Responsiveness Summary
Deletion of Surface Soil from National Priorities List
Pacific Coast Pipe Lines Superfund Site

March 2018

Introduction
A Notice of Intent for Partial Deletion for the Pacific Coast Pipe Lines Superfund Site was published in the Federal Register on December 26, 2017 (82 FR 60943-60946). The publication of this notice was intended to inform the public that EPA planned to delete the surface soil portion of the site from the National Priorities List (NPL), and provide a 30-day public comment period on the proposed deletion. The closing date for comments on the Notice of Intent for Partial Deletion was January 25, 2018. Eight written comments were received: five supporting EPA’s decision, two opposing, and one that was not related to the proposed partial deletion. These comments are available in the Information Repositories. All public comments were considered in EPA’s final decision to delete the Site from the NPL.

Responsiveness Summary
The Responsiveness Summary has been prepared to provide responses to comments submitted to EPA during the 30-day public comment period regarding the Notice of Intent to Delete (82 FR 60943-60946) the Pacific Coast Pipe Lines (PCPL) Superfund Site. The original comments are summarized below and available at http://www.regulations.gov, Docket ID No. EPA-HQ-SFUND-1989-0011, with the support materials under document type “Public Submissions”, and at the information repositories at the following addresses:
Superfund Records Center, 75 Hawthorne Street Room 3110, San Francisco, California, Hours: 8:00 AM – 4:00 PM; (415) 947-8717.
Site Repository: Fillmore Library, 502 2nd Street, Fillmore, California. Call (805) 5243355 for hours of operation.
Summary of Adverse Comments:
· The soil portion of the site should be kept on the National Priorities List (list of Superfund sites) (two commenters).
· Concerns raised by the commenters include: contaminated soil remains on the property; contaminated soil was disposed on-site in consolidation areas; EPA needs to let the public know where the consolidation areas are and where benzene is in the groundwater; residents could be exposed to contaminated soil in the future because of a natural disaster.

EPA’s Response:
The remedial action objectives and associated cleanup levels established in the Record of Decision Amendment (2011) are intended to protect human health and 2 the environment. Confirmation sampling indicates that all contaminants of concern in the PCPL Site’s soil are below the cleanup levels specified in the ROD Amendment. Although the surface soil still contains low levels of lead and polycyclic aromatic hydrocarbons at concentrations that EPA does not consider safe for residential use, the surface soil has been cleaned up to a level that allows for commercial and recreational use of the former refinery, which are the permissible future land uses (see further discussion below). Soil containing higher concentrations of contamination were excavated from across the PCPL Site and deposited at a minimum depth of ten feet below ground surface in two on-site consolidation areas that are under multi-layer engineered caps, designed to prevent leaching of contaminants into groundwater. At these depths, the more highly contaminated soil that was found at the PCPL Site is secure and poses no threat to human health or the environment.
· The Final Soil Operation, Maintenance, and Monitoring Plan establishes an inspection, monitoring, and maintenance program and a schedule of activities.
· There are land use covenants to ensure that cap integrity will be maintained and that future use of the property is restricted to commercial and recreational uses.
EPA, DTSC, and Texaco, Inc. developed a land use covenant to restrict the use of the Site. This covenant was recorded at the Ventura County Recorder's Office on August 19, 2016, and “runs with the land,” meaning the restrictions are binding on current and subsequent property owners.
· Because the site is not available for unlimited use or unrestricted exposure, EPA will review the effectiveness of the soil cleanup at the PCPL Site every five years to determine whether the cleanup remains protective of human health and the environment.
· The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) establishes criteria that EPA uses to delete sites from the NPL. In consultation with California’s Department of Toxic Substances Control, EPA has determined that the criterion for delisting the PCPL Site has been met: the responsible party, Texaco, Inc., has implemented all appropriate response actions for surface soil set forth in the 2011 ROD Amendment (which selected the remedy for contaminated soils at the PCPL Site), and no further response action for soil is necessary.
· Deleting the surface soil portion of the PCPL Site from the NPL does not prohibit EPA from taking actions, as appropriate, to protect human health and the environment, including during natural disasters. Nor does it release responsible parties from legal liability for response actions at the PCPL Site that are necessary to protect human health and the environment. All releases deleted from the NPL are eligible for further remedial actions if warranted and, in the event there is a significant release from the surface soil portion of the PCPL Site in the future, EPA can restore it to the NPL.
· The locations of the two plumes of benzene in groundwater and the two consolidation areas are shown in the PCPL Soil Remedial Action Report 2016, Figures 2 and 3, respectively. This report was included in the online deletion docket at Regulations.gov and included in the PCPL Site information repositories as a supporting document. It is also available at the EPA website www.epa.gov/superfund/pacificcoastpipeline under Site Documents & Data. The 3 groundwater cleanup continues at the PCPL Site and is not affected by this partial deletion.
. Summary of Supportive Comments:
· Several commenters stated that partial deletion of the soils portion of the PCPL Site could benefit local government and residents by reducing the perceived stigma of a Superfund site designation. The partial deletion could also benefit nearby property values, facilitate recreation activities and access, and provide beneficial reuse opportunities for the community.
· A business leasing the PCPL Site states that reduced liability insurance costs and reduced investor concerns could result from the partial deletion of the PCPL Site.
In addition, one comment received discussed California wildfires and air pollution. It was not considered to be related to the proposed deletion of the PCPL Site.