­¦ý°±·>œ `bœ_Ï€¡7 •ø<bjbjUU G7|7|2ll"""""""tñ¬¬¬»ä ñDñbÊʸ¸¸¸¸¸|~~~$¢ŒvŒJ$s ìRn]"¸¸¸¸¸n ""¸¸À   ¸&"¸"¸| ¸| \ |†¾""|¸Ž `€øIµ¬ñ,¬"’l|·0tÂÂ| ññ"""" June 06, 2002 Via Certified Mail 7001 1940 0003 5507 0295 Carmen D. Santos-Prior, Project Manager RCRA Corrective Action Office (WST-5) U.S. ENVIRONMENTAL PROTECTION AGENCY Region IX 75 Hawthorne Street San Francisco, CA 94105 Re: BKK Landfill Site, West Covina, California RCRA ß3008(h) Administrative Orders on Consent _ USEPA Docket No. RCRA-09-89-0019 (effective March 31, 1989) _ USEPA Docket No. RCRA-9-2000-0003 (effective September 14, 2000) Monthly Progress Report for May 2002 Dear Mrs. Santos-Prior: In accordance with Section IX.2 of the 1989 Consent Order and Section VIII.B.1 of the 2000 Consent Order, BKK Corporation is herein presenting a report which summarizes RCRA corrective action progress and activities at the BKK Landfill site for the latest month. The first Order requires a monthly report while the second Order requires a bimonthly report. In order to avoid redundancy, those two deliverables are combined herein into a single monthly report. This report is organized as follows: 1.0 Activity Status as of May 2002 1.1 Groundwater Corrective Action 1.2 Soil and Sediment Characterization 1.3 Soil Gas Characterization 1.4 Ambient Air Characterization 1.5 Risk Assessment 1.6 Miscellaneous 2.0 Activities Planned for June 2002 1.0 ACTIVITY STATUS AS OF MAY 2002 1.1 Groundwater Corrective Action After more than a decade and a half of study, USEPA selected the final groundwater remedy in February 2000. USEPA and BKK then jointly signed a mutual Consent Agreement in September 2000 which provides the administrative framework by which BKK will implement the remedy under USEPA oversight. The status of remedy implementation is summarized below: Significant Activities: BKK submitted the Corrective Measures Implementation Plan (CMIP) in October 2000. Once that workplan is approved by USEPA, work will begin to design and permit the remedy and then install it in the field. USEPA issued comments on the CMIP in May 2001. The two parties then met in May, June, August, October and December 2001 to discuss the comments and review BKKís draft preliminary design for one segment of the remedy. USEPA has a number of CMIP comment deliverables which continue to be overdue. The need for one last meeting prior to BKKís submittal of a revised CMIP will be determined by both parties upon issuance of USEPAís pending comment deliverables. Summary of Findings: No significant findings were made during the month. Summary of Problems: No significant problems were encountered during the month. Actions to Rectify Problems: Since no significant problems were encountered during the month (see above), no actions were necessary to rectify the nonexistent problems. Personnel Changes: No changes to key project personnel were made during the month. Outside Contacts: No significant contacts were made by BKK with the press, the local community or public interest groups during the month regarding the final groundwater remedy. Treatment System Effectiveness: The leachate treatment plant (LTP) treats mixed waste-waters which include leachate, condensate and groundwater. It has been in operation since 1987. During the current reporting month, the LTP continued to operate in conformance with the performance criteria established in applicable agency permits. The following information is also relevant to groundwater corrective action, but falls outside of the purview of the two joint Consent Orders dated 1989 and 2000: _ Leachate Pumping: Pumping of waste liquids on the Class I landfill from the deep landfill gas extraction wells and the leachate extraction wells continued during the month. A total of approximately 115,350 gallons were evacuated from those wells. A totalizer report which lists the wells and the volume pumped from each is presented in Appendix A. Additional liquid pumping is performed from various groundwater extraction wells located on and adjacent to the site. _ Well Abandonment: After previous interaction, a meeting was held in February 2001with USEPA, DTSC, Los Angeles County and BKK to propose different well abandonment methodologies than had been approved in April 1996. BKK excavated several old wells in April and July 2001 to confirm their condition. At the Countyís request, BKK met with the County, DTSC and the state Department of Water Resources in April 2001. BKK met with DTSC and USEPA in June and resubmitted various information in June and July 2001. Well MW35A was abandoned in August 2001. Efforts to abandon Well MW35C in September 2001 were hampered by the drill rig being pushed off the hole at about 35 feet below ground surface. DTSC was contacted. Resolution is pending. BKK met with DTSC on February 15, 2002 to discuss wells in Parcel 1. 1.2 Soil and Sediment Characterization The nearby surface soils and sediments which potentially could have been exposed to contaminants while the Class I landfill was receiving hazardous waste (between 1972 and 1984) have long since been excavated and safely buried. USEPA determined in December 1996 that there is no need for BKK to perform additional work to characterize site soils and sediments. This issue will be revisited in the highly unlikely event that future land uses contemplate the re-excavation of historic surface soils that are now buried (note that there are no current plans for this type of a development). 1.3 Soil Gas Characterization Following field data collection during the winter of 1996/97, BKK submitted a preliminary Soil Gas Report in March and, after receipt of USEPA comments, submitted an expanded Soil Gas Report in June 1997. At an ensuing September 1997 meeting, USEPA had no further comments on the data and modeling presented in the expanded report, but requested a field validation program to validate the model results prior to concluding this issue. BKK consented, and immediately developed and presented a proposed field validation program at the September meeting for USEPA consideration. After various minor refinements, USEPA approved the field validation workplan in June 1998. The field validation gas probe sampling occurred under Tetra Tech (a USEPA contractor) oversight in September 1998. The study appeared to largely validate the model, but it also discovered an anomaly in a localized area near Nogales End. The data indicated a detection of about 1.9 ppmV of 1,1-Dichloroethene in soil gas at Probes 224.6D and 224.6T. This compound was detected in the conspicuous absence of landfill gas. Nevertheless, as a precautionary measure, BKK installed ten additional gas control wells in line with pre-existing perimeter wells in February and installed two more in March 1999. BKK collected additional data two weeks after the February 1999 well installation with results that showed nondetect and 0.5 ppmV (respectively) of 1,1-DCE in the two noted probes, and showed nondetect in adjacent soil and near-surface air. BKK submitted a workplan in April 1999 to perform a focused study in the area, and met with USEPA to discuss the workplan later that same month. USEPA provided written comments on the workplan in June 1999 and BKK responded six days later, and the two parties then met again in September and December 1999. BKK developed a revised workplan which was submitted in February 2000. USEPA comments on the revised February 2000 workplan are still pending. 1.4 Ambient Air Characterization BKK submitted the draft Ambient Air Sampling Report in September 1997. USEPA then issued its comments in May and held the initial meeting to discuss the report in November 1998. USEPA had additional pertinent information that it forwarded to BKK in January and February 1999, thereby allowing BKK to revise the 1997 report and resubmit it to USEPA in February 1999. USEPA comments on the revised February 1999 report are still pending. BKK is continuing to conduct voluntary ambient air sampling for vinyl chloride about twice a month at the southeast perimeter of the Class I landfill and offsite in the adjoining neighborhood, and on an annual basis at other perimeter and offsite locations. Additional ambient air sampling is done monthly and quarterly pursuant to South Coast AQMD Rule 1150.1. The analytical results for the voluntary program are summarized in Table 1 (with accompanying maps that depict sample station locations), and copies of the raw analytical data for the month are provided in Appendix B. The rolling 12-month average of biweekly monitoring at the Nogales End sampling station at the southeast perimeter of the Class I landfill had been dropping steadily over the preceding years and, as of September 1997, it dropped below and today it still continues to remain below 0.05 ppbV for vinyl chloride. That value is USEPA's proposed Preliminary Remediation Goal for vinyl chloride and, perhaps coincidentally, is also the state's Proposition 65 notification level. 1.5 Risk Assessment BKK submitted a revised Risk Assessment workplan in August 1998. That workplan had been revised in accordance with detailed USEPA/BKK discussions in April and May 1998, hence it should have reflected substantial agreement. USEPA met with BKK in November 1998 to present its initial verbal comments on the revised workplan. USEPA then asked its Cincinnati office in June 1999 to also review a portion of the workplan. USEPA written comments on the August 1998 workplan are still pending. 1.6 Miscellaneous USEPA agreed in September 2000 to forward copies of Agency guidance on the use of monitored natural attenuation for site remediation. That guidance has not yet been received. BKK provided a number of comments in December 2000 on USEPAís initial Environmental Indicator determination for the site, but has not received a response. BKK reiterated its request in an August 2001 letter. No reply has been received. BKK asked USEPA in April 2002 for a copy of its draft Vapor Intrusion Guidance document. That guidance has not yet been received. USEPA held a joint public hearing with DTSC in February 2002 regarding the City of West Covinaís proposal for a ìBig League Dreamsî commercial recreation complex to be located on virgin soil and virgin bedrock along the western edge of the site. USEPA has proposed to remove its prohibition on ìparks and playgroundsî in this part of the site. Final USEPA action was slated to occur in March, but that was later revised to April 2002. Final USEPA action is still pending. 2.0 ACTIVITIES PLANNED FOR JUNE 2002 Activities planned for the current month are summarized below: ÿ• Routine monitoring of groundwater wells will continue (see Section 1.1 above). ÿ• Routine waste liquids pumping will continue from deep landfill gas, leachate and groundwater extraction wells on the Class I landfill (see Section 1.1 above). Removed liquids will continue to be treated on site in the LTP for subsequent onsite reuse. ÿ• If USEPA submits its overdue comment deliverables on BKK s October 2000 Groundwater CMIP and no further meetings are necessary, work can then proceed to revise that workplan (see Section 1.1 above). Routine monitoring of landfill and soil gas probes will continue (see Section 1.3 above). ÿ• If USEPA submits comments on BKK's February 2000 revised workplan to perform a focused study of 1,1-DCE in soil gas at Nogales End (see Section 1.3 above), work can then proceed to finalize that workplan. ÿ• If USEPA submits comments on BKK's February 1999 revised Air Report (see Section 1.4 above), work can then proceed to finalize that report. Routine monitoring of ambient air will continue (see Section 1.4 above). ÿ• If USEPA submits comments on BKK's August 1998 revised Risk Assessment Workplan (see Section 1.5 above), work can then proceed to develop a re-revised workplan. As always, if you have any questions, please do not hesitate to call me at (626) 965-0911 x361. Sincerely, BKK CORPORATION Christopher W. Hansen, P.E., Vice President Engineering and Environmental Programs Enclosures: Table 1 Ambient Air Monitoring Program: Vinyl Chloride Figure 1 Ambient Air Monitoring Station Locations Figure 2 Ambient Air Monitoring Dilution Station Locations Appendix A Leachate Extraction Totalizer Report Appendix B Ambient Air Analytical Data cc: Richard Allen - DTSC Region 3, Glendale CA Kim Bolander - South Coast AQMD, Diamond Bar CA Chris Guerre - DTSC GSU, Cypress CA Steve Janes - The Janes Network, Santa Cruz CA Steve Samaniego - City of West Covina, West Covina CA Scott Walker - CIWMB, Sacramento CA Wen Yang - RWQCB Los Angeles, Los Angeles CA City of West Covina Public Library BKK Central File (without enclosures) BKK Clearinghouse File APPENDIX A LEACHATE EXTRACTION TOTALIZER REPORT APPENDIX B AMBIENT AIR ANALYTICAL DATA PAGE 2 June 6, 2002 Carmen D. Santos-Prior, Project Manager Monthly Progress Report for May 2002 ß ‡ \ o ¶ ¼ — °¾ž®üØxà..§.¶.¢0§0Ï2Ó2å4é4>6@6?;p;z;¢;±;¾;…;½;¼;†;<<<˜Ò˜Ò˜Ò˜Ò˜Ò˜Ò˜Ò˜Ò˜Ò˜Í˜Í˜Í˜Í˜Í˜Í˜ý˜ý˜¹˜¹Š¹˜˜OJQJaJmHnHujOJQJUaJ5ÅOJQJ\ÅaJ OJQJaJ>*OJQJaJ OJQJaJ+ABjêµø²ÏÌKâÃÒÚ  Ž˜————È—————————““““———————Ñ­`Ñ­ `™ÑPуÊ^ÑP`уÊ ­±;<››#Elä´ø‹–—  = > € ¶ ß [ \ € ¶ – — Ý°˜ÎÎÎÎÎΘÈÈȤÈÈÈÈ³È³È³È³È  & F `™ `™Ñ­Ñ0›^Ñ­`Ñ0› `™ÑpÑ0›^Ñp`Ñ0›Ñ­`Ñ­°Ùžß®¯˜úùuv¶ß‘¦­=>ðÞÙ ž !!‘"–ٖٖÙÙÙÊÙÊÙÊÙÙÙÙÊÙÙÙÙÙÊÙÙ `™Ñ­Ñ0›^Ñ­`Ñ0›  & F `™‘"¦"%%%Ò&Ú&''Ú(Û()))…)€*¶*)+*+--+-,-k-l-¢.§.Ý0››››››Ô›››Ô›››››››››››››Ô›Ô `™Ñ­Ñ0›^Ñ­`Ñ0›Ý0¢04262Í2Ï2ä4å4®55<6>6Ñ7Ü7#8$8/8?8@8A8B8n8ï8ñ88 9F9›Ô›Ê›ÔÔԛʛԛ›››››››››››ýýÑÝ`ÑÝ  & F `™ `™Ñ­Ñ0›^Ñ­`Ñ0›F9v9ù9û9Õ9›9!:P:Ü::×:™: ;7;8;9;:;;;<;=;>;J;K;q;r;s;˜ÎÈÈ“““““““““ÈÈÈÈÈÈÈðÈðÈÈ HÑ­`Ñ­ `™Ñ@ Ñ`™^Ñ@ `Ñ`™ÑÝ`ÑÝs;t;u;v;w;x;y;Ö;Ü;£;§;€;¶;ß;®;©;;´;¨;‚;Æ;Ø;ƒ;±;ª;»;•;<››››››—›—››››››››››››››È››› $ÑÑÑë$& #$a$ H<<<<<<<<<<›¯›››››››d +0Pƒ­/ ƒý=!ƒÝ"ƒÝ#êÝ$êÝ%ƒƒÝƒÝ. 00Pƒ­/ ƒý=!ƒÝ"ƒÝ#êÝ$êÝ%ƒƒÝƒÝ. 00Pƒ­/ ƒý=!ƒÝ"ƒÝ#êÝ$êÝ%ƒƒÝƒÝ. 00Pƒ­/ ƒý=!ƒÝ"ƒÝ#êÝ$êÝ%ƒƒÝƒÝ. 00Pƒ­/ ƒý=!ƒÝ"ƒÝ#êÝ$êÝ%ƒƒÝƒÝ+0Pƒ­/ ƒý=!ƒÝ"ƒÝ#êÝ$êÝ%ƒƒÝƒÝ+0Pƒ­/ ƒý=!ƒÝ"ƒÝ#êÝ$êÝ%ƒƒÝƒÝ iH@ÒH Normal1$7$8$H$OJQJ_HaJmH sH tH <A@Ú°< Default Paragraph Font4&@ÚÒ4 Footnote Reference2œO2 Level 1Ñ­Ñ0›^Ñ­`Ñ0›ß­!¾,ß1’1ä2~-~]~ç~‡~Ì~ABjêµø²ÏÌKâÃÒÚ  Ž#Elä´ø‹–—=>€¶ß[ \ € ¶ – — Ý ° Ù ž ß ® ¯ ˜ ú ù uv¶ß‘¦­=>ðÞÙž‘¦!!!Ò"Ú"##Ú$Û$%%%…%€&¶&)'*'))+),)k)l)‡)æ)º*‡*Ü+á+·+’+±,¾,@-A-ä-ã-../.è.ê.õ.´.¨.‚.Æ.Ž.//E/w/¾/’/ 0 090i0ç0º0Ú01C1f1å1£1§1€1¶1ß1®1©111…1ð1Þ1þ1ý1·1’1“1”1Â1Ò1Ú1222222222222222'242\2Å2Ç2É2Ñ2Ö2Ü2á2ã2ò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò`0ÄÄò 0ÄÄò0ÄÄò 0ÄÄò0ÄÄò 0ÄÄò0ÄÄò 0ÄÄò0ÄÄò 0ÄÄò0ÄÄò 0ÄÄò0ÄÄò 0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò`0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò`0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò 0ÄÄò0ÄÄò0ÄÄò`0ÄÄò0ÄÄò0ÄÄò 0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄöÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄöÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄò0ÄÄö@0ÄÄò@0ÄÄò@0ÄÄò@0ÄÄò@0ÄÄò@0ÄÄö@0ÄÄò@0ÄÄö@0ÄÄö@0ÄÄ 0ggggggggggggggggggggggggiiiiiikkkkkn<5°‘"Ý0F9s;<<689:;<=><7n!tïÄ$*/þ”5 < à Œ   ü ß õ§‘™œ®±†æ›?Gݮ˕|Ñÿý4"8"\"c"/#7#N#V#B$J$°$©$÷$Þ$Ì%Ù%* *Ù*˜*d+l+,,,%,ß,Ø,‹,÷,-Ø-Œ-Ð-$.,.‡/‰/‹/Ž/=0E0ì0ò0ü0§0¬0À0112à2ã2K]âõú®EMø­¸åû¯  ô´MvßØ|ä´#ƒ#Û$%n)u)¥,,ç-è-2à2ã23333333333333333322&2ã2 SSAMANIEGOC:\WINDOWS\TEMP\Monthly0502.wpdœêcvw*œDH‰œÝH‰PH‰ @­ Ñ­Ñ0›^Ñ­`Ñ0›OJQJo(_¨H‰ @­ Ñ­Ñ0›^Ñ­`Ñ0›OJQJo(ÿ•@HPLJ4LPT1:HPPCL5MSHP LaserJet 4PHPLJ4î@gœXX@MSUDHP LaserJet 4P”<d HPLJ4î@gœXX@MSUDHP LaserJet 4P”<d Ä”§dXl)l*l+l,l-l.ä2@@@.@0@2@4@6@p@UnknownGêá:Times New Roman5êÄSymbol3&ê á:Arial7"êUnivers;êÄWingdings71êCourier"Aà Ú­hrf¶rf¶?R)Xë Úê‹€¿xxÉ2æ2@ Úê‹þ SSAMANIEGO SSAMANIEGOœ ýÖüÚ˜Oh´ë+'„0lêò§ƒŸ­ÐÏ   ( 4 @LT\d”ss SSAMANIEGOSAMSAMNormalE SSAMANIEGO2AMMicrosoft Word 9.0@åÜG@<9œ¥¬@»øEµ¬?R)œ ¹Õ¹ú.ìó+,˜Æ0¯ hpåîú§ ¨¥ºŸ à ”CITY OF WEST COVINAXæ2Ý  Title  !"#$%&'()*+,-./0123456789:;<=>?œABCDEFGHIJKLMNœPQRSTUVœXYZ[\]^œ›aœœœRoot EntryArialConsole+Úø b ¿Furier Ne`€øIµ¬cÄ+Úø1Table—øw>Ÿ«bôÖAà1Comic Sans MS—øw>Ÿ«bôÖAàB  @ÂchweWordDocument—øw>Ÿ«bôÖAà"Mon+Úø b—øw>Ÿ«bôGSummaryInformation—øw>Ÿ«bôÖA(ookshelf Symbol 1+Úø bOøwDocumentSummaryInformationb8AàBookshelf Symbol 3W+ÚøCompObj>Ÿ«bôÖAà Arial Blackmbol 3—øw>Ÿ«bôÖAjquaObjectPool—øw>Ÿ«bôÖAà Cent`€øIµ¬`€øIµ¬Aà"  Impact Gothicl 3+Úø b—øw>Ÿ«bôÖA Outlookhicl 3+Úø b—øw>œœ  ¿FMicrosoft Word Document MSWordDocWord.Document.8Ù9¾q