detected in DZ-2 VOCs were not detected in DZ-1 (Table 5)

The highest VOC concentrations were detected at and within approximately 25 feet of well MW-2, at depths of approximately 1 foot to 20 feet bgs This area, where chemicals may have been released to the vadose (unsaturated) zone and constitute a source of chemicals to groundwater, is referred to as the Source Area

2.2 Previous Treatability Study

Under the auspices of the Department of Toxic Substances Control (DTSC), BARF1 retained LFR to conduct a treatability study at the Site using potassium permanganate (KMn04) as an in-situ oxidizer of organic chemicals

During the months of' November 2000 and February 2001, a 5 percent potassium permanganate solution was injected into the vadose and saturated zones of the PCE plume. Approximately 3,800 gallons of permanganate solution (1,600 pounds of permanganate) was injected at 121 locations during the two injection events, at pressures of up to 1,000 psi Injection zones ranged from 2 to 20 feet bgs

The ~ i l o t test was centered on monitor in^ well MW-2. which is centered in the main - source area The permanganate was injected at four different g~ids of 2 5 , 5, 7 5, and 10 feet In addition, permanganate was injected in downgradient locations that specifically targeted the saturated zone Direct evidence of the radius of influence of these injection wells was observed only in the 2 5-foot grid, where injected permanganate was flowing out of p~.eviously injected points

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Groundwater monitoring results showed that VOC concentrations in groundwater declined directly after injection but gradually rebounded to near pre-injection amounts,, VOC concentrations in MW-2 showed a significant reduction of PCE, with a correspondiig increase in TCE and cis-1,2-DCE,,

Mode~ate increases in alkalinity and chlo~ides were noted Significant inc~eases in manganese concenhations were most likely the result of solid MnOz particles in the unfiltered groundwater samples Hexavalent chromium was detected in only one sample di~ectiy afte~ the first injection at a concentration of 50 pgll, but quickly returned to non-detectable levels

Soil sampling results showed that VOC concentrations were significantly reduced f ~ o m the elevated levels detected in p~evious sampling events, and that VOC concentrations in soil have been reduced below the residential p~eliminaxy remediation goals (PRGs) and the land disposal aeatment standards Figwe 7 summa~izes the analytical results for the soil samples collected after the treatment

REMOVAL AC,TION OBJECTIVE

Applicable or Relevant and Appropriate Requirements and Guidance To Be Considered

The emo oval action will comply with relevant p~omulgated federal, state, and local requirements, criteria, guidance, and standa~ds These envi~onmental and public health ~equirements fall into two geneIal categoIies:

requirements that aIe potentially applicable or relevant and approp~iate

criteria, adviso~ies, guidance, and standards that are to be considered

Applicable 01 ~elevant and approp~iate ~equuements aIe called ARARs; othe~ cr iteria and standa~ds aIe refer~ed to as TBCs (to be conside~ed)

3.1.1 ARARs

ARARs fall into three general categories: chemical-specific, action-specific, and location-specific

Chemical-specific ARARs are health- or risk-based concentration limits that ale established for a specific chemical in a specific medium (typically groundwater, soil, surface water or air) Chemical-specific ARARs represent the acceptable concentration of a chemical that may be found in or discharged to the ambient environment,

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Action-specific ARARs are technology-based requirements that establish how to perform a specific action These ARARs either restrict or direct specific types of remedial or waste management activities

Location-specific ARARs are requirements that either restrict or direct certain activities at cextain locations

Chernical-specific ARARs and risk assessment methods are used to establish remedial cleanup levels, whereas action-specific and location-specific ARARs are used to evaluate remedial alternatives. The ARARs that were identified fox. the Site are summarized in Table 6

3.1.2 TBCs

In addition to promulgated laws and ~egulations, federal and state agencies develop various guidance, criteria, and advisories that can provide useful info~mation or procedures The TBCs that were identified for the Site are presented in Tables 6 and 7

3.2 Removal Action Goals

The goal of the removal action is to achieve risk levels for soil that are acceptable for unrestricted or residential land use, and risk levels for groundwate~ that are acceptable for domestic consumption The U S Environmental Protection Agency (U S EPA) and DTSC consider acceptable levels of risk to be a hazard index of 1 for noncarcinogenic health effects and an excess cancer risk of 1x10" to lx104 for carcinogenic health effects Residential cleanup standards for soil consider exposure to chemicals in soil via incidental ingestion, dermal contact, and inhalation of vapors or suspended particulates by both children and adults

For the purposes of this Removal Action Workplan, the removal action objective is to remediate the Site such that the contaminant concentrations in soil after remediation result in a residual risk of less than the noncancer hazard index of 1 and less than an excess cancer ~ i s k of 3x106 This objective will be achieved by removing soils and treating groundwater to achieve the following removal action goals for each chemical contaminant The groundwater removal action goals are based on the Maximum Contaminant Levels (MCLs) for drinking water

Chemical Groundwater

Cis-1 2-Dich101,oe

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I Vinyl Chloride I 1 0.5 I

4.0 REMOVAL AC,TlON ALTERNATIVES

4.1 Site Conditions Related to the Remediation of VOC-Affected Soil and Groundwater

Based on site-specific field and analytical data presented in Geomat~ix's Decembe~ 1997 and May 1999 IepoIts, as well as LFR's Pe~manganate T~eatability Study and Janua~y 2001 qua~te~ly g~oundwate~ sampling IepoIt, the following conditions aIe pIesent at the Site:

Boring logs show that soil at the Site is predominantly a very stiff clay from the ground su~face to approximately 20 feet bgs. Within this clay are thin (< 1 foot) layers of sand to sandy clay that produce water below approximately 10 feet bgs

Analytical results indicate that g1,oundwater and soil at the Site contain PCE and its degradation products The source of contamination is within a 10- to 20-hot radius around monitoring well MW-2

Analytical results for the most soil samples collected at the Site (Feb~uary 27, 2001) indicate that PCE and its degradation p~oducts ale present at concennations up to 2 03 mglkg in the vicinity of MW-2

The pIesence of PCE degradation products (TCE, cis-1,2-DCE, trans-1,2-DCE, 1,1,2-TCA, 1,1,2,2-PCA, 1,4-DCB, VC, and 1,2-DCA) in groundwate~ samples indicates that reductive dechlorination of PCE is occu~ring at the Site

The direction of shallow groundwater flow in the Site vicinity is p~irna~ily to the west, with a horizontal hydraulic g~adient of app~oximately 0 09 ftlft Hydraulic conductivity values were estimated to be 0 3 h o t per day (ftlday) fbr the shallow water-bearing zone and 0 0003 ftlday f o ~ the vadose zone (Freeze and Cherry, 1979) Using a horizontal hydraulic g~adient of 0 09 ftlft, average hydraulic conductivities o f 0 3 ftlday and 0 0003 ftlday, and an estimated effective po~osity of 0 30, the average flow velocity is approximately 33 feet per yea1 for groundwater and approximately 0 0 3 foot pel year for soil

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Concenhations of PCE and its degradation products decrease in groundwater downgradient f ~ o m the source area Concentrations of PCE in March 2001 ranged from 20,000 pgll in samples collected from well MW-2, which is located approximately in the source area, to 0 018 pgll in samples collected from well MW-10, which is located approximately 170 feet west (downgradient) from the suspected source area

Soil with VOC concentrations above the MCLs for groundwater is a continuing source of groundwater contamination

4.2 Development of Removal Action Alternatives

An "Interim Evaluation of Remedial Technologies" for the Site was submitted to the DTSC on June 19, 2000 This report reflects the conditions now evident at the Site after the Treatability Study and subsequent sampling. The following factors were used to evaluate the feasibility of soil and g1,oundwater remediation alternatives for the Site:

Effectiveness - ability of the technology to handle affected media at the Site; long-term effectiveness and reliability of the process; and potential effects on human health and the environment during implementation

0 implementability - availability of technology; availability of materials, equipment, and labor; short- and long-term materials, storage, and disposal considerations; operation and maintenance considerations; and permitting considerations

Cost - relative capital and operation and maintenance costs

Remediation of VOC-affected soil and groundwater at the Site can be achieved by the following methods:

no further action

in situ passive biodegradation

in situ enhanced biodegradation

in situ chemical oxidation

excavation and disposal

pump and weat

These alternatives are discussed separately in the following sections

4.2.1 Alternative 1 - No Further Action

The No Further Action alternative is used as a baseline for evaluating the effectiveness, implementability, and cost of other alternatives The No Further Action scenario would

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have BARF1 forego any futher cleanup or monitoring effo~ts at the Site. Remaining chemical concentrations would gradually be reduced over an extended period of time by naturally occurring mechanisms,,

4.2.2 Alternative 2 - Passive Biodegradation

Passive biodegradation involves naturally occurring anaerobic microbes that can dechlorinate the chemicals of concern Evidence that this is occur~ing is seen by the presence of daughter p~.oducts of dechlorinated P C E PCE (four chlorine atoms) degrades to TCE (three chlorine atoms), then to several types of DCE (two chlorine atoms), and then to vinyl chlo~ide (one chlorine atom) All these chemicals are found in groundwater at the Site Graphs of groundwater quality in various wells (Figures 8, 9, and 10) show that total concentrations of these compounds are lessening over time The sample results also illustrate the increase of daughter products as the distance fiom the soulce area increases Passive biodegradation can be extremely cost effective for sites that show no plume migration, and where the length of remediation time is not critical Under the passive biodegradation scenario, the current quarte~ly groundwater monitoring program at the Site (including yearly analysis of biodegradation parameters) would continue,,

4.2.3 Alternative 3 - CIhemical Oxidation

Chemical oxidation involves injecting an oxidizing agent (in this case potassium permanganate [KMnOd]) into the subsurface, where it will break down the target chemicals As explained in Section 2 1, this technology can quickly des&oy dissolved-phase compounds, but the dense nonaqueous phase liquid (DNAPL) or liquid-phase chemicals are much harder to degrade Repeated injections in the source area and around the groundwater plume would be required to remove the problem compounds However, since this technology relies on direct contact, which the fine- grained nature of the aquifer materials would make difficult, it would take numerous injections to reduce the chemicals to acceptable levels

4.2.4 Alternative 4 - Excavation, Disposal, and Enhanced Biodegradation

Excavation and disposal is a widely used technique for removing shallow areas of impacted soils, particularly when remediation time is limited A compact excavation area, low disposal costs, and limited impact on nearby infrastructure and tenants are usually the main factors to be considered when excavating The impacted soil at the Site appears to be present at the 1- to 20-foot depth interval, and in a relatively small area around MW-2 (Figure 6 ) Soil borings have shown that soil at the Site is predominately a very stiff to hard clay that can be excavated without shoring Analysis of soil samples collected during the Treatability Study r.evealed that chemical concentrations have been greatly reduced and are cur~ently below the land disposal txeatment standards, which greatly decreases the cost fbr disposal Excavation would reduce the source of the groundwater contamination but would not di~ectly address the rest of the plume

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LFR LevineFricke

Enhanced biodegradation is a process by which biodegradation is stimulated by the delivery of nutrient to chemically affected groundwater. This process is designed to maximize biodegradation of compounds that can be anaerobically metabolized The technology utilizes injection wells or points to deliver the nutrient to naturally occur~ing microorganisms that are already biodegrading the chemicals. As explained in Section 4.1, there is indication of' a healthy population of' these microbes already metabolizing the chemicals at the Site. An application of nutrient could greatly increase the observed degradation rates However, because of the possible presence of DNAPL at the Site, it might take two to three years or more of monitoring and repeat injections before concentrations of chemicals in the groundwater are below the removal action goals for groundwater

During the backfilling of the excavation, a nutrient or hydrogen releasing compound (HRCa) would be added to drain rock placed in the excavation below the water table This would ensure that groundwater in this area would quickly return to anaerobic conditions, and that the downgradient VOC plume would start to shrink If the HRC" treatment in the excavation will not be effective, HRCa or similar product would be injected across the plume area A grid of 10-foot centers across the Site would equal 144 injection points We assume that HRCa would be injected twice in one year, followed by monitoring,,

4.2.5 Alternative 5 - Pump and Treat

Pump and neat technology consists of extracting the groundwater and treating it before disposing of it through municipal sewe1.s or storm drains. The most widely used treatment is filtering the groundwater through activated carbon to remove organic chemicals This technology is good for homogeneous aquifers with high hydraulic conductivity and no suspected DNAPL

4.3 Evaluation of Removal Action Alternatives

4.3.1 Alternative 1 - No Further Action

This method would abandon all the monitoring wells and return the Site to its pre-existing condition

Effectiveness: Low to mode~ate chance of long-te~m ~emediation of compounds of concern

Implementability: Very easy to implement Because this alternative requires no further work at the Site, it is technically implementable

C:ost: Approximately $20,000

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4.3.2 Alternative 2 - Passive Biodegradation

This alternative would continue the cwrent quarterly groundwater monitoring program at the Site, which includes yearly analysis of biodegradation parameters

Effectiveness: Mode~.ate chance of long-te~m remediation of compounds of concern,,

Implementability: Very easy to implement

Cost: Approximately $220,000,

4.3.3 Alternative 3 - Chemical Oxidation

This method would ~equire the ~epeated injection of permanganate a~ound and in the soulce area, until VOC concent~ations have been permanently reduced Groundwate~ sampling between each injection would be required, with analysis of chemical oxidation parameters besides VOCs Semi-pe~manent injection points would be installed, and pesmanganate solution would be injected once each month for six months Groundwater monitoring would continue for one year after injection, after which time the monitoring wells would be abandoned

Effectiveness: Moderate to good chance of expedited ~emediation of compounds of conceIn

Implementability: Moderately difficult to implement A push-type d~illing ~ i g and attendant pumps and mixing equipment will be needed to get around the Site Entails some dis~uption of deliveries to businesses in the shopping cente1, and co~doning the w o ~ k area off f ~ o m the public

C:ost: Approximately $270,000

4.3.4 Alternative 4 - Excavation, Disposal, and Enhanced Biodegradation

This method would require the excavation and disposal of approximately 450 cubic yards (cy) 01 700 tons of RCRA-listed soil, the impo~ting and placement of approximately 500 cy of clean soil as backfill, and the addition of approximately 3,000 pounds of HRC" to the backfill We are also assuming that 1 to 2 years of additional groundwater monitoring would be required, followed by well abandonment If the treatment in the excavation does not reduce the contaminant concentrations in groundwater to emo oval action goals, HRC" or other similar products would be injected across the plume area A grid of' 10-foot centers would equal 144 injection points, assuming that HRC" would be injected twice in one year

Effectiveness: Good to excellent chance of expedited remediation of compounds of concern,

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Implementability: Low difficulty to implement Soil removal and replacement is readily implementable Excavation and backfilling are commonly performed, and subcontractors and equipment are readiiy available. The excavation and equipment will disrupt all deliveries to the extreme west side of the shopping center Truck traffic delivering and hauling soil will also cause traffic problems within the shopping center. The work site will be cordoned off with a temporary fence, and the public will be denied access to the area

Cost: The cost of soil excavation, disposal, and initial HRC" treatment is approximately $300,000 The cost of the HRC@ injection across the plume area, including g~oundwater monitoring, is app~oximately $360,000

4.3.5 Alternative 5 - Pump and Treat

This technology would require the installation of up to 20 groundwater extraction wells and subsurface piping, and construction of a pumping and treatment facility Since the materials underlying the Site are composed mainly of compacted clay, the radius of influence of the pumping wells would be small

Effectiveness: Low to moderate chance of long-term remediation of compounds of concern Groundwater pumping and air sparging technologies may not be effective for the Site because of the predominantly fie-g~.ained materials that underlie the Site

Implementability: Moderate difficulty to implement The installation of the extraction wells and subsurface piping will disrupt deliveries and traffic on the west side of the shopping center The extraction and treatment equipment will require maintenance and can be expected to be on site fbr 5 to 20 years

Cost: Approximately $1,000,000

5.0 RECOMMENDED REMOVAL ACTION ALTERNATIVE

Based on site-specific data and the preceding discussion, Alternative 4 - Excavation, Disposal, and Enhanced Biodegradation has been selected as the best removal action alternative for the Site This selection was made for the following reasons:

Excavation is a sure way of quickly removing impacted soil that may be a source of fwther g~oundwater contamination

Site conditions are amenable to this type of remediation The contamination is shallow and localized

The costs for disposal of the impacted soil are reasonable

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Biodegradation is already occur~ing at the Site, and has been shown to be effective in removing chemical mass

This alternative will involve less operation and maintenance, since it does not require a pumping and treatment facility

Contingency Alternative

If the proposed remedial alternative cannot meet the removal action goals for groundwater, a groundwater pump and treatment method will be evaluated subject to DTSC approval and environmental review,,

REMOVAL ACTION IMPLEMENTATION

Permitting

All appropriate permits will be acquired before excavation begins The City of Pinole requires an excavation permit The County of Contra Costa Department of Environmental Health requires a well destruction and installation permit The Bay Area Air Quality Management District (BAAQMD) requires a pe~mit or notification for soil excavation and stockpiling Access to the Caltrans right-of-way has to be obtained fbr excavation, treatment, and well sampling

Health and Safety Plan

LFR will prepare a site-specific Health and Safety Plan (HSP) in accordance with applicable federal and state regulations (29 CFR 1910 120 and 8 CCR 5192, respectively) The HSP will be reviewed and approved by an LFR Ce~tified Industrial Hygienist before beginning the field activities outlined in this workplan The HSP will address the potential fbr exposure to hazardous constituents, as well as delineate the general safety procedures that are required fo~ . the safe opelation of mechanical equipment to be used while conducting field operations at the Site

Utilities Clearance

The excavation subcontractor will contact Underground Service Alert prior to conducting drilling activities at the Site, as required by law LFR will also subcontract a private underground utility locator to assist in the clearance of the proposed excavation or injection locations

0020774160.12 Mercury Removal Action WP dac:CS Page 13

LFR LevineFricke

6.4 Excavation and Disposal

6.4.1 Excavation

The proposed excavation area will be centered on monitoring well MW-2 (Figure 6 ) Dimensions of the proposed excavation are 30 feet by 20 feet by 20 feet deep Groundwater at the Site occu~s at approximately 10 feet bgs, and the contaminated aquifer extends another 10 feet (to 20 feet bgs) P r e l i m b y assessment by an LFR geotechnical engineer indicates that shoring will not be needed The nearest structures are the mall, which 1s located about 20 feet southeast of the proposed excavation, and the freeway off-lamp, which is located about 50 feet northwest of the proposed excavation

All the excavated soil (approximately 450 cy) will be shipped off-s~te to a permitted disposal facility The soil will be temporarily stockpiled near the edge of the excavation so water may drain back into the excavation We assume there will be very slow dischaxge of groundwater into the excavation If groundwater becomes a problem, the groundwater will be pumped out of the excavation to a holding tank@) for shipment to a permitted disposal facility The water will be analyzed and profiled for proper shipment and disposal procedure

The backfill will consist of 1-inch gravel (crushed virgin rock) to 1 foot above the water table A porous geomemb~ane will be placed on top ofthe gravel This membrane will be covered by compacted soil fill, and the surface will be completed to match the existing area The soil fill will be analyzed for total petroleum hydrocarbons (TPH), VOCs, semivolatile organic compounds (SVOCs), California Assessment Manual (CAM) metals, pesticides, and polychlorinated biphenyls (PCBs) prior to use to ensure it is free of contaminants

6.4.1.1 Air Monitoring Plan

All VOC and dust emissions will be monitored during excavation and loading activities Elevated VOC emissions will be suppressed by covering the soil with plastic,, Dust will be suppressed by water spray All applicable permits will be obtained by the excavation subcontractor, and emission monitoring and recording will be performed by LFR Excavation and stockpiling activities will be conducted in accordance with the BAAQMD's requirements under Regulation 6 (Particle Matter and Visible Emissions) and Regulation 8, Rule 40 (Aeration of Contaminated Soil and Removal of Underground Storage Tanks) The Health and Safety Plan will detail the air monitoring procedure that will be followed during the excavation or remediation at the Site

6.4.1.2 Confirmation Sampling

Sidewall and bottom confiumation samples will be collected after the excavation is complete Sixteen samples will be collected in a grid pattern The sidewall samples will

Page 14 M2-OT141.W-12 Mercury Removal Action WP doc:^^

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be collected at an approximate depth of 12 feet Since the walls of the excavation w ~ l l not be sho~ed, all confiImation samples will be collected using the excavator bucket Samples will be taken from the soil in the bucket and placed in laborato~y-weighed, methanol-filled VOA vials or simila technology The sample1 will be cleaned with laboratory-g~ade soap and ~insed with de-ionized 01 distilled wateI between sampling points

The sample containe~s will then be sealed, labeled, and placed in a chilled cooler pending delive~y to the analytical labo~ato~y These samples will be taken to a Califo~nia-ce~tified labo~atory unde~ st~ict chain-of-custody documentation and analyzed f o ~ VOCs using EPA Method 8260 If necessaIy, backfilling of the excavation will be delayed pending ~eceipt of analytical ~esults

6.4.1.3 Quality Assurance/Quaiity Control

Duplicates of two confirmation soil samples (or 10 percent, whichever is more) will be submitted to the primary laborator'y under different names to monitor the reproducibility of the analytical results

6.4.2 Disposal

As mentioned above, we expect that all excavated soil will be shipped of-site fbr disposal Soils with contaminant concentrations above the land disposal treatment standards must be treated to meet the standards befbre the soils can be disposed of at a permitted disposal facility Since recent analytical data have shown that total VOC concentrations in soil are below the land disposal treatment standards, we anticipate manifesting the soil as RCRA hazardous waste that already meets treatment standards The waste facility will prepare hazardous waste manifests that will be signed prior to transport off-site

All necessary safety requirements will be met during loading Soil will be dewatered before being transported off-site Any air pollution monitoring requi~ements will be met during excavation The amount of water that will be in the excavation is not known However, we do not anticipate the need to dewater the excavation, since it will be backfilled with gravel

6.42.7 Transportafion Plan

Excavated soil will be transpo~.ted to Chemical Waste Management's Kettleman Hills Class I treatment and disposal facility in Kettleman City, Califbrnia (888-543-9646), using 20-ton end-dump trucks. Approximately 30 dump t~ucks will be loaded in back of the Pinole Shopping Center, out of traffic right-of:.ways The trucks will exit the shopping center onto Pinole Valley Road, and will then travel 0 2 5 mile west befo~e merging onto the northbound Interstate 80 The trucks will travel north on Interstate 80 fbr 4 miles before merging with the eastbound SR-4 The trucks will travel east 12 miles to Interstate 680, and then go south 23 miles to Interstate 580 The trucks will

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LFR Levin~Fricke

then aavel30 miles east to Interstate 5, 137 miles south to the Gafiey Road exit, and 2 miles east to Kettleman City

If an event or accident results in the spillage of soil fiom a truck, the driver will first contact the appropriate accident response personnel, police or medical personnel, if needed. These can be reached by calling 91 1 ,, The driver will also secure the event or accident scene with traffic cones or caution tape to keep the public away from the spilled soil The driver will then call the project health and safety officer or the project manager These individuals will be identified in the Health and Safety Plan and at the start of the field construction activities. The driver will stay in the truck until law enforcement or other assistance arrives All drivers will be provided with a copy of the Health and Safety Plan, which contains detailed instructions on emergency p~ocedures as well as the telephone numbers of emergency personnel, the health and safety officer, and the project manager

6.5 Enhanced Anaerobic Biodegradation

Regenesis Bioremediation Products of San Clemente, Califbrnia, developed Hydrogen Release Compound" (HRC"), a patented biodegradable food-grade polymer, to enhance the microbial anaerobic reductive dechlorination of chlorinated solvents in groundwater Reductive dechlorination is a process by which chloride ions atoms are progressively removed from PCE or substituted for two electrons and a hydrogen ion (for each substitution), yielding TCE, then cis-DCE, then vinyl chloride, then ethane Ethane is further converted to carbon dioxide and watel. It is a naturally occurring process mediated by microorganisms Ultimately, the result of the microbial action is the conversion of hazardous chlorinated solvent molecules to methane, carbon dioxide, and hydrogen chloride

HRC" consists of a benign polylactate ester specially formulated fbr the slow release of lactic acid (an organic acid) upon hydration When HRC" is introduced into the aquifer, the water hydrates the ester linkage and releases the polylactic acid complex, which in turn become lactic acid molecules When the lactic acid is released, indigenous anaerobic microbes can fe~ment it, converting it to several other o~ganic acids and producing hydrogen. The resulting hydrogen can be used by reductive dehalogenating mic~oorganisms, which are capable of dechlorinating the contaminants This occurs as a moderately slow process, depending on the size and nature of the microbial population in the vicinity of the application, and can facilitate anaerobic remediation fbr an extended time

HRCm is usually added to the subsurface by injection though geoprobe-like push rods However, we plan to coat the gravel backfill with HRCa as we backfill the saturated zone ofthe proposed excavation. The coated g~avel will serve two purposes: it will ensure that any water left in the excavation will be anaerobic, and it will provide hydrogen for the continued dechlorination of the rest of the plume HRCa will maintain anaerobic conditions in the aquifer throughout treatment, and favors ~eductive dechlorination over competing methanogenic activity

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Groundwater Monitoring

Quarterly groundwater monitoring at the Site will continue following the soil excavation The CUII ent groundwater monitor ing program includes sampling ten shallow wells (MW-2, MW-4, MW-5, MW-6, MW-7, MW-8, MW-9, MW-10, MP-I, and MP-2) and three deeper wells (DZ-1, DZ-2, and DZ-3) Groundwater samples are analyzed for VOCs; additional samples are obtained annually and analyzed for biodegradation parameters Quarterly groundwater monitoring repor ts are submitted every April, July, October , and January

A new monitoring well will be installed to ~eplace MW-2, which will have been destxoyed Monitoring well MW-I 1 will be included in the monitoring schedule This well was installed during the txeatability study and is located directly downgradient from the excavation

After one year, if conditions indicate that natural attenuation is occurring, BARF1 will request that the DTSC review the Site and, if cleanup goals have been achieved, issue a finding for site closure and permit the abandonment of all wells Groundwater monito~.ing reports will continue to be published until closure f o ~ the Site is granted, or as directed by DTSC

Removal Action Completion Report

An excavation Ieport will be published within two months of completing the excavation activities at the Slte This 1epor.t will include a discussion of the excavation, soil sampling, and backfill procedu~es, analytical results, soil and groundwater disposal, HRCB application, groundwater ~emediation, and site resto~ation

California Environmental Quality Act

In accordance with the California Environmental Quality Act (CEQA), DTSC has evaluated the cleanup project fbr the Site to determine any potential adve~se environmental impacts DTSC found no negative impacts from the proposed cleanup plan DTSC has determined that the proposed removal action is exempt from CEQA and would have no impact on the environment due to the small volume of soil, the limited area, and the short duration of'the project Therefbre, DTSC has prepared a Notice of' Exemption for the project in compliance with CEQA

SCHEDULE

The Draft RAW will undergo a 30-day public comment period Comments on the Draft RAW will be incorporated in the Final RAW A schedule f o ~ the project following DTSC approval of the Draft RAW is presented below:

WZM74ld0-12 Mercury Removal Action WP doc:CS Page 17

LFR Levine.Fricke

comment pe~iod on the D~aft RAW - one month

Final RAWIResponsiveness Summary - two weeks

DTSC ~eview - two weeks

RAW implementation - two months

Removal Action Completion Rep01.t - two months

It should be noted that this schedule is only tentative; it may be extended for any numbe~ of' reasons

8.0 ADMINISTRATIVE RECORDS LIST

8.1 Site-Specific Records

LFR LevineF1,icke. 2001a Final Report Potassium Permanganate Treatability Study, Fo~mer Mercury Dry Cleaners Site, 2714 Pinole Valley Road, Pinole, California June,.

LFR LevineFricke 2001b Progress Report and Re-injection Work Plan f b ~ Potassium Pe~manganate Treatability Study for Source Area Remediation, Former Mercury Dry Cleane~s, Pinole, Califo~nia January

LFR Levine Fricke 2000. Revised Work Plan for a T~eatablility Study f o ~ Source Ar.ea Remediation, Former Me~cury Dry Cleaners, 2714 Pinole Valley Road, Pinole, Calif01.Na August

Geomatxix Consultants, Inc 1999a Monito~ing Point Installation and Quarte~ly Monito~ing Repo~t, July to Septembe~ 1999, Forme1 M e ~ c u ~ y D I ~ Cleane~s, Pinole. Califo~Na Octobe~

Geomatrix Consultants, Inc 1999b Results of Additional Investigation, Forme1 M e ~ c u y D I ~ Cleane~s, 2714 Pinole Valley Road, Pinole, Califo~nia May

Geomatrix Consultants, Inc 1997 Repo~t of Soil and G~oundwate~ Investigation Findings, F o ~ m e ~ M e ~ c u ~ y Dxy Cleane~s, 2714 Pinole Valley Road, Pinole California Decembe~

Ge~aghty and Miller 1996 Letter Repo~t Summarizing Tempo~a~y Well Sampling and Deep Well Installation at Pinole Valley Shopping Cente~ ( F o ~ m e ~ Me~cury D I ~ Cleane~s), 2714 Pinole Valley Road, Pinole Califo~nia Decembe~

Geraghty and Mille~ 1996 Amended Removal Action Wo~kplan f o ~ Soil Excavation, Forme1 Mercwy D I ~ Cleane~s, 2714 Pinole Valley Road, Pinole, Califo~nia September

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McLaredHart 1995. Additional Site Investigation at the Former Mercury Dry Cleaners Facility, 2714 Pinole Valley Road, Pinole, California. Septembex

McLaredHat. 1994. Results of Phase 11 Soil and Groundwater Investigation at the Former Mercu~y Dry Cleaners Located at 2714 Pinole Valley Road in Pinole, California June

McLaredHart 1992 Results of Agency Resea~ch and Phase I1 Soil and Groundwater Sampling and Analysis at M e ~ c u ~ y Dry Cleane~s, 2714 Pinole Valley Road in Pinole, California Octobe~

Versa1 1989 Ropexty T~ansfei Assessment, Pinole Valley Shopping Cente~, Pinole Valley Road, Pinole, California August

8.2 Regulatory Records

8.2.1 Federal

Clean Water Act (CWA), 33 U S C sd1251 et seq (1977)

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund), 42 U S C s/s 9601 et seq (1980)

Occupational Safety and Health Act (OSHA), 29 U S C . 651 et seq (1970)

Resource Conservation and Recovery Act (RCRA), 42 U S C sis 321 et seq (1976)

Toxic Substances Control Act (TSCA), 15 U S C s/s 2601 et seq (1976)

8.2.2 State

8.2.2.1 Health and Safety Code

CHAPTER 6.5. HAZARDOUS WASTE CONTROL

CHAPTER 6.6. SAFE DRINKING WATE,R AND TOXIC ENFORCE,MENT ACT OF 1986

CHAPTER 6..65. UNIFIED AGENCY REVIEW OF HAZARDOUS MATERIALS RELEASE SITES

CHAPTER 6..66. OVERSIGHT COSTS

CHAPTER 6.85. CALIFORNIA EXPEDITED REMEDIAL ACTION REFORM ACT OF 1994

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LFR LevineFricke

CHAPTER 6.9. LIABILITY FOR ABATEMENT OF HAZARDS

8.2.2.2 California Civil Code

DMSION 2: Property

PART 2: Real or Immovable hoperty

TITLE 3: Rights and Obligations of Owners

CHAPTER 3: Environmental Responsibility Acceptance Act

SECTION: 850 - 851

8.2.2.3 California Environmental Qualify Act

Statutory References

Statuto~y Exemptions Listed I Public Resouxces Code @21080 - 21080.33

Categorical Exemptions Defined I Public Resou~ces Code 521084

Addition 01 Deletion of Exempt Categories I Public Resources Code $21086

Guideline References

Catego~ical Exemptions 1 14 Califo~nia Code of Regulations §§15300 - 15329

Catego~ical Exempt~ons Defined / 14 Califoxnia Code of Re,gulations $15354

8.3 Other Records

Koenigsbe~g, Stephen S and Craig A Sandefur 1999 The Use of Hydrogen Releasing Compound fbr the Accelerated Bioremediation of Anaerobically Degradable Contaminants: The Advent of Time-Release Electxon Donor's

Page 20 Mn4774lMI-I2 Mercury Removal Action WP doc:CS

Table 1 Page 1 of 2

11 5

MW-2 24-Mar-94 5 5 12

MW-3 24-Mar-94 5 5

11 5

MW-4 25-Mar-94 6 5

12

MW-5 24-Mar-94 7 0

14 5 ~ ------ - - ~~

MW-6 25-Jul-95 5 5

10 5 ~~ .~ ~.~

MW-7 25-Jul-95 5 5 -

MW-8 25-Jul-95 5 5

1 0 5 - ~

SB-I 23-Jul-92 5 0

Summary of Historical Analytical ~esults' - Soil Former Mercury Dry Cleaners

2417 Pinole Valley Road Pinole, California

Concentrations in milligrams per kilogram (mg/kg)

Well Number

Date Sampled

Sample Depth (ft)

PCE TCE cis-1.2-DCE trans-1,2-DCE OTHER

Table I Summary of Historical Analytical Results - Soil

Former Mercury Dry Cleaners 2417 Pinole Valley Road

Pinole, California Concentrations in milligrams per kilogram (mglig)

Page 2 of 2

B-I 24-Jun-96

Well Number

Notes: * =Table # I o i 12197 Geomatrix Report of Soil and Groundwater Investigation Findings < = not detected above the iaboratory reporting iimit

PCE = tetrachloroethene TCE = trichloroethene

cis-I 2-DCE = cis 1 2-dichloroethene lrans-I 2-DCE = trans-I 2-dichloroethene

1.1-DCE = I l-dichloroethene

Date Sampled

Sample Depth (fl)

PCE TCE cis-1,2-DCE trans-1,2-DCE OTHER

Table 2 Summary of Historical Analytical ~esults' -

Monitoring Well Samples Former Mercury Dry Cleaners

2417 Pinole Valley Road Pinole, California

Concentrations in micrograms per liter (pg4)

Notes: * = Table #2 of 12197 Geornatrix Report of Soil and Groundwater Investigation Findings < = not detected above the laboratory reporting limit

PCE = tetrachloroethene TCE = trichloroethene

cis-1,2-DCE = cis 1 ,Bdichloroethene trans-1,2-DCE = trans-1.2-dichloroethene

Well Number

7741-t02 xls \ Table 2

Date Sampled PCE TCE cis-1,2-DCE trans-1,2-DCt

Table 3 Summary of Historical Analytical ~esults' -

Grab Groundwater Samples Former Mercury Dry Cleaners

2417 Pinole Valley Road Pinole, California

Concentratrons in micrograms per liter (/pg//)

Notes: * =Table #3 of 12/97 Geomatrix Report of Soil and Groundwater Investigation Findings < = not detected above the laboratory reporting limit

PCE = tetrachloroethene TCE = trichloroethene

cis-1,2-DCE = cis 1.2-dichloroethene

7741-102 xls \ Table 3

Location Date

Sampled PCE TCE cis-? &DCE trans-I ,2-DCE OTHER

Table 5 Volatile Organic Compounds Detected in Groundwater Samples

Former Mercury Dry Cleaners 2417 Pinole Valley Road

Pinole, California Concentrabons m m~crograms per leer (pg/7)

Page 1 of 4

Shallow Zone MW-I MW-I MW- I

MW-2 MW-2 MW-2 MW-2 MW-2 MW-2 MW-2 MW-2 MW-2 MW-2

MW-3

MW-4 MW-4 M W-4 MW-4 MW-4 MW-4 M W-4 MW-4

MW-5 MW-5 M W-5 MW-5 MW-5 MW-5 MW-5 MW-5

MW-6 MW-6 MW-6 MW-6 MW-6 MW-6 MW-6

CAS #

107-06-2

7741-102 XIS \ Table 5

CAS #

156-60-5 Well

Number Notes Date

Sampled EPA

Method CAS #

156-59-2

PCE CAS #

127-18.4

TCE CAS #

79-01-6

Table 5 Volatile Organic Compounds Detected in Groundwater Samples

Former Mercury Dry Cleaners 2417 Pinole Valley Road

Pinole, California Concentrations in micrograms per liter (pgfl)

Page 3 of 4

MP-I MP- I MP-I MP-I MP-I MP-I MP-I MP-I

MP-2 MP-2 MP-2 MP-2 MP-2 MP-2 MP-2 MP-2

Well Number

Deep Zone DZ- l DZ-l DZ-l DZ-I DZ- l DZ- l DZ-l DZ-I

DZ-2 DZ-2 DZ-2 DZ-2 DZ-2 DZ-2 DZ-2 DZ-2 DZ-2 DZ-2 DZ-2 DZ-2 DZ-2

03/28/00 Dup 03/28/00

06/02/00 Dup 06/02/00

0911 2100 1211 I100

DUP 1211 1/00 03/05/0 1

Dup 03/05/01 06/04/0 1

Dup 06/04/01 09/04/01 12/04/01

Notes

030802PHH 7741402 xls \ Table 5

Date Sampled

EPA Method

PCE

CAS #

127-18-4

TCE

CAS #

79-01-6

cis-1,2-DCE

CAS #

156-59-2

trans-1,2-DCE

CAS #

156-60-5

1,2-DCA

CAS #

107-06-2

Table 5 Volatile Organ ic C o m p o u n d s Detected in Groundwate r S a m p l e s

Former Mercury Dry Cleaners 2417 Pinole Valley Road

Pinole, California Concentrations in mlcmgrams per liter (pgfl)

Page 4 of 4

Field Blanks MW-7 FB DZ-l FB MW-7 FB MW-2 FB EB-12 1100 EB-I21200 EB-20010306 EB-20010307 MW-2FB MW-2FB MW-10-FB

-

Trip Blank TB 03128100 8260B <O 5 <O 5 <O 5 <O 5 <0 5 TB-I 0911 1/00 82608 <O 5 <O 5 <O 5 <O 5 <O 5

TB-20010305 03/05/01 82608 .:O 5 <O 5 <0 5 <O 5 .:O 5

TB-20010307 03/07/01 8260B <0 5 <O 5 <0 5 <0 5 <O 5 TB-060401 06/04/01 S26OB 4 5 4 5 <0.5 <0.5 <0.5

Data updated by NPD Proofed by LPL QA'QC by AEGD

Notes: NS = Not sampled FB = Field Blank TB = Trlp Blank Dup = Duphcate

I ,2-DCA

CAS #

107-06-2

1,1,2,2-PCA = 1,1,2,2-Tetrachioroethane I ,4-DCB = I ,4-D~chlorobenzene I ,2-DCA = 1,2-Dichloroethane CIS-1.2-DCE = cis-l,2-D~chloroethcnc trans-1,2-DCE = trans-l,2-D~chloroethcnc PCE = Tenachloroethene TCE = Trlchloroethene VC = Vinyl Chlorlde I,I-DCE = 1.1-Dtchloroethene I ,1,2-TCA = I , I ,2-Tr~chioroethane

Well Number

Additional compounds detected (pgll):

PCE

CAS #

127-18-4

(1) 20 VC; 7 $,I-DCE; 0 8 l , l2-TCA; 14 Chlorobenzene; 0 8 1,1,2,2-PCA; 0 9 1 4-DCB

(2) 1 3 VC (3) 0 9 VC (4) 4 7 Chiorofbrm (5) 0 6 I,I-DCE, 0 9 VC (6) 2 8 VC (7) 0 6 VC (8) 0 7 VC (9) 2 3 VC ( 1 0 ) 0 8 VC.05 I,I-DCE ( l 1 ) 4 2 V C (12) 1 0 V C

Notes

7741-102 XIS \ Table 5

trans-1,2-DCE

CAS #

156-60-5

TCE

CAS #

79-01 -6 Date

S a m p l e d

cis-1.2-DCE

CAS #

156-59-2 E P A

Method

Table 6 Potentially Applicable or Revelant and Appropriate Requirements (ARARs)

and To Be Considered (TBCs) Regulations

FEDERAL

Criteria, Limitation

Classification and Regulation 01 Hazardous Waste

I1 Hazardous Waste Identification

11 Drinking Water Standards

Transport of Hazardous Waste

Clean Air Act

Occupational Health and Safet). I------- II Health Risk Assessement

Preliminary Remediation Goals I

Citation

42 USC 7401-7642

40 CFR 261 24

40 CFR $41 11-141 16

40 CFR 141.60-141.63

40 CFR 263

42 USC 7401-7642

29 CFR 1910 120

S EPA Risk Assessmen Guidance for Superfund

1989

US EPA Region iX

CFR = Code of Federal Regulations

USC = United States Code

Establishes criteria for the fetermination of hazardous waste and ChemicallAction

Description

its regulation

Establishes criteria to determine I

Type of ARARs or TBCs

whether solid waste exhibits hazard characteristics to toxicitv

Establishes national primary drinking water standards

( Chemical

Standards applicable to transporters of hazardous w x t e I Action . . . -- - . . -. . . -. . .

I

Guidance and framework to assess health risk

TBCs (Action)

Emission standards from stationary and mobile sources

Establishes requirements for health and safety training

istablishes screening numbers based on health risk assessment

I TBCs (Chemical)

Chemical

Action

7741402 xls \ Table 6

I

Table 7 Potentially Applicable or Revelant and Appropriate Requirements (ARARs)

and To Be Considered (TBCs) Regulations

State and Local

I/ Hazardous Waste Generator 22 CCR 66262, et seq Establishes standards applicable to

Requirements generators of hazardous waste Action 11

Type of ARARs or TBCs

--

Determination of Hazardous Waste

Description Standard, Requirement, Criteria, Limitation

II 22 CCR Division 4, Chapte Estabiishes drinking water standards Drinking Water Standards 14

64401 et seq I for public water supply system I Chemical

Citation ~ ~-~p

22 CCR 66260 et seq

Ambient Air Quality Standards

Transportation of Hazardous waste

II Stockpiling Requirements of Establishes standards for stockpiiing Contaminated soil 1 l 3 1 of mnRCRA contaminated soil 1 Action II

Establishes criteria for determining waste classificstion for the purposes

of transportation and disposal of wastes

22 CCR Chapter 13

22 CCR Chapter 13

Environmental impact Review

Emission Standard

Grading Permit

Chemical

CCR = California Code of Regulations H&S = Health and Safety Code

Establishes standards for emissions of chemical vapors and dust

Governs transportation of hazardous materials

Public Resources Code Sections 21000-21 177

Rule 40 Regulation 8

City of Pinole Ordinance

Occupational Health and Safety

Chemical

Action

Emission Standards from stationary and mobile sources

Establishes emission standard for particuiate matter: and notification

requirement

Permit required for site excavation and grading activites

8 CCR Sect 1500 2300 and 3200 et seq

Action

Chemical

Action

Estabiishes standards for working conditions and employees

Action

MAP SOURCE. U.S.G.S Topographic Map. 7.5' Quadrangle. Mare Island and Richmond. California. 1981

0 1.000 2,000 4,000 feet

Site Vicinity rr - LFR Figure 1

L E V I N E * FRICKE Project No. 7741

NOTTO SCALE

LEGEND

* APPROXIMATE BORING LOCATION

V VACANT'

BARF~nance P~nole LL Y

z C Site Location Map E -

u Pincle Valley Shopping Center 8 1. LL

I Pinole, CA I gI u u m - Z -

Figure 2 -, 5 Project No 7741 k u

-1

EXPLANATION

S-jC FENalProperty Line

MW-l@ SHALLOW MONKOIUNG WELVPOlM LOCATION

MW-11 @ SHNLOW MONITORING WELL INSMLLEO BY LFR LEYINEiRIO

DZ-:3 . DEEPMONITORING WELL LOCATION

'-' @ PIEZOMETER LOCATION

CREEK WKER W A T I O N MONKORINC STATION

Site Plan Showing f Monitoring Well Locations 2 m

8 i j - 0,

Figure 3 - Project No 774, lil SOURCL GEOeWXTRIX APPROXIMATE SCALE IN FEE?

p- I I

0 50 feet u Approximate

SCALE IN FEET (APPROXIMATE)

@ MONITORING WELL LOCATION

@ TEMPORARY WELL POINT CLUSTER

. ,----- -------- TOPOGRAPHIC CONTOUR (in feet above mean sea level)

Groundwater Sampling Locations

Source: Geornatrix *

EXPLANATION

S Monitoring Well Location

6 Soil Boring

Soil Boring

Depth of Sample and PCE lo' * Concentration in mglkg

Pinole Valley Shopping Center

Forrher Mercury

Dry Cleaners

Test Area Boundary TH2 11m

TCE cis trans 2' :25 <25 <25

<25 <25 c25

TH7 11/3o/OO I

PC€ TCE cis trans 4' l c5.1 <5 1 <5 1 8' d . 1 W O M R29P

THlO 2/27/01 I

PCE TCE cis trans 2' <4.9 <4.9 <4.9 <4.9 4' . 4 . 0 -5.0 4 . 0

THl 11kYOO PCE TCE cis trans

4' <25 <25

qm Wi- 4 5

8' : ~ 4 . 8 <4.8 <4.8 12' : -5.0 ~ 5 . 0 4 . 0

CalTrans Property I THB 11/30/00

PC€ TCE cis trans 4' q5.0 ~ 5 . 0 <5.0 4 . 0 8' <4 7 <4.7 <4 7 -

1 ; THll 02/27/01

PCE TCE cis trans 2' uur* 4 . 0 <5.0 c5.0 4' 'masm 4 . 2 4 . 2 4 . 2 8' <23 <23 <23 12' 4 3 0 4 3 0 4 3 0

I TH3 11/6/00

PCE TCE cis trans 4' <25 <25 <25 12' ' 4 3 0 <I30 4 3 0

TH6 11/3WOO PC€ TCE

4'

TH9 2/27/Y)1 I

PC€ TCE cis trans 2' 4 . 0 4 . 0 4 . 0 e5.0 4' 4 . 0 -5.0 m. w- 8' <4.9 , : rtPlp- 12' B#: m: rn

I TH12 2/27/01 Asphalt

PCE TCE cis trans 2' <4.9 <4.9 .,M IC#l 4' 4 3 0 4 3 0 ,B

8' <25 ,m "W Ale 72' , , r n - m : u - a p * -13

I

TH5 11/3WOO PC€ TCE cis trans

4' 4 3 0 4 3 0 .,-. :&; 8, w. g wi

. . < . , . . . -

rH4 llM6/00 I

PC€ TCE cis trz.8

Dirt

WLANATION

Monitoring Wells

- Soil Test Borings

- - - Limits of Excavation

PCE TeBachloroethene TCE Trlchloroethene

cls 1,2 cis-Dichloroethene Wens 1 2 trans-Dichloroethene

c Less than the Reporting Limit

All Concentrations milligrams per kilogram

RARFinanr~ - Pi,, i

Excavation Area and Soil Data

Figure 8 MW-1

1/9/01

Date

1 /2Q/C

in,

TCE cis-1,2 DCE

Total VOC Conc

Figure 9 M W-2

Date

- .

-* PCE -:-. TCE

cis-1,2 DCE

- Total VOC Conc

injection injection

Figure 10 MW-10

injection Date

- - - - - . . - . . ..

+ PCE

+ TCE

t. cis-1,2 DCE

&Total VOC Conc ~...

injection

APPENDIX A

Notice of Exemption

Winston H Hickox Agency Secretary California Environmental

Protection Agency

To:

From:

Department of Toxic Substances Control

Edwin F Lowry, Director 700 Heinz Avenue, Suite 200

Berkeley, California 94710-2721

NOTICE OF EXEMPTION

Office of Planning and Research 1400 Tenth Street, Room 108 P O Box 3044 Sacramento, California 95812-,3044

Department of Toxic Substances Contr.01 (DTSC) Northern California Coastal Cleanup Operations Branch 700 Heinz Avenue, Suite 200 Berkeley, California 94710

Gray Davis Governor

Project Title: Approval of Removal Action Workplan for Former Mercury Dry Cleaners

Project Location: 2714 Pinole Valley Road City: Pinole County: Contra Costa County

Project Description:

The proposed project is approval of a Removal Action Workplan (RAW) which proposes to excavate and dispose of offsite soils with concentrations of chlorinated solvents, primarily perchloroethylene (PCE), above the residential cleanup goals The former Mercury Dry Cleaners Site is located in the Pinole Valley Shopping Center, in a mixed residential and commercial area The Site is zoned for commercial use and is expected to continue to be used as a shopping center

PCE was detected in site soils up to 920 parts per million (ppm) Contaminated soils will be removed from the Site to achieve the health-based residential cleanup level of 5 7 ppm PCE Approximately 450 cubic yards of contaminated soils will be excavated and removed from the Site The excavated soils will be loaded to trucks and transported offsite to permitted disposal facilities The excavations will be backfilled with gravel and clean fill and will be restored to its original condition to the extent possible

The energy challenge facing California is real Every Californian needs to take immediate action to reduce energy consumption For a list of simple ways you can reduce demand and cut your energy costs, see our Web-site at www dtsc cagov

B, Printed on Recycled Papel

Groundwater at the site was encountered at approximately nine feet below ground surface and has been impacted with chlorinated solvents PCE was detected in groundwater up to 110,000 parts per billion (ppb) The groundwater will be treated with Hydrogen Release Compound (HRC) to enhance the reductive dechlorination of the chlorinated compounds in groundwater It is a naturally occurring process mediated by microorganisms Treatment will be conducted to achieve the Maximum Contaminant Level (MCL) in drinking water of 5 ppb PCE Since soil excavation will extend below the water table, HRC will be placed in the excavation by coating the gravel backfill HRC may also be injected in the saturated zone downgradient of the excavation to achieve the cleanup goals The proposed groundwater remediation will have no impact on the domestic water source in the area Groundwater is not used for drinking in the City of Pinole The East Bay Municipal Utilities District (EBMUD) supplies all water in the City from the Sobrante filter plant which accepts water from San Pablo and Briones reservoirs EBMUD does not use groundwater in its distribution line,

Contingency alternatives for groundwater remediation are also included in the RAW in the event that the cleanup levels can not be achieved The contingency alternatives include a pump and treat system and other in-situ treatment method, subject to separate DTSC approval and environmental review

The Site's land use will remain commercial and the project will not change the current zoning The remediation will allow for unrestricted use of the Site with respect to soil contamination,,

A health and safety plan will be implemented to protect the workers and the public during the remediation activities The plan complies with federal OSHA regulations under 20 CFR section 1910 and state regulations under Title 8 of the California Code of Regulations The plan includes the use of personal protective clothing for workers and dust suppression measures during remediation activities to protect the workers and the public

Dust generation will be minimized by implementing the following measures Water spraying will be implemented, as necessary, to suppress potential dust while excavating and loading the contaminated soils into the hauler trucks Gentle loading will be performed to minimize the potential for spill or dust creation After loading, the contaminated soils will be covered with tarpaulins No excavation or loading will be performed during unfavorable weather conditions (high winds or storms)

The transportation procedure in the RAW requires that loaded trucks be covered and follow specific truck routes to the landfill The trucks will not travel in residential areas since the Site is located in a commercial area near the freeway A Class I landfill will be used for disposal of contaminated soils All hazardous waste soil leaving the site will be handled by a registered hauler and under manifest

Name of Public Agency Approving Project:

Mercury Dry Cleanerr Site Notice o/E:xemption Page 2

California Environmental Protection Agency Department of Toxic Substances Control

Name of Person or Agency Carrying out Project:

Bank of America Realty Finance, Inc Richard H Oliver, Project Manager

Exempt Status:

Title 14, CCR 15061 (b)(3) With certainty, no possibility of significant effect on the environment

Reason Why the Project is Exempt:

The project will not have a significant effect on the environment because:

The project is of limited areal extent and short duration

The volume of soil that will be excavated and transported to permitted disposal facilities is small (approximately 450 cubic yards)

The contaminated area will be remediated to residential standards so that land use will not be restricted after the remediation, although land use will remain commercial

Dust control measures will be implemented as necessary based on air monitoring This will include water spray, dust suppressant or reduced equipment travel speeds,,

A Health and Safety Plan will be implemented to ensure that the workers and the public will not be exposed to airborne contaminants

The RAW includes a transportation procedure to insure the safe transport of the contaminated soils to permitted disposal facilities Transportation routes will not affect school and residential areas since the Site is located adjacent to 1-80,, ~T'rucks will travel from the Site to the disposal facility to avoid peak commute hours.

Mercury Dry Cleaners Site Notice of Exemption Page 3

Lead Agency Contact:

Rernedios V Sunga Department of Toxic Substances Control (51 0) 540-3840

Signature: Date 5-7-2a 2 Barbara J ~ o o k p E , Chief 0 Northern California Coastal Cleanup Operations Branch

Date received for filing at OPR:

Mercury Dv Cleaners Slte No t~ce of Exemption Page 4

APPENDIX B

Responsiveness Summary

Winston H Hickox Agency Secretary California Environmental

Protection Agency

Department of Toxic Substances Control

Edwin F Lowry, Director 700 Heinz Avenue, Suite 200

Berkeley, California 9471 0-2721 Gray Davis Governor

FORMER MERCURY DRY CLEANERS SITE RESPONSIVENESS SUMMARY

PUBLIC COMMENTS RECEIVED ON THE DRAFT REMOVAL ACTION WORKPLAN

I ,, Introduction

The Former Mercury Dry Cleaners Site is located within a retail shopping mall known as the Pinole Valley Shopping Center at 2174 Pinole Valley Road, Pinole, Contra Costa County Mercury Dry Cleaners occupied the northernmost end space of the shopping center from 1959 to 1993 The dry cleaning operations ceased in 1993 and the unit has been unoccupied since then The Site includes the part of the shopping center formerly occupied by Mercury Dry Cleaners and an adjacent area where soil and groundwater are contaminated Tetrachloroethene or perchloroethene (PCE) was used in the dry cleaning operations Site investigations found soil and groundwater contamination in a parking area behind the facility where PCE solvent filters was alleged to have been dumped PCE and its break down chemicals were detected in soil and groundwater at the Site A Draft RAW was prepared that recommended digging up the contaminated soil and taking it to an approved offsite disposal facility and an in-place groundwater treatment

The Draft RAW went through a 30-day public comment period that ran from April 5, 2002 through May 6, 2002 A notice of the comment period was placed in the West County Times on March 26, 2002 and April 5, 2002 A Fact Sheet, which discusses the Draft RAW and the proposed cleanup method for the Site, was mailed out on March 18,2002 The Fact Sheet and a Notice of Comment Period Correction was also hand-delivered and mailed on April 12, 2002 A copy of the Fact Sheet and Public Notice is included in Attachment A

The purpose of this Responsiveness Summary is to present a written response by the Department of Toxic Substances Control (DTSC) to the comments received on the Draft RAW The comments received during the comment period are compiled and included in this Responsiveness Summary A copy of this Responsiveness Summary will be mailed to those who provided comments

The energy challenge facing California is real Every Califomran needs to take immediate action to reduce energy consumption For a list of simple ways you can reduce demand and cut your energy costs, see our Web-s~te at www dtsc ca gov

@ Printed on Recycled Paper

This Responsiveness Summary is organized as follows:

. Section I is the Introduction,

. Section II lists the comments received and provides responses to the comments

Section Ill lists the repositories of site-related documents

Attachment A provides a copy of the Fact Sheet, the display advertisements of the Public Notice, and the Notice of the Public Comment Period Date Correction,,

Attachment B provides a copy of a Fact Sheet that was returned with comments

I1 Comments and Responses

One Fact Sheet with annotated comments was returned DTSC responses to the written comments received are outlined below

From: Fiat Music Company 2704 Pinole Valley Road Pinole, California 94564 (510) 758-7777

Comment As Written: Use method that is economically feasible and feasible time wise

Response: Various cleanup methods have been evaluated for the Site The cleanup alternative evaluation is outlined in the document entitled Interim Screening and Evaluation of Remedial Technologies for Source Area Remediation (LFR, June 19, 2000) Based on this initial screening, five cleanup methods, including no action for baseline comparison, were further evaluated for effectiveness, implementability and cost

Effectiveness is the ability of the cleanup method: to handle the contaminated soil and groundwater; and to protect human health and the environment in the short and long term,,

Implementability is the technical and administrative feasibility of constructing, operating and maintaining a cleanup method Technical feasibility refers to the ability to construct, operate and meet technology-specific regulations

~Merculy Dry Cleanerr Szte RA WRerponszvenesr Summary

Page 2

. May 2002

Administrative feasibility refers to: the ability to obtain approvals from other offices and agencies; and the availability of treatment, storage, disposal services and capacity, specific equipment, and technical specialists

Cost includes capital, operation and maintenance costs

The proposed alternative would be effective in protecting the human health and the environment Soil removal and replacement is readily implementable Excavation and backfilling are commonly performed, and subcontractors and equipment are readily available The excavation and disposal costs are reasonable This alternative involves less operation and maintenance, since it does not include a groundwater pumping and treatment facility

Comment As Written: We in the center have suffered from lack of tenants and no walking traffic for too long

Response: In its present state, the Site does not pose a health risk to occupants and customers of the shopping center and nearby residents since the Site is covered with a building and pavement that prevent exposure to contaminated soil The excavation will be conducted behind the building in 1-2 weeks, including disposal and site restoration activities The cleanup project should have no significant effect on traffic and deliveries in the shopping center and on public health and the environment since:

The project is of limited areal extent and short duration;

T'he volume of soil that will be excavated and transported to permitted disposal facilities is small (approximately 450 cubic yards);

The contaminated area will be remediated to residential standards:

Air monitoring will be conducted and dust control measures will be implemented if necessary;

A Health and Safety Plan will be implemented to ensure the protection of workers and the public; and

The RAW includes a transportation procedure to insure the safe transport of contaminated soil

Mercury Dry Cleaner r S ~ t e RA WResponriveners Summary

Page 3 Mav 2002

111 Final Removal Action Workplan

The RAW has been finalized The Notice of Exemption, which was prepared in compliance with the California Environmental Quality Act, is included in the Final RAW as Appendix A This Responsiveness Summary is included in the Final RAW as Appendix B Field implementation of the RAW is scheduled to begin this summer The Final RAW and other documents related to the Site are available for review at:

Department of Toxic Substances Control 700 Heinz Avenue, Second Floor Berkeley, California 9471 0 (51 0) 540-3800 (appointment necessary) Hours: Mon - Fri, 8:00 a m - 500 pm, ,

Contra Costa Public Library Pinole Branch 2935 San Pablo Dam Road Pinole, California 94564 (51 0) 758-,2741 Hours: Mon &Wed, 1.00 p m - 9:00 p m

Tue, 10:OO a m - 6:00 pm,, Thurs, Closed Fri, 1.00 p m - 500 pm,, Sat, 10:OO a m - 500 p m Sun, 1.00 p m - 300 p m ,

/ e , M e , , , y: S I , ~ ~ , x-/7 /o 2

Prepared by: Remedios V Sunga u Date Project Manager Coastal Cleanup Operations Branch

~-cQ'i'-- 3- 7 - J o o L Approved by: Barbara J Cook, F1($ , Chief Date

Northern ~a l i fo rn ig Coastal Cleanup Operations Branch

Mercury Dry Cleaners Szte Page 4 RA WRerponrzveness Summary

. May 2002

Attachment A Copy of Fact Shee t , Public Notice a n d Newspaper Advertisements

m L I C COMMEh'1 PERIOD DAIE CORRECTION for

Draft Removal Action Workplan FORMER MERCURY DRY CLEANERS SIIE

The California Environmental PI otection Agency, Department of Toxic Substances Control (DTSC) announces the availability of the Draft Removal Action Workplan (RAW) for public review and comment from April 5, 2002

through May 6, 2002 for the Former Mercury Dry Cleaners Site This public notice was in the March 26, 2002 issue at the Classified Legal Notice section

The Site is located at the Pinole Valley Shopping Center, at 2714 Pinole Valley Road Pinole, Contra Costa County, Califbrnia 94564, Mercury Dry Cleaners conducted its dry cleaning operations at the Site from 1959 to 1993.. The dry-cleaning operation ceased in 1993 and the facility has been vacant since then,. Site investigations fbund soil and

groundwater contamination in a parking area behind the facility where solvent filters were alleged to have been dumped,. Contaminants detected include perchloroethene (F'CE) and its break down chemicals,. PCE is a colorless

liquid typically used as dry cleaning and degreasing solvents. In its present state, the site does not pose a health risk to site occupants and nearby residents since the Site is covered with a building and pavement. However, cleanup actions are necessary to remove the source of and to address groundwater contamination. The proposed removal actions are

described in the draft Removal Action Workplan (RAW) which proposes excavation and offsite disposal of' contaminated soils and in place treatment of' groundwater by enhancing the biodegr.adation of contaminants.,

In accordance with the California Environmental Quality Act (CEQA), DTSC has evaluated the proposed Site cleanup plan to determine if there will be any potential adverse environmental impacts. DTSC fbund that the project will not have a significant effect on the environment. DTSC has prepared a Notice of Exemption in compliance with

CEQA fbr the project.,

The public is invited to comment on the draft RAW at any time during the 30-day public comment period Written comments should be postmarked no later than May 6,2002 and should be mailed to Remedios Sunga, Project

Manager at the DTSC address helow Questions ahout this project can he directed to either Remedios Sunga at (510) 540-3840, rsunga@dtsc ca gov, or Rachelle Maricq, DTSC Pubic Participation Coordinator at (510) 540-3910,

rmaricq@dtsc.cagov For media questions, please call Angela Blanchette, DTSC Public Information Officer at (510) 540-3732, rblancbette@dtsc .ca gov

You can review the draft RAW along with other site-related documents at the following locations

Department of' Toxic Substances Control Berkeley Office

700 Heinz Avenue, Suite 200 Berkeley, CA 94710

By appointment: call (510) 540-3800

Pinole Public Library 2935 Pinole Valley Road

Pinole, California (510) 758-2741

During regular Library Hours

The full administrative recor d is available at the above DTSC office

plays outcall sex specialist Poopay in the Masquers' , comic thriller "Communicating Door"

deau, opening April 12 at Altarena Playhouse, 1409 High St, Alameda

Cotton-candy fluffy and ar- guably one of the funniest plays eve witten, it's a bieakneck romu throud~ scenes of romantic

7 1CKER int&ue, &en identities, leal-

:r 5 lit revolving

%specialist from ed Poopay, played

nes to a suite 11 at the behest #no eschews a f confessing to his u of two wives )1 place in the

drawn into thls r h e hghts fiash, I :h of the dead I). xrah Andrews ,x, appear h e as e ?ars of thelr

ace ensues to f h b in tune to and pIevent the r happenxng m

e, out seems a lit. ble onstage -

'little " r, Conrad Cady es iomplete the Serena Anderson 1 X I bravo for I (radshaw and r. -;ew The ele- mockout - in- L- 1cked.out wall a ve bathmorn, e. nat has a mi- =

proceedings :c- carried away! ! n Fridays and

1 . mdays, April 7, cets are $12 Call

F NCH PASTRY: ..,I something

different Oavor; try E - " the classic y eorges Fey.

ous rages and rwolving beds "Flea in Her Ear" is directed

by Brian Siewert and produced by Deborah Robbins It plays at 8 p rn Fridays and Saturdays t h ~ u g h May 12 with Sunday matinees Ap1il21 (sold out), h r i l 2 8 and Mav 5 and 12 ------

Tickets are $i2 general ad- mission; $9 for seniors and stu- dents Racy fun for grownups, but not recommended for chi].. aren CaJ 510-523-!553.

ITS 'CARNIVAL' TIME: at- fore we leave Altarena here s an audition of interest for all you s o n g b i i and nimble-footers The theater will be casting the musical "Carnival" on April 15 and 16 at 7 p a at the play. house Randall Men, director. David Howitt, musical duenor; and George Adams, chor.eogra- pher, are looking for six men (ages 25-60) and five women (16 60) for principal roles and six to eight people of all ages for a mixed chorus Bring a song in your key Be prepared to move and read kern the saipt

Cirrus skills are especidly d e suable A puppeteer and a d m - mer are also needed Perfor- mance dates are weekends hom May 31 through June 30

For additional information, you on reach Metz at 510-569- 3144, or e-mail questions to pup petcorn@hofmail.com,

AND 'SHAKE' A FINALE: Wlliam Shakespeare's romantic tragicomedy "Perides. Prince of Tyrr" opened last night at La Val's Subterranean, 1834 Euclid Ave.. Berkeley,

The show.mntinues at 8 p m Ihursdavs. Fridavs and Satur-

PUBLIC COMMENT PERIOD DATE CORRECTION for'

Draft Removal Action Workplan FORMER MERCURY DRY CLEANERS SITE

-he Cahfomia Environmental Protection Agency, Department of Toxic Substances Control @TSC) announces the

wailability of the Draft Removal Action Work lan (RAW) for ublic review and comment fmm A ril5,200$ through ~ a , y

9,2002 for the former Mer Dry heaners site. This ubhc notice was in the March 2 6 3 0 2 issue at the Classifie Legal

Notice section 2

Ihe site is located at the Pinole Valley Shop ing Center, at 2714 Pinole Valley Road, Pinole, Contra &sta County,

California 94564 Mercury Dry Cleaners conducted its dry cleaning operations at the site from 1959 to 1993 The dry

cleaning operation ceased in 1993 and the facility has been vacant since then. Site investigations found soil and

groundwater contamination in a parking area behind the facility where solvent filters were aUe ed to have been

dumped Contaminants detected i nc lde perchlomethene (PCE) and its breakdown chemicals. PCE is a colorless liquid typically used as dry cleaning and degreasin solvents. In its

Dresent state. the site does not Dose a hea l s risk to site oc&~ants and nearbv residen- shce the qite is covered with ~~ ~ ~ ~~ ~. - -. ~~- ~- - ~~~ ~ ~ . .

2 hciiding and ?aCement However, cleanup acflons are necessaN to remove h e source of and to address

qoundwa!er conrrminanon The proposed remo\.a! amons are descnbsd LI rhe drair Rerno\,a: Amon Mbrkplan (R41.V)

In 3c:xdm:c with -he Ciiiomia Enviroxne~tal Quaky .Act CEQA . 3 5 C has ?valuated rhe xo?osed xte cleanup plan

:c dc:emre .f rhne wil! be &v ?orcnna: adverse

the project

Ihe public is invited to comment on the draft RAW at any time during the 30-day public comment period. Written

comments should be postmarked no later than Ma 6,2002 and should be m d e d to Remedios Sunga, Project d anager at the DTSC address below Questions about this project can be

duened to either Remedios Sunga at (510) 540-3840. rsun aadtsc ca gov, or Rahelle Marie% DTSC Public _

%articipation Coordinator at (510) 540-3910. -. marieq@dtsc.ca. ov For media questions, please call An ela ?.Ianchette, D~K$ublic Information O£ficer at (510) 540-39/32,

rblanchette@dtsc ca gov

You can revlew the draft RAW along with other site-related documents at the following locations

Department of Ibxic Substances Control Berkeley Office

700 Heinz Avenue, Suite 200 Berkeley, CA 94710

By appointment caU: (510) 540-3800

Pinole Public Library 2935 Pinole Valley Road

Pinole, California (510) 758-2741

During regular Library Hours

The hill administrative record is available at the above D'TSC office

INTRODUCTION Ihe California Environmental Protection Agency, Department of' Toxic Substances Control (DTSC) has prepared this fact sheet to inform the public about the proposed cleanup activities at the Former Mercu~y Dry Cleaners Site (Site) located at 2714 Pinole Valley Road in Pinole, Contra Costa County, California (Figu~e 1)

DTSC has prepared a draft Removal Action Workplan (RAW) which recommends dig,dg up the contaminated soil and takmg it to an approved offsite disposal facility and an in-place groundwater treatment In accordance with the California Environmental Quality Act (CEQA), DTSC has evaluated the Site cleanup project to detexmine any potential adve~se environmental impacts from the proposed cleanup plan DTSC found that the project will not have a significant effect on the environment DTSC has p~epared a Notice of Exemption in compliance with CEQA fb~. the project

This fact sheet provides information on opportunities for public involvement, describes the contamination present at the Site, specifies the removal action goal, and discusses the alternative methods evaluated to achieve this goal This information is discussed in detail in the Draft RAW which is now available for public review and comment at the information repositories (see For More Information Box1

PUBLIC PARTICIPATION Comment Period

DTSC invites the public to comment on the Draft Removal Action WoI%;plan (RAW) during a 30-day public comment period which begins March 20,2002 and runs through April 18,2002.

Written comments must be postmarked no later than April 18,2002 and should be adkessed to Remedios Sunga, 700 Heinz Avenue, Suite 200, Berkeley, CA 94710-2721 Email comments to rsunga@dtsc ca gov

At the close of'the public comment period, DTSC will carefully consider public comments received before finalizing the RAW. A 1,esponse to comments document will be prepared and placed in the information repositories listed in the For More Information Box A copy of the response to comments will be mailed to individuals or organizations who submitted comments to DTSC

Terms in Bold are described in the Glossary on page 5,.

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Mercu~y Dxy Cleaners Site Fact Sheet March 2002

SITE DESCRIPTION AND BACKGROUND

The Site is located within a retail shopping mall known as the Pinole Valley Shopping Cente~; which is currently owned by BarFinance, Inc, an affiliate of' Bank of America. The shopping center covers approximately 5 5 acres, and includes thee buildings surrounded by asphalt pavement

The Former Mercury Dry Cleaners occupied the nor.thernmost end space of the shopping center from 1959 to 1993 The Site (area of contamination) includes part of the shopping center formerly occupied by Mercury Dry Cleaners

The shopping center is bounded by Caltrans right-of-way embankment (which is unpaved), up to Interstate 80 to the north, Pinole Valley Road to the east, and Pinole Creek to the south and west

The shopping center area is relatively flat Pinole Creek flows northward through an approximately 10-foot deep gully approximately 250 feet west of the former dry cleaning facility, Pinole Creek drains to San Pablo Bay approximately 6,600 feet no~thwest of the Site,

SITE INVESTIGATIONS

Site investigations found soil and groundwater contamination in a parking area behind the facility where solvent filters were alleged to have been dumped Contaminants detected include tetrachloroethene or perchloroethene (PCE) and its break down chemicals PCE is a colorless liquid typically used as dry cleaning and degreasing solvents

At least seven phases of soil, surface water andor groundwater investigations have been conducted at the Site from 1989 to 1997,

including an investigation to identify potential impacts to nearby surface water of' Pinole Creek. Groundwater was encountered at nine feet below ground PCE was detected in soil and groundwater.-at the Site, primarily near the paved driveway behind the former cleaning facility at the alleged filter dumping location The contaminants were not detected in surface water.

Results of the sampling activities indicated that app~oximately 450 cubic yards of soil are contaminated with elevated levels of PCE and its breakdown chemicals The same contaminants were detected in the goundwater Cleanup actions are necessaxy to remove the source of groundwater contamination in the soil

In its present state, the Site does not pose a health risk through direct contact since the Site is covered with a building and pavement The dry cleaning ope~.ations ceased in 1993 and the unit has been unoccupied since then.

A chemical oxidation pilot study was conducted in November 2000 using potassium permanganate for in place cleanup of contaminants in soil and groundwater The contaminant concentrations in soil were reduced below the cleanup levels However, the groundwater requi1.e~ fiuther treatment or cleanup Removal of soil with elevated contaminant concentrations is proposed to eliminate or reduce the source of contamination in groundwater

REMOVAL ACTION WORKPLAN

Cleanup Goal

The goal of the removal action at the Site is to achieve risk levels for contaminants of concern in soil and goundwater that are considered acceptable by DTSC for protection of public health and the environment and for unrestricted land use To achieve t h s removal action goal, cleanup levels for soil and groundwatk contaminants were set at residential standards for

Page 2

Mercuy Dry Cleaners Site Fact Sheet March 2002

soil and at maximum contaminant levels (MCLs) in drinking water for groundwater The soil and groundwater cleanup levels for PCE are 57 milligam PCE per kilogram of' soil (mgkg), and 5 microgram PCE per liter of groundwater (ug/l),,

Alternatives Considered

A draft RAW has been prepared which evaluates several remedial alternatives These were evaluated based on effectiveness in protecting the public health and the environment, implementability and cost

The five remedial dteinatives that were evaluated are summarized below A detailed description of each alternative is included in the draft RAW

1) No Action No cleanup actions would be conducted at the Site This alteinative is a baseline against which other alternatives can be evaluated

2) Passive Biodegradation This alteinative involves natuially occurring micioorganisms - that break down the contaminants to nontoxic chemicals

3) Chemical Oxidation This alternative involves injecting an oxidizing agent, such as potassium permanganate, into the subsurface to break down the contaminants

4) Excavation/Of'fsite Disposal and Enhanced Biode~adation Contaminated soils would be excavated and disposed at an approved landfill Then a patented chemical would be placed in the excavation to enhance the destruction of contaminants in g~ oundwater

5) Groundwater P u m and Treat This involves groundwater extraction and treatment before disposing to sewer or storm drain The most widely used treatment involves filte~ing the groundwater through activated carbon to the remove the contaminants

Recommended Alternative

DTSC is recommending Alternative 4 (Soil ExcavatiodOffsite Disposal and Enhanced Biodegradation) as the prefe~red altemative because it is protective of public health and the environment and is economically feasible,,

T h s alternative involves removing contaminated soils in a 20 feet by 20 feet area to a depth of' 20 feet to Iemove the continuing source of groundwatn. contamination. Approximately 450 cubic yards of' soils (about sixty truckloads) will be removed, stockpiled, loaded into 'aucks and hauled to a permitted disposal facility Additional sampling will be done to ve~ify that the remaining soil concen&ations meet the cleanup levels Clean imported fill, that meets residential standards, will be placed in the excavation and graded to match the existing ground surface The excavated area will be repaved andor restored to its original condition, to the extent possible,,

The groundwater will be treated to enhance the biodegradation of' the contaminants in groundwater Biodegradation is a naturally occu~ring process mediated by microorganisms., The process will conveIt the toxic contaminants to nontoxic chemicals, such as water and carbon dioxide

Air monitoring will be conducted and a Health and Safety Plan will be implemented to ensure that the w0rke1.s and the public are protected during the cleanup activities

Page 3

Mercury D I ~ Cleaners Site Fact Sheet March 2002

Figure 1 - Site Map

Page 4

Mercury Dry Cleaners Site Fact Sheet March 2002

California Environmental Quality Act

DTSC has determined that the proposed removal action is exempt from CEQA and would have no impact on the environment The exemption was based on the small volume of' contaminated soil that will be removed, the limited excavation area, and the short duration ofthe project The groundwater is not used for drinking Therefore, DTSC has prepared a Notice of Exemption in compliance with CEQA for the project

Sensitive Receptors Near the Site

DTSC considers schools, daycare centers, and places of' worship to be sensitive receptors The closest residential area is located approximately 400 feet southwest of' the Site, across Pinole Creek, The closest school is approximately 0 25 mile The closest place of' worship, child care facility, senior center and hospital are about one mile iiom the Site

DTSC does not believe that the proposed remediation will impact any of the closest sensitive recepto~s. No sensitive issues have been voiced by either residents or public officials,,

Contingency Alternative

The RAW includes a contingency alternative that may be implemented in the event that the recommended alternative is not effective in achieving the groundwater cleanup levels Alternative 5 (Groundwater Pump and ?r.eat) is the contingency alternative to cleanup the goundwater contamination at the Site,

Glossary of Terms

Biodegradation - A process that deseoys organic contaminants by soil microorganisms The microbes obtain theu food and energy directly fram the destmction of'the organic chemicals,, The organic contaminants are converted to carbon dioxide and water which are nontoxic,,

California Environmental Quality Act (CEQA) - A California law that of all actions with possible environmental impacts (for example, development and cleanup actions The Act applies gene~ally to all activities undertaken by state and local agencies, and to private activities financed, ~egulated, approved by the state and local agencies

Chemical Oxidation - A process that destroys organic contaminants using oxidants such as hyhogen peroxide, potassium pe~manganate and ozone The organic contaminants are converted to carbon dioxide and water which are nontoxic

Hydrogen Releasing Compound (HRC) - A patented biodegradable food gade compound used to stimulate the growth of' microor ganisms that destroy organic contaminants,,

Tetrachloroethene or Perchloroethene (PCE) - A colorless liquid used as a dry-cleaning and degreasing solvent

Potassium Permanganate - Dark purple crystals soluble in water It is used as oxidizer, disinfectant, and in air and water. purification It can oxidize or convert organic contaminants, such as PCE, into nontoxic substances

Notice to Hearing Impaired Individuals TDD users can obtain additional information about the Site by using the California State Relay Se~vice (1-888-877-5378) to reach PPS at (510) 540-3910

Page 5

Mercuxy Dry Cleaners Site Fact Sheet March 2002

For More Information

If you have questions or would like more information on the Former Mercuxy D I ~ Cleaners Site, please call: Remedios Sunga, DTSC Project Managa, (510) 540-3840, rsunga@dtsccagov; or Rachelle Maricq, DTSC Public Participation Coordinator, (510) 540-3910, rmaricq@dtscca gov For media questions, call Angela Blanchette, DTSC Public hfo~mation Officer, 510-540-3732, ablanchette@dtsc cagov

The Draft Removal Action Workplan and related documents for the Former Mercu~y Dry Cleaners Site are available for public ~eview at:

DTSC Pinole Public Library 700 Heinz Avenue 2935 Pinole Valley Road Berkeley, California 94 71 0 Pinole, California 94564-1491 510) 540-3800 (510) 758-2741 Call for an appointment

The full administrative record is available at the above DTSC office

Rachelle Maricq, Public Participation Coordinato~ California Envi~.onmental Protection Agency Department of Ioxic Substances Control 700 Heinz Avenue, Suite 200 Berkeley, Califo~nia 947 10-2'72 1

Page 6

Attachment B Copy of Returned Fact Sheet with Comments

INTRODUCTION The California Environmental Protection Agency, Department of Toxic Substances Control (DISC) has prepared this fact sheet to inform the public about the proposed cleanup activities at the Fo~mer Mercury Dry Cleaners Site (Site) located at 2714 Pinole Valley Road in Pinole, Contra Costa County, California (Figure 1)

DTSC has prepared a draft Removal Action Workplan (RAW) which recommends digging up the contaminated soil and taking it to an approved offsite disposal facility and an in-place groundwater treatment In accordance with the California Environmental Quality Act (CEQA), DISC has prepared a Notice of Exemption for the project

This fact sheet provides information on opportunities for public involvement, describes the contamination present at the Site, specifies the removal action goal, and discusses the alternative methods evaluated to achisve this goa! This information is discussed in detail in the Draft RAW which is now available for public review and comment at the information repositories (see For. More Information Box)

Terms in Bold are described in the Glossary on page 5

PUBLIC PARTICIPATION Comment Period

DTSC invites the public to comment on the Draft Removal Action Workplan (RAW) during a 30-day public comment period which begins March 25, 2002 and runs though April 23,2002.

Written comments must be postmarked no later than April 23, 2002 and should be addressed to Remedios Sunga, 700 Heinz Avenue, Suite 200, Berkeiey, CA 947 10-2721 Email comments to rsunga@dtsc ca gov

At the close ofthe public comment period, DTSC will carefidly consider public comments received before finalizing the RAW A response to comments document will be prepared and placed in the information repositories A copy of the response to comments will be mailed to individuals or organizations who submitted comments to DTSC

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De~artment of Toxic Substances Control

Edwin F Lowry, Director 700 Heinz Avenue, Suite 200

Winston H Hickox Berkeley, California 94710-2721

Agency Secretary California Environmental

Protection *gencY FINAL REMOVAL ACTION WORKPLAN APPROVAL RECORD

Site Name: Mercury Dry Cleaners

Site Location: 2714 Pinole Valley Road, Pinole, California

County: Contra Costa County

Regional Section: Northern California, Coastal Cleanup Operations Branch

This is to certify that the attached Removal Action Workplan has been circulated for public comments and subsequently finalized as deemed appropriate The proposed remedial action has been determined to be reasonable and feasible

The undersigned hereby approve to adopt the attached as the final Removal Action Workplan..

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Cleanup Operations Unit Chief Date

<-ma Cleanup ~~erat i@ranch Chief

The oncrg! cna .enge facrng Calliorn8a 1s rcal Ever/ Callfornran needs lo l3Ke ~rnmeo.are acl.on lo reducc energy cons~rnplron For a hsl of s.rnp.2 ~vays you can reduce demand and cul /oLr encrgy cosls, see our aeb -o le a1 v/v/v/ ofsc ca ~ o v

Gray Davis Governor

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