Free Additional Attachments to Main Document - District Court of Arizona - Arizona

Remedial Planning Activities at Selected Uncontrolled Hazardous Waste Sites-Zone II

Environmental Protection Agency
Hazardous Site Control Division Contract No. 68-O1-7251

RECORD OF DECISION PHOENIX-GOODYEAR AIRPORT SUPERFUND SITE GOODYEAR, ARIZONA September 1989 RDD63605.RA Work Assignment 30-9L19.0

Ecology and Environment

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SFUND RECORDS CTR 0217-00493 SFUND RECORDS CTR 94901

RECORD OF DECISION PHOENIX-GOODYEAR AIRPORT SUPERFUND SITE GOODYEAR, ARIZONA

September 1989
RDD63605.RA Work Assignment 30-9L19.0

NONDISCLOSURE STATEMENT

This document has been prepared for the U.S. Environmental Protection Agency under Contract No. 68-01-7251. The material contained herein is not to be disclosed to, discussed with, or made available to any person or persons for any reason without the prior express approval of a responsible official of the U.S. Environmental Protection Agency.

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CONTENTS Page

Declaration for the Record of Decision Declaration ,

1 5

Record of Decision Concurrence Page 1
2

7 1-1
2-1 2-1 2-2 2-10 2-14 2-16 2-20
3-1 3-1

Site Description
Site History and Background Site History Site Characterization Exposures Toxicity Risk Cleanup Levels and ARARs
Enforcement History Phoenix-Goodyear Airport and Former GAG Facility UniDynamics Phoenix, Inc.

3

3-2
4-1

4

Community Relations History

5

Alternatives Evaluation Phoenix-Goodyear Airport and the Former GAG Facility UniDynamics Phoenix, Inc., Facility

5-1 5-1
5-53

6

References
Index of Administrative Record

6-1
A-l

Appendix A.

Appendix B.
Tables

Response Summary

B-l
Page

2-1

Comparison of the Applicable or Relevant and Appropriate Requirements and Other Criteria to Groundwater Data Comparison of the Applicable or Relevant and Appropriate Requirements and Other Criteria to Soil and Air Data
Summary of Exposure Routes and Risks

2-4

2-2

2-12

2-3

2-17

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CONTENTS (Continued)

Tables (Continued)
2-4 Estimated Excess Lifetime Cancer Risk Due to TCE Exposure Based on Implementing the

Page
2-20

No Action Alternative
2-5 Legally Applicable State and Federal Requirements and Other Criteria for Groundwater 2-22

5-1 5-2 5-3
5-4

Estimated Capping Areas Estimated Surface Areas and Number of Wells for Soil Vapor Extraction Soils Remedial Action Screening Summary
Summary of Soils Remedial Action Alternatives

5-10 5-16 5-17
5-19

5-5

Soils Remedial Actions--Cost Summary

5-21

5-6
5-7

Summary of Engineering Constraints for Water End Use Alternatives
Public Health and Environmental Considerations by Water Use Type

5-26
5-28

5-8
5-9
5-10 5-11

Summary of the Screening of Groundwater Aquifer Remedial Actions
Summary Table of Groundwater Extraction Alternatives
Detailed Analysis of Alternatives -- Effectiveness Detailed Analysis of Alternatives-Implement ability --

5-29
5-30
5-31 5-37

5-12

Detailed Analysis of Alternatives -- Cost

5-41

5-13

Summary of VOC Removal Technologies

5-44

Screening
5-14 Treatment System Costs--Air Stripping 5-47

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1 1 1 1 1 1 1 I 1 1 1 1 1 1 1 1 1 1
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CONTENTS (continued)

Tables (continued) 5-16 5-17 5-18

Page 5-49 5-51 5-57

Total Treatment Costs
End Use Alternatives--Cost Summary

Technical Feasibility Screening of Technologies and Processes for the Soils Objective
Soils Remedial Actions- -Cost Summary
Evaluation of Soil Options

5-19
5-20 5-21

5-59
5-61

Technical Feasibility Screening of Technologies and Processes for the Groundwater Quality Objective

5-65

5-22 5-23 5-24

Summary of the Screening of Groundwater Aquifer Remedial Actions Detailed Analysis of Groundwater Alternatives
Detailed Cost Analysis for Groundwater Alternatives

5-70 5-72 5-78

Figures 1-1 1-2 2-1 2-2 2-3 2-4 2-5
Site Location Map Summary of Major Activities at PhoenixGoodyear Airport

Page 1-3 1-5
2-3

Cross Sectional View of Geology

Organic Compounds Above ARAR Concentrations-Subunit A Organic Compounds Above ARAR Concentrations- Subunit B Organic Compounds Above ARAR Concentrations -- Subunit C
Exposure Pathway arid Receptor Summary

2-8 2-9 2-11 2-15

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CONTENTS (continued)

I 1
Page «

Figures (Continued)

5-1

Target Area 1 for Soils Remedial Action at Phoenix-Goodyear Airport and Former GAC Facilities
Target Area 2 for Soils Remedial Action at Phoenix-Goodyear Airport and Former GAC Facilities
Target Area 3 for Soils Remedial Action at Phoenix-Goodyear Airport and Former GAC Facilities Capping Alternative Area Delineated by Soil Sampling Analyses at Phoenix-Goodyear

5-3

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5-2

5-5

5-3

5-7

5-4

5-11

Airport and Former GAC Facilities
5-5 Capping Alternative Area Delineated by Elevated Soil Gas at Phoenix-Goodyear Airport and Former GAC Facilities Groundwater Remedial Action Alternatives Target Areas A, B, and C for Soils Remedial Action at UniDynamics 5-13

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DECLARATION FOR THE RECORD OF DECISION SITE

Phoenix-Goodyear Airport (PGA) Superfund site, Goodyear, Arizona.
PURPOSE

In accordance with the National Contingency Plan, the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), and the Superfund Amendment and Reauthorization Act of 1986 (SARA), potential remedial actions have been developed and evaluated for the PGA site. This decision document represents the U.S. Environmental Protection Agency's (EPA) preferred final remedy and remedial actions for the entire site. A Record of Decision for the Section 16 Operable Unit (OU) addressing groundwater contamination in Subunit A of the Upper Alluvial Unit (see Figure 2-1) within Section 16 was signed in September 1987. The Section 16 OU Record of Decision is consistent with the selected remedial actions represented in this Record of

Decision. The Arizona Department of Environmental Quality and the Arizona Department of Water Resources concur with these selected final remedies.
BASIS

This decision is based on the administrative record for the PGA site, which includes the results of the Remedial Investigation (RI) conducted by EPA, Unidynamics Phoenix, Inc. (UPI), and the Goodyear Tire and Rubber Company, and the Feasibility Study (FS) conducted by EPA and UPI. Appendix A identifies all the items contained in the Administrative Record upon which the selection of the preferred remedial actions are based.
DESCRIPTION

The PGA site is located approximately 17 miles west of Phoenix, Arizona, in the western part of the Salt River Valley. The site covers a total area of about 35 square miles (Figure 1-1). Except for the airport, which is owned by the City of Phoenix, the PGA site lies almost entirely

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within the City of Goodyear.

The City of Avondale occupies

about 2 square miles along the eastern border of the site. Current land uses consist predominantly of agriculture, but also include residential and industrial. Future land uses are predicted to become more residential. The combined population of the area was 30,000 people in 1985. The City of Goodyear expects to grow at a rapid pace, exceeding 140,000 people within the boundary of the PGA site in 20 years. Clusters of residential development are occurring west of the airport.
PLAN AND RATIONALE

A groundwater divide roughly follows the alignment 7>f Yuma Road, effectively dividing the site into two distinct halves, north and south. UniDynamics Phoenix, Inc., undertook investigation of contamination in the north part of the site, while Goodyear Tire and Rubber Company and EPA completed the investigation for the south portion of the site. The preferred plan of action and rationale were developed for each portion of the site. Remedial actions for Sub-

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unit A groundwater in the south portion of the site were developed during an operable unit feasibility study completed in 1987. EPA selected extraction and treatment with air stripping as the preferred remedy. Goodyear Tire and Rubber Company is currently undertaking the design of the operable unit ( U remedial action. The OU remedial action O )
is consistent with the preferred plan as stated below. Therefore, the OU and the following remedies constitute the final remedy.

Based on the PGA RI/FS, the preferred alternative for the south portion of the site consists of extraction and treatment of Subunit B/C groundwater, and soil vapor extraction for the vadose zone. o The groundwater alternative proposes the continued use of 20 existing wells for extraction and the addition of 3 more extraction wells. This alternative, which includes air stripping without carbon absorption, would result in reducing VOC concentrations in treated groundwater to levels equal to or less than Applicable or Relevant and Appropriate Requirements (ARARs). A central plant will be constructed to treat the water from all but one of the extraction wells. The remaining well will have treatment at the wellhead since it lies some distance from the airport. The treated

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water will be provided to current users of the extraction wells, with the additional flow from the three new wells going to the City of Goodyear for municipal use. Total present worth cost for extraction and treatment is estimated at $9,160,000.
o Soil vapor extraction (SVE) for the area containing 99 percent of the mass of contaminants. This area corresponds approximately to Target Area 2 in the RI/FS. Under this alternative, VOCs would be extracted through a system covering
approximately 284,100 square yards. Pilot testing conducted at this area of the site indicates that

soil vapor extraction is an effective means of removing VOC contamination from the unsaturated vadose zone, thereby removing a source of potential groundwater contamination. All SVE units will be equipped with emission controls. Costs for SVE are estimated to range from $3,904,000 for a phased implementation to $5,370,000 for a full-scale implementation.
Based on the UPI RI/FS, the preferred alternatives for the northern portion of the site are the following:

o

For groundwater, pump and treat Subunit A and Subunit C to equal to or less than ARARs. Groundwater treatment will consist of air stripping, followed by liquid phase granular activated carbon with granular activated carbon polishing on the air emissions. The end use will consist of either reinjection (treated groundwater from Subunit A) or incorporation into the community potable water supply (treated groundwater from Subunit C). The pumping rate for both subunits will be specified in the system design.

If, in the implementation of the remedial action, EPA determines that air stripping cannot treat methyl ethyl ketone (MEK) to the level required by the ARARs, then hot air stripping and scale control methods will be employed unless EPA determines that the technology is impracticable. If the technology to treat MEK is impracticable, EPA will waive compliance with the MEK ARAR pursuant to CERCLA Section 121(d)(4), and set an alternative limit that is protective of human health and the environment.

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Total cost is estimated at $12,157,000 for the Subunit A alternative and $1,870,000 for'the Subunit C alternative.

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The soils will be treated with soil vapor extraction with emission controls. The target area consists of the area where VOCs were detected in soil samples and the area where soil gas samples quantified VOCs greater than 1 ug/1. The area may be expanded or reduced to include removal of 99 percent of the contaminants. Excavation and treatment may be required to remove residual contamination where soil vapor extraction is not effective. This includes soils contaminated with MEK and acetone.
SVE costs are estimated to be $3,136,000. Costs for excavation and treatment will depend on the volume requiring removal which will be decided once the effectiveness of the SVE is determined. A total unit cost for treatment and disposal is estimated to be $715 per cubic yard.

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DECLARATION

The selected remedy for this Operable Unit is protective of human health and the environment, meets Federal and State requirements that are applicable or relevant and appropriate, and is costeffective. This remedy satisfies the preference for treatment that reduces toxicity, mobility, or volume as a principal element. All substantive permit requirements will be met during the implementation of this remedial action. It is determined that the remedy for this Operable Unit uses permanent solutions and alternative treatment technologies to the maximum extent practicable. The Arizona Department of Environmental Quality and the Arizona Department of Water Resources have concurred with the remedy presented in this document.

Because this remedy will not result in hazardous substances remaining onsite above health-based levels, the five-year facility review will not apply to this action after completion of the remedial action.

Date

Dswfiel W. McGovern Regional Administrator Region IX

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RECORD OF DECISION CONCURRENCE PAGE

Site: Phoenix-Goodyear Airport Superfund Site, Goodyear, Arizona * The attached Record of Decision package for the Phoenix- Goodyear Airport Superfund Site, Goodyear, Arizona, has been reviewed, and I concur with the contents.

Date

Gail ox>per. Acting Regional Counsel Office of Regional Counsel U.S. Environmental Protection Agency, Region IX
Director Hazardetis Waste Management Division U.S. Environmental Protection Agency, Region IX
Harry Seraydarian, Director

Date

Date

r Management Division U.S. Environmental Protection Agency, Region IX
Date

/David P. Howefeamri," Director /VAir ManagementDAvision -^ U.S. Environmental Protection Agency, Region IX

Date
Assistant Regional Administrator Office of Policy and Management U.S. Environmental Protection Agency, Region IX

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1.

SITE DESCRIPTION

The Phoenix-Goodyear Airport (PGA) site covers a total area

of about 35 square miles and is located about 17 miles due west of Phoenix, Arizona, in the western part of the Salt River Valley. Figure 1-1 illustrates the site location and
site features. The City of Avondale occupies about 2 square miles along the eastern border of the site. Except for the airport, which is owned by the City of Phoenix, the

remainder of the PGA site lies alnupst entirely within the
City of Goodyear. The remaining land is presently used

primarily for agriculture; however, residential development
west of the airport is anticipated. The general area had a combined population of about 30,000 people in 1985.

The two major surface-water drainages within the area are the Gila River to the south and the Agua Fria River to the east. The Gila River flows perennially due to releases from treatment plants. The Agua Fria River is dry most of the year with occasional flows resulting from releases from dams, irrigation tailwaters, or treatment plants. The Agua
Fria River drains south into the Gila River, which then

flows to the west. Drinking water supplies, industrial water supplies, and irrigation water come solely from groundwater that is pumped from the alluvial deposits of the western Salt River Valley
underlying the entire area. The site contains the Loral Corporation facility (formerly owned by Goodyear Aerospace Corporation [GAG]), the PhoenixGoodyear Airport (formerly operated by the U.S. Navy), and UniDynamics Phoenix, Inc. All of these facilities have been identified as sources of contamination at the PGA site. Figure 1-2 illustrates the chronology of the major activities conducted at the PGA site and places in perspective the

timing and relationship between the Section 16 Operable Unit (OU) Record of Decision and this Record of Decision for the site as a whole.
A Record of Decision was approved for the Section 16 OU at the PGA site. The Section 16 OU addressed VOC-contaminated groundwater in Subunit A within Section 16. This Record of Decision addresses the vadose zone and remaining groundwater
contamination for the entire site.

The following problem areas were defined during the PGA
RI/FS:

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Vadose zone contamination with VOCs in the vicinity of the former GAG facility and the Phoenix-Goodyear Airport
Contamination of the Subunit B/C aquifer south of the ground-water divide

Vadose zone contamination with VOCs at the UPI ity

facil-

VOC contamination of Subunit A onsite and downgradient of the UPI facility VOC contamination of the Subunit B/C aquifer onsite and downgradient of the UPI facility A V

Limited chromium contamination of soil and groundwater in the GAC sludge drying beds and adjacent areas
The PGA RI/FS describes these areas and problems in detail

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I I I I I

CITY OF AVONDALE

A R I Z O N A
CITY OF GOODYEAR
(FORMERLY GOODYEAR AEROSPACE CORPORATION) Ifff""5

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LORAL CORPORATION

I I I I I I I I I I I I I

UNIDYNAMICS-PHOENIX INC. SECTION 16

PHOENIX GOODYEAR AIRPORT 1 1 11

GROUNDWATER FLOW DIRECTION

PGA STUDY AREA BOUNDARY

6000 FEET

FIGURE 1-1 SITE LOCATION MAP
PHOENIX GOODYEAR AIRPORT ROD
R D D 6 3 6 Q S . R A AUGUST 1989

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1981

1982

1983

1984

1985

1986

1987

1988

1989

A
ADHS IDENTIFIES CONTAMINATED GROUNDWATER AT GOODYEAR, ARIZONA

A
PGA IS PLACED ON THE NPL

A
UPI INITIATES RI/ES

-A
COMPLETES RI/FS

A
ERA INITIATES RI/FS

-A
COMPLETES RI/FS

A--------

-A

GAC INITIATES Rl

EPA INITIATES SECTION 16 OUFS

SECTION 16 OU ROD SIGNED

A
PGA ROD SIGNED (PROPOSED)

RQURE1-2 SUMMARY OF MAJOR ACTR/THES AT PHOBNDC GOODYEAR ARPORT
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AIRPORT ROD

2.

SITE HISTORY AND BACKGROUND
SITE HISTORY

In 1981, the Arizona Department of Health Services discovered that groundwater in the PGA area was contaminated with solvents and chromium. Additional sampling of wells in 1982 and 1983 found 18 wells contaminated with trichloroethylene (TCE). As a result, the EPA added the PGA site to the National Priorities List in September 1983. In 1984, EPA began a Remedial Investigation of the Litchfield Airport Area (presently known as the Phoenix-Goodyear Airport) to characterize the site, investigate the extent of the contamination, and identify the potential sources.

Historical data indicate activities at three primary facilities contributed to the groundwater contamination at the PGA site:

o

The former Goodyear Aerospace Corporation (GAG) facility owned by Goodyear Tire and Rubber, currently owned by Loral Corporation
The Litchfield Park Naval Air Facility, currently the Phoenix-Goodyear Airport
UniDynamics Phoenix, Inc. ( P ) U I

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Historical data on waste handling at the former GAG facility, the airport, and the UPI facility can be found in the PGA Feasibility Study and the UniDynamics Phoenix, Inc., Feasibility Study, respectively.

Sampling data for groundwater identified two major areas of contamination, a northern area and a southern area. UniDynamics Phoenix, Inc., operates an industrial facility north of the former GAG facility across Yuma Road. UniDynamics Phoenix, Inc., undertook the preparation of a Remedial Investigation/Feasibility Study (RI/FS) report on the contamination identified north of Yuma Road and proximal to its facility. The area south of Yuma Road was investigated by the EPA, Goodyear Tire and Rubber, and the Corps of Engineers on behalf of the Department of Defense and the U.S. Navy. Most of the contamination in the southern area of the site is concentrated within Section 16. This Record of Decision covers groundwater, with the exception of Subunit A water in the south portion, and soil

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contamination, with the exception of the chromiumcontaminated soils located in the sludge drying beds at the former GAG facility. The Goodyear Tire and Rubber JCompany is performing an expedited response action under an Administrative Order on Consent for the chromium sludge beds.
SITE CHARACTERIZATION

The site is located in a region having a climate characterized by long, hot summers and short, mild winters. Relative humidity is low, particularly during early summer, and the rainfall averages about 7.1 inches per year. The average daily maximum temperature in July is 107°F, the average daily minimum temperature in January is 34°F, and the average yearly temperature is 70 °F. Temperatures vary between these extremes throughout the year.

Groundwater is pumped from the alluvial deposits of the western Salt River Valley. These deposits consist of the Upper Alluvial Unit, the Middle Fine-Grained Unit, and the Lower Conglomerate Unit, as shown in Figure 2-1. The Upper Alluvial Unit has been further subdivided into Subunit A, from the surface to about 120 feet deep; Subunit B, from about 120 to 240 feet deepj and Subunit C, from about 240 to 360 feet deep. Subunits A, B, and C are hydraulically connected.
Most wells in the area pump water from a zone between 100 and 600 feet deep. Depth to the water table has varied in the past, but recently has been measured between 40 and 100 feet below the ground surface. Groundwater flows in the PGA area are divided at approximately Yuma Road. The northern area, in the vicinity of UPI, has groundwater flows to the north or northwest, and the southern area, in the vicinity of the airport and the former GAC facility, has groundwater flows to the southwest and west. In addition to the TCE and chromium mentioned earlier, several other compounds were found to contaminate the groundwater. Among these are perchloroethylene (PCE), 1,1-dichloroethylene (1,1-DCE), chloroform, and carbon tetrachloride. Table 2-1 identifies the wells tested, concentrations detected, and the applicable Federal or State standards or other criteria. Figures 2-2 through 2-4 show well locations where organic compounds were detected above ARAR concentrations at the PGA site. The highest

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