SFUND RECORDS CTR

2201-00131

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

75 Hawthorne Street

San Francisco, Ca. 94105-3901

August 14, 1992

SFUND RECORDS CTR

88151632

MEMORANDUM

SUBJECT: Sola Optical Superfund Site Interim Close Out Report

FROM: Janet Kuefler

Regional Rotation Progra

THRU:

TO:

Michael Montgomery

Remedial Project ManagerNathan Lau, Chief

Enforcement Response 'Section

" Nancy"~Lindsay7^Chief

Superfund Enforcement Branch

Keith A. Takata

Deputy Director for Superfund

Jeff ZeZiksan, Director

Hazardous Waste Management Division

Daniel W. McGovern

Regional Administrator

This Superfund Site Interim Close Out Report has been

prepared to support recategorization on the National Priorities

List (NPL) of Sola Optical USA in Petaluma, California.. This

site is undergoing long-term remedial action and the construction

phase of the action is complete and operating properly. A precertification inspection was completed on July 20, 1992, to

determine that the remedy was constructed in accordance with

design specifications. The Sola Optical site therefore

qualifies for reclassification to the Construction Completion

category of the NPL.

The attached report has been prepared in accordance with the

"Procedures for Completion and Deletion of NPL Sites." (OSWER

Directive 9320.2-3A, dated September 1991). This report has been

reviewed and approved by Headquarters.

Printed on Recycled Paper
SUPERFUND SITE INTERIM CLOSE OUT REPORT

Sola Optical USA

Petaluma, California

I. SUMMARY OF SITE CONDITIONS

Background

Sola Optical USA is located at 1500 Cader Lane in southern

Sonoma County, California, on the southeastern edge of the City

of Petaluma. Sola has been manufacturing hard-resin ophthalmic

lenses since 1978 at its 35-acre facility in Petaluma's

industrial area. The site was proposed for inclusion on the

National Priorities List (NPL) in June 1988, due to solvents in

the ground water. Final NPL listing occurred in February 1990.

The manufacturing process involves the injection of a

catalyzed, thermosetting resin into a cavity between polished

glass molds. The mold assembly is subsequently placed in an air

oven to cure the resin. The assembly is removed from the oven,

the cured resin lenses removed from the assembly, and the

assembly is put through a cleaning process before production is

repeated.

The facility is located in an area zoned for industrial

uses. Residential subdivisions are located about 300 feet

northwest of the site. Property adjacent to the site is used for

office space and manufacturing; some of the adjacent land is

undeveloped.

Sola identified solvents in the ground water under the Sola

property near six underground solvent storage tanks. Sola used

these six 1,000 gallon underground tanks to store 1,1,1-

trichloroethane (1,1,1 TCA), acetone, and methanol. In July

1985, Sola independently removed the underground tanks. The

removal of the tanks reportedly included the excavation of gravel

back-fill and an additional three (3) feet of native soil from

the sides and bottom of the tank excavation. Sola collected

twenty-two (22) soil samples from the excavation pit. Based on

the analysis of these soil samples, Sola excavated an additional

two (2) feet from the eastern wall of the excavation pit. In

July 1986, additional samples taken following the excavation

indicated the presence of volatile organic compounds (VOC's);

however, no additional excavation was conducted.

Sola's early investigation also confirmed that ground

water at the site was contaminated with VOC's, including 1,1,1-

TCA, 1,l-dichloroethane (1,1-DCE), 1,1-dichloroethane (1,1-DCA),

and methylene chloride. In 1983, the San Francisco Regional

Water Quality Control Board (SFRWQCB) directed Sola to

investigate the ground water at the site. In 1987, the SFRWQCB
issued Sola a Cleanup Order to construct a ground water

extraction and treatment system. In August 1988, Sola began

operating its ground water extraction and treatment system. Sola

currently discharges the treated ground water to Adobe Creek

under a National Pollutant Discharge Elimination System (NPDES)

permit from the SFRWQCB.

In April 1990, EPA required Sola to collect and analyze

subsurface soils and soil gases. Contaminants in soils did not

exceed leachable levels that would result in ground water

contamination above maximum contaminant levels (MCL's).

Remedial Planning Activities

The Sola facility was proposed for the National Priorities

List (NPL) in June 1988. EPA found Sola Optical USA to be the

sole potentially responsible party for the site. A General and

Special Notice was issued to Sola prior to negotiations. Sola

has financed and conducted a Remedial Investigation/Feasibility

Study (RI/FS) under an EPA Administrative Consent Order (Docket

#89-22), signed in October 1989.

The Remedial Investigation included sampling of soils, soil

gas, and ground water. The Remedial Investigation Report, which

summarized these activities, was submitted by Sola on December 3,

1990. EPA completed the Risk Assessment in April 1991.

The Feasibility Study was submitted by Sola on June 10,

1991. The proposed cleanup levels for ground water contaminants,

listed below, were based on the lower of State and Federal

drinking water standards.

Table 1. Clean-up Levels for Ground water,

Sola Optical site parts per billion (ppb)

Chemical

1, 1-Dichloroethylene

1, 1-Dichloroethane

1,1, 1-Tr ichloroethane

Freon 113

Clean-up Level

parts per billion (ppb)

6

5

200

1,200

Five alternatives, including no-action, were evaluated for

remediating the aquifer. Under the no-action alternative, it was

predicted that cleanup levels would be achieved by natural

attenuation within 500 years.
EPA issued the Record of Decision (ROD) for the site on

September 27, 1991. The selected remedy includes:

Continued operation of the existing extraction well,

installation of two additional shallow extraction

wells, and conversion of two deep monitoring wells into

extraction wells.

Treatment by carbon adsorption if the water is

discharged to Adobe Creek. Alternatively, the water

may be discharged to the city sewage treatment

facility. The city has an industrial discharge limit

of 1 part per million for total toxic organics.

Under this alternative, it was estimated that the cleanup levels

would be achieved in 15-20 years. The cost of the selected

remedy is estimated to be between $2.1 and $2.2 million.

Remedial Construction Activities

The installation of the two additional shallow extraction

wells and the conversion of the two monitoring wells into

extraction wells were completed by April 30, 1992. These wells

were connected to the existing ground water treatment plant which

continued to treat water pumped from the nine previously existing

extraction wells. EPA inspected the ongoing construction of the

extraction wells on April 21, 1992.

Community Relations Activities

Two fact sheets were prepared describing the investigation

and cleanup activities at the Sola site. In June 1991 EPA issued

the proposed cleanup plan, and opened a 30-day public comment

period on June 17, 1991. A public meeting describing the RI/FS

and proposed plan was held in Petaluma on June 25, 1991.

II. DEMONSTRATION OF QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)

FROM CLEANUP ACTIVITIES

The QA/QC program used throughout the remedial investigation

and during the remedial action has been sufficiently rigorous to

enable EPA and the State of California to determine that all

analytical results are accurate to the degree needed to ensure

satisfactory execution of the ROD. All monitoring was performed

using EPA-approved methods.
III. MONITORING RESULTS

Sola was required to monitor ground water wells three times

per year. In March 1992, this schedule was modified based on

historical VOC concentrations, ground water flow gradients, and

well locations. Routine monitoring and reporting of the quality

of ground water from the monitoring and extraction wells will

occur on a quarterly, semiannual, or annual basis.

Recent monitoring results show concentrations above the

cleanup criteria for 1,l-Dichloroethene and 1,1-Dichloroethane in

several wells. Based on this data, quarterly monitoring is now

required for thirteen wells, including those with the highest VOC

levels, so that the effectiveness of the extraction system can be

evaluated. Six additional monitoring wells will be monitored

semiannually, and eight wells will be monitored annually. EPA

took split samples with Sola's contractor from seven monitoring

wells on June 26, 1992.

Sola will initially be discharging the treated ground water

to Adobe Creek. Sola may in the future discharge some or all of

the ground water to the City of Petaluma"POTW, and this discharge

would be subject to industrial pretreatment limits.

IV. SUMMARY OF OPERATION AND MAINTENANCE

The extraction and treatment system was inspected by the EPA

Remedial Project Manager and a Representative from the State of

California on July 20, 1992. The Remedial Action Report

submitted by Sola certifies that the plant is operating and that

all construction at the site is complete. The San Francisco

Regional Water Quality Control Board also provided final

certification of the implementation of the remedy. The plant

will continue to be operated by the PRP.

As the construction phase of the remedy is complete and

operating properly, the site meets the requirements for inclusion

in the Long-term Response Action subcategory of the Construction

Completion category of the NPL. Ground water cleanup standards

are expected to be achieved in 15-20 years, at which time pumping

will cease and no further operation and maintenance will be

required.

V. SUMMARY OF FIVE YEAR REVIEW STATUS

Section 121(c) of the Comprehensive Environmental Response

Compensation and Liability Act (CERCLA) requires that EPA review,

no less often than each five years, any remedial action selected

that results in any hazardous substances, pollutants, or

contaminants remaining at the site. The ROD for the Sola Optical
site contains cleanup levels that, when attained, will allow

unlimited use and unrestricted exposure. OSWER Directive 9355.7-

02 (Structure and Components of Five-Year Reviews," May 23, 1991)

provides that EPA will conduct five-year reviews as a matter of

policy (Policy Review) at sites where hazardous substances will

remain above levels that allow unlimited use and unrestricted

exposure after completion of construction of the remedial action,

but the clean-up levels specified in the ROD will require five or

more years to attain.

The site's treatment system was functional in 1988, so the

site will be subject to a five-year review in 1993. Based on the

five-year review, EPA, in consultation with the State of

California, will determine whether human health and the

environment are being protected by the remedial action being

implemented.

VI. PROTECTIVENESS

This Interim Closeout Report will be amended when all ROD

cleanup objectives have been achieved, and confirmatory ground

water sampling demonstrates that the site no longer poses any

threat to human health and the environment.

A site map and a list of reports relevant to the completion

of this site under the Superfund program are attached.

Approved By: Disapproved By:

Daniel W.McGovernDat e Daniel W. McGovern Date

Regional Administrator Regional Administrator
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SITE AND VICINITY PLAN

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Attachment B

References

1. Remedial Investigation, Sola Optical Superfund Site,

Petaluma, California, December 3, 1990.

2. Feasibility Study, Sola Optical Superfund Site, Petaluma,

California, June 10, 1991.

3. Record of Decision, Sola Optical Superfund Site, Petaluma,

California, EPA Region 9, September 27, 1991.

4. Joint EPA/State Certification of Implementation of Remedy,

Sola Optical Superfund Site, Petaluma, California. EPA

Region 9 and San Francisco Regional Water Quality Control

Board, July 20, 1992.
ROUTING AND TRANSMITTAL SLIP

Data

July 31, 1992

Action

Approval

As Requested

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REMARKS

Sola Optical Superfund . Site Interim Close Out Report.

•tf-Tfr

DO NOT use this form as a RECOIi

clearances,

of approvals, concurrences, disposals.

similar actions

FROM: (Name, org. symbol. Agency/Post)

Janet Kuefler (x!629)

VMSkshael Montgomery (x2403)

Room No.—Bldg.

H-7-1

Phone No.

* l*S.i(3PO: 1990 — 262-080

OPTIONAL FORM 41 (Rev. 7-76)

PmcrilMd by GSA

FPMR (41 CHI) 101-11.206