cooper drum co.

9316 ATLANTIC AVE

The Cooper Drum Superfund Site is a 3.8-acre facility located at 9316 South Atlantic Avenue in South Gate, California. The Site is in an urban area of mixed industrial, commercial and residential uses. Rayo Avenue borders the site to the east and the former Tweedy Elementary School property is located directly to the south. From 1941 until 1992, Cooper Drum Co. reconditioned closed-topped, steel drums that previously held a variety of industrial chemicals. The reconditioning process consisted of flushing out and stripping the drums for painting and resale. Heavy duty cleaning called hard washing was performed in the northeast portion of the Site (the former hard wash area, or HWA), when necessary. Beginning in 1976, reconditioning activities took place within the present-day drum processing area (DPA) located in what is now the central portion of the Site. Fluids generated by reconditioning and hard washing activities were collected in open concrete pits and trenches. This led to the contamination of the soil and groundwater beneath the site. Previous investigations have shown that contamination at the Site can be traced to the HWA and the DPA. In April 1987, the Los Angeles County Health Department (LACHD) Emergency Response Team responded to an incident at the Tweedy Elementary School property. An unknown quantity of highly caustic liquid waste had migrated via underground seepage from the Cooper Drum Co. property. The waste resulted from the caustic wash water from the drum recycling process line located in the building directly north of the school property. Initially, the waste was thought to comprise mainly sodium hydroxide and oil. When contamination migrated onto school property, the top layer of soil was excavated and the area was paved. Due to public health concerns, Tweedy Elementary School has remained closed and the property is currently used for school district administrative and maintenance functions. Municipal wells located within 4 miles of the site supply drinking water to approximately 335,000 people; the nearest of these wells is located within 1/2 mile of the site. An estimated 340,000 people live within 4 miles of the site. By 1992, when the drum reconditioning business had been sold to Waymire Drum Company, the Cooper Drum site facilities were retrofitted to provide better environmental protection. An aboveground, enclosed system for containing liquids and wastes was installed including closed-top steel tanks and hard piping to replace the open pits, sumps, and trenches. The former hard-wash area (HWA) was closed and replaced with a new HWA in the Drum Processing Area (DPA), which also provided hard piping and secondary containment. All buildings have concrete floors and the entire facility was paved with asphalt . Since 1992, drum processing operations have not resulted in any release of hazardous substances into the soil or groundwater beneath the site. Waymire Drum Company continued to operate the facility until 1996. Consolidated Drum Company was the drum-reconditioning operator at the Site from 1996 until their departure in 2003. The facility was fitted to process plastic totes (large square containers) during this period. Since 2003, drum processing operations no longer occur at the Site and all drum processing equipment has been removed from the Site. Following the removal of the drum processing operations, there were four new tenants at the Site, including a pallet company, a trucking and towing company, and two automotive repair/ salvage companies. As of June 2006, the automotive repair/salvage companies moved operations off site and the pallet company expanded there operations to the entire property. The Cooper Drum Site was placed on the Superfund site list on June 14, 2001. EPA completed its Remedial Investigation of the Site in May 2002. The investigation concluded that substantial portions of the soil and groundwater beneath the Site have been contaminated by volatile organic compounds (VOCs), mainly chlorinated solvents such as trichloroethene (TCE) and isomers of dichloroethene (DCE) and dichloroethane (DCA). Other contaminants of concern are 1,4-dioxane in the groundwater and polyaromatic hydrocarbons (PAHs), polychlorinated biphenols (PCBs) and lead in the soil. Based on field investigations, it was determined that the groundwater contamination is only present in the shallow groundwater and has not vertically migrated to the deeper aquifers from which municipal wells draw water. EPA also performed a Feasibility Study to evaluate potential alternatives to clean up the contaminated soil and groundwater at the Site. In September 2002, EPA issued a Record of Decision (ROD) which selected the remedial actions for the Site. The groundwater remedy consists of using a combination of in situ chemical oxidation (ISCO) to enhance treatment of VOCs and 1,4 dioxane in the source area, and extraction and treatment of the contaminated groundwater. The selected soil remedy for VOCs consists of using dual phase extraction (DPE) due to the presence of a perched aquifer. DPE is a process in which contaminated soil vapors and groundwater are extracted simultaneously for treatment of VOCs. The selected soil remedy for non-VOCs (i.e. PAHs, PCBs and lead) is excavation and off-site disposal. Institutional controls, which would limit access and soil disturbing activities, will be required in areas where excavation is not feasible. EPA completed the Soil and Groundwater Remedial Design (RD) reports in September 2007. During the RD two in situ treatability studies were completed, which evaluated using an ISCO treatment technology injecting ozone and hydrogen peroxide into the contaminated groundwater, and a reductive dechlorination technology injecting a HRC into the groundwater. The ISCO study showed significant reductions of both VOCs and 1,4 dioxane in the groundwater and is an innovative technology for in situ treatment of these contaminants. HRC was effective on VOCs only. These, treatment technologies were included in the RD to implement the in situ portion of the groundwater operable unit (OU) 1 remedy. Extraction and treatment was also chosen to complete the groundwater remedy. The soil (OU2) remedy included use of DPE in the two source areas (HWA and DPA) of the site. As a result of continued migration of the contaminated groundwater and commingling with other plume(s) in the downgradient area, additional field sampling and ground water pump testing are necessary to identify the downgradient plume boundary and areas of commingling prior to implementation of the groundwater remedy. The site has transitioned from a fund lead site to a PRP enforcement lead site. Special notice letters were sent in May 2008 to 68 PRPs for them to take over the remedial action (RA) and pay past site costs. In February 2009, EPA issued a Unilateral Administrative Order (UAO) to 43 PRPs to conduct the RA for soil and ground water. The PRPs have formed a Cooper Drum Coordinating Parties Group (CDCPG) and have complied with the UAO. EPA will oversee the cleanup of soil and groundwater contamination at the Cooper Drum Site, which is being performed by the CDCPG responsible parties who contributed to this contamination. EPA recently approved work plans for soil and groundwater cleanup. Construction of the Soil Vapor Extraction (SVE) treatment system has been completed and the system began operating in February 2011. Construction of the Groundwater Treatment System was completed in September 2011. The Dual Phase Extraction (DPE) Wells began operating in April 2012 after the wastewater discharge permit was obtained form the Los Angeles County Sanitation District. The DPE wells extract contaminated water from the perched aquifer and allow the SVE system to remove and treat the contaminated soil vapor from this perched zone. The extraction and treatment of contaminated groundwater from the aquifer beneath the Site began in August 2012 from an on-site groundwater extraction well. The next step is to construct the remaining extraction wells and conveyance piping off-site across Rayo Avenue in order to begin treating the contaminated groundwater plume which extends to Southern Avenue.