ri.
                               PB99-963807
                               EPA541-R99-085
                               1999
EPA Superfund
      Record of Decision:
      Federal Creosote Site OU 1
      Manville, NJ
      9/28/1999

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                NOTE

Some parts of this document may be illegible.
The document was copied, unaltered, from
originals received by the source (EPA).

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               DECLARATION FOR THE RECORD OF DECISION

 SITE NAME AND LOCATION

 Federal Creosote Superfund Site
 Borough of Manville, Somerset County, New Jersey

 STATEMENT OF BASIS AND PURPOSE

 This Record of Decision (ROD) documents the U.S. Environmental
 Protection Agency's selection of an early interim remedial action
 to address source material at the Federal Creosote site, in
 accordance with the requirements of the Comprehensive
 Environmental Response,  Compensation and Liability Act of 1980
 as amended (CERCLA) [42  U.S.C. §9601-9675], and to the extent '
 practicable,  the National Oil and Hazardous Substances Pollution
 Contingency Plan,  as amended, 40 CFR Part 300.   This decision
 document explains the factual and legal basis for selectina the
 remedy for the first operable unit of the site.

 The New Jersey Department  of  Environmental Protection (NJDEP)  has
 £e,!;2T £onsult^? °n the Planned remedial action in accordance with
 CERCLA §121(f)  [42  U.S.C.  §962l
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 •    Transportation of the source material for off-site thermal
     treatment and disposal.

 DECLARATION OP STATUTORY DETERMINATIONS

 This interim action is protective of human health and the
 environment for a portion of the site, and is intended to provide
 an early response to the principal threats before the final ROD
 is signed for the site.  This action complies with those federal
 or state requirements that are applicable or relevant and
 appropriate for this limited scope action, and is cost-effective.
Although this interim action is not intended to address the site
 fully, the statutory mandate for permanence and treatment was met
 to the maximum extent practicable. In addition, this interim
action utilizes treatment as a principal element of the remedy,
and thus supports that statutory mandate.  Because this action
does not constitute the final remedy for this site,  the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element, although
partially addressed by this remedy,  will also be addressed
further by additional response actions.  Subsequent actions are
planned to address fully the threats posed by conditions at this
site.

Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted to
ensure that the remedy continues to provide adequate protection
of human health and the environment within five years after
commencement of the remedial action.  Because this is an interim
action ROD,  review of the site and remedy will be ongoing as EPA
continues to develop remedial alternatives for the site.
     Jean:
 Regiona

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                RECORD OF DECISION


                 DECISION SUMMARY


               Federal Creosote Site


Borough of Manville,  Somerset  County, New Jersey
     United States Environmental Protection Agency
                     Region II
                 New York, New York
                   September 1999

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                           TABLE OF CONTENTS

 SITE NAME,  LOCATION AND DESCRIPTION

 SITE HISTORY AND ENFORCEMENT ACTIVITIES  	  1

 ENFORCEMENT ACTIVITIES   	  4

 HIGHLIGHTS  OF COMMUNITY PARTICIPATION '	4

 SCOPE AND ROLE OF RESPONSE ACTION	5

 SUMMARY OF  SITE  CHARACTERISTICS  .     	6

 SUMMARY OF  SITE  RISKS	      	    7

 REMEDIAL ACTION  OBJECTIVES	,	  8

 DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES  	  9

 SUMMARY OF  COMPARATIVE ANALYSIS OF ALTERNATIVES  	   12

 SELECTED REMEDY	   17

 STATUTORY DETERMINATIONS  	   18

DOCUMENTATION OF SIGNIFICANT CHANGES	20

  APPENDICES
                      i
  APPENDIX  I     FIGURES
  APPENDIX  II    TABLES
  APPENDIX  III   ADMINISTRATIVE  RECORD INDEX
  APPENDIX  IV    STATE  LETTER
  APPENDIX  V     RESPONSIVENESS  SUMMARY

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SITE NAME LOCATION AND DESCRIPTION

The site is  located in the Borough of Manville, Somerset County,
New Jersey  {see Figure 1 in Appendix I), and is currently an
active residential community of single-family homes on
approximately 35 acres.

The site is  located within the Raritan River watershed system.
The Raritan  River is located approximately 2,000 feet north and
east of the  site and the Millstone River is located approximately
1,200 feet to the southeast.  It is situated on a topographic
high that is nearly equidistant from the Raritan and Millstone
Rivers and approximately a mile west (upstream) of their
confluence.  The site is bordered to the west by a variety of
commercial uses, including the Rustic Mall.  To the north, on the
opposite side of the Norfolk Southern railroad tracks, is the
'former Johns-Manville property.  The Johns-Manville company
property has been redeveloped for a variety of commercial and
retail uses, including automobile storage, warehousing, and large
retail stores.  To the south, on the opposite side of the CSX
tra'cks, the  area is primarily residential.

SITE HISTORY

The site was the location of a wood treatment operation beginning
in approximately 1910.  During the operations untreated railroad
ties were delivered to the site by rail and were processed in a
treatment plant located on the western portion of the property.
Coal tar creosote was applied to the railroad ties in this area
of the property.  Treatment residuals from the plant were
discharged into two unlined canals.  One canal directed the flow
of the treatment residuals to the northern portion of the
property for a distance of approximately 375 feet where the canal
contents entered an unlined lagoon.  The other canal directed the
flow of treatment residuals toward the southern portion of the
property, where the contents of this canal spilled into another
unlined lagoon located approximately 1,500 feet from the
treatment plant.  After treatment, the railroad ties were moved
from the plant to the central portion of the property where the
excess creosote dripped from the treated wood onto the ground.

Land use patterns on the Federal Creosoting Company property
remained the same until the mid-1950s when the wood treatment
plant ceased operations and was dismantled.  During the late
1950s and early 1960s, the area that formerly housed the
treatment plant was developed into a 15-acre commercial and
retail property known as the Rustic Mall.  Through the early to
mid-1960s, 35 acres of the former Federal Creosoting Company
property, including the drip area, canals and lagoons, were
developed into the Claremont Development which is made up of 137
single-family homes.

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 In April  1996,  NJDEP responded to an incident  involving  the
 discharge of an unknown liquid from a sump  located at one of the
 Claremont Development residences  on Valerie Drive.  A thick,
 tarry substance was  observed flowing from the  sump to the street.
 In January 1997,  the Borough of Manville responded to a  complaint
 that  a sinkhole had  developed around a sewer pipe in the
 Claremont Development along  East  Camplain Road.  Excavation of
 the soil  around the  pipe identified a black tar-like material in
 the soil.   Subsequent investigations of these  areas revealed
 elevated  levels of contaminants consistent  with creosote.

 Following the discovery of this material, NJDEP, with technical
 assistance from EPA,  began an investigation of the site.  In
 April and May 1997,  air samples were collected inside the
 majority  of homes in the Claremont  Development.  With the
 exception of one house,  the  analysis of these  samples indicated
 that  the  site-related contaminants  were not present in the homes
 at  elevated levels.

 In  October 1997,  EPA's Environmental Response  Team (ERT)
 initiated a site investigation limited to properties believed to
 contain creosote contamination based on analysis of historical
 aerial  photographs as well as input  from residents.  This
 investigation included the collection of surface and subsurface
 soil  samples at  select locations  within the residential
 development.  Over 100 surface and  subsurface  soil samples were
 collected.   These sampling results,  contained  in the November
 1998  report entitled "Technical Memorandum  - Site Investigation
 Report",  indicated that  the  canals  and lagoons still exist
 beneath the Claremont Development.   The result of this
 investigation indicate that  the contamination  is extensive, is
 uncontrolled, and has impacted sediment, soil  and groundwater in
 the area.

 In January 1998,  responsibility for  the site was transferred from
 NJDEP to EPA.

 Prom  February through April  1998, ERT collected over 1,350
 surface soil  samples  on  133  properties  in and adjacent to the
 Claremont  Development in order to determine if an immediate
 health risk existed.   The results of  the surface soil sample
 analyses,  which were  made available  to  each individual property
 owner, were reported  in  the  "Interim Surface Soils Human Health
 Risk Assessment", dated  January 19,  1999.  EPA identified 19
properties  with  surface  soil  in yards  containing elevated levels
 of creosote related contaminants.  While the levels were
 elevated,  a risk  assessment  showed that they did not pose a
 short-term (acute) risk  to residents.  However, the risk
 assessment  did show that the  levels exceed EPA's acceptable risk
 range for  carcinogens  and pose a long-term risk.  Therefore, EPA
 applied topsoil, mulch,  seed  and sod  on properties that contained

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 elevated levels of creosote in surface soils, to limit the
 potential for exposure.  In addition, EPA installed an odor
 control system in the basement of one property and installed a
 storm water drainage system on one property.

 In February 1999, the Agency for Toxic Substances and Disease
 Registry (ATSDR)  completed a health consultation that assessed
 the public health impact from direct contact with the surface
 soils.  ATSDR concluded that the surface soil concentrations of
 lead, arsenic and PAHs do not pose a public health hazard.

 The groundwater beneath the site is classified by NJDEP as  IIA,
 potable water.   It is currently a source for the public water
 supply and,  based upon NJDEP classification is expected to
 provide drinking water in the future.  As part of its site
 investigation,  ERT installed 17 groundwater monitoring wells to
 begin the investigation into the extent of groundwater
 contamination.   The public water supplies and monitoring wells
 installed in and  around the site were sampled for any site-
 related contamination in March and April 1998 by ERT.   The
 results of  this sampling indicated that the public water supplies
 are not currently being affected by contamination from the site.
 However,  the results of the groundwater sampling from monitoring
 wells located on  the site do indicate that the groundwater is
 contaminated with components of creosote.   A comprehensive
 groundwater  investigation is being conducted to complete the
 characterization  of  the groundwater conditions in the  area
 surrounding  the site.

 In  November  1998,  EPA initiated a remedial investigation and
 feasibility  study (RI/FS)  to more fully characterize the nature
 and extent of contamination at  the site.   Subsurface soil
 sampling started  in  December 1998 and was  completed in March
 1999.   Over  230 borings  were installed,  and  approximately 2,000
 soil  samples have  been  collected  for  analysis.   In contrast  to
 ERT's investigation, which  focused on the  lagoon  and canal areas,
 this  investigation will  characterize  deep  soils throughout the
 entire  Claremont Development.   In addition,  the results of this
 sampling will provide more  accurate data concerning the  lateral
 and vertical extent of the  lagoon and canal  source areas.

 In  March 1999, as part of the RI,  a more extensive groundwater
 investigation was  initiated to characterize  the vertical and
 lateral extent of groundwater contamination  caused by the site.
Approximately 30 additional monitoring wells will be installed
 and tested in areas surrounding the development.  Several of the
 subsurface boring holes  from the  soil investigation have been
 converted into shallow monitoring wells that, when sampled,  will
provide information on the quality of shallow groundwater at the
 site.  In addition, sediment samples in the Millstone River and
Raritan River will be taken as part of the RI to determine if the
site has impacted the river.

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Completion of the field work for this broader site investigation
is expected in the fall of 1999.  Following these investigations,
EPA will evaluate what other remedies may be necessary to address
the site.

The site was proposed for the National Priorities List (NPL) on
July 27, 1998, and was formally placed on the NPL on January 19,
1999.

The data from the 1997/1998 investigation conducted by ERT
indicate that the canal and lagoon areas are the major sources of
soil and groundwater contamination in the Claremont Development.
EPA then prepared an Engineering Evaluation/Cost Analysis (EE/CA)
to evaluate remediation options for only the lagoon and canal
source materials.  This EE/CA was completed in April 1999.

ENFORCEMENT ACTIVITIES

EPA has identified Federal Creosoting Company, and Kerr-McGee
Corporation as potentially responsible parties (PRPs). EPA sent a
general notice letter to one PRP for this site, Kerr McGee
Corporation.

HIGHLIGHTS OP COMMUNITY PARTICIPATION

The Proposed Plan and supporting documentation for the cleanup of
the lagoon and canals were released to the public for comment on
April 30, 1999.  These documents were made available to the
public at the EPA Administrative Record File Room, Room,  290
Broadway, 18th Floor, New York, New York; and at the Manville
Public Library, 100 South 10th Avenue, Manville, New Jersey
08835.

On April 30, 1999, EPA issued a notice in the Courier-News
newspaper which contained information relevant to the public
comment period for the site, including the duration of the
comment period, the date of the public meeting and availability
of the administrative record.  The public comment period began on
April 30, 1999, and was scheduled to end on June 1, 1999.  Due to
a request, the comment period was extended until June 25, 1999.
A public meeting was held on May 12, 1999, at the Weston
Elementary School located on Newark Avenue, Manville, New Jersey.
The purpose of this meeting was to inform local officials and
interested citizens about the Superfund process,  to discuss the
Proposed Plan and receive comments on the Proposed Plan,  and to
respond to questions from area residents and other interested
parties.  Responses to the comments received at the public
meeting and in writing during the public comment period are
included in the Responsiveness Summary (see Appendix V).

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 SCOPE AND ROLE OP RESPONSE ACTION

 The remedial action described herein addresses the principal
 threats associated with the Federal Creosote site.  The source
 material found in the canals and lagoons is a principal threat
 waste in that it is considered to be toxic and mobile,  cannot be
 reliably contained, and presents a significant risk to. human
 health or the environment should exposure occur.   This  remedial
 action pertains to the first phase,  or Operable Unit, at the site
 and is considered to be an earlv interim action that only
 addresses the cleanup of the highly contaminated  source areas:
 the lagoons and canals.  Based on the information EPA has
 obtained to date,  10 houses are located either directly over or
 immediately adjacent to the lagoons.   In addition,  the  canals and
 a trench exiting one of the lagoons  have been found on  22 other
 properties within the Claremont Development.   Portions  of the
 canals appear to lie underneath houses on some of the 22
 properties.

 The scope of this  Operable Unit is estimated  to include 32
 residential  properties:  10 properties associated  with the
 lagoons;  and 22  properties associated with the canals and the
 Lagoon A exit trench.   To the  extent  that  the lagoons and canals
 extend beneath public roads within the Claremont  Development,
 those  roads  would  also be included in the  Operable  Unit.

 EPA plans to initiate this remedial action in order to  address
 the principal threat  waste by  initiating a remedy for the source
 areas  as  early as  possible.  As described  below,  EPA's  action
 will require the permanent relocation of residents  from an
 estimated 10 to  19 properties,  so that  the houses can be
 demolished to excavate the contaminant  source  areas.  (The exact
 number of  permanent relocations needed  to  address the source
 areas  will be determined  after the ongoing subsurface
 investigations described  above are completed.)  Other residents
 may also require temporary relocation during the work of
 addressing the source  areas.   Because the permanent relocation
 and temporary relocation processes can be  time-consuming,  this
 early  interim action serves to initiate  the relocation process as
 early  as possible.  Until  the permanent  relocations are complete,
 EPA will not  begin any excavation activities.

 This ROD does not address  any potential  contamination on other
 residential properties within the Claremont Development, within
 the Rustic Mall, or in the groundwater.  This early interim
 action will be consistent, with the final remedy for the  site, and
 as  such, will not preclude the implementation of the final
remedy.  Any contamination from the Federal Creosote site found
 in these areas may be the subject of future actions.  The results
of EPA's investigations of the other 105 residential properties
in the Claremont Development were made available to the  residents

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of the  Claremont Development  in August 1999.  EPA expects to
issue a Proposed Plan  to  address those properties in the fall of
1999.

SUMMARY OF SITE CHARACTERISTICS

Preliminary determinations of the locations of the canals and
lagoons were based on  various historical aerial photographs  (see
Figure  2, Appendix I).  The locations of these source areas were
further refined by the subsurface soil investigation conducted in
1997 by ERT.  This investigation confirmed that the canals and
lagoons were not removed  before the Claremont Development was
built.  The canal and  lagoon found in the northern portion of the
Claremont Development  were designated as Canal A and Lagoon A,
respectively.  The maximum concentrations of total PAHs in Canal
A and Lagoon A are 21,206 parts per million (ppm) and 77,363 ppm
respectively.  The canal  and lagoon found in the southern portion
of the  development were designated as Canal B and Lagoon B,
respectively.  The maximum concentration of total PAHs found in
Canal B was 21,417 ppm; the maximum concentration of total PAHs
found in Lagoon B was  83,280 ppm.

The description and dimensions of the lagoons and canals provided
below is based on the  1997 ERT data.  Once the data is evaluated
from the 1998/1999 subsurface sampling activities, these
dimensions may change.  Canal A extends approximately 400 feet
from Valerie-Road, through four residential properties on Valerie
Drive to a point where it meets Lagoon A at 90 Valerie Drive.
The canal is approximately eight feet wide, four to eight feet
deep, with the upper surface about three feet below the present
surface of the yards (see Figure 3, Appendix I).

Lagoon  A is approximately 375 feet in length and extends through
the backyards of 90, 98,  104, and 110 Valerie Drive.  The top of
Lagoon  A is approximately eight to ten feet below ground surface
and the lagoon is at least six feet thick in some places.  In
addition, an exit trench  associated with Lagoon A apparently
served  as a drainage way  for overflow material to exit the
lagoon.  This exit trench has been found along the back property
lines of approximately four properties on Valerie Drive east of
Lagoon  A.

Canal B is approximately  1,500 feet in length and extends from
the parking lot of the Rustic Mall near Summit Bank, along the
north side of East Camplain Road, through 10 to 13 residential
properties, to a point where it meets Lagoon B at 186 East
Camplain Road.  Like Canal A, Canal B is approximately eight feet
wide.  Very little fill was found above Canal B.  The bottom of
Canal B is estimated to range from several inches to eight feet
below the ground surface.

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Lagoon B extends about 300 feet from southwest to northeast.  The
lagoon is located on properties at 186, 192, 198, 204, and 210
East  Camplain Road, and may extend into the back yard of 216 East
Camplain Road.

The yards of these properties slope downward from the rear of the
homes toward the back property boundary near the railroad tracks.
Total elevation change is about six feet.  Soil borings near the
rear  of the yards showed that the lagoon is within about two feet
of the surface.  Closer to the houses, the lagoon is about six
feet  below ground surface due to fill that was placed prior to
construction of the homes.  Lagoon B extends to a depth of 20 to
25 feet.

The total volume of the source areas is estimated to be 44,158
cubic yards based on the available data.  However, this volume
may change pending a review of the subsurface data.

SUMMARY OF SITE RISKS

PAHs  associated with creosote are the main contaminants of
concern at the site.  Samples taken from the site were analyzed
for volatile organic compounds (VOCs), semivolatile organic
compounds (SVOCs), and metals.  Among the SVOCs analyzed were 23
PAH compounds, seven of which are classified as probable human
carcinogens (see Table 1 in Appendix II).  Historically, PAH
compounds have been reported in several ways, including total PAH
concentration (TPAH), total carcinogenic PAH concentrations
(CPAH), and benzo [a]pyrene equivalents  (BAP).  TPAH is the sum of
all PAH concentrations in a sample and is always greater than or
equal to CPAH, which is the sum of the portion of PAHs classified
by EPA as carcinogenic.  BAP is a weighted concentration based on
the individual carcinogenic PAHs and can be used to assess the
carcinogenicity of CPAH in terms of benzo[a]pyrene, which is a
carcinogenic PAH that has been extensively studied.  See Table 2,
in Appendix II for concentrations of PAHs found in the lagoon and
canal areas of the site.

Data  from the site indicate that the ground water, a source of
drinking water,  is contaminated with creosote from the lagoons.
In addition, creosote was observed being discharged from a sump
in a  residence on Valerie Drive into the street.    PAHs, due to
their highly toxic and highly mobile nature at this site,  are
considered a principal threat.  For these reasons, action is
needed to address the principal threat source material in the
lagoon areas.

Although the quantitative risk assessment for the subsurface
soils has not yet been completed,  site information indicates that
an early interim action is needed quickly to prevent further
environmental degradation and achieve a reduction in risk while a

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final remedial solution is being developed.  Samples from the
lagoon areas show that the concentrations of PAHs in Lagoon A
were as high as 1,862 ppm, and PAHs in Lagoon B were found to be
as high as 2,548 ppm  (as BAP equivalents}.  Under a direct
contact residential scenario, PAH concentrations that are above 9
ppm  (BAP equivalents) exceed a 10-4 risk and indicate the need
for action.

The more specific findings of the baseline risk assessment and
the ultimate cleanup objectives for the site will be included in
a subsequent ROD for the site.

The response action selected in this Record of Decision is
necessary to protect public health or welfare or the environment
from actual or threatened releases of hazardous substances into
the environment.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human
health and the environment.  These objectives are based on
available information and standards such as applicable or
relevant and appropriate requirements (ARARs).

The following remedial action objectives were established for GUI
of the Federal Creosote site:

•    Clean up the canal and lagoon source areas to levels that
     will allow for unrestricted land use.

•    Remove as much source material as possible in order to
     minimize a potential source of groundwater contamination.

The current and reasonably anticipated future land use for most
of the areas affected by the canals and lagoons is residential,
and groundwater beneath the site is currently a source for the
public water supply and, based upon NJDEP classification, is
expected to provide drinking water in the future.

For this early interim action only, EPA has used a visible
contamination threshold as the remediation goal, for cost and
volume estimation purposes.  EPA has not yet completed the
baseline risk assessment and its associated quantitative
determination of cleanup levels.  Soil cleanup levels will be
developed prior to the excavation of the creosote source material
and any adjacent contaminated soil.  This will ensure that all
unacceptable material is removed in a single cleanup action.
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DESCRIPTION OF REMEDIAL ALTERNATIVES

Section 121(b)(1) of the Comprehensive Environmental Response,
Compensation and Liability Act  (CERCLA),  42 U.S.C. §9621 (b)  (I)/
mandates that a remedial action must be protective of human
health and the environment, be cost effective, and utilize
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
Section 121(b)(1) also establishes a preference for remedial
actions which employ, as a principal element, treatment to
permanently and significantly reduce the volume, toxicity,  or
mobility of the hazardous substances, pollutants and contaminants
at a site.  Section 121(d) of CERCLA 42,  U.S.C. §9621(d),  further
specifies that a remedial action must attain a level or standard
of control of the hazardous substances, pollutants, and
contaminants, which at least attains ARARs under federal and
state laws, unless a waiver can be justified pursuant to section
121(d)(4) of CERCLA, 42 U.S.C. §9621(d)(4).  CERCLA also requires
that if a remedial option is selected that results in hazardous
substances, pollutants, or contaminants remaining at a site above
levels that allow for unlimited use and unrestricted exposure,
EPA must review the action no less than every five years after
the start of the action.

Based on information acquired from evaluating and cleaning up
other wood treatment sites, EPA has undertaken an initiative to
develop presumptive remedies to accelerate cleanups at these
types of sites.  The objective of the presumptive remedies
initiative is to use the Superfund program's experience to
streamline site characterization and speed up the selection of
cleanup actions, ensure consistency in remedy selection, and
reduce the cost and time required to clean up similar sites.  In
accordance with this initiative, and relying on the Agency's
technology selection guidance for wood treatment sites, both
bioremediation and thermal treatment  (e.g., thermal desorption,
incineration) were considered for the Federal Creosote site in
the EE/CA.

In addition to the presumptive remedies, the EE/CA also
considered a No Action alternative as a baseline for comparison
with the/presumptive remedies.  Bioremediation, thermal treatment
and containment are technologies that are sometimes implemented
on site, but due to limited space, and the residential nature of
the community, the on-site application of these technologies was
eliminated during the screening phase.  As a result, this ROD
evaluates two remedial alternatives for addressing the
contaminated material associated with the lagoons and canals.  As
referenced below, the time to implement a remedial alternative
reflects only the time required to construct or perform the
remedy and does not include the time required to relocate
residents, design the remedy, and procure contracts for design

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 and construction.

 The remedial alternatives  for  the  site are:

  Alternative 1:      No Action

  Alternative 2:      Excavation and Off-Site Thermal Treatment and
                     Disposal

 Alternative  1;  No Actipn

 Capital  Cost:        $0
 Annual Operation and
 Maintenance  (O&M):   $0
 Present  Worth:       $0
 Time to  Implement:   not applicable

 The Superfund program  requires that the No Action alternative be
 evaluated at every site to establish a baseline for comparison.

 Under this alternative, no further remedial actions would be
 taken to address the source areas.  Because no action results in
 contaminants remaining on site above acceptable levels, the site
 would have to be reviewed every five years per the requirements
 of CERCLA.

 Alternative  2;  Excavation and Off-Site Thermal Treatment and
 Disposal

 Capital  Cost:        $59,100,000
 Annual Operation and
 Maintenance  (O&M):   $0
 Present Worth:       $59,100,000
 Time to  Implement:   2-3% Years

 Alternative  2 includes the excavation and off-site transportation
 of the source materials associated with the lagoons (including
 the Lagoon A exit trench) and  canals for thermal treatment and
 disposal.  For this  early interim action only.  EPA has used a
visible  contamination  threshold as the cleanup level for cost and
volume estimation purposes.  This is due to the fact that EPA has
not yet completed the  baseline risk assessment and its associated
 quantitative determination of  cleanup levels.   However, these
 subsurface soil cleanup levels can be developed prior to the
 excavation of the creosote source material and any adjacent
 contaminated soil.   This can ensure that all unacceptable
material is  removed  in a single cleanup action.

 The time to  implement  does not include the necessary preliminary
 steps of designing the remedy or permanently relocating
residents, which may each take up to one year,  but can be
 conducted concurrently.  In addition,  the time to implement is

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        as  a  range  due to uncertainties relative to the exact
 ?h!ri^°;Lhouses  that need to be underpinned prior to excavating,
 the extent  of excavations in the canals, the exact number of
 houses that need  to be temporarily and permanently relocated  and
 riL^I11!;  t0 ?£ich both Canal/Lagoon A and Canal/Lagoon B can be
 remediated  at the same time.  Concurrent remediation of these
 areas  may not be  feasible if it adversely restricts access to the
 development.  If  these areas are remediated sequentially, the
 time to implement will be lengthened; however,  the disruption to
 the whole development may be minimized.

 As mentioned previously,  EPA's proposed action would require the
 permanent relocation of residents from an estimated 10 to 19
 properties,  so that the houses can be demolished to excavate the
 source areas.   Investigations to date indicate that ten houses in
 the Claremont  Development have been built on top of or adjacent
 to the lagoon source areas and nine houses may have been built on
 the canal source areas.

 For houses that  may be  located on the canal source areas,  the
 number of permanent relocations needed to excavate the canals
 will be determined after  the  ongoing subsurface investigation is
 completed.

 For the purpose  of excavating the lagoons,  the  affected
 properties would need to be acquired by EPA and the  residents
 permanently  relocated.  Following permanent relocation,  the
 houses  on these  properties would be  demolished.   Based on  current
 data, Lagoon A is  believed to be located beneath  the  followina
 properties:  90 Valerie Drive,  98 Valerie Drive, 104 Valerie
 Drive,  and 110 Valerie Drive.   It is  estimated  that Lagoon A
 W0.   . ?-nvolve the  excavation  of  approximately 7,200 cubic  yards
 of soil.   The depth of the excavation is currently estimated  to
 be 16 feet.  Based upon current  data, Lagoon B  is believed to be
 r°?ated beneath  the following properties: 186 East Camplain Road,
 192 East Camplain  Road, 198 East Camplain Road, 204 East Camplain
 V?? v 210  East Camplain Road, and may extend into the backyard of
 216 East Camplain  Road.  To excavate  the source area associated
 with Lagoon  B, approximately 29,946 cubic yards of material would
 be removed.

 It is estimated that approximately 3,012 cubic yards of material
 would be excavated from Canal A and the Lagoon A exit trench.  It
 is further estimated that approximately 4,000 cubic yards of
 material would be  excavated from Canal B.   Residents of affected
properties on Valerie Drive and East Camplain Road may need to be
 temporarily  relocated during some or all  of the excavation
 activities on their properties.  It is anticipated that temporary
 relocation would be for a period of six months to one year
Because Canal A and Canal B are relatively shallow,  structural
engineering measures such as foundation underpinning may be used
to remove the source areas from beneath these structures without

                               11

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demolishing  the houses.  However, until all of the subsurface
data is received and evaluated, EPA cannot determine whether
extensive  contamination exists at depth on these properties that
may result in the need to acquire more homes in order to excavate
the canal  contamination.  During the excavation of Lagoon B, it
is anticipated that portions of East Camplain Road may need to be
closed to  provide room for construction equipment.

During the excavation of the lagoons, the use of a prefabricated
fabric structure  (PFS) equipped with a ventilation system may be
necessary  to control noise, dust, odors, and to limit rain water
in the excavation area.  Air emissions from the PFS would be
treated prior to discharge to the atmosphere.  For canal
excavation,  the use of the PFS is not believed necessary.  Air
monitoring would be conducted during the excavation of the canal
and lagoon areas.

The source material is a Resource Conservation and Recovery Act
(RCRA) listed waste, and would be transported for off-site
thermal treatment and disposal.  In excavation areas, where
houses would be demolished, the lots would be completely
backfilled and would be revegetated and restored as open lots.

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In selecting a remedy, EPA considered the factors set out in
section 121  of CERCLA, 42 U.S.C. §9621, by conducting a detailed
analysis of  the viable remedial alternatives pursuant to the
National Contingency Plan (NCP), 40 CFR §300.430(e){9}  and OSWER
Directive  9355.3-01.  The detailed analysis consists of an
assessment of the alternatives against each of nine evaluation
criteria and comparative analysis focusing upon the relative
performance  of each alternative against those criteria.

The following "threshold" criteria must be satisfied by any
alternative  in order to be eligible for selection:

•    Overall Protection of Human Health and the Environment draws
     on the  assessments conducted under other evaluation criteria
     and considers how the alternative addresses site risks
     through treatment, engineering,  or institutional controls.

•    Compliance with ARARs evaluates the ability of an
     alternative to meet applicable or relevant and appropriate
     requirements (ARARs) established through Federal and State
     statutes and/or provides the basis for invoking a waiver.

The following "primary balancing" criteria are used to make
comparisons  and to identify the major trade-offs between
alternatives:
                                12

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 *    Long-term Effectiveness and Perma^^** evaluates the ability
      of an alternative to provide long-term protection of human
      health and the environment and the magnitude of residual
      risk posed by untreated wastes or treatment  residuals.

 *    deduction of Toxicitv.  Mobility or Volume  Through Treatment
      evaluates the degree to which an alternative reduces risks
      through the use of treatment technologies.

 •    Short-term Effectiveness addresses the cleanup  time  frame
      and any adverse impacts posed by the  alternative during the
      construction and implementation phase,  until cleanup goals
      are achieved.

 •    Implementability is an  evaluation of  the technical
      feasibility,  administrative feasibility, and availability  of
      services and materials  required to implement the
      alternative.

 •    Cost includes  an evaluation of capital  costs, annual
      operation and  maintenance  costs,  and  net present worth
      costs.

 The following "modifying"  criteria  are considered fully after the
 formal  public comment period on the Proposed Plan is  complete:

 •     State Acceptance indicates the State's  response  to the
      alternatives in  terms of technical and  administrative issues
      and concerns.

 *     Community Acceptance evaluates the issues and concerns  that
      the public may have regarding  the alternatives.

A comparative  discussion of  the seven  alternatives on the basis
of the  evaluation criteria presented above follows.

Overall  Protection  of Human  Health  and the Environment.
Alternative 1, the  no action alternative, would not be protective
of human health and the environment because the site would remain
in its  current condition.  Under this alternative, contaminated
subsurface soils would remain in place at the site and would not
be subject to a remedial action.  The limited surficial soil
covering over the lagoons and canals does not provide a
protective barrier  from exposure.   In addition,  under the no
action  alternative, the lagoons and canals would continue to
serve as a source of  groundwater contamination.

Under Alternative 2, excavation and off-site thermal treatment
and disposal, all of the identified subsurface soils exhibiting
signs of visible contamination would be excavated and thermally
treated off site.  EPA is currently describing this alternative
based on visible cleanup goals since the baseline risk assessment

                                13

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 and its associated quantitative  determination of cleanup  levels
 have not yet been completed.   The  subsurface soil cleanup levels
 will be developed prior to the actual  removal of the creosote
 source material and any adjacent contaminated soil.

 Excavation and off-site thermal  treatment and disposal would
 eliminate:  (1)  the actual  or potential exposure of residents to
 contaminated soils from lagoon and canal areas; and  (2) the
 contaminants that might migrate  to the groundwater.  Any
 potential environmental impacts  would  be minimized with the
 proper installation and implementation of dust and erosion
 control measures,  by performing  excavation within a PFS where
 practicable,  and if determined to  be necessary, by conducting
 water pretreatment,  and by using a lined temporary staging area.

 There would be  no local human  health or environmental impacts
 associated  with off-site disposal  because the contaminants would
 be  removed  from the site to a  secured  location.

 .Compliance  with ARARs:   There  are  three types of ARARs: action-
 specific, chemical-specific, and location-specific„  Action-
 specific ARARs  are technology  or activity-specific requirements
 or  limitations.   Chemical-specific ARARs establish the amount or
 concentrations  of  a chemical that  may  be found in, or discharged
 to,  the  environment.  Location-specific ARARs are restrictions
 placed on concentrations of hazardous  substances found in
 specific locations,  or  the  conduct of  activities solely because
 they occur  in a specific location.

 Actions  taken at  any Superfund site must meet all applicable or
 relevant and appropriate requirements  of federal and state law or
 provide  grounds for invoking a waiver  of these requirements.
 Alternative 2 would comply with ARARs, Alternative 1 would not.
 Major ARARs are described below.

 The Resource  Conservation and  Recovery Act is a federal law that
 mandates procedures  for treating,  transporting,  storing,  and
 disposing of  hazardous  substances.  All portions of RCRA which
 are applicable  or  relevant and appropriate to the proposed remedy
 for the  site would be met by Alternative 2.

The source  materials associated with the two canals and lagoons
 consist  of  coal-tar  creosote.  Soils excavated from the site
 during remediation and  all or part of the associated debris are a
 listed hazardous waste  (F034) as defined in RCRA.   As a listed
hazardous waste, excavated material is subject to the Land
Disposal Restrictions (LDRs) under RCRA.

The Uniform Relocation Assistance and Real Property Acquisition
 Policies Act of  1970, which provides regulations and guidance for
the government  in  conducting relocation activities where property
 is acquired, is not an  environmental law,  but would have bearing

                               14

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on Alternative 2, which proposes permanent relocation.  The Act
provides for uniform and equitable treatment of persons displaced
from their homes by federal programs.  All portions of the Act
that are applicable to the proposed action would be met by
Alternative 2.

Long-term Effectiveness and Permanence:  The no action
alternative offers no long-term effectiveness and permanence.  In
contrast, the excavation and removal of the lagoons and canals
would represent a permanent solution for a portion of the site,
because the source material would be entirely removed from these
areas and transported to a hazardous waste facility.  In
addition, the waste material would be treated to destroy the
contaminants, providing for a permanent solution to the waste.

Off-site treatment/disposal at a secure, permitted hazardous
waste facility for the source material is a technically viable
and often used disposal technique.  This option is reliable
because the design of these types of facilities includes
safeguards and would ensure the reliability of the technology and
the security of the waste material.

Reduction of Toxicity. Mobility or Volume: The no action
alternative does not provide for any reduction of toxicity,
mobility, or volume of the waste material in the source areas.

In contrast, removal and treatment of principal threat source
material significantly reduces the toxicity,  mobility, and volume
of contaminants through treatment.  Thermal treatment generally
treats organic contaminants by subjecting them to temperatures
ranging from 900 to 2,000 degrees Fahrenheit.  During thermal
treatment,  the toxicity of the source material would be reduced
during volatilization when organic contaminants are driven off as
gases and are captured or combustion converts the organic
contaminants to less toxic compounds such as carbon dioxide,
water,  hydrogen chloride, and sulfur oxides.

Short-term Effectiveness: During excavation and staging of the
source material,  health and safety measures would be implemented
to protect surrounding residents and field personnel from
exposure to the contaminated materials.  Any potential
environmental impacts would be minimized with the proper
installation and implementation of dust and erosion control
measures, by performing excavation with appropriate health and
safety measures,  which may include a prefabricated structure
where practicable,  by conducting water pretreatment, and by using
a lined temporary staging area.  Appropriate transportation
safety measures would be required during the shipping of the
contaminated soil to the disposal facility.

Imp 1 ement ab i 3. i t y: Excavation techniques are commonly used in
construction and by environmental remediation firms.  The

                               15

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installation of side wall support systems and erection of
prefabricated structures have also been employed at numerous and
similar environmental remediation sites.  Underpinning of houses
during excavation has also been used at other Superfund
remediation sites.  The heavy equipment necessary to implement
this alternative is readily available and typically used for
excavation activities.  Numerous vendors are available to procure
or rent the necessary prefabricated structures.  Also, the
quantities of backfill soil needed for excavations are available.

The personnel required to operate the heavy equipment would
require appropriate OSHA certifications (e.g., hazardous waste
worker), in addition to being certified in the operation of the
heavy equipment.  Such individuals are readily available.

The property buyouts associated with permanent relocation would
result in some scheduling uncertainties related to the time
necessary to complete negotiations with all affected homeowners.
In addition, various issues may arise during the negotiation
process with the individual homeowners that can complicate and
lengthen the acquisition process.

Permitted hazardous waste facilities for treating creosote-
contaminated material are available and have the capacity to
accept the estimated volumes of waste identified for removal.
This treatment option is reliable because of the stringent design
and operation requirements imposed by permits.  Following thermal
treatment, the treated material would be disposed of in a
Subtitle C landfill.  Publicly Owned Treatment Works  (POTWs) are
also available for receiving pretreated water collected during
excavation operations for the response action.

During excavation and staging of the material, health and safety
measures would be implemented to limit surrounding residents and
field personnel from exposure to the contaminated materials.
Excavation techniques could be implemented in a relatively short
time period because the necessary equipment is readily available.
Demolition of homes associated with excavations could be
performed without specific or highly specialized construction
controls.

gosj:; The capital cost and present worth costs for Alternative 2
are $59,100,000.  There is no annual operation and maintenance
associated with Alternative 2.  Table 3-5 in the Focused EE/CA
provides detailed break down of the cost estimate.

State Acceptance?  NJDEP has concurred with the selected remedy.
                                 •
Community Acceptance;  Based upon public comments addressed in
the responsiveness summary  {Appendix V), the community supports
the selected remedy.'


                                16

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SELECTED REMEDY

EPA and .NJDEP have determined, after reviewing the alternatives
and public comments that Alternative 2, excavation and off-site
thermal treatment and disposal, is the appropriate remedy for the
site, because it best satisfies the requirements of section 121
of CERCLA, 42 U.S.C. §9621, and the NCP's nine evaluation
criteria for remedial alternatives, 40 CFR §300.430 (e) (9) .  The
capital and present worth costs for this remedy are $59,100,000.
There are no operation and maintenance costs associated with the
remedy.  Alternative 2 is comprised of the following components:

•    Permanent relocation of residents from certain properties
     within the canal and lagoon source areas, and temporary
     relocation where necessary to implement the remedy;

•    Excavation of source material from the canal and lagoon
     source areas, backfilling with clean fill, and property
     restoration as necessary; and

•    Transportation of the source material for off-site thermal
     treatment and disposal.

Based on the information available at this time,  EPA and NJDEP
believe the selected alternative will be protective of human
health and the environment, will comply with ARARs and will
reduce the toxicity, mobility and volume of contaminants through
treatment to the maximum extent practicable.  Because the
selected alternative will treat contaminated material, it will
also meet the statutory preference for the use of a remedy that
involves treatment as a principal element.

EPA plans to implement the selected alternative in a phased
manner and will be initially moving forward with the relocation
of affected residents.  The relocation of residents and
demolition of the houses must take place before any actual
construction can begin.  This process can take up to one year.
However, the agency does not plan to begin the actual removal of
the source area contamination until the site-wide RI/FS is
completed.  EPA believes that the full extent of contamination
within the development should be known prior to the initiation of
intrusive cleanup activities.  As indicated previously,  the
available data indicate that 32 residential properties need to be
remediated, ten to nineteen of which will require the permanent
relocation of the residents.  Based on this data, EPA believes
that excavation and off-site thermal treatment of the lagoon and
canal wastes, while maintaining the existing nature and character
of the development, is the appropriate remedy for the site.  It
is not expected that the extent of this early interim action will
significantly expand beyond the scope presented in this document.
If, however, the source material is found to extend further


                                17

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 beyond the properties identified in this  document,  then
 modification of this remedy will be addressed  as part of  the
 site-wide ROD.   Any such modification would be subject to full
 public input and comment.

 It should be noted that  the site was reviewed  by EPA's National
 Remedy Review Board.   The Board,  which includes senior
 representatives from EPA offices across the nation, was
 established to  review proposed high-cost  remedies and provide
 advisory recommendations relative to national  consistency and
 cost  effectiveness.   Among its recommendations, the Board
 supports the need for action at the site  including the region's
 plan  to move forward with the relocation  of affected residents
 necessary to address  the highly contaminated lagoon and canal
 source areas.   The Board also believes that, given the
 uncertainty regarding the  extent of subsurface  contamination on
 many  properties within the development, and the potential affect
 of this uncertainty on the proposed remedial approach, the site-
 wide  RI/FS should be  completed prior to the removal of any source
 materials.   The region intends to implement the selected
 alternative in  a phased  manner consistent with  these
 recommendations.

 STATUTORY DETERMINATIONS

As previously noted,  section 121(b)(1)  of CERCLA, 42 U.S.C. §9621
 (b)(1),  mandates  that  a  remedial  action must be protective of
human health and  the  environment,  be cost-effective, and  utilize
permanent solutions and  alternative  treatment technologies or
resource recovery technologies to the  maximum extent practicable.
Section 121(b)(1)  also establishes  a preference for remedial
actions which employ  treatment to permanently and significantly
reduce the  volume, toxicity,  or mobility of the hazardous
substances,  pollutants,  or contaminants at the  site.  Section
121(d)  of CERCLA,  42 U.S.C.  §9621(d),  further specifies that a
remedial action must attain a  degree of cleanup that satisfies
ARARs  under federal and  state  laws,  unless a waiver can be
justified pursuant to  section  121(d)(4) of CERCLA,  42 U.S.C. 42
U.S.C.  §9621(d)(4).  As  discussed below, EPA has determined that
the selected remedy meets  the  requirements of section 121  of
CERCLA 42 U.S.C.  §9621.

Protection  of Human Health and the Environment

The selected remedy is considered fully protective of human
health and  the  environment.  The treatment of the contaminated
source material through  a  thermal treatment process will remove
or destroy  the  organic contaminants.  Treatment of the principal
threat  source material will result in the elimination of the
potential direct human health  threats posed by the soils,  and
will eliminate potential long-term sources of groundwater  and


                                18

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surface water contamination.

Compliance with ARARs

At the completion of the response action,  the selected remedy
will have complied with all applicable ARARs, including:

Action Specific ARARS:

•    National Ambient Air Quality Standards for Hazardous Air
     Pollutants

•    RCRA - Land Disposal Restrictions

•    RCRA - Standards Applicable to Transport of Hazardous Waste

•    RCRA - Standards for Owners/Operators of Permitted Hazardous
     Waste Facilities

•    DOT -  Rules for Transportation of Hazardous Materials

•    OSHA - Safety and Health Standards

•    OSHA - Record keeping, Reporting -and related Regulations

•    Uniform Relocation Assistance and Real Property Acquisition
     Policies Act of 1970

Chemical-Specific ARARs:

•    None applicable.

Location-Specific ARARs:

•    None applicable.

A full list of ARARs and TBCs  (e.g., advisories, criteria, and
guidance) being utilized is provided in the Table in Appendix II.

Cost-Effectiveness

The selected remedy is cost-effective in that it provides overall
effectiveness proportional to its cost.  The total capital cost
of the remedy is $59,100,000; no long-term operation and
maintenance costs are- expected.  With respect to the total cost,
approximately 36% of the cost is attributed to excavation,
backfilling, and other activities  (e.g., relocation, building
demolition and disposal); the remaining 64% is attributed to
transportation, thermal treatment, and landfilling of the source
material.  A detailed cost breakdown can be found in the Focused
EE/CA.


                                19

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 Utilization of Permanent Solutions and Alternative Treatment
 Technologies to the Maximum Extent Practicable

 This early interim action is not designed or expected to be the
 final action for the site.   EPA and NJDEP have determined that
 the selected remedy utilizes permanent solutions  and treatment
 technologies to the maximum extent practicable for this  operable
 uint,  and represents the best balance  of  trade-offs among
 alternatives with respect to criteria,  given the  limited scope of
 the action.   This determination was made  based on the evaluation
 of alternatives with respect to long-term effectiveness  and
 permanence,  reduction of toxicity,  mobility  or volume through
 treatment,  short-term effectiveness, implementability, and cost,
 as well  as the statutory preference for treatment as  a principal
 element,  and State and community acceptance.

 Preference for Treatment as a Principal Element

 Inpeeping with the statutory preference  for treatment as a
 principal element of the remedy,  the remedy  provides  for the
 treatment of source materials (the  lagoons and canals) which
 constitute the principal threat known  to  exist at the site.

 DOCUMENTATION OP SIGNIFICANT CHANGES

 The Proposed Plan for the Federal Creosote site was released for
 a  public  comment period on  April  30, 1999 that  was  scheduled to
 run until  June 1,  1999.   In response to a comment,  the public
 comment period was extended to June 25, 1999  to provide
 additional information related to the preferred alternative.

 The Proposed Plan identified Alternative 2, excavation and  off-
 site thermal treatment,  as  the preferred response action.
 Thermal treatment in the proposed plan  was defined as
 incineration.   To provide flexibility of treatment for the  source
 material, the definition of  thermal treatment has been expanded
 to include both thermal  desorption and  incineration.

 The cost of  the preferred remedy in the Proposed Plan was
 erroneously  presented as $58,000,000.  The correct cost estimate
 for the remedy is $59,100,000.

All  written  and verbal comments submitted during the public
 comment period were  reviewed by EPA.  Upon review of these
 comments, it  was  determined  that no significant changes to  the
remedy, as it was  originally identified in the Proposed Plan,
were necessary.
                                20

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APPENDIX I

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-------
;i_-.^--.-^::—
                                                          Alma_White
                                                          GollegeX   . 4
                                                                   .,  Radio-towers
                                                                   ". ° n (WAVVZ)
     Source: U.S.G.S 71/2 Minute Quadrangle
            Bound Brook, NJ 1955
            Photoinspected 1977, Photorevised 1970
 98P-Z7S2
              FIGURE   1

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100  0  100 200 300 400 Feet
                                                            FIGURE 2
                                                 FEDERAL CREOSOTE COMPANY, ACTIVE FACILITY
                                                           FEDERAL CREOSOTE
                                                          MANVILLE, NEW JERSEY

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 FEDERAI, CREOSOTE SITE
CLAREMONT DEVELOPMENT
                                  Buyout /Temporary Relocate
                            FIGURE 3

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APPENDIX II

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                      Table 1
                 List of Target PAH*
PAHj
1
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Naphthalene
2-Methylnaphthaiene
1 -Methylnsphthalene
Biphenyl
2,6-Dimethylnaphthalene
Acenaphthenc
Dibenzofiiran
Fluorene
Phenanthrene
Anthracene
Carbaxote
Fluoranthene
Pyrene
Benzo(a)anthracene*
Chrysene*
Benzo(b)fluoramhene*
Benzo(k)fluoranthene*
Benzo(e)pyrene
Benzo(a)pyrene»
Indeno( 1 ,2 J»)
77^«3
2U06
13^80
—^^}£}l—^mmm
CPAH

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                                                              TABLE 3-1
                                                   Chemical-Specific ARARs,
                                                      Federal Creosote Site,
                                                            Manville, NJ
    Standard Requirements, Criteria, or
               Limitations
        Citation
            Description
                                                                            Conmenli
Safe Drinking Water Act (SDWA)
40 USC 300 ct scq.
    Nalioiiiil Primary Drinking Water
    Standards
40CFR I4I
Establishes health-based standards for
public water systems (maximum
contaminant levels |MCLs|).
MCLs are ARARs in cases where affected
groundwaler is or may be used directly for
drinking water.
•   National Secondary Drinking Water
    Standards
40CFRI43
Establishes welfare-based standards for
public water systems (secondary
maximum contaminant kvels |SMCLs|).
    Maximum Contaminant Level Goals
PL 99-339, 100 Slat. 642
(1986)
Establishes drinking water quality goals
set at levels of no known or anticipated
adverse health effects, with an adequate
margin of safety.
 Clean Water Act (CWA)
 33 USC I25lelseq
    Water Quality Criteria
 40CFR13I
 Quality Criteria for Water,
 1976, 1980, and 1986
Sets criteria for water quality based on
toxicily to human health.
                                                                                                           If water is discharged to surface water.
    Ambient Water Quality Criteria
 40CFRI31
 Sets criteria for ambient water quality
 based on toxicily to aquatic organisms.
                                                                                                           If water is discharged to surface water.
    Toxic Pollutant Effluent Standards
 40CFR 121
 Establishes effluent standards or
 prohibitions for certain toxic pollutants,
 ic, aldrin/dieldrin, DDT. DDD. DDK.
 ciidrin, toxaphcne, beiizidine. and PCBs.
 If water treatment and discharge will be
 required during remediation.

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        TABLE 3-2
Chemical-Specific ARARs,
  Federal Creosote Site,
      Manville, NJ
      (Continued)
Standard Requirements, Criteria, or
Limitations
Resource Cowervatloa and Recovery Act
(RCRA)
• Identification and Listing of Hazardous
Wastes
• Releases from Solid Waste Management
Units (SWMUs)
* Land Disposal Restrictions (LDRs)
Clew Air Act (CAA)
• National Ambient Air Quality Standards
• National Emissions Standards Tor
Hazardous Air Pollutants (NESHAPs)
• New Performance Standards for Criteria
and Designated Pollutants
Citation
42USC6«K)letseq.
40 CFR 261
40 CFR 264, Subpart F
40 CFR 268
42 USC 7401
40 CFR 50
40 CFR 61
40 CFR 60
Description

Defines those solid wastes that are
subject to regulation as hazardous wastes
under 40 CFR 262-265, 270, and 271.
Establishes maximum concentration
levels for specific contaminants from a
solid waste management unit (SWMU)
Establishes treatment standards for land
disposal of hazardous wastes.

Establishes primary and secondary
standards for six pollutants to protect the
public health and welfare.
Establishes regulations for specific air
pollutants such as asbestos, beryllium,
mercury, vinyl chloride, and benzene.
Establishes new source performance
standards (NSPSs) for certain classes of
new stationary sources.
Comments

For identification of listed or characteristic
RCRA wastes at a site.
Probably not ARARs for slate Supcrfund
sites.
Applicable materials will be disposed of
on land.

These are ARARs for remedial
alternatives that would result in emissions
of the specific pollutants during
implementation.
Potentially not applicable to contaminants
at this site.
Potentially not applicable because the
remediation will not involve a new source
(eg, an oil-site incinerator) subject to
NSI'S

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                                                     TABLE 3-3
                                                 Chemical-Specific ARARs,
                                                   Federal Creosote Site,
                                                         Manville, NJ
                                                         (Continued)
    Standard Requirements, Criteria, or
               Limitations
        Citation
            Description
             Comments
State of New Jersey Statutes and Rules
New Jersey Administrative
Code (N.J.A.C.); New
Jersey Statutes Annotated
(N.J.S.A.)
•   Drinking Water Standards—maximum
    contaminant levels (MCLs)
58 N.J.S.A. I2A-1
Establishes MCLs (hat arc generally
equal to or more stringent than SDWA
MCLs.
Although there are no local receptors and
all properties are served by city water, (he
underlying aquifer is a drinking water
supply source.

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                                                                TABLE 4-1
                                                          Location-Specific ARARs,
                                                            Federal Creosote Site,
                                                                   Manville, NJ
 Standard Requirements, Criteria, or
             Limitations
        Citation
                 Description
             Comments
National Historic Preservation Act
16 USC 469 el seq.
40CFR630l(c)
Bslablislles procedures to provide for preservation
of historical and archaeological data that might be
destroyed through alteration of terrain as a result
of a federal construction project or a federally
licensed activity or program.
If historical or archaeological data could
potentially be encountered during
remediation.
Fish and Wildlife Coordination Act
16 USC 661466
Requires consultation when federal department or
agency proposes or authorizes any modification of
any stream or other water body and adequate
provision for protection offish and wildlife
resources.
Not an ARAR because I lie response
actions will not aflccl surface water
bodies
Clean Water Act (CWA)
 33 USC 1251-1376
•   Dredge of Fill Requirements
    (Section 404)
                                       40 CFR 230-231
                          Requires dischargers to address impacts of
                          discharge of dredge or till material on the aquatic
                          ecosystem.
                                               Not an ARAR because the response
                                               action will not involve discharge of
                                               dredge or fill into surface water body.
•   Executive Order on Flood Plain
    Management
 New Jersey Flood Hazard Control Act

 _. .   -              —  ii  -     - -
 New Jersey Freshwater Protection Act
 Executive Order 11988
Requires federal agencies to evaluate the potential
effects of actions they may lake in a flood plain to
avoid, to the extent possible, the adverse impacts
associated with direct and indirect development of
a flood plain.
An ARAR if any portion of the site is
within the 100-year flood plain.
 N.J.A.C.7:I3
                                                                 Slate standards for activities within flood plains
                                               An ARAR for those aspects of the site
                                               work (hat arc within the flood plain
 N.J.S.A. I3:9B-I;
 N.J.A.C. 7:7A
 Require permits for regulated activity disluibiug
 wetlands.
Not an ARAR because no wetlands on
site would be affected.

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     TABLE 4-2
Location-Specific ARARs,
  Federal Creosote Site,
      Manville, NJ
      (Continued)
Standard Requirements, Criteria, or
Limitations
Endangered Species Act
Endangered and Non-Game Species
Act
Fish and Wildlife Coordination Act
New Jersey Uniform Construction
Code
Citation
16 USC 153 let scq.;
40 CFR 400
N.J.S.A. 23:2A-1
16 USC 66 let scq.
NJ AC 5:23

Description
Standards for (lie protection of threatened and
endangered species.
Standards fur lite protection of threatened and
endangered species.
Requires conservation of fish and wildlife and
their habitats.
Establishes standards for all new construction and
renovation.
ConaMnfs
Not an ARAR because no listed species
identified at (he site.
Not an ARAR because no listed species
identified at the site.
Not an ARAR because (his site does not
contain fish and wildlife habitat.
This may be an ARAR to the extent that
new construction falls within the
standards.

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     TABLE 5-1
Action-Specific ARARs,
 Federal Creosote Site,
     Manville, NJ
Standard Requirements,
Criteria, or Umitations
Clean Water Act (CWA)
• National Pollutant Discharge
Elimination System (NPDES)
• Effluent Guidelines and
Standards for the Point Source
Category
• National Pretrcalment
Standards
RcMurce Conservation and
Recovery Act (RCRA)
• Criteria for Classification of
Solid Waste Disposal
Facilities and Practices
• Standards Applicable to
Generators of Hazardous
Wastes
Citation
33 USC 1251-1376
40CFRI25
40 OR 4 14
40 CFR 403
42 USC 690 1-6987
40 CFR 257
40 CFR 262
Description

Requires permit Tor the discharge or pollutants Tor any
point source and slormwaler runoff for specific Standard
Industrial Codes (SICs) into waters of the United Slates.
Requires specific effluent characteristics for discharge
under NPDES permits.
Sets standard to control pollutants that pass through or
interfere with treatment processes in public treatment
works or that may contaminate sewage sludge.

Establishes criteria for use in determining which solid
waste disposal facilities and practices pose a reasonable
probability of adverse effects on public health or the
environment and thereby constitute prohibited open dumps
Establishes standards for generators of hazardous wastes.
Comments

Substantive requirements for a permit will
be required for discharge to a surface waiter
body if water generated during I he
remediation is discharged to surface water.
Probably not applicable because there wsll
be no ongoing commercial activity at a
slate Supcrfund site.
Only if the selected alternative includes
discharge of water to a POTW.

Not an ARAR because on-silc disposal is
not an option at the site.
An ARAR because response action involves
soil or water that would be considered
hazardous under RCRA.

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                                                            TABLE 5-2
                                                        Action-Specific ARARs,
                                                         Federal Creosote Site,
                                                               Manvilie, NJ
                                                               (Continued)
    Standard Requirements,
    Criteria, or Limitations

•   Standards Applicable to
    Transporters of Hazardous
    Wastes
Standards Tor Owners and
Operators or Hazardous Waste
Treatment, Storage, and Disposal
Facilities (TSDFs)
    General Facility Standards
    Preparedness and Prevention
 •  Contingency Plan and
    Emergency Procedures
     Manifest System,
     Rccordkeeping. and Reporting

    	1—	•
     Releases from Solid Waste
     Management Units (SWMUs)
      Citation
40CFR263
40 CFR 264
Subpart B
 Suhparl C
 Subpart D
 Subpart F
 Subpart F
                    Description
Establishes standards that apply to transporters of
hazardous wastes within the United Slates if the
transportation requires a manifest under 40 CFR 262.
Establishes minimum national standards that define the
acceptable management of hazardous wastes for owners
and operators of facilities that treat, store, or dispose of
hazardous wastes.
Establishes minimum standards for treatment, storage, and
disposal facilities (TSDFs).
                                                       Establishes minimum standards for hazard management.
                                                       Establishes minimum standards for hazard management.
 Establishes standards for tracking wastes during off-site
 transport
 Establishes standards for control of SWMUs.
                                                                                        Comments
An ARAR because response action involves
off-site transportation of soil or water that
would be considered hazardous under
RCRA.
Part 264 requirements may be ARARs for
certain remedial actions under CERCLA.
See each subpart that follows.
May be an ARAR if any remedial actions
are selected for which other subparts of 264
are relevant and appropriate.
                                                     Not an ARAR because on-sife storage or
                                                     treatment will not be conducted.
                                                     Not an ARAR because on-sile storage or
                                                     treatment will not be conducted.
 An ARAR because response action will
 involve off-site transport of hazardous
 waste.
 Not an ARAR because response action will
 not involve on-site disposal.

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                                                               BLE 5-3
                                                      Action-Specific ARARs,
                                                      Federal Creosote Site,
                                                             Manville, NJ
                                                             (Continued)
Standard Requirements,
Criteria, or Umitalioni
      Citation
                    Description
                                                                                          Comments
Closure and Post-Closure
SubpartG
                                                    Establishes standards for sile closure.
                                                     CERCLA establishes review of remedial
                                                     actions should contaminants be left on-site.
                                                     Substantive requirements need to be met.
                                                     including monitoring and deed notices.
Financial Requirements
Subpart H
Use and Management of
Containers
Subpart!
Tanks
Subpart J
Eslablislics administrative requirements Tor demonstrating
fiscal responsibilities.
These are administrative requirements
only.
Establishes standards Tor container storage.
May be ARARs if an alternative would
involve storage or containers of hazardous
wastes.
                                                    Establish standards Tor tank storage and handling.
                                                     May be ARARs if an alternative would
                                                     involve use of tanks to treat or store
                                                     hazardous materials.
Surface Impoundments
Subpart K
 Waste Piles
 Land Treatment
Subpart L
 Subpart M
                                                    Establishes standards for surface-impounded wastes.
                                                     Not an ARAR because alternatives would
                                                     not involve a surface impoundment to treat,
                                                     store, or dispose of hazardous materials.
                                                     Established standards for managing wastes in piles.
                                                      Not an ARAR because alternatives would
                                                      not treat or store hazardous materials in
                                                      piles.
                                                     Establishes standards for managing land treatment
                                                      Not an ARAR because alternatives won) I
                                                      not involve on-site treatment.

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                                                               TABLE 5-4
                                                         Action-Specific ARARs,
                                                          Federal Creosote Site,
                                                                 Manville, NJ
                                                                 (Continued)
    Standard Requirements,
    Criteria, or Limitations
      Citation
                    Description
                                                                                           Commtati
    Landfills
Subpart N
Establishes standards Tor managing landfills.
May be ARARs if an alternative would
involve disposal of hazardous materials in a
landfill.
    Incinerators
Subpart O
                                                        Establishes standards for incineration of wastes.
                                                      May be ARARs if an incinerator alternative
                                                      is selected.
•   Interim Standard for Owners
    and Operators of Hazardous
    Waste Treatment, Storage.
    and Disposal Facilities
40 CFR 265
Establishes minimum national standards that define the
acceptable management of hazardous wastes during the
period of interim status and until certification of Final
closure or if the fucilily is subject to post-closure
requirements, until post-closure responsibilities are
fulfilled
Remedies should be consistent with the
more stringent Part 264 standards, as these
represent the ultimate RCRA compliance
standards and are consistent with
CERCLA's goal of long-term protection of
public health and welfare and the
environment.
    Standards for the
    Management of Specific
    Hazardous Wastes and
    Specific Types of Hazardous
    Waste Management Facilities
40 CFR 266
Establishes requirements that apply to recyclable materials
that are reclaimed to recover economically significant
amounts of precious metals.
Does not establish additional cleanup
requirements.
     Interim Standards for Owners
     and Operators of New
     Hazardous Waste Land
     Disposal Facilities
 40 CFR 267
 Establishes minimum standards that define acceptable
 management of hazardous wastes for new land disposal
 facilities
 Remedies should be consistent with the
 more stringent Part 264 standards, as tiiese
 represent the ultimate RCRA compliance
 standards and are consistent with
 CERCLA's goal of long-term protection of
 public health and the environment

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                                                             TABLE 5-5
   Standard Requirements,
    Criteria, or Limitation*
   •••———man^^mB.,^—
   Land Disposal Restrictions
•   Hazardous Waste Permit
    Program
    Underground Storage Tanks
•   Resource Conservation and
    Recovery Act (RCRA) Rule
    Change
•   Corrective Action
    Management Units (CAMUs)
    and Temporary Units (TUs)^

    RCRA LDRs, Phase II
 •   RCRA LDRs, Phase II
      Citation
40 CFR 268
40 CFR 270
40 CFR 280
 57 FR 37193
 40 CFR, Subpart S,
 Part 264


 57 FR 27880, 30657,
 37284,47376, and
 6149
 •  • ~
 57 FR 12
                                                        Action-Specific ARARs,
                                                         Federal Creosote Site,
                                                               Manville, NJ
                                                               (Continued)
                    Description
Identifies hazardous wastes that are restricted from land
disposal and describes those circumstances under which an
otherwise prohibited waste may be disposed of on land.
Establishes provisions covering basic EPA permitting
requirements.
Establishes regulations rci.tied to underground storage
tanks (USTs)                           	
                                                       Addresses the LDRs for hazardous debris.
 Enables availability of CAMUs to those wl» initiate
 corrective action and seek agency approval under RCRA
 Establishes a list of items considered induslrial waste as a
 solid or hazardous waste.

     ------ —	—	••— •  •
 EPA clarification that a waste is not presumptively
 hazardous merely because it contains an Appendix VIII
 liii/ardotis waste constituent.
                                                                                        Comments
An ARAR because alternatives include
land application of wastes.
A permit is not required for on-sile
CERCLA response actions. Substantive
requirements are addressed in 40 CFR 2<'4.
No alternative involving the use of USTs is
anticipated
                                                                           An ARAR because debris is present.
                                                                           Not an ARAR.
 Not applicable because there will be no
 ongoing commercial activity.
 Applicable if ongoing commercial aclivi'y
 occurs.

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                                                            TABLE 5-6
                                                      Action-Specific ARARs,
                                                       Federal Creosote Site,
                                                             Manvilie, NJ
                                                             (Continued)
   Standard Requireraenti,
    Criteria, or UmiUtioni
Hazardous Materials
Transportation Act (HMTA)
•   Hazardous Materials
    Transportation Regulations
Clean Air Act (CAA)
    Permitting
      Citation
49 USC 1801-1813
49 CFR 107,
171-177


42 USC 7401
                                40 CFR 61
                   Description
Regulates transportation of hazardous materials.
                      Requires permits for the discharge of pollutants for point
                      sources, area sources, or fugitive emissions.
                                                                                     Comments
An ARAR because response action would
involve transportation of hazardous
materials.
                                                   Substantive requirements for a permit will
                                                   be required for discharge from the
                                                   excavation enclosure.

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                                                            TABLE 5-7
                                                        Action-Specific ARARs,
                                                         Federal Creosote Site,
                                                               Manville, NJ
                                                               (Continued)
    Standard Requirements,
    Criteria, or Limitations
      Citation
                    Description
                                                                                         Comments
    RCRA LDRs, Phase II
57 FR 21524 as
corrected by 57 FR
29220
Establishes management standards for recycled oils.
Not applicable because recycled oils are not
present.
•   RCRA
                                40 CFR 265
                       Establishes organic air emission standards for tanks,
                       surface impoundments, and containers.
                                                     Applicable to hazardous waste treatment,
                                                     storage, and disposal facilities (TSDFs) that
                                                     receive new or re-issued permits or Class 3
                                                     modifications after 5 January 1995.
    RCRA LDRs, Phase II
EPA, 976 F.2d 2, 17-18
(D.C. Cir 1992)
Establishes universal treatment standards and treatment
standards for organic toxicily characteristic wastes and
newly listed wastes.
May be applicable to listed or
characteristically hazardous wastes for
which a treatment standard has been
promulgated, landfilling is planned, and
the CAMU/TU regulations do not apply.
    RCRA LDRs, Phase IV
 40 CFR 268.30 and
 268.40
 Establishes specific land disposal prohibitions and
 treatment standards for wood-preserving wastes.
 An ARAR because response actions will
 involve off-site treatment and disposal of
 F034 wastes.
 Occupational Safety and Health
 Act (OSHA)
 29 USC 651-578
 Regulates worker health and safely.
 Under 40 CFR 300.38, requirements of the
 act apply to all response activities under the
 NCP
 Safe Drinking Water Act
 (SDWA)
 40 CFR 144-147
     Underground Injection
     Control Regulations
 40 CFR 144-147
 Provides for protection of underground sources of drinking
 water.
 Not an ARAR because response action does
 not involve groundwater remediation.

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Ill

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                      FEDERAL CREOSOTE SITE
                    ADMINISTRATIVE RECORD JILE
                        INDEX OF DOCUMENTS
1.0 SITE IDENTIFICATION

1.4 Sits Investigation Reports
     100001-   Report: Technical Memorandum - Site Investigation.
     100189    Federal Creosote Site. Manville. NJ. prepared by
               Roy F. Weston, Inc., prepared for U.S. EPA/ERTC,
               November 1998.
2.0 REMEDIAL RESPONSE
2.4 EE/CA
P.
200001-
200269
P.
200270-
200832
Report: Focused Engineering Evaluation/Cost
Analysis (EE/CA).  Technical Memorandum for the
Subsurface Soils Associated with the Historic
Lagoons and Canals at the Federal Creospte Site.
Manville. Somerset County. New Jersey, prepared by
Region II Superfund Technical Assessment and
Response Team, Roy F. Weston, Inc., prepared for
U.S. EPA, Region II, 6 April 1999.

Report: Engineering Evaluation/Cost Analysis for
the Subsurface Soils Associated with the Historic
Canals and Laaoons at the Federal Creosote Site
Manville„ Somerset Countv. New Jersey, prepared by
Region II Superfund Technical Assessment and
Response Team, Roy F. Weston, Inc., prepared for
U.S. EPA, Region II, 6 April 1999.
8.0 HEALTH ASSESSMENTS

8.1 ATSDR Health Assessments

p.   800001-   Report: ^nterim Surface Soils. Human Health Risk
     800272    Assessment. Federal Creosote Site. Manville. New
               J«»rsev. prepared by CDM Federal Programs

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                Corporation,  prepared for U.S.  EPA,  Region II,
                January 13,  1999.

 P.   800273-   Report:  Health Consultation.  Federal CreoaotK*
      800281    Site.  Manville.  Somerset  County. New Jersey.
                CERCLis  NO.  NJ0001900281.  prepared by Exposure
                Investigation and  Consultation  Branch, Division of
                Health Assessment  and Consultation,  Agency for
                Toxic  Substances and Disease  Registry, prepared
                for U.S.  EPA,  Region II,  February  11, 1999.
 10.0 PUBLIC PARTICIPATION

 10.3 Public Notices

 P.    10.00001- Notice: EPA To  Start Soil Sampling, prepared by
      10.00001  U.S. EPA,  Region II, undated.

 P.    10.00002- Notice: EPA To  Hold A Community Meeting, prepared
      10.00002  by U.S. EPA, Region II, undated.

 P.    10.00003- Notice: EPA Soil Sampling In Your Neighborhood,
      10.00003  Update, prepared by U.S. EPA, Region II, undated.

 P.    10.00004- Notice: Community Update, prepared by U.S. EPA,
      10.00004  Region II, undated.

 P.    10.00005- Notice: Upcoming Field Activities In Your
      10.00005  Community, prepared by U.S. EPA, Region II,
               undated.

 P.    10.00006- Notice: Public  Meeting Agenda, Public Meeting to
      10.00006  Discuss Remedial Activities for the Federal
               Creosoting Plant, prepared by NJDEP, Site
               Remediation Program, Bureau of Community
               Relations, April 16, 1997.

 P.    10.00007- Notice: Public Meeting Agenda, Public Meeting to
      10.00007  Discuss the Federal Creosote Plant Site, prepared
               by NJDEP, Site Remediation Program, Bureau of
               Community Relations, September 10, 1997.

P.   10.00008- Notice: Site Update, Federal Creosote Site,
     10.00008  Manville Borough, Somerset County, prepared by
               NJDEP,  Site Remediation Program, Bureau of
               Community Relations, January 21, 1998.

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 P.   10.00009- Notice: Federal Creosote Superfund Site, prepared
      10.00010  by U.S. EPA, Region II, October 1998.


 10.6 Fact Sheets and Press Releases

 P.   10.00011- Fact Sheet: Federal Creosoting Plant, Manville
      10.00012  Borough,  Somerset County,  Sampling Activities
                Planned at Development Site,  prepared by NJDEP,
                Site Remediation Program,  Bureau of Community
                Relations, April 16,  1997.

 P.   10.00013- Fact Sheet: Federal Creosote  Site,  Manville
      10.00013  Borough,  Somerset County,  Focused Soil and Ground
                Water Sampling Planned,  prepared by NJDEP,  Site
                Remediation Program,  Bureau of Community
                Relations, September 10, 1997.

 P.    10.00014- Fact Sheet: Fact Sheet on  the Pronosed Plan.
      10.00014  prepared  by U.S. EPA",  Region  2,  April 199.9.


 10.9  Proposed Plan

 P.    10.00015-  Plan:  Superfund Proposed Plan.  Federal Creosote
      10.00029  Site.  Manville.  New Jersey, prepared by U.S.  EPA,
                Region II,  April 1999.

 P.    10.00030-  Memorandum to Mr.  Richard L.  Caspe,  Director,
      10.00032   Emergency  and Remedial Response  Division, U.S.
                EPA, Region II,  from Mr. Bruce K. Means,  Chair,
                National Remedy Review Board,  Office of Solid
                Waste  and  Emergency Response,  re: National Remedy
                Review Board Recommendations  for the Federal
                Creosote Superfund Site, May  3,  1999.


11.0 TECHNICAL  SOURCES AND GUIDANCE DOCUMENTS

11.1 EPA Headquarters

P.   11.00001- Report: Presumptive Remedies  for Soils.  Sediments
     11.00059  and Sludges  at Wood Treater Sitea. prepared by
               U.S. EPA, Office of Solid Waste  and  Emergency
               Response, December 1995.

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APPENDIX IV

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Christine Todd Whitman
Governor
          Department of Environmental Prelection
Robert C. Shinn, Jr.
    Cnmmitsioaer
           Ms. Jeanne M. Fox
           Regional Administrator
           U.S. EPA-Region U.
           290 Broadway
           New York, NY 10007-1866
           Subject:
           Dear Ms. Fox:
Federal Creosote Superfund Site
Record of Decision (ROD)
           The New Jersey Department of Environmental Protection (NJDEP) has evaluated and concurs
           with the components of the selected remedy as described below for the Federal Creosote
           Superfund She. The selected remedy corresponds to the first planned operable unit for the Site
           which includes properties located in Manvillc Borough, Somerset County, New Jersey.

           The major components of the selected remedy include:
           •   Permanent relocation of residents from and estimated 10 to 19 properties so that the houses can
               be demolished for the excavation of contaminated source material.

           •   Excavation of burial lagoons and canals that arc considered source areas of the creosote
               contamination.

           NJDEP concurs that the selected remedy is protective of human health and the environment,
           complies with requirements (hat arc legally applicable or relevant and appropriate for the
           remedial action, and is cost effective.

           The Slate of New Jersey appreciates the opportunity afforded to participate in the Superfund
           process.
                                                      Robert;
                                                      Commissioner
                                                      Now Jersey Department of Environmental
                                                      Protection
                                                 KtcydttFxpcr

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APPENDIX V

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                            APPENDIX V


                      RESPONSIVENESS SUMMARY
                 FEDERAL CREOSOTE SUPERFUND SITE
                       MANVILLE,  NEW JERSEY
INTRODUCTIO:
This Responsiveness Summary provides a summary of the public's
comments and concerns regarding the Proposed Plan for the Federal
Creosote site and the U.S. Environmental Protection Agency's
(EPA's) responses to those comments.  At the time of the public
comment period, EPA had proposed a preferred alternative for
remediating the source material contained in the buried lagoons
and canals which has been designated as Operable Unit 1 (OU1).
All comments summarized in this document have been considered in
EPA's final decision for selection of a remedial alternative for
OU1.

EPA held a public comment period to solicit community input and
ensure that the public remains informed about site activities.
EPA's Proposed Plan for Operable Unit 1 was released to the
public on April 30, 1999.  A copy of the Proposed Plan was placed
in the Administrative Record and was made available in the
information repository at the Manville Public Library.  A public
notice was published in The Manville News and The Courier-News on
April 30, 1999, advising the public of the availability of the
Proposed Plan.  The notice also announced the opening of a 30-day
public comment period and invited all interested parties to an
upcoming public meeting.  In response to a request from a
concerned party, the public comment period was extended to June
25, 1999.

The public meeting to present the preferred remedial alternative
for OU1 was held at the Weston Elementary School, Newark Avenue,
Manville, New Jersey on May 12, 1999, at 7:00 pm.

This Responsiveness Summary is divided into the fc.lowing
sections:                                  •

I.   BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS:  This
     section provides the history of community involvement and
     interests regarding the Federal Creosote site.

II.  COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS
     AND RESPONSES:  This section contains summaries of oral
     comments received by EPA at the public meeting, EPA's

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     responses to these comments, as well as responses to written
     comments received during the public comment period.

The last section of this Responsiveness Summary includes
appendices which document public participation in the remedy
selection process for this site.  There are four appendices
attached to this Responsiveness Summary.  They are as follows:

     Appendix A contains the Proposed Plan that was distributed
     to the public for review and comment;

     Appendix B contains the public notice which appeared in the
     Courier-News;

     Appendix C contains the transcripts of the public meeting;
     and

     Appendix D contains the written comments received by EPA
     during the public comment period.

I.   BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS


NJDEP and EPA have taken an active role in community involvement
at the site.  Community relations activities included;

•    Public meeting held by NJDEP to escplain history of the site
     and plans for future investigations  (April 16, 1997).

•    Public meeting held by NJDEP updating residents of
     preliminary findings and providing plans for future
     investigations (September 10, 1997).

•    Public meeting held by EPA to discuss plans to install
     monitoring wells and sample the soil on each property in the
     Claremont Development (January 21, 1998).

•    EPA circulated a flyer to request residents to sign access
     agreements which give the Agency permission to conduct soil
     sampling on their properties (February 10, 1998).

•    EPA prepared and distributed a fact sheet to inform affected
     residents and local officials of site investigations and
     upcoming actions.  The fact sheet also contained information
     on health issues, EPA contact persons, and the contacts for
     the Community Advisory Group (May 1998).

•    EPA held a public meeting to release surface sampling
     results and to inform residents of future plans, including
     subsurface soil sampling in Fall 1998 and additional
     groundwater sampling in Spring 1998  (July 1998).

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EPA circulated a flyer to announce the start of subsurface
soil sampling within the development, and describe the
sampling process and equipment to be used.  The flyer also
presented a schedule for field investigations (November 15,
1998).

EPA issued a press release to announce that it had placed
the Federal Creosote site on the final National Priorities
List  (January 19, 1999).

A citizens advisory group meeting was held.  EPA provided
residents information on the progress of the investigations
as well as a schedule of upcoming events (February 9, 1999).

EPA representatives met individually with homeowners whose
houses are located either adjacent to or over lagoon and
canals to explain the data they had received concerning
their property (week of March 15, 1999).

EPA held a community meeting to inform residents of the
progress of ongoing site investigations and possible options
that may be considered for properties located in lagoon and
canal areas (March 18, 1999).

A community update flyer was distributed by EPA to members
of the community summarizing the meeting of March 18th and
providing a map to each resident depicting lagoon and canal
areas (March 22,  1999).

EPA provided a flyer to all residents of the community
informing them of upcoming field activities in the
development that included additional sampling of specific
properties and surveying of sampling points (March 1999).

A citizens advisory group meeting was held with EPA.  EPA
presented to the residents information about the
availability of a Technical Assistance Grant (March 31,
1999).

Community interviews were conducted by EPA with Claremont
Development residents, local officials, and other interested
parties to assess their current issues and concerns  (April
1999).

EPA established an information repository for the site at
the Manville Public Library on 100 S. 10th Avenue (April 29,
1999).

EPA placed a notice in The Manville News and The Courier-
News to announce the release of the Proposed Plan and
Engineering Evaluation/Cost Analysis (EE/CA) Report, the

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     opening of a 30-day public comment period,  and a public
     meeting on May 12, 1999 (April 30, 1999).

•    EPA opened the public comment period on the Proposed Plan,
     scheduled to run from April 30,  1999 to June 1,  1999.

•    Flyers were sent to each residence within the Claremont
     Development reminding people of the upcoming public meeting
     and providing additional information about field activities
     being conducted in the neighborhood in the upcoming two
     weeks (May 3, 1999).

•    EPA held a public meeting to provide an opportunity for
     public comment on the preferred alternative for the first
     operable unit, the lagoon and canal areas in the Claremont
     Development.  Over 100 local residents attended the meeting
     at Weston School  (May 12,  1999).

•    An open house was held in the EPA field office where the
     public was invited to ask questions and obtain additional
     information about how EPA conducted remediation work in
     other residential neighborhoods similar to the Claremont
     Development  (June 2 & 3, 1999).

•    In response to a public comment, EPA extended the comment
     period to June 25, 1999.

Community concerns have centered around the impact that soil
contamination in the development may have on the quality of life
as well as the associated economic impact on the value of
property in the Claremont Development.   Additional community
concerns regarding site cleanup activities were raised during the
May 12th public meeting and are summarized in Section III below.

II.  COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS.
     CONCERNS. AND RESPONSES

This section summarizes comments received from the public during
the public comment period, and EPA's responses.

A.   SUMMARY OF QUESTIONS AND EPAs RESPONSES FROM THE PUBLIC
     MEETING CONCERNING THE FEDERAL CREOSOTE SITE - MAY 12, 1999

A public meeting was held May 12, 1999, at 7:00 p.m. at the
Weston Elementary School, Newark Avenue, Manville, New Jersey.
Following a brief presentation of the  investigation findings, EPA
presented the Proposed Plan and preferred alternative for the
Federal Creosote  site.  Comments raised by the public following
EPA's presentation are categorized by  relevant topics and
presented as follows:

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       1.      Permanent and Temporary Relocation
       2.      Remedial Construction
       3.      Health Concerns
       4.      Funding the Preferred Remedy
       5.      Property Ownership Issues and Potential Liability
              to Homeowners

1.     Permanent and Temporary Relocation

Comment #1:   As part of the preferred alternative, ten to
nineteen houses would be demolished so that the lagoon source
areas may be  excavated.  Several questions were raised about the
disposition of the property during the remedial construction
phase of the  project including: is it necessary for the
government to buy the land; can the property owners own the land,
and build new homes on their land once remediation is completed;
if this option is chosen by the property owner, will the property
owner get enough money to rebuild what they have?

Response: Entering into an arrangement with a property owner by
which the party retains ownership of the land and EPA purchases
the structure is an option that can be made available to affected
property owners at the site.  Homeowners who retain ownership of
the land would receive compensation for the present value of the
structure which is to be removed.

Comment #2: One commenter suggested that EPA buy out the entire
community and offer everybody $150,000,  instead of implementing
the preferred remedy.

Response: The issue of property purchase in the Claremont
Development by EPA is triggered by the need to excavate source
material.  If source material exists within close proximity of a
structure such that excavation would endanger its structural
integrity or  threaten the safety of area residents and
remediation workers,  then that property would be purchased and
the structure demolished.  At present,  EPA believes it is
necessary to purchase ten to nineteen properties and demolish the
associated structures so that the source material can be
excavated.  However,  additional data will determine whether there
is a need to purchase other properties in the Claremont
Development in order to excavate source material.

Comment #3: The Proposed Plan states that it may be necessary to
temporarily relocate residents other than those who reside in
houses with canals beneath them,  particularly residents on East
Camplain Road and Florence Court,  due to a possible road closure.
The following questions were raised concerning the possibility of
temporary relocation of residents located on Florence Court and

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East Camplain Road: Is temporary relocation mandatory?  To avoid
temporary relocation, would it be possible to park on another
street and walk to our homes?

Response: Temporary relocation is a voluntary program.  If it
becomes necessary to close a portion of a road during
construction, EPA would make temporary relocation available to
residents directly affected by such a closure on a voluntary
basis.  If a road closure becomes necessary, those residents
directly affected by limited access to their homes may either be
temporarily relocated or may park their vehicles on another
street and walk to their house.

Comment #4: Do the temporarily relocated residents find their own
apartments or does EPA find an apartment for them?  Who pays the
rent?  Is there a certain amount that EPA would allow for rent?

Response: Should EPA offer to temporarily relocate a resident and
the resident agrees to be temporarily relocated, EPA would find a
rental property for that resident and make payments directly to
the landlord.   The resident would continue to have financial
responsibility for his/her home (e.g. mortgage).  If a resident
finds their own rental property, the amount of rent a temporarily
relocated resident would be entitled to would be based on a
typical rent for a rental property in Manville.

Comment #5: If we live in a home with 3 bedrooms, have a yard and
a basement, how does EPA accommodate us during temporary
relocation - do we get a comparable living situation?

Response: Temporarily relocated residents may choose from a range
of lodging options, depending on family size and needs.  These
include apartments and single-family houses that are available in
the area. Consideration will be given to family size, commuting
patterns to work and school, whether the family has pets and
personal preferences.  Relocation specialists will work with
families to help identify their needs and preferences.

Comment #6: A resident asked if security personnel would be
provided to watch houses during the period of temporary
relocation.

EPA Response: Twenty-four hour security would be provided during
the cleanup activities.

Comment #7: A resident expressed concern that EPA had indicated
it could take up to one year to complete the permanent relocation
of affected property owners, and that seemed like a long time.

EPA Response: EPA estimates that the permanent  relocation process

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 will  take nine months  to one  year,  from  the  start of the process
 until the last person  is permanently relocated.  It is EPA's
 experience that some relocations  will progress quickly and others
 may take up to one year.

 Comment  #8:  Should homeowners in  the drip area continue to invest
 their money in their homes  to do  general maintenance?

 EPA Response:  Sampling results for  the subsurface soil conditions
 will  be  provided to residents this  summer.   These results will
 indicate if  other source areas are  present in the development.
 Should other areas of  source  material be identified in the
 community,  it  may be necessary to purchase additional properties
 to  excavate  such material.  Therefore, it is recommended that
 residents wait until this data is provided to them before major
 home  renovation projects  are  implemented.

 2.  Remedial  Construction


 Comment  #9:  As part of  construction activities, EPA plans to
 control  dust and odors  to the maximum extent practicable.
 Several  questions were  raised concerning dust and odors
 including: how does EPA plan  to control odor and dust; can EPA
 power  wash houses surrounding the construction area to remove
 dust  from the  houses; will  odors  and dust get into peoples houses
 and into their carpets,  and if  so,  will EPA replace those
 carpets?

 EPA Response:  EPA will  take measures  to control dust and odors
 during remedial  construction  activities.  The specific
 engineering  controls used to  limit  dust and odor emissions will
 be considered  during the  design stage of the project.   EPA's
 efforts  in,dust  control would focus  on, preventing the migration
 of any potentially contaminated dust.  However, EPA has pressure-
 washed buildings  at other sites to  remove dust from non-
 contaminated construction activities.  Odor controls will be put
 in place  to  limit  odors during remediation activities.  It is not
 anticipated  that  odors will penetrate carpeting to such an extent
 that EPA will  need to replace  it.

 Comment  #10s One  resident inquired  if it would be possible to
move a house that  is located  above  the canal source area,  dig out
 the source material, and  then replace the house back on its
original  location.

EPA Response:  The  EE/CA report considered moving houses off their
foundations  to remove the source material; however,  due to space
limitations, this  was not considered practicable.  In other
residential  communities with  contamination beneath houses,  EPA

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has underpinned the foundation of the house,  and removed the
contaminated material.  Underpinning is an alternative to
demolition.  However, use of such an option is dependent on the
lateral and vertical extent of source material found in the deep
soils on the property.  Deep soil sample results that will
provide information on the extent of source material in the
community will be available this summer.  This information will
be a significant factor in the decision on whether a structure
may be underpinned or may need to be demolished to safely remove
source material.

Comment #11: Several questions/comments were raised about the
time of operation of cleanup activities and length Of time it
would take to complete construction activities.  These
questions/comments were: What hours and days will construction
activities be conducted; if this site is a priority, would seven
days a week be necessary to get the site cleaned up in an
expedited fashion; if resources applied to the cleanup are
doubled, the work will be completed in half the time; how long
will the cleanup take; which lagoon will be cleaned up first,
lagoon A or lagoon B?

EPA Response: It is anticipated that construction activities will
be carried out five days a week from approximately seven o'clock
in the morning to five o'clock in the evening.  As at other
remediation sites situated in residential neighborhoods, remedial
workers typically arrive at the site at seven o'clock in the
morning.  At that time, health and safety meetings are conducted
and the day's activities are planned and coordinated.  Operation
of heavy equipment may not start until an hour later.  Community
input will be taken into consideration in establishing the hours
of construction activities.

EPA realizes that the schedule of construction activities would
be shortened if construction were to take place seven days a week
or if resources allocated to the work were doubled.  However,
these approaches may pose a great deal of inconvenience and
burden on the community.  Community input during the design phase
of the project will be solicited to achieve a balance between the
speed of remediation and community disruption.

It is anticipated that cleanup of the lagoon and canal areas
would be completed in three and a half to four years.  This time
frame includes approximately one year to design and relocate the
residents, and two to three and a half years to conduct remedial
construction activities.

The decision on which area gets cleaned up first will be made
during the design process - with community input.

Comment #12: Several questions/comments were raised regarding the

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flow of traffic into and out of the community including the
resident's accessability to their community,  as well as the
amount of truck traffic that is planned for construction
activities.  Specific questions/comments were: the possibility of
closing roads in the community will restrict  access to the
development - there would be no way for residents or emergency
services to get in or out of the development; how many dump
trucks will it take to remove 44,000 cubic yards of material?

EPA Response: The remedy would be designed to keep access to the
Claremont Development open at all times.  The construction
activities would be designed to limit the restriction of traffic
flow and avoid a complete road closure.  However, should it
become necessary to temporarily close a portion of a road to
carry out remedial activities, detours would be provided that
allow access to the development.  In the event that detours
become necessary, emergency services and residents in the area
would be informed of such detours before they would be
implemented.

The number of dump trucks required to remove 44,000 cubic yards
of material and backfill the excavated area with clean fill is
estimated to be approximately 3,300 trucks.  However, further
consideration of roadway weight limits and traffic controls will
be considered in the design and construction phases of the work
to determine the number of trucks needed.  In addition, traffic
patterns used and the frequency of trucks entering and exiting
the development will also be considered during design, with
community input.

Comment #13: A number of questions were asked concerning the
manner by which material would be transported out of the
community during remedial construction activities: would the
trucks be sealed; how would the trucks be loaded without getting
the waste material on the tires and wheels and spreading it
through the community?

EPA Response: All vehicles used to transport the waste material
would be sealed before they leave the loading area and exit the
development.  Truck tires would be cleaned before leaving the
loading area to prevent tracking the waste material through the
development.

Comment #14: Several questions focused on the identity and number
of remediation workers that would be used: are the remediation
personnel federal workers or private contractors; how many
workers would be used?

EPA Response: Cleanup work at Superfund sites is typically
performed by private firms under contract with the government or

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 PRPs.  The  remediation workers at the Federal Creosote site would
 be  employees  of private  firms that are specialized in remediation
 work.  The  number  and type of workers required will vary during
 different phases of  the  work.  Private contracting firms will
 recommend the number of  employees needed to perform specific
 tasks which are subject  to EPA or United States Army Corps of
 Engineers  (USAGE)  approval.  However, a remediation contractor
 has not been  selected to undertake construction work at this time
 and, therefore, the  number of workers required is not yet known.

 Comment #15:  What  happens to fences, sheds, and pools in the back
 yards of properties  where it is necessary to excavate canals or
 exit trenches?

 EPA Response: If a shed  can be moved out of the way of the
 excavation  area without  compromising its structural integrity, it
 would be moved.  However, if the shed cannot be moved and
 replaced intact in its current condition, the structure would be
 demolished  prior to  excavation and be replaced after remediation
 work on that  property is completed.  In the case of fixed
 structures  such as pools and fences that may be located in the
 area to be  excavated, it is anticipated that such structures
 would be demolished  and  replaced.                             ^

 Comment #16:  One commenter stated that he had information that
 led him to  believe that  the cleanup of industrial sites takes
 precedent over the cleanup of residential sites.  The same
 commenter also stated that he noticed in the Proposed Plan that
 parts of the  Rustic  Mall may be located over the canal area and
 asked if the  cleanup of  the Mall could be performed at the same
 time that cleanup  of the Claremont Development takes place.

 EPA Response: EPA  response actions are designed to mitigate
 threats to  human health  and the environment regardless of whether
 such threats  are located in a commercial or residential setting.
 In  the case of the Federal Creosote site, EPA focused its
 investigation efforts in the residential community where the
majority of the source material is located and,  therefore,  poses
 the greatest  risks to human health and the environment.

EPA is aware  of the  potential for other source areas to be
 located beneath the  Rustic Mall.   As a result, EPA is currently
 investigating subsurface soils in the Mall.  Should the need
 arise to cleanup portions of the Rustic Mall,  EPA may be able to
 coordinate  the cleanup of the Rustic Mall with the residential
neighborhood.

 Comment #17:  Would EPA still remediate the canal and lagoon areas
 if  a commercial development were to be built in place of the
residential development?


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EPA Response: EPA would remediate the canal and lagoon material
if a commercial development were to be built in place of the
residential development.  The canal and lagoon material are the
source of soil, groundwater, and possibly sediment contamination
in the area.  The source material within the lagoons and canals
represents an uncontrolled release into the environment and,
therefore, would be remediated irrespective of the future use of
the land.

Comment #18: One commenter stated that the Proposed Plan was
vague in terms of concrete specifications for the remedial
action.

EPA Response: EPA seeks public comment to ensure that the
criteria of community acceptance for a preferred remedy has been
considered before EPA invests considerable resources in design of
a remedy.  The intent of the Proposed Plan is to provide the
public an opportunity to comment on what EPA proposes to do at a
site.  The specifics of how the work will be performed is a
component of design which usually begins only after community
acceptance criteria is given consideration.

3. Health Concerns

Comment #19: One commenter asked what creosote does to the body.

EPA Response: Coal-tar creosote is a blend of over 200 compounds
and approximately 85% of it is composed of polycyclic aromatic
hydrocarbons  (PAHs).  Although no data exist which suggest PAHs
are human carcinogens, some of the PAH components of creosote
have been classified by EPA as probable human carcinogens.  In
studies conducted on animals, PAHs have been associated with
certain types of cancers.  Therefore, as part of its mission to
protect public health, EPA assumes that PAHs may also cause
certain types of cancer in humans.  Certain non-cancer health
effects have also been associated with exposure to PAHs and
creosote.  These include irritation of the respiratory tract and
skin irritation.

Comment #20: Is anyone in danger of dying from the creosote?
What is the mortality rate of living in the Claremont
Development?

EPA response: No one can give a precise answer to the question of
mortality.  EPA evaluated the potential for current or  future
exposure  to contaminated soil resulting in an increased risk of
cancer and found a  one  in 10,000 chance of developing cancer
during a  lifetime of exposure to contaminated soils over  a 30-
year period for most of the residents  in the community.   When
determining risk, EPA makes conservative assumptions about

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 exposure  to contaminants.   For  instance,  it  is assumed that
 people  would ingest  small  amounts of  soil every day for a period
 of  30 years.   EPA combines that information  with conservative
 assumptions about the  toxicity  of the chemicals that comprise
 creosote, which in this  case, are predominantly PAHs.  EPA is
 most concerned about PAHs,  which have been demonstrated to cause
 some types  of cancers  in animal studies.  Although PAHs have not
 been demonstrated to cause cancer in  humans, EPA cautiously
 treats  any  chemical  that causes cancer in animals as if it has
 the potential to be  a  human carcinogen.  The risk assessment for
 the Federal Creosote site,  therefore, takes  a conservative
 approach  to evaluate the reasonable maximum  exposure to the soil
 and combines  this with information on the toxicity of the PAHs to
 estimate  the  potential risks from exposure to contaminants in the
 soil by the residents  of the Claremont Development.

 Comment #21:  A resident  suggested that people with health
 concerns  might want  to get a blood test to give them peace of
 mind.

 EPA response:   Special tests are available which are able to
 detect  PAHs attached to  certain body  tissues or in blood.  These
 tests,  however,  are  limited in  that they cannot determine the
 extent  or source of  exposure or if health effects will occur due
 to  exposure to PAHs.   Since these tests require special
 equipment,  they cannot usually  be performed  in all doctors'
 offices.  The names  of doctors  who can perform these tests are
 available from the Agency  for Toxic Substances and Disease
 Registry  (ATSDR).

 Comment #22:  Some residents inquired  if specific types of land
 use in  the  Claremont Development posed any threat to their
 health, specifically:  is it safe to let small children play on
 this potentially hazardous  soil; is it safe  to eat the vegetables
 grown in my garden?

 EPA response:  A portion  of  the  Claremont Development was part of
 the former  drip area.  In  this  area,  treated lumber was left to
 drip and dry  immediately after  treatment.  Creosote compounds
 were detected in surface soils  at many properties in this area.
 Typical average  exposures  are not expected to contribute
 significantly to an  increased risk.   Because the subsurface soil
 investigation is not complete and a thorough risk assessment has
 not yet been  conducted to  determine what the potential risks are,
 activities  with high exposures  to the subsurface should be
 avoided.  PAHs,  which  are  the primary chemicals of concern at the
 site,  are not  readily  bioaccumulated  in vegetables, and,
 therefore,  increased risks  from exposure to  home-grown vegetables
 are not expected.  However, as  a extra precaution, residents may
 consider a  raised garden -  bringing in a few inches of topsoil in
which to plant  vegetables.

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Comment #23: A resident questioned whether the creosote
components  found in the Millstone River affect the Elizabethtown
Public Water system, which uses the Millstone River as a source
of public water supply.

EPA response:  Samples of surface water and the sediment were
taken from  the Millstone River upstream of the public water
supply intake.  Creosote components were detected in the sediment
of the river, however, no components of creosote were detected in
the surface water.  EPA has scheduled additional sampling of the
surface water and sediment for this summer.  In addition, the
Elizabethtown Water Supply performs routine testing of the water
on a regular basis to ensure the safety of the water supply.

Comment #24: A resident wanted to know why their development was
on the National Priorities List (NPL) if the site does not pose
an immediate or acute health threat.  Several other residents
made references to asbestos contamination from the Johns-Manville
Company.  They claimed that residents have been dying from
asbestos exposure for 30 years and nobody did anything.  They
also said that asbestos from Gushers field has been contaminating
the Raritan River for 50 years, and that Walmart was built on top
of the asbestos-contaminated property.  Their view is that people
have lived  in the Claremont Development for 35 years without
incident, and for EPA to place the site on the NPL is overkill.

EPA Response: The Superfund Program is designed to investigate
and clean up uncontrolled releases of hazardous substances into
the environment.  In the case of the Federal Creosote site,
contamination was discovered in a residential area.  It has been
determined that the site does not pose an immediate health threat
to the residents of the Claremont Development.  However, the
contamination is extensive, is uncontrolled,
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responsible party  (PRP) for the Federal Creosote site.   The PRP
may be provided an opportunity to fund or undertake the work.
Should the PRP elect not to fund or undertake the work, the work
will be funded by the United States government and the  State of
New Jersey.  In the latter case, ninety percent of the  cost will
be the paid by the federal government, and ten percent  of the
cost of the remedial action will be paid by the state.


5.    Property Ownership Issues and Potential Liability to
      Homeowners

Comment #26: A question was raised concerning property  deeds,
particularly, if homeowners would have clean deeds at the
completion of the remediation.  There was concern expressed about
what type of notation would be placed on the deeds to indicate
that EPA had cleaned up their properties.

EPA response:  At the conclusion of the cleanup, EPA will provide
documentation to residents which states that properties were
cleaned and that the homeowners have unrestricted use of their
properties.

Comment #27: Should homeowners in the Claremont Development
decide to sell their properties at any time after the cleanup,
would there be any future liability to those selling their homes?

EPA response: EPA will not assign federal liability for cleanup
actions to the homeowners of the Federal Creosote site, but can
make no assurances about lawsuits from others.  EPA will stay
involved with the community after the cleanup to provide
residents with any requests for documentation or information on
behalf of prospective buyers.


B.    WRITTEN COMMENTS RECEIVED DURING THE  PUBLIC COMMENT  PERIOD
      PROM THE POTENTIALLY RESPONSIBLE PARTY

Comments and concerns which were not addressed at the public
meeting were accepted  in writing during the public comment
period.  Written comments that were received from Kerr-McGee, a
potentially responsible party, appear in this section of the
responsiveness summary, verbatim, in  italicized print.   These
written comments are categorized by relevant topics and presented
as follows:

      1.     Superfund Process
      2.     Health/Risk Characterization
      3.     Proposed  Remedy
      4.     Relocation

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 1.   Superfund Process

 Coimnent #28:  The scope of the EPA's preferred alternative  is not
 compatible with the definition of Operable  Unit provided in the
 National Oil  and Hazardous Substances Pollution Contingency Plan
 (NCP).   The Proposed Plan indicates that  the  cleanup  strategy  for
 the site is the first phase,  or Operable  Unit, and is considered
 to  be  an early action that only addresses cleanup of  the highly
 contaminated  source areas.   The NCP defines an operable unit as a
 discrete action that comprises an incremental  step toward
 comprehensively addressing site problems.

 The highly contaminated soils and sludges identified  in canals A
 and B  and lagoons A and B can reasonably  be identified as  source
 materials whose location satisfies the NCP  definition of an
 operable unit.  However,  the $58,000,000 estimate for  EPA's
 preferred alternative is not consistent with an action that is
 supposed to be  a "discrete  portion of the remedial response".
 For example,  the average Superfund cleanup  construction project
 cost is now $10,000,000.   The current average  reflects a decrease
 of  $1.2 to $1.6 million per project over  the last two years.
 Moreover,  the Superfund Program was able  to affect these savings
 while maintaining protective  cleanups that  continue to achieve
 the mandate for "permanence"  and treatment  of  waste.   The  site is
 neither so complex,  nor the exposure  to hazardous substances so
 acute,  as to  warrant an expenditure of almost  six times the
 current average.

 If  the  EPA preferred remedy is  not an operable unit,  the EE/CA
 suggests it is  a removal  action.   However,  the estimated cost  and
 duration of the EPA preferred remedy  would  also not justify it as
 a removal  action under  the  NCP.

 EPA responses The NCP states  that  an  operable unit may address
 geographical portions of  a  site, specific site problems,  or
 initial  phases  of an action,  or may consist of any set of actions
 performed  over  time or  any  actions  that are concurrent but
 located  in different parts  of the  site.  EPA's decision to
 identify the lagoon and  canal source material as an operable unit
 is  consistent with the NCP  definition of an operable unit,  and is
 a discrete  action comprising  an incremental step toward
 comprehensively  addressing  site problems.   The $59,100,000
estimate is specific only to OU1,  a discrete portion of the

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 remedial response,  and is  not  applied  to any other area of the
 site.

 It is  misleading to compare  the  cost of any one site to an
 "average cleanup"  cost.  The cost assumptions found in the
 remedial alternative cost  estimate are set forth in detail in the
 EE/CA  and rely,  in part, on  vendor submissions.  In particular,
 the cost of  treatment adds considerable expense because the
 source material  is a RCRA  listed waste which must be treated in
 accordance with  RCRA land  disposal restrictions.

 Comment #29:  In  light of the comment above, EPA should have
 gathered more information  regarding the nature and extent of
 contamination, developed remedial alternatives that encompassed
 all the presumptive remedy options, and performed a more
 comparative  analysis typical of  a. feasibility study.  As
 explained later  in this comment  document, there exist other
 options,  not considered by EPA,  to accomplish the objectives set
 forth  in the proposed plan for this operable unit for
 considerably less  cost.

 EPA response: The  EE/CA considered a number of remedial
 alternatives  including in-situ treatment (i.e., slurry grouting,
 chemical  grouting),  off-site disposal, bioremediation, thermal
 desorption,  and  incineration.  Analysis of these alternatives were
 provided in  the  EE/CA and  is discussed in greater detail below.

 Comment  #30:  Jn  opting for the permanent relocation at ten to
 nineteen residents,  there  was  an obligation under the NCP to seek
 a  cost-effective remedial  action once  the affected areas were
 vacated.

 The NCP provides for remedial  action costs associated with the
permanent relocation of residents.  In doing so, it is presumed
 that relocation  (either alone  or in combination with other
 measures)  is  more  "cost-effective" than, and environmentally
preferable to, the  secure  disposition  off-site of such hazardous
 substances that  may otherwise  be necessary for the protection of
 the public health  or welfare.

Relocation of residents in this plan appears to be for practical
purposes,  i.e.,  to  facilitate  the excavation of the buried wastes
 as ATSDR  has  determined that there are no short-term exposure
 risks.   However, if residents  are relocated to facilitate
 cleanup,  longer-term risks must  also be reduced.  This reduction
 in potential  risks  would suggest that  the limitations to on-site,

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in-situ or ex-situ remedial options,  which were eliminated from
consideration in the Proposed Plan would have been removed.
Hence, on-site actions should be reasonably considered in
conjunction with relocation.  The plan should therefore evaluate
both ex-situ and in-situ, on-site alternatives, because they
would considerably reduce the remedial costs.

EPA response: The scope of the permanent relocation is limited to
properties that have structures located either above or adjacent
to source material.  The EE/CA considered on-site,  in-situ and
ex-situ remediation, however, the space provided by the permanent
relocation of ten to nineteen properties is not contiguous and is
limited to such an extent that these remedies could not be
effectively implemented.

Comment #31:  The £58,000,000 preferred alternative identified in
the Proposed Plan by EPA warrants a review by the National Remedy
Review Board (NRRB).

The EPA administrative memorandum announcing the formation of the
NRRB anticipated that the board would conduct its review and make
its recommendations on a preferred remedy before a proposed plan
is issued for public comment.  Moreover, the involvement of the
NRRB was extended to the review of non-time critical removal
actions, applying the same criteria and emphasizing that the
review occur before the Engineering Evaluation/Cost Analysis
(EE/CA) is issued for public comment.

There is no mention in the Proposed Plan that an NRRB review took
place, or if it did, what the recommendations of the NRRB were.

EPA response:  The preferred alternative was reviewed by the NRRB
before the Proposed Plan and EE/CA were made available for public
comment.  The recommendations of the NRRB were included in the
Administrative Record for the site.  The Proposed Plan did not .
explicitly identify the NRRB recommendations, however, the NRRB
recommendations were taken into consideration in the selection of
the preferred alternative and are addressed in the Record of
Decision.

Comment #32:  By conducting  the Engineering Evaluation/Cost
Analysis  (EE/CA), EPA acknowledged that it could not  take
advantage of the generic justification provided by  the
"Presumptive Remedies for Soils, Sediments, and Sludges at Wood
Treater Sites."
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 EPA has identified presumptive remedies for wood treater sites,
 which the agency believes represent appropriate response action
 alternatives.  The actions identified in the presumptive remedy
 document are expected to be used except under unusual site-
 specific circumstances.   Presumptive remedies are expected to
 save time and reduce costs and,  therefore,  generally should be
 used.  EPA also acknowledged that it might be possible to
 accelerate remedy selection for non-presumptive technologies by
 performing a conventional Remedial Investigation and Feasibility
 Study (RI/FS) or EE/CA.

 EPA response: An EE/CA may consider a broad range of remedial
 alternatives that EPA may consider as appropriate response
 actions.   The bioretnediation and thermal desorption  technologies
 were considered in the EE/CA.   The EE/CA presented rationale why
 these two technologies were not  considered appropriate for on-
 site application and provided an analysis of each of these
 alternatives for off-site application.   Many of the  presumptive
 remedial  approaches presuppose either the viability  of on-site
 action or the availability of open land to perform treatment,
 neither of which are practical options  in this neighborhood.

 Comment #33:   EPA adopted presumptive remedial approaches to
 streamline and accelerate the remedy selection process.   However,
 at  the site,  EPA still found it  necessary to carry out an EE/CA
 to  justify its remedy selection.   Although the EE/CA did
 streamline the remedy selection  process,  the $58,000,000 cost for
 the remedy can hardly be viewed  as a minimized cost.   This is due
 largely to the fact that excluding the  no action alternative,  of
 the five  remedial  alternatives considered in the EE/CA,  four were
 predicated on general response actions  involving excavation and
 off-site  disposal  and treatment.   Hence,  the largest  engineering
 cost component (excavation and off-site treatment and disposal),
 that represents in excess of 50% of the estimated remedial cost,
 was common to the  majority of alternatives.  As a result,  the
 EE/CA was  skewed in its  evaluation.   The EE/CA did not consider
 alternatives  that  employed bioremediation and/or thermal
 treatment,  two additional technologies  identified in  the wood
 treater presumptive remedy document.

 EPA response:  Remedial alternatives  such as bioremediation and
 thermal treatment  were given consideration in  the  EE/CA.   The
 preferred  alternative is  thermal  treatment of  the  source
 material.   In weighing these remedial alternatives, consideration
was given  to  a  number of  criteria  that  include  compliance  with
ARARs and  implementability.  RCRA is  a  federal  law that mandates

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procedures for treating, transporting, storing,  and disposing of
hazardous substances.  To comply with RCRA,  once the material is
removed, it must be treated prior to disposal.  This treatment
may occur either on site, or if treated off site,  the material
must be handled at a RCRA-permitted facility.   Space limitations
at the site render on-site treatment alternatives
unimplementable.  No RCRA-permitted bioremediation facilities
were identified in the EE/CA and, therefore, that alternative was
not carried forward for additional consideration.

Comment #34:  The EE/CA was biased in its identification of
remedial alternatives, even in identifying those that are
consistent with presumptive remedies for wood treater sites.

The EE/CA considered only certain alternatives relating to
bioremediation, thermal desorption and incineration technologies,
the identified presumptive remedies for wood  treater sites.
However, in deciding to conduct  the EE/CA, EPA should have
considered on-site, ex situ or in-situ bioremedial and/or thermal
options that would achieve the stated objectives, particularly as
such options become practical with resident relocation.
Moreover, in-situ options are less likely to result in the
magnitude of potential exposures to the community during
excavation as compared to the EPA's preferred alternative.

EPA response: The EE/CA considered a wide range of alternatives:
in-situ treatment, bioremediation, thermal desorption,
incineration, and off site disposal.  The lack of open land area
within the development as well as the viability of performing an
inherently industrial activity in a residential neighborhood were
two issues identified in the EE/CA that led to the conclusion
that on-site options for treatment and disposal of excavated
materials were not implementable.  In the event that it would
become necessary to permanently  relocate residents from nineteen
properties, permanent relocation of residents at these properties
would not provide enough space to make either bioremediation or
thermal treatment alternatives practicable since the nineteen
properties are not contiguous throughout the  development.  There
are areas where relocation would occur on adjoining properties,
however, this still does not provide  adequate space for on-site
treatment.

Comment #35:  On-site options, which  are  consistent with  the
presumptive remedies for wood  treater sites,  would be  viable  once
residents are relocated.

EPA response:  As  stated above,  EPA disagrees with the assessment
that on-site options would be viable  once residents are

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 relocated.   The permanent relocation of  residents  is limited to
 those areas where source material  is located, and  the remedy
 anticipates that the remaining home  owners would not be
 relocated.

 Comment #36:   The presumptive remedy guidance recognizes  that,
 among other things,  there may be significant advantages of
 innovative  technologies over the presumptive remedies that
 warrant their consideration.   To the extent in-situ application
 of one or more of the presumptive  remedies would be considered
 innovative,  the NCP expects EPA to consider an appropriate
 innovative  technology.   As indicated in  EPA's Presumptive Remedy
 Policy and  Procedures,  presumptive remedies do not preclude the
 consideration of innovative technologies should the technologies
 be demonstrated to be as effective or superior to  the presumptive
 remedies.

 EPA response:   The NCP  contains the  expectation that EPA will
 consider the  use of  innovative technologies when such
 technologies  offer the  potential for superior implementability
 and fewer adverse impacts compared to other available approaches.
 On-site,  in-situ technologies  were given consideration in the
 EE/CA.   They  were considered to be unimplementable in a
 residential setting  such as the Claremont Development and further
 would  not provide a  satisfactory degree  of permanence as
 discussed further below.

 Comment  #37:   The only  complete discussion of the balancing
 criteria, other than cost, appears for the first time in the
 Proposed Plan.   Since the Proposed Plan  only presented two
 remedial  alternatives,  one being No  Action, other remedial
 alternatives,  including those  that should have been considered,
 did not benefit from this more detailed  evaluation.

 EPA response:   Remedial  alternatives  other than those discussed
 in the Proposed Plan were  given consideration and evaluated in
 the EE/CA.  Alternatives  in the EE/CA were evaluated on the basis
 of balancing criteria,  such as  long-term effectiveness,  short-
 term effectiveness,  implementability, and the reduction of
 toxicity, mobility and volume  through treatment.   Since the
 source material  to be addressed in OU1 is located within a
 residential community without  adequate space,  not all remedial
 alternatives considered  in the  EE/CA were carried through to the
 Proposed Plan, particularly remedial  actions that would require
 locating objects  such as an incinerator,  thermal desorber, or a
bioreactor in  a  densely-populated  residential community.

Comment #38:   EPA's preferred  remedial alternative was not

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 compared to remedial  alternatives  that employed the other
 presumptive wood treater remedies, or remedial alternatives
 developed,  using all  of the balancing criteria, i.e., long-term
 effectiveness  and permanence, reduction in toxicity, mobility and
 volume  and  short-term effectiveness, in addition to
 effectiveness,  implementability and cost.  These criteria, along
 with  the other threshold criteria  were only discussed in the
 Proposed Plan  when  the basis of comparison was only No Action.
 Therefore,  the EPA's  preferred remedial alternative was not
 afforded a  full comparative analysis, which focuses on the  .
 relative performance  of each considered alternative, as
 contemplated in the NCP.

 EPA response:   Other  presumptive wood treater remedies such as
 bioremediation,  thermal desorption, immobilization, and
 incineration were considered in the EE/CA.  Immobilization was
 not considered effective since it  is better suited for inorganic
 contaminants.   The  contaminants at the site are organic compounds
 derived  from creosote waste.  As discussed earlier,
 bioremediation and  thermal desorption were considered as on-site
 and off-site treatment alternatives in the EE/CA.   Due to space
 limitations  and the residential nature of the community,  the on-
 site options of  these alternatives were not carried forward for
 further  analysis.  Off-site options for these alternatives were
 also considered in  the EE/CA, however,  these options were not
 considered viable, due to the lack of facilities that are
 permitted to treat  this RCRA-listed waste.

 Comment  #39:   The EE/CA should have considered waiving certain
ARARs in light  of the costs for the considered remedial
 alternatives.

 The Proposed Plan states that the material in the source areas is
 a listed RCRA-waste.  Off-site treatment and disposal would
 therefore need to be performed at a RCRA-permit ted facility.  The
 EE/CA identified this issue as an ARAR,  effectively eliminating
 any other off-site  thermal treatment, except incineration, as an
 option because no such RCRA-permitted facility was identified.
 Consequently,  the EPA's preferred remedial alternative adopts
 off-site  thermal treatment by an incinerator.

 Once again,   the  cost associated with the EPA's preferred remedial
alternative  ($58,000,000)  should have triggered a more in-depth
review of treatment options.  Aside from the previously mentioned
alternatives, which are consistent with presumptive remedy


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 guidance and more cost effective,  the limited alternatives
 considered in the EE/CA could benefit from consideration of
 waiving this ARAR.

 According to the NCP,  a remedy must  satisfy  the two threshold
 criteria,  protection of human health and  the environment and
 compliance with ARARs (unless a specific ARAR is waived).
 Although cost is not a factor in identification of ARARs, CERCLA
 authorizes the waiver of an ARAR with respect to a remedial
 alternative if any one of  six bases  exist.  Specifically, cost
 may be  a consideration when determining whether a waiver is
 justified for "technical impracticability",  "equivalent level of
 performance",  or "Fund-balancing".

 A waiver for the ARAR associated with the EPA's preferred
 remedial alternative that prevents off-site  treatment at a non-
 RCRA-permit ted facility should have been evaluated based on
 "equivalent level of performance" or "Fund balancing".

 While cost is not considered  in evaluating equivalence, this
 waiver  could provide cost-saving flexibility.  Because the
 estimated cost for  treatment  and disposal is more than 50% of the
 total estimated preferred remedial alternative cost, less
 expensive  technologies that can achieve the same outcome should
 have been  explored before adopting a costly approach.   Rejection
 of a comparable technology simply because of an action-specific
 ARAR is  unjustifiable.

 Since Fund monies are  being expended for the preferred remedial
 alternative,  consideration should have been given to invoking a
 Fund-balancing waiver  with respect to the need for using an off-
 site RCRA-permitted  facility  for treatment.  EPA's policy is to
 consider this waiver when the total cost of the remedy is greater
 than four  times the  national  average cost of remediating an
 operable unit  (currently 4 X  $10,000,000 or $40,000,000).  As the
 estimated  cost for the preferred remedial alternative exceeds
 this threshold,  a waiver may be warranted if this single site
 expenditure  would place  a disproportionate burden on the fund.

EPA response:   The commenter  states that EPA should have
conducted a more  in-depth review of treatment options.  As stated
in the ROD, EPA screened out other treatment options.   The
regulatory treatment requirement for this waste is the RCRA land
disposal restrictions  (LDR) and that rule requires meeting a

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treatment level for this waste using any available technology.
On-site treatment is limited due to site-specific factors.   Off-
site permitted treatment is limited to thermal treatment.

The commenter also states that the Agency should have considered
invoking the Fund-balancing waiver because of the need of  using
an off-site RCRA permitted facility for treatment. EPA selected
off-site treatment because of site-specific constraints, not
because of ARARs.  ARAR waivers (in this case the Fund-balancing
waiver)  only have application to on-site remedies.  The use of  an
ARAR waiver either through "technical impracticability,"
"equivalent level of performance," or "Fund-balancing" does not
have relevance at this site because off-site treatment is  the
selected remedy.

Comment #40:  The administrative record was not readily available
and is incomplete.  The administrative record was not available
at the EPA-Superfund Records Center in New York.  The
administrative record at the Manville Public Library is
incomplete.  For example, it does not include information such as
the raw analytical data, the QA/QC packages and the boring logs.
We reserve the right to review this data and comment further at a
later date.

EPA response:  The administrative record was available at  the
EPA-Superfund Records Center in New York during the public
comment period.  The administrative record was also available at
the Manville Public Library.  The administrative record included
boring logs of sample points.  This information may be found in
the Environmental Response Team Report titled "Technical
Memorandum - Site Investigation Report", November 30, 1998.  This
report also provided data summary tables of all samples taken
during ERT's investigation of the lagoon and canal areas.
However, because of the voluminous nature of the documentation
that supports the data tables in the ERT report, e.g., QA/QC data
validation packages and raw data sheets, such documentation was
not included in the administrative record.  This  "raw data" is
typically not made part of administrative records.  However, EPA
has made this information available to the interested party and
extended the public comment period to provide the party a
reasonable opportunity to comment on that information in addition
to the administrative record.

2.  Health/Risk Characterization:

Comment #41:  The distribution of PAH congeners does not resemble
other wood  treating sites, and the assessment of potential risks
may therefore need to be reevaluated.   Virtually  every polycyclic


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 aromatic hydrocarbon (PAH)  was  detected at  the site, including
 all  species of carcinogenic PAHs  (cPAHs).   Unusually, however,
 benzo(a)pyrene (BaP)  is  consistently present as • 60% of the total
 cPAH risk.   Normally, BaP is a  minor constituent.  The EPA should
 make sure that a  QA/QC check has been done  to insure that BaP
 (and other PAHs)  are being  identified correctly.  Alternatively,
 the  risk assessment  performed by CDM Federal Programs may have
 incorrectly assumed  a log normal distribution for the
 contaminants.   Evidence  should  be provided  to support the use of
 a  log normalcy assumption.   Finally, CDM Federal Programs
 generally substituted one-half  the detection limit for non-
 detects.   In a small censured data set, this substitution may be
 inappropriate  and may have  contributed to the unusual
 distribution of PAHs observed.

 EPA  response:  All data used to  characterize risk at the site have
 been reviewed  using  appropriate Quality Assurance/Quality Control
 procedures  as  required by the CLP protocol.  This includes
 analyzing calibration verification standards, matrix spike/matrix
 spike duplicate samples,  and method blanks at the appropriate
 frequency to ensure  that  the analytical results meet the highest
 level of  QA/QC standards  so that results reflect a positive
 presence  of the contaminant in  samples, where present,  as well as
 accurate  and precise  concentrations.  All analytical data which
 are  used  in the risk  assessment must meet the QA/QC standards
 required  by the CLP protocol.

 The  comment also  states  that benzo[a]pyrene (BaP) contributes up
 to 60% of  the  risk from  carcinogenic PAHs.  It should be noted
 that  potential risk  from  exposure to carcinogenic PAHs (cPAHs)
 was  estimated  using  the Relative Potency Factor approach.  As per
 EPA  guidance,  cPAHs  are  evaluated based on their individual
 toxicity  relative to  BaP.   In this method, the relative potencies
 of BaP and  dibenz[ah]anthracene are 1.0,  while the relative
potencies of all  other cPAHs have been set at values which are
 orders of magnitude  less  than 1.0.  Using this approach,  it is
 likely that BaP would contribute a significant portion to the
 cumulative  risk associated  with cPAHs,  even when the
 concentration  of  BaP  is  consistent with other cPAHs.

 The  risk  assessment did assume  the data for each property were
 lognormally distributed.  This  assumption is based on two
 important pieces  of  information.  First,  approximately 10 to 12
 surface soil samples  were collected at each residence.   These
 data  sets are  too small to  statistically determine if the
 contamination  is  normally or lognormally distributed.  Second,
 EPA guidance ("Supplemental Guidance to RAGS: Calculating the
 Concentration  Term" OSWER;  Publication 9285.7-081) states that .it
 is reasonable  to  assume that data from soil samples are

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lognormally distributed.  This assumption is based on review of
many soil sample data sets for Superfund sites which show that
the data are lognormally distributed.

Actual constituent concentrations were used to develop the
exposure point concentrations used in the risk assessment.
Consistent with current EPA guidance (RAGS Volume I: Human Health
Evaluation Manual  [Part A] Interim Final [OSWER; EPA/540/1-
89/002] ), when results were reported as non-detects, one-half of
the reported detection limit was used to develop the exposure
point concentration.

Comment #42:  The site at present does not present unacceptable
exposure risks.  Although potential carcinogenic risk exists at
depth and, at least upon two occasions, apparent creosote tars
have come bubbling up to the surface, there is no fate and
transport analysis as to whether further excursions of impacted
materials to the surface are likely to occur.  ATSDR has
concluded that the site does not present an unacceptable public
health risk at present, which conclusion is at odds with EPA's
preferred alternative  (i.e., if current risks are acceptable an
extensive high cost remedy with significant short-term risks may
not be warranted).

EPA response:  PAHs associated with creosote are the main
contaminants of concern at the site.  Samples taken from the site
were analyzed for volatile organic compounds (VOCs), semivolatile
organic compounds  (SVOCs), and metals.   Among the SVOCs analyzed
were 23 PAH compounds, seven of which are classified as probable
human carcinogens.  Historically, PAH compounds have been
reported in several ways, including total PAH concentration
(TPAH), total carcinogenic PAH concentrations (CPAH),  and
benzo[a]pyrene equivalents  (BAP).  TPAH is the sum of all PAH
concentrations in a sample and is always greater than or equal to
CPAH, which is the sum of the portion of PAHs classified by EPA
as carcinogenic.  BAP is a weighted concentration based on the
individual carcinogenic PAHs and can be used to assess the
carcinogenicity of CPAH in terms of benzo[a]pyrene, which is a
carcinogenic PAH that has been extensively studied.

Data from the site indicate that the ground water, a source of
drinking water, is contaminated with creosote from the lagoons.
In addition, creosote was observed-being discharged from a sump
in a residence on Valerie Drive into the street.   PAHs, due to
their highly toxic and highly mobile nature at this site, are
considered a principal threat.  For these reasons, action is
needed to address the principal threat source material in the
lagoon areas.
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Although  the  quantitative risk assessment for the subsurface
soils  has not yet been  completed, site information indicates that
an  early  interim action is needed quickly to prevent further
environmental degradation and achieve a reduction in risk while a
final  remedial  solution is being developed.  Samples from the
lagoon areas  show that  the concentrations of PAHs in Lagoon A
were as high  as 1,862 ppm, and PAHs in Lagoon B were found to be
as  high as 2,548 ppm  (as BAP equivalents).  Under a direct
contact residential scenario, PAH concentrations that are above 9
ppm (BAP  equivalents) exceed a 10-4 risk and indicate the need
for action.

The more  specific findings of the soil baseline risk assessment
and the ultimate cleanup objectives for the site will be included
in  a subsequent ROD for the site.

Comment #43:  Risks to  the community will be exacerbated through
execution of  the preferred remedial alternative.  As noted in
EPA's  emergency listing, there are no unacceptable public health
risks  at  present.  However, the proposed excavation and hauling
off-site  of over 44,000 cubic yards of contaminated soil will
present considerable public health risk.  Increased exposures
from EPA's preferred remedial alternative include: mobilization
of  creosote tar components into groundwater and air (both vapors
and dust),  and  contamination of adjacent commercial and
residential properties,  and risks to community residents from
heavy-duty vehicular traffic.  Concerning the latter,  it should
be  noted  that the Claremont Development has limited access at
present,  which  access would be further limited by excavation
activities and  increased truck traffic at entry ways.   In
contrast  to EPA's preferred remedy, various in-situ remedial
alternatives  will minimize potential exposures to contaminants,
vehicular traffic and public health risks, although these
technologies  may require limited evacuation of some Claremont
residents.

EPA response:   Evaluation of the short-term effectiveness
criterion considered the period of time needed to achieve
protection and  any adverse impacts on human health and the
environment that may be  posed during the construction and
implementation  period until cleanup goals are achieved.
Mitigation of dust and  odors can be achieved by such engineering
controls  ranging from the use of wetting agents to prefabricated
structures during remedial activities at the site.

Mobilization  of creosote tar components in the groundwater is a
concern.   Groundwater sample results indicate that the creosote


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tar components are mobile and are present in the groundwater.   It
is the objective of the remedial action to reduce or eliminate
the mobility of the contamination at the site.   Engineering
controls will be used to ensure that the response action does not
increase the mobility of the source material.

EPA acknowledges that access to the Claremont Development is
limited and will design the response action such that access to
the Claremont Development is unimpeded.

As mentioned in previous responses, in-situ remedial alternatives
were given consideration in the EE/CA and found not to be
implementable.

Comment #44$ The Proposed Plan fails to indicate what the
estimated potential risks were for the two apparent excursions of
creosote tars to the surface.  Both EPA default and revised
cancer risk guidelines should be used to complete the analysis.
The analysis should consider the short-term nature of the
potential exposures, the actual constituent concentrations in the
material encountered, and the fact that these two excursions
represent the only known potential exposures over the 50+ years
that the materials have been at the site.

EPA response: The response to comment #42 addresses this comment.

Comment #45:  The site should be characterized more completely
concerning potential exposure pathways.  The site
characterization as presented in the Proposed Plan appears
incomplete, especially concerning physical parameters of the
subsurface.  A more complete description of physical properties
of creosote tars and hydrogeology are required to predict future
fate and transport of tar constituents, for accurate predictive
risk assessment and prior to implementation of any in-situ or ex-
si tu treatment technologies.  Critical issues which must be
examined and resolved prior to any fate and transport analysis,
risk assessment or remedy implementation include:
             The mobility of creosote  tars in the canal and
             lagoon areas;
      _      The consistency  (viscosity) of  these tars as
             compared to other viscous substances such as
             asphalt, molasses, heavy oil or light oil;
             The melting point and high  temperature water
             solubility of  tar constituents;
             The water solubility of tar constituents under
             ambient conditions;

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              The composition of subsurface soil with respect to
              granularity, carbon and clay content,  an
              permeabi 1 i ty;
              Whether creosote tars exist within both saturated
              and unsaturated zones; and
              Potential 'mobilization conduits created by sewer,
              optical cable and other lines which transect the
              si te.
 Resolution of these critical issues will have a direct  impact on
 the design and construction of the preferred remedial
 alternative.   Moreover,  the potential  adverse effects from such
 data gaps can cause schedule slippage  and cost overruns during
 the design and construction phases of  remedy implementation.

 EPA response:  EPA believes adequate data has  been collected in
 order to  select a remedy.   As reported in the ERT Technical
 Memorandum -  Site Investigation,  the material found  in  the
 lagoons is a  sludge like  material which has been found  in both
 the unsaturated and saturated zones.   The material found in the
 shallow portions  of the canals is a drier material,  however,  in
 some of the deeper  areas  of the  canals  this material has been
 determined to  be  a  sludge like material.   Further sampling is
 being conducted to  determine the pathways that  the material may
 have taken.  Additional sampling to fill in the data gaps
 identified in  the comment will be performed in  the design phase
 of  the project.

 Comment #46:   In-situ  remedial alternatives exist which will
 minimize  future risks.  As noted above,  excavation and  removal
 actions will exacerbate public health risks.   In-situ
 technologies exist,  however,  which will  alleviate future
potential  migration of creosote  tars to  the surface.  While some
 of  these might entail  partial  or temporary complete evacuation,
 these will prove  less  disruptive,  safer  and less costly than  the
proposed remedy.  Ostensibly,  if an in situ alternative remedy
 requires no excavation, no homes would need to  be destroyed.  If
relocation  is  for a longer term,  a viable sub-option, from a  risk
perspective, would  be  to  buy all  affected homes and, following
remediation, sell these homes  back to  the community.

EPA response:  Engineering controls  can be put  in place  to
mitigate short-term public health risks  during  the implementation
of the preferred remedy.   As discussed earlier, in-situ  remedial
alternatives were considered  in  the  EE/CA and were considered
impracticable.  Temporary  or permanent relocation of all
residents in the development is  far more  disruptive to  the

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community than the more limited relocation arrangement provided
in the preferred alternative.   EPA's preference,  as  presented in
the Interim Policy on the Use  of Permanent Relocations as Part of
Superfund Remedial Actions (June 30,  1999 OSWER Directive
9355.071P), is to address the  risks posed by the contamination by
using well-designed methods of cleanup which allow people to
remain safely in their homes and businesses.  Consistent with this
guidance, EPA will limit permanent relocations to structures that
are an impediment to implementing a protective cleanup.

3.  Proposed Remedy:

Comment #47:  It is premature to evaluate and select a preferred
remedial alternative for this site until after the investigation
and delineation activities are completed.  Based on the
significant uncertainties regarding the extent and volume of
impacted materials to be remediated, it is premature to complete
the evaluation and selection of a remedial option for the site.
As presented in the Proposed Plan, the volume of impacted
materials requiring remediation "may change substantially pending
a review of the subsurface data".  Such changes could
dramatically impact the number of houses to be relocated, the
number of affected residents,  the total costs and risks of
various alternatives, and the overall comparison of options.
Because  the ATSDR evaluation has indicated that there are no
unacceptable short-term risks, and because the waste has been
present for at least 40 years, it would be appropriate to wait
until the site investigation and evaluation activities are
completed prior to the final evaluation and selection of a
preferred remedy.

EPA response: EPA plans to implement the selected remedy in a
phased manner and will be initially moving forward with the
relocation of affected residents.  However, the agency does not
plan to begin the actual removal of the source area contamination
until the site-wide RI/FS is completed.  EPA believes that the
full extent of contamination within the development should be
known prior to the initiation of intrusive cleanup activities.
As indicated previously, the available data indicate that 32
residential properties need to be remediated, ten to nineteen of
which will require the permanent relocation of the residents.
Based on this data, EPA believes that excavation and off-site
thermal  treatment of the lagoon and canal wastes, while
maintaining the existing nature and character pf the development,
is the appropriate remedy for the site.   If, however,  the ongoing
investigation of the remaining 105 properties in the development
reveals  extensive contamination necessitating the purchase  of  a
significant number of additional properties, EPA may reconsider

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 that portion of  the proposed remedy dealing with the source
 areas.   Any such change  would be  subject to full public input and
 comment.

 Comment  #48:  The EPA's proposed remedy should be reconsidered
 because  the actual  remediation costs may greatly exceed the
 $58,000,000 estimate for the preferred alternative presented in
 the Proposed Plan.   A number of factors including a potentially
 larger waste volume,  potentially  underestimated unit costs, and
 potentially  omitted remediation  activities could cause the EPA's
 preferred   remedy to cost much more than the $58 million
 presented  in the Proposed Plan.   As a result, the evaluation and
 comparison of remedial alternatives is a flawed basis for
 selection  of a preferred remedy.

 As presented in  the Proposed Plan, all soils "exhibiting signs of
 visible  contamination" would be removed under the preferred
 remedy.  Further, the Proposed Plan states that the estimated
 volume of  impacted  soils upon which the evaluation was based "may
 change substantially pending a review of the subsurface data".
 This lack  of data presents a significant concern with regards to
 the evaluation of remedial options because even a small change in
 the volume of soil  to be removed  could have a profound impact on
 the overall  cost of the  remediation since more than 50 percent of
 the remedial  cost is  for excavation, treatment and disposal.  For
 example, considering  the difficulties likely to be encountered
 during the excavation, and potential over-excavation as a result
 of visual  staining  and field decisions,  removal of as little as 5
 feet of additional  soil  from each boundary of Lagoons and Canals
A and B would result  in  a 30 percent increase in the volume of
 soil excavated.  This would  increase the overall cost by
 approximately $8 million.  If chemical testing is used to define
 the limits of excavation, cost  increases much greater than 30
percent could easily  result.   Costs could therefore easily
 increase to beyond  $100  million.  Such a potential cost increase
 warrants a re-evaluation of  the remedial alternatives and
preferred  remedy.

 The unit costs for  off-site  transportation and incineration may
be underestimated,  and are therefore not a reasonable basis for
 the evaluation and  selection  of a preferred remedy.   For example,
recent vendor quotes put the  cost of incineration alone (without
 transportation and  associated costs) at $700 to over $1,000 per
 ton of material,  as opposed  to  the $510 per ton assumed in the

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EE/CA  (see Appendix III).  Published remediation coat data also
reflect a cost of over $1,000 per ton for the incineration of
bulk solid wastes.  Based on the estimated 60,000 tons of
material to be incinerated, every $100 extra per ton would
increase the total remediation costs by $6 million.   Based on a
transportation and incineration cost of $1,000,  the total
remediation cost could approach $30 million more than estimated
in the EE/CA.

A detailed evaluation of the EE/CA also indicates that costs for
items such as perimeter air monitoring for community protection
and related required activities have not been adequately
reflected in the estimated costs presented in the Proposed Plan.

EPA response:  Cost estimates in the EE/CA are based on quotes
from vendors and are considered adequate.  Contingency factors
have been built into the estimates to take into account
variability in costs and uncertainties in volume estimates.

EPA is aware of the uncertainty of the scope of the cleanup and
has addressed this issue in its response to earlier comments.

Comment #49:  The $58 million preferred alternative identified by
EPA in the Proposed Plan presents potentially significant
implementation problems and short-term risks that have not been
adequately evaluated in the Proposed Plan.

The analysis of the EPA's preferred remedy presented in the
Proposed Plan underestimates the potential implementation
problems and short-term risks associated with the excavation and
off-site incineration of the impacted soils, and therefore is not
an appropriate basis for the selection of a remedy.   For example,
the actual volume and locations of material to be excavated have
not been fully defined, and "may change substantially pending a
review of the subsurface data".  As a result, implementation
concerns associated with the total area of disturbance, volume of
material to be handled, and number of affected properties and
house to be demolished have not been adequately characterized.

Further, the Proposed Plan states that the EPA'B preferred
alternative  (excavation and off-site disposal) would eliminate
the potential exposure of residents to contaminated soils, and
there would be no local human health impacts.  However, based on
the estimated excavation mass of greater that 66,000 tons, and


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assuming a standard  truck size of approximately 20 tons, the
EPA's preferred remedy would require more than 3,300 additional
trucks  to and  from the site.  This additional traffic presents
potentially significant risks to the public as a result of
traffic accidents, spills, releases, etc.  Also, the significant
exposure and handling of impacted soils increases potential
exposure risks as compared to the current conditions where the
materials are  generally separated for the community by existing
cover soils.

Finally, the EE/CA and Proposed Plan do not adequately reflect
the potential  implementation concerns and short-term risks
associated with the  control of fugitive emissions.  As a result,
the EPA's preferred  remedy likely presents greater short-term
risks than reflected in the Proposed Plan.  The EE/CA and
Proposed Plan  rely on the use of a pre-fabricated enclosure for
the control of fugitive emissions.  However, based on the
location of the impacted soils to be excavated,  and the
structures schedule  to remain in place, there is not enough room
to erect an enclosure over all excavation areas, and therefore,
fugitive emissions are a potential concern.   Also, and as
discussed in related EPA technical documents, short-term risks to
workers working within an enclosure can be significant as a
result of hazardous  air concentrations within the enclosure,
significant personal protective equipment (PPE)  required, the
potential for  PPE failure, and significant physical hazards
associated with the  confined working conditions and poor
visibility.

EPA response:  Implementability and short-term effectiveness
criteria have been identified and have been evaluated in the
EE/CA and the  Proposed Plan.  The EE/CA considered using a pre-
fabricated structure (PFS) to control dust and odor during
excavation.  The EE/CA recognized that there will be some areas
where use of a PFS may not be practicable.  In such instances,
other engineering controls such as wetting agents could be used.

EPA acknowledges the uncertainties identified with regard to the
volume estimate of source material, and has responded to this
issue already.

Potential short-term risks to hazardous waste site remediation
workers is inherent  in the hazardous remediation field.  However
such risks can be managed to ensure the safety of site workers.
Engineering controls to maxinize worker safety will be given
consideration during design.

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Comment #50:  The remedy evaluation and selection process failed
to adequately consider alternate in-situ remedial approaches that
could be more cost-effective than the preferred alternative
identified in the Proposed Plan.  The EE/CA considered only one
in-situ treatment alternative  (in-situ immobilization).

Bioremediation is an applicable remedy identified in the EPA wood
treaters presumptive remedy guidance document.  Both ex-situ and
in-situ bioremedial remedies have been identified, screened and
selected as the preferred remedy at wood treater sites.  As
presented in EPA's wood treaters presumptive remedy guidance, of
the 18 RODs where bioremediation was considered, it was selected
as the preferred remedy in 9 RODs (as comparison, off-site
incineration was selected at only 4 of the 26 sites where
incineration was considered).  Considering the residential nature
of the site, use of in-situ bioremediation would maintain the
integrity of the community while reducing the overall risks to
the residents.  Although bioremediation of the site may require a
longer period to reach target levels, the ATSDR evaluation has
indicated that there are no acute short-term risks, therefore,  a
longer remedial program could effectively be implemented.  EPA
technology documents present a potential cost range of $50 to
$250 per cubic yard for the successful biological treatment of
creosote-contaminated soils and wastes, which would result in
significantly lower remediation costs that presented by the
preferred remedy.

In-situ thermal desorption is another potentially cost-effective
remedial measure that was not considered in the EE/CA or the
Proposed Plan.  This process uses thermal wells and/or thermal
blankets to remove constituents-in situ, where they are collected
and destroyed at the surface.  This remedial approach has been
effective at manufactured gas plant sites and other sites with
creosote-type wastes.  By leaving the wastes in situ, the
significant implementation concerns associated with excavation
and off-site incineration (e.g., short-term exposure risks, house
demolition, disruption of the entire community, increase truck
traffic, fugitive emission controls, excavation below the water
table, etc.) are eliminated.  Further, this process can be
implemented in a relatively short time period, and estimated
costs for this alternative  ($50 to $150 per ton) are
significantly lower than costs for off-site incineration.

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Related technologies that are also potentially applicable to this
site include in-situ thermal methods that involve steam and
oxygen injection such as the hydrous pyrolys is/oxidation (HPO)
process. HPO has been demonstrated to be successful at the
Visalia Commercial Creosote Site in Visalia, California.

Phytoremediation, i.e., the use of plant for remediation has
gained acceptance in the past 2 to 4 years and has been
demonstrated effective as; alternative caps for waste site
closure, groundwater treatment systems and cleanup agents.   Plant
species tolerant to wood treater wastes such as perennial rye
grasses have passed greenhouse treatability studies at a wood
treatment site in Portland Oregon.  The site has been seeded and
studies indicated that significant contaminant degradation in
shallow soil should occur in two growing seasons.  Mulberry and
hackberry trees have been used by Union Carbide to provide a
closure for a former impoundment containing highly toxic sludge
with the consistency of axle grease that contained PAHs and other
mixed wastes.  The vegetative cover has lowered the water-table
in the former impoundment, preventing contaminant leaching to
groundwater and excavation of the site has revealed that the
upper portions  (up to 40-inches) of the basin looks like top soil
and no longer has a chemical odor.  Chemical testing of shallow
soil samples indicated low PAH concentrations.  Although
phytoremediation was not identified as a presumptive remedy by
the EPA, recent demonstrations suggest that this technology could
be applicable to the site, especially to remediate the shallow
PAH-impacted soil.  This technology should be evaluated in light
of the $58 million cost associated with the preferred remedy.

EPA response: Concerns relating to the technical feasibility of
treating site soils using bioremediation exist.  Studies on the
bioremediation of creosote-contaminated soils indicate that 2-,
3-, 4-ring compounds can be biodegraded effectively, but 5-and 6
ring compounds are generally not degraded as easily.  As a
result, treatment criteria for some PAHs may not be attainable or
may take long periods of time to achieve.  Also, soils with high
levels of concentrated residual creosote typically are not
amenable to treatment using bioremediation.

Based on EPA's experience and its scientific and engineering
evaluation of alternative technologies, presumptive remedies are
preferred technologies for common categories of sites, such as
wood treater sites.  The objective of the presumptive remedies
initiative is to use Superfund program's experience to streamline
site characterization and speed up the selection of cleanup

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 actions.   EPA has the expectation that presumptive  remedies  will
 be used at all appropriate  sites  except  under unusual  site-
 specific circumstances.   In-situ  thermal treatment  technologies
 are not presumptive remedies  for  wood treater sites. In-situ
 thermal treatment technologies  introduce uncertainties that  are
 either eliminated or greatly  reduced by  presumptive remedies for
 wood treater sites.   The  time it  takes to remove the material
 from the subsurface and the ability to remove all the  source
 material are uncertainties  associated with in-situ  thermal
 treatment technologies.   In addition, impact to underground
 utilities (i.e.,  fiber optic  cables, natural gas lines) present
 additional concerns regarding this technology's application
 within a residential community.   Furthermore, the ability to
 capture off-gases is uncertain  and such  a long-term, on-site
 treatment plant  required  to control and  treat such  off-gases
 produced by these technologies  is not appropriate within a
 residential community.

 The comment points out that phytoremediation may be effective in
 reducing  PAH concentrations in  shallow soils.  The  contaminant
 reduction that can be achieved  by this technology is not widely
 documented.   Considering  the  general transport properties of
 target  contaminants  (high organic carbon partition  coefficient,
 low solubility),  which would  limit dissolved contaminant
 concentration in  soil moisture, it is unlikely that the cleanup
 goals  could be achieved by  this technology.  In addition, it is
 expected  that the depth of  the  root-bearing zone for trees/shrubs
 (e.g. mulberry and hackberry  trees) would be no more than three
 feet following planting.  Grasses (e.g.  perennial rye  grass),
 which already exist  on contaminated properties, would  only
 address surface soils.  By  contrast, the PAH contamination within
 the  Claremont Development extends to a depth of 20  feet and  is
 too  deep  to consider phytoremediaiton a  viable alternative.

 Comment #51:   The remedy  evaluation and  selection process failed
 to  adequately consider alternate  on-site,  ex-situ remedial
 approaches that could be more cost-effective than the preferred
 alternative identified in the Proposed Plan.  The EE/CA
 considered only a limited number  of on-site ex-situ treatment
 alternatives,  and there were  generally all eliminated  because of
 the  residential nature of the area and a lack of space.  However,
 if houses were to Jbe demolished and relocated (as would be the
 case for  the preferred remedy), significant space could be made
 available,  and such  a process could be less disruptive to the
 community by reducing truck traffic, and could be completed  for a
 much reduced overall project  cost.  As a result, the EPA's
preferred remedy  should be  reconsidered  in light of the
potentially effective on-site, ex-situ remediation  approaches
 available.

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Ex-situ remediation approaches that could be conducted on-aite
and that have been successfully utilized at other creosote sites
include bioremediation, thermal desorption, asphalt batching,  and
soil washing.  Although some excavated materials may be
classified as a hazardous waste, the EPA could designate the
excavation/backfill area and the ex-situ treatment unit as part
of a Corrective Action Management Unit  (CAMU) ,  and Land Disposal
Restriction  (LDRs) and Universal Treatment Standards (UTSs) would
not be triggered, and the alternative could satisfy all ARARs.
As presented in EPA'a Presumptive .Remedies for Soils, Sediments,
and Sludges a Wood Treater Sites, ex situ bioremediation and ex-
si tu soil washing were two of the most commonly selected remedies
present in RODs for creosote sites.  Estimated costs for ex-situ
biological treatment remedies are approximately $50 to $150 per
cubic yard of material, which are far less than the costs for
excavation and off-site incineration.  Estimated costs for on-
site thermal desorption are approximately $100 to $200 per cubic
yard, which are also far less than excavation and off-site
incineration.

With regard to the space limitations stated in the Proposed Plan
for such on-site, ex-situ remedies, sufficient space would be
made  available by the removal of houses as currently proposed by
the EPA.  For example, a typical thermal desorption unit and
associated equipment can be laid out in an area of approximately
120 feet by 120 feet, which would only occupy approximately two
properties if located on-site  (10 to 19 properties are considered
in the Proposed Plan for permanent relocation).

The Proposed Plan also indicated that on-site, ex-situ remedies
were eliminated from consideration given the residential nature
of -he area.  This reason is considered to be invalid because the
community disruption that would be associated with on-site, ex-
situ treatment is insignificant as compared  to the site
disturbance associated with implementation of the preferred
remedy  (e.g., resident relocation, house demolition, site-wide
excavation, emission control structures, truck traffic, etc.)

Given the lack of consideration in the  EE/CA, the proven
acceptability, effectiveness, and low cost of on-site, ex-situ
remedies for other creosote-contaminated sites, and  the actual
availability of  the required space for  such processes, these
options should be fully reconsidered prior to the selection of  a.

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preferred remedy.

EPA response:  EPA gave consideration to on-site alternatives in
the EE/CA.  As pointed out previously, the demolition of houses
in the preferred alternative is generally limited to properties
that either have source material beneath or adjoining structures.
The space made available by such demolition is not adequate for
on-site treatment alternatives proposed in previous comments
because the space created by such demolition is insufficient to
accommodate the facilities required for the treatment of the
volume of source material.  Although thermal desorption units
exist that may be laid out in an area approximately 120 feet by
120 feet,  the  capacity of such a plant would be restricted to
such an extent that the time period of operation would be more
extensive than excavating and removing the material off-site for
treatment and  disposal.  In addition, the suggested plan would
require the construction of a treatment plant on one lagoon,
treating  the waste from the other lagoon, then dismantling the
plant and mobilizing again at the other lagoon.  Off-site
treatment and  disposal would have the space needed to stage
larger amounts of material before treatment which allows for
faster excavation and removal of material from the residential
community.  Moreover, trucking of material through the community
to an on-site  treatment facility would not be eliminated and
would result in a full scale hazardous waste treatment plant
within the confines of a residential community.

The comment states that the Proposed Plan indicates that on-site,
ex-situ remedies were eliminated from consideration given the
residential nature of the area.  The comment claims this reason
is invalid because the community disruption that would be
associated with on-site,  ex-situ treatment is insignificant as
compared  to the site disturbance associated with implementation
of the preferred remedy (e.g.,  resident relocation,  house
demolition, site-wide excavation,  emission control structures,
truck traffic, etc.).  Any on-site,  ex-situ treatment would
require two general components: excavation of the source material
and treatment  of the source material on site.  Since excavation
is a component of the on-site ex-situ treatment alternative, such
a remedy  would also necessitate resident relocation,  house
demolition, and emission control,  etc.  In comparison,  however,
the preferred  alternative is less disruptive to the community
because it involves only one general component - the excavation
of material and does not include treatment on site.

Comment #52:   The remedy evaluation and selection process failed
to adequately  consider alternate off-site, ex-situ remedial
approaches that could be more cost-effective than the preferred
alternative identified in the Proposed Plan.
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Because  the remedy evaluation and selection process failed to
adequately consider alternate off-site, ex situ remedial
approaches that  could be more cost-effective than the EPA's
preferred alternative identified in the Proposed Plan, the
evaluation and selection of a preferred remedy is based on flawed
analysis.

The  Proposed Plan  states that "incineration is believed to be the
only available option for off-site treatment" because of the
absence  of other facilities permitted to accept RCRA-hazardous
wastes.   However,  a review of available facilities indicates that
permitted,  off-site thermal desorption units exist in New Jersey
which could potentially accept the materials, and the materials
could also potentially be sent to a recycling facility for
incorporation  in asphalt (as was done for the creosote-impacted
materials a the  Utah Power & Light/American Barrel Superfund Site
in Salt  Lake City,  Utah).  Landfills and related facilities in
Canada which should accept the materials have also been
identified.  Such  facilities present potentially significant cost
savings  as compared to off-site incineration (costs $40 to $150
per  ton  as compared to $700 to $1,000 for incineration),  and the
lack of  consideration of such facilities reflects the incomplete
nature of the  identification and evaluation of potential remedial
options.   Because  of the significant cost savings potentially
afforded by such facilities, any remedial options involving off-
site disposal  of excavated materials should re-consider the
available alternatives to off-site incineration.

EPA  response:  In the case of the Utah Power & Light/American
Barrel Superfund Site,  only creosote-impacted soils were allowed
to be sent  to  a  recycling facility for incorporation into
asphalt.   The  ROD  for that site included the provision that RCRA
wastes would not be used in the asphalt treatment process and
would be  shipped off site for incineration.

EPA  is aware that  thermal desorption units exist in New Jersey
that have  the  potential to treat wastes from the site, however,
no thermal  treatment facility in New Jersey is permitted to treat
RCRA F034  listed waste at this time.   EPA is also aware that one
facility has considered applying for a permit to treat F034
listed waste.  Should a thermal treatment facility become
permitted  to treat F034 listed waste,  EPA will consider sending
the  source material to such a facility.  Consistent with this
approach, EPA  has  modified its definition of thermal treatment in
this ROD  to  include thermal desorption or incineration to provide
flexibility  in treating the waste material.

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Comment #53:  The remedy evaluation and selection process failed
to adequately consider alternate on-site containment remedial
approaches  that could be more cost-effective than the preferred
alternative identified in the Proposed Plan.

The Proposed Plan indicates that containment options were
eliminated  from consideration as a result of uncertainties
associated  with containment and EPA's determination that the
canal and lagoon areas comprise principal threat wastes.
However, containment options are among the most common, proven
and reliable remediation approaches, and EPA guidance states that
the treatment of principal threat materials should not be
conducted if implementation of the remedy would result in greater
overall risk to workers or the surrounding community during
implementation.  Because the EPA's preferred alternative likely
increases short-term exposure risks, and because current risks
were determined by the ATSDR to be acceptable,  other options such
as containment should be reconsidered (consistent with the EPA's
Principal Threat Guidance) prior to the selection of a remedy for
the site.   For example, traditional containment measures such as
capping, vertical barrier walls (a.k.a.,  slurry walls), and
groundwater pump and treat could result in much reduced short-
term risks, lower impacts to the community,  and lower costs.  If
it is assumed that houses are to be removed and relocated as
would be done for the preferred remedy in the proposed plan,
significant containment and redevelopment options (e.g., for
industrial  or commercial uses)  exist that were not identified or
evaluated in the EE/CA or Proposed Plan.   Even if all the houses
required removal and/or relocation to facilitate implementation
of a protective remedy for the site (i.e.",  groundwater recovery
and treatment,  asphalt capping,  and commercial/industrial
redevelopment), estimated costs for such a remedy would be
significantly less than those for the preferred remedy.
Similarly,  the industrial/commercial redevelopment of this site
would be consistent with EPA and New Jersey initiatives and
regulations regarding the appropriate and risk-based
redevelopment of contaminated properties.  As a result of the
omissions in EPA's evaluation,  the remedy evaluation and
selection process needs to be reconducted prior to the
designation of a preferred remedy.

EPA response:  EPA's risk analysis concluded that health risks at
the site exceed EPA's acceptable risk range.  Engineering

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controls will be used during implementation of the preferred
remedy that will minimize short-term health risks.  Since a
health risk exceeding EPA's acceptable risk range exists at the
site, and engineering controls will minimize short-term risks,  it
is not anticipated that implementation of the preferred remedy
would result in greater overall risk to the community.

The comment also claims that significant containment options were
not considered in the EE/CA.  The EE/CA did consider five
different grouting techniques, and six different types  of
chemical grouting as containment options.  These were not carried
forward due to the uncertainties associated with the technologies
at this site.  Furthermore, containment does not meet the NCP
expectation that treatment be used to address the principal
threat wastes posed by a site.  Engineering controls, such as
containment, would be more appropriate for low-level threat
wastes that present only a low risk in the event of release.  In
contrast, the source material is considered to be toxic and
mobile; it cannot be reliably contained, and would present a
significant risk to human health or the environment should
exposure occur.  This precludes containment as a remedy for the
source materials regardless of future land use.  In addition,
EPA's preference (Interim Policy on the Use of Permanent
Relocations as Part of Superfund Remedial Actions, June 30, 1999,
OSWER Directive 9355.0-71P) is to address the risks posed by the
contamination by using methods of cleanup which allow people to
remain safely in their homes and businesses.

Comment #54: The EPA Proposed Plan is premature in the absence of
a. completed site-wide. Remedial Investigation and Feasibility
Study  (RI/FS).  The EPA Proposed Plan is premature, particularly
in light of the fact that environmental data are still being
developed as part of an ongoing RI/FS.  Hence, it is
inappropriate to move forward with the preferred alternative in
the EPA Proposed Plan until a full comparative analysis of
remedial alternatives, as contemplated in the NCP, is completed.

This contention is supported by the NRRB as stated in the
memorandum found in the administrative record in EPA's Region 2
office.  The NRRB states that the EPA Proposed Plan  considered
only a single cleanup alternative; it emphasizes  the need  to
complete a site-wide RI/FS; and recommends  that on-site  treatment
alternatives be considered as part of'a  site-wide RI/FS.

EPA response: The EPA Proposed Plan focuses on OU1,  the  canal and
lagoon source areas of the site.  The NCP provides that  the
cleanup of a site can be divided into a number of operable  units,
depending on the complexity of the problems associated with the


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 site.  OU1  addresses an  initial phase of action that comprises an
 incremental step  toward  comprehensively addressing site problems.
 The NCP encourages early actions prior to or concurrent with
 conduct of  an RI/FS as information sufficient to support remedy
 selection is developed.  The data collected on the source areas
 is sufficient to  base a  remedial decision for OU1.  The NRRB
 supports the need for action at this site, as well as the
 region's plan to  buy and demolish houses and recommended that EPA
 work closely with the community to determine how best to preserve
 the integrity of  the existing residential community.  The NRRB
 also pointed out  that such work will be necessary to address the
 highly contaminated source material under any circumstance.  The
 NRRB also recommended that should a more extensive buy-out be
 required, on-site treatment options should be included in an
 assessment  of alternatives as part of the site-wide RI/FS.  Site-
 wide data is still being gathered, and EPA will not begin
 remedial construction on OU1 until the results of the site-wide
 investigation are available.

 Comment #55: There is uncertainty about site conditions that
 could impact waste treatment and/or disposal options.  ATSDR has
 determined  there  is neither an immediate nor short-term health
 threat under existing conditions.  Therefore, the more prudent
 course of action  is to await completion of the ongoing sampl .ng
 and RI/FS as referenced  in the EPA Proposed Plan.  Then, a
 baseline risk assessment can be completed to develop Site-
 specific soil cleanup objectives so appropriate response actions
 can be considered.

 The NRRB memorandum states that the EPA selected its preferred
 alternative without the  benefit of fully understanding site
 conditions.  As a result, the EPA Proposed Plan did not consider
 an appropriate range of  remedial alternatives that adequately
 took into account these  considerations.  The NRRB memorandum
points out  that the appropriate handling of any excavated
material or decision on  land-use options should be based on a
more thorough cleanup strategy.

A more thorough cleanup  strategy should focus on on-site, ex-situ
 and in-situ remedial alternatives, as well as off-site, ex-situ
 treatment/disposal options other than incineration.  As stated in
 the previous comments, there are on-site,  in situ and ex situ,
 treatment options that are equally protective and more cost
 effective than the preferred alternative in the EPA Proposed
 Plan.   They should have been part of the range of alternatives
 considered in developing the EPA Proposed Plan.  Additionally, as

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 we previously commented, off-site facilities exist that can
 accept  the material for  thermal treatment  (New Jersey), recycling
 or land disposal  (Canada).  As noted by the NRRB, on-site
 treatment options may become more practicable following
 completion of a site-wide RI/FS.  The range of in situ and ex-
 si tu remedial  alternatives  that we identified in our prior
 comments have been employed at other similar CERCLA sites and are
 far more cost-effective  than the preferred alternative in the EPA
 Proposed Plan.

 EPA response:  The contamination in the lagoon and canal areas has
 been adequately characterized to provide a basis for.a remedial
 decision.  The uncertainty  of site-wide contamination throughout
 the development is associated with the extent of subsurface
 contamination  in the other  areas of the Claremont Development.
 The investigation into the  sub-surface soil conditions throughout
 the remainder  of the community is ongoing.  Consistent with
 NRRB's  recommendation, the  ongoing investigation into the
 subsurface soil conditions  for the remainder of the development
 will be completed prior to  the actual removal of any source
 material.

 Comment #56: EPA failed  to  develop and consider a full range of
 remedial alternatives.   The EPA Proposed Plan considered only a
 single  alternative.  To  ensure consistency with the NCP, a more
 comprehensive  evaluation of alternatives needs to be documented
before  acceptance of the EPA Proposed Plan and issuance of a ROD.
 This evaluation is properly done at the conclusion of the ongoing
RI/FS.  The considered alternatives should include biological and
 thermal treatment options as outlined in our prior comments.
 Only then will EPA be able  to demonstrate they are controlling
response cost  while promoting a consistent and cost-effective
decision.

Because EPA considered only a single alternative, the NRRB was
 unable  to achieve one of its key objectives: investigating
 whether other  approaches to achieve cleanup had been evaluated.
 This is one of the subjects that the NRRB is tasked to complete
when it reviews a cleanup strategy for consistency with the NCP.

EPA response:  EPA considered a full range of alternatives in the
EE/CA which included biological and thermal options.   The full
range of alternatives that  were given consideration in the EE/CA
were presented to the NRRB  as acknowledged by the NRRB in its
memorandum dated May 3, 1999,  which can be found in the
administrative record.  The approach used by EPA to select a

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remedy for the first operable unit is consistent with the NCP in
that it will be consistent with the future overall remediation at
the site.  Consistent with the NCP, EPA's action with regard to
the lagoon and canal source areas is a discrete action that
comprises an incremental step toward comprehensively addressing
site problems.

Comment #57: The failure to use laboratory cleanup techniques set
forth in SW-846 adversely affected the accuracy of reported
concentrations and elevated the sample detection limits.   EPA
made available the raw data from approximately 300 samples that
were collected as part of the lagoon and canal delineation for
review during this extended comment period.  The data are
predominantly from soil samples that were analyzed for
polynuclear aromatic hydrocarbons  (PAHs).  The quality assurance
information from selected random samples identified problems
associated with surrogate recoveries, and matrix and matrix spike
duplicate  (MS/MSD) analyses.  These problems were identified and
addressed by the EPA contractor's validators.

Detection limits were elevated in many of the samples reviewed,
primarily due to high concentrations of both target PAHs and non-
target heterocyclic PAHs, as indicated in the tentatively
identified compound  (TIC) data included in the validation
reports.  Neither of the two laboratories that analyzed the
samples used any of  the cleanup techniques presented in SW-846 to
improve detection limits or bring MS/MSD analyses into control by
removing the heterocyclic PAHs.

In not following the prescribed procedures set forth in SW-846,
much of the reported concentrations relied upon to develop EPA's
Proposed Plan were biased high.  Consequently, any calculated
exposure point concentration, like benzo(a)pyrene  (BaP)
equivalents, are overstated.  An inaccurate assessment and
communication of potential risks will result if biased high data
is relied  upon to characterize risks.

EPA response:  The cleanup techniques used in SW-846 generally
remove straight chain hydrocarbons and/or non-substituted
hydrocarbon chains and cyclic rings.  The cleanup techniques are
specifically designed not to affect the presence or
concentrations of target groups, i.e., any compounds containing
aromatic ring structures, chlorides, phenols, etc.  Therefore,
any cleanup should not affect "non-target heterocyclic PAH"
concentrations due to the presence of polyaromatics on the

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molecular structures.

Detection limits may have been improved with cleanup if the
reason for the dilution was based on the presence of non-target
long chain hydrocarbons obscuring the analysis, but there were no
target compounds observed which required dilution.  The compounds
requiring dilution also may or may not have been removed by the
cleanup steps.  Matrix interferences are observed in complex
highly contaminated samples even after cleanup.  Therefore, it is
inaccurate to state that the use of the cleanup technique would
have resulted in all sample runs without dilutions.  Sample
results used to determine exposure point concentrations were
reported from analytical methodologies which identify target
heterocyclic PAHs.

The risk analysis performed for the Federal Creosote site used
only detected concentrations for the calculations of the exposure
point concentrations.  The risk results are, therefore, not
affected by the high detection limits.

Comment #58: The reliance on visual contamination in developing
and implementing EPA's preferred alternative is inappropriate due
to the presence of diesel fuel in the samples.  The EPA Proposed
Plan states that a subjective criterion, visible contamination,
was used for the cleanup criterion and resultant cost and volume
estimates.  If relied upon during implementation of the remedy,
the presence of diesel fuel will distort the scope of the
excavation and likely result in unnecessary removal and treatment
of soil.

The diesel fuel was identified in the PAH gas chromotographs  (GO
as a series of symmetric peaks at retention times of
approximately 18 to 22 minutes.  The corresponding mass spectra
from late eluting PAHs, such as benzo (g, h, i)perylene, show alkyl
fragmentation patterns not characteristic of the parent PAH,
confirming the presence of the diesel fuel.

EPA response: Analysis for the presence of diesel fuel was not
performed during the sample analysis.  Evidence of a diesel fuel
gas chromatograph pattern  (18 to 22 min) was only seen in
relatively few samples.  Where a diesel fuel pattern was
observed, samples also exhibited high target compound
concentrations.  Two benzo(g,h,i) perylene mass spectra did show
evidence of a hydrocarbon signature pattern.  Both were from
samples with significant target compound contamination.
Integrated ion chromatograms for dibenzo(a,e)pyrene from high
concentration samples showed some possible high bias due to
background.  However, this possible additive effect is minimized


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due to the presence of other target compounds at 50 to 100 times
the concentration of dibenzo(a,e)pyrene in the sample.  EPA
concludes that there is no evidence of wide spread contamination
of diesel fuel at the site,  as only relatively few samples show a
diesel fuel pattern.  Where diesel was possibly observed,  there
are also high concentrations of target compounds.   Therefore,
cleanup of creosote product using visual observation is
appropriate.

Comment #59:  There are insufficient data to support the
conclusion that the lagoons and canals are active sources of
contamination.  As a result of reviewing the additional documents
provided by EPA during the extended comment period, we have
concluded there are insufficient data to show that the lagoon and
canal areas are active source areas.  Hence, the EPA should await
completion of the site-wide RI/FS so that a comprehensive
remedial strategy can be developed that addresses all
contamination in a cost-effective and protective manner.

The groundwater data and physical conditions encountered beneath
Lagoon A suggest the PAHs are not migrating.  Specifically, the
Technical Memorandum prepared in November 1998 indicates that
there is a dense silt layer, which could not be penetrated,
located beneath Lagoon A.  If continuous, this layer would serve
to inhibit downward migration from the lagoon.  With the
exception of one geoprobe sample believed to be water from within
Lagoon B, groundwater sampling, conducted at various locations
around the development, did not detect any constituents above
MCLs.  Additionally, many of the soil samples collected from the
lagoons had solids concentrations greater than 90 percent,
suggesting the material has a consistency similar  to asphalt.  As
the PAHs also have extremely low aqueous solubilities, there is
no basis of EPA's rational for characterizing these as major
sources of soil and groundwater contamination.

EPA response: The ERT Technical Memorandum - Site  Investigation
reported that contamination was found approximately 120 feet
below ground surface in the bedrock formation.  In addition, ERT
sampling results from the Millstone River indicate that PAHs have
migrated from the site to the Millstone River.  PAH
concentrations in sediment samples taken downstream of the site
were an order of magnitude higher than sediments samples taken
from a location upstream of the site.

The lagoon and canals remain in place beneath the  Claremont
Development and, in several areas, are at or near  the soil

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surface and are accessible to residents either by direct contact
with the surface or by contact during digging.  Some material has
been found to be weathered and,  as a result,  does have the
consistency of asphalt, but this is generally found to be true of
the material located closer to the ground surface which still
represents a direct contact threat.


C.    WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
      PROM THE COMMUNITY

Comments and concerns which were not addressed at the public
meeting were accepted in writing during the public comment
period.  Written comments were received in a letter from the
Mayor of Manville.  In addition, letters were received from
several residents.  They are answered in the following part of
the Responsiveness Summary.  These written comments are
categorized by relevant topics and presented as follows:

      1.     Superfund Process
      2.     Relocation

1.  Superfund Process

Comment #60:  The results of the site investigation performed to
date and the EPA pumping tests at the Manville Borough wells
indicate a clear and compelling reason for EPA to quickly proceed
with cleanup of the lagoon and canal areas, preferably by
complete off-site removal.  We believe that the EPA has the
jurisdiction, authority, and ability under CERCLA to either i)
perform the lagoon and canal area cleanup as a removal action; or
ii) immediately allocate funds under either the Removal or
Remedial programs to start cleanup of the lagoon and canal areas.


EPA response:   During previous community meetings, EPA has
indicated that remediation of the site  (i.e., addressing the
creosote waste and contaminated soil) could not immediately begin
due to the need for careful planning and design of the cleanup.
EPA also informed the public that the cleanup would occur under
EPA's Remedial Program.  The commenter urges EPA to begin
immediate cleanup actions at the lagoon and canal areas under the
Agency's Removal Program, due to imminent risk to drinking water
and groundwater.

Under the present course of action, EPA is proceeding as quickly
as it possibly can to begin a cleanup at the site.  However, the
Agency cannot begin on-site remediation, either through the
Remedial or the Removal Program, until the relocation of
residents in the affected areas is complete.  This process could
take nine months to a year to perform.  Furthermore, EPA has

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repeatedly informed the public that any cleanup activities would
result in disruptions to the residents remaining on the site.   In
order to minimize these disruptions and ensure that the cleanup
is performed in the safest and most expedient manner,  the Agency
will need to develop a detailed design for the remedial
activities.  Due to the extensive scope of the cleanup, this
design would need to be developed regardless of the program
utilized to cleanup the site.  EPA is continuing a site-wide
investigation that may be used to develop a cleanup strategy for
potentially contaminated areas within the Claremont Development
that are located outside of the lagoon and canal areas.  The
Agency anticipates that the overall cleanup plan for the site
will be available for public comment and ready to proceed to the
design phase concurrent with completion of relocation activities.
Therefore, EPA does not believe that there will be any delays
using this approach.

2.  Relocation

Comment #61: All homes should be bought out giving the residents
a chance to relocate and live in a safe environment.

EPA response: To this date, investigations at the site have
indicated that the historic canal and lagoons from the Federal
Creosote site remain buried beneath only limited portions of the
Claremont Development, and not the entire development.  The
ongoing investigation will characterize the extent of subsurface
contamination in the other areas of the development.  Should this
investigation determine that additional source areas are in
locations such that other structures would have to be removed to
extract the source material, then additional properties will be
purchased as necessary.

Comment #62: Two commenters stated that as homeowners on the
potential buyout/buyout list, they would like to have the Right
of First Refusal.  After cleanup is completed, the property they
received compensation for should be offered to them first for
purchase.  The commenters also stated that they would like to pay
a fair price below market value without bidding against
developers.

EPA response: In the event of a property buyout, the title to the
land would be transferred to the State of New Jersey.  In similar
circumstances at other sites, the previous land owner has been
given the first opportunity to reacquire the property.

Commant #63: Faced with the possibility of being temporarily
relocated, one commenter favored a buyout of his property citing
the inconvenience of busing children to school from a  temporary
location. In addition the commenter stated that he feared for the


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health and safety of his family if they continued living in the
community during any phase of the cleanup.

EPA response: To implement Alternative 2, EPA believes that
permanent relocation of residents will be required at not more
than 19 properties.  In addition, temporary relocation of
residents is expected for a small number of properties (estimated
at less than 20) during certain periods of the work.  Temporary
relocation is typically needed when utilities need to be
disconnected for an extended period or if access to a property is
considerably limited by the work.  It is EPA's experience that
temporary relocation of property residents is effective,  and that
property acquisition would not expedite the process.  EPA
acknowledges that temporary relocation is disruptive and
burdensome on residents, and will attempt to keep residents in
their homes whenever possible.

At other sites where temporary relocation was required, EPA has
attempted to minimize the time for relocation as much as
possible, and has made efforts to find comparable residences with
similar access to schools, shopping, parking, and other
neighborhood amenities.  EPA has also accommodated families with
special needs, such as those requiring wheelchair accessability,
and has attempted to provide rental properties that accept pets,
when required.
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 APPENDIX A





PROPOSED PLAN

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SUPERFUND PROPOSED PLAN
                      FEDERAL CREOSOTE SITE
                        MANVILLE, NEW JERSEY
USEPA
                      APRIL 1999
PURPOSE OF PROPOSED PLAN

This Proposed Plan identifies the preferred
alternative for cleaning up canal and lagoon
areas (referred to as the source areas) at the
Federal Creosote Superfund site. These areas
are contaminated with creosote, a substance
that consists primarily of semivolatile organic
compounds, specifically polycyclic aromatic
hydrocarbons (PAHs). The preferred
alternative is Excavation and Off-Site Thermal
Treatment and Disposal of the lagoon and
canal areas.

Based on the information EPA has obtained to
date, ten houses sit over or adjacent to the
lagoons.  In order to excavate the lagoon
wastes, EPA must demolish the houses. EPA
proposes to acquire the affected properties
and permanently relocate the residents.
Following permanent relocation, the houses
would be demolished. The number of
properties that may need to be acquired may
change, if the recently collected subsurface
data indicates that the canals and lagoons are
more extensive than expected.  In addition, a
number of residents may have to be
temporarily relocated due to excavation
activities on or in close proximity to their
properties. The extent of any temporary
relocations will be determined at a later date.

This document is issued by the United States
 Environmental Protection Agency (EPA), the
 lead agency. The New Jersey Department of
 Environmental Protection (NJDEP) is the
 support agency for site activities.
EPA is issuing this Proposed Plan as part of its
community relations program under Section
117(a) of the Comprehensive Environmental
Response, Compensation and Liability Act
(CERCLA or Superfund). This Proposed Plan
summarizes information that can be found in
greater detail in the Engineering Evaluation/
Cost Analysis, EPA's December 1995
presumptive remedy directive for wood treater
sites, and other documents contained in the
Administrative Record for the site.  EPA will
select a final remedy for the lagoon and canal
source areas only after the public comment
period discussed below has ended and the
information submitted during this period has
been reviewed and considered.  A
responsiveness summary addressing the
public comments will be issued as  part of the
Record of Decision (ROD) which will document
the appropriate response actions for the site.
   DATES TO MARK ON YOUR CALENDAR

 April 30,1999 to June 1,1999: Public
 comment period on proposed remedial
 alternative.

 May 12,1999: Public meeting at Weston
 School Auditorium. Manville, New Jersey.
 EPA encourages the public to review these
 and other documents in the Administrative
 Record in order to gain a more comprehensive
 understanding of the site and the Superfund
 activities that have been conducted there. The

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 Administrative Record, which contains the
 information upon which the selection of the
 response action will be based, is available at
 the following locations:

 Manville Public Library
 100 South 10mAve.
 Manville, New Jersey 08835
 (908)722-9722

 Hours: Mon., and Fri.      9:00am - 5:00pm
       Tue., and Thurs.:    noon - 8:00pm
        Wed.:           11:00am-8:00pm
        Sat:            9:00am - 2:00pm

 and can also be found at:

 EPA-Superfund Records Center
 290 Broadway, 18th Floor
 New York, New York 10007-1866
 (212)637-4308
 Hours: Mon - Fri, 9:00am - 5:00pm

 SITE BACKGROUND

 The site is located in the Borough of Manville,
 Somerset County, New Jersey (see Figure 1),
 and is currently an active residential
 community of single-family homes on
 approximately 35 acres.  The community was
 developed starting in the early to mid-1960's.
 A creosote plant had operated on the land
 from approximately 1910 to the mid-1950's.

 The site is located within the Raritan River
 watershed system. The Raritan River is
 located approximately 2,000 feet north and
 east of the site and the Millstone  River is
 located approximately 1,200 feet to the
 southeast.  The site  is situated on a
 topographic high that is nearly equidistant from
 the Raritan and Millstone Rivers and
 approximately a mile west (upstream) of their
 confluence. The site is bordered to the west by
 a variety of commercial uses, including the
 Rustic Mall, which occupies 15 acres of the
former wood-treating property. To the north,
on the opposite side of Conrail tracks, is the
former Johns-Manville property. The Johns-
Manville company property is currently being
redeveloped for a variety of commercial and
retail uses, including automobile
transshipment, warehousing, and large retail
 stores. To the south, on the opposite side of
 other Conrail tracks, the area is primarily
 residential.

 The wood treatment facility closed in the mid-
 1950's, and in the early 1960's,15 acres of the
 property were developed as the Rustic Mall for
 commercial and retail use. In the 1960's, 35
 acres adjacent of the site were developed for
 single-family housing, known as the Claremont
 Development, which now consists of 137
 single-family homes.

 In April 1996, NJDEP responded to an incident
 involving the discharge of an unknown liquid
 from a sump located at one of the Claremont
 Development residences on Valerie Drive. A
 thick, dark brown, tarry, oil-like substance was
 observed flowing from the sump to the street.
 In January 1997, the Borough of Manville
 responded to a complaint that a sinkhole had
 developed around a sewer pipe in the
 Claremont Development along East Camplain
 Road. Excavation of the soil around the pipe
 identified a black tar-like material in the soil.
 Subsequent investigations of these areas
 revealed elevated levels of contaminants
 consistent with creosote.

 A review of historical information revealed that,
 during its operation, the facility treated railroad
 ties and telephone poles with creosote and
 discharged the excess via canals to two
 lagoons located on the site. The creosote
 material discharged into these lagoons was not
 removed prior to the development of the
 property for residential and commercial use.
 The Claremont Development residential
 community and the Rustic Mall were built over
 much of the former Federal Creosote property.

 Following the discovery of this material,
 NJDEP, with technical assistance from EPA,
 began an investigation of the site.  In April and
 May  1997, air samples were collected inside
the majority of homes in the Claremont
 Development.  There was no indication that
the site-related contaminants were present in
the homes at elevated levels.

In October 1997,  EPA's Environmental
Response Team (ERT) initiated a limited site
investigation. This investigation included the

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                                                  Alma_White
                                                  Gotfege*'
          1000   2000   3000
              —•••=
              Scale in Feet
    Source: U.S.G.S 71/2 Minute Quadrangle
         Bound Brook, NJ 1955
         Photoinspected 1977, Photorevised 1970
Quadrangle Location
98P-27H
           FIGURE  -1 VICINITY MAP OF THE FEDERAL CREOSOTE SITE,
                       MANVILLE, SOMERSET COUNTY, NEW JERSEY

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collection of surface and subsurface soil
samples at select locations within the
residential development. Over 100 surface
and subsurface soil samples were collected on
properties believed to contain creosote
contamination based on analysis of historical
aerial photographs and input from the
residents themselves.  A n umber of these
samples revealed elevated levels of the
chemicals that make up creosote - PAHs. The
results of this investigation can be found in the
November 1998 report entitled 'Technical
Memorandum -  Site Investigation Report".
(This report and all other documents
mentioned in this Proposed Plan are available
in the Administrative Record for the site.)

In January 1998, responsibility for the site was
transferred from NJDEP to EPA.

From February through April 1998, ERT
collected over 1350 surface soil samples on
133 properties in and adjacent to the
Claremont Development in order to determine
if an immediate  health risk existed. The
results of the surface soil sample analyses
were made available to each individual
property owner, and can be found in the
"Interim Surface Soils Human Health Risk
Assessment", dated June 19,1998.  EPA
identified 19 properties with surface soil in
yards containing elevated levels of creosote.
While the levels were elevated, a risk
assessment showed that they did not pose a
short-term (acute) risk to residents. However,
the risk assessment did show that the levels
posed a long-term risk greater than EPA's
acceptable risk range.  Therefore, EPA applied
topsoil, mulch, seed and sod on properties that
contained elevated levels of creosote in
surface soils to limit the potential for exposure.
In addition, EPA installed an odor control
system in the  basement of one property and
installed a storm water drainage system
(including cover) on one property. All of this
work was performed by EPA's removal
program.

In February 1999, the Agency for Toxic
Substances and Disease Registry (ATSDR)
completed a health consultation that assessed
the public health impact from direct contact
with the surface soils. ATSDR concluded that
the surface soil concentrations of lead, arsenic
and PAHs do not pose a public health hazard.

As part of its site investigation, ERT installed
17 groundwater monitoring wells to begin to
define the extent of groundwater
contamination. The public water supplies and
monitoring wells installed in and around the
site were sampled for any site-related
contamination in March and April 1998 by
ERT.  The results of this sampling indicated
that the public water supplies are not currently
being affected by contamination from the site.
However, the results of the groundwater
sampling from monitoring wells located on the
site do indicate that the ground water,
classified by NJDEP as GW MA, potable water,
is contaminated with components of creosote.
A comprehensive groundwater investigation is
being conducted to complete  the
characterization of the groundwater conditions
in the area surrounding the site.

In November 1998, EPA initiated a remedial
investigation and feasibility study (RI/FS) to
more fully characterize the nature and extent
of contamination at the site. Subsurface soil
sampling started in December 1998 and was
completed in March 1999.  Over 200 borings
were installed, and .about 1,400 soil samples
have been collected for analysis. The
subsurface soil borings will characterize soils
that lie beneath the Claremont Development.
In addition, the results of this  sampling will
provide more accurate data concerning the
lateral and vertical extent of the lagoon and
canal  source areas.

In March  1999, as part of the  Rl, a more
extensive groundwater investigation was
initiated to characterize the vertical and lateral
extent of groundwater contamination caused
by the site.  Approximately 30 additional
monitoring wells will be installed and tested in
areas surrounding the development. Several of
the subsurface boring holes from the soil
investigation have been converted into shallow
monitoring wells that, when sampled, will
provide information on the quality of shallow
ground water at the site.  In addition, sediment
samples in the Millstone River and Raritan
River will be taken as part of the Rl to
determine if the site has impacted the river.

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 Completion of the field work for this broader
 site investigation is expected in the fall of
 1999. Following these investigations, EPA will
 evaluate what other remedies are necessary to
 address the site.

 The site was proposed for the National
 Priorities List (NPL) on July 27,1998, and was
 formally included on the list on January 19,
 1999.

 The data from the 1997 investigation
 conducted by ERT indicate that the canal and
 lagoon areas are the major sources of soil and
 groundwater contamination in the Claremont
 Development. Therefore, EPA believes  it
 prudent to expedite the remediation of these
 source areas. In order to expedite this action,
 an Engineering Evaluation/Cost Analysis
 (EE/CA) was prepared to evaluate remediation
 options for only the lagoon and canal source
 materials. This EE/CA was completed in April
 1999.

 SITE CHARACTERIZATION:

 Preliminary determinations of the locations of
 the canals and lagoons were based on various
 historical aerial photographs.  The locations of
 these source areas were further refined by the
 limited subsurface soil investigation conducted
 in 1997 by EPA's ERT. This investigation
 confirmed that the canals and lagoons were
 not removed before the Claremont
 Development was built.  The canal and lagoon
 found in the northern portion of the Claremont
 Development have been designated as Canal
 A and Lagoon A, respectively. The canal and
 lagoon found in the southern portion of the
 development have been designated as Canal
 B and Lagoon B, respectively.

The description and dimensions of the lagoons
and canals provided below is based on the
 1997 ERT data.  Once the data is evaluated
from the 1998/1999 subsurface sampling
activities, these dimensions may change.
Canal A extends approximately 400 feet from
Valerie Road, through four residential
properties on Valerie Drive to a point where it
meets Lagoon A at 90 Valerie Drive. The
canal is approximately eight feet wide, four to
eight feet deep, with the upper surface about
 three feet below the present surface of the
 yards (see Figure 2).

 Lagoon A is approximately 375 feet in length
 and extends through the backyards of 90, 98,
 104, and 110 Valerie Drive.  The top of Lagoon
 A is approximately eight to ten feet below
 ground surface and the lagoon is at least six
 feet thick in some places. In addition, an exit
 trench associated with Lagoon A apparently
 served as a drainage way for overflow material
 to exit the lagoon. This exit trench has been
 found along the back property lines of
 approximately five properties on Valerie Drive
 east of Lagoon A.

 Canal B is approximately 1,500 feet in length
 and extends from the parking lot of the Rustic
 Mall near Summit Bank, along the north side of
 East Camplain Road, through 10 to 13
 residential properties, to a point where it meets
 Lagoon B at 186 East Camplain Road. Like
 Canal A, Canal B is approximately eight feet
 wide. Very little fill was found above Canal B.
 The bottom of Canal B is estimated to range
 from several inches to eight feet below the
 ground surface.

 Lagoon B extends about 300 feet from
 southwest to northeast. The lagoon is located
 on properties at 186, 192,198, 204, and 210
 East Camplain Road, and may extend into the
 back yard of 216 East Camplain Road.

 The yards of these properties slope downward
 from the rear of the homes toward the back
 property boundary near the railroad tracks.
 Total elevation change  is about six feet.  Soil
 borings near the rear of the yards showed that
 the lagoon is within about two feet of the
 surface. Closer to the houses, the lagoon is
 about six feet below ground surface due to fill .
 that was placed prior to construction of the
 homes. Lagoon B extends to a depth of 20 to
25 feet.

The total volume of the  above source areas is
estimated to be 44,158  cubic yards based on
the available data. However, this volume may
change substantially pending a review of the
subsurface data.

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ttACK
                                                                                     EXISTING BURIED FIBER OPTIC LINE
                                                                                     LIMIT OF WASTE-CANAL/EXIT TRENCH
                                                                                     LIMIT OF WASTE-LAGOON
                                                                                     RESIDENTIAL HOME
                                                                           t  I  II   CONRAIL RAILROAD
                                                                 400
                             FIGURE 2. FEDERAL CREOSOTE SITE, CLAREMONT DEVELOPMENT
                                       HISTORIC CR1Q$OTE UGOONS & CANALS

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SCOPE AND ROLE OF ACTION:

This Proposed Plan identifies a cleanup
strategy for the first phase, or Operable Unit, at
the site and is considered to be an early action
that only addresses the cleanup of the highly
contaminated source areas:  the lagoons and
canals. Based on the information EPA has to
obtained to date, ten houses are located either
directly over or immediately adjacent to the
lagoons. In addition, the canals and the
Lagoon A exit trench have been found on 22
other properties within the Claremont
Development.  Portions of the canals appear
to lie underneath houses on  some of the 22
properties.

The scope of this Operable Unit is estimated to
include 32 residential properties: 10 properties
associated with the lagoons; and 22 properties
associated with the canals and the Lagoon A
exit trench.  To the extent that the lagoons and
canals extend beneath public roads within the
Claremont Development, those roads would
also be included in the Operable Unit.

EPA plans to initiate this cleanup action in
order to address the worst threats first at the
site and to initiate a remedy for the source
areas as early as possible. As described
below,  EPA's proposed action would require
the permanent relocation of residents from an
estimated ten to nineteen properties, so that
the houses can be demolished to get at the
contaminant source areas. (The exact number
of permanent relocations needed to address
the source areas will be determined after the
ongoing subsurface investigations described
above is completed.) Other residents may
also require temporary relocation during the
work of addressing the source areas.  Because
the permanent relocation and temporary
relocation processes can be  time-consuming,
this early action serves to initiate the relocation
process as early as possible. Until the
permanent and temporary relocations are
complete, EPA cannot begin any excavation
activities.

This Proposed Plan does not address any
potential contamination on other residential
properties within the Claremont Development,
within the Rustic Mall, or in the ground water.
Any contamination from the Federal Creosote
site found in these areas may be the subject of
future actions. The results of EPA's
investigations of the other 105 residential
properties in the Claremont Development may
be available in the summer of 1999. EPA
expects to issue another Proposed Plan to
address those properties in the fall of 1999.

SUMMARY OF SITE RISKS:

EPA has conducted an investigation of
subsurface soils in the areas historically
occupied by the lagoons and canals at the
Federal Creosote site. The risk assessment
focused on contaminants in the subsurface soil
that are likely to pose significant risk to human
health and the environment.  PAHs associated
with creosote use are the main contaminants
of concern at the site. There are 23 PAH
compounds, seven of which are considered
carcinogenic. A full list of target PAH
compounds can be found in Table 1.
Historically, PAH concentrations have been
reported using several means, including: total
PAH concentration (TPAH); total carcinogenic
PAH concentration (CPAH); and
benzo(a)pyrene equivalents (BAP). TPAH is
the sum of all PAH concentrations in a sample
and is always greater than or equal to CPAH.
BAP is a weighted (given consideration to the
intrinsic carcinogenicrty of each compound)
average of the individual carcinogenic PAHs
and can be used to assess the carcinogenicity
of CPAH  in terms of benzo(a)pyrene (a
carcinogenic PAH  that has been studied
extensively).

Sampling results from both lagoons (A and B)
and canals (A and B) demonstrated high
concentrations of TPAH, CPAH and BAP. The
maximum detected concentrations in terms of
benzo(a)pyrene equivalents (BAP) for Lagoon
A, Lagoon B, Canal A and Canal B were 1,862
parts per million (ppm), 2,548 ppm, 357 ppm
and 595 ppm, respectively. See Table 2 for a
summary of the maximum detected
concentrations of PAHs in the lagoons and
canals.

The limited surficial soil covering the lagoons
and canals does not provide an adequate or
permanent barrier to exposure. Future

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 subterranean disturbance of the lagoon and
 canal areas could result in the following
 exposure pathways: incidental ingestion of soil,
 dermal contact with soil, and inhalation of
 fugitive dust.  In addition, the lagoons and
 canals serve as a continuing source of
 groundwater contamination.

 For known or suspected carcinogens, EPA has
 established an acceptable cancer risk range of
 one-in-ten thousand to one-in-a  million.  Action
 is generally warranted when excess lifetime
 cancer risk exceeds one-in-ten thousand.

 In its Interim Surface Soils Human Health Risk
 Assessment (June 1998) for surface soils,
 EPA assessed risk by calculating a "trigger
 level" for BAP equivalents which equates to
 various risk levels. This "trigger level" can be
 used as a point of comparison for lagoon and
 canal area source materials. The trigger level
 of 9 ppm BAP equivalent in soil equates to an
 excess lifetime cancer risk of one-in-ten
 thousand under a conservative residential
 exposure scenario. The maximum BAP
 equivalent concentration in each of the
 lagoon/canal areas was compared to the
 trigger level BAP equivalent concentration of 9
 ppm and found to far exceed that level.  Thus,
 under reasonable maximum exposure
 conditions to lagoon/canal-associated soils,
 the potential excess lifetime cancer risk to
 residents significantly exceeds EPA's
 acceptable risk range.

 Actual or threatened releases of  PAHs from
 the lagoon/canal areas, if not addressed by the
 selected alternative, may present an imminent
 and substantial endangerment to the public
 health.

 SCREENING EVALUATION OF
 ALTERNATIVES:

 The information presented in the Technical
 Memorandum - Site Investigation Report,
 prepared by ERT, was used to focus and
 conduct the EE/CA that evaluates cleanup
 alternatives for the site. In addition, EPA
 considered the December 1995 EPA Directive
"Presumptive Remedies for Soils, Sediments,
and Sludges at Wood Treater Sites" in
preparing the EE/CA. The EE/CA provides an
 evaluation of various options, referred to as
 remedial alternatives, to address the source
 areas at the site.

 The remedial alternatives available for
 addressing the source material are limited.
 EPA considered on-site containment as an
 alternative for the canals and lagoons.
 However, EPA's technical evaluation of
 available containment options indicated that
 the source areas could not be effectively or
 reliably contained. In addition, the wastes
 within these source areas are considered
 "principal threat wastes" at the site. They
 represent a significant direct contact threat and
 have already impacted area groundwater
 quality. Whenever practicable, EPA expects to
 utilize  treatment to address such principal
 threat wastes. As a result of the uncertainties
 associated with on-site containment and EPA's
 determination that the canal and lagoon areas
 comprise principal threat wastes, the on-site
 containment alternative was eliminated  from
 further consideration.

 EPA's Presumptive Remedy Directive
 considered three technologies effective in
 treating creosote wastes: bioremediation;
 thermal desorption; and incineration.  The
 EE/CA considered on-site and off-site
 applications of these technologies. Due to the
 residential nature of the site and the lack of
 available space, on-site treatment of the
 creosote waste was not considered
 practicable.

 The use of each of these presumptive
 remedies in an off-site scenario was
 considered by EPA.  Since the material  in the
 source areas is a listed waste under the
 Resource Conservation and Recovery Act
 (RCRA), any off-site treatment and disposal
 would need to be performed at a RCRA-
 permitted treatment and disposal facility.
 Because RCRA-permitted treatment facilities
 that employ bioremediation or thermal
 desorption are unavailable, thermal treatment
 involving incineration is believed to be the only
available option for off-site treatment
 Consequently, in developing the alternatives, it
 is assumed that the source material would be
transported to a commercial incineration
facility for treatment and disposal.

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More detailed descriptions of the remedial
alternatives can be found in the EE/CA report,
which is available in the Administrative Record.

SUMMARY OF ALTERNATIVES:

The remedial alternatives for the site are:

 Alternative 1:  No Action
 Alternative 2:
Excavation and Off-Site
Thermal Treatment and
Disposal
Alternative 1:  No Action

Capital Cost:           $0
Annual Operation and
Maintenance (O&M):    $0
Present Worth:                $0
Time to Implement:     not applicable

Superfund regulations require that the No
Action alternative be evaluated at every site to
establish a baseline for comparison with other
remedial alternatives.

Under this alternative, no further remedial
actions would be taken to address the source
areas. Because no action results in
contaminants remaining on site above
acceptable levels, a review of the site at least
every five years is required.

Alternative 2:  Excavation and Off-Site Thermal
Treatment and Disposal

Capital Cost:           $58,000,000
Annual Operation and
Maintenance (O&M):    $0
Present Worth:         $58,000,000
Time to Implement     2 - 3% Years

Alternative 2 includes the excavation and off-
site transportation of the source materials
associated with the lagoons (including the
Lagoon A exit trench) and canals for thermal
treatment and disposal. For this early action
only. EPA has used a visible contamination
threshold as the cleanup level for cost and
volume estimation purposes.  This is due to
the fact that EPA has not yet completed the
baseline  risk assessment and its associated
quantitative determination of cleanup levels.
However, these subsurface soil cleanup levels
will be developed prior to the excavation of the
creosote source material and any adjacent
contaminated soil. This will ensure that all
unacceptable material is removed in a single
cleanup action.

The time to implement does not include the
necessary preliminary steps of designing the
remedy or permanently relocating residents,
which may each take up to one year, but will
be conducted concurrently.  In addition, the
time to implement is shown  as a range due to
uncertainties relative to the  exact number of
houses that need to be underpinned prior to
excavating, the extent of excavations in the
canals, the exact number of houses that need
to be temporarily and permanently relocated,
and the extent to which both Canal/Lagoon A
and Canal/Lagoon B can be remediated at the
same time. Concurrent remediation of these
areas may not be feasible if it adversely
restricts access to the development.  If these
areas are remediated sequentially, the time to
implement will be lengthened; however, the
disruption to the whole development may be
minimized.

As mentioned previously, EPA's proposed
action would require the permanent relocation
of residents from an estimated ten to nineteen
properties, so that the houses can be
demolished to excavate the source areas.
Investigations to date indicate that ten houses
in the Claremont Development have been built
on top of or adjacent to the  lagoon source
areas and nine houses may have been built on
the canal source areas.

For houses that may be located on the canal
source areas, the number of permanent
relocations needed to excavate the canals will
be determined after the ongoing subsurface
investigation is completed.

For the purpose of excavating the lagoons, the
affected properties  would need to be acquired
by EPA and the residents permanently
relocated.  Following permanent relocation,
the houses on these properties would be
demolished. Based on current data, Lagoon A
is believed to be located beneath the following

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 properties: 90 Valerie Drive, 98 Valerie Drive,
 104 Valerie Drive, and 110 Valerie Drive.  It is
 estimated that Lagoon A would involve the
 excavation of approximately 7,200 cubic yards
 of soil. The depth of the excavation is currently
 estimated to be 10 feet.  Based upon current
 data, Lagoon B is believed to be located
 beneath the following properties: 186 East
 Camplain Road, 192 East Camplain Road, 198
 East Camplain Road, 204 East Camplain
 Road, 210 East Camplain Road, and may
 extend into the backyard of 216 East Camplain
 Road. To excavate the source area
 associated with Lagoon B, approximately
 29,946 cubic yards of material would be
 removed.

 It is estimated that approximately 3,012 cubic
 yards of material would be excavated from
 Canal A and the Lagoon A exit trench.  It is
 further estimated that approximately 4,000
 cubic yards of material would be excavated
 from Canal B. Residents of affected properties
 on Valerie Drive and East Camplain Road may
 need to be temporarily relocated during some
 oral) of the excavation activities on their
 properties. It is anticipated that temporary
 relocation would be for a period of six months
 to one year. Because Canal A, the Lagoon A
 exit trench and Canal B are all relatively
 shallow, it is expected that structural
 engineering measures such as foundation
 underpinning can be used to remove the
 source areas from these properties without
 demolishing the houses.  However, until all of
 the subsurface data is received, EPA cannot
 determine whether extensive contamination
 exists at depth on'these properties that may
 result in the need to acquire more homes in
 order to excavate the canal contamination.

 During the excavation of Lagoon B, it is
 anticipated that portions of East Camplain
 Road may need to  be closed to provide room
for construction equipment. As a result,
 residents in Florence Court and some
 residents on East Camplain Road may need to
 be temporarily relocated.

 During the excavation of the lagoons, the use
of a prefabricated fabric structure (PFS)
equipped with a ventilation system may be
necessasry to control noise, dust, odors, and
 to limit rainwater in the excavation area.  Air
 emissions from the PFS would be treated prior
 to discharge to the atmosphere.  For canal
 excavation, the use of the PFS is not believed
 necessary.  Air monitoring would be conducted
 during the excavation of the canal and lagoon
 areas.

 The source material is a RCRA-listed waste,
 and would be transported for off-site thermal
 treatment (incineration)  and disposal. In
 excavation areas where houses would be
 demolished, the lots would be completely
 backfilled and would be revegetated and
 restored as open lots.

 EVALUATION OF CRITERIA:

 This section describes the requirements of
 CERCLA in the remedy  selection process.
 Remedial alternatives are evaluated using the
 following criteria:

 Overall Protection of Human Health and
 Environment: This criterion addresses
 whether or not a remedy provides adequate
 protection and describes how risks are
 eliminated,  reduced or controlled through
 treatment, engineering controls or institutional
 controls.

 Compliance With ARARs:  This criterion
 addresses whether or not a remedy will meet
 all of the applicable or relevant and appropriate
 requirements (ARARs) of other environmental
 statutes and/or provide grounds for invoking a
 waiver.

 Long - Term Effectiveness and Permanence:
 This criterion refers to the ability of the remedy
 to maintain reliable protection of human health
 and the environment over time once cleanup
 goals have been met

 Reduction of Toxicitv. Mobility or Volume:
 This criterion addresses the degree to which a
 remedy utilizes treatment technologies to
 reduce the toxicity, mobility or volume of
 contaminants.

 Short - Term Effectiveness: This  criterion
considers the period of time needed to achieve
 protection and any adverse impacts on human

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health and the environment that may be posed
during the construction and implementation
period until cleanup goals are achieved.

Implementability: Thi$ criterion examines the
technical and administrative feasibility of a
remedy, including availability of materials and
services needed to implement the chosen
solution.

Cost: This criterion addresses capital and
operation and maintenance costs of each
alternative.

State Acceptance: This criterion indicates
whether, based on its review of the EE/CA and
the Proposed Plan, the State concurs with,
opposes, or has no comment on the proposed
alternative.

Community Acceptance: This criterion will
assess the community interest and concerns
and evaluate comments. These comments will
be addressed in the responsiveness summary
section of the ROD.

ANALYSIS OF CRITERIA;

OVERALL PROTECTION: The lagoon and
canal areas act as a continuing source of
groundwater contamination.

Alternative 1, the no action alternative, would
not be protective of human health and the
environment because the site would remain in
its current condition. Under this alternative,
contaminated subsurface soils would remain in
place at the site and would not be subject to a
remedial action. The limited surficial soil
covering over the lagoons and canals does not
provide a protective barrier from exposure. In
addition, under the no action alternative, the
lagoons and canals would continue to serve as
a source of groundwater contamination.

Under Alternative 2. excavation and off-site
thermal treatment and disposal, all of the
identified subsurface soils exhibiting signs of
visible contamination would be excavated and
incinerated off site.  EPA is currently
describing this alternative  based on visible
cleanup goals since the baseline risk
assessment and its associated quantitative
determination of cleanup levels have not yet
been completed.  The subsurface soil cleanup
levels will be developed prior to the actual
removal of the creosote source material and
any adjacent contaminated soil.

Excavation and off-site thermal treatment and
disposal would eliminate: (1) the actual or
potential exposure of residents to
contaminated soils; and (2) the level of
contaminants that might migrate to the ground
water.  Any potential environmental impacts
would be minimized with the proper installation
and implementation of dust and erosion control
measures, by performing excavation within a
PFS where practicable and if determined to be
necessary, by conducting water pretreatment,
and by using a lined temporary staging area.

There would be no local human health or
environmental impacts associated with off-site
disposal because the contaminants would be
removed from the site to a secured location.

COMPLIANCE WITH ARARS:  Actions taken
at any Superfund site  must meet all applicable
or relevant and appropriate requirements of
federal and state law or provide grounds for
invoking a waiver of these requirements.
Alternative 2 would comply with ARARs. Major
ARARs are briefly described below.

The Resource Conservation and Recovery Act
is a federal law that mandates procedures for
treating, transporting,  storing, and disposing of
hazardous substances. All portions of RCRA
which are applicable or relevant and
appropriate to the proposed remedy for the
site would be met by Alternative 2.

The source materials associated with the two
canals and lagoons consist of coal-tar
creosote.  Soils excavated from the site during
remediation and all or part of the associated
debris are a listed hazardous waste (F034) as
defined in  RCRA. As a listed hazardous
waste, excavated soil is subject to the Land
Disposal Restrictions  (LDRs) under RCRA.

The Uniform Relocation Assistance and Real
Property Acquisition Policies Act of 1970,
which provides regulations and guidance for
the government in conducting relocation

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 activities where property is acquired, is not an
 environmental law, but would have bearing on
 Alternative 2, which proposes permanent
 relocation. The Act provides for uniform and
 equitable treatment of persons displaced from
 their homes by federal programs.  All portions
 of the Act that are applicable to the proposed
 action would be met by Alternative 2.

 LONG-TERM EFFECTIVENESS AND
 PERMANENCE: The no action alternative
 offers no long-term effectiveness and
 permanence.  In contrast, the excavation and
 removal of the lagoons and canals would
 represent a permanent solution for a portion of
 the site, because the source material would be
 entirely removed from these areas and
 transported to a hazardous waste facility.  In
 addition, the waste material would be treated
 to destroy the contaminants,  providing for a
 permanent solution to the waste.

 Off-site treatment/disposal at a secure,
 permitted hazardous waste facility for the
 contaminated soil is a technically viable and
 often used disposal technique.  These options
 are reliable because the design of these types
 of facilities includes safeguards and would
 ensure the reliability of the technology and the
 security of the waste material.

 REDUCTION OF TOXIC1TY, MOBILITY AND
 VOLUME: The no action alternative does not
 provide for any reduction of toxicity, mobility, or
 volume of the waste material  in the source
 areas.

 In contrast, removal and treatment of source
 material significantly reduces the toxicity,
 mobility, and volume of contaminants through
treatment. Thermal treatment by incineration
generally treats organic contaminants by
subjecting them to temperatures typically
ranging from 1,200 to 2,000 degrees
Fahrenheit in the presence of oxygen and
flame. During incineration, the toxicity of the
source material would be reduced when
volatilization and combustion convert the
organic contaminants to less toxic compounds
such as carbon dioxide, water, hydrogen
chloride, and sulfur oxides.
 SHORT-TERM EFFECTIVENESS: During
 excavation and staging of the soils, health and
 safety measures would be implemented to
 protect surrounding residents and field
 personnel from exposure to the contaminated
 materials. Any potential environmental
 impacts would be minimized with the proper
 installation and implementation of dust and
 erosion control measures, by performing
 excavation with appropriate health and safety
 measures, which may include a prefabricated
 structure where practicable, by conducting
 water pretreatment, and by using a lined
 temporary staging area. Appropriate
 transportation safety measures would be
 required during the shipping of the
 contaminated soil to the disposal facility.

 IMPLEMENTABILITY: Excavation techniques
 are commonly used in construction and by
 environmental remediation firms.  The
 installation of sheet piling and erection of
 prefabricated structures have also been
 employed at numerous and similar
 environmental remediation sites.
 Underpinning of houses during excavation has
 also been used at other Superfund
 remediation sites. The heavy equipment
 necessary to implement this alternative is
 readily available and typically used for
 excavation activities.  Numerous vendors are
 available to procure or rent the necessary
 prefabricated structures. Also, the quantities
 of backfill soil needed for excavations are
 available.

 The personnel required to operate the heavy
 equipment would require appropriate OSHA
 certifications (e.g., hazardous waste worker),
 in addition to being certified in the operation of
 the heavy  equipment.  Such individuals are
 readily available.

 The property buyouts associated with
 permanent relocation would result in some
 scheduling uncertainties related to the time
 necessary to complete negotiations with all
 affected homeowners.  In addition, various
 issues inevitably arise during the negotiation
 process with the individual homeowners that
can complicate and lengthen the acquisition
process.
                                              10

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 Permitted hazardous waste facilities for
 treating creosote-contaminated material are
 available and have the capacity to accept the
 estimated volumes of waste identified for
 removal. This treatment option is reliable
 because of the stringent design and operation
 requirements imposed by permits. Following
 thermal treatment, the treated material would
 be disposed of in a Subtitle C landfill.  Publicly
 Owned Treatment Works (POTWs) are also
 available for receiving pretreated water
 collected during excavation operations for the
 response action.

 During excavation and staging of the waste
 soils, health and  safety measures would be
 implemented to limit surrounding residents and
 field personnel from exposure to the
 contaminated materials. Excavation
 techniques could be implemented  in a
 relatively short time period because the
 necessary equipment is readily available.
 Demolition of homes associated with
 excavations could be performed without
 specific or highly specialized construction
 controls.

 COST: Cost of the no action alternative is $0.
 Cost of excavation and off-site thermal
 treatment and disposal is approximately $58
 million.

 STATE ACCEPTANCE:  The State of New
 Jersey agrees with the general approach of
 the preferred remedy in this proposed plan.

 COMMUNITY ACCEPTANCE: Community
 acceptance of the preferred alternative will be
 evaluated after the public comment period
 ends and will be described in the Record of
 Decision for the site.

 SUMMARY OF THE PREFERRED
ALTERNATIVE:

The preferred alternative for addressing the
source areas of contamination is Alternative 2,
excavation and off-site thermal treatment and
disposal.

The preferred alternative is believed to provide
the best balance of trade-offs among the
alternatives with respect to the evaluation
 criteria.  Based on the information available at
 this time, EPA and NJDEP believe the
 preferred alternative will be protective of
 human health and the environment, will
 comply with ARARs and will reduce the
 toxicity, mobility and volume of contaminants
 to the maximum extent practicable. Because
 the preferred alternative would treat
 contaminated material, it would also meet the
 statutory preference for the use of a remedy
 that involves treatment as a principal  element.

 EPA plans to implement the preferred
 alternative in a phased manner and will be
 initially moving forward with the relocation of
 affected residents. However, the agency does
 not plan to begin the actual removal of the
 source area contamination until the site-wide
 RI/FS is completed. EPA believes that the full
 extent of contamination within the
 development should be known prior to the
 initiation of intrusive cleanup activities. As
 indicated previously, the available data indicate
 that 32 residential properties need to be
 remediated,  ten to nineteen of which will
 require the permanent relocation of the
 residents. Based  on this data, EPA believes
 that excavation and off-site thermal treatment
 of the lagoon and  canal wastes, while
 maintaining the existing nature and character
 of the development, is the appropriate remedy
 for the site. If, however, the ongoing
 investigation of the remaining 105 properties in
 the development reveals extensive
 contamination necessitating the purchase of a
 significant number of additional properties,
 EPA may reconsider that portion  of the
 proposed remedy  dealing with the source
 areas. Any such change would be subject to
 full public input and comment.

 COMMUNITY ROLE IN THE
 SELECTION  PROCESS:

 EPA and  NJDEP rely on public input to ensure
 that the remedy  selected for each Superfund
 site is fully understood and that the agencies
 have considered the concerns of the local
 community, and to ensure that the selected
 remedy provides an effective solution.

 EPA has set a public comment period from
April 30,1999 to June 1,1999  to encourage
                                             11

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public participation in the selection process.
The comment period includes a public meeting
during which EPA will discuss the EE/CA and
the Proposed Plan, answer questions, and
accept both oral and written comments.

The public meeting is scheduled for May 12,
1999 at 7:00 pm and will be held at Weston
School Auditorium, Manville, New Jersey.

Comments will be summarized and responses
provided in the Responsiveness Summary
section of the ROD. The ROD is the document
that presents the selection of a response
action. Written comments on this  Proposed
Plan should be addressed to:

       U.S. Environmental Protection Agency
       Rich Puvogel
      290 Broadway, 19th Floor
      New York, New York 10007 -1866
EPA may modify the preferred alternative
presented in the Proposed Plan and the
EE/CA based on new information or public
comments.  Therefore, the public is
encouraged to review and comment on
the alternative explained here.
                                           12

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                       Table 1
                  List of Target PAHs
PAHs
1
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Naphthalene
2-Methylnaphthaiene
1 •Methylnaphthalene
Biphenyl
2,6-DimethylnaphthaIene
Acenaphthene
Dibenzofuran
Fluorene
Phcnanthrene
Anthracene
Carbaxole
Fluoranthene
Pyrene
Benzo(a)anthracene*
Chrysene*
Benzo(b)fluoranthene*
Benzo{k)fluoranthenc*
Benzo(e)pyrene
Benzo(a)pyrene*
Indeno(l,2,3-cd)pyrene*
Dibenzo(a,h)anthracene*
Benzo(g,h,i)perylene
              * = Carcinogenic PAH (CPAH)
                       Table 2

Maximum Concentrations of PAHs found in Lagoons and Canals
Location
Lagoon A
Canal A
Lagoon B
Canal B
TPAH
(ppra)
77,363
2U06
83,280
21,417
CPAH
(ppm)
5,838
UlS
12,390
2,135
BAP Equivalents
(ppm)
1,862
357
2,548
595

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 APPENDIX B





PUBLIC NOTICE

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                                                                                         ••ff-iv rir.-~-
                                                                      pCTIONAGENC
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   •located in Manville, Ne^Jersey.pisTearly action^^afwrewespe S'^P y'^^^J0^3u^^ivhotKa '•
'(lllcnu OnU UXWAUC VlOt VV*A**A*»*««« »»* —-- »	T--	.-    . ;   -     •  v  • • 41 ,. »•  . .-, »  ..'.._ -.-j I•, ,      . ,  •










: Broadway, 18th Floor, in New York City. .lM     ,    u', •-.                              -   ,-i,.,
 alternatives:


 Alternative 1: No Action
 action would be taken to address the, source areas.
  completely^backmied.revegetated, and restored as open lots.      -              .     ,     ,

  i^^SkSSiMm^of ^^^


                       received^gthe.^^

  The public may comment in person aVu« public 'i
                     '
                       .     •   !VW=   ,rv;-- RichPuvpgel     -  .'•  '   •..,.••>•••   ••-••
                      '...."   v   -    Remedial Project Manager"^' ••''•" •--•*>-*•*"•-':
                                '  »T ** ••-•	•	.^._»_i *n«>^*ox*fi/%*i Attfrnfv • *   ^
                                  U.S. Environmental Protection Agency  '  V
                                     • •: 290 Broadway, 19th Floor       ^.
                                    New York, New York 10007-1866    .  <•;
                                                                                ..'A"

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THE COURIER-NEWS
FRIDAY, JUNE 11,1999
         UNITED  STATES ENVIRONMENTAL PROTECTION AGENCY

                           EXTENDS  PUBLIC COMMENT PERIOD

                           on the Proposed Cleanup Federal Creosote Superfund Site

                                Town of Manville, Somerset County, New Jersey

    I:I»A announces an extension of the public comment period on the Proposed Plan and the Engineering Evaluation/ Cost Analysii (EE/CA) Report for a cleanup
    strategy for (he first phase at the Federal Creosote Superfund Sile located in Manville, New Jersey, This early action addresses the cleanup of the highly
    contaminated source areas,  (he canal and lagoon  areas of the Claremonl Development, a residential community of single-family homes.

    A» the Icail dgeiicy for the site, EPA .conducted an EE/CA to evaluate cleanup options for only the latoon ahd canal source materials first because these meus
    a/e the major sources of soil and groundwaier contamination'in the Claremonl Development and therefore pose the greatest risks to human health and the
    environment. The EE/CA Report and all information related to the cleanup are available in the Administrative Record located at the Manville Public Library
    100 South 10th Avenue, Manville. New Jersey and at EPA's Superfund Records Center, 290 Broadway, 18lh Floor, in New York City.

    Based upon the results of the EE/CA, EPA pepared a Proposed Plan, which describes the cleanup alternatives and provides EPA's rationale for recommending
    a single alternative for this first phase. EPA evaluated the following alternatives: •

    Alternative I: No Action

    The National Oil and Hazardous Substances Contingency Plan requires EPA lo evaluate a No Action Alternative to establish a baseline for comparison with
    other remedial  alternatives.   Under  this alternative, no further remedial  action, would  be taken lo  address the source  areas.

    Alternative 2: Excavation and Off-Site Incineration   •             ...        . •        * '  '

    Alternative 2 includes the cxcavationa dn off-site thermal treatment and off-site disposal of source materials associated with the lagoons and canals. It also
    includes acquiring and demolishing an estimated 10 to 19 houses In the Claremont Development and permenantly relocating these residents. Also, residents
    on other affected properties may require temporary relocation during the cleanup.  The source materials would be transported for off-site thermal treatment
    (incineration)  and disposal. Excavated areas where houses were demolished would be completely backfilled, revegelated, and restored as open lots.

    EPA and the New Jersey Department of Environmental Protection (NJDEP) recommend Alternative 2. This preferred alternative would provide the best
    balance of overall protection ol human health and the environment; compliance with applicable or relevant and appropriate requirements; and reduction of
    loxicity, mobility, or volume of contaminants through treatment technology. EPA and NJDEP will select a final remedy after review and consideration of
    community concerns received during the extended public comment period.

    The Public May Submit written comments through June 25,1999 lo:

                                                    RichPuvogel                       .            .

                                             Remedial Project Manger

                                     U.S. Environmental Protection Agency

                                             290 Broadway, 19th Floor

                                        New York, New York 10007-1866

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        APPENDIX C





PUBLIC MEETING TRANSCRIPTS

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      SUPERFUND PROPOSED PLAN

       FEDERAL CREOSOTE SITE

        MANVILLE, NEW JERSEY



           Public Hearing
Held at the Western School Auditorium

      Wednesday, May 12, 1999

             7:00 p.m.
  SCHULMAN, CICCARELLI  &  WIEGMANN
   CERTIFIED SHORTHAND  REPORTERS
EDISON   TOMS RIVER   ATLANTIC  CITY
          (732)  -  494  -  9100
   SCHULMAN,  CICCARELLI  & WIEGMANN

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APPEARANCES:
         PAT  ESPPI,  U.S.  EPA
              Community  Relations Coordinator
         JOHN  PRINCE,  U.S.  EPA
             Central  New Jersey Remediation
             Section
         RICH  PUVOGEL,  U.S.  EPA
             Remedial  Project  Manager
         MARK  MADDALONI,  U.S.  EPA
             Risk  Assessor
         ARTIE  BLOCK,  ATSDR
         TOM  MIGNONE,  ATSDR

         MAYOR  ANGELO  CORRADINO
         COUNCILWOMAN  ALJEANETTE D. ZEMANEK
         COUNCILWOMAN  SENGA ALLAN
         GARY IP.  GARWACKE,  P.E.,
              Administrator & Engineer
          SCHULMAN, CICCARELLI t WIEGMANN

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            MAYOR CORRADINO:  Good evening,




everyone.  I want to thank everybody for




taking time out of their busy schedule and




coming out on this gorgeous night.  As we




know, we're all here for the same reason,




to find out exactly what's going on in the




section where you live.  And before we




start, I'd like to make a brief




introductions.  We have our two Council




people, Aljeanette Zemanek and Senga Allan.




We have Lynn Giovanni, who's been with us




since day one of the problem from Bob




Frank's office, so Linda thanks for




everything.  We appreciate it.  This




meeting was called, I guess, in March.




Am I right, Pat?




            MS. SEPPI:  Yeah.




            MAYOR CORRADINO:  We were  told




that we had to have a public hearing on  the




Superfund Site and, hopefully, we'll get




some more information about what's  going




on.  So  Pat can update us on where  they  are




and  where they're going.  So Pat,  if you




don't mind.



            MS SEPPI:  Thank you,  Mayor.   I
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want also want to thank you for coming out




this evening and apologize to the people




who were here in March because a lot of




what you hear tonight is going to be



similar to what you heard that night. ,,



            AUDIENCE MEMBER:  Who are you?




            MS. SEPPI:  I was going to get




to that in a second.  My name is Pat Seppi.




I'm with EPA.  I'm a Community Relations




Coordinator and I've also been involved




with the site since the beginning and all  I




wanted to do before I introduce anybody




else here, sorry that you're going to hear




information a lot of you have heard before,




but as the Mayor said, this meeting



is mandated by law as part of the Superfund




process.  Let me go to the other people who




are from EPA.  Rich Puvogel is the Remedial




Project Manager.  John Prince is the Chief




of the Central New Jersey Remediation



section.  Mark Maddaloni is a risk



assessor.  Jim Hackler is also with  EPA.




Michael Sidak  is a.risk assessor for EPA.




We also have  two other familiar  faces.




Artie Block  and Tom Mignone from ATSDR.
                 SCHULMAN, CICCARELLI & WIEGMANN

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                                                           5
 1                        AUDIENCE  MEMBER:   How  much is

 2            that in  salaries?
 3                        MAYOR  CORRADINO:   Let's keep
 4            the meeting to  the purpose  we're here for.
 5                        MS.  SEPPI:   Thank you,  Mayor.
 6            So the reason that we are  here tonight for
 7            this proposed plan meeting  is to take your
 8            comments and your  questions on our proposed
 9            plan which tells you  what  we plan to do,
10            what we'd like  to  do  with  two lagoons
11            and the  adjoining  canals that are in the
12            Claremont Development.   If  you live in
13            Claremont, you  should have hopefully
14            received a copy of this proposed plan in
15            your mailbox.   There  are some additional
16            copies out back.  I understand they may be
17            all gone, if  somebody doesn't have one and
18            would  like them, please come and let us
19            know.  We'll  make  sure that you get one.
*2 o                   So as  I  said, this is a mandated
21            meeting.  It's  a little bit different than
22             the meetings  that we've usually had with
23             you,  whereas  it's more formal.  If you'll
24             notice,  we have a court reporter here who
25             will  be  taking everybody's questions  and

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 comments  and make  it  part  of  the public




 record.   We're  being  a  couple weeks into




 right  now what  we  call  the public comment




 period also  reflected in your proposed




 plan.   The public  comment  is  your time to




 share  concerns  and comments about what




 we've  presented in this plan  the last  night




 January 1st.  Tonight everybody's questions




 and comments, as I said, will  be taken down




 and transcribed.   However,  if  you would




 prefer to  give  written comments,  it's  not  a




 problem.   They  would  be addressed to Richie




 and his address  is in the  Proposed Plan.




 Okay.  The only  other thing I  would ask




 about  this meeting, because it  is a little




 bit more  formal, we do have a  couple of




 short  presentations.  Right,  short



 presentations.  And if you could hold  your




 questions  and thoughts until after that, I




 would  appreciate it.  Usually  in a more



 informal setting we sort of just  go through




 that.  If you could just allow  us  to do our




presentations, we'll  be here to  answer  any




 questions and address any comments  that  you



have.
                SCHULMAN, CTCCARELLI & WIEGMANN

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                                                          7
 1                  Now, one thing that I have mentioned
 2            before is, and I did want to mention again,
 3            tonight is the ability of a qualified
 4            citizens group to receive a Technical
 5            Assistance Grant which is offered by EPA.
 6            What it does is provide funds for a group
 7            who's affected by this site to hire
 8            independent technical advisors to help  them
 9            interpret any of the documents,
10            site-related information that we will be
11            showing to you.  And community involvement
12            is an important part of this whole
13            process, especially from now on where we're
14            going to be getting into the relocation and
15            the designs and construction and a  TAG  is  a
16            good way to become involved.  So we're
17            going to be talking about this more with
18            our community advisory group which  is just
19            one other thing I wanted to mention.  We do
20            have a community advisory group now.  We
2i            meet pretty much on a monthly basis.  We're
22            going to  continue to do that.  My  only
23            concern with that is most of the people who
24            are in that group right now are the people
25            who are directly affected by the

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                                                           8
  1             relocations,  either  the  permanent buy out

  2             or the  temporary  or  permanent  buy out,

  3             whatever  it  may be.   I would  certainly like

  4             to get  a  lot  more  people in the  rest of the

1  5             community involved because as  things

  6             proceed with  the  construction, we'll find a

  7             lot of  things that are going  to  be of

  8             interest  to  everybody.   So I'll  be sending

  9             out a flier  to everybody in the  next couple

10             of weeks  with a date  for the next meeting

11             and if  we could get more people  involved,  I

12             think that would be very helpful  for

13             everyone.

14                  Okay.   So I  think  at this  point I'll

15             turn this over to  John Prince.   He's going

16             to talk very  shortly  about the Superfund

17       •      Program.
18                        MR. PRINCE:   Thank you.  Pat.

19             I'm going to  speak briefly about  how the
20             Superfund process  was developed  by Congress
21             for EPA to implement.  And then  Richie  will

22             describe  the  plan  for first phase of what

23             we think  be a  multi -- several stages of
24             clean up  to address the  problems  associated

25             with the  Federal Creosote Superfund Site.


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Congress wrote the Superfund law initially




in 1980 and it's really meant to address




sites like this one, a long forgotten




industrial operation that got redeveloped




into a number of different uses, primarily




residential where there are some -- many




concerns of residual contamination and




clearly something should be done.  That's




exactly where Superfund is meant to step




in.  The Superfund process really acts  on




two levels.  The first sort of  response is




typically called a removal action.  And it




addresses emergency actions,  spills,  and




imminent threats to the public  or threats




of releases into the environment.  Once




those  immediate hazards are addressed,  the




remedial process begins and that's what




this  -- that's  what we are all  apart  of in




EPA.   The  remedial  process is meant  to take




a  look at  a number  of  different types of




things, but in  a more  broader way  to  know



the  limits  of  any potential  contamination,




to find out any potential  problems  that



might be  associated with  the  site  and then




figure out how to  address  them.
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      This site such as this being




qualified for and this one has qualified




for its national priorities list, which is




the Superfund list.  There are about 1,500



sites across the country that are, I guess,




they're the ones that pose the biggest



concern and are being addressed through the




Superfund Program.  Once a site is on the




national' priorities list, it




qualifies for this remedial response which



involves investigations to figure out what




the extent of the problem is and funding




where necessary to address those problems.




Before remedial funds can be expended to




address a problem at a Superfund site, EPA




and the state, in this case the State of




New Jersey, need to go through and be




confident that we really know two things:




That we know the extent of the problem or



in this case a portion of the problem posed




by the site and then that we're confident




that we have a remedy that will address it




and that it's, therefore, a good use of




public funds and the right remedy for this




site.  When that is done, we prepare a k
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                                                         11
 1             proposed plan which has now been released.
 2             We bring it to the  public.   We request your
 3             input in that process.   At  the end of the
 4             public period, in this  case on June 1st,  we
 5             will evaluate all those comments and
 6             determine whether any of them merit changes
 7             in that proposal and it has happened where
 8             the input from residents or people in the
 9             community have highlighted something that
10             we were not focusing on that have changed
11             remedies.  So it's an important part of the
12             process.
13                   After that has been evaluated, EPA
14             with the State of New Jersey, formalizes
15             the remedy in something called  a Record of
16             Decision, which we are expecting to  issue
17             for this site in July of this year.   It
18            will very  clearly  state what  the plans are
19            for  this first part  of the  site which will
20            address  the  canals and the  lagoons.   The
2i            Record  of  Decision provides  a road  map on
22            how  the remedy  should  be performed.   Then
23            EPA  goes back out  and  goes  back to  the
24            drawing board and  draws up  what we  call  a
25            Remedial Design, which is  similar to the

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plans and specifications you wculd expect


for any large construction project like the


construction of a bridge or building.  The


scale of this first action that we're


contemplating is very large and so


that's the next phase.  And then from those


plans, from that design, we execute a


remedy.  Then after the remedy is complete,


the site can actually come off of


eventually the Superfund list.  So that's


the process:  Identify the site, evaluate


it and investigate, proposal, public input,


select a remedy, design it, implement it,


take the site off the list and a site like


this, which is very complicated, we're


actually looking at addressing the site in


we think three phases.  The first one is


focusing on the most highly contaminated


areas; the canals and lagoons within the


Claremont Development.  The next phase,


which we will be going through this process


again for other homes in the Claremont


Development, the remaining homes, to figure


out exactly what to bring a proposal to you


again as to how to address those houses and
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                                                            \
                                                         13
 1            then the last phase would be addressing


 2            some other things such as possible ground


 3            water contamination, possible other


 4            commercial properties in the area that


 5            might be contaminated.  That is coming


 6            later,  though.  Right now we're focusing on


 7            the residential area where we know about a


 8            problem that needs to be addressed.


 9                  I'm going to turn it over to Rich


10            Puvogel, the site manager, and Richie will


11            go into some details and have some


12            historical background about what we are


13            actually planning on doing.


14                        MR. PUVOGEL:  I'm going to talk


15            to you pretty briefly.  My talk's broken up


16            into three parts.  First I want to talk to


17            you about the history of the site.  Some


18            have you have heard it before.  I have a


19            couple historical aerial photographs that


20            kind of give it a little bit more insight


21            from the creosote was run and where certain


22            parts of the facility is located, treatment


23            areas and such.  The next part of my


24            presentation we're going to give you a


25            broad overview of what EPA's doing out at
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             the site and the approach  to  the
             investigation what we're looking  at.   And
             the last part of my  talk is going to  be
             focused on what we are  doing  in the  canal
             clean up; proposed plan  we're  bringing to
             you tonight.  So briefly let  me start with
             the history  of  the site.
                    Federal Creosote Site started
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8
              operations  about  1910,  1911.   They started
              in there  what  is  known as the Claremont
              Development.   I  have an aerial photograph
              here of what  the  site looked like in about
              1954.  You  could see -- let me fish out my
              laser pointer.   For several site features,
              over here this is the Johns-Manville site
              just to ,get you oriented.  Just down here
              is Lost Valley.  This road here is Main
              Street.  Here is the beginning of East
              Camplain Road and about 1954 it stopped
              right about there.  Several prominent

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               features  of  the  site are the wood that's
               been stacked up  to be treated.   This
               lighter color wood that you see here,
               that's untreated wood ready to be treated
               at the site.  This wood would be put on
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rail cars and end up in the treatment




facility down in this corner of the site.




Here you could see there are some tanks and




treatment building where the wood was



loaded in and treated with creosote.  After




the wood was treated, it was rolled out on




rails into this area right here.  This




is what we call today the drip area.  The




treated ties were left out there to dry off




and some of the Creosote has dripped from




the ties onto the ground.  That's what that




black staining area  is from.  Here you




could see a row of treated ties right about




Here .



      Two other prominent features on the




site are what we call today Canal A.  This



is A.  This distributed the creosote from




the production area  to this lagoon where it




ended up and deposited there.  This is what




we call Lagoon A.  It's up in the northern



part of the property or the development.




Down in the southern end along East



Camplain Road we see another  canal  here.




This runs  from the treatment  facility down




to the  south and eventually into  the  larger
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                                                          16
 1             lagoon,  which  we  call  Lagoon  B  located
 2             right  here.  You  could see  this feature,
 3             dark area.   The facility  ran  until  abouc
 4             the mid  1950's when  it was  dismantled,
1 5             taken  apart.   By  about .the  early '60s we
 6             start  to see some development in the area.
 7             The first houses  or  the Claremont
 8             Development  start to show up.   This would
 9             be Valerie Drive  right here and Louise.   At
10             about  this point  in  time  wx^eV don't see  the
11             lagoons  and  canals anymore.   We believe
12             that what we have for now with the  borings
13             we've  done,  these areas are now buried.
14             This will be Lagoon  A. Down  in this area
15             Lagoon B. The canals are also buried by
16             this time, is  how it all  started.  And
17             development  went  on  until about the mid
18             '60s,  I  believe,  unt^l it looks like pretty
19             much this.  This  is  an airplane shot in
20             1975.  You could  see the  Johns-Manville
2i             property still up and running,  but  this
22             gives  you an idea of the  Claremont
23             Development, 137  single family homes.  Most
24             of  you know  that, since you are living
25             there  today.   This is the Rustic Kail area.

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Today up here you have the Walmart shopping




area, Arbey's, McDonald's.




      Pretty rftuch that's the history of the




site.  It closed down in the mid fifties




and development went pretty quickly after



that.  That's about a brief overview of the




history.  I just wanted to give you an idea




where things were located in relation to




what the property looks like today, just




wood treatment facility with the tanks were




over in this area in the previous photo in




1963 that you saw.  They were dismantled at




that time and taken away.  The lagoons up




here and here in the drip area, north of




Louise Drive around here.  That's just a




little bit on the history.



      And I want to go next in the second




part of my talk about what we're doing and




what we're looking at so to address the



problems that are left behind by that




facility.  We have a bunch of



investigations going on at the same time or



part of one large investigation.  The first




part is, obviously, the lagoons and canals.



We're looking at  -- we're focusing on the
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worse place first.   As John said, the



lagoons and canals  are areas that we still




find the pure creosote left there.  They



were not removed before the developer put




these houses in this development is one




of the things about the lagoon and canal or




excuse me.  The next area that we're



looking at is the sitewide soils.  When




this developer built these properties, we




weren't sure whether these lagoons or



canals or parts of them were moved into




other areas before he developed  it.  These




aerial photos show some pictures of what




the place looked like when the  facility  was




active.  We don't have a  good  idea, we




didn't further  on, have a good  idea  if




these  features  were  still there.  So  we



did  soir.e  investigation into  lagoons  and




canals.   We  found, yeah,  they're still



there.  They  didn't  move  them.   They're




simply buried over.   We're  doing an



investigation now  for the remainder  of  the




Claremont Development,  other properties




that aren't  affected by  canals and lagoons.




We've taken over 200 deep boring samples,
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some as deep as about 36 feet, to find out




if there are other source areas around the




development.  Those results, we're getting




analytical results back.  We should have




our results back to you by July.  We want




to try and get these results to you as




quickly as possible.  We have quite a




number of samples, 1400 samples for




different analyses for each boring.  So




it's quite a lot of work, but we're working




to get it to you as quickly as we can.




      Another phase or aspect of our




investigation that we're doing right now  is




the ground water investigation.  You might




see drillers around the neighborhood and  in




the past working on some holes or wells




that have been in place in  the community.




We're establishing a network of about




fifty-five monitoring wells throughout the




community and up  in the Walmart Shopping




Center down Lost Valley to  surround this



site with a network of monitoring wells to



see what's  going with the ground water.   So




far we've tested  the municipal wells.



They're not affected by this  creosote.
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We're also looking £t the surface water.




We've taken samples on the Mill River cr




the Millstone River and the Raritan River.




We've taken surface water samples and




sediment samples.  Now Harry Allen back




about a year ago, some of you might knew




Harry, he's the ERT specialist or




Environmental Response Team.  He's done



some sampling on the Raritan River.  We've




sampled sewerage outfalls.  There's slight




levels of PAH's or creosote components in




the sediment, but we didn't find any in the




surface water.  We're looking at additional




samples, taking additional samples in the




Millstone to determine the extent of that




problem.  Last part of the investigation or




another part of the investigation that



we're doing right now is we're looking into




responsible parties, seeing if we could




find who's responsible for leveling this in




the way.  It's what we usually look for to




get responsible parties to the book to




contribute towards some of the work on the




site or at least contribute to the cost



that we spend in cleaning up the problem.
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      The third part of my talk, just




briefly going to go into the lagoon and




canal proposed plan.  We're going to talk




about a few of the components of the plan




what we're going to do.  Plan is to




excavate the material that's left in Lagoon




A and Lagoon B as well as both canals.




Right now the materials in the northern




lagoon, Lagoon A, is approximately about




12 to 15 feet in depth.  The material down




in the bottom lagoon, Lagoon B appears to




be about 25 feet deep, between 20 and 25




feet deep and is a much larger area.  The




total amount of material we're looking to



excavate is approximately 44,000 cubic




yards.  What we do with the material once




we excavate it would be to take it off-site



to a incinerator to have it destroyed.




Cost for this proposed plan is estimated to



be about $58 million.  The proposed plan




that comes to you tonight, as John says,




is part of the process of the Superfund.



This is our proposal.  You know, it's




subject to public comment.  We'd like to




hear you.  You know, any questions you have
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and try tc answer them tonight.   They're a




lot of uncertainties at this point of how




the work is going to get done.  Those are




questions that we're going to do or look at




and try and solve in the design phase of




the project.  What we're trying to do to




move things along pretty quickly is we're



trying to get a design team together right




now to take a look at this problem in the




canals and lagoons and tell us how we can




address these problems in an  expedited




fashion.  We're also at the same time



looking trying to start the relocation




process for the homes that are located  on




Lagoon A  and Lagoon B.  The properties  in




yellow, those residents will  need  to be




permanently relocated.  We'd  like  to buy



their properties  and  they would  then move




out so we could begin work.   Work  could not




begin until we could  move them out.



      The other houses  on the pink dotted




lines and in  pink are houses  that  are



located  either have  a portion of the  canal




located  very  close  to their  house  or



underneath portions  of  their house.   These
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properties we don't know yet what we can do




with them.  Our hope is we can save the




houses.  The last thing we want to do is




take out houses unnecessarily if we don't




have to.  We'll make every effort to save




them.  Those are about nine houses we'll




have sampling results in July that will




give us a better picture on how deep the




canal contamination if it lies beneath




portions of the house or not.  We'll look




at that information and provide it to the




homeowners.  We'll also have, if we could




start, hopefully, we'll have shortly after




that design our engineers look at the




situation as well to determine whether  the




homes can be saved.



      On the relocation process, we think




from where we're standing right now the




relocation process or the temporary, excuse




me,  the permanent relocation folks, it's




going  to  take about nine months to  a year




to do  the title searches, the deed, pull



the  deeds, do appraisals, negotiate, come




to contract, and get possession of  the




properties.  In that time we're going  to  be
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                                                          24
 1            concurrently working a design around
 2            designing the cleanup of the canals and
 3            lagoons.,  When we get it, as we move  along
 4            with the design for the canals and lagoons,
 5            what we'd like to have happen is get  the
 6            rest of the information for all the other
 7            properties on the Claremont Development.
 8            Once we get that information on the rest of
 9            the Claremont Developments and make some
10            decisions on what needs to be done on the
11            Rest of the remaining properties, we'll
12            feature that information into the design
13            while we're working on the canals and
14            lagoons and see how we can address the
15            whole development as a whole.  Work would
16            not begin until we know the situation with
17            the rest of the properties in the
18            development.
19                  That's about all I have to say  right
20            now about this aspect of the project.
2i                        MS. SEPPI:  Thank you.  And now
22            we'd like to open up this to questions and
23            comments, but just a couple of things I'd
24            like to ask, because we do have Darlene,
25            our court reporter here, we would like you

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to come up to the microphone, please, to




make a comment or ask the question and if




you could state your name and maybe  spell




it for Darlene, that would help, just so




she could get it correctly down for  the




record.  Okay?  So Angelo?



            MR. MARUKA:  Wait your turn.




Name is Maruka, 38 East Drive.  I got a



plan better than that.  You  offer everybody




$150 thousand.  That will cost  you 22




million.  If  the people want to move out,




fine,  but if  they stay after you're  done,




they have to  pay you 100,000.   That  will



get you back  ten million  on  the 22 million.




You could do  what you  want with the  rest  of




it.  It's only  random.  They're going to




dig two holes.   Now you're talking  about




ground water  and everything  else.   I worked




at  JM. You  have a  mountain  at  asbestos  at




Gusher field  that's  leaching water  into  the




Raritan River and  has  been  leaching water




into  the  Raritan River for  50 years and




nobody's  saying anything.  You built



Walmart  on  the same property and all you




 did was  what we did at Claremont,  you
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  buried it.   Now I  don't know what the



  problem is.   What  is  Walmart going to have



  the  same  problem 30 years  from now?



  Everybody's  been living in the development



  for  35  years  there hasn't  been a dead cat



  seen on the property  and I find this  here



  overkill.  Thank you.



             MR. ALESANDRO:   Jim Alesandro.



  I live on Florence Court.   I'm want to



 address the map that you have  displayed  on



 the overhead.



             MR. PUVOGEL:   Yeah.



             MR. ALESANDRO:   According to



 what  was being read on page eight of



 one of  your handouts,  it says the



 following:   During  excavation of the



 lagoon,  it  is  anticipated that portions of



 East  Camplain  Road  may need to be closed to



 provide  for  construction equipment.   Okay



 Florence Court,  okay,  as a  result of



 residents of Florance  Court and some



 residents on East Camplain  Road may  need  to



 be tempoxarily  relocated.   According to



 what you have on  the overhead,  we're not



part of that relocation.  Also,  if you look
    L
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 1            on this handout you gave us, this is, you

 2            know, this is describing our lives as

 3            little more than a footnote.  Okay.

 4            Which is if we get relocated, I mean that's

 5            going to tremendously impact our lives over

 6            here.  So I'd like you to comment something

 7            about that.

 8                        MR. PUVOGEL:  The area in pink

 9            shows homes that are directly affected by

10            the canals.  The area in pink shows the

11            purpose of those areas that are colored

12            pink was to show the homes.  The purpose of

13            the map and coloring the areas in to pink

14            was to show those homes that are directly

15            located either abutting or on the canals.

16            For the areas in Florence Court where's

17            it's mentioned in the proposed plan, that's

18            part of the proposed plan, these may need

19            to be relocated.  That's a question we're

20            going to have, we're going to address in

21            the design.  The intent is to minimize the

22            inconvenience to the residents as much as

23            possible.  There's a lot of working going

24            to be going on.  We don't want to relocate

25            people unnecessarily.  We'll work around
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                                                         28
 1            this as much as possible, but what we're
 2            saying is that it might be a possibility,
 3            we don't know yet, until the folks who get
 4            the design done, designing engineers give
. 5            us those answers.
 6                        MR. ALESANDRO:  The reason why
 7            we're being relocated is that because of
 8            placement of construction equipment?
 9                        MR. PUVOGEL:  No.  It's
10            primarily because the road may be closed  at
11            a certain time.  You might not have access
12            to your house.
13                        MR. ALESANDRO:  Even  if the
14            road is closed, why can't we park on
15            another street?
16                        MR. PUVOGEL:  That would be
17            fine.
18                        MR. ALESANDRO:  We'd  like  to
19            work with you  on  this.
20                        MR. PUVOGEL:   Oh, no,  we'd
2i            like to work with you.   By all means,  if
22            you want to park  around the block and  walk
23            to your 'home,  we  could  make  --
24                        MR. ALESANDRO:  We could
25            save the federal  government  a  lot of money.

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                                                         29
 1                        MR. PUVOGEL:  The last thing we
 2            want to do is move you out of homes
 3            unnecessarily.
 4                        MS. SEPPI:   May'l?  Temporary
 5            relocation is a voluntary program.  We
 6            would not force anybody to move out of
 7            their home even temporarily.  The only
 8            reason is to try to make it less  intrusive
 9            to your life.  It's very traumatic to move
10            temporarily.  I've been doing this for  the
11            agency for a long time.  If we could work
12            around it and could have you stay there and
13            you're willing to put up what you're
14            probably going to have  to put up  with,
15            that's fine.  We just want you to know  this
16            program is available for people who may not
17            work during the day, who may be home, who
18            may not be able to stand the noise and
19            everything else that occurs.
20                        MR. ALESANDRO:  That's all  we

21            ask.
22                        MS. SEPPI:  That's why we don't
23            have all the  homes that we may or may not
24            have to temporarily  relocate without  a
25            design.  We  really don't know which  homes

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are gcfng tc be at this point.



            MR. ALESANPRO:  So I could




say on the record there will not be no




forced relocations.  East Camplain




Road and Florence Court where it's not




highlighted in terms of --



            MS. SEPPI:  We won't force




anybody to relocate temporarily.



            MS. KRAUS:  I'm not using the




mike.  I have a very loud voice.  To the




flying dust that this is going to create,




we're going to get that fugitive dust that




you mentioned in the report that you sent



to us.  That could be contaminated or not.




It will settle all over our homes and then




if we open the window, we can inhale it and




get very sick.  I would like to suggest



that when this is all over and before we




come back to our homes, if we get



relocated, to powerwash the houses near the




construction site to get rid of that dirt




and dust that's going to accumulate all




over the place.  Could you do that?



            MR. PUVOGEL:  First what we're




trying to do is to control the dust first
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                                                         31
 1             and control  any emissions from the site is
 2             take whatever any precautions necessary to
 3             stop that happening in the first place.
 4             Whether you  saw mention in the proposed
 5             plan is talk about a prefabricated
 6             structure.  There may be other ways to
 7             control this dust that's going to be
 8             emitted and  that's certainly an option that
 9             we would explore if your house showed to
!0             have dust on it, that we would clean it
11             off.
12                         MS. KRAUS:  You're saying  that
13             that much dust will be generated  when you
14             start the construction?
15                         MR. PUVOGEL:  Yeah.   We try to
!6             minimize  that as much as possible.  We
i7             don't want  this stuff -- we're trying  to
18            protect,  you know,  human health  as much as
19            possible.   Dust is  a  concern as  well as the
20            odors.   So  we're going  to try and control
2i            them as  much as possible.
22                         MS.  KRAUS:   When you demolish
23            the homes right  there,  you're going  to have
24            dust.   It might  not be  contaminated  dust,
25            but it  is going to be a lot of dust.

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            MR.  PUVOGEL:   Right.   There are
engineering ways we cculd control the dust
to simply one wetting the area down before
demolition, but  no, we'll take that into
consideration in the design.
            MS.  KRAUS :   If the dust is a
lot, even if it  isn't,  will you wash the
homes?  You know, you have that powerwash
that they use.  Hire somebody.
            MR.  PUVOGEL:   What we can do,
we could look into that and see if we could
do that.  We first want to know that if
it's a real problem, we'll take a sample.
We'll take a wipe  sample.  If we see it's
visually there,  we could do that, too.
            MS.  KRAUS:  Thank you.
            MR.  PUVOGEL:   Any other
questions  or comments?
            MS. MANDERSKI :  Theresa
Manderski, Valerie Court.  Actually,  it's
going to  take a year or eighteen months  for
your title search and deed searches.   So
we're talking about eighteen months  before
you start.  Once you start, is  there a
specific  hour of operations while  you do
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this?  I mean we have to work.  We have to




get our kids to school.  We have to make




arrangements for our lives.  We're not




going to relocate, you know, some of us do




have canals in our backyard.  We're not




part of the pink or the temporary



relocation.  So I guess it's along our back




fence lines or along the road.  What



happens to our pools, our  sheds or fences?




I mean that's all on the fences when you




are going to come in.   I'm not taking off




six months vacation so  you could do ray.




backyard.  My boss is not  going to let me




do that.



            MR. PUVOGEL:   For  those areas




where  those kind  of materials  are, pools  or




shed are  in the backyard that  we  need  to




excavate  that  area, we're  taking  those




sheds  and pools and  if  they're in the  area




of  the excavation, we  would pretty much




demolish  them  and give you new sheds  and




a new  pool.   As  far  as they're at the  area



on Valerie Court  where the exit trench is



up north  where it comes out east  of the



 lagoon,  again,  relocation isn't -- what
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                          "'    -                            34
 1            hours are you going  to be  in  there?   Are

 2            you  going to be in there at 7:30  in  the

 3            morning?  Are you leaving  at  five?   Are you

 4            coming  in on the weekend?

 5                        MR. PRINCE:  It's  typical that

 6            we do construction basically  five days &

 7            week.   Five days a week during normal

 8            construction hours.  So basically seven to

 9            five.   Now, let me make --

10                        MS. MANDERSKI:  Seven?

11                        MR. PRINCE:  Yeah.  They start

12            pretty  early.  Understand  that one of the

13            reasons why we have  a community advisory

14            group for this site  is so  that while we are

15        ""   developing the design over the next  year

16            for  how we're gcing  to address these areas,

17            we can  resolve some  of these  things.   Do we

18            have to close parts  of the roads during the

19            week?  How do we work that out?  When

20            do the buses come for the kids?  We  do need

21            to make sure there aren't trucks on  the

22            roads--.  Questions like that that we  need to

23            incorporate right into our construction

24            plans.  So that'yes, all those questions

25            need to be answered  and that's part  of the


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                                                         35
 1             process.   And there is definitely
 2             neighbor  input to that.
 3                         MS.  MANDERSKI:  Thank you.
 4                         MR.  BRZEZIENSKI:  Ron
 5             Brzezienski.  I'm here on behalf
 6             of my mother Helen Brzezienski.  She
 7             supposedly has a -- 72 Valerie Drive  --
 8             canal under the house.  What is the
 9             possibility of just picking the house up
10             off the foundation and moving it back
11             whenever the work's done and putting  the
12             house back on the foundation?
13                         MR. PRINCE:  The EPA has
14             experienced in residential  communities
15             where there is contamination that's
15             actually under houses, have actually.
17             undermining the house with  essentially  a
18             new  foundation, removing  the contaminated
19            material and  then rebuilding a  foundation
20            underneath  the house.  That is  another
2i            option instead of actually  taking  the house
22            down.
23                         MR.  PRINCE:   It has a  lot to  do
24            with how  deep the material  is.
25                         MR.  BRZEZIENSKI:   You

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                                                          36
  1            supposedly say the canal is like four to

  2            six feet down.

  3                        MR.  PUVOGEL:   In some areas

  4            it's deeper than eight feet.  In some areas

1  5            the canal varies.

  6                        MR.  BRZEZIENSKI:  I remember

  7            when they were bulldozing our foundation

  8            and around most  of the houses.   We did not

  9            see any creosote.

10                        MR.  PUVOGEL:   That's a positive

11            thing.   We talked  to you  early  on when we

12            were taking samples on either side of your

13            mother's house to  see how deep  the creosote

14            is.   If it's below the footings and such,

15            that will give us  a better idea what we're

16            in  for  as trying up around the  house.

17                        MR.  BRZEZIENSKI: That's a

18            possibility of moving the foundation?

19                        MR.  PUVOGEL:   Yeah.   Yeah.

20                        MR.  STRAIN:   Robert Strain.   I

21            live at 271 East Camplain Road.   I live  all

22             the  way at  the end of that  cul-de-sac

23             there.   If  you're  going to  be doing all

24             this excavating, all  this stuff,  how am  I

25'            going to get  to  my house  back and forth?


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It's ridiculous for you to be closing the




roads down.  If there's ever a fire or




somebody needed an ambulance, had to get in




right away, there's no way that, you know,




people are going to be able.  I'm in the




construction business.  There's no way that




you are going to have -- people are going




to be able to get in and out of here.  I




think the gentleman that spoke before with




giving an option to buy everybody for say




$150,000 and then doing what you want with




all the property here is a good idea.



            MR. PUVOGEL:  One of the things




we're going to be looking at during design




is how we could work around  closing the




roads.  We don't want to shut off access  to




the community.



            MR. STRAIN:  You can't do that.




People got to come and go.



            MR. PUVOGEL:  We realize that.




So we're not going to shut  the  community




roads off.



            MR. STRAIN:  I  seen people  work




to  see there's no way that  you  are  going




to  be able to  do  it.  You're not  going  to
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keep the dust out.  You build a tent, how
are you going to give up and work with
machines in there?  It's never going to
work.
        '.    MR. PUVOGEL:  We've done it at
other sites.  It's a lot slcwer.
            MR. STRAIN:  The people that
live here,  you're going to have to smell
the smell of creosote.  You smell what it's
like when trains go and they're putting in
new railroad tracks in.  That smell people,
are going to be getting sick from it.  Am I
right that people are going to be -- you
know, you sit there and breathe that in
constantly, you dig into that, it's not
going to let off any fumes or anything?
            MR. PUVOGEL:  What we're.going
to do as we dig, try to control the odor
as much as possible.
            MR. STRAIN:  A guy works on a
gasoline main.  They open the gas.  The gas
comes out right away.  How are you going to
get rid of that smell?  The smell don't go
away.
            MR. PUVOGEL:  Those are the
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considerations we're going to take,into  the




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best we can.




            MR. STRAIN:  Okay.  Thanks.




            MS. KRAUS:  The temporary




people that have to be relocated,  do they




find their own apartments or whatever or do




you find it for them?  And if you  do, how




much would you allow for the rent?




            MS. SEPPI:  Temporary




relocation, if you wanted to, if you need




to be relocated temporarily and you could




find a place on your own, that would be




fine.  But what we'd like to do is  get




government leases for properties and then,




you know,  take the burden off you.  That




way we can handle it, that way we  can pay




directly to the landlord.  Your name isn't




on the lease for a temporary relocation.




            MS. KRAUS:  My name isn't on




it?




            MS. SEPPI:  No, not if  you have




a government lease.




            MS. KRAUS:  But I live  right




there.
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                                                         40
 1       i                 MS.  SEPFI:   I mean saying if
 2             you should have  to be temporarily
 3             relocated, the government reabsorbs --
 4                         MS.  KRAUS:   Do you find us a
'5             place or do we find our own?
 6                         MS.  SEPPI:   Either way.  If you
 7             can't find a place, we would certainly work
 8             to find one for you.  What happened in past
 9             sites, the people, maybe a relative, has an
10             apartment or something.  They said was it
13>             all right to move there?  We said  fine, as
12             long as that's where you want to go.
13                         MS. KRAUS:  There is a certain
14             amount they would allow for rent?
15                        MS. SEPPI:  What we  do in
16            Manville, we base  it on the average  rent  in
17            Manville.  That would  be  the parameters,
18            that ballpark amount that you would  be
19            entitled  to.
20                        MS. MANDERSKI:  I have a
21            question  on that.   We  have  animals.   We
22            have  small kids.   We're  used  to  living  in
23            three,  four,  five bedroom homes  with full
24            finished  basements and all  that  entails.
25            you are telling me average  rent  in Manville
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probably goes about what?  I mean Manville,




unfortunately, is on the cheaper side of




rent.  You could get a two bedroom




apartment in Manville for like $750 a




month.  My $1800 mortgage, you are not




going to fit into a $750 a month apartment




with my two dogs, one of which is a pit




bull and my kid.  It's not going to happen.




            MS. SEPPI:  You don't have




to temporarily relocate.




            AUDIENCE MEMBER:  Me too.  My




dog  is now in any backyard.




            MS. SEPPI:  We've done this




many times.  We will work to find something




that works for you, you know, if you  had




to go out temporarily.



            MR. MARUKA:   You keep saying




we.



            MS. SEPPI:   I'm  sorry.




            AUDIENCE  MEMBER:  I  asked if




you  had  ever  been  relocated.  That's  all.




            MS.  SEPPI:  No,  I've been - -




personally  I  haven't  been and  I  now  how




traumatic  an  experience  it  can  be  for




people.  That's  why we  try not  to  do it  if
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 wo dor.'t have to.  But we would work with

 you if we had to do it and we would try to

 find you something that's comparable to

 what you have.   That's all I could say to

 you right now.   Hopefully, that won't

 become an issue for you.

             MR.  PUVOGEL:   Any other

 questions?

             MS.  KRAUS:   If the people

 choose to be relocated,  not the permanent

 ones,  the temporary relocation,  do they

 have  to put  their name  on a list?   Kow does

 that  happen? Is  there  a  list?

             MS.  SEPPI:  No.   No.

             MS.  KRAUS:   I'm right  on  top  of

 the construction  site across.   I'm going  to

 hear  and  smell everything all  day  long.

 We're  home all day  long.   We're not

 working.  We don't  go to  school or work.

 We're  retired.  Sometimes  we go here and

 there, but I can't  stay in  that house and

 smell  all that contamination,  dust  and

 having -noise, noise plus.   I cannot stay in

 that house.   So if you have a  list, please

put my name on it.  You know me.
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                                                         43
 1                        MS. SEPPI:   We don't have a
 2            list yet.
 3                        MS. MRZYGLOCKI:   My name is
 4            Joan Mrzyglocki.  I live 52  Louise Drive.
 5            I want to  know if I could make my garden.
 6            I like fresh tomatoes.
 7                        MS. SEPPI:   I think that's a
 8            question for you, Artie.
 9                        MR. BLOCK:   Good evening.  My
10            name is Artie Block and I am a
11            representative for the agency for toxic
12            substances and Disease Registry.  We're an
13            independent environmental and health
14            agency.  That's a great question.  It's
15            actually one that was asked earlier when we
16            first began our work here in terms of
17            uptake or dose your vegetables get
18            impacted by the contamination.  And the
19            answer is no problem.  You can do whatever
20            you want to in your gardens.  Eat your
21            vegetables, whatever you want to.  There's
22            no impact in terms of the contamination on
23            this site.  Now, on other sites, yes.
24            Different hazards, but  in this one, it's
25            not a problem,  folks.   Enjoy your

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              vegetables.   Okay?
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                          MS.  KAZUR:   My name is Joan

              Mazur.   I live at 78 Valerie Drive and Pat

              knows I'm very upset over this.  I do not

              want to move.   I'm one  of them.  I'm sorry.

              Clean my house up, knock it down, but give

              me my stuff,  my home back.  And another

              thing,  there was real estate the last time,

              too.  They spoke to somebody in my family.

              Oh,  your land is -- we  can get your land

              for $55,000 and sell it for 80.  I mean why

              can't I have my own land back?  This is in

              a way discriminatory, too.  I'm getting

              people saying they put  a bid on it.

                          MS. SEPPI :   Not us.

                          MS. MAZUR:   Somebody.

                          MR. PUVOGEL:  An independent

              real restate agent.

                          MS. MAZUR:   This is America.

              Supposed to be.

                          MR. PUVOGEL:  What we're trying

              to  do is see if we could  save  those homes.

              The last thing we want to do is  take the

              properties or remove you  from  your home.

                          MR. MAZLENSKI:  James
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                                                         45
 1            Mazlenski,  107 Valerie.   Pertaining to here
 2            with these houses that are going to be torn
 3            down in the yellow,  why do you have to buy
 4            the land back?  Why can't they just own the
 5            land,  you knock their house down, clean up
 6            the site and just build them a new home?
 7            This way you don't have to buy the
 8            property, sell it back to the bureau and
 9            somebody else bids on it.
10                        MR. PRINCE:   There has been on
11            other sites arrangements like that where we
12            basically compensate the property owner for
13            the structures.  They keep possession of
14            the land.  When we are finished, they
15            may -- they own the land, they can sell the
16            land,  they may use that money to
17            rebuild the house.
18                        MR. MAZLENSKI:  Are we going to
19            get enough money to rebuild what they have
20            now?
21                        MR. PRINCE:  That's the intent.
22                        MR. MAZLENSKI:  It's going
23            to cost more for the same house to be
24            built.  It's going to cost more, so it's
25            going to be out of their pocket?

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            MR. PRINCE:  The way it has




worked before was that the rate of



compensation was such that they could build




a house today on that lot of a similar




size .



            MR. MAZLENSKI:  What if they




don't want similar or they wane the same or




greater, not smaller?



            MR. PRINCE:  I'm implying not




only the same size, but the same levels of




finish, same number of bathrooms, finished




basement, essentially the equivalent house.




            MR. MAZLENSKI:  Another




question is with the smell and odor and




everything, if people are getting



relocated, the odor is going to be in their




house.  Now they got wall-to-wall



carpeting.  Are they going to replace all




the carpeting  in the house?



            MR. PRINCE:  We don't




anticipate that the carpeting is going to




be affected.



            MR. MAZLENSKI:  What if  it does




get affected by all these homes.  All the




odor  is; -- you ain't going to be able to
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                                                         47
 1             control  all  the odors.
 2                         MR. PRINCE:   When we typically
 3             relocate someone during  the work, in other
 4             words,  we have to sort  of work right around
 5             their house,  we also seal the house up.
 6                         MR. MAZLENSKI:   Seal the house
 7             up?  Now another question is people that
 8             you are going to be relocating, are you
 9             going to have any security there to watch
10             their homes?
H                         MR. PRINCE:   Yes, sir.  Yes.
12             We also have 24 hour security while we do
13             the sort of work.
14                         MAYOR CORRADINO:  You were
15             talking about  taking nine months to a  year
16             for the surveys and the  negotiations and
17        .     the buyout.  When is that process going to
18             start?
19                        MR. PUVOGEL:  We've  already
20            started  the process.  It's  jumping  the gun
2i            a  little bit,  the proposed  plan  hasn't --
22            it's not finalized.  We  already  started
23            that process.   The  Army  Corps  of Engineers
              has  been brought  on board  and  has  started
25            to look at  titles  and deeds for  these

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                                                           48
 affected properties  so that process  already

 started.

             MAYOR CORRADINO:  When are  you

 going to notify the homeowners?  You  are

 starting negotiations.  You say you have to

 work from nine months to a year, then

 design the plan.  Now you already know  that

 these houses have to be bought out and  in

 order that this has  to be corrected,  these

 are the  lagoons.  Why can't we start  on

 those right away?  Why can't you start

 negotiations with  those people right  now so

 we  don't  have  to wait a year and half for

 this  phase  to  be done?

             MR.  PUVOGEL:   What we're  trying

 to  do is  do  two  steps at  once, negotiation

 with  the  people  as the  contract  is being

 drawn up.  The process  of negotiation, has

 to  go through  several steps.   First have an

 assessor assess  the property.  Then we

 could start negotiations with  the folks,

 Closing to contract.   After that they have

a certain amount of time that  they've given

to leave  their homes.

            MAYOR CORRADINO:  As soon as
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                                                         49
 1             that  process  is  completed,  then you could
 2             start the  cleanup in that area with phase
 3             one.
 4                         MR.  PUVOGEL:   What we need
 5             first is this Record of Decision.  The
 6             finalized or formalized decision that we're
 7             making on the canals.  Then work can begin.
 8             We're jumping the gun.  We're starting the
 9             process of relocation now, but we get the
10             real money after that Record of  Decision is
xl             written that releases the funds  so we could
12             do this design work  and that's the process
13             Of superfunding provides an opportunity  for
14             public  community which we're  doing tonight
15             and  - -
16                         MR.  PRINCE:  Before  we spend
17            the  money.
18                         MR.  PUVOGEL:   Right.
19                         MS.  SEPPI:   So  you understand
20            it's not  nine to twelve  months.   We've  done
 21            some of the  relocation stuff  already.   The
 22            deeds and the title searches,  we're  in the
 23            process of getting a local appraiser on
 24            board to do the appraisals.  That we can do
 25            before we have  the Record of Decision.
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Until we have that Record of Decision in




July, we can't get into any kin:' of




negotiations with any of the residents.




You know, but once we have that Record of




Decision and it's signed,  then we could




start meeting with everybody individually




and getting into this relocation process.




So we're not talking about nine to twelve




months for that.  We're talking about two




months before we could start doing that.




            MAYOR CORRADINO:  Once that's




completed, that's when that phase is going




to start?  We've been reading it's going to




take between four and six years to complete




this.  Now this four or six years, is this




retroactive to two years ago when we



discovered it, when DEP or EPA got involved



or are we talking starting this from day




one because this is -- that's quite along




time for people to be displaced or their




Lifestyles to be disturbed.  I think we



need to expedite -- I think we submitted a




plan with local engineers where you could




get it done in two years.   That's my main




concern.  We need to get back to normal is
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for these people as quickly as possible




and four years is just too long.  I'm




concerned about the other people, too.




            MS. SEPPI:  Do you have a




question, sir?



            MR. SAZZACHAKO:  Stephen




Sazzachako.  I live approximately a mile




and a half away from this development.




Directly it doesn't affect me.   Indirectly




it may.  There's an individual or two




individuals here that are considered  risk




assessors.  May I please have a  definition




of your  position and what exactly do  you




work in  the way of the statistics and the




fine --  I  can't find  the right words.




sorry, but please explain what you  do.



            MR. MADDALONI:  Mark Maddaloni.




Well,  we look  at all  the data that  was




generated  from the site  and make estimates




of any actual  or projected health  risks




that we  may suffer as  a  result  of  being



exposed  to this site  and we did this. Many




of you have come to me before.   I  should be




familiar with your face  and come up and



explain about the  nature of the surface
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 soil assessments  that we  did.   We  have  very

 conservative  assumptions  about  how you

 might be exposed.  That test, if you  use

 soil, and people  ingest small amounts,

 incidentally, every day,  and we assume  that

 you'll be in  contact with that  soil every

 day for a 30  year exposure period,  that's

 the upper bounds  of how much time  we  spend

 living at a house, we think then combine

 that with very conservative assumptions

 about the toxicity of chemicals.   That

 polycyclic aromatic hydrocarbons,  that's

 by-products of the creosote process.  From

 that we could make, I think, very  informed

 educated scientifically defensible

 projections about what kind of health risks

 are involved.  And so I'll be glad to spend

 as much time  as you need to satisfy your

 need to understand risk assessment.

            MR. SAZZACHAKO:   Basically your

 explanation probably put half of these

people to sleep.

            MR. MADDALONI:  It's a little

 dry.

            MR. SAZZACHAKO:   What  I'm
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gearing for,  we know as Manvillites what




asbestos has  done to the human body.




What does creosote do to the human body?




            MR. MADDALONI:   Again, there is




a lot of products from creosote.




            MR. SAZZACHAKO:  Very, very




simply, what  are we looking at?




            MR. MADDALONI:   We're probably




most singly concerned with cancer causing




potential of  a group of these components,




what's called the PAHs.  They have been




demonstrated in animal models to  cause some




types of cancer.  They're not demonstrated




human carcinogens, but they have  been




demonstrated in animal models.  Bear in




mind in very high doses.  They  are very




different in some areas where we  don't have




equivalent like the four stomachs.  The




EPA takes a very conservative approach and




treats any carcinogen  as if it  could be  a




human  carcinogen.  That's the main  driving




risk that is behind our trigger levels and




clean  up goals  for this site.   Cancer




causing potential from a group  of chemicals




called PAHs, polycyclic aromatic
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hydrocarbons.



            MR. SAZZACHAKO:  Is anybody  in



danger of dying?



            MR. MADDALONI:  I'll get to



that.  Hold on, sir.



            MR. SAZZACKAKO:  Thirty-five



years the Claremont Development has been



there and many of those individuals have



lived there since it was developed,



actually bought the houses as brand-new.



In turned there have been, of course,



resales.  Now, as a risk assessor, tell  me



after five years, after ten years, after



twenty-five years, after fifty years,



mortality rate, please.



            MR. MADDALONI:  I don't think



anyone on earth can .gi.ve you a precise



answer to that.  But we did look at the



surface soils have been completely



characterized.  Now, the medium which are



mostly in contact with and most of the



homes probably about 120 of them had very



low risk.  That's what we projected would
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be less than one in 10,000 chance of excess



cancer risk over a lifetime frcm being
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exposed every day to those soils.  It's not




zero.  And we don't want to live with any




risk.  And I don't blame you for that, but




there is,  you know, small amounts of risk.




            MR. SAZZACHAKO:  You can't give




me any numbers?



            MR. MADDALONI:  Less than one




in 10,000.



            MR. SAZZACHAKO:  Less than one




in ten thousands.




            MR. MADDALONI:  For  almost all
the properties.




            MR. SAZZACHAKO:




course of how many years?




            MR. MADDALONI:
 Over the
A 30 year
exposure.



            MR. SAZZACHAKO:   Thirty year




exposure.  Approximately  137.




Approximately  forty-five.   Theoretically,




you're telling me  you  feel  because it's one




in  10,000  I cannot see any  mortality there,




any mortality  rates involving Creosote?  I




don't believe  that.   If we  look at what we




have the problem with, asbestos where people




never worked  in Johns  Manville, people
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actually  lived 20,  30  miles  away were




exposed to clothes  that  had  asbestos, we




had mortality rates.   I  still  think you




know the  answer to  my  question.   I  believe




that you  just don't want  tb  tell us.




            MR. SAZZACHAKO:  I'm sorry,  I




can't disagree with you  more.   I couldn't




disagree  with you more.   58  million dollars




to remediate, 44,000 cubic yards.   How many




dump trucks is that?




            MR. MADDALONI:   I'm  going to




have to pass that one  off.




            MR. SAZZACHAKO:  Sealed?




Unsealed?




            MR. MADDALONI:   Any  other




health questions I'll  be  giad  to answer




that.




            MR. PRINCE:   Sealed  trucks




departing the site and the trucks,  namely




44,000,  40 yards a dump,  20  yards a




dumpster,  2,000 trucks.




            MR. SAZZACHAKO:  2,000




truckloads?




            MR. PRINCE:  And then 2,000.




            AUDIENCE MEMBER:   22,000.
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            MR. SAZZACHAKO:  Better




Arithmetic than the federal government I




see .



            MR. PRINCE:  That would be two




yards a truck.




            MR. SAZZACHAKO:  Sealed.




            MR. PRINCE:  Sealed trucks.




And I should also point out that we are




taking all of this material out so we need




to bring clean material in.  So they're




twice as many trucks that need to be




involved in this process.




            MR. SAZZACHAKO:  Now sealed




trucks.  I don't know how you're going to




pack these trucks without getting it on  the




tires and wheels and driving right through




the community, but was that something you




are going to have to worry about.




            MR. PRINCE:  Yes, it is.




            MR. SAZZACHAKO:  Now you




mentioned construction time between seven




a.m. and five p.m.  Are these Federal




workers?  Are they private contractors?




How many individuals?  How many workers?




How many trucks?
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            MR. PRINCE:  We typically  do




this:  all the clean up work is performed




under contract to private remediation,




environmental remediation firms that




specialize in this kind of work, that  have




the specialized kind of workers that are




needed to know how to remove this material.




So it's typically a fixed price contract




with the federal government performing the




cleanup work.



       ',     MR. SAZZACHAKO:  That's




unusual.   I love the way you answered  the




question.  I was back there sitting with my




wife.  Every individual came up here asking




you questions, I see some of the residence




here laughing at you.  Basically you are




giving us no answers.  Do you recall what I



just simply asked you?  How many workers?




How many trucks?  How long does it take?  I



would like to know.  58 million dollars, as




far as I'm concerned, I'm willing to pay




it.  I've paid my taxes,  so if these



individuals are from other remediations



throughout this country,  how many workers?




How many trucks?  And how long?  You never
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gave me an answer.  You guys skirted right




around it.  You've been trained very well.




            MR. PRINCE:  Thank you.  I will




tell you that we do not have the answers




to all those questions because we will --




            MR. SAZZACHAKO:  You should at




this point.  You should.  It's



unbelievable.  I'm going to use something




that I don't normally use.  You people,




that's basically a slur in a lot of places,




you people have been working on this for




so long, you don't even have the answers




to simple questions like that?



Mathematics, that's all it is.  I'm not




affected by this.  I am not going to be




dying from this.  Half of these people




probably will.  I did not get that answer




correctly from him.  Risk assessment




is basically risk mortality.  How many




people are going to die?  Is that




a statistic?  That's it.



Now, if you don't have that question, how




can you possibly say that you are giving



these people the necessary information they




need?
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                                                         60
 1                        MR. PRINCE:  These are all
 2            questions --
 3                        MR. SAZZACHAKO:  The court
 4            reporter is taking these questions and I
 5            assume that is probably going to be
 6            answered, if not in .the papers, at least
 7            hopefully send me a copy of it.  Tell
 8            these people what they can expect.  Now
 9            your turn.
10                        MR. PRINCE:  Thank you.  The
11            process when we have questions at meetings
12            like this that we cannot answer, is that  we
13            have recorded that for several reasons.
14            One because we need to be able to
15            memorialize any responses that we can't
15            give, but also we need to document that
17            we're all participating in this process
18            that we're EPA's not going hell mell on
19            some process that is unvetted by the
20            community.  That's not where we did not    *
2i            give the community an  opportunity to
22            provide  their  input.   So yes, the Record  of
23            Decision that  we discussed that formally
24            says how EPA will perform this clean up,
25            will have a section in it that will have
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                                                         61
 1            all of these words and then we'll actually




 2            have written responses where our verbal




 3            efforts are insufficient.




 4                        MR. SAZZACHAKO:  Thank you.




 5            Earlier you had mentioned that there are




 6            certain number of Superfund sites.  I'm




 7            sorry, I missed that number.




 8                        MR. PRINCE:  About 1,500 across




 9            the country.




10                        MR. SAZZACHAKO:  1,500.  How




11            many are in residential areas?




12                        MR. PRINCE:  I don't know.




13                        MR. SAZZACHAKO:  I could tell




14            you right now.  One.




15                        MR. PRINCE: . Not true.




16                        MR. SAZZACHAKO:  This  is what




17            we were told.  Then my information was




18            incorrect.  Because we have information




19            here.  Also that  industrial sites  takes




20            precedent over residential sites.  I don't




21            know why.  Because it would be easier  to




22            control or easier to  remediate?




23                        MS. SEPPI:  That's incorrect.




24                        MR. PRINCE:  May I respond to




25            that?







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                          MR. SAZZACHAKO:  Sure.  Go
ahead.



            MR. PRINCE:  This site




affects -- we know where the plant



was and we know where the ties were stored




and we know where the canals are and



lagoons are now located and we've done a




lot of testing to characterize where that




material is, not contaminated soil that




might be spread around in other places, but




really where the creosote residues are and




our plan is to address that first.  The




actual facility is primarily under the



Rustic Mall commercial area and we suspect



that  there's probably  some  contamination




there, too.  We have not  gotten to that



stage of  our investigations yet.  That's  to




come  because we are  focusing  on what we




perceive  and I think what you  all agree  is



what  we  should be  addressing  first,  which




is the residential area.



             MR.  SAZZACHAKO:   Oh,  without




question,  I agree.  What  about the



Foodtown where we  eat  the food from?



             MR.  MADDALONI:   That's  a good
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 point.   I  notice on the plans it seems as
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 over  some  canals.  Why subject the

 residents  to the open soil, the possible

 contamination of their lungs and their

 homes,  et  cetera, and then have them

 return  to  the neighborhood and then work

 and open up the commercial area?  Why can't

 you all do it at the same time?

             MR. PRINCE:  Well, we think

 that  we're addressing the worst part of the

 site  first.

             MR. SAZZACHAKO:  You're dancing

 again.

             MR. PRINCE:  Pardon?

             MR. SAZZACHAKO:  You're dancing

 again.   Think of it, why do one and not the

 other at the same time?  You're going to

 disrupt this whole town.  Now, back to the

 next  question.  Realizing that $58 million

 and again, you don't know how many workers

 or how  many trucks are going to be

 involved,  you're figuring four to six

 years,  two to four years?

             MR. PRINCE:  The four to six
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 time frame is more for addressing all of


 what we might find including possible


 ground water contamination,  concerns about


 the rivers,  some  of  the  broader  site


 i ssues.


        ;     MR. SAZZACHAKO:   Now,  four to


 six years,  $58 million,  "X"  amount  of


 workers,  "X"  amount  of trucks, if  you


 double the  number  of workers,  double the


 number of  trucks,  you'll double  the number


 of  expense  and you'll get  it  done  in half


 the  time.   Have you  thought  of that?


            MR. PRINCE:  One  of  the issues


 that we need  to work out in  the  design


 which  is related to  that is  that there are


 two  lagoons and it would be most


 disruptive, but quickest if we were


 addressing them both at the same time.


 However, we need to make sure that  we  can


 do that and allow for emergency services,


 regular lives to continue,  and not  cause


 too much disruption such that it  becomes an


unlivable place.   So we need to weigh  that


decision.  Do we do them both at  the same


time or do we do them sequentially and we
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need to work that out.



            MR. SAZZACHAKO:  In a sense




you'd rather disrupt the neighborhood for




four to six Christmases instead of two to




three?



            MR. PRINCE:  It's an open




question.



            MR. SAZZACHAKO:  Title




searches, you mentioned six months.



            MR. PRINCE:  The estimate that




we give is six to -- I'm sorry, nine to




twelve months to perform the permanent




relocations of the properties that need  to



be permanently relocated.  That's  from the




start of  the process until the  last person




is relocated.  So some  people might be out



in a month and some  people might be out  in




six months.  Based on  our  experience at  our




sites where we have  had to do permanent



relocation, give that  as an  approximation




of how  long it will  take to  do  the whole




process.



            MR.  SAZZACHAKO:   Now,  who  has




the  final say  on this  whole  project?   Is




that  Mr.  Puvogel?   Who has the  final  say
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                                           66
in how this is going to be taken care of?




            MR. PRINCE:  The remedy




decisions are made on a region wide basis.




The EPA is broken up into ten regions.




This is region two.  The regional



administrator is Jean Fox and she will




ultimately be signing the Record of



Decision which will be issued, which will




say this is how EPA's going to address




and perform this work.



            MR. SAZZACHAKO:  Thank you.




            AUDIENCE MEMBER:  Does anybody




know how long it's going to take?  When we




are told by the EPA, two, three, five years




maximum, now you are talking four to  six




after two years went by.  Do you know how




long it's really going to take or not?



            MR. PUVOGEL:  The lagoon/canal




area we're estimating at this point about




two to three years.



            AUDIENCE MEMBER:  Now the with




four to  six, you are talking about, I think




the Mayor and  the politicians, because




they're  going  to speed this along and cut




the time down,  every time we come to  a
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meeting, you add two more years.

            AUDIENCE MEMBER:  Creosote,


isn't that kind of just like a natural


process or byproduct of when you burn wood


in a fireplace?  If the wood has a high


moisture content, is that what you get?

            MR. PUVOGEL:  That's true.


            AUDIENCE MEMBER:  Your readings


could show, especially for  a lot of

people that have been burning wood

fireplaces during the winter when you're  --


during your excavations.

            MR. PUVOGEL:  There  are


background amount or man-made amounts  of


creosote that  occur in the  soils as  part  of


a natural  society.
                    *?
            AUDIENCE MEMBER:  Oh, we


breathe it every day to a certain degree,


let's say  if you have a house with  a


fireplaces, especially.

            MR.  PUVOGEL:  Yes.

            MS.  PONGRAZZI:   Rebecca


Pongrazzi.  I  live  at  23  Valerie Drive.


Essentially, my  home  is not a  buy out  or


potential  buy  out.   I  agree with a  lot of
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                                                           68
 things that have been said here  where  as

 homeowners we've lost the freedom  to sell

 our homes if we choose to.  I personally

 don't want to be here through this?  My

 family owns an environmental company.

 Although you could put up tents and

 minimize the dust,  it's still going to be a

 mess.   There's going to be

 gigantic holes.   You are talking 20, 30

 feet deep.   It isn't going to be a friendly

 environment  once you start tearing things

 up.   You  know,  utilities are  probably

 realistically  are  going  to be  accidentally

 hit  and people  are  going to  lose water,

 gas, things  like that, temporarily.  That

 happens.  It's definitely  going  to  be an
        *>
 ugly scene for a lot  of  people and  I  feel

 as though you should  give  the choice  to the

 homeowners to have  their homes bought out

 if they choose to because  we've  lost that

 choice as homeowners.  We  can't  sell our

 homes at this point.  And  I feel  as if  you

 were to buy the homes and  give us that

 choice, you are not going  to lose that

money because once it's cleaned up, you



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could resell it for the value that you




bought it for or possibly higher.  You have




nothing to lose.  If you own the property,




at least it gives us the choice to leave if




we choose to.  The other question I have




is I agree that we have gotten a song and a




dance with our questions.  The question




about the garden, that was the first time




I've heard a definitive answer that, yes,




it is safe to eat our vegetables.  I was




told last year that while you were planting




if you saw creosote, if you saw black




residue, then it's probably not safe.  I




have done my own research on the




internet on creosote and the components




that make up creosote, and there's a lot of




things in creosote, that seem very



dangerous.  I've read things about




reproductive problems associated with some




of the components.  I've read something on



breast cancer.  I've read something on




blood disorders.  And I know you are saying



that it's long-term health risk, but I mean




it's a health risk period and there's




people here.  I would1 like to know
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                                           70
definitively if it's safe for my ten month




old daughter to' play on my grass.  My grass




is in a drip area.  I've never got a




definitive answer.  Is it safe?  Everybody




has small children and as parents, you love




them more than anything.  Would you let




them crawl on this potentially hazardous




soil?  Yes or no?



            MR. MADDALONI:  The answers are




not crystal clear.



            AUDIENCE MEMBER:  That's shit.




            MR. MADDALONI:  We use the best




science that we have available to us.




That's all we could use  and sometimes




there's just --
kids?
 them.
 answer.
            MS. PONGRAZZI :   Do  you  have  any
            MR. MADDALONI:   I  have  two of
             MS.  PONGRAZZI:   I  want an
             MR.  MADDALONI:   When we




 delivered the  soil  to  the  risk assessor,  we




 identified a couple of problems and you




 were each individually mailed where, you
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                                                         71
 1            know, you had slightly higher levels.
 2            Nothing posed an immediate risk, but we
 3            said over the long-term based on -- based
 4            on what Congress has directed EPA to take
 5     "       action when cancers has seen certain
 6            levels, we have targeted certain homes for
 7            long-term remediation.  I spoke to this
 8            group and I said there are not immediate
 9            hazards.  I said you should --
10                        MR. MADDALONI:  My daughter,
11            she can't play on the grass.  A ten month
12            old because you don't have an answer.
13                 •     '  AUDIENCE MEMBER:  Can she put
14            her child out on the lawn?  I heard her
15            say, "Honey, get the butterfly.  Look this
16            at this butterfly."  Can she or can she not
17            do that with her kids with no risk, with no
18            risk to her child?
19                        MS. PONGRAZZI:  I was told with
20            my child as long as that child doesn't come
21            in contact with the soil.  You know, that's
22            not realistic.  Children are going to
23            stick their fingers in their mouth after
24            they touched the grass and play.  They put
25            dirt in their mouth.

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            MR. MADDALONI:   Hold on.  We


have -- we have the kind of --

            MR. BLOCK:  I'll answer that.


Again,  my name is Artie Block.  The answer

to your question is yes, your child'can


play in the yard.

            MS. PONGRAZZI:   Would your


child?

            MR. BLOCK:  Yes.  You have to


understand something about risk.  Okay.


What Mark talks about is, and

toxicologists will do this, they need to

look at numbers.  Okay? ' Risk assessors


need to look at numbers.

            MS. PONGRAZZI:  What about


people?  Look at people.

            MR. BLOCK:  You as a person,


what do you see on top of, hopefully, on


top of the dirt?

            MS. PONGRAZZI:  Grass.

            MR. BLOCK:  What does the grass
do?
soil.
            MS. PONGRAZZI:  It covers  the
            MR. BLOCK:  One more question
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                                                         73
 1             or  a  statement  maybe.   This  is  what  you
 2             call  exposure.   Okay?   The level of
 3             exposure  your  child may have.   If there is,
 4             in  fact,  if  there is,  in fact,
 5             contamination  and there may be  some
 6             contamination  in the dirt, maybe one, two
 7             inches,  three  inches underneath, the
 8             reality of it  is as your child is crawling
 9             over the grass, okay,  hopefully most of it
10             will be underneath.  I cannot tell you, as
H             Mark stated, that every little parcel  of
12             soil that your child may  come in contact
13             with will be contamination  free.  I  cannot
14             Say that to you.  Mark cannot say that  to
15             you.
16                         MR.  MARUKA:   I  can  say  it.
17            we've been  here  for five  years  and  they eat
18            the  tomatoes and everything else and
              nobody's  gotten  sick.
20                        MR.  BLOCK:   Basically,  sir, I
 21            think  that's what Mark said, that the  risk
 22            is very  low.   Okay?   But the practical part
 23            of it,  you  and your child,  have your
 24            child  play  on  it.  There's no  problem with
 25             it.  Okay.  There is  really no problem with
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                                                          74
  1             it.   And again,  please let  me repeat what
  2             Mark repeated because  you need to
  3             understand,  there  is no immediate or acute
  4             health threat.   The  only time that you may
1  5             get  exposed  to that  type of levels is if
  6             you  go into  those  pools down there.   That's
  7             where the acute  and  the immediate hazard
  8             is.   Dermally,  in  your skin,  inhalation,
  9             that's where.   That's  where the PAHs impact

10             on you.  :Okay.   Overall,  looking at  -- and
11             again,  we are an independent environmental
12             health agency and  although  we utilize
13             EPA's data and consult with them and talk
14             to them, , we  make our own call in ATSDR and
15             that said you don't  have an immediate and
16             acute health threat.   Yes,  there is  a
17             potential long-term  threat,  but let's talk
18             practicality.   The practical issues  are the
19             exposure. The real  issue here is how much
20             are  you exposed?  I  don't know if that

21             helps.
22                     ,    MS.  PONGRAZZI:   If there, as
23             you're saying,  is  no imminent health risk,
24             why  have we  been put on the national
25             priority list?  What is the criteria for

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 1            that?  If there's no human health risk, how


 2            come we are on that?  I mean I'm just


 3            curious.
                    \

 4                        MR.  BLOCK:  Okay.  The one


 5            thing I'll reemphasize what you said is


 6            there's no health risk associated because


 7            of the exposure issue.  All of this stuff


 8            is underneath.  Okay?


 9                        AUDIENCE MEMBER:  Why are we


10            going through this?


11                        MR.  BLOCK:  That's something


12            EPA will have to answer.  I can answer the


13            health part of it.  Okay?


14                        MR.  PRINCE:  The Superfund


15            Program is designed to address uncontrolled


16            releases in the environment.  It's a very


17            broad term, but it essentially means when


18            we don't know how extensive a problem


19            is and we don't know where  it might be


20            popping up.   It was put here, but it's


21            coming up over there.


22                        AUDIENCE MEMBER:  He  just  told


23            you  that nobody's died in 35 years.  How


24            long do you want  somebody to stay here?


25            Seventy years before you're safe?




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             MS.  PONGRAZZI:  Everyone in my



 home prior to me has died of cancer.  I'm



 not saying that  it's this, but it has



 happened anyway.




             MR.  PRINCE:   Fine.  And I'm




 going to continue  answering the question.




 The Superfund Program is  designed to be




 available  when surprises  like  this,  unknown



 things  like  this come up  and this,  you




 know, this appeared  to the State  of  New




 Jersey  and then was  shown to EPA




 essentially  two years ago in 1997.   And in




 those two years we've managed  to  determine



 the  extent to  which  there is any  imminent




 health  threat.  Because we didn't  see one




 in  the  ground  water,  we didn't  see one  in




 the  surface  soils, we  didn't see  a concern




 that required  that sort of  immediate




 response, but  then there  is  a  --  there  is




 an enormous amount of  contaminated stuff




 down there.  Listen.  What EPA's program,



what EPA's proposal here  says, we think it




doesn't belong in a residential community




and we're planning on taking it out.



That's our goal.   Unfortunately, this is
r
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not simple.  It's not simple for us.  It's



not simple for you to understand.  And




we're not going to be able to fully




characterize and answer every question




about it tonight.  But part of the reason




we're here so is that we can get this sort




of feedback to know what you think.  Do you




want us to do this?  Do you want, us to




leave?



            AUDIENCE MEMBER:  Residents are




dying from this -asbestos for 30 years and




nobody did anything.  They just died.




They're dying.  Now you make a federal  case




over creosote and everybody's been  living




on it for 35 years.



            MR. PRINCE:  We could continue




formally responding to questions including




yours.



            MS. PONGRAZZI:  If the  creosote




remains in the ground and there's no health




to residents, what  if say a commercial




development would build on top of here  and




everything was paved over, would that make




the  problem go away or do you have  to




completely remediate the  site either way?
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 1                        MR. PRINCE:  IT. is our -- it is


 2            our belief that no matter what happens,


 3            even if this were to become a commercial


 4            place, that these lagoons and canals would

i
 5            need to come out anyway and that's one of


 6            the reasons why even though we don't have

 7            the answers on all of the other properties


 8            in the 'Claremont Development, we know
 *^                                                     f

 9            what's going to happen here one way or the


10            other.  We're trying to work it, you know,


11            work it out so that it's addressed while


12            you folks can still live there.

13                        MS. PONGRAZZI:  You mentioned


14            that your picking up places of  it in the


15            rivers.  That doesn't directly  affect  our


lg            water  supply because we have our own water

17            department, but Elizabethtown Water, which


18            is probably the biggest water suppliers


19            here,  pulls out of that river.


20                        MR. PRINCE:  Sure.

21                        MS. PONGRAZZI:   Is  it coming


22            into  there?

23                        MR. PRINCE:  Elizabethtown


24            Water Supply,  do  you know  a  specific  answer


•25            to  that  question?



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            MR.  PUVOGEL:  We've tested the




surface water.  The trace amounts we found




are in the bottom of the river in the




sediment.  We've attempted the surface




water.  We don't detect anything in that




surface water.



            MS.  PONGRAZZI:  Okay.



            MR.  PRINCE:  Plus Elizabettown




Water is responsible to do testing and




identify whether they are going to address




that.  They're in the business of doing




that.



            MS.  PONGRAZZI:  Right.  Okay.




Thank you.



            MR.  McGINNIS:   My name is




Ralph McGinnis.   I  live at 127 East



Camplain Road.  I guess everyone knows  on




the  overhead  here,  I'm  in the  -- I'm  on  the




pink in  the lower left-hand corner, so  I



think everyone can  appreciate  that  I'm  here




for  the  real  deal.   I'm not here to play



around.   I'd  just like  to say  a  couple  of



things  to  the audience, just  for your



information.  There is  a  community  group




that we  put together and  Pat  did  say
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earlier about people coming cut to it.  You




know, we get a turn out of maybe five or




ten people,  the latter one maybe had



fifteen.  Yeah, this is a good turn out.  I



know a lot of people are angry, frustrated




and truthfully, the situation sucks, but we




have to do something about it.  It's not




going to go away.  Coming to one meeting




and bitching isn't the way to get it  fixed.




Excuse me, I am speaking.  If you could



just hold your voice or your questions




until I'm done, I would really appreciate



it, sir.  You know, the turn out, there are



notices and again, the ability to talk  with




the EPA and have some ability  to have



direction into what we want to have  done.



She  also brought up the TAG.   The technical




assistance grant that is  something  new  that




we needed to get people involved  in.  You




know,  this  isn't going away folks and if




it's  three years or six years, you  know,




it's  going  to  be what  it's going  to be, but



we need people involved to make  it  the  best




it can be so we  could  get things  done and




the  EPA can  get  their  work done.  And you
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know, just when you see these dates or




times to come out, we'd really appreciate




it and really it's volunteering your time.




You're concerned about your quality of




life.  Well, you got to participate in part




of it as well.  You can't sit back and just




talk amongst your friends.  You got to get




out and talk in these committees.  I mean



we've already spoken about some of these




homes, the ones in the yellow, you know,




does the borough buy them?  Can the public




buy them?  Why not put, you know, you could




make these homes a park.  You know, there's




a lot of options,  but we just have to think




about it.  For myself, I just want to, you




know, I've had almost all these people from



the EPA, and ATSDR,  they've been to my home




one time or another.  These are decent




folks.  They're not our enemy.  I'm not




trying to kiss up to them, but they're here




to help us.  You know, so it's -- they're




not the enemy.



            AUDIENCE MEMBER:  Who is?



            MR. McGINNIS:  I guess as far



as a real recommendation to this plan, I do
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question the plan itself because it was




vague and seme of the remedial action,




whether :you may lift a house, you may not




lift a house, I thought this plan would



have a few more concrete specifications




into how it's going to be remediated.  I




thought it was weak in that regard.  You




know, there's still a lot of things that



are up in the air about that.  I guess the




real recommendation for my plan where my




property is, unfortunately, I'd like to see




that turned to a yellow block.  I don't




want to run away from this, but the




sampling you did on the side of my house  to




say well, you know, that's going to tell  me




if I got creosote under my property, under



-- all right, underneath the house.  You




said it yourself, the canal varies.  My




house is approximately 50 feet wide across




with the canal going through it, it




completely -- you still can't take samples



out outside and tell me what's underneath




my house.  Thank you.



            MS. ZEMANEK:  Counselwoman




Aljeanette Zemanek.  I've had a few
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questions from residences.   They  meet  me




different places iii town.  One  of the  areas




we haven't really talked about  is the  drip




area.  And many of the residents  in  the




community, like myself, are  getting  older




in our lives and putting our life on hold




for five years is a big chunk of  what  we




may have left.  Some of these families




we're talking about, things  that  are




general maintenance of their homes,  they




want new siding,  they want new  windows,




they need new roofs.  Do we  go  ahead?  Do




we spend our money that we've saved  to put




in our property or do we sit  and  wait  for




four years or six years or do we  make  those




improvements, hoping that what  we're going




to get out,  will compensate  what  we're




doing.  I'd like assurances  for those




people that are in those drip areas  if they




want to do something to their homes, should




they move forward with their general




maintenance?  Should they take  care  of




their homes or should they just say  I  have




to wait six years to find out, what's going




to happen?  Secondly, some of those
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families, are people like myself, who at




some point in tine maybe before six years




may want to move out of their homes.  They




may want to go to their dream home in




Florida.  But right now, they can't do




that.  And I think we have to look at that,




if some people had those desires, that they



have to be able to talk to someone and see




if they do have a future, that they can go




and seek a retirement before this is over.




            MR. PRINCE:  We'd like to



respond to individual requests where




possible, individual inquiries about




particular properties.  What I will -- and




there is still outside of the lagoons and




canal area, there is still some question in




EPA's mind, which we plan on bringing back



to the community this summer, the answers




to those questions about whether there




might be other houses that need to be




removed to get this work done.  What I can




say today is that we know where the many




canals are and we know where the lagoons




are and the data to the extent on all the




other lots to the extent that we have been
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                                                         85
 1            able to look at it as sort of a big
 2            picture.  Again, we don't have it all so we
 3            can't do that yet.  It indicates that there
 4            aren't other areas of very deep
 5            contamination like this, in, for example,
 6            under the rest of the community or under
 7            many, many more houses there may be some
 8            more where some deep excavation work needs
 9            to be done.  When that happens, then the
10            issue of a permanent relocation comes up.
11                        MS. ZEMANEK:  So would you say
12            the answer to my question is yes or no,
13            should these people that are in the drip
14            zones that are not pink or are not yellow
15            continue to invest their money that they
16            have saved to do their general maintenance?
17            People are talking about new siding.  Do I
18            go ahead and put new siding on my home?  Do
19            I do those things or do I put my life on
20            hold for five or six. years and then decide?
21                        MR. PRINCE:  The people who
22            live in the drip area should wait to hear
23            our next meeting in July.  We will be
24            meeting with residents individually
25            beforehand before that meeting and then

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a broad presentation for all of those



residents.  So I'm actually recommending




that they await those improvements.



            MS. ZEMANEK:  I know at least




for two months I know there were families




that were talking about selling and



retirement.  Right now you can't sell your




home there.  Your home is not going to sell




if you want to move and go somewhere else.




Basically even if you want to move out of




your home and rent it,  I don't know how



easy that would be either and I think it's




like many of us, and just looking around




the room, when we start putting our life on




hold for four, six, hopefully only six



years, that may be a long time to some of




us.



            MR. PRINCE:  Thank you.




            MS. SEPPI:   Just one second.




Those are some really good points that you



brought up and I appreciate those comments,




you know, and I agree with John.  Hold off




until our next meeting in July.



            AUDIENCE MEMBER:  When?
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            MS. SEPPI:  We  don't  know  yet,




but some time in July, probably around the




middle of July.  At that  time  this  map that




you see up here now will  be  revised.   Maybe




there will be some additional  yellow homes




on it based on what we find  out from this




next round of data that we're  expecting.




Maybe they'll be some additional  yellow




houses, but at that point if you  know  that




your house is not going to be  directly




impacted by this, then I  would say, you




know,  you go ahead and do what you  want to




do.  So if you could, just give us a couple




more months,  then you could  go on and  make




any improvements that you want to make,  as




long as,  again,  your house isn't  directly



impacted.




            AUDIENCE MEMBER:   In  answer to




that gentleman's question, you've disrupted




my life for two years and you  are the



enemy.   You are the suit  that's in  front of




me and I have to holler at you.   If he




doesn't think that he's the  enemy,  well,




that's his business if he wants to  play



with me.   And as far as this other  stuff
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  e^, we've been putting weed  killer  down,

mowing  lawns and everything else  for  30

years and you can't tell me I  shouldn't

waste another fifty bucks trying  to kill

Dandelions because I have to wait until

July.   By July the whole lawn  will be burnt

up .

            MR. PUVOGEL:  It's Debbie

Sangiovonni, 16 Florence Court.   This
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happens to be the second EPA fund that's

affected my life.  This happens to be the

second  EPA fund that has affected my life.

My husband was a maintenance foreman on the

South Plainfield Industrial Park.  So since

that had been such a big EPA problem, and

was also put on the Superfund list.

            MS.  SEPPI:   Yes.

            MS.  SANGIOVONNI:  Maybe to give

some of these residents piece of mind, I

know my husband had gotten blood sampling

to see if he had any cancer-causing agents.

            MS.  SEPPI:   Those are PCBs.

            MS.  SANGIOVONNI:  Possibly some

of these residents  would like to do that

and give them a  little  piece of mind.   One
88

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                                                          89
 1            thing I want to do that once you  go  in  and

 2            clear all of the soil and everything, is

 3            there going to be any recording done  on the

 4            deed that we do have clean deeds?  I  mean

 5            is anything going to be done, any  recording

 6            on the deeds?

 7                        MR. PRINCE:  When the  work  is

 8            completed?

 9                        MR. SANGIOVONNI:  Yes.

10                        MR. PRINCE:  The intent  of  the

11            clean up work on properties where  we're

12            doing a demolition and an entire  clean  up

13            or on a property where we're only  having to

14            work around the house, the intent  is  to

15            clean up to a residential living  standard.

16            So a degree to where EPA which is  very

17            conservative in its assumptions of risk,

18            where EPA says that unrestricted use  by

19            the homeowner of that lot.

20                        MS. SANGIOVONNI:  But  that

21            doesn't tell me you have cleaned  it.

22                        MR. PRINCE:  And we will  write

23            you documentation to that effect.  They'll

24            be done that level of clean up.

25                        MS. SANGIOVONNI:  Do you  think


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there's going to be any future liability




for the homeowner if they do come  in and



they clean up and if they sell their house




in ten years, is there going to be any




liability to the homeowner?




           r MR. PRINCE:  In a similar




experiences at other properties where




residential properties have been cleaned




up, EPA has stayed involved with the




communities and with the residents so that




when they're interested in selling, if they




can't find the documentation that  said




we're finished, we've done everything, we




don't need to come back, that,  you know,




we'll have -- we'll keep that so that




either when you want to sell your house in



five years or in ten years, you'll be able




to provide the respective purchasers of




your house, the people come to look at it,




an answer that says oh, this is not a




problem.



            MS. SANGIOVONNI:  This is being




funded by the government?



            MR. PRINCE:  State and federal




government.
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            MS. SANGIOVONNI:  What  if  the




government comes in everything  that  comes




in outside of Manville and  says  they pull




the finding, where does that  leave  all  of




us?  Can the funding be pulled  from  our




Site?  Can the government come  in and  say,




"We are pulling it because  of what's going




in on Yugoslavia" or we go  to war or




whatever else is going on?




            MR. PRINCE:  The  EPA is  part of




the federal government.  Obviously,  we  go




to Congress every year with funding




requests, that state we have  this much




clean up work to do on this site, this




site,  this site.  This is what we're going




to do and Congress does have  the power  of



the purse.  That is their role and we need




to make a presentation.  Since I don't  know




if you remember the budget showdown  in  '95




between the administration and Congress,




there was a time during that period  when



funding for clean up work was not




available.  Since then there has not been




any problems where EPA has not been  able to




move ahead because of lack of funding,
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            MS. SANGIOVONNI:  But that




could be a possibility that we could get




into a year and half work, then all of a




sudden,  it's going to stop?




            MR. PRINCE:  It's part of the




regular budget process.



            MS. SANGIOVONNI:  Okay.  Thank




you.



            MR. PUVOGEL:  Any other




questions or comments?



            MS. MANDERSKI:  Which lagoon




will you clean up first, A or B?




            MR. PUVOGEL:  That we




don't know yet.  Once we start design,




we'll involve  the community in those




decisions and  how we're going to approach




it.



            MR. NCVICKY:  Nick Novicky, 29




Valerie.  I know I'm  in the middle  of more




or  less what's going  to go  on.   One




question I think would be perhaps  up  to all




the  residents  to think about, you  said  that




crew would work like  nine to  five  or




whatever weekdays.   I mean  if this  is a
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                                                          93
  1             priority,  I think wouldn't seven dates a
  2             week be necessary to get this stuff cleaned
  3             up?
  4                         MR.  PUVOGEL:  Yeah.
  5                         MR.  NOVICKY:  I know it's
  6             overtime.   I'm saying the residents would
  7             perhaps to  take  a vote on,  do they want
  8             their  weekends disrupted?  We're going to
  9             be disrupted anyway from what I  see.   Where
10             I am the homes to the right of me and then
11             behind  me,  I imagine Valerie would be a
12             pretty  messy street,  too.
13                         MR.  PUVOGEL:   That's one  of
14             the  items --
15                        .MR.  NOVICKY:   Who's  going to
16             make the decision to how long these crews
17             work or, you know,  what  hours.   When  they
18             have to fix  the  road,  they're 24 hours.   I
19             mean they have to get  something  done  real
20             quick and this is  a  serious situation.
21             It's not something,  you  know what  I mean,
22             you  are going  to  piddle  around with and
23-             work Monday  through  Friday  and the  weekends
24             is whatever.
25                         MR.  PUVOGEL:  Right.  That's
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the halance that we need  to  strike,  how




much inconvenience or burden  to  the




homeowners, and faster  clean  up  versus a




longer clean up is less intrusive, that's




a balance we'll strike  as we  go  through




design and include the  community in  this




process.




            MR. NOVICKY:  Okay.   Thank you.




            MS. SEPPI:  I think  you're




a great candidate for our advisory group.




            MR. NOVICKY:  I'm not retired.




            MS. SEPPI:  Then  you have more




time.  That's perfect.




            AUDIENCE MEMBER:  He's not




retired.




            MR. PUVOGEL:  Does anybody else




have any questions or comments?   Then the




other part of this public comment period




includes written comments and the proposed




plan that you folks have.   My name and




address is at the back of that proposed




plan.  You could send your written comments




to me.   They'll be responded  to  and  this




Record of Decision we've been talking about




will be written up about a month  and a
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                                                          95
 1             half  documents  our  decision process and

 2             their input  into  that  process.   Thanks for

 3             coming out tonight  and if  you have any

 4             questions, see  us.

 5                         (Whereupon,  the hearing is

 6             concluded at  8:55 p.m.)

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                                                         96

 1

 2                   CERTIFICATE

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         I, DARLENE K. LEITHAUSER, a Certified

Shorthand Reporter and Notary Public of the State

of New Jersey, certify that the foregoing is a

true and accurate transcript of the stenographic

notes of the hearing on the date and place

hereinbefore set forth.

         I FURTHER CERTIFY that I am neither

attorney nor counsel for, nor related to or

employed by, any of the parties to the action in

which this hearing was taken, and further that  I

am not a relative or employee of any attorney or

counsel employed in this action, nor am  I

financially interested in this case.
                           DARLENE  M.  J/EITHAUSER,C.S.R
                           LICENSE  NO.  XIC1002
                 SCHULMAN,  CICCARELLI  & WIEGMANN

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   APPENDIX D





WRITTEN COMMENTS

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BOROUGH OF MANVILLE
325 NORTH MAIN STREET, MANVILLE, NJ • PHONE: 908-725-9478
                                     FAX:    908-231-8620
 Mr. Richard Caspe
^Director, Emergency and Remedial Response Division
 United States Environmental Protection Agency- Region n                   >•
 290 Broadway                                     -
 New York NY 10007-1866

 RE:    Federal CreosotmgNPL Site, Manville, New Jersey

 Dear Mr. Caspe:

 This correspondence is regarding the Federal Crepsoting Site located in Manville, New Jersey.
 On Tuesday, February 10,1999, at the Borough's municipal building, representatives of the
 USEPA and the Agency for Toxic Substance and Disease Registry ("ATSDR") presented
 information on the status of the site activities to the Claremont Community Advisory Group and
 Borough representatives. At the meeting, questions were raised to USEPA representatives Dr.
 James Hackler and new Project Manager Richard Pavogel regarding the timing of future cleanup
 activities in the Claremont development Specifically, we were told that cleanup activities would
 start at the canal and lagoon areas in two years. As I verbalized at the meeting, this timing is not
 acceptable to me or the citizens of the Claremont development

 Dr. Hackler explained at the meeting that the startup of cleanup activities would take at least two
 years to initiate due to i) Hie need for careful planning to- mimim-?*! disruptions to the rest of the
 neighborhood resulting from odors, dust and noise from excavating the canals  and lagoons, ii)
 the need for the cleanup design to tie into and be consistent with the remediation of the rest of the
 site; and iif) the problems posed by active freight rail lines directly adjacent to the lagoons.

 After the meeting, Dr. Hackler noted that ah additional reason for the delay in performing
 cleanup activities at the .site was the allocation and availability of financial resources. According
 to USEPA representatives, future site remediation will be addressed as a "Remedial** activity
rather than as a "Removal" activity. As I understand h, this means that further site work must
 await piioritization among other sites. It Is also my understanding that Federal  regulations
prohibit the USEPA from terminating a Removal action if mere are  imminent risks posed by the
site to drinking water or other receptors. Based on the USEPA's own data, I believe the site
remains an imminent risk to drinking water and groundwater, and therefore the  USEPA should
continue remediation of the site under the Removal program and initiate immediate cleanup
actions at the lagoon and canal areas. My rationale is presented below.

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    Mr. Richard Caspe                          .

    Page 2

    1.     The Removal Action Is Not Yet Complete
          According to the Comprehensiye Environmental Response, Compensation and Liability
          Act ("CERCLA," 40 CFR 300.410), a removal site evaluation "shall be terminated when
          the OSC or lead agency determines (1) there is no release; (2) the source is neither a
          vessel nor.a facility as defined in §300.5 [State-lead remediation]; (3) thejelease involves
          neither a hazardous substance, nor a pollutant or contaminant that may present an
       •   imminent and substantial danger to public health or -welfare." The USEPA uses eight
          factors to determine the appropriateness of a removal action and whether or not there is a
         "threat to public health or welfare or the environment" (40 CFR 300,415(a)(2)):

    0     Actualor potential exposure to nearby human populations, animals, or tkefood chain
       •  from hazardous substances or pollutants or contaminants
          The ATSDR opined at our February 10,1999 meeting that there is no. "health risk" by the
          levels of contaminants found in surficial soils (0"-6" interval only) at portions of the
          Claremont development -However, considerable creosote contamination and sludges
          'were found in the lagoon and canal areas during the initial site investigation activities.
          Further information on subsurface soils and the actual extent of contamination from the
          lagoons and canals is only now being collected, and will not be ready for dissemination
          for many months. Because exposure to humans, animals, and the food chain may occur
          through routes from subsurface as well as surficial soils, the concerns posed by the
          lagoons and canals remain unknown and unquantified. Therefore, mis first criterion
          cannot be negated at this time.                                    .
*                        " * *                      *  - * •                  •
    (u)   Actual or potential contamination of drinking water supplies or sensitive ecosystems
         ' The USEPA conducted pumping tests and collected samples from Manville's drinking
          water wells, which are located just north of the site, to assess the possibility of a
          "connection" between the wellfield and the former creosote site. While the results of lie
          pumping tests are still underreview, USEPA's representatives found that Manvffle's
       .  wellfield may be in direct hydraulic connection with the lagoons and canals at the Federal
          Creosotihg site.                             -                   .

          Manvffle's bedrock wells are "open hole" and intercept the same aquifer system that was
          previously shown to be contaminated by the former creosote site. One of the active wells
          (C-2A) contained bis(2-ethylhexyl)phthalafc at 0.190 mg/1, above the State of New
          Jersey's Class HA Groundwater Quality Standard of 0.030 mg/I. There is no drinking
          water standard for this substance, although the USEPA Region ffl1 gives 0.0048 mg/1 as a
           'USEPA Region III Risk-based Concentrations: RJU Smith, (1/31/95).

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 Mr. Richard Caspe

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       maximum risk-based value for tap water. The source of the substance, a potentially
       carcinogenic industrial solvent, is currently unknown, and the possibility of a connection
       to the former creosote site can not be ruled out.
       *
       Manville's inactive test well T-l was also sampled by the USEPA during the pumping
       test. Benzene, ethylbenzene, and naphthalene were detected at 0.0007,0.0008, and
       0.0023 mg/1 respectively, below the Federal and State Maximum Contaminant Levels
       ("MCLs") for drinking water of 0.001,0.7 and 0.03 mg/1, respectively. Other „
       semivolatile organic compounds were also detected, including acenaphthene (0.017
       mg/1), fluorene (0.0054 mg/1),  and carbazole (0.011 mg/1).  Various tentatively identified
       compounds ("TICs") were also found in T-l, including benzothiophene and a
       benzothiophene isomer.  The semivolatile compounds listed above do not have any
       Federal or State drinking water standards. While these compounds were detected only at
       very low levels, they are associated with coal tar, from which creosote is derived. These
       compounds could be associated with the Federal Creosoting site, but it is not possible to
       be more certain based on this data alone.

       It should be noted that it is not typical for semivolatile organic compounds to travel large
       distances to a production well unless the aquifer is fractured and there is a nearby source
       of a coal tar derivative, such as creosote. Both conditions are applicable to the Claremont
       development. Free product creosote is documented to remain in the lagoons and canals,
       and is a reasonable candidate to be the source of contamination to T-I  and possibly C-2A.

       Because one of Manville's active potable supply wells and one inactive supply well
       contain contaminants that may be associated with the Federal Creosoting site, the
       USEPA's criterion regarding contamination of drinking water supplies cannot be negated.

(iii)    Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other
       bulk storage containers that may pose a threat of release
       The canals and lagoons contain free product creosote. The intent of the "drum, barrel,
       tank or other bulk storage container" criterion is to emphasize mat containerized liquids
       may be an ongoing contaminant source. Free product creosote, in underground lagoons,
       not only poses a threat of further release, but is a release which deserves at least as much,
       if not more, attention than a containerized source would receive.

(iv)    High levels of hazardous substances or pollutants or contaminants in soils largely at or
       near the surface that may migrate
       High levels of creosote (a hazardous substance, pollutant, and contaminant) have been
       found in soils near the surface and below the ground-water table.  Creosote remains in free

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Mr. Richard Caspe

Page 4

       product form, and the various contaminant'components have both migrated and show the
       continued potential to migrate. Therefore, mis criterion is easily satisfied.

(v)    Weather conditions that may cause hazardous substances or pollutants or
       contaminants to migrate or be released                             »
       Precipitation recharges the groundwater table in the lagoon and canal areas, and
       represents a continuing and ongoing threat to mobilize hazardous substances and
       pollutants and allow continued migration. Creosote has already been found by the
       USEPA's contractor in the bedrock over 100 feet below the ground surface. This
       criterion is also satisfied.

       Threat of fire or explosion
       The USEPA has identified no threat of a fire or explosion at this site.

(yii)   The availability of other appropriate federal or state response mechanisms to respond
       to the release
       If other Federal or State response mechanisms were available to respond to the Federal
       Creosoting lagoons and canals, the site would not now be on the NPL, nor be considered
       for further actions by the USEPA.  This criterion is satisfied.

(vili)   Other situations or factors that may pose threats to public health or welfare or the
       environment
       The USEPA and/or ATSDR have opined that neither air nor surficial soil are currently a
       threat to public health or welfare. However, tne site remains uncontrolled, and this factor
       alone satisfies mis criterion.

In conclusion, for the USEPA to terminate a Removal site evaluation, there must no longer be an.
imminent and substantial danger to public health' or welfare.  Seven of the eight criteria used by
the USEPA to verify, such danger, listed as items (i) through (vifi) above, are satisfied, thus:

• •    the USEPA's Removal action for the Federal Creosoting Site is not complete and may
       not be terminated pursuant to Federal regulations; and

•      cleanup of the lagoon and canal areas should be performed under the Removal program.

2.     The Removal Action May Be Continued
       Federal regulations (40 CFR 300.415(b)(5)) require that Removal actions be terminated
       (i) after $2 million has been obligated for the action or 12 months have elapsed from the
       date that removal activities begin on-she, unless the lead agency determines that there is

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  Mr. Richard Caspe

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        an immediate risk to public health or -welfare or the environment; continued response
        actions are immediately required to prevent, limit, or mitigate an emergency; and such
        assistance will not otherwise be provided on a timely basis; or (u) continued response
        action is othenvise appropriate and consistent with the remedial action to be taken. These
        criteria are discussed below.                                        5

 (0     There is an immediate risk to public health or welfare or the environment; continued
        response actions are immediately required to prevent, limit, or mitigate an emergency;
        ana'such assistance vnU not otherwise be provided on a timely basis
        As demonstrated under item 1 above, the site poses an immediate risk to the public health
        or -welfare or the environment  Should the ongoing migration of contaminants from the
        lagoon and canal areas continue -without limitation or mitigation, these areas wHI remain
        a threat to the Borough's welifield and to groundwaters of the State. Hie Borough of
        Manville would certainly argue that contamination  of its water supplies constitutes an
        emergency. Without the immediate allocation of resources by USEP A, such assistance is
  .      unavailable from others on a timely basis.                  .     .

 (H)     Continued response action is etherise appropriaU and consistent ivith the remeaM
        action to be taken               .       .             .       , '  •
      '  Continued response actions are entirely appropriate as discussed above. It would be up to
        the USEPA to ensure that the most appropriate removal action is taken regarding the
        canals and lagoons, and this action would need to be made consistent with the remedial
       actions wMch will be taken regarding the rest of tbe site.
         ..''-..      •   ' •           x
 In conclusion, Federal regulations allow the Removal action to be continued to address me
 lagoons and canals in a timely manner.    .'•...'

 3.     The Removal Program is Designed For die Site Conditions at the Federal
       CreosotingSfte
       Federal regulations (40 CFR 300.415(d)) include removal actions that are, "as a general
       rule, appropriate., .however, the list is not exhaustive and is not intended to prevent the
       lead agency from taking any other actions deemed necessary .under CERCLA or other "
       appropriate federal orstate enforwanentcrre^onse authorities...'' Among these listed
       actions are the following, which are directly applicable to the current Federal Creosoting
       site conditions:

•      Stabilization of berms,  dikes, or impoundments or drainage or closing of lagoons-where-
       needed to maintain the integrity of the structures (§300.415(4)3);

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 Mr. Richard Caspe

 Page 6

• •     Capping of contaminated soils or sludges-where needed to reduce migration of hazardous
       substances or pollutants or contaminants into soft, ground or surface water; or air
       (§300.415(d)4);

 •     Excavation, consolidation, or removal of highly contaminated soils from .drainage or
       other areas-where such actions will reduce the spread of, or direct contact with, the
       contamination (§300.415(d)6);

 •     Removal of .drums, barrels, tanks, or other bulk containers that contain or may contain
       .hazardous substances or pollutants or contaminants-where it will reduce the likelihood of
      . spillage; leakage; exposure to humans, animals, or food chain; or fire or explosion
       (§300.415(d)7); and

 •     Containment, treatment, disposal, or incineration of hazardous materialsVwhere needed to
       reduce the likelihood of human, animal or food chain exposure (§300.415(d)8). .

All of the above categories, especially item §300.415(3)6, the excavation of contaminated
materials from drainage areas, apply directly to the canals and lagoons at the Federal Creosoting
Site.         . :

Conclusion                  •
The results of the site investigation performed to date and the USEPA pumping tests at the
Manville Borough wells indicate a clear and compelling reason for USEPA to quicldy proceed
with the cleanup of the lagoon and.canal areas, preferably by complete off-site removal. We
believe that the USEPA has the jurisdiction, authority,  and ability under CERCLA to either i)
perform the lagoon and ranal area cleanup as a Removal Action; or ii) immediately allocate
funds under either the Removal or Remedial programs  to start cleanup of the lagoon and canal
areas.          ,           .                     '•'•..          •   •  •

I am always available to discuss these matters further.  I look forward to hearing from you.

                                                     Very truly yours,
                                                     Angelo jCorradino, Mayor
cc:.   Hon. Robert Franks                                  •

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                                    May 13, 1999
 U.S. Environmental Protection Agency
 Mr. Rich Puvogel
 290 Broadway, 19th Floor
 New York, NY  10007-1866

 Dear Rich,

 This letter is in response to the Superfund Proposed Plan for the Federal
 Creosote Site in Manville, NJ. As homeowners on the buyout list, I would
 like to have the Right of First Refusal.

 I propose that after the clean-up is completed, my property should be offered
 to me first for purchase.  I did not intend to move, yet it was necessary.  My
 property is where I had intended to continue living. Therefore, I would like
 to have the first option to purchase my property without bidding against
 developers. I would like pay a fair price, below market value. The Borough
 of Manville will still gain income, and I will not have additional hardship.
After all, I will be living in a different location, with all new expenses.  This
has been a drastic imposition on my family and I would like to see that my
proposal is considered. It shows good community conscience and
compassion.

                                  Sincerely,

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Robert & Mary Strain
271 East Complain Road
Manv&e, New Jersey 08835
(908)725-7044
                                                   June 23, 1999
         Rich Puvogel
         Remedial Project Manager
         US Environmental Protection Agency
         290 Broadway - 19th Floor
         New York, NY 10007

         Re:    Proposed rfcai^iyp Federal Creosote Superfund Site
               Town of Manvffle, Somerset County, New Jersey

         Dear Mr. Puvogel:

         We are writing to express our concerns regarding the proposed plan referring to die above.
         In light of the alternatives suggestions, we have the following concerns:

               The safety for ourselves, neighbors, family, and friends.
               According to the plan, it will take years before the site is absolved of the creosote,
               cleanup, construction, etc.
               Our level of confidence is not high regarding the safety of living in the development
               while construction is being done (equipment, flow of traffic, security, etc.).
               The odor of creosote will be unbearable.
               Construction will be easier for all parties concerned if all homes were bought.  All
               the homes should be demolished, the area cleaned up, and the borough can do
               what they want with the land (new homes, stores, parks, etc.). In the long run, this
               will also save time and money.
               We are forced to live in a development/home which we do not feel secure. We
               cannot sell our homes for  fair market value.
               Since the problem of creosote arose a few years ago, we still cannot get a dear
               answer to any questions (health risks, timeframe for cleanup, extent of damage,
               cleanup plan, etc.).

         In dosing, we believe the best recommendation for the quality of lives of all concerned,
         all homes should be bought out giving the residents a chance to relocate and live in a safe
         environment.
                                                   Mary A. Strain

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                                      May 13, 1999
   U.S. Environmental Protection Agency
   Mr. Rich Puvogel
   290 Broadway, 19th Floor
   New York, NY 10007-1866

   Dear Rich,

   This letter is in response to the Superfund Proposed Plan for the Federal
   Creosote Site in Manville, NJ. As a homeowner on the potential buyout list,
   I would like to have the Right of First Refusal.

   In the event of a buyout, I propose that after the clean-up is completed, my
   property should be offered to me first for purchase. My property is where I
   had intended to continue living without any health risks. Therefore, I would
   like to have the first option to purchase my property without bidding against
   developers. I would like pay a fair price, below market value. The Borough
   of Manville will still gain income, and I will not have additional hardship.
   After all, I will be living in a different location, with all new expenses. This
   has been a drastic imposition on my family and I would like to see that my
   proposal is considered. It shows good community conscience and
   compassion.

   Second, I would like to be on record in favor of a buyout of my property.  I
   do not look forward to the inconvenience of busing my children to school
   from a temporary location. I would not like to move twice. This would put
   my life on "hold" even longer. I also fear for the health safety of my family
   if we will continue living in this community during any phase of clean-up
   and just following clean-up.  The superfund process has taken a mental toll
   on my family, including my children.  Please let it end.

                                     Sincerely,
& ~ Co.

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Comments on the April 1999
 Superfund Proposed Plan
   Federal Creosote Site
   Manville, New Jersey
        1 June 1999

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Table of Contents
      Comments on the Superfund Proposed Plan

         - Superfund Process Comments
         - Risk Characterization Comments
         - Proposed Remedy Comments
         - Alternative Remedy Comments
         - Table 1: Summary of Potential Costs and Risks for Alternate
                 Remedial Options

      Attachment 1 - Documents to Suport Procedural Comments on
         Proposed Remedy

      Attachment 2 - Selected ROD Summaries Reflecting Alternate
         Remedial Technologies

      Attachment 3 - Documents to Support the Evaluation of the
         Proposed Remedy and Alternate Remedies

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TABLE OF CONTENTS
            Attachment 1
            1.  USEPA National Remedy Review Board. Progress Report Fiscal Year
               1997. USEPA Office of Emergency and Remedial Response (5204G).
               EPA 540-R-032, OSWER 9220.0-26, PB98-963250, February 1998.

            2.  USEPA Memorandum December 18,1997. Review of Non-Time
               Critical Removal Actions by the National Remedy Review Board.

            3.  USEPA Presumptive Remedies:Technology Selection Guide for Wood
               Treater Sites. Office of Solid Waste and Emergency Response.
               Publication 9360.0-46FS.  EP540-F-93-020, April 1993.

            4.  USEPA Presumptive Remedies: Policy and Procedures. Office of Solid
               Waste and Emergency Response. Directive:  9355.0-47FS.  EPA 540-F-
               93-047.  PB93-963345, September 1993.

            4.  USEPA Introduction to: Superfund Accelerated Cleanup Model
               Updated February 1998.  Office of Solid Waste and Emergency
               Response. EPA540-R-98-025, OSWER9205.5-15A.  PB98-963 223, June
               1998.

            6.  USEPA The Role of Cost in the Superfund Remedy Selection Process.
               Office of Solid Waste and Emergency Response. Publication 9200.3-
               23FS. EPA 540/F-96/018. PB96-963245, September 1996.

            7.  USEPA Technology Innovation Office. Workshop on
               Phytoremediation of Organic Contaminants.  Ramada Plaza Hotel,
               Fort Worth, Texas. December 18-19,1996.

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TABLE OF CONTENTS
            Attachment 2
            1.  USEPA Record of Decision for the Utah Power & Light/American
               Barrel Site, Utah, July 7,1993.

            2.  USEPA Record of Decision for the South Cavalcade Street Site,
               Houston, Texas, September 26,1988.

            3.  USEPA Record of Decision for the Cabot Carbon/Koppers Site,
               Florida, September 27,1990.

            4.  USEPA Record of Decision for the L.A. Clarke and Son, Inc. Site,
               Spotsylvania County, Virginia, March 31,1988.

            5.  USEPA Record of Decision for the Cape Fear Wood Preserving Site,
               Fayetteville, North Carolina, June 30,1989.

            6.  USEPA Record of Decision for the American Creosote Works, Inc. Site,
               Florida, September 28,1989.

            7.  USEPA Record of Decision for the Burlington Northern (Somers Tie
               Plant), Flathead County, Montana, September 27,1989.

            8.  USEPA Record of Decision for the Koppers Wood Treating Facility,
               Galesburg, Illinois, June 30,1989.

            9.  USEPA Record of Decision for the Moss-American/Ken>Mcgee Oil
               Co., Wisconsin, September 27,1990.

            10. USEPA Record of Decision for the Popile, Inc. Site, AR, February 1,
               1993.

            11. USEPA Record of Decision for the American Creosote Works,
               Winnfield, Louisiana, April 28,1993.

            12. USEPA Record of Decision for the North Cavalcade Street Site,
               Houston, Texas, June 28,1988.
                                            u

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TABLE OF CONTENTS
            Attachment 3
            1.  A Guide to Principal Threat and Low Level Threat Wastes, US
               Environmental Protection Agency, Office of Solid Waste and
               Emergency Response, Superfund Publication: 9380.3-06FS, November
               1991.

            2.  Innovative Treatment Technologies: Annual Status Report US
               Environmental Protection Agency, Office of Solid Waste and
               Emergency Response, EPA 542-R-94-005, September 1994.

            3.  Environmental Remediation Cost Data - Unit Price, R.S. Means
               Company Inc., and Delta Technologies Group, Inc., 1998. Cost Item 33
               19 9520, page 8-186.

            4.  A Summary of Remedial Options for Gas Holders at Former
               Manufactured Gas Plant Sites. Atlantic Environmental Services, Inc,
               February, 1995.

            5.  Demonstration of a Trial Excavation at the McColl Superfund Site -
               Applications Analysis Report, US Environmental Protection Agency,
               Office of Research and Development, EPA/540/AR-92/015, October
               1992.

            6.  MGP Remediation Using Thermal Desorption: Emerging Technology
               Yields A Permanent Solution, Daniel E. Umfleet, Susan Anderson
               Bachman.

            7.  Take it to the Mart, Chip D'Angelo, and Anthony Chiesa, "Soil and
               Groundwater Cleanup", June 1998.

            8.  Transportable Incinerator Economically Treats Creosote-Contaminated
               Soil

            9.  Asphalt - Batching, of Creosote Wastes

            10.  Pilot-Scale Demonstration of a Slurry-Phase Biological Reactor for
               Creosote-Contaminanted Soil  - Applications Analysis Report, US
               Environmental Protection Agency, Office of Research and
               Development EPA/540/A5-91/009, January 1993.
                                           111

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 11. Landfarming bioremediation is viable solution at Lake Erie MGP,
    Brian P. Herner, Steven M. Goldberg, and Owen P. Ward, "Soil and
    Groundwater Cleanup", June 1998.

 12. BetzDearborn Bioremediation Technologies, Daramend™, Remedial
    Technologies Network, Copyright 1999.

 13. SteamTech, Inc. and Integrated Water Technologies, Inc., In Situ
    Hydrous Pyrolysis/Oxidation (HPO), Remedial Technologies
    Network, Copyright 1999.

 14. In Situ Hydrothermal Oxidative Destruction of DNAPLS in a Creosote
    Contaminated Site, Roald N. Leif, Marina Chiarappa, Roger D, Aines,
    Robin L. Newmark, Kevin G. Knauss, and Craig Eaker, Visalia,
    California, Edison Pole Yard Site.

 15. Cleaning Soil with Steam Injection,, "Environmental Technology",
    September/October 1997.

 16. Western Research Institute, Contained  Recovery of Oily Wastes
    (CROW™), Remedial Technologies Network, Copyright 1999.

 17. In Situ Thermal Desorption, "Environmental Protection", Jude R.
    Rolfes, February 1998.

 18. Destroying PCBs in Soil at a Dragstrip-In Situ, "Environmental
   Technology", Mike Attaway, September/October 1997.

 19. BioTrol Soil Washing System for Treatment of a Wood Preserving Site-
   Applications Analysis Report US Environmental Protection Agency,
   Office of Research and Development, EPA/540/A5-91/003, February
   1992.

 20. Phytoremediatipn can be Designed for MGP Site Contaminants,
   George E. Boyajian and Richard B. Sumner, "Soil and Groundwater
   Cleanup", June 1998.

21. Carbon Consultants, HCZyme, Remedial Technologies Network,
   Copyright 1999.

22. National Oil and Hazardous Substance Pollution Contingency Plan, 40
   CFR Part 300, section 300.5 (Definitions), March 8,1990 (revised
   September 14,1994).

23. National Oil and Hazardous Substance Pollution Contingency Plan, 40
   CFR Part 300, section 300.5 (Definitions), March 8,1990.
                                iv

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 24. Memorandum on the Formation of National Superfund Remedy
    Review Board, from Assistant Administrator Elliott P. Laws to
    Regional Waste Management Division Directors, November 28,1995.

 25. Memorandum on the Review of Non-Time-Critical Removal Actions
    by the National Remedy Review Board, from Stephen D. Luftig,
    Director of OEER to Regional Waste Management Division Directors,
    December 18,1997.

 26. Presumptive Remedies for Soils, Sediments, and Sludges at Wood
    Treater Sites, US Environmental Protection Agency, Office of Solid
    Waste and Emergency Response, Directive 9200.5-5-162, EPA/540/R-
    95/128, (page 2) December 1995.

 27. Presumptive Remedies: Policy and Procedures, US Environmental
    Protection Agency, Office of Solid Waste and Emergency Response,
    Directive 9360.0-46FS, EPA 540-F-93-047, September 1993.

 28. Presumptive Remedies: Technology Selection Guide for Wood Treater
   Sites, US Environmental Protection Agency, Office of Solid Waste and
   Emergency Response, Publication 9360.0-46FS, EPA 540-F-93-020,
   April 1993.

 29. The Role of Cost in the Superfund Remedy Selection Process, US
   Environmental Protection Agency, Office of Solid Waste and
   Emergency Response, Publication 9200.3-23FS, EPA 540/F-96/018,
   (page 6) September 1996.

30. Federal Register. Volume 55 No. 46, page 8750, March 8,1990.

31. Engineering Issue: Data Gaps in Remedial Design. Movlan, JE, US
   Environmental Protection agency, US Army Corps of Engineers, July
   1991.

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THEODORE L. GARRETT
    DIRECT DIAL NUMBER
     (2021062-5308
    tgarrenOcov.com
COVINGTON  &  BURLING
  12OI PENNSYLVANIA AVENUE, N. YV.
          P.O. BOX 7566
   WASHINGTON. D.C. 2OO44-7566
         f2O2) 662-6000
        FACSIMILE: I2O2I 662-6291

             June 1,1999
    LECONFIELD HOUSE
    CURZON STREET
    LONDON WIT BAS
      ENGLAND
 TELEPHONE *4-I7l-*O3-Se56
 FACSIMILE *4-l7l-
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      COMMENTS ON THE SUPERFUND PROPOSED PLAN
                     FEDERAL CREOSOTE SITE
                      MANVILLE, NEW JERSEY

This document summarizes comments on the Proposed Plan for the Federal
Creosote Site ("Site") in Manville, New Jersey. The Proposed Plan, dated April
1999, was issued by the US Environmental Protection Agency ("EPA") and
identified a preferred remedial alternative for the source areas of the Site. EPA
maintains that the preferred remedial alternative will be protective of human
health and the environment comply with Applicable, or Relevant and
Appropriate Requirements (" ARARs") and will reduce the toxiciry, mobility and
volume of contaminants to the maximum extent practicable. EPA further
maintains that the preferred remedial alternative will also meet the statutory
preference for using a remedy that involves treatment as a principal element
The preferred remedial alternative identified in the Proposed Plan is estimated to
cost $58,000,000.

The comments in this document raise serious questions regarding:  1) the process
by which EPA came to select the preferred alternative; 2) how the risk
characterization skewed the magnitude of the response and failed to
proportionately consider the risks associated with implementation of the
preferred remedial alternative; 3) uncertainties in the engineering evaluation that
will undoubtedly result in the cost for the preferred remedial alternative
exceeding the $58,000,000; 4) the biased selection of excavation and off-site
treatment/disposal as general response actions in developing the remedial
alternatives that were considered; and, 5) the elimination of other remedial
alternatives that could accomplish the same objectives at a significantly lower
cost
Superfund Process Comments

1.  The scope of the EPA's preferred alternative is not compatible ivith the
   definition of Operable Unit provided in the National Oil and Hazardous
   Substances Pollution Contingency Plan (NCP).

The Proposed Plan indicates that the cleanup strategy for the Site is the first
phase, or Operable Unit and is considered to be an early action that only
addresses cleanup of the highly contaminated source areas. The NCP defines

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  operable unit as a discrete action that comprises an incremental step toward
  comprehensively addressing site problems.1

  The highly contaminated soils and sludges identified in canals A and B and
  lagoons A and B can reasonably be identified as source materials whose location
  satisfies the NCP definition of an operable unit However, the $58,000,000
  estimate for the EPA's preferred alternative is not consistent with an action that
  is supposed to be a "discrete portion of the remedial response". For example, the
  average Superfund cleanup construction project cost is now $ 10,000,000.4 The
  current average reflects a decrease of $1.2 to $1.6 million per project over the last
  two years. Moreover, the Superfund Program was able to affect these savings
  while maintaining protective cleanups that continue to achieve the mandate for
  "permanence" and treatment of waste. The Site is neither so complex, nor the
  exposure to hazardous substances so acute, as to warrant an expenditure of
  almost 6 times the current average.

 If the EPA preferred remedy is not an operable unit the EE/CA suggests it is a
 removal action. However, the estimated cost and duration of the EPA preferred
 remedy would also not justify it as a removal action under the NCP.

 In light of the above, EPA should have gathered more information regarding the
 nature and extent of contamination, developed remedial alternatives that
 encompassed all the presumptive remedy options, and performed a more
 comparative analysis typical of a feasibility study.  As explained later in this
 comment document, there exist other options, not considered by EPA, to
 accomplish the objectives set forth in the proposed plan for this operable unit for
 considerably less cost

 2.  In opting for the permanent relocation often to nineteen residents, there was
    an obligation under the NCP to seek a cost-effective remedial action once the
    affected areas were vacated.

 The NCP provides for remedial action costs associated with the permanent
 relocation of residents. In doing so, it is presumed that relocation (either alone or
 in combination with other measures) is more "cost-effective" than, and
 environmentally preferable to, the secure disposition off-site of such hazardous
 substances that may otherwise be necessary for the protection of the public
 health or welfare.2
1  National Ofl and Hazardous Substance Pollution Contingency Plan. 40 CFR Part 300, section
   300.5 (Definitions), March 8,1990 (revised September 14,1994)

2   National Oil and Hazardous Substance Pollution ConHnppr
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 Relocation of residents in this plan appears to be for practical purposes, iev to
 facilitate the excavation of the buried wastes as ATSDR has determined that
 there are no short-term exposure risks. However, if residents are relocated to
 facilitate clean up, longer-term risks must also be reduced. This reduction in
 potential risks would suggest that the limitations to on-site in situ or ex situ
 remedial options, which were eliminated from consideration in the proposed
 plan would have been removed. Hence, on-site actions should be reasonably
 considered in conjunction with relocation. The plan should therefore evaluate
 both ex situ and in situ on-site alternatives, because they would considerably
 reduce the remedial costs.

 3.  The $58,000,000 preferred alternative identified in the Proposed Plan by EPA
    warrants a review by the National Remedy Review Board (NRRB).

 The NRRB was created in January 1996 as part of a comprehensive package of
 reforms to the Superfund program. The NRRB "...is intended to help control
 remedy costs and to promote consistent and cost-effective decisions at Superfund
 sites, ..."3

 The NRRB is tasked with reviewing all proposed cleanup decisions where: 1) the
 proposed action costs more than $30,000,000; or 2) the proposed action costs
 more than $10,000,000 and this cost is 50% greater than that of the least-costly,
 protective alternative that also complies with other laws or regulations that are
 "applicable" or "relevant and appropriate" to a site  decision or action. The
 EPA's preferred alternative in the Proposed Plan meets these criteria.

 The EPA administrative memorandum announcing  the formation of the NRRB
 anticipated that the board would conduct its review and make its
 recommendations on a preferred remedy before a proposed plan is issued for
 public comment Moreover, the involvement of the  NRRB was extended to the
 review of non-time critical removal actions, applying the same criteria and
emphasizing that the review occur before the Engineering Evaluation/Cost
Analysis (EE/CA) is issued for public comment4

There is no mention in the Proposed Plan that an NRRB review took place, or if it
did, what the recommendations of the NRRB were.
   Memorandum on the Formation of National Superfund Remedy Review Board, from
   Assistant Administrator Elliott P. Laws to Regional Waste Management Division Directors,
   November 28,1995.
   Memorandum on the Review of Non-Tin uxTViHrd Removal Actions by the National remedy
   Review poard, from Stephen D. Luftig, Director of OEER to Regional Waste Management
   Division Directors, December 18,1997.

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4.  By conducting the Engineering Evaluation/Cost Analysis (EE/CA), EPA
   acknowledged that they could not take advantage of the generic justification
   provided by the "Presumptive Remedies for Soils, Sediments, and Sludges at
   Wood Treater Sites."

EPA has identified presumptive remedies for wood treater sites, which the
agency believes represent appropriate response action alternatives. The actions
identified in the presumptive remedy document are expected to be used except
under unusual site-specific circumstances. Presumptive remedies are expected
to save tune and reduce costs and therefore, generally should be used. EPA also
acknowledged that it might also be possible to accelerate remedy selection for
non-presumptive technologies by performing a conventional Remedial
Investigation and Feasibility Study (RI/FS) or EE/CA.5

EPA adopted presumptive remedial approaches to streamline and accelerate the
remedy selection process. However, at the Site, the EPA still found it necessary
to carry out an EE/CA to justify its remedy selection.  Although the EE/CA did
streamline the remedy selection process, the $58,000,000 cost for the remedy can
hardly be viewed as a minimized cost This is due largely to the fact that
excluding the no  action alternative, of the five remedial alternatives considered
in the EE/CA; four were predicated on general response actions involving
excavation and off-site disposal and treatment Hence, the largest engineering
cost component (excavation and off-site treatment and disposal), that represents
in excess of 50% of the estimated remedial cost, was common to the majority of
alternatives. As a result the EE/CA was skewed in its evaluation. The EE/CA
did not consider alternatives that employed bioremediation and/or thermal
treatment two additional technologies identified in the wood treater
presumptive remedy document

5.  The EE/CA was  biased in its identification of remedial alternatives, even in
   identifying those that are consistent with presumptive remedies for wood
   treater sites.

The EE/CA considered only certain alternatives relating to bioremediation,
thermal desorption and incineration technologies, the identified presumptive
remedies for wood  treater sites. However, in deciding to conduct the EE/CA,
EPA should have considered on-site ex situ or in situ bioremedial and/or
thermal options that would achieve the stated objectives, particularly as such
options  become practical with resident relocation. Moreover, in situ options are
   Presumptive Remedies for Soils, Sediments, and Sludge? at Wood Treater Sites, US
   Environmental Protection Agency, Office of Solid Waste and Emergency Response, Directive
   9200.5-5-162, EPA/540/R-95/128, (page 2) December 1995.

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 less likely to result in the magnitude of potential exposures to the community
 during excavation as compared to the EPA's preferred alternative.

 On-site options, which are consistent with the presumptive remedies for wood
 treater sites, would be viable once residents are relocated.  As such, they are
 consistent with EPA's presumptive remedy guidance. Moreover, the
 presumptive remedy guidance recognizes that among other things, there may be
 significant advantages of innovative technologies over the presumptive remedies
 that warrant their consideration.6 To the extent in situ application of one or more
 of the presumptive remedies would be considered innovative, the NCP expects
 EPA to consider an appropriate innovative technology.7 As indicated in EPA's
 Presumptive Remedy Policy and Procedures, presumptive remedies do not
 preclude the consideration of innovative technologies should the technologies be
 demonstrated to be as effective or superior to the presumptive remedies.8

 The additional remedial alternatives described later in this comment document
 are viable substitutes to consider to meet the objectives as set forth in the
 Proposed Plan. These additional remedial alternatives are either consistent with
 the presumptive remedy guidance or are innovative approaches for which
 performance data shows their applicability to the subject waste profile. EPA
 should have evaluated these alternatives in light of the agency's
 acknowledgement that there are practical considerations associated  with the
 expense of shipping quantities of contaminated soil in excess of 5,000 cubic yards
 off-site for disposal.9

 6. The only complete discussion of the balancing criteria, other than cost,
   appears for the first time in the Proposed Plan. Since the Proposed Plan only
   presented two remedial alternatives, one being No Action, other remedial
   alternatives, including those that should have been considered (see above),
   did not benefit from this more detailed evaluation.

As previously mentioned, the five remedial alternatives identified in the EE/CA
 (excluding No Action) were biased to those based on excavation and off-site
treatment and disposal. These alternatives were screened for effectiveness,
implementability and cost Presumably, the initial EE/CA served as the basis for
7  National Oil and Hazardous Substance Pollution Contingency Plan. 40 CFR Part 300, section
   300.430 (a) (1) (in) (E), March 8,1990 (revised September 14,1994)
8  Presumptive Remedies: Policy and Procedures. US Environmental Protection Agency, Office
   of Solid Waste and Emergency Response, Directive 9355.0-47FS, EPA 540-F-93-047,
   September 1993.
9  Presumptive Remedies: Technology Selection Guide for Wood Treater Sites. US
   Environmental Protection Agency, Office of Solid Waste and Emergency Response
   Publication 9360.0-46FS, EPA 540-F-93-020, April 1993.

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 the focused EE/CA because all four alternatives contained in the focused EE/CA
 required excavation and off-site treatment and disposal. The alternatives in the
 focused EE/CA were based on remedial strategies from the original EE/CA,
 with modifications incorporating different elements of the original alternatives to
 create four separate new alternatives.  The focused EE/CA only evaluated the
 costs associated with these four limited alternatives. As stated above,
 bioremedial and thermal desorptive approaches were not evaluated.

 The process of selecting a remedy is the decision making bridge between
 development of remedial alternatives and documentation of a selected remedy.
 The process begins with the identification of a preferred remedial alternative in a
 Proposed Plan. The identification process relies on the evaluation of previously
 developed remedial alternatives.

 The EPA's preferred remedial alternative was not compared to remedial
 alternatives that employed the other presumptive wood treater remedies, or
 remedial alternatives developed, using all of the balancing criteria i.e., long-term
 effectiveness and permanence, reduction in toxicity, mobility and volume and
 short-term effectiveness in addition to effectiveness, implementability and cost
 These criteria, along with the other threshold criteria were only discussed in the
 Proposed Plan when the basis of comparison was only No Action. Therefore, the
 EPA's preferred remedial alternative was not afforded a full comparative
 analysis, which focuses on the relative performance of each considered
 alternative, as contemplated in the NCP.10

 7.  The EE/CA should have considered waiving certain ARARs in light of the
    costs for the considered remedial alternatives.

The Proposed  Plan states that the material in the source areas is a listed RCRA
waste.  Off-site treatment and disposal would therefore need to be performed at
a RCRA-pennitted facility. This EE/CA identified this issue as an ARAR,
effectively eliminating any other off-site thermal treatment except incineration,
as an option because no such RCRA permitted facility was identified.
Consequently, the EPA's preferred remedial alternative adopts off-site thermal
treatment in an incinerator.

Once again, the cost associated with the EPA's preferred remedial alternative
($58,000,000) should have triggered a more in-depth review of treatment options.
Aside from the previously mentioned alternatives, which are consistent with
presumptive remedy guidance and more cost effective, the limited alternatives
10     National Oil and Hazardous Substance Pollution Contingency Plan. 40 CFR Part 300,
section 300.430 (e) (2) (iii), (ii),(9)/ (ii) March 8,1990 (revised September 14,1994)

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  considered in the EE/CA could benefit from consideration of waiving this
  ARAR.                                                      6

  According to the NCP, a remedy must satisfy the two threshold criteria,
  protection of human health and the environment and compliance with ARARs
  (unless a specific ARAR is waived)." Although cost is not a factor in
  identification of ARARs, CERCLA authorizes the waiver of an ARAR with
  respect to a remedial alternative if any one of six bases exist12 Specifically, cost
  may be a consideration when determining whether a waiver is justified for
  "technical impracticability", "equivalent level of performance", or "Fund-
  balancing".

 A waiver for the ARAR associated with the EPA's preferred remedial alternative
 that prevents off-site treatment at a non-RCRA permitted facility should have
 been evaluated based on "equivalent level of performance" or "Fund balancing".

 In the case of "equivalent level of performance", the EE/CA acknowledges that
 thermal desorption can meet an equivalent level of performance as incineration.
 A similar conclusion was set forth in the guidance for presumptive remedies for
 wood treater sites. The only impediment to off-site thermal desorption is due to
 the listed nature of the  material and the unavailability of off-site RCRA
 permitted thermal desorption units.

 While cost is not considered in evaluating equivalence, this waiver could provide
 cost-saving flexibility. Because the estimated cost for treatment and disposal is
 more than 50% of the total estimated preferred remedial alternative cost less
 expensive technologies that can achieve the same outcome should have been
 explored before adopting a costly approach.  Rejection of a comparable
 technology simply because of an action-specific ARAR13 is unjustifiable.

 Since Fund monies are being expended for the preferred remedial alternative,
 consideration should have been given to invoking a Fund balancing waiver with
 respect to the need for using an off-site RCRA permitted facility for treatment
 EPA's policy is to consider this waiver when the total cost of the remedy is
 greater than four times the national average cost of remediating an operable unit
 (currently 4x$10,000,000 or $40,000,000)." As the estimated cost for the preferred
"  National Oil and Ha/m-dous Substance Pollution Ctmtin^ry Plar. ^n «~pp pnrt ?nn lcction
   300.430 (f) (i) (A), March 8,1990 (revised September 14,1994)
U  The Role of Cost in the Super-fund Remedy Selection Pmr^ T K F»^	nrnfn| Protection
   Agency, Office of Solid Waste and Emergency Response, Publication 920O3-23FS EPA
   540/F-96/018, September 19% (page 6).
»  Ibid.
14  bid.

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remedial alternative exceeds this threshold, a waiver may be warranted if this
single Site expenditure would place a disproportionate burden on the fund.15

8.  The administrative record was not readily available and is incomplete.

The administrative record was not available at the EPA-Superfund Records
Center in New York. The administrative record at the Manville Public Library is
incomplete. For example, it does not include information such as the raw
analytical data, the QA/QC packages and the boring logs.  We reserve the right
to review this data and comment further at a later date.
Risk Characterization Comments

9. The distribution of PAH congeners does not resemble other wood treating
   sites, and the assessment of potential risks may therefore need to be re-
   evaluated.

Virtually every polycyclic aromatic hydrocarbon (PAH) was detected at the Site,
including all species of carcinogenic PAHs (cPAHs). Unusually, however,
benzo(a)pyrene (BaP) is consistently present as 60% of the total cPAH risk.
Normally, BaP is a minor constituent  The EPA should make sure that a QA/QC
check has been done to insure that BaP (and other PAHs) are being identified
correctly. Alternatively, the risk assessment performed by CDM Federal
Facilities may have incorrectly assumed a log normal distribution for the
contaminants.  Evidence should be provided to support the use of a log normalcy
assumption. Finally, CDM Federal generally substituted one-half the detection
limit for non-detects. In a small censured data set this substitution may be
inappropriate and may have contributed to the unusual distribution of PAHs
observed.

20. The Site at present does not present unacceptable exposure risks.

Although potential carcinogenic risk exists at depth and, at least upon two
occasions, apparent creosote tars have come bubbling up to the surface, there is
no fate and transport analysis as to whether further excursions of impacted
materials to the surface are likely to occur. ATSDR has concluded that the Site
does hot present an unacceptable public health risk at present which conclusion
is at odds with EPA's preferred alternative (ie., if current risks are acceptable, an
extensive high cost remedy with significant short-term risks may not be
warranted).
15  Federal Register, Volume 55 No. 46, page 8750, March 8,1990.


                                   8

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11. Risks to the community will be exacerbated through execution of the
   preferred remedial alternative.

As noted above, despite EPA's emergency listing, there are no unacceptable
public health risks at present However, the proposed excavation and hauling
off-site of over 44,000 cubic yards of contaminated soil will present considerable
public health risk. Increased exposures from EPA's preferred remedial
alternative include:  Mobilization of creosote tar components into ground water
and air (both vapors and dust), and contamination of adjacent commercial and
residential properties, and risks to community residents from heavy-duty
vehicular traffic.  Concerning the latter, it should be noted that the Claremont
development has limited access at present which access would be further limited
by excavation activities and increased truck traffic at entryways.  In contrast to
EPA's preferred remedy, various in situ remedial alternatives will minimize
potential exposures to contaminants, vehicular traffic and public health risks,
although these technologies may require delimited evacuation of some
Claremont residents.

12. The Proposed Plan fails to indicate what the estimated potential risks were
   for the two apparent excursions of creosote tars to surface.

Both EPA default and revised cancer risk guidelines should be used to complete
the analysis. The analysis should consider the short-term nature of the potential
exposures, the actual constituent concentrations in the material encountered, and
the fact that these two excursions represent the only known potential exposures
over the 50+ years that the materials have been at the Site.

13. The Site should be characterized more completely concerning potential
   exposure pathways.

The Site characterization as presented in the Proposed Plan appears incomplete,
especially concerning physical parameters of the subsurface. A more complete
description of physical properties of creosote tars and hydrogeology are required
to predict future fate and transport of tar constituents, for accurate predictive
risk assessment and prior to implementation of any in situ or ex situ  treatment
technologies.

Critical issues which must be examined and resolved prior to any fate and
transport analysis, risk assessment or remedy, implementation include:

•  The mobility of creosote tars in the canal and lagoon areas;

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 •  The consistency (viscosity) of these tars as compared to other viscous
    substances such as asphalt, molasses, heavy oil or light oil;

 •  The melting point and high temperature water solubility of tar constituents;

 •  The water solubility of tar constituents under ambient conditions;

 •  The composition of subsurface soil with respect to granularity, carbon and
    clay content and permeability;

 •  Whether creosote tars exist within both saturated and unsaturated zones; and

 •  Potential mobilization conduits created by sewer, optical cable and other lines
    which transect the site.

 Resolution of these critical issues will have a direct impact on the design and
 construction of the preferred remedial alternative.  Moreover, the potential
 adverse effects from such data gaps can cause schedule slippage and cost
 overruns during the design and construction phases of remedy
 implementation.16

 14. In Situ remedial alternatives exist which will minimize future risks.

 As noted above, excavation and removal actions will exacerbate public health
 risks. In situ technologies exist, however, which will alleviate future potential
 migration of creosote tars to the surface. While some of these might entail partial
 or temporary complete evacuation, these will prove less disruptive, safer and less
 costly than the proposed remedy. Ostensibly, if an in situ alternative remedy
 requires no excavation, no homes would need to be destroyed. If relocation is for
 a longer term, a viable sub-option, from a risk perspective, would  be to buy all
 affected homes and, following remediation, sell these homes back to the
 community.

 Proposed Remedy Comments

 25. It is premature to evaluate and select a preferred remedial alternative for this
   site until after the investigation and delineation activities are completed.

 Based on the significant uncertainties regarding the extent and volume of
 impacted materials to be remediated, it is premature to complete the evaluation
 and selection of a remedial option for the Site. As presented in the Proposed
16  Engineering Issue: Data Gaps in Remedial Design. Moylan, JE, US Environmental Protection
   Agency, US Army Corps of Engineers, July 1991


                                  10

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Plan, the volume of impacted materials requiring remediation "may change
substantially pending a review of the subsurface data". Such changes could
dramatically impact the number of houses to be relocated, the number of affected
residents, the total costs and risks of various alternatives, and the overall
comparison of options. Because the ATSDR evaluation has indicated that there
are no unacceptable short-term risks, and because the waste has been present for
at least 40 years, it would be appropriate to wait until the site investigation and
evaluation activities are completed prior to the final evaluation  and selection of a
preferred remedy.

16. The EPA's proposed remedy should be reconsidered because  the actual
   remediation costs may greatly exceed the $58,000,000 estimate for the
   preferred alternative presented in the Proposed Plan,

A number of factors including a potentially larger waste volume, potentially
underestimated unit costs, and potentially omitted remediation activities could
cause the EPA's preferred remedy to cost much more than the $58 million
presented in the Proposed Plan. As a result the evaluation and comparison of
remedial alternatives is a flawed basis for the selection of a preferred remedy.

As presented in the Proposed Plan, all soils "exhibiting signs of visible
contamination" would be removed under the preferred remedy. Further, the
Proposed Plan states that the estimated volume of impacted soils upon which the
evaluation was based "may change substantially pending a review of the
subsurface data". This lack of data presents a significant concern with regards to
the evaluation of remedial options because even a small change in the volume of
soil to be removed could have a profound impact on the overall cost of the
remediation because more than 50 percent of the remedial cost is for excavation,
treatment and disposal. For example, considering the difficulties likely to be
encountered during the excavation, and  potential over-excavation as a result of
visual staining and field decisions, removal of as little as 5-feet of additional soil
from each boundary of Lagoons and Canals A and B would result in a 30 percent
increase in the volume of soil excavated. This would increase the overall cost by
approximately $8 million.  If chemical testing is used to define the limits of
excavation, cost increases much greater than 30 percent could easily result Costs
could therefore easily increase to beyond $100 million. Such a potential cost
increase warrants a re-evaluation of the remedial alternatives and preferred
remedy.

The unit costs for off-site transportation and incineration may be
underestimated, and are therefore not a reasonable basis for the evaluation and
selection of a preferred remedy. For example, recent vendor quotes put the cost
of incineration alone (without transportation and associated costs) are $700 to
                                  11

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 over $1,000 per ton of material, as opposed to the $510 per ton assumed in the
 EE/CA (see Attachment 3). Published remediation cost data also reflects a cost
 of over $1,000 per ton for the incineration of bulk solid wastes.17 Based on the
 estimated approximately 60,000 tons of material to be incinerated, every $100
 extra per ton would increase the total remediation costs by $6 million. Based on
 a transportation and incineration cost of $1,000, the total remediation cost could
 approach $30 million more than estimated in the EE/CA.

 A detailed evaluation of the EE/CA also indicates that costs for items such as
 perimeter air monitoring for community protection and related required
 activities have not been adequately reflected in the estimated costs presented in
 the Proposed Plan.

 27. The $58,000,000 preferred alternative identified by EPA in the Proposed Plan
   presents potentially significant implementation problems and short-term
   risks that have not been adequately evaluated in the Proposed Plan.

 The analysis of the EPA's preferred remedy presented in the Proposed Plan
 underestimates the potential implementation problems and short-terms risks
 associated with the excavation and off-site incineration of the impacted soils, and
 therefore is not an appropriate basis for the selection of a remedy.

 For example, the actual volume and locations of material to be excavated have
 not been fully defined, and "may change substantially pending a review of the
 subsurface data". As a result implementation concerns associated with the total
 area of disturbance, volume of material to be handled, and number of affected
 properties and houses to be demolished have not been adequately characterized.

 Further, the Proposed Plan states that the EPA's preferred alternative (excavation
 and off-site disposal) would eliminate the potential exposure of residents to
 contaminated soils, and there would be no local human health impacts.
 However, based on the estimated excavation mass of greater than 66,000 tons,
 and assuming a standard truck size of approximately 20 tons, the EPA's
 preferred remedy would require more than 3,300 additional trucks to and from
 the site. This additional traffic presents potentially significant risks to the public
 as a result of traffic accidents, spills, releases, etc. Also, the significant exposure
 and handling of impacted soils increases potential exposure risks as compared to
 the current conditions where the materials are generally separated from the
community1 by the existing cover soils.
17  Environmental Remediation Cost Data - Unit Price. RS. Means Company Inc, and Delta
   Technologies Group, Inc., 1998. Cost Item 3319 9520, page 8-186.


                                  12

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 Finally, the EE/CA and Proposed Plan do not adequately reflect the potential
 implementation concerns and short-term risks associated with the control of
 fugitive emissions. As a result the EPA's preferred remedy likely presents
 greater short-term risks than reflected in the Proposed Plan. The EE/CA and
 Proposed Plan rely on the use of a pre-fabricated enclosure for the control of
 fugitive emissions. However, based on the location of the impacted soils to be
 excavated, and the structures schedule to remain in place, there is not enough
 room to erect an enclosure over all excavation areas, and therefore fugitive
 emissions are a potential concern. Also, and as discussed in related EPA
 technical documents18 (see Attachment 3), short-term risks to workers working
 within an enclosure can be significant as a result of hazardous air concentrations
 within the enclosure, significant personal protective equipment (PPE) required,
 the potential for PPE failure, and significant physical hazards associated with the
 confined working conditions and poor visibility.

 Alternative Remedy Comments

 18. The remedy evaluation and selection process failed to adequately consider
   alternate in situ remedial approaches that could be more cost-effective than
   the preferred alternative identified in the Proposed Plan.

 The EE/CA considered only one in situ treatment alternative (in situ
 immobilization), and eliminated it on the basis of effectiveness and technology
 limitations.  However, a number of other in situ remedial approaches have been
 successfully utilized at similar sites, and would likely provide a more cost-
 effective and lower risk remedy than the preferred remedy presented in the
 Proposed Plan. Based on the significantly lower costs and potentially lower risks
 presented by these in situ technologies, the EPA's preferred remedy in the
 Proposed Plan should be reconsidered.

 Bioremediation is an applicable remedy identified in the EPA wood treaters
 presumptive remedy guidance document Both ex situ and in situ bioremedial
 remedies have been identified, screened and selected as the preferred remedy at
wood treater sites. As presented in EPA's wood treaters presumptive remedy
guidance (se Attachment 1), of the 18 RODs where bioremediation was
considered, it was selected as the preferred remedy in 9 RODs (as a comparison,
off-site incineration was selected at only 4 of the 26 sites where incineration was
considered).  Considering the residential nature of the Site, use of in situ
bioremediation would maintain the integrity of the community while reducing
the overall risks to the residents. Although bioremediation of the site may
18
   Demonstration of a Trial Excavation at the McColl Superfand Site - Applications Analysis
   Report, US Environmental Protection Agency, Office of Research and Development,
   EP A/540/AR-92/015, October 1992.
                                   13

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 require a longer period to reach target levels, the ATSDR evaluation has
 indicated that there are no acute short-term risks, therefore a longer remedial
 program could effectively be implemented. EPA technology documents present
 a potential cost range of $50 to $250 per cubicyard for the successful biological
 treatment of creosote-contaminated soils and wastes19, which would result in
 significantly lower remediation costs than presented by the preferred remedy
 (see Attachment 3).

 In situ thermal desorption is another potentially cost-effective remedial measure
 that was not considered in the EE/CA or the Proposed Plan.  This process uses
 thermal wells and/or thermal blankets to remove constituents in situ, where they
 are collected and destroyed at the surface. This remedial approach has been
 effective at manufactured gas plant sites and other sites with creosote-type
 wastes (see Attachment 3). By leaving the wastes in situ, the significant
 implementation concerns associated with excavation and off-site incineration
 (e.g., short-term exposure risks, house demolition, disruption of the entire
 community, increased truck traffic, fugitive emission controls, excavation below
 the water table, etc.) are eliminated. Further, this process can be implemented in
 a relatively short time period, and estimated costs for this alternative ($50 to $150
 per ton; see Attachment 3) are significantly lower than the costs for off-site
 incineration. Related technologies that are also potentially applicable to this site
 include in situ thermal methods that involve steam and oxygen injection such as
 the hydrous pyrolysis/oxidation (HPO) process. HPO has been demonstrated to
 be successful at the Visalia Commercial Creosote Site in Visalia, California (see
 Attachment 3).

 Phytoremediation, i.e., the use of plants for remediation has gained acceptance in
 the past 2 to 4 years and has been demonstrated effective as; alternative caps for
 waste site closure, ground water treatment systems and clean up agents (see
 Attachment 3).  Plant species tolerant to wood treater wastes such as perennial
 rye grasses have passed greenhouse treatability studies at a wood treatment site
 in Portland Oregon. The site has been seeded and studies indicate that
 significant contaminant degradation in shallow soil should occur in two growing
 seasons.  Mulberry and hackberry trees have been used by Union Carbide to
 provide a closure for a former impoundment containing highly toxic sludge with
 the consistency of axle grease that contained PAHs  and other mixed wastes. The
vegetative cover has lowered the water-table in the former impoundment
 preventing contaminant leaching to ground water and excavation of the site has
 revealed that the upper portions (up to 40-inches) of the basin looks like top soil
19  Pilot-Scale Demonstration of a Slurry-Phase Biological Reactor for Creosote-Contaminated
   Soil - Applications Analysis Report US Environmental Protection Agency, Office of Research
   and Development, EPA/540/A5-91/009, January 1993.


                                   14

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 and no longer has a chemical odor. Chemical testing of shallow soil samples
 indicated low PAH concentrations. Although phytoremediation was not
 identified as a presumptive remedy by the EPA, recent demonstrations suggest
 that this technology could be applicable to the Site, especially to remediate the
 shallow PAH-impacted soil (see Attachment 3). This technology should be
 evaluated in light of the $58 million cost associated with the preferred remedy.

 19. The remedy evaluation and selection process failed to adequately consider
    alternate on-site, ex situ remedial approaches that could be more cost-
    effective than the preferred alternative identified in the Proposed Plan,

 The EE/CA considered only a limited number of on-site, ex situ treatment
 alternatives, and they were generally all eliminated because of the residential
 nature of the area and a lack of space. However, if houses were to be demolished
 and relocated (as would be the case for the preferred remedy), significant space
 could be made available, and such a process could be less disruptive to the
 community by reducing truck traffic, and could be completed for a much
 reduced overall project cost As a result, the EPA's preferred remedy should be
 reconsidered in light of the potentially effective on-site, ex situ remediation
 approaches available.

 Ex situ remediation approaches that could be conducted on-site and that have
 been successfully utilized at other creosote sites include bioremediation, thermal
 desorption, asphalt batching, and soil washing.  Although some excavated
 materials may be classified as a hazardous waste, the EPA could designate the
 excavation/backfill area and the ex situ treatment unit as part of a Corrective
 Action Management Unit (CAMU), and Land Disposal Restrictions (LDRs) and
 Universal Treatment Standards (UTSs) would not be triggered 2°, and the
 alternative could satisfy all ARARs. As presented in EPA's Presumptive
 Remedies for Soils, Sediments, and Sludges at Wood Treater Sites (Attachment
 1), ex situ bioremediation and ex situ soil washing were two of the most
commonly selected remedies presented in RODs for creosote sites. Estimated
costs for ex situ biological treatment remedies are approximately $50 to $150 per
cubic yard of material21, which are far less than the costs for excavation and off-
site incineration. Estimated costs for on-site thermal desorption are
approximately $100 to $200 per cubic yard (see Attachment 3), which are also far
less than excavation and off-site incineration.
20  Presumptive Remedies for Soils. Sediments, and Sludges at Wood Treater SitesAJS
   Environmental Protection Agency, Office of Solid Waste and Emergency Response, Directive
   9200.5-5-162, EPA/540/R-95/128, (page 20) December 1995.
21  Ibid.
                                   15

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 With regard to the space limitations stated in the Proposed Plan for such on-site,
 ex situ remedies, sufficient space would be made available by the removal of
 houses as currently proposed by the EPA. For example, a typical thermal
 desorption unit and associated equipment can be laid out in an area of
 approximately 120 feet by 120 feet which would only occupy approximately two
 properties if located on-site (10 to 19 properties are considered in the Proposed
 Plan for permanent relocation).

 The Proposed Plan also indicates that on-site, ex situ remedies were eliminated
 from consideration given the residential nature of the area. This reason is
 considered to be invalid because the community disruption that would be
 associated with on-site, ex situ treatment is insignificant as compared to the site
 disturbance associated with implementation of the preferred remedy (e.g.,
 resident relocation, house demolition, site-wide excavation, emission control
 structures, truck traffic, etc.).

 Given the lack of consideration in the EE/CA, the proven acceptability,
 effectiveness, and low cost of on-site, ex situ remedies for other creosote-
 contaminated sites, and the actual availability of the required space for such
 processes, these options should be fully reconsidered prior to the selection of a
 preferred remedy.

 20. The remedy evaluation and selection process failed to adequately consider
   alternate off-site, ex. situ remedial approaches that could be more cost-
   effective than the preferred alternative identified in the Proposed Plan.

 Because the remedy evaluation and selection process failed to adequately
 consider alternate off-site, ex situ remedial approaches that could be more cost-
 effective than the EPA's preferred alternative identified in the Proposed Plan, the
 evaluation and selection of a preferred remedy is based on a flawed analysis.

 The Proposed Plan states that "incineration is believed to be the only available
 option for off-site treatment" because of the absence of other facilities permitted
 to accept RCRA-hazardous wastes. However, a review of available facilities
 indicates that permitted, off-site thermal desorption units exist in New Jersey
 which could potentially accept the materials, and the materials could also
 potentially be sent to a recycling facility for incorporation into asphalt (as was
 done for the creosote-impacted materials at the Utah Power & Light/American
 Barrel Superfund Site in Salt Lake City, Utah; see Attachment 2). Landfills and
 related facilities in Canada which could accept the materials have also been
identified. Such facilities present potentially significant cost savings as
compared to off-site incineration (costs of $40 to $150 per ton as compared to
$700 to $1,000 for incineration), and the lack of consideration of such facilities
                                   16

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 reflects the incomplete nature of the identification and evaluation of potential
 remedial options. Because of the significant cost savings potentially afforded by
 such facilities, any remedial options involving off-site disposal of excavated
 materials should re-consider the available alternatives to off-site incineration.

 21. The remedy evaluation and selection process failed to adequately consider
    alternate on-site containment remedial approaches that could be more cost-
    effective than the preferred alternative identified in the Proposed Plan.

 The Proposed Plan indicates that containment options were eliminated from
 consideration as a result of uncertainties associated with containment and EPA's
 determination that the canal and lagoon areas comprise principal threat wastes.
 However, containment options are among the most common, proven and
 reliable remediation approaches, and EPA guidance states that the treatment of
 principal threat materials should not be conducted if implementation of the
 remedy would result in greater overall risk to workers or the surrounding
 community during implementation22. Because the EPA's preferred alternative
 likely increases short-term exposure risks, and because current risks were
 determined by the ATSDR to be acceptable, other options such as containment
 should be reconsidered (consistent with EPA's Principal Threat Guidance) prior
 to the selection of a remedy for the site.  For example, traditional containment
 measures such as capping, vertical barrier walls (a.ka., slurry walls), and ground
water pump and treat could result in much reduced short-term risks, lower
 impacts to the community, and lower costs. If it is assumed that houses are to be
 removed and relocated as would be done for the preferred remedy in the
proposed plan, significant containment and redevelopment options (e.g., for
industrial or commercial uses) exist that were not identified or evaluated in the
EE/CA or Proposed Plan. Even if all houses required removal and/or relocation
to facilitate implementation of a protective remedy for the site (i.e., ground water
recovery and treatment asphalt capping, and commercial/industrial
redevelopment), estimated costs for such a remedy would be significantly less
than those for the preferred remedy. Similarly, the industrial/commercial
redevelopment of this site would be consistent with EPA and New Jersey
initiatives and regulations regarding the appropriate and risk-based
redevelopment of contaminated properties. As a result of the omissions in EPA's
evaluation, the remedy evaluation and selection process needs to be re-
conducted prior to the designation of a preferred remedy.
   A Guide to Principal Threat and Low Level Threat Wastes. US Environmental Protection
   Agency, Office of Solid Waste and Emergency Response, Superfund Publication: 9380.3-06FS,
   November 1991.
                                   17

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                            Table 1
Summary of Potential Costs and Risks for Alternate Remedial Options
                     Federal Creosote Site
                     Manvllle, New Jersey
Remedial Option
EPA's Preferred Remedy
(Off-Site Incineration)
On-Site. Ex-Situ Treatment
(Thermal or Biological)
On-Site, In-SItu Treatment
(Thermal or Biological)
On-Site Containment
(Cap and Slurry Wall)
Unit Treatment Cost
$510 to $1,000 per ton
$50 to $250 per ton
$50 to $150 per ton
(also, no excavation/backfill)
Not Applicable
Total Estimated Cost
$58 to $88 million
$30 to $43 million
$23 to $29 million
$10 to $30 million
Short-Term Exposure Risks
HIGH due to significant waste
disturbance and traffic.
MODERATE due to significant
waste disturbance.
LOW as a result of minor
waste exposure.
LOW as a result of minor
waste exposure.

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Attachment 1
Documents to Support
Procedural Comments on
Proposed Remedy

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         United States
         Environmental Protection
         Agency
Office of Emergency and
Remedial Response
(5204G)
EPA 540-R-97-032
OSWER 9220.0-26
PB98-963250
February 1998
         aupertund
EPA    National Remedy Review Board
         Progress Report:
         Fiscal  Year 1997

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                        NRRB Progress Report 1997
Introduction	 .	1

EPA's Superfund Reforms	1

The National Remedy Review Board	2

FY 1997 Board Reviews	2

Board Review Criteria  	„	3

The Board Review Process	4

NRRB Operating Improvements	5
      Non-Time-Critical Removal Action (NTCRA) Reviews	5
      High Cost Sites that do not Trigger Review Criteria  	6
      Post-Proposed Plan Cost Increases  	6
      PRP and Community Technical Submissions to the Board 	6

FY 1997 Operating Costs	8

Conclusion	8

Attachments:

      Attachment 1
            November 28, 1995, EPA Memorandum: "Formation of the
            National Superfund Remedy Review Board"
      Attachment 2
            National Remedy Review Board Members
      Attachment 3
            Role of Interested Parties in the National Remedy Review Board
            Process
      Attachment 4
            September 26, 1996, EPA Memorandum: "National Superfund
            Remedy Review Board"
      Attachment 5
            December 18,1997, EPA Memorandum: "Review of Non-Time-
           Critical Removal Actions by the National Remedy Review Board"
      Attachment 6
           Publicly Available NRRB Review Memoranda (Board
           Recommendations)

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                               NRRB Progress Report 1997
             Introduction
J
    EPA created the National Remedy
Review Board (the Board) in November
1995 as part of a comprehensive package of
reforms designed to make the Superfiind
program faster, fairer, and more efficient.
This report is the second annual report on
the Board's progress.  It focuses on
significant accomplishments for the fiscal
year (FY) ending September 30, 1997.
However, it also presents information not
publicly available when the Board issued its
1996 report, as well as information on
several Board reviews conducted in the  first
quarter of FY 1998.  The report notes this
where appropriate.  This report should help
those interested in the Board's work learn
more about the review process, its
contribution to the Superfund program,  and
how interested parties can contribute to
review efforts.

    EPA believes the Board has
accomplished a great deal this past year.
The reviews have contributed  to a more cost
effective,  consistent Superfiind program,
improved the quality of several high-cost
cleanup decisions, and contributed
positively to human health and
environmental protection.  In addition, FY
1997 Board recommendations may result in
potential site cleanup cost savings of more
than $6 million, bringing the cumulative
reduction in estimated cleanup costs  to over
$37 million. The Board expects these
savings estimates to increase as Regions
complete their analyses of Board comments
and issue proposed plans in the coming
months.

    The next section describes the
Superfund reform initiative and explains
how the Board contributes to its goals. The
following sections discuss the Board's
operations, refinements, influence on
Superfund cleanups, and resource issues.
Included as attachments to this report are
several EPA documents and memoranda
that provide information about Board
operating procedures, cleanup decision
reviews, and other issues. Note that several
Board operating procedures have  changed in
the past year. Please refer to the  section
titled "NRRB Operating Improvements" for
an explanation of these changes.
              EPA's Superfund Reforms
                                      J
             The Superfund program is an ambitious
         and complex environmental program that
         •protects citizens and the environment from
         the dangers of abandoned or uncontrolled
         hazardous waste sites.  When Congress
         enacted CERCLA1 (the Superfund law) in
         1980, the challenge of cleaning up what was
         assumed  to be a few hundred discrete,  land-
         based cleanups appeared relatively
         straightforward.  The problem of neglected
         hazardous waste sites, however, has
         revealed  itself to be far more complicated
         and widespread than anyone at first
         realized.  EPA now recognizes that the
         number and complexity of hazardous waste
         sites across the nation dwarfs original
         estimates.

            As a  logical outgrowth of its experience
         managing the Superfund program, EPA has
                 Superfiind is authorized by tbe Comprehensive
         Environmental Response, Compensation, and Liability Act
         (CERCLA), as amended. 42 U.S.C. §9601 et. seq. Tbe
         program's principal implementing regulation is tbe National
         Oil and Hazardous Substances Pollution Contingency Plan,
         also known as tbe NCP 40 CFR 300.

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                              NRRB Progress Report 1997
put in place a series of Superfund reforms.
These reforms change substantively the way
the Agency handles its responsibilities
within existing laws.  The reforms
accelerate the pace and reduce the cost of
cleanups, streamline remedy selection,
increase fairness, promote economic
redevelopment, and better integrate federal
and state cleanup programs. These
changes, however, do not alter the law's
preference that Superfund cleanups provide
long-term reliability and reduce the toxicity,
mobility, or volume of waste through
treatment.  The Agency believes these
reforms will save money without sacrificing
public health or environmental protection.
One of the principal program reforms is the
National Remedy Review Board.
   The National Remedy Review
                Board
    The Board has been fully operational
since January 1996.  Its goal is to review
proposed high cost cleanup decisions to
assure that they are cost effective and
consistent with current law, regulations, and
guidance.

    The Board generally meets quarterly to
review the proposed cleanup decisions that
meet its cost-based review criteria.  The
Board is essentially a peer-review group that
understands both the Regional and
Headquarters perspectives in the remedy
selection process. The product of the
review is a memorandum sent from the
Board Chair to the appropriate Regional
decision maker.  This memorandum
documents Board recommendations about
the proposed cleanup strategy.
    The Board is composed of managers or
senior technical experts from each,EPA
Region, as well as senior technical or policy
experts from EPA offices important to
Superfund remedy selection issues. This
membership ensures that the Board adopts a
cross-Regional perspective when it
examines key issues.  It also provides for
senior policy and technical input from EPA
Headquarters and Laboratories.   Offices
represented on the Board include the Office
of Emergency and Remedial Response
(OERR), Office of Research and
Development, Technology Innovation
Office, Office of Indoor Air and Radiation,
Federal Facilities Restoration and Reuse
Office, and Office of General Counsel.  The
Board is Chaired by Bruce Means, Senior
Process Manager for Response Decisions in
OERR.  See Attachment 2 for a list of
Board members.
                                                    FY 1997 Board Reviews
                                     1
    The Board reviewed eight cleanup
decisions in FY 1997 and three cleanup
decisions in the first quarter of FY 1998,
bringing the total number of reviews as of
January 1998 to 23.  In all cases, the
Regions conduct analyses to decide whether
and to what extent the reviews may
ultimately affect their cleanup approaches.
Table 1 presents summary information on
each cleanup decision the Board has
reviewed from its inception to January
1998.

    Please note that EPA Regions are still
considering Board recommendations on
several cleanup decisions, particularly those
conducted most recently.  EPA Regions,
however, have already estimated cleanup
cost reductions of more than $6 million

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                              NRRB Progress Report 1997
from FY 1997 reviews.  Since the Board
began its reviews in early 1996, EPA
estimates total cleanup cost reductions of
more than $37 million.  The Board fully
expects these savings estimates to increase
as Regions complete their analyses of Board
comments and issue proposed plans.  Below
are just two examples of how Board
recommendations have contributed to
significant cost savings since the Board last
issued this report.

•   The Board reviewed a cleanup decision
    for the New Bedford Harbor,
    Massachusetts, site in September 1996.
    One recommendation the NRRB  made
    was for the Region to assess whether its
    air monitoring program was too
    extensive given the nature of the
    contaminants and planned cleanup
    actions.  The Region subsequently
    analyzed the need for this continued
    monitoring and found that it could
    adjust the monitoring program and
    reduce costs by approximately $8.4
    million.

•   At the Tex Tin site in Texas, Board
    comments encouraged the Region to
    reassess how threats from a
    contaminated on-site building might best
    be addressed. As a result, die Region
    found a way to save approximately $6
    million compared with its  original
    proposal.

    It is important to recognize that
estimated cost reductions such as these do
not reflect the full range of benefits gained
from Board reviews. Other important
benefits include greater scrutiny of cleanup
costs, increased national consistency  in
remedy selection, improved technical
analysis of promising cleanup  strategies,
better-articulated decision rationale at high
 cost sites, and increased confidence of
 Agency staff and stakeholders in the final
 remedy.
        Board Review Criteria
J
The Board uses the following criteria to
determine whether it will review a site. The
Board will review all proposed Superfund
cleanup decisions (final or interim final) for
which: (1) the action costs more than $30
million; or (2) the action costs more than
$10 million and is 50% greater in cost than
the least-costly, protective, cleanup
alternative that complies with other laws or
.regulations "applicable" or "relevant and
appropriate" to the site decision or action.

The criteria above cover federal facility
sites with the following exceptions.

•   For Department of Energy sites where
    the primary contaminant is radioactive
    waste,  the Board will review proposed
    cleanup decisions where: (1) the action
    costs more than $75 million; or (2) the
    action costs more than $25 million and
    this cost is 50% greater than that of the
    least costly, protective, cleanup
    alternative that complies with other laws
    or regulations "applicable" or "relevant
    and appropriate" to the site decision or
    action.

•   The Board does not review proposed
    decisions for Base Realignment and
    Closure (BRAG)  sites.

The Board, as of FY 1998, will also review
all proposed non-federal facility non-time-

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                               NRRB Progress Report 1997
 critical removal actions (NTCRAs)
 estimated to cost more than $30 million.
      The Board Review Process
J
    As soon as the Region determines that a
 proposed action will trigger Board review,
 the RPM calls the state/tribe, potentially
 responsible party (PRP), and community
 group to notify them of the pending review
 and explain the review process.
 Approximately four weeks before the
 meeting, the RPM delivers  to the Board the
 informational site package that the Board
 will use to conduct its review.

    For each review, the Board meets in
 two stages: information-gathering and
 deliberations.  The EPA site manager
 (Remedial Project Manager, or RPM)
 invites state and/or tribal representatives to
 participate in the information-gathering
 phase of the appropriate review. These
 representatives may participate in the
 deliberative discussion only for
 state/tribe-lead fund-financed decisions and
 state/tribe enforcement-lead decisions  where
 the state/tribe seeks EPA concurrence.
 Otherwise, the Board limits its deliberative
 discussion to Agency personnel.

    At the meeting, the RPM begins the
 information-gathering phase with a briefing
 that focuses on key remedy selection issues.
 Following the RPM briefing, state and/or
 tribal representatives present their view of
 key issues. The Board generally responds
with technical questions to clarify issues
related to the site and proposed cleanup
strategy. The Board may also discuss
 community, state/tribe, and/or PRP
 technical concerns in detail.

    The Board then deliberates for several
 hours, focusing on whether the proposed
 cleanup decision is cost effective and
 otherwise consistent with the National Oil
 and Hazardous Substances Contingency
 Plan (NCP) and program guidance. The
 Board asks the RPM to attend the
 deliberation.  The Board drafts its
 recommendations based on this discussion.

    After the review, the Board transmits a
 memorandum from the Board Chair to the
 appropriate Regional decision maker.  This
 memorandum documents any
 recommendations, advice, or findings the
 Board may have. Regional decision makers
 are then responsible for explaining, in a
 memorandum to the Board Chair, how the
 Region has considered the
 recommendations.  The Region places both
 memoranda in the site's Administrative
 Record. Below are examples of the kind of
recommendations the Board makes
 (excerpted from several recent Board
memoranda):

•  The NCP sets forth program
   expectations to treat principal threats
   wherever  practicable. Another
   expectation is to contain low level
   threats, because treating these wastes
   may not be cost effective or practicable.
   The NCP  also states that, for many
   sites, EPA will use a combination of
   treatment  and containment.  For this
   site, the information presented to the
   Board did not fully explain the extent to
   which the  explosives-contaminated soils
   to be treated constitute principal threat
   wastes. The Board believes that less
   costly containment alternatives may be
   adequate for at least some of these

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                           NRRB Progress Report 1997
materials, given the anticipated future
land use and ground water
considerations at the site. The [site
managers] should further explore these
alternatives or more thoroughly
explaining the decision document its
rationale for choosing treatment over
containment.
During remedial design it may be
possible to take advantage of existing
soil or hydrogeologic characteristics to
refine and focus the extent or intensity
of remediation work, and still  achieve
the desired remediation endpoints in a
reasonable time frame. The Region
should continue to examine key areas in
more detail to refine the number of
acres needing various levels of
remediation to optimize the cost-
effectiveness of the revegetation.

The Board believes that there may be
alternate (lower cost) approaches to
constructing the proposed "Corrective
Action Management Unit" in the lagoon
area.  For example, adequate
dewatering and stabilization of the
sludge may be achieved by surcharging
the area to achieve load-bearing
capacity, while adequate cap
performance may be achieved using the
surcharge soils and the proposed
impermeable material. The Board
recommends that the [site managers]
evaluate the feasibility of this or similar
approaches.

The Board is concerned that the quarry
may remain a long-term source of
contamination to the shallow ground
water. The State should evaluate the
appropriateness of ground water
extraction near the quarry to reduce the
potential for plume migration.
    [Site managers should]  . .  . require
    PRPs to address facility-specific
    contamination sources.  Such action is
    important to reduce continued aquifer
    degradation and reduce the potential for
    future groundwater remediation efforts.

    The [site managers] should explain
    [their] rationale for addressing
    subsurface soil. This explanation
    should consider the potential for soil
    contamination as a continuing source of
    groundwater contamination, the
    exposure assumptions used in
    establishing preliminary remediation
    goals (for the protection of health
    and/or environmental effects), and the
    incremental costs associated with
    addressing subsurface soils.
  NRRB Operating Improvements
I
    This past year the Board conducted an
extensive analysis of its operating
procedures.  The purpose was to respond to
stakeholder concerns and assess whether the
Board could improve its performance given
the experience gained in the first year.  This
included gathering and analyzing
stakeholder comments and concerns,
working with EPA Headquarters and
Regional management to assess Board
performance, soliciting suggestions for
improvement, and sometimes, holding
intensive internal meetings to guarantee the
Board was conducting efficient, effective
reviews. The following section summarizes
changes or refinements to the Board's
operating procedures resulting from this
work.

    Non-Tim^Crrtical Removal Action
            (NTCRA) Reviews

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                               NRRB Progress Report 1997
     Superfund removal actions can be cost-
 effective, efficient ways to address health or
 environmental threats. Consequently, EPA
 is using NTCRAs increasingly to carry out
 relatively high-cost response actions and
 expedite cleanups at National Priorities List
 sites. To assure that these high cost
 NTCRA decisions are consistent with
 national policies and guidance, the Board
 will review all proposed non-federal facility
 NTCRAs estimated to cost more than $30
 million. The review should occur before
 the Engineering Evaluation/Cost Analysis
 (EE/CA) is issued for public comment.
 This review criterion is effective as of
 October 1, 1998.

    EPA officials are currently working
 with DOE Headquarters and other federal
 agency officials to discuss Board review of
 federal facility NTCRAs.  Until the Agency
 reaches an official agreement with its
 federal counterparts, the NRRB will not
 review NTCRAs at federal facility sites.

    High Cost Sites  that do not Trigger
             Review Criteria

    The Board holds its reviews early in the
 cleanup process to take advantage of senior
 management and technical expertise before
 the Region finalizes its initial proposed
 action for a site. During this phase of the
 decision making process, Regions develop
 initial cost estimates according  to formal
 EPA cost estimating guidance.  However,
 these estimates are preliminary and carry
 with mem a range of uncertainty. The
 Board understands stakeholder interest in
 the quality and accuracy of these cost
estimates because the estimates determine
 whether a site triggers Board review.  In
response to stakeholder concems*me Board
has adopted the following policy:
 •   For sites that are close to, but do not
     trigger, the $30 million cost criteria: the
     appropriate Regional Board member
     will discuss briefly with the Board the
     key remedy selection and cost issues at
     the site and present the Region's
     position on whether the site would
     benefit from Board review.
     Post-Proposed Plan Cost Increases

    The Board recognizes that marginal,
post-proposed plan cost increases are not
uncommon. The Board believes it is
important, however, to review cleanup
decisions that do not trigger review criteria
at the proposed plan stage, but undergo
significant cost increases after the Region
issues the proposed plan.  Although the
Board does not expect to deal with such a
situation often, it has in place the following
operating protocol.

•   For proposed actions that did not
    originally trigger Board review, and the
    Region subsequently develops a new
    proposal that costs 20% more than the
    original cost estimate, and these costs
    trigger review criteria, then the Board
    will review the cleanup decision before
    ROD signature.

•    Where the Board has already reviewed
    a proposed action and the Region
    subsequently  develops a new proposal
    (or chooses a different alternative) that
    costs 20% more than the original
    preferred alternative, then the Board
    will review the proposed decision.

     PRP and Community Technical
        Submissions to the Board

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                             NRRB Progress Report 1997
    In FY1997, the Board doubled the page
limit for PRP and community group
submissions to 10 pages. The Board
believes that 10 pages of technical
comment, if it is focused on those issues
relevant to the Board's discussions, is
sufficient space to highlight any critical
issues concerning remedy selection at the
site.
                 TABLE 1: CUMULATIVE BOARD REVIEW SUMMARY
Site and Region
Fernald OU-5, R5
Petrochem, R8
Operating Industries, Inc., R9
Fernald OU-3, R5
Coleman Evans, R4
Petroleum Products, R4
Dupont Necco Park, R2
RoebHng Steel, R2
Jack's Creek, R3
Shipyard Sediments, RIO
New Brighton, R5
New Bedford Harbor, Rl
Fletcher Paint, Rl
Tar Creek, R6
Anaconda Smelter, R8
Continental Steel, R5
Review Date
January 1996
January 1996
January 1996
March 1996
May 1996
May 1996
May 1996
June 1996
June 1996
August 1996
August 1996
August 1996
November 1996
January 1997
April 1997
April 1997
Decision Stage
at Review
Post-PP
Post-PP
Pre-PP
Pre-PP
Post-PP
Pre-PP
Pre-PP
Pre-PP
Pre-PP
Post-PP
Pre-PP
Pre-PP
Pre-PP
Pre-PP
Pre-PP
- Pre-PP
Board memo
available to
uublic*
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes

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                           NRRB Progress Report 1997
Montrose/DelAmo, R9
Nebraska Ordnance Plant, R7
Oak Ridge National Lab, Surface
Impoundment OU, R4
Tex Tin, R6
San Gabriel, Puente Valley OU, R9
LenzOil, R5
Joliet Army Ammunition , R5
April 1997
July 1997
July 1997
July 1997
December 1997
December 1997
December 1997
Pre-PP
Post-ROD
Post-PP
Pre-PP
Pre-PP
Pre-PP
Pre-PP
pending
yes
yes
yes
yes
yes
yes
* Please refer to attarfumw 6 for the fall text of Board recomoKodatians publicly available as of January 1998.
          Key: R=Regkm, OU=operable unit, PP=proposed plan, ROD=Record of Decision

-------
                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                                                      OFFICE OF-
                                                                   SOLID WASTE AND
                                                                      EMERGENCY
                                                                      RESPONSE
MEMORANDUM


SUBJECT:    National Remedy Review Board Recommendations on  the  Coleman
            Evans Wood Preserving Site.

FROM:       Bruce Means, Chair
            National Remedy Review Board

TO:         Richard D. Green, Acting Director
            Waste Management Division
            EPA Region 4

DATE STAMPED:
AUGUST 12 1996                   •


Purpose

      The purpose of this memorandum is to document the findings  of  the
National Remedy Review Board (NRRB) on the proposed remedial action  for
the Coleman Evans Wood Preserving Site in Florida.

Background

      As you recall, the Administrator established the NRRB as one of
the October 1995, Superfund Administrative Reforms to help control
remedy costs and promote consistent and cost-effective decisions.  The
Board will review all proposed cleanup actions where:  (1) the estimated
cost of the preferred alternative exceeds $30 million, or (2) the
preferred alternative costs more than $10 million and is 50% more
expensive than the least-costly, protective, ARAR-compliant alternative.
In its review, the NRRB considers the nature and complexity of the site;
health and environmental risks; the range of alternatives that address
site risks; the quality and reasonableness of the cost estimates  for
alternatives; Regional, State/tribal, and other stakeholder opinions on
the proposed actions (to the extent they are known at the time of
review); and any other relevant factors or program guidance.

      Generally, the NRRB makes "advisory recommendations" to the
appropriate Regional decision maker before the Region issues the
proposed plan.  These recommendations are then to be included in  the
Administrative Record for the site.  While the Region is expected to
give the Board's recommendations substantial weight,  other important
factors, such as subsequent public comment or technical analyses  of
remedial options, may influence the final Regional decision.  It  is
important to remember that the NRRB does not change the Agency's
delegation authorities or alter in any way the public's current role in
site decisions.  This Reform is intended to focus the program's
extensive experience on decisions at a select number of high stakes
sites.

-------
 Findings

       The NRRB met with the Regional and State Remedial Project Managers
 (RPMs) for the Coleman Evans Wood Preserving site on May 8, 1996.  Based
 on that review and discussion, the members of the NRRB make the
 following observations.

       The Board is in general agreement with the preferred cleanup
 approach (Alternative 4), which relies primarily upon thermal desorption
 to address remedial action objectives: preventing PCP leaching to
 groundwater,  and mitigating direct human contact with or ingestion of
 dioxin.   The remedy complies with the preference for treating principal
 threats  stated in the National Contingency Plan,  and complies generally
 with EPA's presumptive remedy guidance on treating soils at wood treater
 Sites (OSWER Directive 9200.5-162).   The Board supports cleaning up the
 site to  levels indicated in the Region's proposal,  which should allow
 unrestricted site use at an estimated cost of approximately $20 million.


       The Board notes two areas of concern,  however.   First,  although
 thermal  desorption remains a viable  option for addressing health threats
 at this  site,  the Board cautions that the technology may not effectively
 treat on-site  soils to the cleanup levels identified by the Region.
 Second,  the State of Florida provided information to the Region the day
 before the  NRRB meeting that may substantially affect dioxin soil
 cleanup  requirements.   They informed the Region that a new State law
 considers dioxin soil levels greater than seven parts per trillion (ppt)
 to be unacceptable.   Neither the NRRB nor the Region can,  at this time,
 completely  evaluate the relative merits  and  cost  effectiveness  of
 various  cleanup options,  since extent of contamination sampling at these
 levels has  not been conducted.

       Region 4 is  currently evaluating whether  this  law constitutes  an
 applicable  or  relevant  and appropriate requirement  (ARAR).   Board
 members noted  that the  seven ppt  dioxin  cleanup level  is  generally
 inconsistent with  several  dioxin  decisions at other  sites.   Further,  the
 Board questions whether  current  treatment  technologies,  such as  thermal
 desorption  or  incineration,  can reach this level.

       Given the concerns noted above, the NRRB recommends that Region  4:

 •      Work with the Florida  Department of Environmental Protection to
       clarify  the  cleanup  objectives  and requirements  for the
       contaminated soil and  groundwater at the site with particular
       emphasis on  the seven ppt dioxin ARAR issue.

•     Conduct a pilot-scale  study on  the effectiveness of thermal
      desorption for treating PCP and dioxin-contaminated soils at the
       site.

•     Explore the feasibility and cost of enhancing Alternative 2,
      containment, given the uncertainty in the potential effectiveness
      of  thermal desorption and the Region's  previous experience in
      evaluating other treatment options for  site contamination.  This
      enhancement may include, but would not  be limited to,  a
      combination cap and slurry wall or an above ground containment
      vault.
      Consider a hybrid alternative that would employ both treatment and
      containment of the same soils.   The Region may find it more cost
      effective to use a treatment technology other than thermal
      desorption (e.g.,  bioremediation)  to address  the principal threat
      posed by PCP and high dioxin levels,  followed by a less expensive
      containment system or barrier (e.g.,  soil cover)  to prevent
      residual dioxin exposures.

-------
•     Further explore the feasibility of Alternative 3, incineration,
      which should be able to meet Regional remediation goals at only
      slightly higher estimated cost.  The NRRB appreciates, -however,
      that the Region must fully consider community and State concerns
      regarding the use of incineration at this site.

      The NRRB appreciates the Region's efforts to work closely with the
State and community to identify the current proposed remedy. The Board
members also express their appreciation to both the Region and the State
of Florida for their participation in the review process.   We encourage
Region 4 management and staff to work with their Regional  NRRB
representative and the Region 4/10 Regional Accelerated Response Center
at Headquarters to discuss appropriate follow-up actions.

      Please do not hesitate to give me a call if you have any questions
at 703-603-8815.

cc:   S.  Luftig
      E.  Laws
      T.  Fields
      B.  Breen
      J.  Hankinson,  Jr.
      J.  Cunningham

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                       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  WASHINGTON, D.C. 20460
                                                                       OFFICE OF
                                                                     SOLID WASTE AND
                                                                       EMERGENCY
                                                                       RESPONSE
  MjEHORMTODK


  SUBJECT:     National Remedy Review Board Recommendations  on the  Tar
              Creek Super fund Site

  FROM:        Bruce K.  Means,  Chair
              National  Remedy Review Board

  TO:          Myron O.   Knudson,  Director
              Superfund Division
              EPA Region 6

  DATE STAMPED:
  MARCH 4 1997


  Purpose


 „* „!, ThS Nati°nal Remedy Review Board (NRRB) has completed its review
 of the proposed remedial action for the Tar Creek Superfund site in
                °klah0ma-  ™S m— dum Documents SJ^'i Advisory
 Context for NRRB Review
                                                          n0
 costs  and promote consistent and cost-effective decisions   The NRRB
 »rea?etL?erIv1ew1ofbn-PhOVidin?a,CrOSS-regi0na1'  -nagemen^leve!,



2.
                                                   -               «
known at the time of review) , and any other relevant factors
      Generally, the NRRB makes "advisory recommendations" ^n ^,
appropriate Regional decision maker before the Region issues the
                                    final Regional decision   it is

-------
NRRB Advisory Recommendations

      The NRRB reviewed the package for the residential properties
operable unit at the Tar Creek site and discussed related issues with -
EPA Remedial Project Manager Noel Bennett and Toxicologist Ghassan
Khoury; Oklahoma Department of Environmental Quality representatives
Monty Elder and Kelly Dixon; InterTribal Environmental Council
representative Kent Curtis; and Quapaw Tribe representative John Gault
on January 28, 1997.  Based on this review and discussion, the NRRB
generally supports the Region's preferred alternative.  In addition, the
Board makes the following comments and recommendations for the Region's
consideration.

•     Given the widespread distribution of chat mining wastes throughout
      the community and the resulting potential for multiple pathway
      exposures, the Board recommends that the Region clarify the
      relationship of this action to future actions the Region may take
      to address remaining contamination at the site  (e.g., chat piles,
      tailings ponds, undeveloped land, industrial properties, etc.).

•     In view of this contamination and uncertainties in implementing
      the remedy (e.g., the ability to secure access to all contaminated
      residential properties), community protective measures are likely
      to play an important supplemental role at this site in protecting
      human health.  The Region should therefore include in the
      preferred alternative (Alternative 2 in the proposed plan) the
      provisions for counseling and public education  (e.g., emphasizing
      proper personal hygiene and the importance of removing indoor
     'dust).

•     The Region should make it clear to residents that there may be a
      residual indoor dust threat following soil excavation, that normal
      household cleaning will reduce the contamination to a protective
      level, and that the Region will loan HEPA vacuums to residents to
      expedite this process, if this service is not provided by others.

•     The Region should encourage the Bureau of Indian Affairs and the
      State to address potential recontamination sources  (e.g., to
      control redistribution of chat around residences, potential
      deterioration of exterior lead-based paint, etc.).

•     Given th6 preliminary results of a recent blood lead study that
      indicate a significant portion of the children in the Tar Creek
      area already experience elevated blood lead levels, the Board
      encourages continued blood lead monitoring of children through the
      State and local health agencies.  Such monitoring would help local
      public health officials track the overall success of multi
      jurisdictional efforts to reduce childhood lead exposures in Tar
      Creek.

      The NRRB appreciates the Region's efforts to work closely with the
State, Indian Tribes, and the community to identify the current proposed
remedy.  The Board members also express their appreciation to the
Region, the State of Oklahoma, the InterTribal Environmental Council,
and the Quapaw Tribe for their participation in the review process.  We
encourage Region 6 management and staff to work with their Regional NRRB
representative and the Region 2/6 Accelerated Response Center at
Headquarters to discuss appropriate follow-up actions.

      Please do not hesitate to give me a call if you have any questions
at 703-603-8815.
cc:   J. Saginaw
      S. Luftig
      E. Laws
     " T. Fields
      E. Shaw -

-------
                                                            http://www.epa.gov/oerrpage/superfund/programs/nrrb/attach5.hti.
                                       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                   WASHINGTON, D.C. 20460
                                                                               OFFICE OF
                                                                        SOLID WASTE AND EMERGENCY
                                                                               RESPONSE
               MEMORANDUM
               SUBJECT: Review of Non-Time-Critical  Removal Actions by the National Remedy
               Review Board
               PROM:  Stephen D. Luftig, Director  /S/ DEC 18 1997,  Office of Emergency and
               Remedial Response
               TO:  Director, Office of Site Remediation  and Restoration,  Region I
               Director,  Emergency and Remedial Response Division,  Region II
               Director,  Hazardous Waste Management  Division,  Regions III,  IX
               Director,  Waste Management Division,  Region  IV
               Director,  Superfund Division, Regions V,  VI,  VII
               Assistant  Regional Administrator, Office  of  Ecosystems Protection and
               Remediation,  Region VIII
               Director,  Environmental Cleanup Office, Region X
               Regional Counsels,  Regions I - X

              DATE STAMP:
              DEC 18 1997
              Purpose
              The purpose of this memorandum is to notify you that the National Remedy
              Review Board  (NRRB) will  be  reviewing proposed non-time-critical removal
              action (NTCRA) decisions  beginning in FY 1998. The NRRB will review all
              proposed NTCRAs for sites at.fund- and enforcement-lead NPL sites where
              costs for the preferred action are estimated to exceed $30 million. While
             .Federal facilities have full authority for NTCRAs at their sites  the
              Office of Emergency and Remedial  Response (OERR),  the Federal Facilities
Jof4
                                                                                        5/18/99 7:42 PM

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                                             h'*p://www.epa.gov/oeirpage/superfund/programs/nrTb/attach5.htm


 Restoration and Reuse Office (FFRRO), and the Federal Facilities
 Enforcement Office (FFEO) are working together with other Federal agencies
 to determine how best to consider expensive proposed decisions at Federal
 facility sites. Until agreements are reached with appropriate Federal
 agency officials, the NRRB will not review NTCRAs for Federal facility
 sites.

 I ask that you please forward this notice to the appropriate Regional
 contacts for implementation.
 Background

 As you know,  the Office of Solid Waste and Emergency Response established
 the NRRB in October 1995 as one of Administrator Browner's Superfund Reform
 initiatives.  The Board's goals are to help control remedy costs and promote
 both consistent and cost-effective decisions at Superfnnd sites, including
 those at Federal facilities.

 The Board reviews proposed decisions when the following criteria are
 exceeded: (1)  estimated costs for the preferred alternative exceed $30
 million; or (2)  proposed remedy costs exceed $10 million and they are 50%
 greater then  than those of the least-costly,  protective, ARAR-compliant
 alternative.  These criteria have triggered Board review of 23 remedial
 actions representing all ten Regions in the last two years.

 As a result of implementation of the Superfund Accelerated Response Model
 (SACM)  and recent Reform efforts,  many Superfund managers have looked to
 the removal program for ways to expedite site cleanup.  Since removal
 actions often provide excellent,  cost-effective tools for quick response to
 pressing health or environmental threats,  NTCRAs are being used more than
 they were in  the past to carry out relatively high-cost response actions.
 Given this increased role for NTCRAs in costly site cleanups,  I believe it
 is prudent to extend the NRRB program for review of high cost decisions to
 these actions as well.
Discussion

Generally, we do not believe  there  will be  many high cost NTCRAs.  In fact,
most NTCRAs are likely to cost  less than  $5 million.  However,  I believe it
is important to review a portion  of Superfund's NTCRAs  in order to provide
the necessary assurances that our decisions are consistent with national
policies and guidance. With this  in mind, I ask that  you submit all
proposed NTCRAs that are estimated  to  cost  more than $30 million to the
NRRB for review. This review  should occur before the  Engineering
Evaluation/Cost Analysis  (EE/CA)  is issued  for  public comment.

The Board will review information packages  for  NTCRAs similar  to those
reviewed for high cost remedial actions. In doing so, the NRRB will
consider the nature of the site;  the risks  posed;  the response actions
considered with associated costs; Regional,  PRP,  State/Tribal,  and
community opinions on the proposed  action (to the  extent they  are  known at
the time); and any other relevant factors or program  guidance  in making
advisory recommendations to the Regional decision  maker.  The Region,  in
turn, is asked to respond in  writing to these recommendations.  Both the
NRRB recommendations and the  Regional response  will become part of the site
Administrative record.

I fully appreciate that the timing  and coordination of proposed NTCRAs with
other ongoing cleanup activity will  often be critically  important.  As  a
result, I expect the NRRB to  make every effort  to  provide  the  review within
a satisfactory timeframe. However,  it is incumbent on the  Regions  to make
sure that parties bring the actions  triggering  review to the Board as  soon
as possible.  This will likely require advanced planning  by the  Regions and
others to account for the NRRB review .time  (i.e.,  about  8  weeks).  I
recognize that many NTCRAs are led by PRPs,  State/Tribes,  or Federal
facilities;  thus,  the planning process should consider the  time required
                                                                         5/18/99 7:42 PM

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 Attrchmc" 5                                                   httpy/www.epa.gov/oerrpage/superfand'programs/nrrb/attachS.htm
  •,* •'•

              both  to  coordinate with and solicit input from relevant stakeholders, and
              the time for  concurrence in enforcement actions.  Generally,  stakeholders
              are invited to participate in the review of NTCRAs in the same manner as
              for remedial  actions.  Please talk with your Regional NRRB representative
              for more details.

              As you know,  while in  some cases  EPA works very closely with other Federal
              agencies in site remediation,  in  general.  Federal facilities have full
              authority to  conduct NTCRAs at their sites.  For this reason,  OERR, FFRRO,
              and FFEO are  working together with other Federal  agency officials to
              determine how best to  consider expensive proposed decisions  at Federal
              facility sites. It should be noted that a recent  EPA memorandum on the
              Final FY 1998 Superfund Reforms Strategy (dated November 13,  1997)
              indicated that NTCRAs  at Federal  facility sites (other than  BRAC sites)
              that are estimated to  cost more than $30 million  (or $75 million for
              Department of Energy  (DOE)  radioactive waste sites)  are expected to be
              reviewed by the NRRB in FY '98. Recently,  however,  EPA officials met with
              DOE Headquarters and other Federal agency officials to discuss the NRRB
              review of NTCRAs in more detail.  As a result,  EPA and DOE have agreed to
              work together to explore additional options  for NRRB involvement. Dialogue
              also continues between EPA and the other Federal  agencies. Therefore, until
              an official agreement  is reached  with other  Federal agency officials, the
              NRRB will not review NTCRAs at Federal facility sites.



              Implementation

              Effective immediately,  please  identify for NRRB review all proposed NTCRAs
              at sites  other than Federal facility sites that are estimated to cost more
              than $30  million.  Your Regional NRRB representative will work with
              appropriate managers and staff to address  relevant  site-specific questions
              about timing  and review materials,  and t,o  establish a review  schedule that
              minimizes potential for pipeline  delays.

              I believe that  this Reform has accomplished  much  to improve both the
              consistency and cost effectiveness  of our  cleanup decisions over the last
              two years. Indeed,   the  NRRB has been well  received  by a wide  range of
              stakeholders  and is likely to  play a significant  role in a reauthorized
              Superfund. Without  question, this  reform's success  is the direct result  of
              the hard  work  of your  staff and management.  We  greatly  appreciate these
              efforts and look forward to your  continued support  in the review of NTCRAs.
              Please contact me,  or Bruce Means,  NRRB  Chair,  (703-603-8815),  if you have
              any questions  or comments.



              cc:  T. Fields

              OERR Center Directors

              OERR Senior Process Managers

              B.  Breen

              J.  Woolford

              E.  Salo

              E.  Cotsworth

              W.  Kovalic

              W.  Farland

              R.  Olexsey

              National  Remedy Review Board Members
3 of 4                                                                                    5/18/99 7:42 PM

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                     United States
                     Environmental
                     Protection Agency
Office of Solid Waste
and Emergency
Response
Publication 9360.0-46FS
EPA540-F-93-020
April 1993
                             Presumptive  Remedies:
                            Technology Selection  Guide for
                            Wood Treater Sites
 Office of Emergency and Remedial Response
 Emergency Response Division 5202G
                             Quick Reference Fact Sheet
 Cfllciyviiuy rwoi/unoo t_rivi^iwn WB.W&.V	__^_^.^______.._—_^_«_^_
Since the enactment of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) in 1980, the
Superfund remedial and removal programs have found that certain site categories have similar characteristics, such as: types of contaminants
present- types of disposal practices; or how environmental media are affected.  Based on information acquired from evaluating and cleaning
up many of these sites Superfund is undertaking an initiative to develop presumptive remedies that are appropnate for specific types of sites
and that are designed to accelerate the Superfund cleanup process. The objective of the presumptive remedies umiat.ve is to draw upon past
experiences to streamline site investigations and the remedy selection process in accordance with the Superfund Accelerated Cleanup Model
(SACM). The Agency has developed presumptions that particular technologies are appropriate for certain types of sites by evaluating
technologies that have been consistently selected and successfully used for past sites.

The Agency is developing a Generic Presumptive Remedies fact sheet which will outline and address the common issues (e.g., use of risk
assessment, innovative technologies, how to rebut the presumptive remedy, etc.) anticipated with the use of a presumptive remedy at any site.
In addition, the Agency is developing guidance on presumptive remedies for soils contaminated by volatile organic compounds, municipal
landfills, polychlorinatedbyphenols, grain storage, coal gasification sites, and contaminated ground water.

Information on technology performance for wood treater sites is presented in this Technology Selection Guide, it will be supplemented by
additional analyses of previous remedy selection decisions and remedy performance. This additional analyses will be developed into a
Presumptive Remedy Guide. This document is intended for use by a decision-making team experienced with wood treater sites.

                                                       are presented in this guide; in addition, other technologies,
                                                       with limited performance data, are also presented here.
BACKGROUND

Abandoned wood treater sites typically contain the following
contaminants either alone or in combination with each other
or with total petroleum hydrocarbon  (TPH) carrier oils:
creosote  (mainly, polynuclear  aromatic  hydrocarbons
(PAHs)); pentachlorophenol (PCP);.and chromated copper
arsenate (CCA). These contaminants may be found in pure
form (product), or in sludge, soil, sediments, surface waters,
or  ground  water.  Light. Non-Aqueous Phase Liquids
(LNAPLs)  and Dense NAPLs (DNAPLs)  may also be
present in surface or ground water.

Removal and remedial program experience at full-scale
projects indicates that there are some demonstrated treatment
technologies capable of achieving defined clean-up goals at
wood treater sites. These technologies
      IMPLEMENTATION

      Choosing among remedies requires care to match treatment
      requirements with site specific conditions, but the process
      can be streamlined within the scope of the National Oil and
      Hazardous Substances Pollution Contingency Plan (NCP)
      remedy selection requirements.  A focused site evaluation by
      experienced personnel with the use of the guide can greatly
      limit the feasible treatment options, identify early actions,
      and expedite the clean-up process.  This guide provides a
      selection procedure  outline  (box  below)  and practical
      considerations for the facilitation of remedy  selection. In
      addition, three tables are  included in the guide: Table I,
      Technologies for Treatment of Sludge, Soil, and Sediment;
      Table II, Technologies for Treatment of Surface Water and
      Ground Water; and Table III, Information Needs and Process
      Limitations. Many of the tasks outlined in this guide can and
      should be conducted simultaneously to accelerate the process

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and to minimize cost; however, a sequential process may be
necessary at times.
           WOOD TREATER TECHNOLOGY
          SELECTION PROCEDURE OUTLINE

        ;         Site Characterization ,

 A. Identify Contaminant         "        ..       '
    I.  Type (Lfr^Cji^TCP. creosote, wTPH)
    2,  Aloneor mixed (e.g., PCP/creosote/CCA)
 B. Establish Site Screening Criteria' Based on Actual or
    Anticipated Land and Water Uses      >  ,
 C. Identify Media and Areas Needing Treatment:
    1.  JVomid(urums, tanks, or recoVerableNAPLs)
    2.  Sludge (dmms, tanks, or open or bnried lagoons)
    3.  Soil and sediments from:
       a.  process areas
       b.  drip areas and storage areas    I          -
       c.  lagoon or drainage areas (pn-sJte/off-si*e)
    4.  SurTace'V/ater  ;
       a.  ponds/lagoons
     .  b. ,  runoff or drainage pathways                ' *
    5.  Ground Water
D.  Identify Possible .Treatment Options (Tables I and B)
F.
   technologies)
E. Dtttnnine Extent, Vohune, and Level of Contamlnaiionin
   Each Medium and Area of Concern
   Characterize Broadly die Physical/Chemical Nature of Each
   Treatment Medium In View of the Possible Treatments
   (Table HI Identifies Additional Information Needs):
   1.  Solids - Particle Size Distribution/ pH/Total Organic
      Carbon (TOC)/Cation Exchange Capacity/Moisture
   2.  Liquids -Phases/pH/TOC
   3.  Sludge - TOC/Moisture/Pumpmg Characteristics
   Select Final Clean-up Goals and  Treatment Levels'
   Considering Anticipated Land and Water Uses and the
   Removal Efficiencies Required to Achieve Those Levels
                                                                        WOOD TREATER TECHNOLOGY
                                                                     .. SELECTION PROCEDURE OUTLINE
                                                                                 ; (continued)

                                                                              Treatment Selection

                                                             A.   ••   Confirm the Volumes, Matrix Homogeneity and
                                                               •   '   Consistency, and Contaminant Concentrations
                                                             B.      Evaluate On/Off-Site and Pre-Treatment
                                                                     Options
                                                             C.    -  Evaluate Capping/Containment Option
                                                             D.      Assess Excavation, Segregation, and Stockpiling
                                                             E.      Select Candidate Treatment Options (Tables I
                                                                     and II)
                                                             F.  '    Evaluate Treatment Limitations and
                                                                     Information Needs Using Tabk HI
                                                             G.     'Select Final Treatments and Perform Site
                                                                     Specific Treatability Studies to Obtain Design
                                                                     Data for Procurement Specification
                                                             'Site SotSOling Criteria toe operational indicator, such as action terete
                                                             resulting from ao exposure ride assessment for a specific land use; they trigger
                                                             IbefiKrf fijr cltan-up. Clean-op Goals andTreaHnejit Levels reflect,;    :
                                                             projected exposures for tHiiicular bnd uses; iheseteveb describe Ihe       :
                                                             nndbiUty ofa resource for tfs intended osc.
PRACTICAL CONSroERATIONS FOR
FACILITATING TECHNOLOGY SELECTION

1.   If the product is still in original containers it should be
     returned to the manufacturer.  Reuse of material (i.e.,
     process liquids) and relocation of equipment to other
     permitted facilities should be  considered.   Phase
     separation should be conducted; water and emulsified
     product  could  be treated  on site.  LNAPLs  and
     DNAPLs may or may not be recyclable depending on
     the purity of the recovered phase.

2.    Where any of the principal wood treating chemicals
     (creosote, PCP, or CCA) can be recovered in high
     enough concentrations to warrant reuse in any process,
     recycling becomes the' preferred technology.  The
     recognized Waste Exchanges are listed in Appendix A.
     The alternative to reuse or recycling is to treat the
     material as waste along with other contaminated liquids
     or solids.

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3.   If the product, (e.g., PCP), is in storage tanks, then it
     should be analyzed for cross contaminants such as
     dioxins/furans.  Total pumpable and non-pumpable
     sludge in tanks and drums should also be determined.

4.   Site characterization should proceed as a single, multi-
     media sampling event  whenever  possible.    Field
     screening methods should be  integrated into the
     sampling and  analysis plan in order to accelerate
     information gathering.  Data quality objectives must
     reflect the ultimate use of the results, but all samples
     taken during a single event may not require the same
     level of data quality.

5.   Site preparation and  bulk material handling needs
     require evaluation  wherever soil treatment is being
     considered. Pretrealment renders a material suitable as
     feed for a treatment process. The technology selection
     should be evaluated for consistency with  the overall
     remedy for the site.  Site preparation and pretreatment
     activities include but are not limited to the following:

   A. Site Stabilization
      1.  Fencing and security
      2.  Capture and treatment of runoff
      3.  Containment of leaking vessels
      4.  Use of liners and covers
      5.  Capping and containment
      6.   Evaluation of on-site pretreatment for off-site
         disposal

   B. Material  Handling.   Waste   Segregation,   and
      Pretreatment
      I.  Surface material removal (poles, tanks, buildings,
         product, etc.)
      2.  Excavation & stockpiling
      3.  Sizing
         a. Screening of inert and oversized materials
         b. Particle fractionation or hydrosieving
         c. Debris handling
      4. Chemical pretreatment or Sterilization

6.   In general, other than in processing areas and storage
     tanks, the highest concentrations of contaminants may
     be  found in  surface  and buried  waste lagoons.
     Contamination can  migrate  vertically from these
     lagoons to significant depths.  Hydrogeologic studies
     may be necessary to discern such contamination and
     additional technologies for remediation may have to be
     considered.

7.   Surface lagoons, soil areas, drip pads, and sediments
     should be  gridded and sampled to determine the
10.
11.
12.
horizontal and vertical extent of contamination.  Soil
and  sludge characterization relevant  to  treatment
selection should reflect the information needs detailed
in Table II I.

Excavation of contaminated soil should generally not
be done until the final treatment technology has been
selected, except where it is deemed necessary to reduce
an imminent hazard or to  control migration. Where
possible,   excavated   organic    and   inorganic
contaminants, and high and low concentration materials
should be staged separately.

It is usually too expensive to snip quantities of greater
than 5,000 cubic yards of contaminated soil  off-site
for disposal.  Pretreatment of soil and water may be
required prior to shipment or discharge to another
treatment facility.

Circumstances  may   arise  where  capping  and
containment of material with relatively low toxicity and
mobility is an appropriate remedy. Such instances will
require careful evaluation.

Representative sampling and analysis for verification
of expected treatment efficiencies should be consistent
with  accepted Superftind quality  assurance/quality
control guidance.

Health  and  safety  considerations enter  into the
technology selection process as described in the Health
and Safety Plan (HASP).  Air monitoring to support
the  HASP  includes  both  on-site   and  off-site
components.

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                                                    TABLE I

                          Technologies for Treatment Of Sludge. Soil, and Sediment
"Contarninanl ", •'
CCA
PCP
Creosote
PCP + Creosote
Creosote + CCA
PCP + CCA
1 J jj (itreatpeat _,, '" ,
* t." *"* TechnoJogfes
Immobilization'
Incineration'
Other Thermal
Treatment3
Biotreatment2
Dechlorinalion*
Incineration1
Other Thermal
Treatment2
Biotreatment2
Incineration'
Other Thermal
Treatment'
Biotreatmenl2
NA
NA
, Testability
(RREL Database? *
80 - 90% TCLP
(B,P,F)
90-99%(B,P.F)
90 - 99°/o (Bf,f)
95 - 99% (BJPJ1)
4
4
Treatment :
Trains*:. • ' '
Soil Washing/
Immob2
Soil Washing/Bio!
Soil Washing/Bio:
Soil Washing/Bio2
Incin/Immob Ash1
Soil Washing/Bio/
Immob2
Incin/Immob/Ash'
Soil Washing/Bio/
Irnmob'
Dechlorin/Immob2
 1,   This technology recommendation assumes that the specified treatment efficiency can be achieved for a given site; it assumes
     that no site-specific constraints exist.

2.   These other technologies may warrant site-specific evaluations, RI/FSs, focused feasibility studies (FFSs), or engineering
     evaluations/cost analyses (EE/CAs) because they lack foil-scale performance dala. Site-specific conditions also may favor a
     subset of the major technology.  Bench-scale and/or pilot studies may be necessary to refine the selection of the most
     appropriate specific treatment method.

3.   Performance data are fora the Risk Reduction Engineering Laboratory (RREL). The database is derived from bench scale (B),
     pilot scale (P). or full scale (F) demonstration projects. Dashes indicate insufficient dala. The RREL is updated on a regular
     basis and is available through the Alternative Treatment Technology Information Center (ATTIC).

4,   Performance efficiency for treatment trains is a function of contaminant concentration, matrix and volume. It can generally be
     presumed that the performance of treatment trains will equal or exceed that of the individual treatment technologies.

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                                              TABLEn

                     Technologies for Treatment of Surface Water and Ground Water
• Contaminant
CCA
PCP
Creosote
Creosote + PCP
Creosote + CCA
PCP + CCA
~~< *" Treatment ->
-Technologies
Precipitation
Reverse Osmosis
Ion Exchange
Carbon Treatment
Biotreatment
Oxidation
Carbon Treatment
Biotreatment
Oxidation
Carbon Treatment
Biotreatment
Oxidation
Carbon Treatment
Oxidation
Precipitation
Carbon Treatment
Oxidation
Precipitation
i" " < Testability >
(SKELBatflbasef
97-99%(B,P,F)
99% (P)
95 - 99% (P)
99%(BJ>,F)
99% (B,P) *
82-99%(P,F)
99%(P,F)
99% (B,P)
82-99%(P;F)
99% (B,P,F)
99% (Bf)
...
—
, Treatment
Trains
Precipflmmob
Precip/RO/Immob
Precip/Ion Ex/Immob
Phase Sep/Carb
Phase Sep/Bio
Phase Sep/Oxidation
Phase Sep/Carb
Phase Sep/Bio
Phase Sep/Oxidation
Phase Sep/Carb
Phase Sep/Bio
Phase Sep/Oxidation
Phase Sep/Treal
Organic/Treat Metals
Phase Sep/Treat
Organic/Treat Metals
KEY:   Treat Organic = Carbon Treatment or Chemical (O3, C1O2> H2O2) or Ultraviolet Oxidation

    Treat Metals = Reverse Osmosis or Ion Exchange or Chemical Precipitation and Immobilization of Residues
    Performance data from the RREL (Risk Reduction Engineering Laboratory). Database is derived from bench
    scale (B), pilot scale (P), or full scale (F) demonstration projects. Dashes in the table indicate insufficient data.

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             TABLE ID




Information Needs and Process Limitations
•:' >!;Tiitim«fvt Technology
Thennal Treatment -
Incineration
Thermal Treatment -
Dcsorption
Immobilization
Biotrcauncnt -
ln-situ
Biolreatment -
Ex-situ
Base-Catalyzed
Dechlorinalion
Soil Washing
'! M i «
*• Information "Needs
i) BTU value
ii) Volatile metals cones. •
iii) Alkali metals (NaJC) cones.
iv) Elemental analysis (N,S,P,CI,etc )
v) Moisture content
vi) Pumping chars, and viscosity
i) Melting and boiling points
ii) Volatile metals cones.
iii) Flash points
iv) Elemental ana!ysis(N,S,P,Cl,elc.)
v) Vapor pressures
vi) Optimum desorplion and
destruction temperatures
vii) Moisture content
i) TOC (oils, TPH, humie material , etc.)
ii) Grain size distribution
iii) Soluble salts
iv) Cation Exchange Capacity (CEC)
i) Indigenous microorganisms
ii) Degradation rates
iii) Solubility
iv) Nutrient requirements and existing
conditions of pH, temp,, oxygen,
moisture, etc.
v) Depth to ground water and
thickness of contaminated zone
vi) Permeability of the soil
i) Indigenous microorganisms
ii) Degradation rates
iii) Solubility
iv) Nutrient requirements and existing
conditions of pH, temp., oxygen,
moisture, etc.
i) Heavy metals cone.
ii) Reactivity at high pH
iii) Elemental analysis (N,P,S,CI, etc.)
iv) Redox potential
v) TOC, humic material and clay content
i) Solubilities and partition coefficients
ii) Grain size distribution
iii) TOC and humic material content
iv) Cation Exchange Capacity (CEC)
JPiTocessConstRimlsaad.l-owtauMs '\
i) High moisture content
ii) High alkali metals soil
iii) Elevated levels of mercury,
organic phosphorus
nO-Volume «3000-,5000 cu-ydsi - .
i) High boiling points over 500°F
(260°C)
ii) Elevated levels of halogenated
organics
iii) Presence of mercury
iv) Corrosivity
i)TPH>I%
ii) Humic matter <20%
i) Toxic metals, chlorinated
organics, pH outside 4.5-9,
limiting growth factors
ii) Ambient temp, below I5°C
iii) Short lime/growth season
iv) Rainfall/evapotranspiration
rate/percolation rate ratios too high
or too low
v) Limiting initial and final cones.
i) Lack of indigenous microbes
ii) Toxic metals, highly
chlorinated organics, pH
outside 4.5-9, limiting growth
factors
iii) See also "ln-situ", above
i) Heavy metals and excess soil moisture
(>20%) may require special treatment
ii) High organic and clay content may
extend reaction time
i) High hydrophobic TOC and humic
material content inhibits detergency
ii) >30% silt and clay particles cancels out
volume reduction benefit of process
iii) Surfactant solutions may cause
operating problems

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 REFERENCES

 Contaminants and Remedial Options at Wood Preserving Sites. USEPA, ORD, RREL, September 1992

 Approaches for Remediation of Uncontrolled Wood Preserving Sites. EPA/625/7-90/011, USEPA Office of Environmental
 Research Information, Cincinnati, OH 45268, November 1990

 "Creosote Contaminated Sites-Their potential for bioremediation," Environmental Science & Technology. Vol. 23.-No. 10. p.
 1197-1201,1989

 Superfiind LDR Guide #6B. Obtaining a Soil and Debris Treatability Variance for Removal Actions. Superfund Publication
 9347.3-068FS, USEPA, OSWER, September 1990

 Guide for Conducting Treatabilitv Studies Under CERCLA:  Aerobic Biodegradation Remedy Screening - Interim Guidance.
 EPA/540/2-91/013A, USEPA, ORD, July 1991

 Guide to Treatment for Hazardous Wastes at Superfiind Sites. EPA/540/2-89/052, USEPA Office of Environmental Engineering
 and Technology Development, March 1989

 Removal Program Representative Sampling Guidance. Volume 1: Soil. USEPA. OERR Publication 9360.4-10, November, 1991

Removal Program Representative Sampling Guidance. Volume 4:  Hazardous Waste - Interim Final OSWER Directive Document
in Preparation by USEPA, OERR, June 1992

Innovative Treatment Technologies:  Overview and Guide to Information Sources. EPA/540/9-91/002, USEPA OSWER, TIO,
October 1991

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 APPENDIX A - U.S. Waste Exchanges
 CALIFORNIA WASTE EXCHANGE
 Robert McCormick
 Department of Health Services
 Toxic Substances Control Division
 400 P Street
 Sacramento, CA 95812
 (916)324-1807

 INDIANA WASTE EXCHANGE
 Environmental Quality Control
 1220 Waterway Boulevard
 P.O. Box 1220
 Indianapolis, IN 46206
 (317)232-8188

 INDUSTRIAL MATERIAL EXCHANGE
 SERVICE
 Diane Shockey
 2200 Churchill Road, #31
 Springfield, IL 62794-9276
 (217)782-0450
 FAX: (217) 782-9142

 INDUSTRIAL MATERIALS EXCHANGE
 Bill Lawrence
 172 20th Avenue
 Seattle, WA 98122
 (206) 296-4899
 FAX: (206) 296-0188

 PACIFIC MATERIALS EXCHANGE
 Bob Smee
 1522 No. Washington St.
 Suite 202
 Spokane, WA 99205
 (509)325-0551
 FAX: (509) 325-2086
NATIONAL WASTE EXCHANGE NETWORK
 1-800-858-6625

RENEW
Hope Castillo
Texas Water Commission
P.O. Box 13087
Austin, TX 78711
(512)463-7773
FAX: (512) 463-8317
 INDUSTRIAL WASTE INFORMATION
 EXCHANGE
 William E. Payne
 New Jersey Chamber of Commerce
 5 Commerce Street
 Newark, NJ 07102
 (201)623-7070

 MONTANA INDUSTRIAL WASTE
 EXCHANGE
 Don Ingles
 Montana Chamber of Commerce
 P.O. Box 1730
 Helena, MT 59624
 (406) 442-2405

 NORTHEAST INDUSTRIAL WASTE
 EXCHANGE
 Lewis M. Cutler
 90 Presidential Plaza
 Suite 122
 Syracuse, NY 13202
 (315)422-6572
 FAX: (315) 422-9051

 SOUTHEAST WASTE EXCHANGE
 Maxi May
 Urban Institute
 Dept. of Civil Engineering
 Univ. of North Carolina
 Charlotte, NC 28223
 (704) 547-2307

 SOUTHERN WASTE INFORMATION
 EXCHANGE
 Gene Jones
 P.O. Box 960
 Tallahassee, FL 32313
(904)644-5516
FAX: (904) 574-6704

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United States       Office of         Directive: 92OO. 5-1 62.
Environmental Protection Solid Waste and    EPA/54O/R-95/T 28
Agency           Emergency Response PB 95-96341O
               Washington. DC 2O46O
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                                        1
                                        9
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S upertund
Presumptive Remedies for
Soils, Sediments, and Sludges
at Wood Treater Sites

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Presumptive Remedies: Policy and Procedures                                  http://www.cpa.gov/oerrpage/superfund/resources/presump/pol.htm



                         ttei*dSf*»*                  Office of             Directive: 9355.0-47FS
                                                  Solid Waste and        EPA 540-F-93-047
                                                  Emergency Response     PB93-963345
                                                                    September 1993
                                Presumptive  Remedies:
                                Policy  and Procedures
            Office of Emergency and Remedial Response                            Quick Reference Fact Sheet
            Hazardous Site Control Division 5203G
            Since Superfund's inception in 1980, the remedial and removal programs have found
            that certain categories of sites have similar characteristics, such as types of
            contaminants present, types of disposal practices, or how environmental media are
            affected. Based on information acquired from evaluating and cleaning up these sites,
            Superfund is undertaking an initiative to develop presumptive remedies to accelerate
            future cleanups at these sites. The presumptive remedy approach is one tool of
            acceleration within the  Superfund Accelerated Cleanup Model (SACM).

            The objective of the presumptive remedies initiative is to use the program's past
            experience to streamline site investigations and speed up selection of cleanup actions.
            Overtime presumptive remedies are expected to ensure consistency in remedy
            selection and reduce the cost and time required to clean up similar types of sites.
            Presumptive remedies are expected to be used at all appropriate sites except under
            unusual site-specific circumstances. EPA plans to develop a series of directives on
            presumptive remedies for various types of sites.

            This directive serves as an overall guide to the presumptive remedies initiative and its
            effect on site cleanup. Through a question and answer format, it explains, in general
            terms, ways in which presumptive remedies will streamline or change the remedial
            and removal processes from the conventional processes and how certain Superfund
            policies will be affected by the initiative. This directive also unites the series of
            directives, due to  come out over the next year, on presumptive remedies for specific
            site types (e.g., Volatile Organic Compounds (VOCs), wood treaters, ground water).
            This general directive, together with the site type-specific directives, will provide
            readers with a comprehensive knowledge of the procedural as well as policy
            considerations of the presumptive remedies initiative. The directive is designed for
            use by staff involved in  managing site cleanups (e.g., Remedial Project Managers
            (RPMs), On-Scene Coordinators (OSCs), Site Assessment Managers (SAMs)). Site
            managers in other programs, such as RCRA Corrective Action, the Underground
            Storage Tank program, State Project Managers, or private sector parties, may also
            use this directive,  as appropriate.


            Provided below are several common questions and answers regarding general issues associated
            with presumptive  remedies.
                                                                                              5/19/99 6:29 PM

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  Presumptive Remedies: Policy and Procedures                                    http://www.epa.gov/oerrpage/supcrfund/resources'presump/pol.htni


               QI.       What Are Presumptive Remedies and How Should They Be Used?
               A.        Presumptive Remedies are preferred technologies for common categories of sites,
                         based on historical patterns of remedy selection and EPA's scientific and engineering
                         evaluation of performance data on technology implementation. EPA has evaluated
                         technologies that have been consistently selected at past sites using the remedy
                         selection criteria set out in the National Oil and Hazardous Substances Pollution
                         Contingency Plan (NCP); reviewed currently available performance data on the
                         application of these technologies; and has determined that a particular remedy, or set
                         of remedies, is presumptively the most appropriate for addressing specific types of
                         sites.

                         Presumptive remedies are expected to be used at all appropriate sites. The
                         approaches described in each presumptive remedies directive are designed to
                         accommodate a wide range of site-specific circumstances. In some cases, multiple
                         technologies are included (e.g., VOCs); in others, various components of the
                         presumptive remedy are optional, depending on site situation (e.g., municipal
                         landfills). Further, these directives recognize that  at some sites, there may be unusual
                         circumstances (such as complex contaminant mixtures, soil conditions, or
                         extraordinary State and community concerns)  that may require the site manager to
                         look beyond the presumptive remedies for additional (perhaps more innovative)
                         technologies or remedial approaches.

                         These tools will help site managers to focus data collection efforts during site
                         investigations (e.g., remedial investigations, removal site evaluation) and significantly
                         reduce the technology evaluation phase (e.g., Engineering Evaluation/Cost Analysis
                         (EE/CA) and/or Feasibility Studies (FS)) for certain categories of sites. The specific
                         impacts on the various stages of the remedy selection process are highlighted in
                         questions 7 and 8 of this guidance. It is advised that presumptive remedies be used
                         with the assistance of the expert teamsi for the various categories of sites,


              Q2.        Why Should Presumptive Remedies Be Used?
              A.        Presumptive remedies are expected to have several benefits. Limiting the number of
                        technologies considered should promote focused data collection, resulting in
                         streamlined site assessments and accelerated remedy selection decisions which
                        achieve time and cost savings. Additional time  savings could be realized during the
                        remedial design since early knowledge of the remedy may allow technology-specific
                        data to be collected upfiront during the remedial investigation. Presumptive remedies
                        will also produce the added benefit of promoting consistency in remedy selection,
                        and improving the predictability of the remedy  selection process for communities and
                        potentially responsible parties  (PRPs).

                        Presumptive remedies may be  used as part of a wide variety of response actions.
                        These actions include non-time-critical removal and early remedial actions, actions at
                        sites with different leads (e.g., Fund-lead, State-lead, PRP-lead),  actions addressing
                        one or  more contaminated media, actions with  several operable units, and actions
                        involving treatment trains.
2oflO                                                                                             5/19/99 629PM

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 Presumptive Remedies: Policy and Procedures                                   Http://www.epa.gov/oerTpage/superfiind/resources/presump/pol.htm


              Q3.       Can Presumptive Remedies be Implemented Within the Existing NCP Process?
              A.         Yes. The presumptive remedy approach is consistent with all of the requirements of
                         the NCP, and in particular the site management principle of streamlining (see section
                         300.430(a)(l)(ii)(C)). The presumptive remedy approach simply consolidates what
                         have become the common, expected results of site-specific decision making at
                         Superfund sites over the past decade. The various presumptive remedies directives
                         and supporting documentation (e.g., "Feasibility Study Analysis for CERCLA Sites
                         with Volatile Organic Compounds in Soils") provide the basis for an administrative
                         record which justifies consideration of a very limited number of cleanup options.
                         These materials summarize the findings of EPA's research and analysis, and the
                         reasons that were found for generally considering certain technologies more or less
                         appropriate.

                         The availability of presumptive remedies does not preclude a Region from expanding
                         the FS (either on its own initiative or at the suggestion of outside parties) to consider
                         other technologies under unusual site-specific circumstances. The site type directives
                         will define the kind of circumstances (e.g., soil conditions, heterogeneous and
                         complicated contamination mixtures, field tests demonstrating significant advantages
                         of alternate or innovative technologies, etc.) that may make presumptive remedies
                         less clearly suited for particular sites. Most of these directives also provide references
                        to additional technologies if the presumptive remedies are found not to apply  at a
                        particular site.


              Q4.       How Did the Presumptive Remedies Initiative Evolve?
              A.        The general concept of presumptive remedies was first proposed in 1990 during the
                        Superfund 90-Day Study and subsequently in 1991 during the 30-Day Study as a
                        method of accelerating the remedial  process. These management studies were efforts
                        to generate options for accelerating the overall Superfund clean-up process. The
                        presumptive remedies initiative is also consistent with, and supports, a larger
                        program initiative known as the Superfund Accelerated Cleanup Model (SACM).
                        SACM incorporates the experience gained from past Superfund actions into an
                        integrated approach to site cleanup aimed at getting response action decisions made
                        and implemented more quickly. The presumptive remedies initiative is one
                        mechanism for accomplishing the broad streamlining goal set forth by SACM. The
                        presumptive remedies initiative was also identified as one  of the Administrative
                        Improvements to Superfund in June of 1993.


                                                    Table 1
                                 Current Presumptive Remedies and Contacts
3 o{ !0                                                                                            5/19/99 6-29 PM

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  Presumptive Remedies Policy and Procedures
http://www.epa.gov/oerrpage/superfiind/resources/presump/pol.htrri
                   Site Type/Schedule          Presumptive Remedy(ies)          ij Anticipated Products              ! EPA Contact
                                                 , , .     	    ....    .•"..,	        5     	

                   General Policy and Procedures .  NA                           ;| Presumptive Remedies:             \ Shahid Mahmud
                   (9/93)                                                  :: Policy and Procedures              I Headquarters,
                                                                         i!                               ! HSCD
                                          :                               |i                               1(703)603-8789

                   Volatile Organic Compounds  i  Soil Vapor Extraction, Thennal        ;j Presumptive Remedies: Site          \ Shahid Mahmud
                   (VOCs) in Soils            :  Desorption, Incineration             :l Characterization and Technology      I Headquarters,
                   (9/93)                   :                               '^Selection for CERCLA Sites with VOCs  i HSCD
                                                                         tin Soils                         =(703)603-8789

                   Wood Treaters              For Organics - Incineration,          \\ Presumptive Remedy: Wood Treating   j Lisa Boynton
                   (6/94)                     Bioremediation, Dechlorination        I Sites                           I Headquarters, ERD
                                            For Inorganics - Immobilization        I                               j (703)603-9052
                                                                         I Technology Selection Guide for Wood   j
                                                                         I Treater Sites (5/93)                I Harry Alien
                                                                         j                               I Emergency
                                                                                                        : Response Division
                                                                                                        1(908)321-6747

                   Municipal Landfills           Containment (could include capping,    \PresumptiveRemedyforCERCLA      i Andrea McLaughlin
                   (9/93)                    leachate collection and treatment, LF    \MunicipalLandfillSites             j Headquarters,
                                           gas treatment, institutional controls,     i                               j HSCD
                                           etc.)                           I                               I (703) 603-8793

                   Contaminated Ground Water  ;  Pump and Treat                   j TBD                           \ Ken Lovelace
                   (1/94)                  ;  (Will specify preferred treatment       j                               I Headquarters,
                                           technologies & describe overall       ij                               j HSCD
                                           approach)                      jj                               j (703)603-8787

                   Region 7 Pilots - PCB Sites,     TBD                          j TBD                           I Diana Engeman
                   Coal Gas Sites, Grain Storage                                 i                               j Region?
                   Site(6/94)              .      .                         ij                               1(913)551-7746



                   KEY:
                   TBD - To Be Determined
                   NA - Not Applicable
                 Q5.        What Other Presumptive Remedy Initiatives are Underway or Planned?
                 A.          There are a variety of presumptive remedy activities currently planned or underway.
                             Table 1 lists the site types with the anticipated schedule of associated presumptive
                             remedy products that are currently underway along with the Headquarters and
                             Regional contacts. There are four site types for which presumptive remedies are
                             being developed in EPA Headquarters: VOCs, wood treaters, municipal landfills, and
                             contaminated ground-water sites. Concurrently, Region 7 is preparing presumptive
                             remedy guidances for PCB, coal gasification, and grain storage sites.
                                                                Table 2
                                          Generic Effect of Presumptive Remedies
4 of JO
                                                                                                                     5/19/99 6:29 PM

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 Presumptive Remedies. P-licy and Procedures
http://www.epa.gov/oenpage/su perfund/resources/presump/po).htm
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              Q6.        How Will Presumptive Remedies Affect the Remedy
              A.          Presumptive remedies are anticipated to affect several phases of the current remedy
                          selection process. A diagram depicting the generic impacts on the overall process is
                          provided in Table 2.

                          Data collection during the initial site assessment (Preliminary Assessment/Site
                          Inspection (PA/SI) or Removal Site Evaluation) can be used to help define the
                          specific site type and to determine whether presumptive remedies may be potentially
                          applicable.

                          Assuming the site warrants further attention (i.e., it is listed on the National Priorities
                          List (NPL) or determined by the Regional Decision Team (RDT) to be an
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  Presumptive Remedies: Policy and Procedures                                    http://www.epa.gov/oerrpage/superfund/resources/presump/pol.htm
 •                                                                           *

                          NPL-caliber site or to merit a removal action), further confirmation of the site type
                          should take place as either an RI/FS or EE/CA is scoped to determine whether the
                          site is a potential candidate for presumptive remedies. For a detailed discussion of
                          how to make this determination, refer to the appropriate site type-specific directive.
                          If it is determined that a site falls into a certain category, the presumptive remedies
                          associated with that site type should be included in the list of likely remedial
                          alternatives (e.g., no action, presumptive remedies, etc.) for the site. Other aspects of
                          scoping that may be affected by presumptive remedies are the designation of
                          appropriate operable units (OUs) and identification of data needed to support the
                          evaluation and selection of a presumptive remedy.

                          Presumptive remedies are expected to help focus data collection efforts. Specifically,
                          initial data collection would focus on confirming the site type. If the site is of the
                          type for which presumptive remedies have been developed, the streamlined steps for
                          site characterization outlined in the site type-specific directive for the particular site
                          type should be followed. These steps outline data collection to determine the extent
                          of contamination and to support selection of the presumptive remedy and  Remedial
                         Design (RD).

                         Presumptive remedies will streamline the FS and the alternatives analysis in the
                         EE/CA more than any other phase of the remedy selection process. In most cases,
                         after a site is confirmed as being a type for which presumptive remedies exist, a
                         focused FS or EE/CA which eliminates the technology identification and screening
                         step would be prepared. The study would limit its consideration to the no  action
                         alternative and the presumptive remedy technologies. This is possible because EPA
                         has conducted an analysis of potentially available technologies for most of the
                         presumptive remedies site categories and has determined that certain technologies
                         are routinely and appropriately screened out either on the basis of effectiveness,
                         implementability, or excessive cost (NCP Section 300.430 (e)(3) and (7)), or have
                         not been selected under the nine criteria analysis identified in NCP  Section 300.430
                         (e) (9). This detailed analysis will serve to substitute for the development and
                         screening of alternatives phases of the FS (and will allow the remaining alternatives
                         to be limited to variations of the presumptive remedy). The site-specific directive and
                         supporting documentation (e.g., "Feasibility Study Analysis  for CERCLA Municipal
                         Landfill Sites") along with this directive then can be placed in the administrative
                         record for the site to support the elimination of the screening step identified in
                         section 300.430 (e) (1) of the NCP. Further supporting materials can be provided by
                         Headquarters (e.g., FS reports included in the analysis, technical reports), as needed.
                         The specific presumptive remedy directives address the process of eliminating the
                        alternatives development and screening step of the RI/FS or EE/CA in further detail.
                        The directives also provide generic discussion of a partial nine criteria analysis
                        (excluding state ARARs and community and state acceptance) and  may help
                        streamline the detailed analysis of alternatives within the FS and EE/CA reports.
                        However, the user is cautioned that the criteria are discussed on a general basis and
                        the nine criteria analysis should be supplemented to reflect the site-specific
                        .conditions.

                        The.Proposed Plan (PP) and subsequent ROD would be similarly streamlined by
                   .     focusing only on the presumptive remedy(ies). The remedial  design (RD) may te  ---
                        streamlined since some RD data will likely have been collected previously during the


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 Presumptive Remedies: Policy and Procedures                       .            http://www.epa.gov/oerrpage/superfiind/resources/presump/pol.htn.


                         site assessment and RI.
              Q7.       How Will Presumptive Remedies Affect the Removal Process?
              A.         Non-time critical removal actions are anticipated to be used more often to
                         accomplish early actions at Superfund sites under SACM. The presumptive remedies
                         approach will focus the data collection during the removal site evaluation and reduce
                         the number of technologies identified and analyzed in the EE/CA. Presumptive
                         remedies are not expected to have an impact on emergency and time-critical actions
                         under the removal program.
              Q8.       What are the Implications of Presumptive Remedies for Innovative
                        Technologies?
              A.        The NCP in section 300.430 (a) (1) (iii) (E) states that "EPA expects to consider
                        using innovative technology when such technology offers the potential for
                        comparable or superior treatment performance and implementability, fewer or lesser
                        adverse impacts than other available approaches, or lower costs for similar levels of
                        performance than demonstrated technologies." The use of the presumptive remedies
                        may tend to reduce the frequency of the full evaluation of innovative technologies.
                        However, as indicated previously, the presumptive remedies provide a tool for
                        streamlining the remedy selection process. They do not preclude the consideration of
                        innovative technologies should the technologies be demonstrated to  be as effective or
                        superior to the presumptive remedies. Innovative technologies may be evaluated and
                        recommended in addition to the presumptive remedies where these criteria are met.

                        EPA encourages review of the latest Innovative Technologies Semi-Annual Reports
                        or Engineering Bulletins for the up-to-date information on the potential effectiveness
                        and applicability of various innovative technologies. Site managers are strongly
                        encouraged to involve the site-type expert team (see Question 13) to determine
                        whether unusual circumstances exist to consider a non-presumptive remedy based on
                        site-specific conditions and/or community, state, and PRP concerns,  or the
                        availability of a potentially promising innovative technology.
             Q9.       How Will Presumptive Remedies Affect Risk Assessments?
             A.         Generally, the role of baseline risk assessments under the presumptive remedy
                        approach would be unaffected with Municipal Landfill sites being a notable
                        exception. It is anticipated that risk assessments would still be needed on a
                        site-specific basis to assist site managers in determining the need for a response
                        action. EPA managers have indicated the value of the risk assessment in
                        communicating with states, PRPs, and local communities about the nature and extent
                        of health and environmental threats. Therefore, it is recommended that the current
                        risk assessment process be continued on an individual site basis except for Municipal
                        Landfills. The site manager should refer to the EP.A Directive entitled "Presumptive
                        Remedy for CERCLA Municipal Landfill Sites," Directive No. 9355.0-49FS to
                        identify streamlining opportunities at Municipal Landfill sites.
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  Presumptive Remcdie«' Policy and Procedures                                    http://www.epa.gov/oeirpage/superfand/resources/presump/pol.htm
      »    •

                         Guidance on developing risk-based preliminary remediation goals (PRGs) would be
                         unaffected under this initiative. These goals are needed for individual sites especially
                         in the absence of ARARs to assist in determining which remedial options will result
                         in medium-specific chemical concentrations that are protective of human health. For
                         example, there may be several candidate presumptive remedies identified in the
                         site-type directives. But it is the extent and degree of contamination across a given
                         site that will determine whether a technology, which is predicted to reduce a
                         chemical's concentration to some specified level, will be adequate by itself to
                         produce protective concentrations following remedial action. For some sites or site
                         locations, because of the magnitude of contamination or co-occurrence of
                         contaminants, it may be necessary to assemble several technologies into a treatment
                         train to adequately reduce levels of all chemicals of concern in a medium to
                         protective levels. In other cases, it may be necessary to evaluate the use of
                         institutional and/or engineering controls on an area following remediation to ensure
                         protection during subsequent land use. In other words, it is not reasonable to assume
                         that because a specific technology resulted in "protection" at one site, it will result in
                         protective levels at all sites. A determination that the selected remedy will result in
                         protection of human health and the environment must be made for each site. Both
                         ARARs and risk-based PRGs are important tools in this exercise.

                         Generally, presumptive remedy directives will specify those technologies that have
                         been determined to achieve levels protective  of human health and the environment
                         under a variety of site conditions. However, because all sites differ to some extent,
                         especially in their relation to surrounding •communities and sensitive ecosystems, a
                         determination must still be made on a site-specific basis as to how a given remedy
                         design is expected to achieve "protectiveness" during remedy construction and
                         following remedial action. Overall protection of human health and the environment is
                         one of two threshold considerations (the other being compliance with ARARs) that
                         must be met in order for an alternative to be eligible for selection as the remedy for a
                         given site.
              Q10.      What if Outside Parties such as PRPs or the Community Want Other
                        Alternatives Considered?
              A.        The identification of a presumptive remedy does not relieve EPA of the obligation to
                        propose the remedy for public comment, or to respond to comments suggesting that
                        other alternatives should have been considered. In some cases, the information in the
                        site-type directive and supporting documentation may be sufficient to address such
                        comments; in others, additional analysis may be required to assess the relative merits
                        of an alternative technology proposed by a commenter.

                        To reduce the risk of delay due to the need to respond to such comments, it is
                        generally desirable to publicize the planned use of presumptive remedies early on,
                        and give States, communities, PRPs, and others an early opportunity to express any
                        concerns they may have about focusing the FS or EE/CA in this way. The agency
                        may then decide whether to include additional alternatives in the FS or EE/CA so
                        that those concerns can be addressed before the remedy is proposed.

                        In general, it is expected that the directive and supporting documents will provide


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 Presumptive Remedies: Policy and Procedures                                   http://www.epa.gov/oerrpage/superfVjnd/resources/presump/pol.htn.


                         substantial justification for preferring the presumptive remedy over alternative
                         technologies. Therefore, the submission of comments advocating other approaches
                         does not necessarily require broadening of the FS or EE/CA, or conducting
                         additional analysis after the plan has been proposed. Whether additional
                         documentation is required will depend upon how substantial or persuasive the
                         comments are (e.g., whether a comment identifies unusual site circumstances that
                         seriously call into question the applicability of the presumptive remedy). The Region
                         will have to assess this by evaluating each comment on its own merits.

                         It should be noted that even if the FS is broadened to consider alternatives other than
                         the presumptive remedy, much of the benefit of the presumptive remedy approach
                         can still be achieved. In such cases, it is not necessary to address the full array of
                         possible technologies, rather only the presumptive remedy and the specific
                         alternative(s) that genuinely warrant detailed study. Therefore, the FS can still be
                         narrowed and data gathering can still be focused.


              Ql 1.       How do State ARARs Affect the Use of Presumptive Remedies
              A.         Any remedy, including presumptive remedies, must be selected in accordance with
                         Section 121(d) (2)(A)(ii) of the Comprehensive Environmental Response,
                        Compensation and Liability Act (CERCLA), which specifies that selected remedial
                        actions comply with promulgated standards under Federal and more stringent State
                        environmental laws (i.e., State ARARs). At this time it is difficult to predict
                        situations where presumptive remedies will not comply with State ARARs, and  such
                        issues must necessarily be addressed on a site-specific basis. However, as the
                        presumptive remedies have been widely selected, they are likely to be capable of
                        meeting State ARARs.


              Q12.      What Are the Implications of Presumptive Remedies on Community, PRP, and State
                        Relations?
              A.         It will generally be desirable to notify the community, State, and PRP(s) as early in
                        the clean-up process as possible that presumptive remedies are being considered for
                        the site. This notification can take the form of a fact sheet, a notice in  the newspaper,
                        and/or a public meeting in which the site manager (with assistance from the expert
                        team, as desired) explains the rationale for taking such actions and distributes the
                        appropriate directives of the site type in question. Additionally, the site manager
                        should explain the potential benefits associated with the use of presumptive remedies
                        such as time  and cost savings, and consistency. Early discussions about the rationale
                       for presumptive remedies should help instill confidence in both the technologies  and
                       remedy selection processes.


             Q13.     How Will EPA Communicate Progress on Current Presumptive Remedies,
                       Newly Developed Presumptive Remedies, and Future Issues Related to
                       Presumptive Remedies?
      • -   .A.        Information about presumptive remedies wilLbe communicated in several ways. First, --•:
                       it is anticipated that an orientation will be provided to communicate the key elements


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                          of presumptive remedies to Regional site managers as appropriate. This may be
                          followed by periodic meetings with expert teams, if necessary, to scope out the
                          applications of presumptive remedies on a site-specific basis. The expert team may
                          also be used to convey any new developments on technology or policies and
                          procedures for general or specific applications. A quarterly conference call is also
                          anticipated between site managers and the expert teams to allow for the exchange of
                          ideas and to identify and resolve technical issues.  Technology selection directives,
                          SACM Bulletins, and Q&A directives will be published periodically to disseminate
                          information on presumptive remedies and related  issues as they arise. Finally, the
                          presumptive remedies directives on the various site categories will be updated every
                          several years to reflect new technology development and up-to-date performance
                          data, as appropriate.
                    'it is envisioned that for most categories of sites, teams of experts (technical, legal, policy, etc.) who
                    have developed the presumptive remedies guidance and Regional site managers conducting field
                    demonstrations, will be available to assist site managers in implementing presumptive remedies on a
                    site-specific basis.
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               I Notice:

              jj The policies set out in this document are intended solely as guidance to the U.S.
              •\ Environmental Protection Agency (EPA) personnel; they are not final EPA actions and do not
               I constitute rulemaking. These policies are not intended, nor can they be relied upon, to create
               I any rights enforceable by any party in litigation with the United States. EPA officials may
               i decide to follow the guidance provided in this document, or to act at variance with the
               I guidance, based on an analysis of specific site circumstances. EPA also reserves the right to
               I change the guidance at any time without public notice.
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United States       Solid Waste and
Environmental Protection  Emergency Response
Agency	(5305W)
 EPA540-R-98-025
OSWER9205.5-15A
   PB98-963 233
    June 1998
   RCRA5 Superfund & EPCRA
        Hotline Training Module
    Introduction to:
       Superfund Accelerated
           Cleanup Model
          Updated February 1998

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                                         DISCLAIMER

This document was developed by Booz-Allen & Hamilton Inc. under contract 68-WO-0039 to EPA. It is
intended to be used as a training tool for Hotline specialists and does not represent a statement of EPA
policy.

The information in this document is not by any means a complete representation of EPA's regulations or
policies. This document is used only in the capacity of the Hotline training and is not used as a reference
tool on Hotline calls. The Hotline revises and updates this document as regulatory program areas change.

The information in this document may not necessarily reflect the current position of the Agency.  This
document is not intended and cannot be relied upon to create any rights, substantive or procedural,
enforceable by any party in litigation with the United States.
                        RCRA, Superfund & EPCRA Hotline Phone Numbers:
          National toll-free (outside of DC area)
          Local number (within DC area)
          National toll-free for the hearing impaired (TDD)
(800) 424-9346
(703)412-9810
(800) 553-7672
                         The Hotline is open from 9 am to 6 pm Eastern Time,
                          Monday through Friday, except for federal holidays.

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           SUPERFUND ACCELERATED CLEANUP MODEL

                               CONTENTS


1.  Introduction	  1

2.  Elements of SACM	  5
   2.1 Site Assessments	  5
   2.2 Early and Long-term Actions	  6
   2.3 Enforcement	  8
   2.4 Public Participation	  9
   2.5 Regional Decision Teams	  9

3.  Presumptive Remedies and Response Strategies	11

4.  Module  Summary	15

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                                                                        SACM - J
                           1.  INTRODUCTION


The Superfund program has been both praised and criticized for how it addresses
abandoned hazardous waste sites.  One of the most effective parts of the program is
the CERCLA statutory enforcement provisions that force polluters to  pay.  On the
other hand, one  of the major criticisms has been that site assessments, response
actions, and enforcement have been costly and slow.  In 1980, when CERCLA was
enacted, Congress did not anticipate the number of uncontrolled hazardous waste
sites that actually exist.  With reauthorization in 1986, Congress amended CERCLA
enhancing the response process, enforcement provisions, public participation
provisions, and increasing the appropriations to 8.5 billion dollars to meet the needs
of the program.  Several factors that drove costs up at Superfund sites include
extended site assessments with duplicative sampling efforts, litigation with
potentially responsible parties (PRPs), and lengthy remedy selection analyses. These
factors, as well as others, contribute to the public's perception that the Superfund
program was inefficient.  In April 1992, EPA responded to these shortcomings by
introducing the Superfund Accelerated Cleanup Model (SACM).  SACM streamlines
the traditional Superfund response process that was established by Congress in
CERCLA, as amended by SARA. SACM does not change the regulations for the
traditional site evaluation process, but rather makes administrative changes to the
traditional approach, while remaining consistent with existing response regulations
outlined in the National Contingency Plan (NCP).

The  main goals of SACM are:

   •   Non-duplicative site assessment
   •   Prompt risk reduction
   •   Cross-program coordination of response planning
   •   Early initiation of enforcement activities
   •   Early public notification and participation.

After successfully implementing the SACM process at several pilot sites, EPA
announced its expectations to use  SACM at all Superfund sites (OSWER Directive
9203.1-13).

In addition to SACM, EPA is developing other tools, such as presumptive remedies
and  response strategies, to speed up the response process. Presumptive remedies are
used for sites with similar conditions and contamination.  These presumptive
remedies are technologies that have been selected repeatedly at a preponderance of
certain types of Superfund sites. For instance, certain technologies have been
consistently selected during the past decade for wood preserving facilities; therefore,
instead of following a lengthy remedy selection process for each site,  the lead agency
may decide to examine just a few of the pre-designated presumptive remedies for
wood preserving facilities. Presumptive response strategies are more
   The information in this document is not by any means a complete representation of EPA's regulations or policies.
                     but is an introduction used for Hotline training purposes.

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 2 -SACM
comprehensive than presumptive remedies in that they address all components of
the response process, rather than just the remedy selection.

This module presents the primary aspects of SACM compared to the traditional
Superfund response process.  These two approaches to the Superfund response
process are illustrated in Figure 1. In addition, this module discusses presumptive
remedies by covering what they are, and providing an overview of the guidance
EPA has developed.

After you have completed this module, you should be able to:

   •  Explain how SACM streamlines the traditional response process

   •  Be familiar with the terms of the response process as renamed by SACM

   •  Explain what presumptive remedies are and provide examples.

Use this list of objectives to check your knowledge after the training session on
SACM and presumptive remedies.
  ine information in tnis document is not by any means a complete representation of EPA s regulations or policies.
                    but is an introduction used for Hotline training purposes.

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                                                                                           SACM -
                                           Figure 1
     THE TRADITIONAL SUPERFUND PROCESS VS. THE SACM PROCESS
     Enfofcarnant
       State
     Parttfcatlon/
     Community
      Halations
                   Curent Superfund
                        Process
                          Site
                       Discovery
                 Preliminary Assessment (PA)
                    Site Assessment (SI)*
                 Expanded Site Inspection (ESI)
                         1
                Hazard Ranking System (HRS)
                 National Priorities List (NPL)
       I
Remedial Investigation (Rl)
  Feasibility Study (FS)'
Selection ol Remedy/
Record ol Decision (ROD)
\
1

Remedial Design 1
(RD) 1
*
Remedial Action
(RA)

1
{
Operation and 1
Maintanance (OAM) 1
f
NPL
Deletion

1
                • Mteam anaumant pha*a of
                                        Superfund Accelerated
                                         Cleanup Model (SACM)
                                                             Site Screening &
                                                              Assesssment
                                                             (PA, Si. ESI. Rl)
                                                                           Long-
                                                                            Term
                                                                           Action
                                                                          Complete
The information in this document is not by any means a complete representation of EPA's regulations or policies.
                       but is an introduction used for Hotline training purposes.

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•   4 -SACM
    J ne inlormauon in this document is not by any means a complete representation of EPA's regulations or policies,
                            but is an introduction used for Hotline training purposes.

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                                                                        SWVl-5
                         2.   ELEMENTS OF SACM


To streamline the traditional Superfund approach, SACM reorganizes and
restructures various components of the response process. In particular, SACM
integrates the numerous Superfund site assessments to create a single, more
efficient evaluation.  SACM also redefines the traditional removal and remedial
actions as early actions and long-term actions, thereby achieving quicker risk
reduction and a more effective, final  site cleanup.  EPA also continues to highlight
rapid enforcement actions and a high level of public participation  as an integral part
of SACM.  To oversee effective implementation of its new approach, SACM uses the
expertise of Regional Decision Teams (RDTs).  This section further describes these
key aspects of SACM.
2.1   SITE ASSESSMENT

Prior to SACM. Superfund site evaluations followed a series of discrete, redundant
steps.  EPA often performed evaluations under the removal program (preliminary
assessments (PAs), and site inspections (Sis)), and the remedial program (PAs, Sis,
Hazard Ranking System scores (HRS), remedial investigations (RIs)) separately,
without considering information gathered under preceding evaluations.  Thus, each
evaluation potentially required separate contracts, equipment, sampling teams,
sampling strategies, and health and safety plans.  This resulted in inefficient use of
time and money that reflected negatively on the  program in the eyes of both
Congress and the public.

SACM accelerates the response process by integrating evaluations using both
removal and remedial authority.  Before beginning an assessment, EPA predicts the
data needs based on the expected response. For example, if EPA believes the
contamination is extensive enough to warrant a  site's inclusion on the NPL, data
can be collected simultaneously for the HRS (to determine if the site will be placed
on the NPL) and for the RI/FS (to select an appropriate remedy).  If possible, one
continuous site evaluation with one report is conducted at each site  (OSWER
Directive 9203.1-03). For more guidance on site assessment and the SACM process.
refer to Assessing Sites Under SACM — Interim Guidance (OSWER  Directive
9203.1-051).

The following fictional examples provide an illustration of the traditional site
assessment versus the SACM  integrated assessment.

Example la: Traditional Superfund Site Assessment:
   EPA receives a public request to assess an old chemical manufacturing facility
   containing thousands of leaking barrels in an unlined lagoon. A contractor
   performs a removal PA and the site is placed in CERCLIS.  The contractor then
   conducts a removal SI to determine the need for a removal. The SI confirms
                                         _^	^^^^^.^^^^^^^
   The information in this document is not by any means a complete representation of EPA's regulations or policies,
                     but is an introduction used for Hotline training purposes.

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  6 -SACM
    that the soil and water are extremely contaminated, and EPA removes the barrels
    to minimize immediate threats.  A year after completion of the removal, EPA
    initiates the remedial SI and begins to collect data for the HRS. The site is placed
    on the NPL and the RI/FS begins.  Three years later, after completion of the
    RI/FS, remedy selection, and remedial design, EPA initiates the remedy.  Five
    years have elapsed from discovery of the site to implementation of the remedy.

 Example Ib: SACM Integrated Site Assessment:
    EPA receives a public request to  assess the same chemical manufacturing facility.
    After initial data gathering,  the Agency  believes the contamination will warrant
    the site's inclusion on the  NPL. A contractor collects data to determine whether
    a removal action is necessary, to calculate the HRS score, and to select a remedy.
    The CERCLA and NCP requirements for the removal and remedial PA and SI,
    the HRS ranking, and the  RI/FS  are all met in a single site evaluation with a
    single report. The barrels are removed, the site is placed on the NPL, and the
    remedial action begins.  Two and a half years have elapsed from the site's
    discovery to implementation of the remedy.

 The integration of the various site evaluations under the two programs, and the
 anticipation of the site's NPL  listing, reduced the cost and  duration of the response
 by two and a half years.
 2.2   EARLY AND LONG-TERM ACTIONS

 Since CERCLA created only two response authorities, remedial and removal, two
 separate cleanup programs evolved. Because all Superfund cleanup actions are
 required to use one of these authorities, EPA placed all sites into one of the two
 programs and the programs operated separately. SACM, instead of directing sites
 under one of the removal or remedial programs, uses both authorities together to
 conduct early and long-term actions.

 EARLY ACTIONS

 The duration of an early action should generally be less than five years. The goal of
 an early action is to quickly reduce threats to human health and the environment.
 This may require that more than one early action be taken at some sites.  An early
 action operates under either removal or remedial authority.  Emergency removals,
 time-critical responses, and non-lime-critical responses are early actions taken under
 removal authority. Early remedial actions are performed under remedial authority.
 Depending on the type of action, different statutory and regulatory requirements
 must be met for Fund-lead sites. For instance, except in  special circumstances.
 removal authority can only be used for  actions requiring less than 2 million dollars
 and 12 months. State assurances, a record of decision (ROD), and identification of
 applicable  or relevant and appropriate requirements (ARARs) are required for early
 remedial actions, just as they are for traditional remedial actions. An early action
	*
   The information in this document is not by any means a complete representation of EPA's reguladons or policies,
                     but is an introduction used for Hotline training purposes.

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                                                                        SACM - 7
can occur in conjunction with a long-term action at a site. This is referred to as a
"phased approach" and ensures a site is cleaned up as quickly and effectively as
possible. Examples of early actions are given in Figure 2.

LONG-TERM ACTIONS
 i

EPA expects long-term actions to take longer than five years to complete. They may
occur at sites where high remedy implementation costs exist, or when long-term
operation and maintenance activities (e.g., groundwater monitoring) are necessary.
Long-term actions follow the NCP remedial process requirements, including NPL
listing, a Rl/FS, and a ROD.  Examples of long-term actions are given in Figure 2.
For more information on both early  and long-term actions see Early Action and
    !-term Action Under SACM - Interim Guidance (OSWER Directive 9203.1-051).

                                    Figure 2
                TYPES OF EARLY AND LONG-TERM ACTIONS
    Early Action
           Either
      Long-Term Action
Access Restrictions
Source Removals
Source Containment
Surface Structures
Source Remediation
Capping/Containment
Relocation
Source Extraction
Alternate Water Supply
Property Acquisition
Groundwater Plume Cleanup
Plume Containment
Extensive Source Remediation
Groundwater Restoration
Surface Water Restoration
The following fictional examples illustrate how early actions and long-term actions
require less time and resources than traditional removal and remedial actions.

Example 2a: Traditional Response Process:
   A work crew discovers a small (e.g., three-acre) abandoned landfill while
   constructing an apartment complex in a residential area where the community
   relies on groundwater as its primary source of drinking water.  A removal PA/SI
   determines that, to reduce immediate threats, the contaminated soil must be
   excavated and removed. Further, to prevent contaminated groundwater from
   reaching nearby drinking water aquifers, the removal contractor installs three
   extraction wells. Later in the remedial SI, EPA personnel decide to collect data
   for an HRS score, as well as for the RI/FS to select a long-term remedy. As part of
   this remedy, a second  contractor excavates an additional, deeper layer of soil to
   eliminate the source of contamination.  During the RI, EPA determines that the
   extraction wells installed under the removal program did not meet all ARARs,
   and were not situated to extract the entire plume of contaminated groundwater.
   The remedial contractor therefore installs four more wells, for a total  of seven.
  The information in this document is not by any means a complete representation oitPA s regulations or policies,
                    but is an introduction used for Hotline training purposes.

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 8 -SACM
    The contaminated groundwater plume is extracted and treated and the aquifer is
    returned to its beneficial use.

 Example 2b: SACM Process:
    At the same site, an integrated site assessment provides HRS and RI/FS data, and
    helps EPA determine that it must remove the surface layer of contaminated soil
    under time-critical authority, and a deeper layer of contaminated soil with an
    early remedial action.  One contractor simultaneously removes both of these
    layers.  Also, as a removal action, the contractor drills three extraction wells to
    protect the drinking water sources.  The wells meet all ARARs and are
    strategically placed such that only one more well is needed for the long-term
    remedial action.  These four wells extract the contaminated groundwater plume,
    and the aquifer returns to its beneficial use.

 In this scenario, EPA used removal and remedial authorities together to consolidate
 steps in the cleanup process and provide an equal measure of protection and
 remediation.  A more efficient remedial design saved time and money.
2.3   ENFORCEMENT

SACM continues to emphasize EPA's "enforcement first" policy. Thus, EPA must
initiate potentially responsible party (PRP) searches and negotiations as early as
possible. However, because response actions under SACM may begin sooner, there
is a greater need to expedite PRP searches so that response actions may begin.  To
preserve valuable resources. Regions must be careful to expedite PRP searches only
at sites that may need a remedial response. Thus, the timing of searches is very
important, and EPA must have a clear strategy to conduct PRP searches.

In order to  conduct PRP searches more quickly, SACM encourages the use of a
phased PRP search that focuses on establishing the liability of, and negotiating with,
those PRPs who are easily found. Once EPA identifies the core group of PRPs, the
PRPs can lead the  response, with EPA oversight.  Involvement with PRPs whose
liability is too costly or time-consuming (e.g., extensive litigation is necessary) to
establish may be delayed until after initiation of the response action.
  The information in this document is not by any means a complete representation of EPA s regulations or policies,
                    but is an introduction used for Hotline training purposes.

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                                                                       SACM - 9
2.4   PUBLIC PARTICIPATION

EPA's experience has shown that early and frequent communication with local
communities can enhance a site response; this is particularly true under SACM.
Because SACM is a new and unfamiliar approach to cleanup, public outreach and
education are crucial to obtaining public support.  EPA must continue to involve
the public as early as possible throughout all stages of the response process.
Integrated site assessments and early actions, however, may have community
involvement requirements that differ  from traditional  requirements.  For example,
because the  NCP requires that the administrative record be made available when the
RI/FS begins, a site undergoing a combined SI/RI/FS will require earlier
establishment  of an administrative record.
2.5   REGIONAL DECISION TEAMS

If SACM is to successfully decrease the time and money spent under the Superfund
program, a creative and informed approach is needed for each site.  To ensure solid
decisions are made, an experienced and knowledgeable team of experts, typically
called a Regional Decision Team (RDT), has been formed in many of the Regions.
The goals of the RDT are effective coordination, communication, and integration of
program authority, expertise, and resources to implement wise and consistent
decisions at Superfund sites.

Regions have flexibility both in establishing and selecting the members of the RDT.
Some Regions may have more than one team while some may not establish a  RDT
as a method to implement SACM. Members may include state officials, on-scene-
coordinators (OSCs), remedial project managers (RPMs), community involvement
coordinators, and site and risk assessors. Once selected, the RDT develops rules that
apply to all sites in the Region including criteria for selecting response actions and
PRP search methods.  Strategies for communicating with Headquarters, states, and
support agencies, such as the Department of Justice, are created, and a plan for
integrating site evaluations is  formed.

Although the day-to-day operations of each site remain the responsibility of the site
managers, the RDT can  play a major role in site-specific decisions.  The Team
prioritizes sites in the Region by addressing the worst sites first, and decides how
early and long-term actions should be  used at each site. The RDT may provide
policy and strategic direction to site managers, sign RODs or action memoranda, and
determine which sites are of NPL caliber so the RI/FS can be included in the
integrated site assessment.  In  addition, the RDT ensures that response actions  are
fully consistent with the requirements contained in CERCLA and the NCP. For
more information  on SACM's RDT mechanism see SAGM Regional Decision
Teams'- Interim Guidance (OSWER Directive 9203.1-051)
   The information in this document is not by any means a complete representation of EPA's regulations or policies,
                     but is an introduction used for Hotline training purposes.

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10 -SACM
 The information in this document is not by any means a complete representation of EPA s regulations or policies.
                         but is an introduction used for Hotline training purposes.

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                                                                        SACM- II
     3.  PRESUMPTIVE REMEDIES AND RESPONSE STRATEGIES
 Presumptive remedies are a key component of SACM.  They represent a way to
 streamline remedy selection based on experience at certain types of sites.  Before
 SACM, EPA presumed that each site on the NPL was unique and required a site-
 specific review of remedial alternatives.  EPA has now learned from experience that
 many sites have similar contaminated media, types of wastes, or historical
 industrial practices, and as a result, will most likely require use of similar
 technologies in the remedy. By adopting technologies consistently selected at the
 majority of similar sites,  presumptive remedies ensure  that a site is cleaned up
 faster, while still remaining consistent with the NCP's  intent of protecting human
 health and the environment. Also, since the Agency anticipates using presumptive
 remedies at appropriate sites, remedy selection is expected to be generally more
 consistent across the nation.

 EPA identified several categories of sites where presumptive remedies are
 appropriate:  municipal solid waste landfills (MSWLFs); sites with volatile organic
 compounds (VOCs) in soils, sediments, and sludges; and woodtreater sites.
 Presumptive remedy guidance exists for all of these types of sites and is under
 development for sites with metal contamination.

 For certain types of sites or contaminants, EPA believes  a broader approach, a
 "comprehensive response strategy," is more appropriate.  To date, only a
 presumptive response strategy for sites with groundwater has been developed.  EPA
 is currently contemplating a comprehensive response strategy for manufactured gas
 plant (MGP) sites. The discussion below provides details of existing and future
 presumptive remedies.

 MUNICIPAL SOLID WASTE LANDFILLS

 In September 1993, EPA selected a presumptive remedy for MSWLFs, which
 constitute approximately 20 percent of all NPL sites (OSWER Directive 9355.3-18FS).
 Because treatment is usually impracticable at such sites, the presumptive remedy is
 a containment remedy which includes the following components as appropriate on
 a site-specific basis: capping to contain the contamination, collection and treatment
 of the gas and leachate, containment of the contaminated  groundwater plume, and
 the use of institutional controls to supplement engineering controls. Since all of
 these actions are demonstrated methods of reducing the risk at MSWLFs, they are
 now a part of a multi-component presumptive remedy  for MSWLFs.

The containment presumptive remedy also takes into account the possibility that
 hot spots, e.g., drums containing principal threat wastes, may need to be addressed.
EPA decides whether the combination of the waste's physical and chemical
characteristics and volume is such that the integrity of the new containment system
will be threatened if the waste is left in place. If so, the hot spot may need to be

  The information in this document is not by any means a complete representation of EPA's regulations or policies,
                    but is an introduction used for Hotline training purposes.

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 12 -SACM
 treated or excavated prior to construction of the landfill cap. This presumptive
 remedy does not address exposure pathways outside the landfill, and does not
 provide a long-term remedy for groundwater restoration. More guidance on the
 presumptive remedy for municipal waste landfills is found  in Presumptive Remedy
 for CERCLA Municipal Waste Landfill Sites (OSWER Directive 9355.0-49FS).

 SITES WITH VOCs IN SOILS

 Over the years, EPA conducted numerous remedial actions at sites with VOC
 contamination. This wealth of experience allowed EPA in September 1993, to
 identify three preferred technologies based on a comprehensive ROD analysis.
 These treatment methods - soil vapor extraction, thermal desorption, and
 incineration of the contaminated soil - comprise the presumptive remedy for sites
 with VOC contamination. The first remedy, soil vapor extraction, removes VOCs by
 passing air through the soil. Thermal desorption  heats the soil until the VOCs are
 vaporized and collected for treatment.  Incineration decomposes VOCs at high
 temperatures. Except under unusual circumstances, one of  these remedies should
 be used at a site with VOC contamination.  More  information on this presumptive
 remedy is found in Presumptive Remedies: Site Characterization and Technology
 Selection for CERCLA  Sites with Volatile Organic Compounds in Soils  (OSWER
 Directive 9355.0-48FS).

 WOOD THEATER SITES

 As EPA gained experience at sites contaminated by wood treatment processes, four
 treatment technologies  emerged as the most frequently selected. The Agency
 selected these technologies as the presumptive remedies for  wood treater sites in
 December 1995.  Three  of the technologies are for treatment  of organic
 contaminants, and one is for treatment of inorganic  contaminants.  If organic
 contaminants are present at the site, bioremediation, which  is the chemical
 degradation of organic contaminants using microorganisms, is the primary remedy.
 Thermal desorption 'or incineration are also options  for treatment of organic
 contaminants. The presumptive remedy for wood treater sites with inorganic
 contamination is immobilization.  Immobilization traps the chemical in place,
 either by solidifying it (e.g., with a  cement), or stabilizing it (i.e., chemically binding
 it to its surroundings).  Sites with both organic and inorganic contamination use a
 series of organic and inorganic treatments called a treatment train.  For more
 guidance on wood treater sites, see Presumptive Remedies for Soils. Sediments, and
 Sludges at Wood Treater Sites  (OSWER Directive 9200.5-162).

 GROUNDWATER CONTAMINATION

Initially, EPA did not anticipate the extent and types of groundwater contamination,
 nor the complexity of subsurface conditions found at Superfund sites. Since
approximately 85 percent of Superfund sites have  contaminated groundwater, EPA
decided it necessary to create a remedy selection guidance. Because of the complexity

  The information in this document is not by any means a complete representation of EPA's regulations or policies,
                    but is an introduction used for Hotline training purposes.

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                                                                        SACM -13
of these sites, there is no single technology that is appropriate for all sites with
groundwater contamination.  Therefore, in October 1996, EPA created a presumptive
response strategy instead of a presumptive remedy.  Because it is difficult and time-
consuming to fully characterize the subsurface nature of a site, a recurring problem
at groundwater contaminated sites was that remedies were selected without
sufficient data.   Thus, a major part of the  presumptive strategy is the phased
approach, which allows data collected from initial assessment phases to be used to
further characterize the  site. Thus, the remedy is selected using more accurate and
complete information. EPA also outlined  methods for deferring the selection of, or
refining,  a remedy after the ROD is signed. Finally, the Agency selected several
presumptive technologies for treatment of extracted groundwater.  See Presumptive
Response Strategy and Ex-Situ Treatment Technologies For Contaminated Ground
Water at CERCLA Sites (OSWER Directive 9283.1-12) for  more guidance.

FUTURE PRESUMPTIVE REMEDIES AND RESPONSE STRATEGIES

Only the metals in soils presumptive remedy remains to be completed.  EPA
considered developing additional presumptive remedies, including one for sites
with PCB contamination, but found remedies for those other categories of sites
already stipulated through other program regulations; thus no new presumptive
remedies are currently anticipated.  The current focus for this initiative is on
appropriately using existing presumptive  remedies.  EPA's Technology Innovation
Office is currently developing a presumptive response strategy for manufactured gas
plant sites.
  The information in this document is not by any means a complete representation of EPA's regulations or policies
                    but is an introduction used for Hotline training purposes.

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14 -SACM
 i SIR information in tins
                     document is not by any means a complete representauon of EPA s regulations or policies,
                        but is an introduction used for Hotline training purposes.

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                                                                       SACM -15
                         4.  MODULE SUMMARY
EPA created SACM to reduce the time and money spent at Superfund sites, while
continuing to protect human health and the environment.  Instead of conducting a
series of separate site assessments, SACM integrates them into one continuous site
assessment with one report, if possible. Also, where EPA once categorized all
actions as either remedial or removal, the Agency now conducts early and long-
term actions using either authority. This allows for earlier remedial actions and
earlier risk reduction. EPA continues to use an enforcement first policy, and
attempts to begin enforcement procedures as soon as possible under SACM. Public
perception of SACM is a high priority, thus the involvement of the public at all
stages of the response is absolutely necessary.

The SACM process is coordinated by RDTs comprised  of EPA and state  personnel
experienced in early and long-term actions, site assessment, enforcement, and
community relations.

The presumptive remedy initiative under SACM promotes the use of cleanup
technologies historically shown to be effective at similar types of sites. To date, EPA
has published presumptive remedies for municipal landfills, sites with  VOC
contamination, and wood treater sites, as well as-a presumptive response strategy for
groundwater contamination.
  The information in this document is not by any means a complete representation of EPA s regulations or policies,
                    but is an introduction used for Hotline training purposes.

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 ^ K
x>  EPA
                         United States
                         Environmental Protection
                         Agency
                                   Office of
                                   Solid Waste and
                                   Emergency Response
 Publication 92OO.3-23F5
      EPA540/F-96/018
           PB96-963245
	September 1996
The  Role  of Cost in the
Superfund  Remedy  Selection  Process
Office of Emergency and Remedial Response
                                                       Quick Reference Fact Sheet
            This fact sheet describes the role of cost in the selection of remedial actions under the Comprehensive
    Environmental Response, Compensation, and Liability Act (CERCLA, commonly referred to as Superfund}. Cost is
    a central factor in all Superfund remedy selection decisions. The objective of this fact sheet is to clarify the current
    role of cost as established in existing law, regulation, and policy. This fact sheet does not elevate or establish a new
    role for cost in the Superfund program, but rather describes the current role of cost as established by the Superfund
    statute (CERCLA) and the Superfund regulations (the National Oil and Hazardous Substances Contingency Plan
    (NCP)),  and as expanded upon in EPA guidance.

            Through the  distribution  of this fact sheet, EPA hopes to ensure that all stakeholders involved in the
    Superfund process fully understand the important role that cost plays in remedy selection under existing law and policy,
    and to summarize recent initiatives aimed at enhancing the cost-effectiveness of remedial actions. These initiatives
    include the National Remedy Review Board, Remedy Selection Rules of Thumb, and Updating Remedy Decisions.
    O  STATUTORY AND REGULATORY
    CONTEXT FOR THE CONSIDERATION
    OF COST

           Understanding the role  of cost  in  the
    Superfund remedy  selection process  requires  an
    understanding  of  the  statutory  and regulatory
    provisions that  guide this  process.    CERCLA
    established  five  principal  requirements  for  the
    selection of remedies. Remedies must:

    1)     Protect human health and the environment;

    2)     Comply with applicable  or relevant and
           appropriate requirements (ARARs) unless a
           waiver is justified;

    3)     Be cost-effective;

    4)     Utilize permanent solutions and alternative
           treatment technologies or resource recovery
           technologies   to   the  maximum  extent
           practicable; and

    5)     Satisfy a  preference for  treatment as  a
           principal element, or provide an explanation
           in the Record of Decision (ROD) why the
           preference was not met.
                                    The   NCP   sets    forth    the   Remedial
                                Investigation/Feasibility Study (RI/FS)  process for
                                gathering the information necessary to select a remedy
                                that is appropriate for the site and fulfills these
                                statutory mandates. The RJ includes sampling and
                                analysis to characterize the nature and extent of site
                                contamination,  performance of  a  baseline  risk
                                assessment to assess the current and potential future
                                risks to human health and the environment posed by
                                that contamination, and the conduct of treatability
                                studies to evaluate the potential costs and effectiveness
                                of treatment or recovery technologies in reducing the
                                toxicity, mobility, or volume of specific site waste.
                                The FS includes the development and screening of
                                alternative  remedial  actions,  and  the   detailed
                                evaluation  and  comparison of the final candidate
                                cleanup options.  Typically, a range of options is
                                developed during the FS concurrently with the RI site
                                characterization, with the results of each  influencing
                                the other in an iterative fashion.

                                    The NCP also lays out a two-step selection
                                process, in which  a preferred remedial action is
                                presented to the public for comment in  a Proposed
                                Plan, which summarizes  preliminary conclusions as to
                                why that option  appears most favorable based on the
                                information available and considered during  the FS.
                                Following  the  receipt  and evaluation  of public
                                comments on the Proposed Plan, which may  include
                                new information (e.g.,  a fuller view of  community

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 input on the options, new information on technology
 performance),  the  decision  maker  makes  a final
 decision and documents the selected remedy in a ROD.
 For a general discussion of this process, see EPA's
 "Guidance for Conducting Remedial Investigations
 and  Feasibility  Studies  Under  CERCLA  Interim
 Final," OSWER Directive 9355.3-01, October 1988,
 and "Guide to Selecting Superfund Remedial Actions,"
 OSWER Directive 9355.0-27FS, hereinafter referred to
 as the  RI/FS Guidance and  the  Remedy  Selection
 Guidance, respectively.

     In addition to the items discussed in more detail
 below, it is important to keep in mind that remedial
 action costs are influenced, in general, by the quality
 of the conceptual site model (CSM), which is a three-
 dimensional "picture" of site conditions that illustrates
 contaminant  distributions,  release  mechanisms,
 exposure pathways, migration routes, and potential
 receptors.  The CSM documents current site conditions
 and is  supported by maps, cross sections,  and site
 diagrams that illustrate what is known about human
 and environmental exposure  through contaminant
 release and migration to  potential receptors.  It is
 initially developed during the scoping phase of the
 RI/FS,  and  modified  as additional  information
 becomes available.  Careful evaluation of site risks,
 incorporating reasonable assumptions about exposure
 scenarios  and  expected  future land  use,  and the
 definition   of  principal  threat  waste  generally
 warranting treatment, help to prevent implementation
 of costly  remediation  programs  that may  not  be
 warranted.

    In addition, EPA expects that the appropriately
 consistent application of existing national policy and
 guidance will result in  the selection of cost-effective
 remedies.   Guidance  that promotes cost-effective
 decision making includes  the  Presumptive  Remedy
 series, Soil Screening  Guidance, and  Land Use
 Guidance.   For  more information,  see  OSWER
 Directives 9355.0 - 47FS, 9355.4-14FSA, and 9355.7-
 04, respectively.
© CONSIDERATION OF COST
DURING THE DEVELOPMENT AND
SCREENING OF ALTERNATIVES

    During the first step of the FS, a range of remedial
alternatives is developed and then screened in order to
identify those alternatives that  should be considered in
more detail. Cost estimates developed for each option
comprise the short- and long-term cost of remediation,
including capital costs (e.g., the costs to put remedial
technology in place, including those for equipment,
 labor, materials, and services), and the annual costs s/f
 operations and maintenance (O & M) for the entire
 period during which such activities will be required.
 Costs should be discounted to a common base year to
 evaluate expenditures over time.  A discount rate of
 seven percent before taxes and after inflation should be
 used to account  for the time value of money  (see
 "Revisions to OMB Circular A-94 on Guidelines and
 Discount Rates for Benefit-Cost Analysis," OSWER
 Directive  9355.3-20,  June 25,  1993).    A more
 complete description of remedial action cost estimating
 can be found in the RI/FS Guidance.
 Development of Alternatives

     In  elaborating  the  RI/FS  process, the  NCP
 instructs decision makers on how to implement both
 the  mandate to utilize permanent solutions  and
 treatment to the maximum extent practicable and the
 requirement to select remedial actions that are cost-
 effective.    Specifically, the NCP establishes the
 program  goal  and expectations found  at 40 CFR
 300.430(aXl)(iii) (See Exhibit 1). These expectations
 identify the appropriate methods of protection  which
 generally  should  guide the development of cleanup
 options for common types of site  situations,  while
 allowing flexibility to modify these expectations to take
 into account truly unique site circumstances.

     The NCP states that the overall goal of the remedy
 selection  process  is "to select  remedies that are
 protective of human health and the environment, that
 maintain  protection  over time,  and  that minimize
 untreated waste" (40 CFR 300.430(a)(])(i)).  This goal
 reflects CERCLA's  emphasis on treatment as the
 preferred method of protection. However, recognizing
 that CERCLA  tempers  its emphasis on permanent
 solutions and treatment  through the addition of the
 qualifier "to  the maximum extent practicable," and
 also contains the co-equal mandate for remedies to be
 cost-effective, the NCP goes on to slate  that,  in
 general, "EPA expects to use treatment to address the
 principal threats posed by a site, wherever practicable.
 Principal threats for which treatment is most likely to
 be appropriate  include liquids, areas contaminated
 with high concentrations of toxic  compounds, and
highly     mobile    materials"    (40     CFR
300.430(a)(l)(iii)(A)) (see "A Guide  to Principal
 Threat and Low Level Threat Wastes," Publication
 9380.3-06FS,  November 1991).

    At  the  same  time,  "EPA expects  to use
engineering controls, such as containment, for waste
that poses  a relatively low long-term threat or where
treatment  is impracticable,"  and to combine  these

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                                              Exhibit 1
                                  PROGRAM EXPECTATIONS
         Protection  of human  health  and  the
 environment can be achieved through a  variety of
 methods: treatment to destroy or reduce the inherent
 hazards posed by hazardous substances, engineering
 controls (such as containment), and  institutional
 controls to prevent exposure to hazardous substances.
 The NCP sets out the types of remedies that are
 expected to result from the remedy selection process
 (Sec. 300.430{a)(l)(m)).

 >•   Treat principal threats, wherever practicable.
      Principal threats for which treatment is most
      likely to be appropriate are characterized  as:

     •   Areas    contaminated    with     high
         concentrations of toxic compounds;
     •   Liquids and other highly mobile materials;
     •   Contaminated media  (e.g., contaminated
         ground  water, sediment,  soil)  that  pose
         significant risk of exposure; or
     •   Media      containing       contaminant
         concentrations several orders of magnitude
         above health-based levels.

 >•  Appropriate  remedies  often  will  combine
     treatment and containment. For a specific site,
     treatment of the principal threats(s) may  be
     combined  with  containment  of  treatment
     residuals and low-level contaminated material.

 >•  Containment will be considered for wastes that
     pose a relatively low long-term threat or where
     treatment is impracticable.  These include
     wastes  that are near health-based levels, are
     substantially immobile, or  otherwise  can  be
reliably contained over long periods of time; wastes
that are technically difficult to treat or for which
treatment  is  infeasible  or  unavailable; situations
where treatment-based  remedies would  result in
greater  overall  risk  to  human  health or  the
environment during implementation due to potential
explosiveness,  volatilization,  or other  materials
handling problems; or sites that are extraordinarily
large where the scope of the  problem may make
treatment of  all  wastes  impracticable, such  as
municipal landfills or  mining sites.

>•  Institutional controls  are most useful as  a
    supplement to engineering controls for short-
    and long-term  management.    Institutional
    controls (e.g., deed restrictions, prohibitions of
    well construction) are important in controlling
    exposure during remedial action implementation
    and as a supplement to long-term engineering
    controls.  Institutional controls alone should not
    substitute for more active measures (treatment or
    containment) unless such active measures are
    found to be impracticable.

>•  Innovative technologies should be considered
    if they offer the  potential for comparable or
    superior treatment performance, fewer/lesser
    adverse  impacts, or lower costs  for  similar
    levels  of performance  than demonstrated
    technologies.

>•   Ground  waters  will  be  returned to  their
    beneficial uses wherever practicable within a
    timeframe  that  is  reasonable  given  the
    particular circumstances of the site.
methods   and  use  of institutional  controls,  as
appropriate, at sites with both types of contaminated
materials (40 CFR 300.430
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 whenever practicable, within a time frame  that is
 reasonable given the particular circumstances of the
 site. When restoration of ground water to beneficial
 uses is not practicable, EPA expects to prevent further
 migration of the plume,  prevent  exposure  to  the
 contaminated ground water, and evaluate further risk
 reduction"  (40 CFR  300.430(a)(l)(iii)(F)).   This
 recognizes  that  there  may  be   particular  site
 circumstances  (e.g., DNAPL in fractured  bedrock)
 where complete restoration will not be practicable.

     These Super fund program expectations guide the
 development of remedial alternatives during the FS.
 Although  cost  is  not  a  specific  element  of the
 Supcrfund program expectations, the recognition that
 different   waste   management  approaches  (i.e.,
 combinations   of  treatment,   containment,  and
 institutional controls) may be appropriate at different
 sites depending on the types of threats posed, reflects
 a  "built-in" sensitivity to  the issue of cost  in the
 Supcrfund remedy selection process  (e.g., large sums
 of money should not be spent treating low-level threat
 wastes). These expectations reflect EPA's belief that
 certain source materials are generally addressed best
 through treatment because  of technical uncertainties
 regarding the long-term reliability of containment of
 these materials, and/or the serious  consequences of
 exposure should a release occur.  These expectations
 also reflect the conclusion that other source materials
 generally can be reliably contained.
Screening of Alternatives

    The NCP  describes  cost  as  one  of three
"screening" criteria (the others being effectiveness and
implemcntability)  used  to  identify higher   cost
alternatives that should not be carried forward for
detailed evaluation. Alternatives may be screened out
if they:

1.  Provide  "effectiveness  and   implementability
    similar to that of another alternative by employing
    a similar  method of treatment or engineering
    control,  but  at   greater  cost"  (40  CFR
    300.430(e)(7)(iii)).

2.  Have costs that are "grossly excessive compared to
    [their]   overall    effectiveness"   (40   CFR
    300.430(e)(7)(iii)).   For  example,  the costs
    associated with treating a complex mixture  of
    heterogeneous  wastes  without discrete  hot
    spots   (e.g.,  a  large municipal landfill) would
    likely be considered excessive in comparison to
    the effectiveness of such treatment. As a result, a
     treatment alternative for such a site would likely
     be eliminated from consideration during  the
     screening process.
     Cost estimates at the alternative screening stage
 should  focus  on  relative,  rather  than  absolute,
 accuracy.   At  the  screening stage,  it may also  be
 unnecessary to evaluate costs that are common to all
 alternatives.
 © CONSIDERATION OF COST
 DURING THE DETAILED ANALYSIS
 OF ALTERNATIVES  AND THE
 IDENTIFICATION OF A PREFERRED
 ALTERNATIVE
     The  purpose of  the  detailed  analysis  is  to
 objectively assess the alternatives with respect to nine
 evaluation  criteria  that  implement the  statutory
 provisions of CERCLA section  121.  This analysis
 consists of an individual evaluation of each alternative
 with respect to each criterion, and  a comparison  of
 options designed to determine the relative performance
 of the alternatives and identify major trade-offs among
 them (i.e., relative advantages and disadvantages) with
 respect to the same factors.

     The decision maker uses information assembled
 and evaluated during the detailed analysis in selecting
 a  remedial action.   Cost estimates  at the detailed
 analysis stage should capture all remedial costs and,
 whenever possible, should provide an accuracy of +50
 percent to -30 percent.  Sensitivity  analysis may be
 warranted if a cost estimate might vary significantly
 with relatively  small  changes  in  the underlying
 assumptions, especially those concerning the effective
 life of a remedial action, the O & M costs, the duration
 of cleanup,  site characteristics  (e.g.,  volume  of
 contaminated material), and the discount rate (R//FS
 Guidance, page 6-12).

    The actual  process  of selecting a Superfund
remedy  is  the  decision  making bridge  between
development of remedial alternatives during the FS
and documentation of the selected remedy in a ROD.
The process begins with  the  identification  of  a
preferred  remedial  alternative  from among those
developed in theFS. This preferred alternative is then
presented to the public for comment  in the form of a
Proposed  Plan.   Based  on the  review of public
comments, a final remedy selection decision is made
and documented in a ROD.

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     Cost is  a critical  factor  in the  process  of
 identifying a preferred remedy. In fact, CERCLA and
 the NCP require that every remedy selected must be
 cost-effective.  A brief summary of the relationship
 between the nine remedy selection criteria and the five
 principal statutory remedy selection requirements will
 provide a useful context for a discussion of the role of
 cost in the remedy selection  process.  For a more
 detailed discussion of the nine criteria and the remedy
 selection process  in  general, see EPA's Remedy
 Selection Guidance.
 Relationship Between the Nine Criteria
 and Statutory Requirements for
 Remedy Selection

    During  the  remedy  selection  process,  nine
 evaluation criteria are considered in distinct  groups
 which play specific  roles in working toward  the
 selection of a remedy that satisfies the five principal
 statutory requirements.  The nine evaluation criteria
 include two "threshold"  criteria, five  "balancing"
 criteria (including cost), and two "modifying" criteria
 (state and community acceptance), as illustrated in
 Exhibit 2.  The modifying criteria are considered to the
 extent possible during the process leading up to and
 including the Proposed Plan, and are fully considered
 after public comments on that plan have been received.
 Following receipt   and,  consideration  of  public
 comments, including any new information they might
 contain, the decision maker makes a final  decision
 which is documented in the ROD.

    The first two statutory requirements — protection
 of human health and the environment, and compliance
 with  ARARs (unless a waiver is justified) --  are
 embodied  in the two threshold criteria. A remedial
 alternative must satisfy these two requirements to be
 eligible for further evaluation against the other seven
 factors.

    Advantages and disadvantages of alternatives that
 satisfy the threshold criteria are balanced using the five
balancing criteria, and the two modifying criteria (if
 there  is enough information to consider these latter
criteria  in advance of the formal public comment
process).  This balancing determines which  option
represents  the  remedy  that  utilizes   "permanent
solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent
practicable"  (MEP)  for  that   site   (40  CFR
300.430(f)(])(ii) (E)). The decision maker considers the
statutory preference for treatment  as an "overlay" to
inform and direct this balancing (id.).
     The alternatives are also separately evaluated
 against  a  subset  of  the criteria  to make  the
 determination of which option(s) satisfy the statutory
 cost-effectiveness.  A remedial alternative is cosi-
 effective if its "costs are proportional to its overall
 effectiveness" (40 CFR 300.430(f)(l)(ii)(D)).  Overall
 effectiveness of a remedial alternative is determined by
 evaluating the following diree of the five balancing
 criteria: long-term  effectiveness  and  permanence;
 reduction in toxicity, mobility and volume (TMV)
 through treatment; and short-term effectiveness (See
 Exhibit 3). Overall effectiveness is then compared to
 cost to determine whether the remedy is cost-effective
 (id.).

     Cost considerations are therefore factored into the
 balancing of alternatives in two ways.  Cost is factored
 into  the  determination  of  cost-effectiveness,  as
 described above.  And, cost is evaluated along with the
 other balancing criteria in determining which option
 represents  the practicable extent to which permanent
 solutions   and  treatment  or  resource  recovery
 technologies can be used at the site.  This balancing
 emphasizes  two of  the  five criteria  (long-term
 effectiveness and permanence, and reduction of TMV
 through  treatment)  (40 CFR 300.430(f)(l)(ii)(E)).
 However, in practice, decisions typically will turn on
 the  criteria that distinguish  the  different  cleanup
 options most.  The expectations anticipate some of the
 likely tradeoffs in several common situations, although
 site-specific factors will always play a role.
The Role of Cost in Determining
Whether to Waive ARARs

    Section  121 of  CERCLA specifies  that  all
remedial actions must "meet any Federal standards,
requirements,  criteria   or  limitations   that   are
determined to be legally applicable or relevant and
appropriate requirements." Specific statutes cited in
CERCLA that might present such an ARAR include
the Solid Waste Disposal Act,  the Toxic Substances
Control Act, the Safe Drinking Water Act, the Clean
Air  Act,  the Clean Water Act,  and the  Marine
Protection Research and Sanctuaries Act. In addition
to the Federal ARAR requirement, remedial actions
must meet any applicable or relevant and appropriate
promulgated State standard, requirement, criterion or
limitation if it is more stringent than the corresponding
Federal  requirement.    As previously  discussed,
compliance with ARARs is one of the two threshold
criteria for the selection of a preferred remedy.

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                                            Exhibit 2
                       RELATIONSHIP OF THE NINE CRITERIA
                            TO THE STATUTORY FINDINGS
                       NINE CRITERIA
              PROTECTION OF HUMAN HEALTH
              AND THE ENVIRONMENT


              COMPLIANCE WITH ARARs
              LONG-TERM EFFECTIVENESS
              AND PERMANENCE

              TOXICITY. MOBILITY, OR
              VOLUME REDUCTION
              THROUGH TREATMENT

              SHORT-TERM EFFECTIVENESS
              IMPLEMENTABILITY
              COST
              STATE AGENCY ACCEPTANCE

              COMMUNITY ACCEPTANCE
     PROTECTION OF HUMAN HEALTH
     AND THE ENVIRONMENT
                                                           COMPLIANCE WITH ARARs OR
                                                           JUSTIFICATION OF A WAIVER
     COST-EFFECTIVENESS
     UTILIZATION OF PERMANENT
     SOLUTIONS AND TREATMENT OR
     RECOVERY TO THE MAXIMUM
     EXTENT PRACTICABLE ('MEP')
     PREFERENCE FOR TREATMENT AS A
     PRINCIPAL ELEMENT OR EXPLANATION AS
     TO WHY PREFERENCE NOT SATISFIED
    Cost is not a factor in the identification of ARARs.
However, CERCLA authorizes the waiver of an ARAR
with respect to a remedial alternative if any one of six
bases exist (See Exhibit 4). As described below, cost
may be a  consideration with respect to determining
whether a  technical impracticability, equivalent level
of  performance,  or  Fund-balancing  waiver  is
warranted.

1.  Technical Impracticability

    Cost is relevant to the technical impracticability
waiver, because engineering feasibility  is ultimately
limited by cost.   EPA  has  stated  that cost can be
considered in evaluating  technical impracticability,
although it "should generally play a subordinate role"
and should not be a major factor unless compliance
would be "inordinately costly" (55 FR at 8748, March
8.1990). Thus, the role of cost in evaluating technical
impracticability is more limited than in the general
balancing  of  tradeoffs with respect to the remedy
selection criteria, but cost may be considered in certain
cases.
2.  Equivalent Level of Performance

    This waiver is available when an alternative will
provide a level of performance equivalent to thai
required by the ARAR, but through an alternative
design or method of operation.   While cost is not
considered in evaluating equivalence, this waiver can
provide cost-saving flexibility in  selecting remedies.
Alternative, less expensive technologies that attain the
same outcome (e.g., concentration of residuals) should
be explored before concluding that a  highly costly
approach must be adopted because  it  is an action -
specific ARAR.

3.  Fund Balancing

    For Fund-financed remedies, the fund-balancing
waiver may be invoked when compliance with an
ARAR would not provide a balance between the need
to provide protection at a site and the need to address.
other sites.  EPA's policy is to consider this waiver
when the total cost of a renedy is greater than  four
times the national  average cost of  remediating an
operable unit  (currently, 4x$10 million,  or  $40
million), or in  other cases where "EPA determines

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                                          Exhibit 3
               ELEMENTS OF THE CERCLA REMEDY SELECTION
                     COST-EFFECTIVENESS DETERMINATION
               LONG-TERM EFFECTIVENESS
                  AND PERMANENCE
          MAGNITUDE OF RESIDUAL RISK
          ADEQUACY AND RELIABILITY OF
          CONTROLS
            REDUCTION OF TOXICFTY, MOBILITY,
            OR VOLUME THROUGH TREATMENT
          TREATMENT PROCESS USED AND
          MATERIALS TREATED
          AMOUNT OF HAZARDOUS MATERIALS DESTROYED
          OR TREATED
          DEGREE OF EXPECTED REDUCTIONS IN TOXICITY,
          MOBILITY, AND VOLUME
          DEGREE TO WHICH TREATMENT IS IRREVERSIBLE
          TYPE AND QUANTITY OF RESIDUALS REMAINING
          AFTER TREATMENT
              SHORT-TERM EFFECTIVENESS
          PROTECTION OF COMMUNITY DURING
          REMEDIAL ACTIONS
          PROTECTION OF WORKERS DURING
          REMEDIAL ACTIONS
          ENVIRONMENTAL IMPACTS
          TIME UNTIL REMEDIAL OBJECTIVES
          ARE ACHIEVED
^-  COST-  -^
 EFFECTIVENESS
COST
                     CAPITAL COSTS
                     OPERATIONS AND
                     MAINTENANCE COSTS
                     PRESENT WORTH COST
that  the single site  expenditure  would place a
disproportionate burden on the fund" (55 FR at 8750).
Consideration of Cost in Determining
the Approach to Complying with
ARARs

    Even when waivers are not available, the NCP
provides opportunity for cost-savings in achieving
cleanup goals. For example, the NCP requires cleanup
to relevant and appropriate Maximum Contaminant
Levels (MCLs) and non-zero MCL goals (MCLGs)
when remediating contaminated ground water whose
beneficial use is as a drinking water source. However,
the time frame over which the MCLs must be achieved
may be adjusted, depending on such factors as whether
the  aquifer  is  currently being used or likely to be
needed in the near future. In some cases, allowing for
an extended time frame to achieve cleanup standards
provides the opportunity to develop less intensive,
lower cost alternatives.
O RECENT SUPERFUND REFORMS
THAT PROMOTE COST-
EFFECTIVENESS

    The Administrative reforms announced in October
1995 include several initiatives that are intended, in
part, to control remedy costs and further facilitate the
achievement of cost-effective cleanup.
National Remedy Review Board

    The National  Remedy Review Board  brings
together senior EPA technical and policy experts to
review and make recommendations on proposed
cleanup actions at sites where the estimated cost for the
preferred alternative is more than $30 million, OT more
than $10 million and 50% greater than the cost of the
least costly, protective, ARAR-compliant  alternative.
Regional decision makers are expected  to give  the
Board's recommendations substantial weight. However,
other  important factors may  influence the final
Regional  decision,  such  as public  comment  or
technical analysis of remedial options.  This reform

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 docs not supersede any delegated decision making
 authority.

 Remedy Selection "Rules of Thumb and
 Management Review Triggers"

     Rules of thumb consist  of key principles and
 expectations corresponding to three major policy areas
 in  the remedy selection  process:   assessment and
 management of risk; treatment of principal threats
 versus containment of low-level  threat  waste; and
 ground water response actions. The purpose of this
 initiative is to promote consistent,  reasonable, and
 cost-effective decision making through the appropriate
 application of national  policy and guidance.    In
 addition, EPA is developing  a set of "Management
 Review   Triggers"  that  will flag  senior  EPA
 management attention to specific aspects of proposed
 remedies that should be examined closely to ensure
 they are justified by site-specific conditions. Together,
 rules of thumb and management triggers will become
 part of a standard list of Superfund  issues on which
 Headquarters, Regions and States work together  to
 ensure appropriate application of national policy and
 guidance.

 Updating Remedy Decisions

    The  purpose  of this  reform is  to  encourage
Superfund RODs. These updates are intended to bring
past remedy decisions into line with the current state
of knowledge with respect to remediation science and
technology, and in so doing to improve the cost-
effectiveness of site remediation  while ensuring
reliable protection of human health and the appropriate
changes to remedies selected in existing  environment.
The primary focus of the "Update" reform effort will
be ground water sites, as ground water science has
advanced a great deal since the inception of the
Superfund program.  Three basic types of updates will
be emphasized, although other types of updates are not
excluded: a) where new remediation technology is
available;  b)  where  remediation  objectives  or
approaches need revision; and c) where streamlining
of a ground water monitoring program is reasonable.
                     Exhibit 4


        BASES  FOR ARAR WAIVERS

 1.       The alternative is an interim measure  that will
         become part of a total remedial action that will attain
         the ARAR;

 2.       Compliance  with  the requirement will  result in
         greater risk to human health and the environment than
         other alternatives;

 3.       Compliance  with  the requirement is technically
         impracticable from an engineering perspective;

4.       The alternative will attain a standard of performance
         that is equivalent to that required under the otherwise
         applicable standard,  requirement, or  limitation
         through use of another method;

5.       With respect to a state requirement, the state has not
         consistently applied, or demonstrated the intention to
         consistently apply, the promulgated requirement in
         similar circumstances at other remedial actions within
         the state; or

6.      For  Fund-financed  response  actions  only,  an
        alternative that attains the ARAR will not provide a
        balance between the need for protection of human
        health  and the  environment at the  site and the
        availability of Fund monies to respond to other sites.
 NOTICE: The policies set out in this memorandum are intended solely as guidance. They are not intended, nor can they be relied upon, to create
 any rights enforceable by any party in litigation with the United States. EPA officials may decide to follow the guidance provided in this
 memorandum, or to act at variance with the guidance, based on an analysis of specific site circumstances. The Agency also reserves the right to
 change this guidance at any time without public notice.

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Attachment 2
Selected ROD Summaries
Reflecting Alternate Remedial
Technologies

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                                RODScan
           Utah Power & Light/American Barrel, UT
              DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Utah Power & Light/American Barrel Site, Salt Lake City, Utah

STATEMENT OF BASIS AND PURPOSE

   This decision document presents the selected remedial action for the Utah Power &
Light/American Barrel Site in Salt Lake City, Utah, which was chosen in accordance with
the requirements of the Comprehensive Environmental  Response, Compensation, and
Liability Act (CERCLA),  as amended by Superfund Amendments and Reauthorization
Act of 1986 (SARA), and, to the extent practicable, the National Oil and Hazardous
Substances  Pollution  Contingency Plan (NCP).   This  decision is  based  on the
administrative record for this site.

   The Utah Department of Environmental Quality concurs with the remedy selected by
the U.S. Environmental Protection Agency (EPA).

ASSESSMENT OF THE SITE

   Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response action selected in the Record of Decision (ROD), may
present an imminent and substantial danger to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

   The objective of this Record of Decision (ROD) is to provide a remedy to address all
contamination caused by previous site activities located on the American Barrel Yard and
                                                                              Copyright

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                                    RODScan
adjacent properties which affect  surface  soils,  subsurface  soils, and  groundwater.
Contamination from historical operations and contaminant sources left on-site at the time
of abandonment have migrated into soil and groundwater.  Remediation will  be to the
extent  of contamination  emanating from the American Barrel Yard and Denver Rio
Grande and Western properties.

   The response actions described in this ROD will permanently address all  principal
threats through treatment. Soil contamination will be reduced  to health based levels for
all contaminants of concern. These levels are based on a future industrial use of the site
but will provide for future residential development with acceptable risks  within EPA's
risk range of 10-* to 1O6.  Groundwater remediation levels are based on the Safe Drinking
Water  Act maximum  contaminant levels or acceptable risk levels for future residential
exposure.

       The major components of the selected remedy include:
       Excavation of soils which are principal threats based on visual observation, to the
       extent possible given physical limitations resulting from locations  of existing
       railroad lines, or until the concentrations of EPA target compound list PAHs are
       below 9,000 mg/kg.   The quantification of principal threats is based on EPA
       guidance, "A Guide to Principal Threat and Low Level Threat Wastes" which
       suggests defining principal threats as having a risk of 10~3 or greater.

       Excavation of soils exceeding health based remediation levels, based on a 10-*
       worker exposure, that have a potential exposure pathway. Soils down to a depth
       of 10 feet are considered to have an exposure pathway.

       Treatment of excavated soils through offsite recycling of soils into  a cold mix
       asphalt product suitable for paving roads. Incorporation of contaminated soils as a
       raw material into the asphalt product involves treatment through solidification.

       If any RCRA characteristic hazardous wastes are encountered, these contaminated
       soils will be shipped offsite for incineration and will not be utilized in the asphalt
       treatment process.

       Soil vapor extraction (SVE) will  be used to remediate principal threat light
       non-aqueous phase liquid  (LNAPL) contamination.   Location  of the SVE
       extraction  wells will be based on a principal threat definition where  benzene in
       soils exceeds  10-3 risk levels  for residential exposure  to  groundwater.    In
       conjunction with SVE, groundwater will be extracted from vapor extraction wells
       to enhance the  SVE process.  Off-gas from the SVE system will be treated prior to
       discharge to the atmosphere.

       Groundwater extracted from SVE  wells, water pumped from excavations, and
       decontamination water will be treated  to POTW discharge standards and then
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       discharged to the Salt Lake City POTW for further treatment.

   •   The dissolved  phase aqueous groundwater contamination plume is expected to
       naturally  attenuate  once   the  principal  threat  sources  for  groundwater
       contamination  are remediated.  If monitoring  of groundwater contamination
       indicates that  natural attenuation is  not restoring groundwater  to remediation
       levels, additional source removal or more active groundwater remediation may be
       required.

STATUTORY DETERMINATIONS

   The selected remedy is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant and appropriate
to the remedial action, except certain requirements for RCRA waste piles where a waiver
is appropriate based on 40 C.F.R.  § 300.430(0(1 )(H)(C)(4).  The selected remedy will
attain a standard of performance that is equivalent to that required under the otherwise
applicable standard.   This remedy  is cost effective, utilizes permanent  solutions and
alternative  treatment  and resource recovery  technologies  to  the  maximum extent
practicable, and satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.

   Because this remedy will not achieve the remediation levels for groundwater within
five years, a review will be conducted within five years after commencement of remedial
action to ensure that the remedy continues to provide adequate protection of human health
and the environment.  Five-year reviews will be conducted as required under Section
I21(c) of CERCLA  and 40 C.F.R. § 300.430(f)(4)(ii) of the National Oil and Hazardous
Substances Contingency Plan.
Jack W. McGraw
Acting Regional Administrator
EPA Region
Date 7/7/93
Dianne R. Nielson, PhD
Executive Director
Utah Department of Environmental Quality
Date 7/19/93

                         THE DECISION SUMMARY
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RECORD OF DECISION TEXT
                       I Site Name, Location, and Description

   The Utah Power and Light/American Barrel  Site (UP&L/ABS or the site) is  an
approximately four-acre parcel in Township 1 North, Range 1 West, Section 36 in Salt
Lake City, Utah (Figure 1).  The site is defined as  the American Barrel Yard and the
extent of contamination originating from  past activities on the yard.  The  city block
bounded by North Temple, South Temple, 5th West and 6th West streets is referred to as
the study area.

   The study area is divided into geographic  areas consisting of the American Barrel
Yard (ABY or yard), the Denver and Rio Grande Western Railroad property or Southeast
Area (SEA), the Union  Pacific Railroad property or  Northwest  Area  (NWA),  the
residential area and the industrial area or Deseret Paint Site.  (Figure 2).

   The principal topographic features  of the site are a gentle (1%) slope towards the
Jordan River (one mile to the west) and a surface cut up to 8 feet deep for the Denver and
Rio Grande railroad track along the eastern boundary of the yard.  The railroad track just
outside the western border of the ABY is at grade.

   The ABY boundary is marked by a secured chain link fence; gates are located at the
property's southwest corner  and the middle of its northern edge.  The yard is sparsely
vegetated and while there are no intact buildings or large trees remaining within the
fenced yard, there are several remnants of structures in and around the yard.

   Residential lots and one  light industrial lot are present along the western boundary of
the study area.  Surface features in this area include small buildings, mixed grass and
gravel yards, old shade trees  in some yards, and wood or sheet metal fences.  To the north
lies a vacant lot, formerly an auto wrecking property area, which is partially bounded by a
woven wire fence and covered with sparse vegetation  and bare soil.

   The Union Pacific Railroad Company property comprises the area west and north of
the ABY.  This area is sparsely vegetated  and  the only surface features are the railroad
tracks and overhead lines. Southeast of the ABY is the Denver and Rio Grande Railroad
property.   There are two small buildings in this area used intermittently by railroad
personnel. The lot  is sparsely  vegetated  and  includes stone foundation remnants and
some paved portions along the eastern boundary. The cut for the railroad track exposes
old building  foundations. Gravel-size ballast underlies all of the railroad tracks at this
site.

    City property forms a paved border around all four sides of the study area.  Sixth
West Street receives moderate traffic and forms the western boundary of the study area.
The North Temple Street overpass carries traffic along the'study area's north side, with a
paved but only occasionally used right-of-way at ground level.  The east  and south
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margins of the study area contain railroad tracks just outside the paved right-of-way.

   The nearest population to the site are those residents who live in the homes which lie
200 feet west of the ABY.  There are also a number of .transients who frequent the area.
In the past, transients may have had extensive contact  with on-site  media.  However,
under current conditions, there is a fence around the ABY to discourage trespassers and
little on site which would attract visitors.

Figure 1. SITE LOCATION MAP

Figure 2. MAP OF ABS SHOWING LOCAL PROPERTY OWNERSHIP
ANDPRINCIPAL SOURCE AREAS

                      n Site History and Enforcement Activities

History of Site Activities

   Activities began at the UP&L/ABS  as early as 1873 and continued until 1987.  The
first process to be conducted on the site was coal gasification. The major features of this
operation included coal storage sheds, a gas-o-meter (gas holder), tar wells, a coal tar still,
the gas works (which included the retort house, exhauster room, condenser, lime house,
and tar scrubbers), and the purifying house. The gas plant was located on the American
Barrel Yard, the SEA,  and a portion of the NWA.  Locations of these structures are
depicted on Figure 3.  The gas-o-meter was a buried tank used to store gas  following
production and before metering out to customers.  It was built of 30 inch thick brick
masonry construction topped  with sandstone building  stone.  The process of cooling the
gas produced a tar/water condensate which was separated in the tar well. The tars were
subsequently used as fuel, sold, or managed on site.  The coal gasification plant included
a distillation procedure to separate usable oils from tars.  The final purification step in
coal gasification involved a purifying house.  In this step, the gas was passed through
long, shallow boxes of hydrated iron oxide, thereby producing ferric sulfide.  By the early
190Qs this step was eliminated by switching to  a scrubber technology.

   •• Normal coal gasification procedures produced a variety of by-products having some
commercial value.  These included coke, ammonia, and lighter  tars and sludges which
were sold to refiners or to the public.  Distillation by-products from the refinement of tars
included  toluene,  naphthalene, anthracene,  and phenols.   By-products having  no
commercial value were also produced:  ash, clinkers, heavy tars, sludges, lime sludges,
spent iron oxides, liquid wastes, and steam condensates.  These products were commonly
disposed of in onsite pits  and  offsite landfills.  Coal gasification  operations ceased in
 1908.

    Creosote  pole treating operations were conducted on the ABY and SEA as early as
 1927. Creosote was brought to the site in drums and stored within and just north of the
northeastern corner of the ABY.  Historical information shows there were two pole
dipping tanks on the ABY and possibly one tank on the SEA.  Design plans indicated one
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was a semi-open tank with walls of 12-gage iron and wooden supports, buried six feet
underground, and built on buried concrete walls.  The other was a 400-gallon capacity
steam heated tank used in conjunction with a boiler house and hot well tank to pressure
treat poles in hot creosote. This tank was made of welded or riveted iron walls, painted
with red lead paint (on the outside), and buried at a depth of 8.5 feet underground. It was
tipped at an angle to allow for drainage into six inches  of sand. No identifiable .tank
structures from this operation remain on site.  The specific chemical composition of the
creosote used at this site is unknown.  However, typical  creosQte compounds include a
variety of polycyclic aromatic hydrocarbons (PAHs), phenolic compounds, and nitrogen-,
sulfur-,  and  oxygen-heterocyclic  components.   Locations of former creosote  wood
treating structures are shown on Figure 4.

Figure 3. COMPOSITE OF FORMER COAL GASIFICATION FACILITIES 1873-1908

Figure 4. COMPOSITE OF FORMER CREOSOTE WOOD-TREATINGFACILITIES
1930-1957

    When the pole treating operations ceased, the ABY was used as a storage yard for
55-gallon drums.  Up  to 50,000 drums  were stored at  any one time on virtually all
portions of the ABY except for the yard margins, areas  allowing for vehicles, and the
extreme southwest extension of the crescent-shaped area.  While no cleaning of drums or
recycling of  contents  was reported to have taken place  on  the yard, some barrels
contained residual products and leaks occurred. According to labels found on some of the
drums,  the  variety of contents included: pesticides, solvents,  resins, paints and paint
removers, kerosene, gasoline, acetone, etc.   It is  assumed that the entire  ABY was
vulnerable to leaks and spills of the drum contents.

    Several other activities have  -occurred within  and  immediately adjacent to the
UP&L/ABS study area over the past century which may have had an influence on the
study area  properties.   Some of these operations included:   railroads, Deseret  Paint
Company, W.P. Fuller Oil  Company, a Chevron gasoline station,  Richard J.  Howa
Company underground storage tanks, and the existing Amoco diesel pipeline.

History of Federal and State Site Investigations

    The U.S. Environmental Protection Agency (EPA) Field Investigation Team  (FIT)
conducted a site inspection in May of 1986 in response to discussions with the Utah
Bureau  of Solid and Hazardous Waste (BSHW). The BSHW is currently the Division of
Environmental Response and Remediation (DERR) and is part of the Utah Department of
Environmental Quality (UDEQ) (formerly the Utah Department of Health).  The BSHW
subsequently submitted a Draft  Preliminary  Assessment to the EPA, and  the  EPA
Technical Assistance Team (TAT) observed drum characterization activities at the ABY
being conducted by the American Barrel and Cooperage Company. The FIT followed up
on the TAT observations of stained soils and product-containing drums by completing a
two-phase site investigation in May, 1987 and February,  1988.
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   The FIT collected surface and subsurface soil samples and installed three monitor
wells from which groundwater samples were collected.  Analytical results indicated an
abundance of PAHs and phenolic compounds present on-yard and extending to some
undefined distance off-yard in surface soils. Concentrations of PAHs as high  as tens of
thousands of micrograms per kilogram (aeg/kg) were reported in soil samples.  The FIT
investigation report  also indicated evidence of contamination by some heavy metals
(cadmium, copper, chromium, lead, and zinc) and BTEX compounds (benzene, toluene,
ethyibenzene,  and xylenes).   Chlorinated  pesticides were found in some on-yard soils,
indicating that contamination could have occurred from leaking drums. The investigation
did  not  provide  sufficient data  to permit evaluation of the air  pathway, although
preliminary reports of surface soil contamination indicated that further study  of the air
pathway was warranted.  Due to the diverse, toxic substances reported on many of the
drum labels, FIT recommended further investigation of all media in the study area.

   On-yard groundwater contamination was found consisting primarily of BTEX and
styrene.  Little information was collected to infer the extent of off-yard contamination.
However, groundwater was determined to potentially be a principal pathway of concern.
While the investigation demonstrated contamination of the shallow onsite aquifer, it did
not characterize relationships to underlying or adjacent aquifer material.

   Information provided by the FIT investigation indicated that surface water  was not a
pathway of concern.

   On June  8, 1988 Utah Power and Light entered into an  Administrative  Order on
Consent under the Comprehensive Environmental Response Compensation and Liability
Act (CERCLA), Section 106.  Under this order, Utah Power & Light repaired portions of
the existing fence and installed new fence to completely surround  the yard.  In addition,
they cut down trees and vegetation at the yard.

   The  Utah  Power and Light/American Barrel Site was proposed for  listing on the
National Priorities List (NPL) on  May 5,  1989.  The Site was finalized on the NPL on
October 4, 1989.

   Pursuant to the findings of contamination by the FIT investigation, an Administrative
Order on Consent was entered into by Utah Power & Light requiring them to  conduct a
Remedial  Investigation/Feasibility  Study  (RI/FS)  to  characterize  the  extent  of
contamination and identify alternatives for cleaning up the site. The RI/FS report, which
was  completed in  1993, concluded that the contaminants found at  the UP&L/ABS
generally reflect the  historical activities of the site.  Results of the RI  are presented in
Section V.

   As part of the RI/FS, EPA conducted a baseline risk assessment (BRA) in May of
1992 to estimate potential health and environmental risks which could result if no action
were taken to clean up the site. The BRA indicated that if the site should be developed in
the future, exposure  to groundwater and soil could result in significant risks due to the
contaminants present. Details of the BRA are summarized in Section VI.
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Outcome of Potentially Responsible Party Search

   Under  CERCLA.  a search is conducted to  identify  those  responsible  for  the
contamination in order  to recover monetary compensation  for the costs incurred to
investigate and clean  up the site.  Results of ari historical  investigation are presented
below.

   The coal  gasification plant was first operated by the Salt Lake City Gas Company
from  approximately 1873  until 1893.  This company merged with two other utility
companies in 1893 and became  the Salt Lake and Ogden Gas and Electric Light
Company, which operated the plant until 1897.  Another merger took place in 1897
forming the Union Light and Power Company, which took control of the coal gasification
facility and operated it until 1899.  That same year, Union Light and Power became Utah
Light and Power Company which  had control of the facility  until  1904.  The company
was then reorganized  and merged with  a  railway company to become Utah Light and
Railway Company. The plant was operated under this owner until 1908.

   Railroad lines were present across the ABY and SEA throughout the operations of the
gas plant.  Rail cars were used to haul coal to the gas plant. Figure 3 is a composite from
several plat maps showing the locations of railroad tracks.

   The coal gasification plant ceased operating in 1908. From 1909 through 1929, the
site was utilized as a  storage yard for equipment, wood power poles, and other items.
During this period the site was owned by  Utah Light and Traction and leased by Utah
Power and Light (UP&L) after 1917.

   A creosote pole-treating facility was in  operation in 1927 until the late  1950s. UP&L
was leasing the facility from Utah  Light  and Traction and became the owner after 1944.
The Phoenix Utility Company operated the first pole-treating operation using a "hot-dip"
process to treat utility poles. This process was continued until 1938 when  the operations
were taken over by UP&L, which used a "cold-dip" process until  1957.

   Pole treating operations ceased in 1958 and UP&L leased the crescent shaped yard to
American Barrel and Cooperage, Inc., which used the yard for the storage of 55-gallon
drums awaiting refurbishing at a local facility.  In 1987, Utah  Power &  Light notified
American Barrel of their intention to deny the renewal of their lease (which was to expire
in 1988) and  required  that they remove all barrels and debris  from  the yard.  During the
barrel removal it was apparent that barrel contents had leaked and spilled onto the ground.

   As a result of the historical investigation, the following companies are considered to
be. Potentially Responsible Parties. (PRPs) for the UP&L/ABS and will be  issued Special
Notice Letters:
American Barrel & Cooperage Co.
Salt Lake City, Utah
Utah Power & Light Co.
Salt Lake City, Utah
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Boise Cascade Corporation
Boise, Idaho
Union Pacific Railroad Co.
Salt Lake City, Utah
Denver & Rio Grande Western Railroad
Denver, Colorado
EBASCO Services Inc.
New York, New York
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         South Cavalcade Street Site, Houston, Texas
               DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

South Cavalcade Street Site, Houston, Texas

STATEMENT OF PURPOSE

   This decision document presents the selected remedial action for the South Cavalcade
Street  site  in  accordance  with  the  Comprehensive  Environmental  Response,
Compensation and Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986; and the National Oil and Hazardous Substances Pollutjon
Contingency Plan, 40 CFR Part 300, November 20,1985.

   The State of Texas (through the Texas Water Commission) has been provided an
opportunity to comment on the  technology and  degree of treatment  proposed by the
Record of Decision and has no objection to the  selected remedy (See Appendix D).

STATEMENT OF BASIS

   This decision is based upon the  administrative record for the South Cavalcade site.
The attached index identifies the documents which comprise the administrative record.
(See Appendix E).

DESCRIPTION OF THE REMEDY

   The selected remedy will treat the health- and environmentthreatening contamination
resulting from historical  wood preserving operations at  the site.  Upon review of the
information  contained in the administrative record,  EPA has determined that soil
remediation  using  a combination  of soil  washing and  in  situ soil  flushing and
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groundwater remediation using physical/chemical separation followed by filtration and
activated carbon adsorption best fulfills the statutory selection criteria. Alternatively, if a
potentially responsible party offers to implement an in situ biological treatment process
for groundwater and can demonstrate that this process can be implemented and operated
at an efficiency equal to or better than activated carbon, then this method will be used to
remediate groundwater. The following is a summary of the proposed remedy:

   Soil Remediation: During the initial stages of the remedial design, contaminated soil
areas will be sampled to better define areas which require remediation. All areas will be
remediated which either exceed the risk-based or leaching potential-based remedial goals.
The risk-based  goals is 700 ppm based on ingestion and direct contact  with soils. The
leaching potential-based goal  will be determined  by the  EPA Toxicity Characteristic
Leaching Procedure test. There are approximately 30,000  cubic yards which may need
remediation.

   In the southeast corner of the site, approximately 19,500 cubic yards of contaminated
soils will be excavated and transported  to the  soil washing facility  which will be
constructed in the center portion of the South Cavalcade site. Wash water from the unit
will be treated  for removal of contaminants in the groundwater treatment system. The
cleansed soils will be placed into the excavations and capped to maintain soil stability.

   In the other parts of the site, contaminated soils will be remediated using in situ soil
flushing. The contaminants  which  travel  into the groundwater will be extracted and
treated in the carbon adsorption wastewater treatment system.

   Groundwater Remediation: Groundwater will be  remediated through extraction and
treatment  of contaminated  groundwater,  with reinjection to  increase  the  hydraulic
gradient and flow velocities. Approximately 50 million gallons of groundwater will need
to be  processed several  times to.  recover  and treat the non-aqueous phase liquids.
Groundwater will be treated to  drinking water standards and no detectable carcinogenic
PAHs. Groundwater collection will continue until the groundwater contaminants have
been recovered to the maximum extent possible. This point  will be determined during the
Remedial Action based upon operational experience in using the collection and treatment
system. After this point  is reached, the  groundwater collection will  cease  and any
remaining contamination be allowed to naturally attenuate to background levels.

   Groundwater will  be  extracted and re-injected  in a  series  of  three groundwater
extraction lines and two groundwater injection lines in the southern part of the site, and a
minimum of one extraction line and reinjection line in the northern  part. These wells will
be screened in the shallow aquifer (approximately 10-20 feet below grade) and in the
intermediate discontinuous sand lenses (approximately 50 feet below grade). The actual
number of lines, locations and spacings of wells and well lines will be refined during
remedial design.

   the groundwater will be treated at an onsite wastewater  treatment plant constructed in
the center portion of the  site.  Groundwater will be pumped into a physical/chemical
separator  followed by  a pressure filter and an activated  carbon  adsorption unit. Any
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nonaqueous phase liquids collected and separated from the groundwater will be recycled
as creosote or incinerated offsite. The water will be treated to levels equal to Maximum
Contaminant Levels and no detectable carcinogenic PAHs. Cleansed groundwater will be
reinjected into the aquifer along with surfactants to help recover the contaminants. Any
excess water will be discharged to the drainage ditch leading into the off-site Hunting
Bayou in accordance with an NPDES  permit.

    Alternate Remediation Plan: If a  potentially responsible party  can show that in situ
biological treatment of soil and groundwater will provide equal or better performance and
can further ensure that the implementability questions can be resolved, EPA will consider
this remedial method. In this case, the performance  goals and groundwater extraction
system will be identical to EPA's selected remedy, but the actual method of treatment will
differ. Groundwater will be treated above ground in the physical/chemical separator and
injected with nutrients and oxygen (if necessary). The treated groundwater will be added
to  the contaminated soil  and re-injected to encourage  biological  degradation  of
contaminants under the ground. Any  excess water  will be discharged into the city sewer
system in accordance with a pretreatment permit and treated in a city municipal treatment
plant.

    Operation and Maintenance: The need for future operation and maintenance should be
minimized  since  the primary   sources of contamination will be removed through
treatment. Site operation and maintenance will include  installing a well screened in the
500 foot sand, monitoring  groundwater  wells  and monitoring  ambient  air  during
remediation. The groundwater  monitoring program will continue  for at least 30 years
unless it can be shown during the Remedial Action that some shorter  length of time is
appropriate. This sampling program will monitor the effectiveness of the selected remedy
and provide the data necessary. If the monitoring  shows leaching from soils now under
existing  structures, then the site  will need to  be  revisited  to  determine if  further
remediation is necessary.

    Additional site maintenance would include, but not necessarily limited to, inspections
of surface vegetation, ensuring proper drainage, and proper operation of any actions such
as groundwater  treatment which may extend beyond the  time  required for the source
control remedy. The  details  of these activities will  be defined in the  Operation and
Maintenance Plan of the remedial design. The monitoring  data will be evaluated during
the Agency's 5-year review, in accordance with CERCLA Section 121 (c), to determine if
any corrective action is necessary.

DECLARATION

   .The  selected remedy is protective  of human health and the environment, attains
Federal and State requirements that  are applicable or relevant  and appropriate, and is
cost-effective. This remedy satisfies  the preference for treatment  that reduces toxicity,
mobility or volume as a principal element. Finally,  it is determined  that this remedy
utilizes permanent solutions and alternative treatment technologies  to the maximum
extent practicable.
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Robert E. Layton Jr., P.E.
Regional Administrator
Date: September 26,1988
RECORD OF DECISION TEXT
                     1. SITE LOCATION AND DESCRIPTION

   The South Cavalcade Street site is located in northeast Houston, Texas about one mile
southwest of the intersection of Interstate Loop 610 and U.S. Route 59 (Figure  1). The
site boundaries are Cavalcade Street to the north, Collingsworth Street to the south, and
the Missouri and Pacific railroad lines to the east and  west. The site is rectangular in
shape with a base of approximately 600 feet,  a height of 4,800 feet, and an area of 66
acres.

Figure 1. Site Vicinity Map

   The site is generally flat. It is drained by two stormwater drainage ditches which flank
the site on the east  and west sides, and  drain water into a flood control  ditch which
discharges into Hunting Bayou, a tributary of the Houston Ship Channel. Hunting Bayou
is currently classified in the Texas water quality standards as a limited aquatic habitat.

   The site is now used by three commercial trucking companies (Merchants Fast Motor
Lines, Transcom Lines, and Palletized Trucking) which have erected four buildings on
the northern and southern parts of the site.  The central  part of the site is not currently
used. The surrounding areas are residential, commercial, and industrial properties. The
nearest residential area is directly to the west. Commercial properties are located along
the major thoroughfares as well as on-site.

                                2. SITE HISTORY

   2.1 2.1 PREVIOUS SITE USE

  • The South Cavalcade  site was used as  a  wood preserving and  coal tar distillation
facility from 1910 to 1962. The wood preserving facility consisted of an operations area,
a drip track, and treated and untreated wood storage areas. The operations area included
wood treating cylinders, chemical storage tanks, and  a wastewater lagoon; this area was
located in the southwestern part of the site. Creosote and metallic salts were used in the
operation. The drip  track ran diagonally from the operations area to the northeast,  and
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 ended before the central part of the site. The coal tar plant was located in the southeastern
 part of the site.

    In 1962, the Koppers Company ceased operation of the facility, and sold the site to
 Merchants Fast Motor Lines. The site was later sold, subdivided, and resold to the current
 property owners. Figure 2 shows current site ownership.

 Figure 2. Site Ownership Map

    2.2 2.2 RESPONSE AND REMEDIAL ArTTVTTTRS

    fa 1983, the Houston Metropolitan Transit Authority investigated the site for potential
 mass transit use and found evidence of buried creosote. The Texas Department of Water
 Resources conducted  a further study and determined that the site may pose a threat to
 public health and the environment. Based on this information, TDWR referred the site to
 EPA for inclusion on the National Priorities List (NPL). EPA proposed the site to be
 added to the NPL in October 1984; the site was formally promulgated in June 1986.

    EPA began the Remedial Investigation and Feasibility Study (RI/FS) in November of
 1985. The Remedial  Investigation included investigations into contamination in soils,
 groundwater, surface  water and sediments, and air.  The Feasibility  Study evaluated
 several methods for remediating the site  problems including containment and treatment
 technologies. The RJ/FS ended in August of 1988 with the publishing  of the reports on
 each.

    2.3 2.3 ENFORCEMENT

    EPA identified four potentially responsible parties (PRPs) in the initial stages of the
 RL EPA issued an Administrative Order on  Consent to the Koppers Company in 1985 to
 conduct a  RI/FS.

    EPA mailed copies of the proposed plan of action for this site to the PRPs on August
 19, 1988.  EPA will continue its enforcement activities by sending  a Special Notice letter
 to the PRPs before the initiation of the  remedial design. Should the  PRPs decline to
conduct future  remedial activities, EPA will either take enforcement  action or will
 provide funding for these  activities while  seeking cost recovery for all EPA-funded
response actions  from  the PRPs.
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                  Cabot Carbon/Koppers Site, FL
                          RECORD OF DECISION
                              DECLARATION
SITE NAME AND LOCATION
Cabot Carbon/Koppers Site
Gainesville, Alachua County, Florida

STATEMENT OF BASIS AND PURPOSE
   This  decision  document presents the selected  remedial action  for  the  Cabot
Carbon/Koppers Site, in Gainesville, Florida, developed with CERCLA, as amended by
SARA and, to the extent practicable, the National Contingency Plan. This  decision is
based on the Administrative Record for this site.

   The State of Florida concurs with the selected remedy.

ASSESSMENT OF THE SITE

   Actual or threatened releases of hazardous substances from this site, if not addressed
by-implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare and the environment.

DESCRIPTION OF THE REMEDY

   The remedial action is proposed as both the first, and the final remedial action for the
site. The function of this remedy is to treat, where feasible, contamination down to health
based levels and to prevent exposure to those contaminants in areas where treatment is
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infeasible.

   The major components of the selected remedy are as follows:
   •   Excavation of contaminated soils from the former North and South Lagoons on
       the Koppers facility;

   •   Soils  washing  of the  soils from the former  North  and  South  Lagoons,
       bioremediation  and,  if appropriate,  solidification/ stabilization  of  residual
       materials, and deposition of treated soils back onsite;

   •   In situ bioremediation and institutional controls for process areas on Koppers
       facility, including the former Cooling Pond and Drip Track Areas;

   •   Institutional Controls for the former Cabot Carbon facility;

   •   Extraction  of contaminated groundwater from shallow aquifer, pretreatment if
       necessary, and discharge into Gainesville Treatment Utility (GRU) system. A plan
       for satisfying NPDES requirements will be developed in the Remedial Design, as
       a contingency against GRU not allowing this discharge;

    •   Provision for lining of North Main Street Ditch to prevent further discharge of
       leachate into the Ditch and Springstead and Hogtown Creeks; to be implemented
       if Ditch is, in the long term, to remain intact;

    •  Continued Operation and Maintenance of the North Main Street lift station until
       implementation of groundwater remediation system renders it superfluous;

    •  Confirmatory sampling of  the intermediate aquifer, Springstead Creek, old Cabot
       lagoons area, and Wetlands/lagoon area.

 STATUTORY DETERMINATIONS

  '• The  selected remedy is protective of human health and the environment, complies
 with Federal and State requirements that arc legally applicable or relevant and appropriate
 to the remedial action, and is cost-effective.

    This remedy utilizes permanent solutions and alternative treatment technologies to the
 maximum extent practicable for  this site. Four source areas are undergoing treatment
 technologies that will reduce the volume, toxicity and mobility of contaminants. For these
 source areas, this remedy satisfies  the statutory preference for treatment as a principal
 element of the  remedy. However, existing structures located  on several of the source
 areas prevent effective treatment technologies from being implemented. For these source
 areas, this remedy does not satisfy the statutory preference  for treatment as a principal
 element of  the remedy. For the groundwater remedy, this  remedy does  satisfy the
 statutory preference for treatment  as a principal element of the remedy.
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    Because this remedy will  result  in hazardous substances remaining onsite above
health-based levels, a review will be conducted within five years after commencement of
the remedial action to ensure that the remedy continues to provide adequate protection of
human health and the environment.
Date: September 27, 1990
Greer C. Tidwell
Regional Administrator

                           RECORD OF DECISION
                      CABOT CARBON/KOPPERS SITE
                          GAINESVILLE, FLORIDA

                             1.0 INTRODUCTION

   The Cabot Carbon/Koppers Site (CC/K) was proposed for the National Priorities List
(NPL) in October, 1981 and finalized in August 1983. A map of the site can be found on
Figure  1.2-1. In 1983, EPA issued  a Cooperative Agreement grant to the  Florida
Department  of  Environmental  Regulation  for the  performance of a  Remedial
Investigation and Feasibility Study (RI/FS). -During the  implementation of the RI, the
Florida Department of Transportation (FDOT) announced that they were going to widen
North Main Street, which runs along the eastern border of the site, from two lanes to four
lanes. This elicited a flurry of public opposition because the public was concerned that
widening the road would cause exposure to contaminants that the road overlay. FDOT
later decided to put the project on hold until EPA had selected a remedial action.

Figure 1.2-1. Site Plan

   In 1987, the initial RI was completed. The EPA and FDER decided that additional
data gathering activities were necessary before a comprehensive FS could be written.
Hpwever,  the Cooperative Agreement fund was depleted. The lead  was then switched
back to EPA, which then started  negotiations with two major potentially responsible
parties (PRPs) (Cabot Carbon Corporation and Beazer Inc.  (formerly Koppers)) for the
supplemental RI and the FS. The Consent Order between EPA and the PRPs for this work
was  signed in October 1988. The RI was  approved in  September 1989,  the  Risk
Assessment (RA) was approved in February 1990 and the Feasibility Study in May 1990.
The public comment period started August 8, 1990, and finished September 7, 1990. The
public meeting to describe the preferred alternative was held August 14,1990.
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RECORD OF DECISION TEXT
                2.0 SITE NAME. LOCATION AND DESCRIPTION

2.1 2.1 Area Land Use

    The site is located within the northern part of the city limits of Gainesville, Florida.
The Koppcrs half of the site is zoned industrial; it  is the only parcel of land zoned
industrial, and is currently operating, in that area. The closest area zoned industrial is the
Gainesville Industrial Area, which is several miles to the north. The former Cabot Carbon
property, along with the marshy area to the north of the old Cabot facility  and property
east and south of the site are zoned commercial. The land to the immediate west of the
site is zoned single family and multiple family residence. To the north-northwest of the
site are scattered small businesses and a trailer park. To the west and northwest of the
site, the adjacent property is residential, consisting primarily  of single family housing.
Commercial facilities border the site to the south and east along NW 23rd Avenue and
North Main Street. To the northeast,  the adjacent land is primarily undeveloped and
heavily vegetated.

    The Gainesville Regional Utilities (GRU)~ northern well field and treatment facility is
located approximately 2.5 miles northeast of the site area. The facility, which is the
municipal supply for the city of Gainesville, draws water from the Floridan aquifer.

    The site area is relatively flat, ranging in elevation from 165 to 185 feet above mean
sea level (ft-msl). Low, swampy areas  are prevalent in the northeastern quadrant of the
site and to the east and northeast of the site in the  undeveloped land segments. The
primary surface water drainage in the  area is  Springstead Creek, which  parallels the
northern boundary of the site. Springstead Creek flows into Hogtown Creek. The North
Main Street ditch, which flows into Springstead Creek, bounds the site along the eastern
and northeastern perimeters. A secondary drainage ditch runs  northeast through the KH
property and discharges into Springstead Creek, a tributary of Hogtown Creek.

2.2 2.2 REGIONAL GEOLOGY

2.2.1 2.2.1 Regional Geologic Setting

    Alachua County  is  underlain  by  several  hundred  feet of  unconsolidated  to
serniconsolidated marine and nonmarine deposits of sand, clay, marl, gravel, limestone,
dolomite,  and dolomitic limestone. The oldest formation bearing fresh water  in the area is
the Lake City Limestone of Eocene Age. This unit is overlain by the younger Avon Park
Limestone and  Ocala Group  (both of Eocene  Age), the   Miocene-Age Hawthorn
Formation, and Plio-Pleistocene terrace deposits.
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    The principal geologic structure in central peninsular Florida is the Ocala Uplift, an
 anticlinal fold or arch  whose crest traverses southwest of Alachua County. The Ocala
 Group, an extensive sequence of limestones  and dolomites, is exposed at the ground
 surface approximately 5 miles southwest of the Cabot Carbon/Koppers site. From this
 area of limestone exposures, the ground surface rises to the northeast as the Ocala Group
 is overlain by  the  Hawthorn  Formation and Plio-Pleistocene terrace deposits  in  the
 vicinity of the Cabot Carbon/Koppers site.

    There are three aquifer systems in Alachua County: (1) the watertable aquifer, (2) the   '
 secondary artesian  aquifer, and (3) the  Floridan aquifer. The water-table aquifer is
 composed of PlioPleistocene sands and clayey sands. The secondary artesian aquifer is
 limited vertically and laterally in extent and consists primarily of a few limestone and
 sand  units  within  the  clays  of the Hawthorn  Formulation.  The Floridan aquifer is
 comprised of several hundred feet of limestone  and underlies the entire  county. This
 aquifer is the most productive because it transmits and  stores water more easily. The
 aquifer is confined where it is overlain by the Hawthorn Formation; it is unconfirmed
 where the Ocala Limestone is  near the surface. In the immediate vicinity of the site, it is
 projected that the depth to the top of the Floridan aquifer is approximately 200 to 250 ft.

 2.2.2  2.2.2 Site Specific Geology

    Based upon the subsurface data available from the previous site investigations, two
 cross  sections  have  been constructed to illustrate geologic conditions  at  the  Cabot
 Carbon/Koppers site (see Figures 2.2-2 and 2.2-3). The surficial Pliocene and Pleistocene
 sediments that underlie the site consist of fine-tomedium sand, silt, and clay. This unit is
 approximately 25 to 30 ft in thickness and exhibits increased  clay content with depth.
 Underlying these surficial deposits is the Hawthorn Formation, which consists of a dense,
 light  green,  marine clay in the  upper  10 ft, becoming interbedded with sandy clay
 stringers and phosphatic limestone. The surface of this unit appears to be dipping toward
 the northeast. A limestone unit, as determined from gamma logging, was encountered at a
 depth of 60 to 65 ft grading from thin seams of interbedded clay, sand, and limestone into
 massively bedded fossiliferous limestone (IT, 1987).

 Figure 2.2-2. Geologic Profile A-A1

Figure 2.2-3. Geologic Profile B-B1

2.2.3 2.2.3 Soil Types

   The  soils   that  make  up  the   Cabot  Carbon/Koppers  site  belong  to  the
Millhopper-Urban Land Complex and the Wauchula-Urban Land Complex (Thomas gt
a]., 1985). The term "complex" indicates that each mapping unit is an undifferentiated
mix of the two soil types; in these cases, the individual soil series of the Urban Land.

   The Millhopper Complex covers the majority of the Cabot Carbon property and the


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  eastern two thirds of the KH property. This complex is characteristically drier than the
  Wauchula Complex with the water table expected to be below 60 inches for most of the
  year. Permeability is rapid in the surface and  subsurface layers and slow  in the subsoil
  layer.

-    The Wauchula Complex covers up approximately one third of the area: This complex
  is wetter than the Millhopper Complex, where  the water table usually is within 40 inches
  of the surface. Permeability is rapid in the sand surface and subsurface layers and slow to
  'moderately slow in the loamy subsoil.

  2.2.4 2.2.4 Surface Water


     The Cabot Carbon/Koppers site lies within  the Hogtown Creek drainage basin, which
  covers an area of 15.6 square miles (mi2). The contact between the upland plateau and the'
  transitional  physiographic regions occurs at the scarp carved  by erosion associated with
  Hogtown Creek drainage. Hogtown Creek drains southward across the transition  zone
  into the western plains region, where it ultimately discharges directly to the Floridan
  aquifer by way of Haile Sink, approximately 10 miles downstream of the site area.

     The Cabot Carbon/Koppers  site has two  drainage ditches which discharge to the
  Hogtown  Creek system. The  North Main Street ditch extends  to  the north  along the
  eastern boundary of the site and discharges into Springstead  Creek, which parallels the
  site's northern boundary. The second site drainage ditch transverses the Of property and
  also discharges into Springstead Creek at the  northern property boundary. Springstead
  Creek discharges into Hogtown Creek north of the site.

  2.2.5 2.2.5 Climate


    The climate in north-central Florida is humid and subtropical. Summer temperatures
 are  fairly  uniform;  afternoon temperatures  generally  reach 90  degrees F. Winter
 temperatures vary from day to day and frost and freezing temperatures  normally occur
 several times a year. Mean annual precipitation is approximately 53 inches; with over half
 of that coming in  the  months of June through  September. During this time of year,
 precipitation usually occurs during thunderstorms that can drop 2 to 3 inches of rain in
 several hours.

 2.2.6 2.2.6 Local Habitat

    Locally,  the most significant feature influencing species composition on the Cabot
 Carbon/Koppers site is  past and present land use management. As described previously,
 the site consists of approximately 99 acres of industrial and commercial activities, which
 limit or exclude the occurrence of natural resources.  Retail commercial establishments
 occur on the former Cabot Carbon property within the southeastern portion of the site;
 consisting of support buildings, roadways, parking lots, and isolated landscaped areas.
 The Kn facility dominates the western portion of the site supporting industrial-related
 buildings and structures, railroad siding, and nonvegetated open areas.
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                                  RODScan
 L. A. Clarke and Son, Inc., Spotsylvania County, Virginia
                           RECORD OF DECISION

Site Name and location

L. A. Clarke and Son, Inc. - Spotsylvania County, Virginia

Statement of Basis and Purpose

   This decision document presents the selected remedial action for the L.A. Clarke site
developed  in  accordance   with  the  Comprehensive   Environmental  Response,
Compensation and Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986, and to the extent practicable, the National Contingency
Plan, 40 CFR Part 300. This decision is based on the Administrative Record for the L.A.
Clarke site. The attached index identifies the items which comprise the Administrative
Record upon which the selection of the remedial action is based.

   The Commonwealth of Virginia has concurred on the selected remedy.

Description of the Selected Remedy

   The selected remedy  addresses the  principal threats  at the site by  controlling
contaminant sources. An estimated 118,000 cubic yards of soil and  sediment require
remediation. Sources to be remediated include two Resource Conservation and Recovery
Act regulated units which constitute an estimated 2% of this volume. Additional remedial
action  addressing contaminant migration pathways  (groundwater  and downgradient
sediment) shall be determined in a Second Operable Unit Record of Decision.
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The selected remedy includes the following major elements:
•  In situ soil flushing, utilizing a surfactant solution, of subsurface soils (creosote
   layer) underlying the process buildings;
   •   Injection/recovery wells to direct washing solutions to the contaminated soils
       and then recover the contaminant-laden wash solution.
   •   Design and use of a well system to attain a self-contained flushing scheme to
       prevent environmental impacts.
   •   A wastewater  treatment  system  to  remove  contaminants from washing
       solutions for recycling of solution back into the process. Disposal of treatment
       residuals is dependent on post-treatment characterization.
•  In situ biodegradation in the creogotg layer area (following the in situ flushing).
   •   Nutrient  and oxygen-rich compounds shall be injected via the well  system
       described above.
•  On-site land fanning of  excavated- surface soils,  sediments,  and  subsurface
   wetland soils. The main land farming operation will be placed in northeast area of
   site. Some soils may be land farmed inplace. The RCRA regulated soil pile and
   Westvaco Pond sediment shall be landtreated in place.
*  Creosote contaminated bottom sediment in the RCRA regulated lagoon shall be
   biologically degraded in a tank.
•  Excavation/dredging and consolidation of contaminated sediments (ditches 1, 2
   and 3, and wetlands), subsurface wetlands soils, buried pit materials, and surface
   soils that are not remediated via in situ flushing/biodegradation and cannot be land
   treated in place:
   •   Geotextile silt  fences,  sedimentation  basins,   and/or  diversion/surface
       management to control off-site soil transport and divert surface-water flows.
   •   Organic vapor monitoring.
   •   -Dewatering  of sediments,  treatment of water  (if required), and  on-site
       discharge of treated water.
•  Erosion/sedimentation control (as described for excavation).
•  Backfill excavated areas with treated soil and sediment. Cover  backfilled  areas
   with topsoil and revegetate.
•  During and post treatment groundwater monitoring.

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   Should   the    on-site   process   building   be   removed,   Alternative    4,
Landfarming/Biodegradation  (as  described in  this document)  would  be an  equally
preferable alternative and may therefore be implemented. The Commonwealth of Virginia
concurs with this decision.

   The EPA and the Commonwealth of  Virginia are currently pursuing measures  to
ensure that on-going wood treatment operations at the L.A. Clarke site will not result in
further contamination of soils and sediments, and as a result, groundwater and surface
water.

Declaration

   The selected remedy is  protective of human health  and the environment, attains
Federal and State requirements that are applicable or relevant and appropriate to this
remedial action, and is cost-effective. This remedy satisfies the statutory preference for
remedies that employ treatment which reduces toxicity, mobility, or volume as a principal
element. Finally, I have determined that this remedy  utilizes permanent solutions and
alternative treatment to the maximum extent practicable.
James M. Seif
Regional Administrator
EPA Region HI
DATE: March 31,1988

             SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
RECORD OF DECISION TEXT
                     SITE. LOCATION AND DESCRIPTION

   The L. A. Clarke wood  treating site is located in Spotsylvania County, Virginia,
approximately 2.5 miles south of Fredericksburg. The site is about 40 acres in size and is
situated at latitude 38 degrees  14'05"N and longitude 77 degrees 25'35"E. The L. A.
Clarke facility is situated approximately one-quarter mile east of Route 608 and north of
Massaponax Creek.

   A regional location map (Figure 1-1) shows the general location of the site. Figure 1-2
shows the location of the site  on the  USGS 7.5 minute quadrangle topographic map.
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Residential communities are located 1000 feet northwest and east of the site. Figure 1-3
shows the various structures and their relative locations on the site. Major site structures
include the processing facility where lumber is treated, the soil waste pile and wastewater
impoundment in the west-centraL position of the site and two major drainage ditches in
the western half of the site.

Figure 1-1. Regional Location of the L. A. Clarke Site

Figure 1-2. L. A. Clarke Site Location on GuineaQuadrangle (USGS) MAP

Figure 1-3. L. A. Clarke Site Map

   L. A. Clarke currently treats wood  with a creosote/coal tar solution in the pressure
treatment facility at the site. Available data indicates that only creosote has been used as
a wood preservative on-site.

   Surface runoff from the site flows into a series of drainage ditches which discharge
into  a wetland south of the  site. Groundwater at the L. A. Clarke site flows in a
southeasterly direction within  two water-bearing zones separated by a low permeability
clay stratum. The shallow aquifer flows beneath the operations area and surfaces at the
southern property boundary in the wetlands area. Groundwater from the site also enters
the drainage  ditches which outfall in the wetland. A deeper aquifer flows under the site
and the wetlands.

   Water from the wetlands flows through several tributaries which flow to Massaponax
Creek, which discharges into Ruffins Pond approximately 2 miles downstream. Ruffins
Pond is used for recreational swimming and fishing. Westvaco Pond, not known to be
used for fishing or recreation, lies immediately to the west of the site. Residential wells
are located within 1000 feet of the site and utilized groundwater  from the shallow aquifer.

                                 SITE HISTORY

   Wood preserving operations began at L. A. Clarke & Son, Inc. in June  1937 and have
cqntinued to date with only one inactive period (from April 1979 to June 1980). Until
1976, the property and facility was owned by the Richmond, Potomac & Fredericksburg
(R,F & P) Railroad and leased to the operator of the facility, L. A. Clarke & Son Inc.

    Creosote contaminated soils and sediments at the L. A. Clarke site have resulted from
spills and leaks  over the past 50 years from  facility operations, from  process waste
streams entering the drainage ditches, and from waste disposal onsite in pits.

   ' In the early 1970s, wastewater treatment consisted of draining process wastewaters
into two concrete-lined pits. Historical aerial  photography indicates that these pits were
present at least from 1953 through 1974,  and are located north of the process facility.
Overflow from the concrete pits went to an earthen pit, and excess water was discharged
to drainage ditches and sprayed on the ground  around the storage yard to control dust.
Four additional waste pits have been identified in aerial photos dating back to 1937. All
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of these pits had been filled in by 1979.

    In  1975, L. A. Clarke and  Son, Inc., was issued a National Pollution  Discharge
Elimination System (NPDES) permit for outfalls from two drainage ditches on-site (see
Figure 1-3). These permits are still in effect. The only toxic contaminant regulated by the
permit of concern is phenol.

    In  1979, a  wastewater impoundment (i.e., lagoon)  was constructed to separate
creosote from process wastewaters. In 1980, L. A. Clarke and Son, Inc. was classified
under RCRA as a treater of hazardous wastes because of the use of this impoundment. L.
A. Clarke was issued EPA I.D. No. VAD007972482. In 1982, L. A. Clarke submitted a
RCRA Part B Permit Application, which addressed  the impoundment and a contaminated
soil pile located south of the process area. The facility lost  RCRA  interim status on
November 8, 1985 as a result  of its failure to submit the certification required under
Section 3005(e).

   The RCRA-regulated soil waste pile was created when soils were excavated from the
processing area and  from ditch  2 along the northern property line. This work  was
conducted as part of a statemandated remedial action in 1982. The waste pile contains
approximately 1,400 cubic yards of soil.

                           SITE CHARACTERIZATION

   Physical investigations during the RI have led to the following conclusions regarding
the drainage, soils and hydrogeology of the site:
       Surface topography is relatively flat due to extensive fill and grading operations.

       The site is underlain by 0 to 26 feet of alluvial gravelly sands on top of a 13- to
       32-foot thick  silty clay/clayey  silt unit. The  alluvium pinches out along  the
       southern margin of the site, exposing the underlying clayey silt.

       A shallow water table aquifer flows to the southeast within the alluvial deposits,
       and continues, where the alluvium pinches out, into the adjacent fractured silty
       clay/clayey silt. A deeper aquifer underlies this unit.

       Free  product   creosote   is   visible   on   the  alluvium-clay  interface  in
       non-production/disposal areas indicating that migration of creosote is, in part,
       controlled by the undulatory nature of the clay surface.

       Creosote is  present 5 or more feet below the surface of the clayey silt/silty clay
       both next to the facility and along the southern site boundary.  The creosote
       appears in sandy interbeds and along microfractures in the clayey silt/silty clay.

       On-site soils and fill are permeable, whichjeduces surface runoff. Ditches that
       drain  the  site  maintain flow  throughout the  year  and are, in fact, surface
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       manifestations of a shallow water table system. The high creosote levels in soils
       at the ditch outfalls (in the wetlands adjacent to Massaponax Creek) indicate that
       the ditches are a primary mechanism for off-site transport.

    In  all cases, the primary  contaminants  of concern are constituents of creosote.
particularly polynuclear aromatic (PNAs) and benzene. Based on chemical  analyses of
surface 'and sub-surface soils, plant practices have  apparently  created the following
contaminant source areas (and Selected Soil  and Sediment Sample  Results and Figures
4-9,4-1 land 4-12):

Figure 4-9. Sampling Locations

Figure 4-11. Shallow Test Pit Location

Figure 4-12. Deep Test Pit, Trench Test Boring andVibracore Location
       Burial of waste creosote in pits has resulted in relatively stationary pockets of
       elevated PNA concentrations  and a source of soluble contamination, which is
       transported by infiltration to the groundwater. (See results for TP-06, TP-33 and
       TR-4.)

       Plant operations have included years of spills and leaks at the treatment cylinders.
       Free product in these areas has completely permeated subsurface soils down to the
       clay stratum. Horizontal migration of free product along the top of this stratum is
       evident, forming a "creosote-layer" (see result for TB-12).

       Sample results also indicate substantial contamination of surface sediments in
       on-site  drainage ditches, particularly 001 and 002, and  at the outfalls of these
       ditches (see results for  Dll  and D12). A significant quantity  of sub-surface
       sediment has been detected at the outfall of ditch 001 (see  VC-01).

       Areas of relatively higher PNA concentrations in surface soil include areas around
       the process facility, the field southeast of the lagoon, and the wetlands near the
       outfalls. Surface soils in the process area become increasingly stained approaching
       the operations buildings due to the frequent transport in that area of freshly treated
       lumber. Surface soils in this area contain total PNA concentrations on the order of
       5,000 mg/kg. Surface soils in the wetlands are heavily stained within 100 feet of
       the outfalls.

       PNA concentrations in excess of 5,000 mg/kg can be found in surface soils in the
       area southeast of the wastewater lagoon. This can be attributed to  the spraying of
       wastewater from the lagoon when in service and  the use of an earthen overflow
       pit, shown on historical overflights, directly south of the lagoon.
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   •   A soil pile, located west of the wastewater lagoon, consists of contaminated soils
       excavated by  L.  A. Clarke from areas surrounding the process facility.  Soil
       samples taken from the file by previous  investigators (Schnabel Engineering
       Associates) indicate the presence of PNAs in excess of 1,000 mg/kg and low
       levels of benzene. In addition, the RCRA regulated lagoon has been estimated to
       hold 278 cubic yards of creosote bottom sediment.

   Chemical  analyses  have  revealed  the following   about  contaminant  migration
pathways:
       Significant contaminant  levels  have been detected in  wetlands  tributaries
       receiving  drainage from  the site (see results for MO2). Massaponax  Creek
       sediments downstream of the site ranged from below detection to 12 mg/kg of
       PNA (detected by U.S. Fish and Wildlife Service).

       A  survey of  bottom feeding fish from Westvaco Pond revealed carcinogenic
       lesions around the gills and mouth in several specimens. These abnormalities may
       be due to direct contact with creosote contaminated sediments. Sediment samples
       taken from the edge of the pond contained total PNA concentrations between 2
       and 18 mg/kg. Areas of blackened soils and sediments have been observed at the
       water's edge.

       Total PNA concentrations in the shallow aquifer ranged up to 1500 ug/1. Benzene
       ranged up to 100 ug/1.

       Total PNA concentrations in the deep aquifer were below detection, with the
       exception of one detection of less than 10 ug/1. Followup sampling of the well
       revealed no PNAs. Benzene was not detected in the deep aquifer.
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 Table 4-4 -
 Table 4-5-
 Table 5-1 -
 Table 5-2 -
 Table 5-3 -
 at Newsom
 Table 6-1 -
 Site
 Figure 1-1 -
 Figure 1-2 -
 Figure 3-1 -
 Figure 3-2 -
 Figure 3-4 -
 Figure 6-1 -
- Estimates of Sediment Volumes that Require Remediation
- Additional Sediment/Soil Cleanup Levels
- Results of Preliminary Screening of Remedial Technologies
• Cost Ranking of Remedial Action Alternatives
• Applicable or Relevant and Appropriate Requirements for Remedial Actions
Brothers Site
 Detailed Cost Analysis of Proposed Remedial Action at Newsom Brothers

-Site Map
- Site Features Map
- Geologic Cross Section
- Monitor Well Locations
• Hazardous Substances Remediation Areas
• Soil Remediation Areas
      Cape Fear Wood Preserving Site, Fayetteville, NC
             DECLARATION FOR THE RECORD OF DECISION

Site'Name and Location

Cape Fear Wood Preserving
Fayetteville, Cumberland County, North Carolina

Statement of Purpose
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    This document represents the selected remedial action for this Site developed in
 accordance with CERCLA as amended by SARA, and to the extent practicable, the
 National Contingency Plan.

    The State of North Carolina has concurred on the selected Remedy.

 Statement of Basis

    The decision  is based upon  the Administrative  Record for the Cape  Fear Wood
 Preserving  Site.  The attached index identifies the  items  which  comprise  the
 administrative record upon which the selection of a remedial action is based.

 Description of Selected Remedy

    Prior to initiating any remedial action on-site,a site  survey will be conducted to
 determine the presence of any endangered plant species on-site.  If endangered plant
 species  are  encountered,  then the Department of the Interior/U.S. Fish and Wildlife
 Service needs to be consulted prior to initiating remedial action to decide how to proceed.

 REMEDIATION OF HAZARDOUS MATERIALS, TANKS & PIPING

        Off-site disposal of sodium dichromate - copper sulfate - arsenic pentoxide (CCA)
    salt crystals, the solidified creosote and asbestoscontaining pipe insulation. The CCA
    crystals and solidified creosote will be disposed of at a RCRA permitted landfill. The
    asbestos-containing pipe  insulation will be disposed of at the Cumberland County
    Solid Waste Facility pursuant to the facilities specifications.

       The tanks and associated piping, above and below ground, will be emptied,
    flushed and cleaned, including triple rinsing, to render the metal non-hazardous. The
    metal will then be cut and either sold to a local scrap metal dealer or disposed of at
    the Cumberland County  Solid Waste Facility. For those tanks and/or piping that
    cannot be cleaned sufficiently to render them non-hazardous they will be transported
    to a RCRA permitted landfill for disposal.

       The contents of the tanks and associated piping contains approximately .50,000
    gallons of 3  percent  CCA solution.and 15,000 gallons  of CCA contaminated
    wastewater. A buyer of the 50,000 gallons of 3 percent CCA solution will first be
    pursued. If no buyer can be found, then the 50,000 gallons of 3 percent CCA solution
    along with  the 15,000 gallons  of CCA contaminated wastewater will be treated
    pn-site through the water treatment system set up for treating the pumped surface
    waters and  extracted  groundwater.  All wastewater (i.e, cleaning equipment, etc.)
    generated by on-site activities will also be directed to the treatment system.

 SOURCE CONTROL (Remediation of Contaminated Soils )

       The preferred alternative for the remediation of contaminated soils/sediment is
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    soil washing. The alternate source control alternative is a low thermal  desorption
    process to remove the organics contaminants from the soil followed by either soil
    washing  or  a  soil  fixation/solidification/stabilization process  to  address  the
    inorganics. The decision as to which source control alternative will be implemented
    will be based on data generated by the soil washing treatability study to be conducted
    during the remedial design.

        Contaminated soils/sediment will  be excavated, treated and  placed back in the
    excavation.  All  wastewater  generated  will  either be reused  or treated on-site
    Following completion of on-site remedial activities, those areas disturbed will be
    revegetated.

 MIGRATION CONTROL {Remediation of Contaminated Groundwater )

        Groundwater extraction will be accomplished through the use of well points in the
    upper (surficial) aquifer. Groundwater removal will be conducted in  10,000 square
    foot sub-areas at a time, until the entire contaminated surficial aquifer is addressed.
    The well points will be moved from one area to another for subsequent dewatering.

        Due to local contamination of the lower aquifer, the lower aquifer will be pumped
    following remediation of the overlying upper  aquifer in this area. This will prevent
    potential contaminant drawdown to deeper depths.

        A water treatment system will  be established on-site. The system's influent will
    include contents of the tanks and piping, all wastewater generated due to remedial
    actions implemented, pumped surface water, and  extracted  groundwater.  The level
    and degree of treatment will depend on  1) the level of contaminants in the influent
    and 2) the ultimate discharge point of the treated water. There are two water discharge
    alternatives for the treated water. The optimal  choice is the local  sewer system The
    other alternative  is to  discharge the  effluent to  a surface stream. The range of
    treatment  for the contaminated  water includes  biological degradation,  air stripping
    filtration  through activated carbon filter, and metal removal  through flocculation!
    sedimentation and precipitation. The point of discharge.and  the degree of treatment
    will  be determined in the Remedial  Design  stage. The effluents, including both
    discharged water and/or air, will meet  all applicable  and  relevant or appropriate
    requirements (ARARs).

Declaration


    The  selected  remedy is protective of human health and the environment, attains
Federal and State requirements that are applicable or relevant and appropriate, and is
cost-effective. This remedy satisfies the preference for treatment that reduces toxicity
mobility, or volume as a principal  element. Finally, it is  determined that this remedy
utilizes permanent solution and alternative treatment technologies to the maximum extent
practicable.
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Green C. Tidwell
Regional Administrator
Date: June 30,1989

                          RECORD OF DECISION
          SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
                  CAPE FEAR WOOD PRESERVING SITE
      FAYETTEVILLE, CUMBERLAND COUNTY, NORTH CAROLINA

                               1.0 Introduction

   The  Cape Fear Wood Preserving (Cape Fear) Site was proposed for the National
Priorities List (NPL) in June 1986 and was finalized in July 1987 as site number 572. The
Cape Fear site has been the subject of a Remedial Investigation (RI) and a Feasibility
Study (FS), both of which were conducted under the REM n contract. The RI report,
which examined air, groundwater, soil, and surface water and sediment contamination at
the Site  and the routes of exposure of these contaminants to the public and environment
was  completed in October 1988. The  FS, which develops, examines and evaluates
alternatives for remediation of the contamination found on site, was issued in final draft
form to the public in February 1989.

   This Record of Decision has been prepared to summarize the remedial alternative
selection process and to present the selected remedial alternative.
RECORD OF DECISION TEXT
                   1.1 SITE LOCATION AND DESCRIPTION

   The Cape Fear Site is located in Cumberland County, North Carolina, on the western
side of Fayetteville near Highway 401 (Figure 1). It includes about nine acres of a 41-acre
tract of land near the intersection of latitude 35 degrees 02'57"N and longitude 79 degrees
01'17"W. The site is adjacent to other industrial/commercial establishments as well as
private residences. Four homes are located near the site. In addition, a subdivision named
"Southgate" is located approximately a quarter of a mile south of the site and houses
approximately 1,000 people. Figures 2 and 3 show the area and major site features.

Figure 1. Map Showing Site Location
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                                    MHW^H

 Figure 2. Map Highlighting Area of the Site

 Figure 3. Map Illustrating Features of the Site


     Of die approximately 41 acres comprising the site, less than 10 acres were developed
 by the facility. The remainder of the site is heavily wooded with coniferous trees with a
 small swampy area northeast of the developed area. The site is  highly disturbed in the
 vicinity of the plant facilities. The buildings are currently abandoned and in various states
 of disrepair. The swampy area consists of a seasonally flooded wetland dominated bv
 rushes. The upland section of the site is sandy and well-drained. A site survey will be
 required pnor to initiating remedial action to determine if endangered plant species exist
 on-site.

    The terrain of the Cape Fear Site is predominantly flat, with drainage provided by a
 swampy area on the northeast side of the site and a man-made ditch to the southeast that
 extends soutfaeastwardly to  a diked pond. A variety of land uses exist around the Cape
 Fear Site. The properties to the north include an undisturbed pine forest, a concrete plant
 and a few residential properties. To the east is a continuation of the undisturbed pine
 forest, and to the west is farmland used for growing crops and raising livestock To the
 south is another concrete plant as well as the Southgate subdivision.

                                1.2 SITE HISTORY

    Operations at the Cape Fear Wood Preserving Site commenced in 1953 and continued
 until 1983.  The Cape Fear Wood Preserving  facility produced cjtjogfitg-treated wood
 from 1953 until 1978 when demand for fireogfite-treated products declined  Wood was
 then treated by a wolmanizing process using salts containing sodium dichromate, copper
 sulfate,  and  arsenic   pentoxide.  This  treatment  process  is  known   as   the
 copper-chromium-arsenic (CCA) process.  The date the CCA process was  initiated is
 unknown.  Nor  is  it  known whether  the creosote  and CCA processes  occurred
 simultaneously or in succession.

    Both liquid and sludge  wastes were generated by these two treatment processes.
 Waste from the cjsasojtg process was pumped into a concrete sump north of the treatment
 unit (Figure 3). As liquid separated from the sludge, it was pumped into a drainage ditch
 that lies southeasterly of the developed portion of the site and discharges into a diked
 pond. Stormwater runoff from the treatment yard also appears to drain into this ditch
 Waste from the CCA treatment process was pumped into a unlined lagoon north of the
 dry kiln and allowed to percolate into the ground.

    In the summer of 1977, the site was determined to be contaminated with constituents
 of coal tar and coal tar creosote. State authorities ordered the owner/operator to comply
 with North  Carolina law. As a  result,the  owner/operator  changed  operations to limit
 further releases, installed a new, potable water well for a neighbor west of the site  and
removed 900 cubic yard  of creosotecontaminated soil from the treatment yard and the
drainage ditch that parallels the railroad. The stgasote-contaminated soil was transported
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for land-spreading to property leased from Grace Parker approximately 2.5 miles south of
the site. The soil on this property was sampled as pan of the RI. Low levels of polycyclic
aromatic hydrocarbons (PAHs) were detected.

    Sometime between 1979 and 1980, a new closed-circuit CCA plant was installed and
the old creqgpte  and CCA facilities  were decommissioned. The new CCA plant was
regulated under the Resource • Conservation and Recovery Act (RCRA)  as  a small
generator until 1983, when the company went out of business. The site was subsequently
abandoned until the summer of 1988 at which time SECO Investment, Inc. purchased the
property.

    The Environmental Protection Agency (EPA) conducted a site reconnaissance and site
investigation in October 1984. Surface water, groundwater,  soil and sediment  samples
were collected  from the  northeast swamp, diked pond,  lagoon drainage ditch and a
domestic  well  west of the site  (S.T.  Jackson).  PAHs, which are £rgQSQte-related
compounds, and  the CCA metals were  detected in all  samples. Consequently, EPA
conducted an emergency removal action at the site in January and February 1985. This
action included.
   «   Removal of creosote sludge from the creosote concrete sump;

   •   Removal of sludge from the lagoon to a depth of 7 feet, and solidification of the
       sludge with fly ash;

   •   Pumpage of lagoon water into storage tanks located south of the new CCA unit;

   •   Removal of contaminated soil from the drainage ditch that parallels the railroad
       tracks and at the culvert near Reilly Road;

   •   Removal of contaminated soils from a potion of the northeast swamp and stained
       areas in the treatment yard; and

  , »   Back  filling with clean sandy soil of areas where contaminated soil had been
       removed.

   All contaminated soils and sludges removed were transported to the GSX hazardous
waste landfill in Pinewood, South Carolina.

   The NUS Corporation conducted an investigating of the site in May and October
1985. Soil, sediment, surface water and  ground water samples were collected. Analytical
results again showed that samples were contaminated with creosote-related compounds,
arsenic, chromium and copper.

   EPA conducted a second emergency response in September 1986 when site visits
revealed that vandals had shot holes in a 3,000-gallon creosote storage tank spilling
approximately 500 gallons of sreogote on the ground. The cleanup operation consisted of:
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    •   Removal,  solidification,  and transport of  approximately 10  cubic  yards  of
       creosote-contaminated sludge to an on-site metal shed east of the new CCA unit;

    •   Removal and transport of the creosote storage tank to the on-site metal shed;

    •   Excavation and grading of the area where the creosote tank had leaked;

    •   Pumping of approximately 15,000 gallons of CCA waste water from  the CCA
       recovery sump into on-site storage tanks located south of the new CCA unit, and

    •   Containment of the CCA recovery sump within an earthen dike.

                        2.0 ENFORCEMENT ANALYSTS

    Several Potentially Responsible Parties (PRPs) have been identified,  including the
Cape Fear  Wood  Preserving Company  (no  longer  active),  Johnson &  Geddes
Construction Company (no longer active), John R. Johnson, Doretta Ivey (wife of former
president of the Cape Fear Wood Preserving Company - deceased), and Dewey Ivey, Jr.
(son of the former president -  deceased). Recently identified PRPs include SECO
Investments, Inc. (SECO), Southeastern Concrete Products, Inc. (SE-LUM), Southeastern
Concrete Products of Fayetteville,  Inc. (SEFay), Mr. Steve Floyd,  MrXouis Lindsey, and
Mr. James Musselwhite.

    In December 1984, EPA issued notice letters to the PRPs informing them of EPA's
intention to  conduct CERCLA remedial activities at the site unless the PRPs  chose  to
conduct such actions themselves.  The PRPs  were sent notice  letters rather than an
administrative order because of their presumed inability to pay for remedial action. On
June 5, 1989, these PRPs were sent RD/RA notice letters informing them that the Agency
was considering spending Fund monies if they are not or incapable of conducting the
project themselves.
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                   American Creosote Works  Inc
                               Record of Deci$}pg


                                  Declaration

                     Surface Soil Contamiqatjon Operable
Site Name and Location:

American Creosote Works, Inc.
Pensacola, Escambia County, Florida

Statement of Basis and Purpose:


    This  decision document presents the selected remedial action for the  American
Creosote Works, Inc. Site in Pensacola, Florida, which was chosen in accordance with
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision document explains the factual and legal
basis for selecting the remedy for the site.

    The State of Florida  has  concurred on the  selected remedy.  The  information
supporting this remedial action decision is contained in the administrative record for this
site.

Assessment of the Site:


    Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response  action selected in this Record of Decision (ROD), may
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 present an unacceptable risk to public health, welfare, or the environment.

 Description of the Selected Remedy:

    The remedy selected by EPA will be conducted in two separate operable units. This
 operable unit is  the  first of two operable units for the site. This initial operable  unit
 addresses treatment of the contaminated surface soil  and is  fully consistent with all
 planned future site activities. Future site activities include treatment of the contaminated
 ground water and previously solidified sludges and underlying subsurface soil.

    The major components of the selected remedy for this first operable unit are as
 follows:
    •   Excavating, screening, and stockpiling the contaminated surface soil

    •   Treatment of this contaminated soil by bioremediation

    •   On-site disposal of the treated soil in the excavated areas

    •   Support activities: remove debris, repair fence, sample drums containing drilling
        muds and properly dispose of contents," and repair existing clay cap.

 Declaration:

    The selected remedy is protective of human health and the environment, complies
 with Federal and State requirements that are legally applicable or relevant and appropriate
 to the remedial action, and is cost-effective. This remedy utilizes permanent solutions and
 alternative treatment technologies to the maximum extent practicable, and it satisfies the
 statutory preference for remedies that employ treatment that reduce toxicity, mobility, or
 volume as their principal element.

    Because this remedy will result hi hazardous substances remaining on  site above
 health-based levels, a review will be conducted within five years after commencement of
 remedial action to ensure that the remedy continues to provide adequate protection of
 human health and the environment
.GreerC.Tidwell
 EPA Regional Administrator
 Date 9-28-89

                                 Record of Decision
                               The Decision Summary
                         American Creosote Works, Inc. Site
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                                    —^^—«—^^^•M™
                         Pensacola, Escambia County, Florida

                                  1.0 Introduction

     The American £reosotg Works, Inc. (ACW) Site was proposed for inclusion on the
 National Pnonties  List  (NPL) in October 1981 and became final  on  the  NPL in
 September 1983. In September  1985,  EPA signed  a Record of Decision (ROD) for
 remediation of all  on-site and off-site contaminated solids, sludges, and sediments
 Ground water contamination was not specifically discussed. The State of Florida was not
 in agreement with the ROD as developed  at that time. Consequently, a Post Remedial
 favestigation (RI) was conducted in June 1988 by EPA to provide further information on
 the extent of contamination. A follow-up Risk Assessment was done utilizing the results
 of the Post RI. In August 1989, a Post Feasibility Study (FS) was completed to identify
 develop, and evaluate alternatives for remediation at the site. Also in August 1989 the
 Proposed Plan, which outlines these alternatives, was released to the public.

 1.1 1.1 Scope and Role of Operable Unit


    As  with many Superfund sites, the  problems at  the ACW site are complex  As a
 result, EPA has organized the remedial work into two smaller units or phases, referred to
 as operable units.  The first operable unit, which is addressed in this Record of Decision
 (ROD), will eliminate the potential for direct-exposure to the contaminated surface soil
 The proposed action is consistent with plans'for future work to be conducted at the site"
 The second operable unit is undergoing additional study to further define the applicability
 of remediation technologies to the contaminated ground water and the solidified sludges
 and underlying subsurface soil.                                              oiuugca

    This ROD has been prepared to summarize  the remedial alternative selection process
 and to present the selected remedial alternative for the first operable unit
RECORD OF DECISION TEXT
                     2.0 Site Name, Location, and Description:

 .. The ACW site occupies 18 acres in a moderately dense, commercial and residential
district of Pensacola, Honda. See Figure 2.1. The site is located about one mile southwest
of the  intersection of Garden and Palafox  Streets  in downtown Pensacola  and is
approximately 600 yards north of Pensacola Bay and Bayou Chico. Immediately north of
the site is a lumber company, an auto body shop, an appliance sales and repair shop and a
wide storage area. Residential neighborhoods are immediately adjacent to the site on the
east and south, and a yacht sales shop is southwest of the site. The residential population
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within a one mile radius was approximately 5,000 people in  1970. The approximate
population in the area of the site was 1,056 in 1970. A total of 404 dwelling units were
present in this same area in 1970.

    The more pertinent features of the site  are shown on Figure 2.2. The site is about
2,100 feet long, east to west, and an average of 390 feet wide, north to south. Primary
access to the site is off Pine Street at its intersection with J Street. Originally, a railroad
spur line of the Burlington Northern Railroad traversed the site to the west and east. The
majority of site buildings, process tanks, and equipment were situated near the center of
the site  in an area designated as the main  plant  area. A few small  work sheds,
miscellaneous equipment, and debris lay about the remainder of the site. At the present!
only two small buildings remain standing on  the site.

    Four surface impoundments were located in the western portion of the site. The main
pond and the overflow pond,  located adjacent to L Street, were used for disposal of
process wastes and are  1.8 and 0.9 acres  in size, respectively. During former plant
operations, liquid wastes periodically overflowed and were drawn off from the two larger
impoundments.  The liquid wastes accumulated  in  the smaller  0.3 acre  railroad
impoundment and 0.1 acre holding pond or were spread on the ground in spillage areas.

                                  3.0 Site History

    Wood-preserving operations  were carried out  at the ACW site from 1902  until
December 1981.  Prior to 1950,  creosote exclusively was used to treat poles. Use of
pentachlorophenol (PCP) started in 1950 and steadily increased  in the later years of the
ACW operations. During its years of operations, liquid process  wastes were discharged
into two unlined, on-site surface impoundments.  Prior to 1970, wastewaters  in these
ponds were allowed to overflow through a  spillway and follow a drainage course  into
Bayou Chico and Pensacola Bay.

Figure 2.1. SITE LOCATION

Figure 2.2. SITE LAYOUT

  •• In subsequent years, wastewater was periodically drawn off the ponds and discharged
to designated, on-site spillage  areas. Additional discharges occurred during periods of
heavy rainfall when the ponds overflowed the containment dikes.

    In March 1980, considerable quantities of "oily/asphaltic/creosotic material" were
found by the City of Pensacola in the ground water near the intersection of L Street and
Cypress Street.  In July 1981, the U.S. Geological Survey (USGS) installed nine ground
water monitoring wells in the vicinity of the ACW site. Samples taken  from the wells
revealed that a contaminant plume was moving in a southerly direction toward Pensacola
Bay.

    In  February  1983,  the EPA  Site Screening Section conducted  a Superfund
investigation. The  investigation  included  sampling  and  analyses of on-site  soil,
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  wastewater sludges, sediment from the area drainage ditches, and existing on-site and
  off-site momtonng wells. Concurrent with this investigation, the USGS initiated a site
  and laboratory research study.  •

     Because of  the  threat posed to human health and the environment by frequent
  overflows  from  the Avaste ponds, the EPA Emergency Response and Control  Section
  performed  an immediate cleanup during September and October 1983. The immediate
  cleanup work included  dewatering the two large lagoons (main and overflow  ponds)
  treating the water via coagulation, settling, and filtration with subsequent discharge of the
  treated water to the City of Pensacola sewer system. The sludge in the lagoons was then
  solidified with lime  and fly ash. A temporary clay cap was placed over the solidified
  material. The Honda Department of Environmental Regulation  (FDER) also assisted
  during the cleanup.
       u   n    ^Stigation/Feasit»lity Study (RJ7FS) under CERCLA was completed in
       by EPA.  In  September 1985, EPA signed a Record of Decision (ROD) which
 specified that all on-site and off-site contaminated solids, sludges, and sediments would
 be placed in  a RCRA  (Resource Conservation  and  Recovery Act)  landfill to be
 constructed on-site. The remediation activity described would have involved excavation
 of significant amounts of soil from residential areas adjacent to the ACW site  Ground
 water contamination  was not specifically discussed. The State of Florida was not in
 agreement with the ROD as developed at that time.

    Consequently, a Post Remedial Investigation (RI) was conducted in June 1988 by the
 EPA Environmental Services Division (ESD) to provide further information on the extent
 of contamination. EPA performed a follow-up Risk Assessment utilizing the results of the
 Post  RL  In August  1989, a Post  Feasibility Study (FS)  was  completed to identify
 develop, and evaluate alternatives for remediation at the site. Using the results of the Post
 FS EPA completed the Proposed Plan in August 1989,  which outlined the alternatives
 under consideration as well as the preferred alternative.

 3.1 3.1 Enforcement Activities


    The earliest documented incident of a release of any type from the ACW site occurred
 in the summer of 1978 when  a spill of liquids  flowed onto a nearby street and  then onto
 the property of a yacht sales company. A flood in March  1979 resulted in a similar spill
 This incident resulted  in increased regulatory attention to ACW by the FDER. In January
 1981, the FDER completed a responsible party search,  a  title search, and a financial
 assessment for the site. In May 1982, the company, American Creosote Works, Inc  filed
 for reorganization in the bankruptcy court. In 1984, the bankruptcy court presented a final
 court stipulation for the approval of the litigants. The ACW  site would be sold  after
cleanup and the proceeds would be divided among  FDER,  EPA,  and the  financial
organizations holding the corporation's assets. The stipulation was entered into in 1988.

   In March 1985,  the Burlington Northern Railroad was sent a notice letter informing
ttiem  of their potential liability and requesting that they perform certain tasks at the site
Specifically, they were to remove railroad spur lines utilizing an EPA-approved work
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plan.  The railroad spur lines, the equipment, and  most of the buildings have been
removed. At the present, only two small out-buildings remain standing on the site. EPA is
investigating to determine whether any other PRPs exist.
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  Burlingtoa-Northern (Somers Tie Plant), Flathead County;
                               Montana
                         RECORD OF DECISION

                             DECLARATION

SITE NAME AND LOCATION         "

Burlington Northern (Somers Plant)
Flathead County
Somers, Montana

STATEMENT OF BASIS AND PURPOSE


   This decision  document represents the U. S. Environmental Protection Agency's
selected and contingency remedial actions for the Burlington Northern (Somers Plant)
Superfund Site ("the Site"), in Somers,  Montana. This document is developed in
accordance with  the Comprehensive  Environmental  Response, Compensation  and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments  and
Reauthorization Act of 1986 (SARA), 42.U.S.C. Section 9601, et seq. (Superfund) and
the National Contingency Plan (NCP), 40 CJF.R. Part 300. This decision is based on the
administrative record file for the Site.

   By signature below, the State of Montana concurs  in this Record of Decision. All
determinations reached in the Record of Decision were made in consultation with the
State of Montana, which has participated  fully in the  development of this Record of
Decision.

ASSESSMENT OF THE SITE
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    Actual or threatened releases of hazardous substances from this Site, if not addressed
by implementing the response action selected in this Record of Decision, may present an
imminent and substantial endangerment to^ublic health, welfare, or the environment.

DESCRIPTION OF THE REMEDY

    This response action is anticipated to be the final action for the Site. Other actions at
the Site included the 1985 Superfund emergency removal in the swamp pond area (see
Figure 3 in the Record of Decision Summary for locations of areas of the Site), after it
was determined to  constitute an imminent and substantial hazard to Flathead Lake, and
the closure in 1988 of two wastewater impoundments at the Site under State Resource
Conservation and Recovery Act (RCRA) authority.

Figure 3. Location of Disposal Areas at the Somers TiePlant

    This response action  addresses the remaining contamination by  remediating  soils,
sediments and ground water, all of which have been determined to pose a potential threat
to human health and the environment The selected remedy addresses the principal threats
by removing the potential  for direct contact with soils, by reducing the impact of the soils
and sediments on ground water and surface water, and by treating the ground water.

Soils and Sediments

    The major aspects of the selected "source control" or soil component of the remedy
include:
   •   Excavation  of approximately  11,700  cubic  yards  of contaminated  soils and
       sediments. Volumes to be excavated include soils above the water table from the
       CERCLA lagoon, drip track, drainage ditch and beneath the retort building as well
       as sediments from the slouMAPgh.

   «   On-Site Biological Treatment Of Excavated Soils.

   •   Restoration  and/or replacement of wetlands lost during remedial action and those
       lost during  the 1985  emergency action. The restoration/replacement will be
       conducted in consultation with the U.S. Department of the Interior.

Ground Water

   The major aspects of the "migration control" or ground water component  of the
selected remedy include:
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    •   Installation and operation of an innovative hot water flushing and water treatment
        system to remove and treat available free creosote contamination from the water
        table aquifer in the CERCLA lagoon and swamp pond areas.

    •   In-situ biological treatment to degrade  both contaminants adsorbed onto  the
        aquifer matrix and residual contaminants dissolved in the ground water.

 Ground Water Restrictions


    Currently, there are no drinking water supply wells in the affected  portions of  the
 water table aquifer. However, institutional controls designed to prohibit the construction
 of new wells downgradient from the CERCLA lagoon and in the swamp pond area will
 be implemented and maintained until ground water quality returns to acceptable levels.
 Monitoring


    The ground water component of the selected remedy will require monitoring to assure
 that treatment is effective and that treatment proceeds until risk-based cleanup levels have
 been  achieved and maintained. In addition/ monitoring  of the town's  proposed new
 municipal  wells in the  bedrock aquifer will be  instituted  if testing indicates that
 drawdown in these well  could cause the contaminated water table aquifer to affect the
 municipal supply. The municipal wells are expected to be installed and tested in  the fall
 of 1989.

 Contingency Remedies


    The selected ground water component of  the remedy  involves two innovative
 technologies: hot water flushing and in-situ biological treatment These technologies are
 expected to be successful at the Site. However, because of their unproven nature under
 the Soraers hydrogeologic conditions, these technologies will require pilot  testing  to
 determine their effectiveness prior to full scale implementation.

    Contingency Remedy A. If EPA determines, based on pilot testing, that ground
 water remediation is not practicable, soils swamp area and to approximately 30 feet in the
CERCLA lagoon area, and downgradient. This  excavation will remove the  source  of
ground  water contamination both above and below the water table, in addition to the
excavation areas outlined in the selected remedy,  fa  this case,  institutional controls
designed to prevent the  construction of drinking water wells downgradient from the
CERCLA lagoon will  be implemented and maintained until natural degradation returns
the aquifer to a usable condition.  Under this contingency, the excavated soils will be
incinerated on-site.

   Contingency Remedy B. If, based on pilot testing, EPA determines that ground water


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 remediation would only be practicable in the area of the CERCLA lagoon but not in the
 swamp area, most likely due to lower permeability aquifer materials, the swamp area soils
.will be excavated to a depth of approximately 20 feet, in addition to the excavation areas
 outlined in the selected remedy. The ground water component of the selected remedy will
 then be implemented in the CERCLA lagoon area only. Under this contingency remedy
 the soils will also be incinerated on-site.

 DECLARATION


     The selected remedy and all the contingency remedies are protective of human health
 and the environment, attain and comply with Federal and  State requirements that are
 legally applicable or relevant and appropriate  to the remedial action, and are cost
 effective.  The selected remedy satisfies the statutory preference for remedies which
 employ treatment that reduces toxicity, mobility or volume as a principal element and
 utilize permanent solutions and alternative treatment technologies to the maximum extent
 practicable. Although Contingency Remedy  A  also involves treatment of soils, this
 remedy would not satisfy the statutory preference for treatment as a principal element of
 the ground water component of the remedy to the extent that ground water contamination
 downgradient from the CERCLA lagoon would not be treated.

     Because the remedy will take longer than five  years to  reach health based cleanup
 levels and because contaminated beach sediments will be left in  place, a review will be
 conducted five years after commencement of the remedial action. The review is to ensure
 that the remedy continues to provide adequate protection of human  health and the
 environment.
 Signature
 James J. Scherer
 Regional Administrator
 U.S. EPA, Region VIE
 DATE: September 27,1989
 In Concurrence
 Donald E. Pizzini, Director
 Department of Health and Environmental Sciences
 State of Montana
 DATE: September 21,1989

                      RECORD OF DECISION SUMMARY
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RECORD OF DECISION TEXT
                                I. Site Description

    The Burlington Northern (Somers Plant) Superfund Site (also commonly referred to
as the Burlington Northern Somers Tie Plant or the Glacier Park Company Somers Tie
Treatment Plant, hereinafter referred to as "the Site") is located in northwestern Montana
in the unincorporated town of Somers, Flathead County (Figures 1 and 2). Fewer than
1,000 residents live in the community. The Site occupies approximately 80 acres within
the community. Residential areas abut the Site on three sides. Areas  known to be affected
by contamination from the tie plant extend from the  plant to the shoreline of Flathead
Lake, a distance of approximately 1,200 feet. In addition, beach sediments contaminated
by plant discharges extend approximately 150 feet into Flathead Lake. The Site is located
partially in the floodplain of Flathead  Lake. Flathead River  enters  Flathead  Lake
approximately five miles east of Somers. Portions of the Site along Flathead Lake and in
a slough area adjacent to the plant are wetlands. Ground water flows from the tie plant
toward the lake and slough.

Figure 1. Regional location of BN-Somers Site

Figure 2. Burlington Northern Railroad Somers TieTreatment Plant

    The Somers community is located in the Flathead Valley surrounded by the Rocky
Mountains of western Montana. Flathead  Lake and Glacier National Park (located
approximately 30  miles to the north)  are important recreadonal  areas. The Flathead
Valley economy depends primarily on lumber, fanning and tourism. Flathead Lake covers
an area of 300 square miles and is used for hydroelectric power generation at Kerr Dam in
Poison. Montana. The lake is also used for recreational fishing and boating. The  local
beach area, which is part of the Site, was formerly used as  a swimming beach, although it
was closed to public access in 1985 by the property owners because of liability concerns.
Most of the southern half of the lake area and shoreline is contained within the Flathead
Indian reservation. A Federal Waterfowl Production Area occupies much of the north
shore of Flathead Lake east of Somers. Waterfowl also breed in the  slough area adjacent
to the tie plant.

   Flathead Lake is currently the source of the Somers municipal  drinking water supply.
The Somers Water District has indicated its intention to convert to a bedrock aquifer
drinking water source in 1989. A bedrock well at the local school located approximately
1/4 mile north of the tie plant currently is the only well  in Somers which is used as a
source of drinking water. Six residences in Somers have private wells used for purposes
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other than drinking water. One of the six wells is completed in bedrock, the other five are
completed in the shallow water table aquifer. None of these wells has thus far been shown
to be affected by contamination from the site.

   The main structures on the tie plant property  include an office building, a retort
building (which housed  the  wood  treating  equipment), a boiler  house,  three large
insulated creosote product storage tanks  and miscellaneous support buildings.  Three
wastewater impoundments and one sanitary lagoon were or are also located on site. The
wastewater impoundments are discussed in the following section.

                    II. Site History and Enforcement Activities

   The Somers tie plant was operated by Burlington Northern between 1901 and 1986.
The plant treated railroad ties and other miscellaneous lumber products to protect the
materials  from weathering and insects. Treatment fluids used by BN included zinc
chloride, chromated  zinc chloride and creosote/petroleum preservative mixtures. The
treatment process generated wastewater  primarily  consisting of  steam condensate
containing zinc chloride or creosote. Other sources of process generated wastewater were
floor and shop washings, drippage from ties pulled out of the retort and drippage from
treated ties in storage. An average  of 350 gallons of wastewater were discharged per day.
Approximately 1,000 pounds of sludge from the retort was generated every one and a half
to two years (ReTec  1989). Prior to 1971, BN discharged wastewater to a lagoon located
immediately south of the retort building (the "CERCLA lagoon"). Overflow from this
lagoon discharged through an open ditch into Flathead Lake. Sometime prior to  1946, a
pond formed in the swamp area (the "swamp pond") adjacent to Flathead Lake and waste
material discharged through the open ditch accumulated here. The  final disposition of
retort sludge is uncertain. Some was reported to have been used to patch holes in local
roads. The locations of the major, presently known disposal areas at the Site are shown in
Figure 3.

    BN abandoned the CERCLA lagoon and ditch in 1971 when the company constructed
two new wastewater holding impoundments (the "RCRA impoundments"). In 1984 BN
implemented a recycling system and stopped all wastewater discharges.

    In February, 1984, the  Montana Department of Health and Environmental Sciences
 (MDHES) sampled the Site soils.  Based on the results of this investigation, the Site was
 proposed for inclusion on the Superfund National Priorities List in October 1984 (49 FR
 40320, October  15,  1984). The  proposed listing cited potential negative effects on
 Flathead Lake and the water supply for the town of Somers which is drawn from the lake.

     In May, 1985, EPA, BN and Sliters (a corporation which owns a portion of the site)
• signed an Administrative Order on Consent (Docket No. CERCLA-VHI-85-02) providing
 for an Emergency Removal action in the area of the swamp pond adjacent to Flathead
 Lake.

     The area was determined to pose an imminent and substantial hazard to Flathead Lake
 because of the presence of heavy creosote contamination hi water and soil located within
 20  feet of the shoreline. Pursuant  to the  1985  Administrative Order,  BN removed
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 approximately 3,000 cubic yards of the most heavily contaminated soils and over 100 000
 gallons of contaminated  water  from the swamp  pond are and from a portion  of the
 drainage ditch. The excavated areas were  backfilled with clean soil and rip rap was
 installed along the lakeshore.  The excavated materials  were placed in the  RCRA
 impoundments, which had  been  cleared and double-lined  for  this purpose The
 contaminated water was processed at the plant to recover any usable materials and the
 soils were transferred to the BN RCRA-regulated facility in Paradise, Montana to await
 treatment.

    In October, 1985, the EPA, BN and Sliters signed  an Administrative Order on
 £T££S™N°' CERCLJ-y™-85^) for * R«^ial Investigation and Feasibility^
 Study (RI/FS). The purpose of the Remedial Investigation and Feasibility Study was to
 determine the nature and extent of contamination at the Site, to evaluate the impacts of
 contamination  on public health and  the environment and to formulate alternatives for
 remedial action. BN began conducting the work under EPA supervision in the fall  of
 1985 and completed its field investigations in the fall of 1988. Sliters provided access to
 their property for site investigations.  A Remedial Investigation/Feasibility Study report
 consisting of final Site Investigation and Exposure and Endangerment reports and public
 review draft Feasibility Study, was submitted to EPA in the spring of 1989 (Remediation
 Technologies, 1989). Correspondence between the EPA and BN regarding the Remedial
 Investigation/Feasibility Study is contained in the Administrative Record file.

    The RCRA impoundments were filled in/and covered with pavement by BN in 1988
 pursuant to a closure plan approved by the  MDHES. Subsequent to the closure of the
 RCRA impoundments, a  ground  water  monitoring  well located adjacent to the
 impoundments  indicated that ground water  was contaminated;  therefore ground  water
 x^f^o6.  aCti°n W3S  re
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     Koppers Wood Treating Facility, Galesburg, Illinois


           DECLARATION FOR THE RECORD OF DECISION (ROD)

SITE NAME AND LOCATION

Koppers Wood-Treating Facility
Galesburg, Illinois

STATEMENT OF BASIS AND PURPOSFr


   This decision document presents the selected final remedial action for the Koppers
Wood-Treating Facility site in Galesburg, Illinois, developed in accordance with the
Illinois Environmental Protection Act, HI Rev. Stat.  1983, ch. 111 1/2, pars. 1001 et. seq.,
CERCLA, as amended by SARA, and the National Contingency Plan (NCP) to the'
maximum extent practicable. This decision is based on the administrative record for this
site.  The attached index (Appendix  C) identifies the  items  that comprise  the
administrative record upon which the selection of this final remedial action is based.

   The U.S. Environmental Protection Agency (USEPA), Region V supports the selected
remedy for the Koppers/Galesburg site.

DESCRIPTION OF SELECTED REMEDy


   The final remedy at  the Kopper's Wood-Treating  Facility in Galesburg  Illinois
consists of the following:
      Excavation of visibly contaminated soils plus a six-inch buffer layer to a depth
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        that ensures effective mitigation of groundwater contamination from "hotspots"
        identified on-site  (north  creosote  lagoon,  drip  track, northeast portion of
        pentachlorophenol (PCP) lagoon and area east of the retort building), samples will
        be taken to assess these mitigative efforts and to  confirm  final remediation to
        health-based levels; backfilling of excavated areas with "clean" soil, regrading of
        the "area • of contamination" for  positive surface. drainage;  revegetation  and
        maintenance of the affected areas.

    8   Conduct an on-site field scale biological treatment demonstration study with a
        biological monitoring program. Upon successful demonstration of technology,
        consolidation of excavated contaminated soils into a full scale cell through a
        phased loading approach. Upon treatment of the final lift of contaminated soil,
        implementation and maintenance of management measures as necessary.

    •   Construction and operation of a system of shallow interceptor trenches and deeper
        pumping wells to contain  and extract contaminated groundwater from the site.
        Extraction will continue until established in-situ groundwater clean-up objectives
        are met.  Extracted groundwater will be pretreated  in  the existing woodtreating
        facility wastewater system as necessary prior to conveyance to the Galesburg
        Sanitary District  publically owned treatment works (POTW) for final treatment.
        Treated groundwater  will meet established clean-up objectives  for surface water
        discharge prior  to release by the POTW.  Maintenance  of  the  groundwater
        remedial system; development  and implementation of contingency plans for
        alternative on-site treatment should the POTW be unable to accept site wastewater
        in the future.

    «   Monitoring  of groundwater within,  and  at the  perimeter,   of the  "area  of
        contamination"   to  assess  the effectiveness  of  the  groundwater remedy;
        development  and  implementation of  contingency  plans  for collection  of
        contaminated groundwater as  necessary. Direct monitoring  of extracted and
        pretreated groundwater prior to release  to the POTW for quality compliance
        purposes.

    «   Application and enforcement of access and land use restrictions for the "area of
        contamination" in accordance with the terms  of the anticipated Consent Decree
        with the responsible parties (RPs).

 DECLARATION

    It is the considered opinion of the State of Illinois, through the Illinois Environmental
 Protection Agency  (EPA),  following consultation with USEPA Region V, that  the
 selected remedy is protective of human health and the envkonment, attains Federal and
 State requirements that are applicable or relevant and appropriate for this remedial action
 (or invokes an appropriate waiver), and is cost-effective. This  remedy is consistent with
 the State  Contingency Plan. This remedy satisfies the federal statutory preference of
 CERCLA/SARA for remedies that employ treatment that reduces toxicity, mobility, or
 volume as a principal element and utilizes permanent solutions and alternative treatment
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                       " '    i-iiMinii i   ,,    immeai^H

 (or resource recovery) technologies to the maximum extent practicable.

    Because this remedy will result in hazardous substances remaining on-site above
 health-based levels, a review will be conducted by EPA, in consultation with USEPA
 within  five years after commencement of remedial action to ensure  that the remedy
 continues to provide adequate protection of human health and the environment
 Bernard P. Killian, Director
 Illinois Environmental Protection Agency
 DATE 6/28/89
                        DECLARATION STATEMENT

                           RECORD OF DECISION
 SITE NAME AND LOCATION

 Koppers Wood-Treating Facility
 Galesburg, Illinois

 STATEMENT OF BASTS
/rt             Document serves as United States Environmental Protection Agency
(U.S. EPA) concurrence with and adoption  of the  remedial action decision for the
Koppers site, as approved by the Illinois Environmental Protection Agency OEPA)  and
pursuant to sections 104(d) and 117 of the Comprehensive Environmental Response
Compensation  and Liability Act (CERCLA). EPA approved this remedial action in
conformance with: Illinois Environmental Protection Act; and it has provided U S EPA
with documentation to demonstrate the State's selection of the remedy conforms with the
requirements  of  the  CERCLA,  as  amended  by  Superfund  Amendments  and
Reauthonzation Act (SARA),  and  the National Contingency Plan,  to the  extent
practicable.

   The State has undertaken response action at the Koppers Facility and has sought U S
EPA concurrence in adoption of the remedy which has been selected The  US  EPA
concurrence with the State's selected remedy is based upon the items listed "in  the
attachment and the adequacy and completeness of those documents as represented by the
DESCRIPTION OF REMF.DTAT
                     provides for ^ cleanup requirements related to
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   •   Excavation of visibly contaminated soils with a six-inch buffer layer to a depth
       that will ensure effective migration of ground water contamination. Samples will
       be taken to confirm final remediation to health-based levels.

   •   Extraction and treatment of shallow and deep ground water until ground water
       clean-up objectives are based.

   •   Discharge of treated ground water  to the Galesburg  POTW that are consistent
       with pretreatment standards and/or surface water.

   •   Monitoring of ground water and bioremediation treatment.

   •   Application of access and land use restrictions for the "area of contamination."

DECLARATION

   The selected remedy  is protective  of  human health and the  environment,. attains
Federal and State requirements that are applicable or relevant and appropriate for this
remedial action, and is cost-effective. This remedy satisfies that statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volume as a principal
element and utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable.

   Because this remedy will result in hazardous substances remaining on-site, the State is
expected to supply information such that the U.S. EPA can conduct a review no less than
five years after commencement of remedial action to ensure that the remedy continues to
provide adequate protection of human health and environment.

   Based on the information described above, U.S. EPA adopts and concurs with the
decision the IEPA has made in the exercise of the  States  authority  in selecting this
remedy under an agreement between U.S. EPA and IEPA pursuant to section 104(d) of
CERCLA for implementation of the remedy, attached hereto.
Valdas V. Adamkus
Regional Administrator
DATE June 30,1989
                    KOPPERS WOOD-TREATING FACILITY
                         GALESBURG, ILLINOIS SITE
                            DECISION SUMMARY
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 RECORD OF DECISION TEXT
                 I. SITE NAME, LOCATION, AND DESCRIPTION
 Site Description


    The  Koppers Company, Inc. (Koppers) Galesburg Wood-Treating Facility site is
 ocated approximately 2 miles south of the City of Galesburg, Knox County, Illinois The
 location  and vicinity maps of the Koppers/Galesburg site are shown in Figures 1 and 2
 Appendix A, respectively. The Koppers site occupies an area of approximately 105 acres'
 The active tie treating area uses approximately 2 acres, with a large portion of the site
 devoted to railroad tie storage.

 Figure 1. Location Map - Koppers Galesburg Site

 Figure 2. Vicinity Map - Koppers Galesburg Site


    The Koppers railroad tie treating facility is located on land owned by the Burlington
 Northern Railroad Company (BN), at the southern end of the BN railroad yard complex
 Operational facilities and waste treatment/disposal areas are shown in Figure 3 Current
 operations  include:  the  treatment cylinder building and drip  track (A&S)- the office
 building (B); storage tanks for cfeogote (D); water (E); wastewater (F and W); the storage
 yard for untreated ties (G); and the wastewater treatment system. Wastewater is piped to a
 tank where it is held prior to discharge to the flocculation basin. From the flocculation
 basin,  the wastewater passes through the  oil/water separator to  the activated sludge
 treatment unit. The  wastewater is discharged from this unit directly to the Galesburg
 Sanitary District publicly owned treatment works (POTW).

Figure 3. Site Map - Koppers Galesburg Site

    Southeast of the Koppers site is the Steagall Landfill. This site is also located on BN
property  and has been included  on the Illinois  State Remedial  Action  Priority List
(SRAPL). See . Figure 4 gives additional information on the land use of the surrounding
area.                                                                         6

Figure 4. Land Use Surrounding Koppers Galesburg Plant

             IL SITE HISTORY AND ENFORCEMENT ACiiVil'lHS
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Site History

   The railroad tie treating plant, built in 1907, was operated by BN until December,
1986. At that time, Koppers leased the production plant from BN and took over operation
of the facility. The treating operation consists of pressure treatment of railroad ties in
treating cylinders utilizing a 70:30 mixture of creosote and coal tar. Previously, a 50:50
blend of creosote and number 6 fuel oil was used. During the period of 1971 to 1976, one
of the three treating cylinders was converted to pentachlorophenol (PCP) use.

   The key areas associated with past waste disposal practices are also shown in . These
areas include the "BN slurry pond" (also known as the old creosote lagoon) (J): the north
(M)  and south (L) creosote lagoons; the PCP lagoon (I); the waste pile storage area (T)
which has been consolidated in the north creosote lagoon area; two drainage ditches that
have been backfilled and regraded, the interceptor ditch (R) and the Koppers ditch (P);
and  two former spray wastewater fields (H) & (N)- The operation history of the plant's
waste disposal areas is summarized in Table 1.
   Table 1 - HISTORY OF ONSTTE WASTED DISPOSAL, KOPPERS GALESBURG
                                      SITE

   SiteApproximate Period of Use                 Activity
   Number
   J       1907-1966   Slurry lagoon that received discharge from the Lake Bracken
                       water treatment plant. (Waste excavated in 1985 from BN slurry
                        is currently stored on-site in Gondola cars and on tarp in old
                                          Spray Field Area).
   L&M   1935-1975     Originally may have been lime sludge lagoons. Creosote
                       wastewater was contained in these lagoons from approximately
                                             1963 to 1975.
   K       1935-1970   Lime sludge lagoon. Temporarily held creosote wastewater in
                              1970 when sites L&M were found to be leaking.
   N       1935-1976  Originally a lime sludge spreading area,this became the original
                            spray field for creosote wastewater from 1974-1976.
   I        1966-1974      Originally used for cooling water. Used for disposal of
                        wastewater containing pentachlorophenol from 1971 to 1974.
                            Although no longer in use, standing water is present.
 .  H       1975-1986            Former spray Geld for plant wastewater.
   R                                       Interceptor Ditch
   X                         Waste Pile, moved to creosote lagoons in 1980.

  * These areas were identified as potential RCRA "units the facility Management Plan.

     The Koppers/Galesburg site was announced for inclusion on United States National

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 Pnonty List (NPL) in December 1982. The Dlinois Environmental Protection Agency
 (EPA) accepted lead responsibilities for conduct of a Remedial Investigation/Feasibility
 Study  (RI/FS), with support from the United States Environmental Protection Agency
 (U.S. EPA). Negotiations were  carried  out with Koppers, and  Burlington Northern
 throughout  1984 and  1985  toward an agreement to  allow them  the  opportunity to
 voluntarily undertake an appropriate RI/FS. On March 19, 1985, Koppers and BN entered
 into a Consent Decree with the State (Docket Number 8.3-CH-92).  Following Work Plan
 development, the RI work took place from May, 1985, through April, 1986. The final
 report  documenting the findings of the RI was issued on  August  8  1986 A public
 meeting was held in April, 1987, to discuss this information. Additional field work has
 been conducted since that time to further characterize the site, which should also decrease
 the forthcoming remedial design  period. Supplemental data on  groundwater  surface
 water and sediment contamination off-site has been provided  by  the  RI conducted bv
 EPA for the adjacent Steagall Landfill.

   The public comment FS findings were released on May 22, 1989, as  was the Agency's
proposed plan. A public comment period was initiated that day and concluded on June 12
 1989. A Special Notice Letter and draft RD/RA Consent Decree will  be sent to Koppers
and Burlington Northern in early July,  1989,  beginning  the  moratorium period on
Remedial Design/Remedial Action (RD/RA) settlement discussions. Formal negotiation
meetings will then take place between Koppers. BN, EPA, and  the  Illinois Attorney
General's Office (IOAG), with technical support from USEPA.
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             Moss-American/Kerr-McGee Oil Co. WI
                DECLARATION for the RECORD OF DECISION

                   Moss-American Site, Milwaukee, Wisconsin

Statement of Basis and Purpose


    This decision document presents the selected remedial action for the Moss American
Site, in Milwaukee County, Wisconsin,  which was chosen in  accordance  with  the
requirements  of the  Comprehensive  Environmental  Response,  Compensation  and
Liability  Act of 1980 (CERCLA), as amended by the Superfund  Amendments and
Reauthonzation Act of 1986 (SARA) and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This decision document
explains the factual and legal basis for selecting the remedy for this Site.

    The Wisconsin  Department of Natural  Resources concurs with the selected remedy
The information  supporting  this  remedial   action decision  is  contained  in  the
administrative record for this Site.

Assessment of the Site


    Actual or threatened releases of hazardous substances from this Site, if not addressed
by implementing the response action selected in  this Record of Decision (ROD), may
present an imminent and substantial endangerment to  public health, welfare, or the
environment.

Description of the Selected Remedy


   The  selected remedy will  be the final remedy at  the  Site  and addresses  three
contaminated  media,  on-site soil,  on-site  groundwater, and sediment of the Little
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 Menomonee River. The selected remedy uses treatment to address the principal threats to
 human health and the environment posed by conditions at the Site. The remedy combines
 source removal and treatment with containment and short-term site  access restrictions,
 thus reducing the threats significantly.

    The major components of the selected remedy include the following:
    *  RemovaJ and treatment of 5,200 cubic yards of contaminated sediment and 80,000
       cubic  yards  of soil  by on-site bioremediation,  covering remaining soil  and
       treatment residue for a total of 210,000 cubic yards, on-site.

    •  Rerouting  river parallel to existing channel, filling  in and  covering existing
       channel.

    •  Collecting and treating contaminated groundwater.

    •  On-site disposal of residue from treatment of Northeast Landfill soil in RCRA
       compliant unit within the area of contamination.

    Specifically, the river  will be rechanneled; highly contaminated on-site soil  and
sediment from the old river channel  will be excavated and treated by soil-washing and
slurry bio-reactor to health based risk levels of 1 x 10-4 or less. The treatment residue and
low level remaining contamination will be covered on-site; the old river channel will be
covered with  soil from the  new  channel. Extracted groundwater will be treated by
oil/water separator and activated carbon.

Long-Term Management:


    The selected remedy provides for continuing monitoring of the groundwater  for at
least 5-10 years after the remedial action is complete. It is  anticipated  that source
removal will reduce groundwater contamination to acceptable limits  within five  years.
However, ground-water quality will be evaluated in increments of 5 years to determine if
the remedial action objectives have been met.

    The selected remedy  also provides  for  fencing  around the landfill area,  and
groundwater monitoring between the old and the new river channels.

Declaration of Statutory Determinations

    The selected remedy is protective of human health and the  environment,  complies
with Federal and State requirements that are legally applicable or relevant and appropriate
to the  remedial action and is cost-effective. A waiver is justified pursuant to Section
121(d)(4)(B) for the Subtitle  C cap and for the State double-liner/ leachate collection
system requirement, on the basis that an impermeable cap and liner that prevents flushing
of groundwater contaminants will present a greater risk to health and the environment by
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 prolonging the groundwater treatment to greater than 200 years. The selected remedy will
 comply with the Land Disposal Requirements (LDRs) through a Treatability Variance for
 the contaminated soil and debris.

    This remedy utilizes permanent solutions and alternative treatment technologies to the
 maximum extent practicable, and it satisfies the statutory preference for remedies that
 employ treatment that reduce toxicity, mobility, or volume as their principal element.

    Because this remedy will result in  hazardous  substances remaining on-site above
 health-based levels, a review will be conducted within five years after commencement of
 remedial action to ensure that the remedy continues to provide  adequate protection of
 human health and the environment.
 Valdas V. Adamkus
 Regional Administrator
 DATE 9/27/90
 RECORD OF DECISION TEXT
                                1. Site Description

    The  eighty-eight acre Moss-American  Site includes  the  former location of  the
Moss-American creosoting facility, five miles of the Little Menomonee River a portion
of which flows through the eastern half of the site, and the adjacent flood plain soils The
Site is located in  the  northwestern section  of the City  of  Milwaukee  County of
Milwaukee, State of Wisconsin, at the southeast comer of the intersection of Brown Deer
and Granville roads, at 8716 Granville Road. See Figure 1 for a location map of the Site
Sixty-five acres of the Site are undeveloped Milwaukee County park land  Twenty-three
acres are owned by the Chicago and Northwestern Railroad and used as an automobile
loading and storage area. Figure 2 shows current Site use.

Figure 1. Location Map

Figure 2. Existing Conditions


    The Little Menomonee River, portions of which are defined as part of the Site flows
through the northeastern portion of the Site, continuing on through the Milwaukee County
Parkway, to the confluence of the Menomonee River about five miles to the south The
Little Menomonee River is included in the Milwaukee Estuary and the Menomonee River
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  Remedial  Action Plans (RAP)  by virtue of its  inclusion in the Menomonee  River
  watershed. The river is classified INT-D, which means that it  is considered suitable for
  intermediate (tolerant) fish and aquatic life. The Site is located in a moderately populated
  suburban area of mixed industrial, commercial, residential, and  recreational use. South
  Eastern Wisconsin Regional Planning Commission (SEWRPC) estimates the population
  at 2,036 persons per square mile. The nature of current Site  and area uses is not expected
  to change in the near future.

     The Milwaukee County Soil Survey classifies the developed areas on the Site west of
  the river as loamy land, land consisting of fill or cut and borrow areas. The wooded areas
  on both sides  of the river consist of a poorly drained silry soil underlain by stratified
  lacustrine silt and very fine sand. The  soil is moderately permeable with high available
  water capacity. Approximately onequarter of the Site is  in the 100-year flood plain  as
  shown in Figure 3.

  Figure 3. 100-Year Plain

     The Site overlies a surficial, low yield. Class n aquifer above a confining bed of dense
  silly clay till. The confining bed is a minimum of 40 feet thick and could be as thick  as
  120 feet. Below the confining bed lies  the regional dolomite  aquifer. The saturated
  thickness above the till is between 5 and  15 feet. Groundwater flows at a rate of seven
  feet per  year from west to east,  discharging, into the river at an average rate of 8,500
  gallons per day. Depth to groundwater varies from zero feet in the wetlands near the river,
  to about 12 feet further west on the Site. The groundwater is not currently  used as a
  source of drinking water; local residents are connected to a municipal system.

     Elevations  at the Site range from 714 to 750 feet. The river drains the entire Site,
  running adjacent to the facility for about 2,100  feet. Typical  base flow water depth of the
  Little Menomonee River is I to 2 feet, with a corresponding  width of about 20 feet. Flow
  rate is estimated at an average annual of 10 -  17 cubic feet per second, with a peak rate of
  330 - 770 cubic feet per second. The sediment is typically silt or clay in composition, soft
  in some areas and hard packed in others.

                       2. Site History and Enforcement Activities

     In 1921,  the T. J. Moss Tie Company  established  a wood  preserving facility on
  twenty-three acres of the Site west of the Little Menomonee River. The plant  preserved
 railroad ties,  poles, and fence posts with creosote, a mixture of  200 or more chemical
 compounds derived from coal tar and fuel  oil. The process used a 50/50 mixture of
 creosote and No. 6 fuel oil. There is no indication that any other chemicaJs were  used at
 the facility. Kerr-McGee purchased the facility in 1963 and changed the facility's name to
 Moss-American.  The  name was changed  again  in  1974 to KerrMcGee  Chemical
 Corporation—Forest Products Division.

     From 1921 to 1971,  the facility discharged wastes to settling ponds that ultimately
 discharged to  the Little Menomonee River. These  discharges ceased in 1971  when, in
 response to a  City  of Milwaukee order, Moss-American  diverted its process water
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  discharge to the Milwaukee sanitary sewerage system. The facility closed in 1976  The
  SiTw8?   i?e.ProJ!rty Wast.ac^uired by Milwaukee County in '1978; Chicago and
  North Western Railroad bought the western parcel in 1980. Figure 4 shows historical Site
 uses.
 Figure 4. Historical Land Use
     State and national attention came to the Site in 1971 when young people, engaged in
 an Earth Day clean up of the river, received chemical burns from a tlrry substance while
 wading more than three miles down river from the Site. Sampling results indicated that
 the tarry substance was creosote and that the Moss-American facility was the source of
 the contamination.                                              }'        source or
    Subsequently, under a Wisconsin Department of Natural Resources (WDNR) order
 Kerr-McGee cleaned the eight settling ponds and dredged about 1,700 feet of river to
 remove cr^soje-contaminated soil and sediment. The settling ponds  were filled with
 clean soil, the discharge pipe to the Little Menomonee Rjver was removed and a twelve
 foot deep underground clay retaining wall constructed between the ponds and the river
 adjacent to the facility.                                         p               er'

    In 1973  United States  Environmental  Protection Agency (U. S. EPA) financed  the
 dredging of approximately  5,000 feet of river between the Site and Bradley Road  As
 Figure 4 shows, most of the dredged sediment were contained on Site  in the Northeast
 Landfill area and along the west bank of the river.

    In  1974,  U. S. EPA (under the Clean Water Act) and Milwaukee County filed a
 complaint seeking an  injunction against  Kerr-McGee  Chemical Corporation  and to
 recover costs incurred for studies and cleanup. In 1978, the lawsuit was dismissed due to
 the discovery that some of the data had been falsified.  Milwaukee  County reached a
 settlement with Kerr-McGee in which it received a major portion of the property  This
 oronertv was ann/»ri tn t\\f  t*-r\ctina ,-,-.,,„.-.. _—>.	••_   ,      .   . .  .   r   •>'
    Between  1977 and 1978, the Southeast District of the Wisconsin Department of
Natural Resources (WDNR) regulated the disposal of demolition waste from the facility
as it was dismantled by the company. This resulted in the removal and off-Site disposal of
450 cubic yards of creosote-contaminated soil.

    The water quality and soil/sediment  contamination studies done by U S  EPA and
other agencies between 1970 and 1980 indicated that gross creosote contamination was
present in the soil and groundwater at the facility as well as in the sediment of the Little
Menomonee Rjver. In 1983, the facility was placed on the National Priorities List (NPL)
pursuant to Section  105 of the Comprehensive Environmental Response, Compensation
(^of^M   (CERCLAX 42 U'S-C- Section 5605  with * Hazard Ranking Score
   In April of 1985,  notice letters were mailed to the  potentially responsible parties
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(PRPs)  which  included  Kerr-McGee,  Chicago  and  Northwestern  Railroad,  and
Milwaukee  County,  inviting them  to  negotiate for the conduct of  the  Remedial
Investigation/Feasibility  Study  (Rl/FS)  at the Moss-American Site.  All  three PRPs
attended the meeting held 8/22/85 but declined to undertake the RI/FS. Under an existing
remedial contract, U. S. EPA assigned  the consulting firm of CH2M Hill the RI/FS
project,  which began in 1987. The RI report was completed in December 1988 and the FS
approved in May 1990.
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                       Popile, Inc. Site, AR
                         rs
                       RECORD OF DECISION

  CONCURRENCE DOCUMENTATION FOR THE POPILE SUPERFUND SITE



Site Remedial Project Manager
Office of Regional Counsel
Site Attorney
Stephen Gilrein, Chief
ALNM Section 6H-SA
Carl Edlund, Chief
Superfund Programs Branch 6H-S
George Alexander, Jr.
Regional Counsel 6C
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                                    RODScan
 for Allyn M. Davis
 Hazardous Waste Management
 Division 6H

               DECLARATION FOR THE RECORD OF DECISION

                               POPILE, INC. SITE
                           EL DORADO, ARKANSAS
          Statutory Preference for Treatment as a Principal Element is Met

 SITE NAME AND LOCATION

 Popile, Inc.
 El Dorado, Arkansas

 STATEMENT OF BASIS AND PURPOSE


    This decision document presents the selected remedial action for the Popile, Inc site
 m El  Dorado, Arkansas,  which was chosen in accordance with the Comprehensive
 Environmental Response, Compensation and Liability Act of 1980 (CERCLA) 42 U S C
 § 9601 SLM& and,  to the extent practicable, the National Oil and Hazardous Substances
 Pollution Contingency Plan (NCP), 40 CFR Part 300.

    This decision is based upon the contents of the administrative record file for the
 Popile, Inc. site.

   The  United States  Environmental Protection Agency  (EPA)  has consulted the
 Arkansas Department of Pollution  Control and Ecology  (ADPC&E) on the selected
 remedy.

   Both EPA and ADPC&E are in favor of a remedy that could provide a permanent
 solution to the hazardous substances, pollutants and contaminants at the Popile  Inc site
 After consultations, ADPC&E and EPA concluded that although incineration (Alternative
 5) could most effectively destroy the hazardous substances, pollutants and contaminants
 at the Popile site, other remedial alternatives, in conjunction with ground water extraction
 and treatment (Alternative C), could provide a protective remedy.

   In a letter to EPA dated August 25, 1992.  ADPC&E  submitted  comments on the
 proposed plan for the Popile site and suggested biological treatment as a potential remedy
 for dealing with all the contaminated material at the site.  Although  EPA originally
 eliminated  biological  treatment  from the  detailed  analysis  of  alternatives   EPA
 reconsidered biological treatment in addition to other treatment alternatives during an
 extension to the public  comment period.  After review of all  public  comments and
considering the relative success of the bioremediation technology at similar wood treater
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  sites, EPA has chosen biological treatment (Alternative 6), in conjunction with ground
  IT e*tr*Ctl0i;iand f ata*nt (Alternative C), as the selected remedy. Additional design
  data will be collected combined with site specific bioremediation treatability studies to
  yenfy that remediation goals can be attained.  If remediation goals cannot be attained  a
  no migration waiver may be required, if appropriate.

  ASSESSMENT OF THE SITE


     Actual or threatened releases of hazardous substances from this site, if not addressed
  by  implementing the response action selected in this  Record of Decision (ROD)  mav
  present  an imminent  and substantial endangerment to public  health welfare  or the
  environment.                                                       ^.i£Uc, ur me

  DESCRIPTION OF THE SELECTED REMEDY


     This  final  remedy  addresses  remediation  of the  shallow ground   water  and
 contaminated soils at the Poptie, Inc. site. The principal threats posed by the  site will be
 eliminated or reduced through treatment and engineering controls

    The major components of the selected remedy include:

 Ground water
       Extraction  of shallow contaminated ground water and wood  treating fluids via
       interceptor trenches and/or pumping wells;

       Treatment and discharge of the contaminated waters on site, either to a surface
       water system or reinjection into the aquifer;

       In situ bioremediation of the deep subsurface soils via above ground bioreactor
       nutrients and/or oxygen enhancement system and reinjection  and/or infiltration
        3il6n&S  HQ
Offsite  incineration  of recovered wood  treating  fluids/carrier  oils  such  as
                    iqus (NAPLS)  •nd  dense
                    h                      •n    ense ™**v*™  Ph    iiquids
       (DNAPLS), which have been determined to be a  principal threat and continual
       source of ground water and subsurface soil contamination.
Soils
       Excavation and onsite biological treatment of contaminated soils and sludges in a



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                                  Kuuocan
       land treatment unit;

   •   Grading of excavated/backfilled areas, followed by a vegetative cover;

   •   Construction/repair of the security fence, installation of warning signs; and

   •   Conducting environmental monitoring to ensure the effectiveness of the remedy.

STATUTORY DETERMINATIONS


   The selected remedy is protective of human health and  the environment, complies
with Federal and state requirements that are legally applicable or relevant and appropriate
to the remedial action and is cost effective. This  remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element.

   Because  this remedy will result in  hazardous substances  being treated onsite for an
estimated fifteen to twenty years, the required five-year review of the remedial action will
be conducted.
Joe D. Winkle
Acting Regional Administrator
U.S. EPA - Region 6
DATE 2-1-93

                            DECISION SUMMARY
                             POPILE, INC. SITE
                           RECORD OF DECISION
RECORD OF DECISION TEXT
                I. LOCATION AND GENERAL DESCRIPTION

   The Popile, Inc., site is an inactive wood preserving operation that utilized creosote.
pentachlorophenol (PCP), and petroleum distillates in its processes.  Those compounds
constitute hazardous substances as defined at CERCLA Section 101(14), 42 U.S.C. §
9601(14), and further defined at 40 CFR  § 302.4.  Product and waste handling practices
resulted in contamination by these materials to surface and subsurface soils,  ground
water,  surface water,  and sediments.  The site  is located  on South West Avenue,
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approximately  1/4  mile  south of the intersection of South  West  Avenue  and U.S.
Highway  82 near  El  Dorado,  Union County, Arkansas  (Figure  1).   The  property
comprises about 41 acres, bordered on the west by South  West Avenue, the Ouachita
Railroad on the east, and Bayou de Loutre on the north. These three boundaries intersect
on the north end of the site.  A forested highland area borders the site on the south. The
site is approximately 3/4 mile south of the El Dorado city limits, which has a population
of approximately 25,000.  The surrounding area is rural  and residential/commercial,
although no homes are located along the site perimeter.

            II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

    El Dorado Creosote. Co., the predecessor company of Popile, Inc.,  began  using the
site as a wood treatment facility in  1947.  El Dorado Pole and Piling Company, Inc.,
purchased the property in 1958. Starting in 1976, three surface pits were used  as part of
the waste treatment process at the plant.

    The primary contaminants  found  at the site  include PCP and creosote compounds
associated  with wood treatment, which are  compounds  that  constitute hazardous
substances as defined at CERCLA Section 101(14), 42 U.S.C. § 9601(14), and further
defined at  40  CFR § 302.4.  Wood  treatment  operations  stopped  in  July, 1982.  In
September that year,  Popile, Inc. was formed and purchased about 7.5  acres of the
property, including the pits, and El Ark Industries, Inc., purchased the remaining 34 acres.
In 1984, Popile consolidated the three pits into one unit, and El Dorado  Pole and Piling
ceased to exist. Closure activities for the three surface impoundments were administered
by AJDPCE in October 1984. Following consolidation of the impoundments, inspections
by  ADPCE documented  surface  contamination and  the possibility of  ground water
contamination  at the site due to leakage from the unit.  In April 1988,  ADPCE requested
EPA  initiate a federal enforcement  action against Popile  pursuant to  the  Resource
Conservation and Recovery Act (RCRA), 42 U.S.C.  § 6901 et sea,.  In  1988 and 1989, an
EPA  Field Investigation Team conducted inspections and sampling  at  the Popile site.
The results of these  investigations revealed contaminated soils, sludges and ground water
at the site.  In June  1989,  EPA initiated a RCRA enforcement action against Popile, Inc.
and its operators, alleging violations relating to the closure and post-closure requirements
for the three  surface  impoundments.   EPA has  recently settled,  in  principal, this
enforcement matter with Popile, Inc.

Figure 1. Location Map

   In  August,  1990, EPA determined that actual  or threatened releases of hazardous
substances  from the closure area owned by Popile and the surrounding property that El
Ark owned posed an imminent and  substantial endangerment to the public health and
environment. Based on this determination, EPA conducted an emergency removal action
pursuant to Section  106 of CERCLA,  42  U.S.C. § 9606,  after Popile, Inc. and El Ark,
Inc., declined to perform the action themselves.  The removal action, conducted  from
September, 1990, until August, 1991, included grading and  shaping the site surface for
erosion control, construction of a temporary impoundment area, placing steel culverts in
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                                    RODScan
the drainage area, placing topsoil and seed over the entire site and construction of a
security fence (Figure 2). More than 66,000 cubic yards of contaminated soil, solidified
with a mixture of fly ash and rice hulls to enhance handling properties, were placed in the
temporary holding cell on the site.  EPA proposed the site for inclusion on the National
Priorities List (NPL)  in  February, 1992.  The Remedial Investigation and Feasibility
Study (RI/FS),  which was conducted by the  Alternative Remedial Contracts Strategy
(ARCS) contractor, Camp, Dresser and Mckee Federal Programs, began in January, 1992
and was completed in July, 1992.
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                 American Creosote Works, LA
              DECLARATION FOR THE RECORD OF DECISION

                 AMERICAN CREOSOTE WORKS INC. SITE
SITE NAME AND LOCATION

American Creosote Works, fee. Site
Winnfield, Louisiana

STATEMENT OF BASIS AND PURPOSE
   This decision document presents the selected  remedial  action  for the American
Creosote Works, Inc., in Winnfield, Louisiana, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation,  and  Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and, to the extent practicable, the National Contingency Plan (NCP).  This
decision is based on the Administrative Record for this site.

   The United States Environmental Protection Agency (EPA), Region 6, has consulted
the Louisiana Department of Environmental Quality (LDEQ) on the proposed remedy,
and LDEQ has written confirming agreement with the proposed remedy.

ASSESSMENT OF THE SITE

   Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response action selected in this Record of Decision,  may present an
imminent and substantial endangennent to public health, welfare, or the environment.
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	RODScan	

 DESCRIPTION OF THE REMEDY

    This Record of Decision (ROD) addresses the source of hazardous substances, as
 defined at Section  101(14) of CERCLA, 42 U.S.C. § 9601(14) and further defined at 40
 CFR  § 302.4,  which  includes  surface sludges, subsurface  pooled creosote  and
 pentachlorophenol  liquids  defined as  nonaqueous  phased  liquids (NAPLs),  and
 contaminated soil and debris.  This is the final remedy and addresses remediation of the
 source of shallow ground water contamination and contaminated soils at the  American
 Creosote Works, Inc. site.  The principal threats posed by the  site will be eliminated
 through treatment.

    This ROD addresses  the  principal  threat at the  site by  thermal  destruction
 (incineration) of the  contaminated sludges and in-situ bioremediation of contaminated
 soils,  thereby eliminating the potential for contaminant migration to surface waters and
 ground waters.  The principal threat at the American Creosote Works, Inc., site is posed
 by NAPLs and contaminated soils which are contaminating the shallow ground water.
 Additional  threats are from direct contact with creosote and pentachlorophenol sludges
 and soils at the surface of the American Creosote Works, Inc., site.  The remedial
 objectives are to minimize potential exposure by direct contact and to reduce the potential
 for migration of contaminants into the surface waters and ground waters.
 The major components of the selected remedy-include:

    (1) Pump, separate and treat liquid contaTnjpantff,  Light nonaqueous phased liquids
        (LNAPLs) and dense nonaqueous phased liquids (DNAPLs) would be pumped
        from the zones of pooled product beneath the site,  separated from the water, and
        destroyed by on- or off- site incineration.

    (2) On-site incineration of 25.000 cubic  yards of highly contaminated  tan?  and
        sludges. 25,000 cubic yards of tars and sludges located in the "sludge overflow
        area" of the site, which is the most highly contaminated material, would be
        excavated and thermally treated on-site. The incinerator ash would be  landfilled
        on-site.

    (3) In-situ biological treatment of 2SQ.QQQ cubic yards of contaminated soils. The
        remainder of the site's contaminated soils/sludges from process areas and buried
        pits would be addressed in-situ by injecting, via wells, nutrients, microbes and
        oxygen as  is  necessary to attain  stated treatment goals.   The ground water
        extraction system used for NAPL recovery would  also be used to hydraulically
        control any off-site migration of ground water  contamination and allow for
        potential recirculation of the bacteria for efficient treatment.

    Because of the expected pace of remediation, the EPA would categorize this site
    remediation as a Long Term Remedial Action.   What this  means  is  that the
   . implementation of this alternative is expected to take several years. The EPA will be
    responsible for  90% funding beyond the  customary 1 year time associated with the
    operational  and functional  period of the  completed  remedy.   90%  funding will
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    continue until such time as the established remediation goals are met.  The State of
    Louisiana will be responsible for 10% of the costs.  This component is innovative and
    is expected to provide permanent treatment.

    (4) Capping of surface contaminated soils, decontamination and on-site landfilling- rf
       process equipment aqd scrag. Grading and capping would be done to complement
       the above remedial actions.
STATUTORY DETERMINATIONS

   The selected remedy is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant and appropriate
to the remedial action, and is cost-effective. This remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element.

   Because this  remedy will result  in  hazardous substances remaining on site for
potentially  several decades,  a review  will  be conducted  within  five years after
commencement of remedial action to ensure that the remedy continues to provide
adequate protection of public health, welfare, and the environment.
Joe D. Winkle
Acting Regional Administrator
U.S. EPA - Region 6
Date 04/28/93


     RECORD OF DECISION CONCURRENCE DOCUMENTATION FOR THE
    AMERICAN CREOSOTE WORKS, INC. SUPERFUND SITE WINNFIELD
                                LOUISIANA
Robert M. Griswold, P.E.
Site Remedial Project Manager
Date 3/31/93
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                               RODScan
John Dugdale
Office of Regional Counsel
Site Attorney
Date 3/31/93
Stephen Gilrein, Chief
ALNM Section 6H-SA
Date 4/19/93
Carl Edlund, Chief
Superfund Programs Branch 6H-S
Mark Peycke, Acting Chief
Office of Regional Counsel
Hazardous Waste Branch 6C-W
George Alexander, Jr.
Regional Counsel 6C
Allyn M. Davis
Hazardous Waste Management
Division 6H
                  AMERICAN CREOSOTE WORKS, INC.
                           SUPERFUND SITE
                          DECISION SUMMARY
RECORD OF DECISION TEXT
                  1.0 SITE LOCATION AND DESCRIPTION
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                                    RODScaii
    The American Creosote Works Inc., site, hereinafter referred to as American
 Creosote, is located m the southern portion of the City of Winnfield, in Winn Parish
 Louisiana (See Figure 1).  The property consists of approximately 34 acres east of Front
 Sjxeet and north of Watts and Grove Streets as depicted in Figure 2.  The facilTis
 bounded on two sides by Creosote Branch, a perennial creek which flows in a 10-12 foot
 deep valley.  Surface drainage is predominantly via three man-made ditches and a single
 natural drainage pathway _which flow into Cxeogpjg Branch. East of the former facility is
 a denuded area containing a mat  of tar-like material,  and further east is a denselv
 vegetated area surrounding the City's sewage treatment plant.

              2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
 2.1 2.1 SITE OPERATIONS HISTORY

    The facility was used for treating timber with creosote and pentachlorophenol (PCP)
 for over 80 years  Both cxeosotfi and PCP have been identified as hazardous substances
 as  defined  at  Section  101(14)  of the  Comprehensive  Environmental Res^nse
 Compensation, and Liability Act (CERCLA), 42 U.S.C § 9601(14) and further defmed ai
 40 Code of Federal Regulations (CFR)  § 302.4.  The .American Creosote site began
 operations in 1901 under the direction  of the Bodcaw  Lumber Company  This firm
 owned 61  acres of land in the area of the site.. In  1910, Bodcaw Lumber sold 22 acres of
 toe property to  the Louisiana Creosoting Company.  Records of site operations for the
period of ownership by either of these two companies are unavailable.  In 1938, American
Create Works of Louisiana, Inc., purchased the.property from Louisiana Creosoting.
Amencan  Creosote Works ran the facility from  1938 until 1977,  during which time it
acquired an additional 12 acres of adjoining property. In 1977, the facility^ purchaLd

                      C°m     WhlCh W
                            ^           kter declared bankruP< «* seized by the
                     taXeS<       rOeit  ^ **              Stallworth Timber
Figure 1. Site Location Map

Figure 2. POST-REMOVAL SITE MAP

    Aerial photographs were utilized to interpret site conditions  over the operational
history, as reported below and shown on Figure 3. Aerial photographs provide evidence
thatthe facility was well established by 1940.  An office Lldg was^r^
Cisespte. Branch along Front Street and just south of the main entrance.  Wood-treating
operations were concentrated in the north-central portion of the site (the process area)
The process area consisted of a boiler building flanked by pressure chambers, or retorts
A tank farm  consisting of several vertical tanks lacking  secondary containment was
S3SiinT^ttSrfcea?-of      ^ buadiflg- ""* southem half of ** p™^ ™
used primarily for debarking, cutting, and staging timbers prior to treatment.

   Several sets of railroad tracks, used to transport treated and untreated lumber around

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                                   RODScan
the facility, ran from the southwest corner of the site north and northeast through the
process area to the northeast portion of the site. The railroad tracks crossed Creosote
Branch on three trestles north of the  process area.  Stacks of  untreated lumber were
present during plant operations hi the southwest and western portions of the site. Stacks
of treated  lumber were evident in the  central and north-central (north of Creosote
Branch) portions of the site. In the  1940 photographs an unnamed drainage pathway in
the northeast portion of the site follows a meandering path from the process area north
and east (through an area later referred to as the "tar mat") to a confluence with Creosote
Branch.

   Between late 1950 and mid 1952,  two impoundments were  constructed east of the
process area (Impoundments  1 and 2 on Figure 3).  These impoundments probably
received liquid wastes from the wood treating process including water, tree sap, creosote.
petroleum distillates, and PCP. A third impoundment was  constructed east of a  new
retort in the early to  mid 1960's (Impoundment 3 on Figure 3).  Based on  the aerial
photographs, the mid- to late- 1960's appear to be the period of maximum activity or
production at the American Creosote site. Records discovered in a shed on site provide
information regarding the magnitude of the American Creosote operation during  that
time. According to these records, for a seven-month period ending July 31, 1966, more
than 750,000  gallons of petroleum  distillate, 40,000 gallons of creosote, and 54,000
pounds of PCP were used to treat approximately 7.5 million board-feet of wood.

Figure 3. PRE-REMOVAL SITE MAP

   Impoundment 1  was apparently backfilled with soil and  wood chips between 1967
and  1970.  Apparent in the 1973 photographs is the development of the tar mat area,
perhaps resulting from a single spill event Located approximately 500 feet east of the
process area, the tar mat is a large, flat, asphalt-like layer which extends over a marshy
portion of the  site.  A number of mature pine trees located within the tar  mat appear to
have died shortly before the 1973 photographs were taken.  Between  1973 and 1976,
extensive earth moving operations north and east of the process area covered up most of
the darkly stained soils and obliterated the remains of Impoundment 1.  Impoundment 4
(Figure 3) was built immediately north of Impoundment 2 and may have been used to
contain drainage  from  Impoundment 2.   A  pond  was  constructed just  south of
Impoundment 2 to collect and store water for emergency fire fighting purposes.  Based on
the volume of treated and untreated  wood present onsite, wood treating operations may
have been declining during this period.

   By 1979, wood treating operations at the American Creosote site appear to have
ceased. No untreated wood and very little treated wood are present in aerial photographs
taken at that time.  All railroad tracks had been removed from  the site.  This roughly
coincides with the time at which the site owner, Dickson Lumber Company, was declared
bankrupt and seized by the City of Winnfield. Aerial photographs taken in 1981, shortly
after the site was purchased by Stallworth Timber Company, provide  evidence of the
resumption of wood treating activities at  the site. A large drainage ditch was excavated
from the south-central portion of the site north and east between the process area and
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                                    RODScan
 Impoundment 2.

    Judging from the quantity of treated and untreated wood stockpiled onsite, operations
 were taking place on  a much smaller scale  after 1980, than during the period of
 ownership by American CreQ?ote Works, Inc. By 1983, Impoundments 2 and 4 had been
 backfilled, presumably with wood chips and soil, and the impoundment retaining walls
 had been  demolished.   Impoundment 3  was  apparently still  active.   Evidence of
 continuing wood treating operations is present in photographs taken in 1983 and 1984.

    In summary, the facility was used for over 80 years as a wood treating operation that
 utilized  creosote  and  PCP  in  the treatment process.   The facility also incorporated
 petroleum products as a carrier fluid for the creosote and/or PCP. Based on a review of
 available records and site sampling  activities there is no reason to believe this facility
 used inorganic compounds (is^ chromated copper arsenate, ammoniacal copper arsenate,
 etc.) in the treatment process.

 2.2 2.2 ENFORCEMENT ACTIVITIES

    The  Louisiana  Department  of Environmental Quality (LDEQ)  issued a letter of
 warning to StaUworth  Timber  Company in January 1983, in  response to releases of
 contaminants to the environment In December 1984, LDEQ found no environmental
 improvements and issued a Compliance Order the next month.  In June 1985  LDEQ
 inspectors found the site abandoned.  In March 1987, LDEQ referred the matter to the
 Environmental Protection Agency (EPA) Region 6, requesting it to take action.  Under
 EPA's direction, several investigations of the site were conducted in 1987 and 1988.  In
 1989, the EPA Emergency Response Branch conducted a removal action pursuant to
 Section  106 CERCLA, 42 U.S.C. §  9606,  having determined that actual or threatened
 releases  of hazardous  substances from the site  posed an imminent  and substantial
 endangerment to the human health or the environment.  This response action at  the
 American Creosote site included source  control and  contaminant  migration  control
 actions.  At the time the site was found abandoned, it consisted of 15 tanks, four pressure
 vessels or retorts, a boiler building, a tool and die shop, offices and other administrative
 buildings, and several unlined waste impoundments.

   In December 1991, representatives of EPA, the United States Department of Justice
 and the  Stallworth Timber Company met.   The purpose of the  meeting was to  discuss
 reimbursement to the United  States  Government for past response costs incurred and
future costs to be incurred at the site by the United States. During the course of this
 meeting the United States learned that the Stallworth Timber  Company had sold the
property  in  1990 to Reinhardt  Investments located in the Netherlands Antilles  In
addition, during this meeting  the  Stallworth  Timber  Company was provided the
opportunity to  conduct the  Remedial Investigation (RI)  and future  activities (i.e.
Feasibility Study (FS), Remedial Design (RD), Remedial Action (RA)) associated with
the site.  The Stallworth Timber  Company indicated in the meeting and subsequently by
letter dated December 12, 1992, its  reluctance to conduct this work due to financial
inability. Further inquires to Reinhardt Investments have provided no response
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                                   RODScan
2.3 2.3 RESPONSE ACTION

   The results from EPA's investigative efforts provided evidence that the site posed a
significant human health and environmental threat.  In May 1988, the EPA issued an
Administrative Order to Stall-worth Timber Company to fence and post warning signs
around the most contaminated portions of the site.  In July 1988, the fencing of the site
was completed  by Stallworth Timber Company.  During oversight monitoring of this
action, an EPA's Emergency Response Cleanup Services (ERCS) contractor noticed that
two storage tanks were in imminent danger of rupturing.  Stallworth Timber Company
was verbally notified by EPA of this threat and declined the opportunity to respond.  This
prompted immediate mobilization of an ERCS team to drain the tanks and construct a
berm around the process area in order to contain and stabilize the heavily contaminated
soils.   Following this work, heavy  rain threatened to overflow and erode the berm.
Consequently, ERCS was remobilized to extend the berm height and install an overflow
filtration system.

   In February 1989, the EPA issued a Unilateral Administrative Order to the Stallworth
Timber Company for a removal action to address the immediate threats posed by the site
that were found during the previous investigations.  Stallworth Timber Company declined
to take action, and between March 17  and August  31,  1989,  EPA conducted  an
emergency removal action at the site pursuant to Section 106 of CERCLA, 42 U.S.C. §
9606. The following steps were taken to stabilize the site.
       Fluids from all storage tanks were consolidated into a single tank (approximately
       10,000 gallons of creosote and  PCP  treating  fluids,  51,000  gallons  of
       contaminated water, and 56,000 gallons of sludge).

       An east-west drainage ditch was constructed to redirect surface water originating
       from the southern portion of the site away from the heavily contaminated northern
       portion.

       The largest north-south drainage ditch running through the most contaminated
       area was backfilled.

       Contaminated water from holding ponds, lagoons, storage tanks, and containment
       basins was filtered and discharged to Creosote Branch.

       Waste wood treating fluids and sludges from storage tanks and contaminant areas
       were transferred to a former impoundment (Impoundment 3),  solidified with fly
       ash and rice hulls, and capped.

       Building and process equipment were dismantled and an attempt was made to
       decontaminate the debris.  This debris was placed in a scrap pile immediately
       northwest of the process area.
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                                  RODScan
tJ
                  Jeffieet Site, Houston, Texas

               DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

North Cavalcade Street site, Houston, Texas

STATEMENT OF PURPOSE


   This decision document presents the selected remedial action for the North Cavalcade
Street  site  in   accordance  with  the  Comprehensive  Environmental  Response,
Compensation and Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986 and the National Oil and Hazardous Substances Pollution
Contingency Plan, 40 CFR Part 300, November 20,1985.

   The State of Texas (through the Texas Water Commission) has been briefed on the
methods of technology and degree of treatment stated by the Record of Decision.

STATEMENT OF BASIS

   This decision is based upon the administrative record for the North Cavalcade Street
site. The attached index identifies the items which comprise the administrative record.

DESCRIPTION OF THE REMEDY

   The selected  remedy will treat the health- and environmentthreatening contamination
resulting from historical wood preserving operations at the site. Upon review of the
information contained in the  administrative record,  EPA has decided that  oil/water
separation   and  carbon   absorption  of groundwater  and  biological treatment of
contaminated soils best fulfills the statutory  selection criteria. The following is a brief
summary of the proposed remedy:
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                                    PODScan
    Contaminated surficial soils - Treat onsite using biological treatment to a level of 1
ppm of carcinogenic polynuclear aromatic hydrocarbons. In-place treatment is preferred,
but the actual  method  will be  selected from the results of pilot  testing during the
Remedial Design.

    Contaminated Groundwater - Extract and treat onsite using oil/water separation and
carbon absorption until all non-aqueous phase liquids (NAPLs) are completely removed
and benzene concentrations do not exceed 5 ug/1; incinerate the NAPLs offsite.

    EPA will  later decide the  optimal  means  for  remediating  contamination  from
polychlorinated biphenyls in the drainage ditch on the eastern boundary of the site.

DECLARATION

    The selected remedy is protective of human  health and the environment, attains
Federal and State requirements that are applicable or relevant and appropriate, and is
cost-effective. This  remedy satisfies the preference for treatment that reduces toxicity,
mobility or volume as a principal element. Finally, it is determined that  this remedy
utilizes permanent solutions and alternative treatment technologies to the maximum
extent practicable.
Robert E. Layton Jr., P.E.
Regional Administrator
Date: June 25, 1988
RECORD OF DECISION TEXT
                     1. SITE LOCATION AND DESCRIPTION

   The North Cavalcade Street site is located in northeast Houston, Texas about one mile
southwest of the intersection of Interstate Loop 610 and U.S. Route 59 (Figure 1). The
site boundaries are Loop 610 to the north, Cavalcade Street to the south, and the Missouri
and Pacific railroad lines to the east and west. The site is triangular in shape with a base
of approximately 600 feet, an apex of 3,000 feet, and an area of 21 acres.

Figure 1. Site Location Map

   The site is generally flat with several small mounds and depressions. It is drained by
three stormwater drainage ditches. Two of these flank the site on the east and west sides,
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                                    RODScan
and drainwater to the third  ditch which bisects the site into  northern and  southern
sections. The third ditch drains into a flood control ditch which discharges into Hunting
Bayou, a tributary of the Houston Ship Channel. Hunting Bayou is currently classified in
the Texas water quality standards as a limited aquatic habitat.

   The site is now used by two commercial enterprises which have erected two buildings
on the southern part of the site. The  remainder of the site is not currently used. The
surrounding areas are  residential, commercial, and  industrial properties.  The nearest
residential  area, an old low-income neighborhood, is directly to the west.  Commercial
properties are located along the major thoroughfares as well as onsite.

                                2. SITE HISTORY

   7.1 2-1  PREVIOUS SITE USE

   The North Cavalcade Street site was not developed until Mr. Leon Aron acquired the
site in 1946 and established on it a small wood preserving business, Houston Creosoting
Company,  Inc. (HCCI). The HCCI business initially included creosote wood preserving
operations. In about 1955, HCCI added  pentachlorophenol (PCP)  wood  preservation
services and other support facilities.

   In 1961, the East End  Bank of  Houston  foreclosed on the  property, and  wood
preserving operations ceased. In 1964, the bank sold the property to  the Monroe Ferrell
Concrete Pipe Company. There has been no industrial activity since 1964.

   Subsequent property owners divided the site into smaller tracts and sold them to a
succession of owners. The property is now owned by two companies and two individuals.
The Great Southern Life Insurance Company owns 1.6 acres in the southwest comer of
the site and has constructed a building. The Coastal Casting Company owns two tracts
consisting of 4.7 acres in the  southern  area of the site; the company built a building used
for engine repair upon  the western most tract. These tracts encompass the operations and
waste pit areas of the old wood preserving facility. Two other tracts are owned by R.  D.
Eichenour (3.9 acres) and A. D. Dover (10.0 acres), and represent the remainder of the
site. Figure 2 shows the current and historical site features.

Figure 2. Composite of Historical and Current SiteFeatures

                      2.2 GEOLOGY AND HYDROGEOLOGY

    The North Cavalcade Street site is in the southeast Texas Coastal Plain. This region is
underlain with Holocene and Pleistocene deposits to a depth of roughly 2400  feet. The
aquifers used to supply water for domestic, industrial and agricultural purposes are the
Lower Chicot  and Evangeline,  both confined aquifers isolated from surface  recharge.
Public water supply wells are screened in the Evangeline Aquifer at  depths greater than
600 feet. Industrial water users have wells screened  in both aquifers at depths ranging
 from 50 to 576 feet.

    The site-specific geology of the upper 50 feet is shown in Figure 3. It consists of four


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                                     RODScan
  distinct layers:

  Figure 3. Generalized Soil Profile
   Stratum  Pepthlfcl                      Description
   I           0~5                   Sandy silt and sandy clay
   H          5-12          Soft to very stiff sandy clay and clayey sand
   E*         12-26              Medium dense to dense fine sand
   IV   •      26-80   Very stiff to hard clay and silty clay with sand and silt layers

     The fine sand in Stratum H is the principal water bearing unit at the North Cavalcade
 Street site. This unit is not currently used as a source of water within Houston because the
 water  yield  is  low.  The  potentiometric  surface  developed during  the  Remedial
 Investigation shows that the groundwater flow is toward the west and is recharged by the
 ditches crossing the site.                                                     J

     2.3 2.3 REMEDIAL INVESTIGATION RESISTS

    The U.S. Environmental Protection Agency (USEPA) sampled five different types of
 environmental media at the North Cavalcade Street site between  September 1985 and
 November 1987. These included air,  surface water, sediments, soils, and groundwater
 The samples collected during this period were analyzed for toxic substances characteristic
 of wood preserving sites.                       '

    The USEPA  found  polynuclear  aromatic  hydrocarbons (PAHs)  and volatiies
 (benzene, toluene, and xylenes) in soils, groundwater, and sediments at levels above those
 natural to this area on the southern 10 acres of the site. These compounds are components
 of crgpspte. one  of the wood preserving mixtures used at the site.  The other wood
 preserving chemical used at this site, pentachlorophenol, was not found. Inorganic metals
 were infrequently found at levels above background. Tables 1 and 2 show the maximum
 concentrations of analyzed compounds in soils and groundwater and their  frequencv of
 detection above background levels.

   The contamination in soil and the upper poundwater unit describes the way in which
 historical operations contributed to the contamination. USEPA first found firgssotfi-type
 contaminants in surficial soil in two areas corresponding to the historical operation area
 and  creosote  lagoon; these areas cover approximately 1 acre. These data show that
 yrevsotq stored in these areas was allowed to seep into the soil and thereby became the
 source of further contamination. The surficial soil is a sandy clay which allows a pathway
 for vertical  migration. The crepspfc became adsorbed onto the soils until they were
saturated. At that point, the crePSytg entered the groundwater in the surface aquifer.
   The surface aquifer is a layer of sand which provides a pathway for further migration
As in the surficial soil, the creosote became adsorbed onto the sand until the sand was
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                                    RODScan
saturated. The creosote then encountered a hard clay below  the  aquifer.  Also,  the
compounds  which comprise creosote became partially dissolved and were transported
westward with the groundwater flow. The volatile compounds such  as benzene are the
more soluble; these traveled the farthest. The dissolved contaminants  in the groundwater
now form a plume covering approximately 4 acres.

   As stated  above, the creosote encountered a layer of hard clay  below the surface
aquifer and spread along the top of the clay to cover an area of approximately 6 acres. The
contamination  in this  clay layer consists of both soil  with  adsorbed PAHs  and a
nonaqueous phase liquid (NAPL)  characteristic of denatured creosote. The clay layer in
general retards further  vertical migration. The permeability of this layer is reported in
other geological investigations of this area as roughly 1O9 cm/sec.

   USEPA  also found creosote-type contaminants in the  sediments of ditches draining
the site. The concentrations of PAH compounds in the sediments ranged from undetected
to 93 ppm. This contamination probably resulted  from rainfall runoff during the time of
historical operations or oil spills along the railroad tracks.

   In addition, sediment samples  in one isolated  area near the railroad track on the east
side  of the site showed contamination from polychlorinated biphenyls (PCBs). PCBs are
not used in wood preserving operations. The cause of this contamination appears to be a
spill resulting from railroad activity. USEPA has  recently  gathered data to better define
the area, and will address remediation of the P.CBs later.

   The analyses of air and drainage ditch water showed no measurable contamination.
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Attachments
Documents to Support the
Evaluation of the Proposed
Remedy and Alternate Remedies

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                            United State*
                            Envvonmentaj Protcafan
                         OffiM Of
                         Said was* and
Supartund Publication:
»380J3-06fS
Nov«mb*r 1991
     &EPA
A  Guide to  Principal  Threat  and
Low Level Threat  Wastes
 OMct of E/ntifyancy and Remedial Response
 Hazardous She Control Division OS-220W
                                                                            Ovck Rtierenct Fact Sfteet
 TheNaponaJ Qfland haaataaSutemca tolluBon Contingency Haa^C?) pccnul«a«lon March 8. I9»state»,J«EPA expecu
 louse
                                                f(x specific types of wiutes. Although ronedy selection dectawsare
 uJtitnaiely jite-ipeclfic imt fa auj^riiinj wartefor wttcb traUne.1 or
 cootoinm«t jea«r«Hi will t» suitable asd provide, definitions, nuapies. and ROD doou»«au(h» reaulrcBKBtt rttattd to
 w«stc that 
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 Scaroplesof principal and low level thrut wastes are provided
 in Highlight 3.

     Risk Management Decisions for
     Principal and Low Level Threat
                      Wastes
 Tb« categorization of source material a* a principal threat
 or lo* level threat watte, and tkt txpcctatkws regarding
 the use of treatment sad conulntnrot technologic* /rtfcrws
 Oe/oodameatal dccisioo at to waethir any rtnedialacdon
' tsreqoiredatadte. Thesa dcterrainatJQM.and the application
 of the expectations, serve as general guidelines and do not
 dictate BJ» setettjon of a particular remedial alternative. For
 «anipic,E?A*j experience hasdemonswcd thai highly mobile
 w«tcs (e.g,. liquids) are difficult to reliably contain s.">d thus
 generally need to be treated As such. EPA expeetsalterRauvw
 developed to address highly  mcsile material  •& facts on
 ttctfmrnt options rather thai containment approaches.

 Ho*evef.ai stated in tteprearabteio the NCP(55£:i « 8703.
 March!, 1990).iheTc nuy bcsJaatioas where wanes iisnufied
as ccnsdnicng i principal  threat may be contained rather than
 treated due 10 difficulties in treating the wasug.   Specific
 situations thai may limit the use c/ gtauntw incline
/
        Treaunent technologies are not tedinicaliy feasible
        or are DCS available within a reasonable time frame;

        The extraordinary volume of nutenaU or
        complexity of the site make implementation of
        treatment technologies inipracticable:

        Implementation of i treatment-based remedy would
        result in greater ovenll risk to human health tnd
        the environment due w risks posed '£> woriccn or
        the jurrcuning community during implemenu^cn;
        Severe effecv icrott snvironrnxnul media
                   m implementation would occur.
Coavetsely. there may be situations where treatment will be
selected for bodi princip*! threat wastes itvily-  eve: threat
wanes. For exatcpte. onee a decision has been mai: la treat
wov} wa$t« .'«.g- in 3n onjjie incinerator) econox:» of
scale may make it «wt eflccJve lo treat »I1 material
inciL-ding tow level threat wastes to alleviate or rrini.-ns; the
need fot engiDeering/}r.gifntieo»l controls.

While  these expocodonx may juldc tbe development of
appropriate «Itcmaaves. the fret thii a remedy is coosiuiu
with the expecuticits coos not constitute sufficient grounds for
tha selection of thai re.-neclial tlitrnau'vc. The selector, cf sr.
approprbte wase mir.ige:r.en: strategy is de^rmined  x>!c:y
through the remedy selectioc ^ocea outliced in the NC? < i.e..
                                                            all remedy seketion deeiitoru an sitt-tpecific and mim be
                                                            based on * contcanun* aftalysit of th* ttunsutfa osin» Ac
                                                            flint aittria in accardam wia tht HCP). tndependeAiorthc
                                                            Ktffnttrm. selecttd ram«cS« must be protective, AftAR.
                                                            eompliaBj. cDR-etTccjrj, asd tat porowcnt jolutioos or
                                                            trcatroem 10 (he maximum extent practicable." Once the ratal
                                                            remedy it idecttd. consistency with the NCP exptcoiions
                                                            shootd b« tSacusssd as pan selear«rwiJaJacuoo3"ifl wtrich ffcatmcm
                                                            which permanently and significantly reducst ibc
                                                            tozieity or mobility of the hazardoas
and coauniiaants is a principal element.*  In cvalaau&g this
sUmbjty preference, the siie maaajer needs to decide whether
treacnent selected in the ROD consitutet treatiaeat as a major
cocnponutoftheremedy for that sice. Remedies wbicfc involve
treatment of principal threat wastes likely wiD sasisfy tbe
statuiory preference  for  treaonent as  a principal clement.
although tha wfll not necessarily be tree in all casea (e.g.. when
priudpAl threat wastes dtat are treated represent only a small
tneoan of (he wastet managed through coaiammenOijpround
water treatment remedies also may satisfy  the statutory
profeirKe, even though  coruanunaied  yuund  wottr is not
consiciered a principal Uucal wast; and even (hough principal
threat joww material may not be «ated\

Pectetor
                                                           The •DeddM .Summary- of the ROD should identify those
                                                           source materials that have been identified as principal threat
                                                           and/cr low level  threat wane*, and the basis for these
                                                           .itsignaikxts.  These designation* should be provided in the
                                                           'Sur* ?**.•'•'  "  3i'-g C^frif^'mti?*' Kfjoa ai  pan of (be
                                                                          nj ct> these source materials that pos« or
                                                                                                             In
addition,
                                                                                 -•? A!t*fngtivg<* »nd the
                                                           of Remedy* sections should briefly note how principal and/Cr
                                                           Vsw level Araat wanes that may have been identified a/e being
                                                           Tbe *^L8t-j!grv rv-rrmn^tions''' jecaon of tb* ROD should
                                                           inclucteacUscusslonof how the statutory preference far ircasnent
                                                           as a principal element is satisfied or explain why it 5* noc
                                                           satisfisd. sunng reasons in termsof tbe oiaeevaluatloa oiaria.

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(r-~"HraBd around w»ar generally U not cccsidei" s w be i
«»ree tnaieriil tUhoogh non-aqueouj phase liquids (NAPLj)
may be viewed u source materials.  Tb* NCP establishes i
different expecuo'cn for remediating contaminated fround
WUBT (Le.. to retum usable ground waters to (heir beneficial
uses in a tin* flW1* **1 '* reasonable gtvsa the particular
circumstances of tftesw). Examples of soon* and ncn-jourc*
materials are provided in Highlight 2.
    H1GHUGHT2:  Examples of Source
    and Non-Source Materials
    Source Materials
          Dnanned waoea
          Cflftl3ff*T"twi soil and debris
          Tools" of tense non-aqoeou$ phase liquids
          (NAPLs)sc&nerged beneath ground waw or
          in ftm-liiwi bcJruck
          N/J*-; f-ctoni on ground water
                i^atod .scdisnenu and
    Noo^Sourc* Maurialt

      •   Ground »-»«r
      •   Sur&c* water
      •   Residuals ruultin; frem tfeauheu of she
          materials
          rra; wasias are Close source materlalt considered W
be highly toxfc or W«ftly mobile thu gavatlly caraoi be
reliably conoined or would present a agnlfjeant rijk to human
NalthortbeenvtraoniemshGuldexponireoccir. Theyindade
liquids and CHhcr highly mcbite mttenalj (e.j.. solvents) or
m3ti.H«ic favtng high caacenmuens of toxic compounds No
•threshold level* of tozirtty/riik has been esnidialwd ID equie
to 'prtocipal threa." Howler, wfcere saxway and mobDuy of
generally tna?nem nJtcnuuve* sbouJd

La'*/ level threai vafl»? ars tiiox source tiuterulstbai generally
can be relhbly c«nui".«i jnd -jut would present only a lownii
in cite event of release.  They include source maie.-iali that
exhibit tow tttticitY. lov naobUicy In the enviroomcou or are
Dear
                          sc ^ce nats: ial B a principal or
iow level threat we should 'ae based on tit: inhertnc toxieiiy
as vdl as a conaderaticr. of the pi-.yjicaJ sata o.r t
               jng. aad oe ta£ t lliy and degtsdaiion produce
                  .
Of thft material.  However, thij »ncept of principal and to*
level threat «aae tfaodd >xr. necessarily be equaled with the
risks po*ed by snrcocKHTiinaaa via variocscxposare pathways.
AJ d^ough «hs chancitriiaticn of some maxrial U principal or
tow level thrcau takes inw account toucuy (md is thusrdaud
to degrseofrisk posed assaminj exposure occursj.choncwnzntj
a -*itti as a priacipai threa: does not mean that the waste posex
^e ,v.-cary nd: ai the site. =cr sample, vaitd inimi leaking
        into jrowxl waier would be comidenx! a principal
iRreu wane, yet tic primary mk at the she (anwning IhUc or
oo direct contact threat} could be ingesuon of conuminsteC
ground was. which udiscrn^asovgunoi considered 10 be
4 source materul. and thus wo»W not b« cauegaristd a I
princip*] threat

The identification of principal and low level ihreau t> raae* on
a siic-jpecifk Hf^* In some tttuaijcftt siu: wastes v3l QQ; be
readOy classirtaWe as either a principal or Ur* level threat
wua. and thus oo general expectations on ho* bewio ntaiace
these touros maeriaa ofacdtnai toxicity And moailiiy wjlj
neccarity apply. [NOTE:  latbwetttcauons waawsdonoi
bavttobechaacterUtd «s help JtroaJine  aad  {ecus tte remedy
aetecdon proceo. not as t mandatory *ra»te classifkatipn
   HIGHLIGHT 3:  Examples of Principal
   and Low Level Throat Wastes
  Wises ihat generally will be coasJdered ft cocstitutB
  principal thnatt include, but «re aox litnHed ux

         l^atnA - w«ae comtincd frt drumt. lacooot or
         tanks. fttepro4uct(NAPLs) OoaoDgoQ or under
         ground ««er(|enenlly txciudin j pound »atff)
                  v wacusants of eoncern*

                source mgieriaT  - surface soil or
         subsorface coil comaining high conceniraUons
         of jootamtnaiui of ccncwn Aaure (or potentially
         » s)  aobilc dee (0 wiatf eatreinmeni.
         volaclizadon (tg.. VOCsX surface ronoff. or
         jab-sartjce wnspoiL
         non-liquid wastes, buried units cenuuniag non-
         liquid wastes, or lofls eonaining  significant
         concenoationc of ni jMy toxic materials.

  .Waste (hat generally win becocutfered to cousiiwietow
  level ifereu wacies icdude. but an not limned to:
         contamlnaati of concern  thai generally are
         relatively imraobtle in aii or ground waicr (i.t.,
         iKwi-llquld, lerr rotKility. low teachaa.lity
         eonuminanu «uch as high moiecular weight
         compoondi)  IB the specific
         •ottinj.
         soil conccinirauoas X< greatly above reference
         doss Jevels or thai present an tx-sss career n±

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EPA
           United Stales
           Environmental Protection
           Agency
              Office
 fice of Solid Waste And
Emergency Response
(5102W)
EPA 542-11-94-005
Number 6
September 1994
Innovative Treatment Technologies:
Annual Status Report

(Sixth Edition)
                                         V $ Fruited of i llucyrloil f\n

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                              Table B-1
Removal Actions: Site-specific Information By Technology Through FY 1993

                        Bioretnediation (Ex situ)
June 1994

Region


2



4





S






6




r


•

Site HIM, Stite,
(ROD Date)


CCL Tie end Treating,
NY
Emergency Reaponse

Southeastern Wood
Preserving, MS
Emergency Response
(Action Heno signed
09/30/90)
See also Soil Hashing
Indiana Wood Treating,
IN
Emergency Response
(Action Heno signed
10/11/92)




H*c*iU«n Ring Free
Oil Company*, AR
Emergency Response
(Action Hem signed
11/09/92)

Scott Lumber, HO
Emergency Response
(Action How signed
07/10/87)

Specific
Technology


Composting



Slurry phese
(preceded by
toll washing)



Composting






Solid phase




Lend treatment




Site Description
«


Wood preserving



Uood preserving





Wood preserving






Petroleun refining




Uood preserving




Media (Quantity)


Soil (4,800 cy>



Soil (12,000 cy)





Soil (18,000 cyi






Sediments (38,000
cy)



Soil (16,000 cy)




Key Contaminants
Treated


PAHs (Creosote)



PAHs (Creosote)





PAHs (Creosote)






VOCS (8TEX), PAHS
(OAF Float)



SVOCs (Phenols,
PAHs
Benzo(a)pyrene)


Status*


In design;
Pilot study
completed in
Jan 1994
Conpleted;
September 1994




Operational;
Completion
planned Fall
1994; After 6
months 8 of 9
compost piles
belou
treatment
target levels.
Being
installed;
project
completion
date planned
Fall 1995
Completed;
Operational
from 1987 to
Fall 1991

Lead Agency
and Treatment
Contractor (if
available)
Federal
lead/Fund
Financed;
ERT/REAC
Federal
lead/Fund
Financed; OHM
Remediation
Services Corp

Federal
lead/Fund
Financed; IT
Corporation,
CMC, Inc. •
subcontractor



Federal
lead/Fund
Financed;
Reidel
Environmental
services
Federal
lead/Fund
Financed;
Remediation
Technologies
Contacts/Phone


Joe Cosentino
908-906-6983
Carlos Ramos
212-264-5636
Don Rigger
404-347-3931




Steve Faryan
312-353-9351






Charles Fisher
214-655-22?



Bruce Morrison
913-551-5014




-------
Region
                                                                         Table B-1
                                    Removal Action.: Site-speclflc Information By Technology Through FY 1993

                                                                       Soil Washing
                                                                                                                                        June 1994
Slt« Hawe, Stati,
(ROD Data)
            Southeastern Mood
            Preserving. HS
            Emergency Responst
            (Action Meow *l«ntd
            09/30/90)
            See alto
            BioreawdUtion (Ex
            Situ)
            Poly-Carb, HV
            Emergency Respons*
            (Action Haew signtd
            05/14/«7>-
            SM »l*o
            BloreMdtitton (Ex
            Situ)
Specific
Ttchnology
                        Soil waihtng
                        (•md  removal,
                        followed by
                        bloremedUtion
                        of fines
                                    Soil  Wishing
                                                     Site Description
                                                     Wood preserving
                                          ComercUl waste
                                          management
                                                                         Media (Quantity)
                                      Sludge  (quantity
                                      uiknowi), Solids
                                      (1,000  cy)
                                                                          Soil  (1,500 cy)
                                                                                 Key Contaminants
                                                                                 Traated
SVOCS, PAHS
(Creosote)
                                                          SVOCs (Phenols),
                                                          PAHs (Cresol)
Operational;
Completion
planned Spring
1994
                   Conpleted;
                   Operational
                   7/87 to 8/88
                                   letd Agency
                                   and Treatment
                                   Contractor (If
                                   available).
Federal
lead/Fund
Financed; OHM
Remediation
Services Corp.
                 Federal
                 lead/Fund
                 Financed;
                 Reldel
                 Environmental
                 Service!
                                                                                                                                                Don Rigger
                                                                                                                                                A04-347-3931
                                                                                                                                                 Bob Handel
                                                                                                                                                 415-744-2290

-------
                            TABLE E-1
REMEDIAL ACTIONS: PERFORMANCE DATA ON COMPLETED PROJECTS (continued)
June 1994
. f
111 III III III Material* II! ' ||| II
Technology/ Media Treated Key ContMinant* Operating III Handling III Residua It
Vendor ||| (Quantity) ||| Treated ||| Parantter* ||| Required (([Management ||| Coroenti II













4


4«















I I 1
Broun Wood Preserving,
FI
10/68 to 12/91











Holllngsworth
solder tecs, FL
1/91 to 7/91

UaiKhea, SC
During 8/93















Land treatment/
Remediation
Technologies,
Inc.
Seattle,
Washington








Soil vapor
extraction
EBASCO (ARCS
contractor)
Thermal
desorptlon

Four Season*
Greensboro, NC












Sol 1 /pond
sediment (7,500
cy)











Soil 60 cy (doun
to 7 feet deep)


Soil (2,200 cy)

















PAHs, defined in
tenas of total
carcinogenic
indicator chemicala
(TClCs)

Criteria:
100 ppm TCICt
sampled on 8
subplot*

Input: Up to 200 ppt
TCIC*
Output: Lees than 92
ppm TCIC*
TCE, vinyl chloride
Target: total VOCs
1 pp.

Criteria:

Acetone - 97 ppm
Benzene - 2.43 ppm
1,2-Oichlorobenzene-
- 33.43 ppm
1 ,4-Dichlorobenzene-
- 38.06 ppa
2,4-Dinltrotoluene -
3.62pp.
Naphthalene • 74.6
pp»
Toluene - 34.5 pea
1,2,4-
Trichlorobenzene •
4.23 pp.
Total Xylenes - 67.6
PPM
Soil treated In 3
lift*
Retention tine: 4
to 15 Month*

Additive*: water
and nutrient*

Mixing rate:
tilled once every
two week*



In »itu


Continuous feed
5-7 tons/hr
















Site
preparation
(land
clearing)

Excavation
Screening
Tilling







Hone required




















Treated
material
vegetated with
Snss (no cap)

Retention pond
constructed for
runoff







Air emissions
vented to
atmosphere

Catalytic
oxidation of
off -gas















Further Information on
this project is
available from the
Remedial Action Close
Out Report.










Design specification*
were vary critical.
Need to pay close
attention to design




















-------

-------
Environmental
Remediation
Cost Data-
Unit Price
4th Annual Edition

-------

-------
     Application of Blocultureto Contaminated
                           	_
     Llflht Petroleum Hydrocarbon Deoraders
     Microorganisms
    L-103 Light Petroleum Biocultures, per 100 Lb
                    - --- __

   Htavy •Pttrol.urr, HydrocarbortfCrB
-------

|33 13 Pi^siCal Treatment ; '"H

33 13 0903 Treat 15,000 -19,999 Tons of Soil, Including
Residual Water
13273 5103 Treatment of 15.000 Tons of Soil. Including
Residual Water
33 13 0904 Treat 20.000 -24,999 Tons of Soil, Including
Residual Water
13273 5104 Treatment of 20,000 Tons of Soil, Including
Residual Water
33 13 0905 Treat 25.000 -29.999 Tons of Soil, Including
Residual Water
13273 5105 Treatment of 25.000 Tons of Soil. Including
Residual Water
33 13 090S Treat 30.000- 34,999 Tons of Soil, Including
Residual Water
13273 5106 Treatment of 30.000 Tons of Soil, Including
Residual Water
33 13 0907 Treat 35,000 -39,999 Tons of Soil, Including
Residual Water
132735107 Treatment of 35,000 Tons of Son, Including
Residual Water
33 13 0998 Treat 40.000- 44,999 Torn of Soil, Including
Residual Water
13273 5108 Treatment of 40.000 Tons of Soil. Including
Residual Water
33 13 0909 Treat 45.000 -49,999 Tons of Soil, Including
Residual Water
*
13273 5109 Treatment of 45.000 Tons of Soil. Including
Residual Water
33 13 0910 Treat 50,000 -54,999 Tons of Soil. Including
Residual Water
13273 5111 Treatment of 50.000 Tons of Soil. Including
Residual Water
33 13 0911 Treat 55.000 -59.999 Tons of Soil, Including
Residual Water
13273 5112 Treatment of 55,000 Tons of Soil, Including
Residual Water
33 13 0912 Treat »• 60.000 Tons of Son, Including
Residual Water
13273 5113 Treatment of 60.000 Tons of Soil. Including
Residual Water
33 13 0915 Mobilize/Demobilize Soil Washing System
13273 5114 Mobaize/Demobiliza Soil Washing System
TON
TON 20
TON
TON 20
TON
TON 20
TON
TON 20
TON
TON ' 20
TON
TON 20
TON
TON 20
TON
TON 20
TON
TON 20
TON
TON 20
Ml
Ml 0
CODEG 1.00
CODEG 1.00
CODEG 1.00
CODEG 1.00
CODEG 1.00
CODEG 1.00
CODEG 1.00
CODEG 1.00
CODEG 1.00
CODEG 1.00
N/A 1.00
Environmental Remediation: Unit Cost

1.89 1.79
1.69 1.79
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
1.89
0.00
0.00
Book
1.79
1.79
1.79
1.79
1.79
1.79
1.79
1.79
1.79
1.79
1.79
1.79
1.79
t.79
1.79
1.79
1.79
1.79
0.00
0.00

^iia-aaaa
35.00 MM
35.00 3tm
135.00 13BJI
135.00 1MB
135.00 m«
135.00 13M
117.50 121.JI
117.50 ttt.»
117.50 121.1*
117.50 «l«
102.50 10U»
102.50 «**
102.50 10t*
102.50 l
81957
fli:
.arc
f*
fe
p
1*
SK-

-------
    33 14   Thermal Treatment
   33 14 0114  Circulating Bed Combuslor, Fixed Cost        EACH

   13277 2273  Circulating Bed Combuslor. Fixed Cost with Unit    EA
        •	Installation, Monitoring. Operation, Maintenance

   33 14 0115  Supercritical Wafer Oxidation, Operations       TON
               Cost

   13277 2274  Supercritical Water Oxidation, without
  .	Mobilization/Demobilization. Prelreatment


  33  14 0116  Supercritical WaterOxidalion. Fixed Cost

  13277 2275  Supercritical Water Oxidation. Fixed Cost with
               Unit Installation. Monitoring, Operation.
              Maintenance
                                                                                 0.00

                                                              N/A      1.00       o.OO
                                                                                          0.00 1,113.000

                                                                                          0.00 1.113.000
EACH

 EA
                                                                                0.00

                                                             N/A      1.00       0.00
                                                                                          0.00  1.325.000


                                                                                          0.00  1.32S.OOO
1.32WOS


1,325.000
  33140117  Advanced El.cJrlc Reactor. Operations Cost    TON
  13277 2276  Advanced Electric Reactor, without
  	    Mottfcation/Demobilaation. Pretreatmenl


  33 14 0118  Advanced Electric Reactor. Fixed Cost        EACH


  132772277  Advanced Electric Reactor. Fixed Cost with Unit    EA
              Installation. Monilorino. Operation, Maintenance
            ^	
                                                             N/A
                                                             N/A
                                                                      1.00
                                                                      1.00
                                                                                0.00

                                                                                0.00



                                                                                0.00

                                                                                0.00
                                             0.00   702.51   702.11

                                             0.00   702.52    TOZSt



                                             0.00 4,001,500  4.901,5*


                                             0.00 4,001.500  4.001JOJ
 33 14  0201



 13277 3511



 33 14 0202



 13277 3512



 33 14 0203

 13277 3513
 Minimum Mobilfze/DeMobllize Chirac <«1 000  EACH
 Mil«, Mobile Process Unit


 Minimum MobilizaSon/Demobilirafion Charge <=   EA      o
 1.000 Mies, for Mobile Process Unit
                                            Ml
 Addlllonil MobilizeTOeMobillze Cnar8« per     MILE
 Mile. Mobile Process Unit

 AddiBonal Mobilization/Demobilization Charge :
 1.000 Mites, for Mobile Process Unit
——	.

 P«rmlttlno/£nginwrlnB far Site

 Permittina Site with Traatability Studies
 Interlacing with Regulator
                                          EACH


                                           EA     0
                                                            N/A
                                                            N/A
                                                                       N/A
                                                                     1.00
                                                                     1.00
                                                                                1.00
                                   0.00      D.OO   84,800   M,8»



                                   0.00     0.00   B4.800   *«•«*



                                   0.00     0.00    68.90


                                   0.00     0.00    68.90



                                   0.00     0.00  35,000

                                   0.00     0.00  35.000
             Direct Firino. R»ntal and Oparallons Cost       TON

             Soil Volatilization in Southeast Region            TON    25

             Indirect Firing. Rental and Operations Cost      TON
                                                         CODEC    1.00
            Son Volatilization in Northeast Region
13277 3516
Mln Mob/Demob Chra for Sm Portable LTTD     EA
Unt»<-I000mi

Min. Mob/Demob Charge for SmallPortabte         EA     n
LTTD Units <= 1000 mi                  •
                                                      TON    25     CODEC    1.00
                                                                       N/A
                                                                                1.00
1.51
1.51
1.51
1.51
0.00
0.00
1.44
1.44
- "•
1.44
1.44
0.00
0.00
127.50
127.50
130.00
130.00
0.00
0.00
                                                                                                                    .1

                                                                                                                    I
                                                                                                                    ir
 31

.£0

 M

 BO

 »


                                                                                                                     001
                         Environmental Remediation:   Unit Cost Book
                                                                                                                t

-------
  33 19 9510  Noncnergetic Drummed Sludge Incineration.   EACH
              56 Gallon

  13277 2621   Drummed Sludge. Non-Energetic. Amenable to     EA      0
              Striking, 55 Gallon Drum
                                                                                         0.00     0.00


                                                                       N/A     1.00      0.00     0.00
                                                                                                         320.00   350.00


                                                                                                         320.00   '320.00
  33 19 9511  Drummed Sludge Requiring Repack           EACH
             Incineration. 55 Gallon

  13277 2622  Drummed Sludge Requiring Repacking. 55        EA     0
             CaBonDrum
                                                                                         0.00     0.00    1,038     1.031


                                                                       N/A     1.0C      0.00     0.00    1.038     1.0M
 33  19 9512  Lean Water Incineration for Non-PCB 55
             Gallon Drummed Waste
                                                      EACH
 13277 2623  Lean Wafer Intineraticn lor Non-PCB Drummed     EA
             Waste. 55 Gallon
                                                                                         0.00     0.00    507.50   SOT.50


                                                                      N/A      1.00       C.OO     0.00    507.50   507.JC
 33 19 1513  Lab Packs Containing Nonnactiv* Material     LB
             Incineration
 13277 2624  lab Pack* Containing Non-Reactive Material
                                                      LB
                                                                      WA      1.00
                                                                                         0.00


                                                                                         0.00
                                                                                                  0.00


                                                                                                  0.00
2.25     Z-25


2.25     Z»
 33 19 9514  Ftoorinated Aerosol Cans Incineration          LB

,132772625  Aerosol Cans, Ftoorinated                      LB
                                                                      N/A      1.00
                                                                                         0.00

                                                                                         0.00
 33 19 1515  Nonflucfinatid Aerosol Cans Incineration      LB

 13277 2626  Aerosol Cans, Noo-FkKJrinaled                 LB
                                                                      N/A      1.00
                                                                                        0.00

                                                                                        0.00
 33 19 9516  Drummed Waste Containing Over 5%         EACH
            «*tog«n. Extra Charges

 13277 2627  Extra Charges for Waste Containing Over 5%      EA
            Halogen
                                                                      N/A     1.00
                                                                                         0.00


                                                                                         0.00
 33 19 9517  Drummed Wast* Containing Over 10% Ash,    EACH
            Extra Charges

 13277 2628 Extra Charges far Waste Containing Over 10%     EA
            Ash
                                                                     N/A      1.00
                                                                                        0.00


                                                                                        0.00
33 19 9518 Wast* Packed In 85 Gallon Metal Drums.       EACH
            £xta Charges

132772629 Extra Charges for Waste Packed in Metal 85       EA
            CaSon Drums
                                                                     N/A      1.00
                                                                                        0.00


                                                                                        0.00
33 19 9519  Wist* Packed In 85 Gallon Plastic Drums,     EACH
            Cxtra Charges

132772631  Exta Charges far Waste Packed mPbslices      EA
            Galon Drums
                                                                     N/A      1.00
                                                                                        0.00


                                                                                        0.00
                                                                                                                             r
                                                                                                                             13

                                                                                                                             XI
                                                                                                                            tr

                                                                                                                            D
33 19 S520  Incineration of Bulk Solid Waste (2.000 Lb/CY)   CY

13277 2653  Incinerate Bo*t SoSd Waste                    LB
                                                                     N/A     000.0
                                                                                        0.00

                                                                                        0.00
33 19 1521  BuflC Uqultts, 2,000 U> 12,000 BTU,            LB
            incineration

13277 2642  Buec Liquids. 2.000 BTU to 12.000 BTU. per       LB     o
            Pound
                                                                     WA      1.00
                                                                                        0.00


                                                                                        0.00
                        Environmental Remediation:  Unit Cost Book

-------
      A SUMMARY  OF REMEDIAL  OPTIONS
         FOR GAS HOLDERS AT FORMER
       MANUFACTURED GAS  PLANT SITES
                                    by Kurt Prochorena,
                                    Ash Jain, and
                                    Dennis Unites
              Some of the Issues Addressed in This Report:
         The Characterization of Gas Holders
         Waste Treatment Methodologies
         Dawatering
         Removal oi Tarry Material
         Treatment Selection
         Excavation Alternatives
         In Situ Remediation
ATLANTIC	
ENVIRONMENTAL SERVICES. INC.  188 NORWICH AVENUE  COLCHESTER. CONNECTICUT 06415  <203) 537-0751

-------

-------
  of large volumes of hazardous waste are many.  On-site materials handling such as removal of
  debris, waste mixing and/or stabilization, and loading for transport would need to be conducted
  under stringent guidelines and may require  expensive additional controls such  as conducting
  operations within enclosed structures.  Hazardous materials transportation requires  special
  haulers and permits and involves liability in  cases of accidental releases.  When considering a
  disposal/treatment  option for hazardous  materials, transportation costs of  approximately
  $0.15/ton/mile  can be expected and can contribute significantly  to the overall  cost  of. a
  remediation program. Finally, facilities permitted to handle hazardous MGP materials are not
  available for  many  cost-competitive disposaytreatment methods such  as thermal desorption,
  asphalt batching, utility boiler fuel use, or  brick or cement loins.   Incinerators are widely
  available, but in many cases cost-prohibitive.

        Options currently available for the disposal/treatment of hazardous MGP materials are
 limited to hazardous  waste landfills and hazardous waste incinerators.  Treatment/disposal of
 hazardous  soils via  incineration  have  been  quoted at  $l,000/ton to  $l,500/ton  plus
 transportation, while landfilling costs can  range from approximately $150 to  $200/ton  plus
 transportation.  Many companies are leery of landfilling hazardous materials due to the long-
 term liability  associated with the waste, since the waste is not destroyed.  Also, the landfill
 option will be available only until land ban rules eliminate the land disposal option completely.
 Assuming the typical 50 ft (diameter) by 15 ft (depth) holder, approximately 1,090 cubic yards
 of material could potentially require disposal.  This volume could result in incineration costs as
 high as approximately $2.4 million plus transportation, with landfilling costs of approximately
 $330,000 plus transportation.  The complications and liabilities associated  with managing
 hazardous waste, coupled with limited disposal options  and high cost,  render excavation and
 treatment/disposal of hazardous holder materials undesirable.

        3.1.2  Excavation of Holder Material as Nonhazardous

        If holder materials were characterized as nonhazardous, remediation through excavation
 followed by on or off-site treatment could be done directly after holder dewatering, if required.
 Lower costs associated with the management of nonhazardous waste materials would facilitate
 remedial activities.  Numerous options  exist for the disposal/treatment of nonhazardous holder
 materials. Most of the disposal/treatment methods are widely available and, because they deal
 with nonhazardous waste only, have lower liabilities associated with them.

        Treatment via thermal desorption can be  conducted on site or  off site.   Thermal
 desorption treats nonhazardous wastes to target levels by heating contaminated materials to drive
 off organic compounds through volatilization.  It is not a combustion process, since the material
 to  be treated is  not burned.  Treatment of contaminated materials at commercial stationary
 facilities generally ranges from $50 to $100/ton plus transportation, and mobile units for on-site
 treatment generally range from $100 to $250/ton,  plus mobilization and demobilization costs.
 Using the upper end costs for off-site and on-site treatment of material from the typical 50 ft

 Summary of Remedial Options	   -12-	            February 1995
A TLANTIC Environmental Services, Inc.

-------

-------
3-EPA
United States
Environmental Protection
Agency
                        Office ol Research and
                        Development
                        Washington DC 20460
EPA/S-IO/Aa-92/015
October 1992
Demonstration of a Trial
Excavation at the McCoIl
Superfund Site

Applications Analysis Report
      SUPERFUND INNOVATIVE
      TECHNOLOGY EVALUATION

-------

-------
                                          EPA/540/AR-92/015
                                          October 1992
Demonstration of a Trial Excavation

    at the McColl Superfund Site


     Applications Analysis Report
       Risk Reduction Engineering Laboratory
        Office of Research and Development
       U.S. Environmental Protection Agency
             Cincinnati. OH 45268
                                 Printed on Recycled Paper

-------

-------
 lion air will be routed through an emission-control system to
 prevent the escape of significant air emissions into the area
 surrounding the excavation zone.

    During the trial excavation at the McColl site, a rigid-frame,
 PVC-covered enclosure structure was erected over part of the
 L-4 Sumppriorlothe start of excavation. Theenclosure proved
 to be effective in preventing the escape of air emissions during
 excavation.
 Problems Related to Enclosure Structure

    The encbswecrcatedaoonfined work space m which tempera-
 tures were approximately OTF above the outdoor temperature.
 During the trial excavation, diesel engines were operated on Ihe
 «rackro^baddKXi'Joader,Bc
-------

-------
 Utilities finding
 themselves
 between a rock
 and a hard place
 now have  a
 solution for their
 MGP soils


 Take
By Wm. Chip D'Angelo and Anthony Chiesa
          ecognizing the need to remediate contaminated
         \ Manufactured Gas Plant (MGP) sites, a local utility sought
         F innovative and cost-effective solutions,. Jn response to that
          need, Casie Protank, a waste transportation, transfer and
          treatment facility in New Jersey, and American Eco Corp.,
         kan international provider of environmental, construction
and industrial services, formed Mid Atlantic Recycling Technologies Inc.
**»1/\K I /.

 Under a five year agreement with the utility and its prime remediation
contractor, MART agreed to commit the necessary resources to finance,

                                 Continues on page 8-»

6 June 1998 Soil & Groundwater Cleanup

-------

-------

                 MGP REMEDIATION USING THERMAL DESORPTION:
            EMERGING TECHNOLOGY YIELDS A PERMANENT SOLUTION
                                  Daniel E. Umfleet, P.E.
                                     Project Manager
                                Barr Engineering Company
                                     P.O. Box 130917
                                Ann Arbor, MI 48113-0917

                                Susan Anderson Bachman
                                    Corporate Attorney
                                     Edwin Highland
                            Director of Safety and Environment
                                Northwestern Public Service
                                    600 Market Street
                                      P.O. Box 1318
                                     Huron, SD 57350
                                       ABSTRACT

   In 1994, Northwestern Public Service hired Barr Engineering Company to conduct an investigation
of a former manufactured gas plant (MGP)  at the site for  its new operations  building.  The
investigation uncovered evidence of MGP residuals in the moist, clay-rich soils, and Barr worked with
Northwestern to remediate the site without causing expensive delays to construction of the operations
center. Because this was the first MGP remediation in South Dakota, Northwestern and Barr worked
closely with the state's Department of the Environment and Natural Resources to gain the necessary
regulatory approvals.

   As its remediation method, Northwestern selected on-site thermal desorption. Full-scale cm-site
thermal desorption has been used at only a handful of MGP sites in the United States, although the
technology  has been used successfully to treat petroleum compounds. However, thermal desorption
offered  several advantages over other remediation  options, including  lower  cost and  reduced
environmental liability, as the soils never left the site. A low-temperature, counter-flow, direct-fired
rotary desorber heated soils up to 1200 degrees F to volatilize organic fractions.  Soils containing
polyaromatic hydrocarbon (PAH) compounds were excavated, treated effectively, and reused at the site
as backfill.

   For the approximately 47,000 tons of soil processed, remediation costs were $82 per ton. Site-
specific factors affecting project costs  included the volume of soil treated, soil type and condition,
inclement weather, and market conditions. Soils were treated to below state-approved performance
criterion, and remediation of the site was completed just 18 months after the project began.

-------
x-        Conservative assumptions were made regarding the most probably future land-use scenario, potential
'          receptors, and routes of exposure. The risk-based treatment performance criterion of 43 milligrams per
          kilogram for the sum of carcinogenic PAH compounds was developed using equations set forth in
          published EPA guidelines. The SD DENR approved the treatment performance criterion.

              The second phase of the remediation began in March 1995 and was completed in September 1995.
          During this phase, the remaining soils with PAH concentrations exceeding the excavation criteria were
          excavated, then soils from both phases were treated by thermal desorption and used as backfill on site.

          Thermal Desorption: How It Works

              In choosing thermal desorption, Northwestern selected a technology that, although widely used
          to treat petroleum compounds, is still a relatively new method for remediating MGP soils.  Full-scale
          on-site thermal desorption has been used at only a small number of former MGP sites in the United
          States.  However, thermal desorption offered several advantages.  In addition to being the least
          expensive method, it also allowed Northwestern to treat MGP soils on site using a mobile treatment
          unit. On-site remediation was more protective of the environment because it eliminated the need for
          truck- or railcar-loads of MGP soils to be transported through residential  areas and the countryside,
          thus preventing potential off-site accidents.

              The basic steps in the thermal desorption process are material preparation, thermal desorption,
          off-gas treatment and air emissions control, and cooling and dust control. At the Huron site,  a test run
          was completed to optimize operating parameters of the thermal desorption system before full-scale
          treatment began. To maximize the efficiency of the system, excavated soils were prepared to render
          the particle-size range (less than two inches in diameter), moisture content (13-26 percent), and PAH
          concentrations (84—1,410 milligrams per kilogram) of the feed stream more homogenous. Soils were
/stockpiled to reduce moisture content and turned mechanically to accelerate the drying process.
*          Prepared soils were placed into a feed chute equipped with a final screening device to remove any
          remaining oversized materials. The soils were then conveyed  into the thermal desorption unit, a
          rotary, low-temperature thermal desorption (LTTD) system designed and constructed specifically to
          remediate materials containing heavy hydrocarbons and polycyclic hydrocarbons,  such as PAH
          compounds (Figure 1). The conveyor system can move between 20-50 tons  of soil per hour, depending
          on the soil type, moisture content, and composition.

              The LTTD system has a two-stage, counter-flow, direct-fired rotary desorber, which is 38 feet long
          and designed to provide  the residence time (approximately 18 minutes) necessary to desorb PAH
          compounds and heavy petroleum products. In the first or low-temperature stage (LTS), the soils are
          fed in a direction countercurrent to the combustion gases, heated to approximately 300-500 degrees F
          to remove the light hydrocarbons and water vapor, then passed into the second or high-temperature
          stage (HTS). The HTS heats soils, as necessary, up to 1200 degrees F, the temperature required to
          desorb heavy and polycyclic hydrocarbons. These are then routed back through the LTS burner flame
          and oxidized to lighter hydrocarbons. This recycling increases the system's fuel efficiency because the
          HTS off-gas material becomes fuel for the LTS. Recycling also lowers the  temperature of the off-gas
          passing through the baghouse, so that it is cool enough not to burn up  the baghouse yet still hot
          enough  to inhibit  condensation of desorbed organics onto bag  filters. The  LTS off-gas is directed
          through the primary baghouse for particulate removal and  then through the thermal oxidizer for
          thermal destruction at temperatures up  to 1800 degrees F. The off-gas  is discharged  into  the
          atmosphere, while the particulate collected in the baghouse is returned to the thermal desorption unit
          for treatment, then mixed with the treated soils.

             The treated soil mixture is cooled, wetted and discharged onto the ground.  Fugitive dust emissions
          from the cooling and wetting process are collected by an auxiliary baghouse and steam is discharged
          into the atmosphere. At the Huron site, oversized materials and treated soils were used to backfill the

-------
                             Table 1. Soil Analytical Parameters
Parameter
Target Analytical Detection Limit
(in milligrams per kilogram)
Carcinogenic PAH Compounds {U.S. EPA Method 8270)
Benzo(a)anthracene
Chrysene/Triphenylene
Benzo(b)fluoranthene
Benzo(k)fiuoranthene
Benzo(a)pyrene
Indeno( l,2,3-cd)pyrene
Dibenzo(a,h)anthracene
1.0
1.0
1.0
1.0
1.0
1.0
1.0
Noncarcinogenic PAH Compounds (U.S. EPA Method 8270)
Naphthalene
2-Methylnaphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthxene
Anthracene
Fluoranthene
Pyrene
Benzo(g,h,i)perylene
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
                                       DISCUSSION
Factors Affecting System Performance
    Several factors affected treatment process performance.  Performance evaluation was based on the
extent .to which the process could minimize site preparation activities, soils preparation, and fuel
consumption; maximize feed rates; and meet scbedule requirements. For example, at the Huron MGP
site, the operator's experience and familiarity with the thermal desorption system being used and
treatment of similar soils minimised the time necessary for setup, startup, and troubleshooting. Site
preparation and setup times were reduced because electricity and natural gas were available at the
site and there was no need to construct additional utilities.
                                               »
    Soil characteristics also affected the treatment process. The high clay and moisture content of the
soils increased  the time and labor necessary for soil preparation. The soils were cohesive, which

-------
                                              CONCLUSIONS

            At the Huron site, the thermal desorption system effectively treated wet, day-rich soils containing
        PAHs and VOCs. The system showed good operating stability and kept critical parameters constant,
        with feed rates averaging 26 tons per hour, HTS desorber temperatures between 1050-1200 degrees F,
        residence times consistently  averaging 18 minutes, oxidizer temperatures  between 1741-1773
        degrees F, and oxidizer residence times  averaging 2-2.5 seconds. Stack emissions stayed within
        operating permit requirements. While there were site-specific factors adversely affecting remediation
        costs (inclement weather, soil type and moisture content), other factors (market conditions, available
        utilities) had a positive effect. Remediation was completed  18 months after the project began and
        construction of the new operations building was not delayed. The successful cleanup of the Huron MGP
        site has also provided benefits to an extended circle. The Electric Power Research Institute funded a
        portion of the project as a field demonstration and published Ban's report on costs and technical
        issues to make that information available to utilities nationwide.

            Northwestern Public Service provided a permanent solution for  MGP residuals at the site,
        protecting  the  environment now and for'generations to come. In May 1996, EPA Region VIII
        recognized Northwestern's remediation of the site with an Outstanding Achievement Award for
        leadership and innovation.
c

-------
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 • Soil and groundwater remediation techniques
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 • Superior nutrient
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     Soil & Groundwoter Cleanup June 1998 7

-------

-------
 MART, from page 6

 construct and operate a low
 temperature thermal desorption
 facility in Vineland, N.J., specifically
 to process MGP and other total
 petroleum hydrocarbon (TPH)
 contaminated soils. The facility took
 seven months and S9 million to
construct. MART began accepting
MGP soils in July 1997.

The problem
 The more than 1500 MGPs
constructed  from the early 1800s to
the mid-1900s produced gas by
heating coal, coke or oil for city
lighting, home and business use.
 Wm Chip D'Angela Is chief executive officer and Anthony Chiesa is director of
 business development of Mid Atlantic Recycling Technologies Inc., Vineland, N.J.
       Getting  optimum pneumatic
       performance  in  remediation
         applications just  got easier
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         soil sparging/vapor extraction compressors
                  and regenerative blowers
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                 systems, Cast has a solution We offer more standard air
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                       than anyone else to make certain you're able to
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                                  A Unit of IDEX Corporation
                                  PO Boi 97 • B«raoi Hartxx. Ml 49023-0097 USA
                                  Phone 616-926-6171 -Fax: 616-9a?-0aoa
                                  wwwgasimtg com
                                               tocx coftP
                            Write In 072

8 June 1998  Soil & Groundwater Cleanup
 The by-products of the MGP
 include coal and oil tars, sludges,
 purifier box wastes and gas-
 scrubbing wastes. Historically, these
 by-products were transported
 offsite for disposal, reused in other
 industrial processes or buried
 onsite.
  With the construction of the  .
 interstate natural gas pipeline and
 regional gas storage facilities, MGP
 operations became obsolete. In most
 cases, these sites were cleared of
 aboveground structures, backfilled
 and left vacant. The gasification by-
 products and facility support
 structures remained out of sight,
 and often, out of mind. Site owners,
 who are mostly public utilities, are
 now faced with the responsibility of
 converting these underused assets
 and liabilities into income
 generating properties.

 The technology
  MART uses an Astec/SPI low
 temperature thermal desorption
 unit (TDU) fully permitted by the
 New Jersey Department of
 Environmental Protection to process
 contaminated soil to Residential
 Direct Contact Standards.
  Non-hazardous (per 40 CFR 261,
 264, 279) petroleum-contaminated
 soils are received by MART and
 sampled for TPH, VOCs and metals
 to confirm conformance with
 contract specifications. Upon
 acceptance, the soil is screened and
 crushed to less than 8 cm and
 process through the TDU. See
 Figure 1, page 9.
 Once processed, the soil is
 analyzed for conformance with N.J.
 Residential Direct Contact
 Standards. The treated soil is
 returned to the generator as fill
 material, or stored onsite for
 beneficial reuse, such as landfill
 cover. The facility accepts almost
 1100 metric tons per day and can
 treat about 900 metric tons per day.
 The 45 metric ton-per-hour unit is
 capable of reaching material
 treatment levels of 540° C.  The
TDU is equipped with a continuous
emission monitor and data is
 submitted to the state to ensure

-------
I
 Figure 1
 How Contaminated Soil Is Remediated Using LTTD
    CONTAMINATED SOIL STOCKPILES
           xi

       P
                                                                   GAS STREAM
                                  IHEHMOCOUFU I   1
                                   EMtRGEMcr •;•:)   *
                                         I   I
          PRIMARY
          DUST
          COLLECTOR
        ir.ra.jk.hj.
        ifTTTT'd
         SOIL  T
        fnni inir JL
        COOLINU ®JOIl«BDUMl
         UNIT
SECONDARY
TREATMENT
UNIT (STU)
          REMEDIATED SOIL
  compliance with air permit requirements. See figure 2,
  this page, for MART'S typical operating conditions.
   MART is in the process of complimenting the Astec
  TDU with a hazardous waste minimization treatment
  and recovery system, called the SAREX system.
  Manufactured by SRS, of Irvine, Calif., the SAREX
  system is capable of treating PCBs, PAHs and RCRA
  wastes, including K and F waste codes. The SAREX
  system combines three distinct processes — MX-1500
  Three Phase Centrifuge, MX-2000 Low Temperature
  Thermal Desorption Unit and the MX-2500 Medium
  Temperature Thermal Processor, in series — to
  minimize the disposal of wastes and maximize the
  recovery of useful products generated during
  separation and remediation.

  MGP case study
   With more than 10 former MGP sites scheduled for
  remediation, the local utility client authorized project
                           Continues on page 10 •
Figure 2: Process Parameters
Soil feed rate
Soil moisture
MGP/TPH feed (max)
Primary Treatment Unit
Fuel input
Secondary Treatment Unit
Fuel input
Stack discharge
VOC removal
Paniculate removal
36 to ^metric
tons/hour
15 to 20 percent
3 percent
480° C
37.72 mm BTU/hr
980° C
33.84 mm BTU/hr
190°C
>99 percent
>99.5 percent
                                                        Soil ft Groundwoter Cleanup June 1°°8 9

-------
  MART, from page 9
Figure 3: TDU performance
Soil Concentration (ppb)
Compound
Anthracene
Benzo(a) anthracene
Benzo(a) pyrene
Benzo(k) fluoranthene
Chrysene
Pyrene
Contaminated
4,000
3.000
4,000
3,000
5,000
5,000
Treated
41
55
43
49
41
80
Cleanup level
100,000
900
660
900
9,000
100,000
 activity to begin during Summer 1997. The first site was
 in an urban, high traffic area where local governmental
 and community leaders wanted to use the vacant MGP
 site for a new office complex. The primary objective of
 the project was to excavate and transport contaminated
 MGP soils to the MART facility, and subsequently
 return the thermally treated and certified clean soil to
 the site as backfill.
  The project began in July 1997 and continued for 16
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10 June 1998 Soil & Groundwoter Cleanup
                                                weeks. During that rime, more than 27,000 metric tons
                                                of MGP soil and debris was processed. See Figure 3,
                                                this page. All materials treated reached the specified
                                                cleanup standards on the initial pass. The project was
                                                completed without disrupting local traffic or creating
                                                an environmental/ health hazard to the local
                                                community. The land was seeded and turned over to
                                                the community for beneficial use.l
                                                                      Write In 717
               The Coronado Springs Hotel.
               Lake Buena Vista. FL
               December 9-12. 1998

 Technologies for Environmental      ,
 Characterization, Monitoring and  . =
 Surveillance	<^'  .

 Key Technologies and Applications:^
 Remote and In-Situ Sensors and Monitors;^
 Sensor Platforms and Delivery Systert
 Non-Destructive Assay/Non-Destructive
 Survey: Continuous Emission Monitors; to
 Robotics; Data Visualization, Geographic }.
 Information Systems, Decision Support JV
 Systems and Methodologies; Modeling, and
 Simulation; Process Control and Monitoring;
 Subsurface Barriers (Containment) Integrity
 and Placement; Bio/Phyto Monitoring.
 Technical paper submitials should be in one til
 Iwo areas:                     A,
 1. Deployment-based, practical application* of
  innovative technologies (i.e.. case studte of '
  actual technology demonstrations.
  deployments, and commercialization eflottt^or,
 2. Introduction ol truly new and innovative  "v^
  technologies which are ready for         'V,
  demonstration, deployment, and /or       ''•.
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 Please submit a 150 to 250 word abstract for
consideration by June 30th. 1993.
Abitracti may be submitted by Email to
Techno9a0bdm.com.
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                                                             Please see the TactmoV»ntioru'98 website at
                                                             httptfpegt*us.cc.ucf,»(Ju/-conl»d/lechno.htm or call In* University ol
                                                             Central Fhnda Conference Manager al (*07) 207-4923 for additional
                                                             information

-------

-------
              Transportable  Incinerator  Economically
                   Treats  Creosote-Contaminated  Soil
 • Problem: Contaminated lagoon
sludge from a bankrupt wood treating
operation in Prentiss, Mississippi,
threatened to overflow into a nearby
stream. An emergency response con-
tractor excavated and stabilized the coal
tar creosote sludge with cement kiln
dust in March 1987.

   While this removed the immediate
threat to the environment, the organic
contaminants were known or suspected
carcinogens, and a permanent solution
was needed. Twenty-five years of con-
tamination was now stockpiled, totaling
9,200 tons of creosote-containing soil.

 • Solution: The Environmental
Protection Agency (EPA) Region IV
selected Williams Environmental
Services, Inc., an environmental con-
tractor, to clean up the Superfund site.
Incineration was chosen as providing the
only environmentally sound alternative
and was selected over burial on site or
off-site landfllling.

   Contaminated soil was sampled and
tested at the beginning of the project.
Data on composite samples, prepared
from over 80 core samples, showed the
soil was relatively high in heating value.
at 1148 Btu/lb dry basis (Table 1). While
the heating value was high, on the
average it did not exceed the heat input
limits of the kiln incinerator at rated
capacity. Heating value is a key parame-
ter, as high heating values reduce incin-
erator throughput due to limitations on
heat release rates and flue gas volumes.
   Soil contained seven polynuclear
aromatic hydrocarbons (PAH). These
organic compounds (Table 2) are consis-
tent with major creosote constituents
noted in wood treating literature. No
pentachlorophenol or arsenic com-
pounds were found and only small
amounts of inorganic chloride were dis-
covered. Inorganic and organic sulfur
was present in small quantities.
              TibU1
            SoHAnslyiis'
              -WiightXfatt basic) -
              Prtuiin*l»   USmats
               10.07      10.07
     Ash        82.18      82.16
     VotaSlM      6.95
     Food Carton   0.80
     C                   6.90
     H                   0.46
     N                   0.22
     S                   0.13
     0                   0.12
     0,            By cSflirwie*
     Total       100.00      100.00
      ' Compoiitc core samplts
              T»M«2
            PAHAiufpIs1
     Compound
mg/Ke
     Napfthafent
     Antirawns
     Ruersn*
1400
1100
1100
1000
900
220
                                          • Contfotite con tampltt.
                Characteristics of the actual soil fed
             to the incinerator varies somewhat from
             the composite samples. However, blend-
             ing prior to incineration reduced the
             amount of variation.

                To burn out the organic hazardous
             waste, Williams constructed and oper-
             ated the industry's largest transportable
             rotary kiln incinerator system. The
             overall processing system {Figure 1)
             corn-prises four major components: feed
             preparation; incineration; ash handling
             and conditioning; and air pollution
             control (Figure 2).

                In the soil feeding system (Figure 3),
             front-end loaders move contaminated
             soil to the staging area, a roofed concrete
             pad. Soil is fed to a vibrating screen that
             removes material larger than 2 inches,
             which is stockpiled for disposal by  EPA.
                           WILLIAMS
                           ENVIRONMENTAL
                           SERVICES, INC
                     2076 West Park Place
                 Stone Mountain. Georgia 30087

                        404/498-2020
                      Wats 900/8784974
                      Fax 404/4604178
                                              Ankle reprinted from
                                         "Chemical Pracentaf* July 1989
TRANSPORTABLEINCINERATOR
                                                                                                   Page 1ot6
                                                                                                     TMIl&MM

-------
Material leu than 2 inches, stockpiled
on the pad, goes into the hopper of the
apron feeder for tho weighbelt scale
serving the dryer/conditioner. This unit
partially drie* the coil, breaks up large
agglomerated particle*, and homogenizes
the feed to the kiln. Since the creosote
•was stabilized, the ability of this unit to
break up the soil lumps is particularly
beneficial to the kiln's operation. The
final unflighted section of the dryer/
conditioner also micropelletizes the fines
fraction of the soil in a fashion similar to
a ball mill.

   Solids move in a closed conveyor
from the dryer/conditioner to the rotary
kiln, where- drying is completed and
crooeota compound* are volatilized and
burned. Operation in concurrent, with
aoth gas and solids exiting the rear of
the unit. The kiln is operated to
maintain an exit gu temperature of
approximately 1600'P and an oxygen
content of >3%.

   This was the third kiln of this aize
the supplier built for hazardous waste
destruction. The unit is 7.5 feet in
diameter and 46 feet long; with a total of
6 inches sprayed refractory; 3 inches of
insulating grade; plus a 3-inch top coat
of hardface. This refractory thickness is
carried through the top half of the
downstream quench tower.

    The kiln has two 18 million Btu/hr
burners. One produces an intense flame,
via a custom secondary air scroll, to
rapidly dry the solids and initiate
volatilization of the organic*. The other
burner has a long flame to burn the
volatile*.
 TRANSPORTABLEINCINERATOR
                                           RBB» 1     PREPARED FEED
                                           5£Zrt   ±  PRIMARY FAN 13
                                                  BAG     STACK
                                                 ,HOUSE
       PRIMARY       »»
       BURNER #2
                     ROTARY
                     KILN
                 PRIMARY
                 BURNER 11
                                                                                                       ACID GAS
                                                                                                       ABSORBER
                                                     ASH
                                                     CONVEYOR
Prv
-------
         Solids exiting the kiln are gravity
      conveyed by chute into a rotary cooler, 7
      feet 3 inches in diameter and 29 feet
      long. Water is added to moisturize the
      decontaminated soil to minimize dust
      emission* and promote compaction.
      Steam is vented from the cooler to the
      secondary combustion chamber inlet.

         Gases exiting the kiln pass through
      a cyclone duat collector where entrained
      particulatee are removed prior to enter-
      ing the secondary combustion chamber.
      A portion of the gas exiting the cyclone
      is diverted to the dryer/conditioner to
      partially dry the soil. Dryer/conditioner
      exit gases are returned to the inlet of the
      cyclone.

         Temperature of the gas leaving the
      cyclone can be increased to as high as
      2200*F in the secondary combustion
      chamber at a residence time of two
      seconds. A more typical temperature
      level used for this waste was 1700*F.
      This chamber is equipped with a "high
      swirl" design burner with a rating of 45
      million Btu/hr. To ensure complete com-
      bustion, a minimum of 3% excess oxygen
      is maintained in the secondary combus-
      tion chamber exit gas.

          Gases then enter a quench tower,
      where they are cooled to 350*F by atom-
      ized water, and passed to a baghouse
      where particulates are removed by 480
      Nome* bags, 6 inches in diameter and 10
      feet long. Use of the baghouse eliminates
      quantities of sludge which would have
      been produced by a wet scrubber such as
      a high-pressure venturi particulate
      scrubber. It also does a better job of
removing fine salts and metals, which
may be formed by vaporization in the
incineration process.

   Dust collected from the secondary
combustion chamber, quench tower and
baghouse is conveyed to a pug mill. Here
it is mixed with water and discharged
onto the filial belt conveyor which take*
the ash to storage.

   After the baghouse, flue gases pass
through a 350-horsepower, induced draft
fan. Since the fan operates on clean, hot
gas that is well above its dewpoint, any
maintenance or reliability headaches
that could have been caused by wet,
dirty gas are eliminated.

   The fan is followed by an acid gas
absorber where HC1 and SO, are re-
moved. Gases are saturated in the unifs
low-pressure-drop venturi inlet section.
   Processed soil is sprayed with water
to minimize dust and temporarily hold in
conical piles with a volume equal to 24
hours of output. Samples are taken to
ensure the soil is clean, less than 100
ppm PAH. Clean soil is periodically
moved to a simple diked area near the
rear of the site for final disposal.

   Scrubber blowdown liquor and
equipment washwater pass through a
sediment filter and an activated carbon
absorber and stored in a 25,000-gallon
tank. This water is used to cool the
process soil as well as to control dust at
the final disposal site. There is no dis-
charge of waatewater.
                TnMfortabU uciiienUum r/ittm at Frooia. Uanttippi, out of A*
                prato irtal cruuau tmat, would bt applicable to pancktmieal
                a*d riftiury mourial.
1
       TRANSPORTABLEINC1NERATOR
                                                                                                               —  Page 3 of6

-------
Instrumentation and Control
Major variables monitored are: flow of
contaminated soil, fuel and air, tempera-
tures, pressures, and process gas stream
constituents. Automated process control
loops, 'smart controllers', are used to
regulate kiln and secondary combustion
chamber temperature* and spray tower
outlet temperature. Sheathed Type K
thermocouples, shielded from direct
flame radiation, sense the combustion
temperatures. They are installed well
into the combustion gases to ensure
accuracy. The waighbelt readout in the
control room give* instantaneous soil
feed rat* in tons/hour and integrated
    A flue gas sample conditioning sys-
 tem extracts gases from the acid gas
 absorber stack and feeds them into con-
 tinuous analyzers for regulatory compli-
 ance evaluation and process monitoring
 and control Flue gas is analyzed for O,.
 CO,. CO, total unbumed hydrocarbons
 (TUHC), and NOr A backup monitor is
 provided for CO. Analy ters also deter-
 mine oxygen level in situ at the kiln
 exhaust and at the outlet of the secon-
 dary combustion chamber. The following
 data are recorded continuously:

    • Waste soil feed rate
    • Combustion gas velocity
    •» Secondary combustion chamber
       exit temperature
     * Stack gas carbon monoxide
       concentration
     * Paniculate loading
     • Absorber water flow rate
     * Kiln and dryer draft
     • Baghouse inlet temperature
                                  Table 3
                    Incinerator Performance Specifications
     Waste sol rato (wet basis @ 15% moisture), tons/hr
     Solid residence time {minimum), minutes
     Kin dze, ft
         Diameter
         Length
     Win outlet gas temperature, *F
     Win outlet oxygen concentration, %
     Secondary combustion chamber outfst temperature, f
     Secondary combuslkin chamber outlet oxygen concentration. %
     Secondary combustion chamber residence lime 9 2200*. sec
     aimer rated capacity (maximum). MM Btu/hr
     Baghoute Intel tampenture, 'F
     PartcuIaM loading after baghouse. gr/dscf
     HQ temoval efficiency (If 4 Ibs/hr), %
     Rwl for burners
               15
               45

               7.5
               45
         1200-2000

         1500-1800
               23
                2
               82
              350
             <0.08
              >M
Propane or natural gas
Data are captured on three-pen strip chart recorders and printed out on a 48-channel
data logger.
Startup and Operation
Operations commenced in April 1988 with clearing and grubbing of the site, followed
by equipment erection and checkout. Incineration of soil began on July 27 and the
unit achieved 100% capacity within seven weeks.

    The primary problem encountered during startup was caused by the higher than
expected fines content of the soil. Cement kiln dust used as a stabilization reagent
and local clays produced an extremely fine ash. Approximately 60% of the ash output
was from the air pollution control system, cyclone through baghouse. The original
conveyors on this system were, therefore, undersized and were replaced with two-
foot-diameter screw conveyors. A conveyor was added to the secondary combustion
chamber to remove fine solids which accumulated there.

    Slagging occurred on two initial shakedown runs, resulting in agglomeration of
the ash. This was solved by running at lower temperatures, and by relocating th« kiln
exit thermocouple which had been reading low due to seal air leakage.

    Initial "miniburn* testa showed inconsistent destruction removal efficiency (1>RE).
This was due to a duct, which collected steam and dust from the product cooler, being
•vented into the baghouse. This line was rerouted into the secondary combustion
chamber to prevent bypassing of organic contaminants.
 TRANSPORTABLEINCINERATOR
                                                                                                           Pag»4efl

-------
   General mechanic*! problems occur-
red in the materials handling system,
principally with the apron feeder. The
problems were solved by upgrading
individual drive components and by
consistent loading of the apron feeder
hopper.

   A trial burn was performed on
October 11 and 12,1988. Naphthalene
was used to test overall incineration
destruction efficiency. It was selected as
the principal organic hazardous con-
stituent (POHC) because of its relatively
high stability ranking (rated 5th highest
out of 320 in EPA's Thermal Stability-
Based Incinerability Ranking). No spik-
ing was done since naphthalene was
present in ample concentrations in the
soil along with a variety of other poly-
nuclear organic compounds. The natural
soil concentration was measured and
used to calculate infeed loading and
ORE.

   The trial burn (Table 4) consisted of
three runs at two test conditions. The
first test condition used a kiln tempera-
ture of 1620*F and a secondary combus-
tion chamber temperature of 1€70*F.
The second trial burn test condition used
a kfln temperature of 1570*F and a
secondary combustion chamber tempera-
ture of 1710»F. For both, the average
waste feed rate was just above the 15
tons/hour design rate for the incinera-
tion system.

   The incinerator passed the RCRA
trial burns with results far exceeding
federal and state requirements.
             T«bl»4
      Trial Bum Test Results
Test Condition 1:
Kin operating temperature, *f
Secondary combustion chamber.
Run number
Waste feed, tons/hr
Naphthalene feed, bftr
Total PAH teed, fair
Naphthalene DRE.%
Total PAH-ORE %
Paniculate emission rate
& n, O», gr/dscf
Teat Condition 2:
Kiln operating tamperatura. f
Secondary combustion chamber.
Run number
Waste toad, toos*r
Naphthalene fsed. Mr
Total PAH toed. Hvhr
Naphthalene ORE. %
Total PAH-ORE, %.
Particular emission rats
& 7% O*. gr/dsd


f
1
15.1
77.2
340
99.9983
>99.9995

0.0130


f
1
15.9
74.5
401
>99.9996
>99.9997

0.0151



2
15.2
48.3
285
99.9988
>99.9988

0.0104



2
15.2
70.2
401
> 99.9998
> 99.9998

0.0121



3
15.5
98.7
418
99.9981
>99.9993

0.0107



3
14.6
44.7
282
>99.9996
>99.9997

0.0103

1620
1670
Average
15.3
74.73
348
99.9987
>99.9995

0.0113

1570
1710
Average
15.2
63.1
361
>99.9997
>995997

0.0125
Secondary cvmbuttiiM chamber and qutnck
Urwtr combination (rift*), along wick an adit
tat abtorbtr. prrttnt tmiiiioa ofaromaaet
during ml tnatiunt
TRANSPOrTTABLEINCINERATOH
                                                                                                           PsgsSolS

-------
    Incinerator itaclc test results showed
 that during all teita and under both teat
 conditions, the incinerator achieved
 2:99.998% DRE, at leant fi ve times better
 than required. DRE» for total PAH were,
 without exception, hosier than those for
 naphthalene. This suggests naphthalene
 waa a good choice for tha POHC, for it
 waa more resistant to thermal decompo-
 sition than tha average PAH compound.
 DREs were unusually consistent.

    DRE data from the second test were
 all "more than* values, since insufficient
 POHC waa accumulated to quantity. In
 this caae, the limits of detection were
 used to back calculate a value. DRE for
 the total PAH compounds waa deter-
 mined to ba £99.999%, at least ten times
 better than required by RCRA
 standards.

    An average particulate emission rate
 of 0.012 Brains per dry standard cubic
 foot (gr/dscO, corrected to 7% oxygen,
 waa found; approximately six times
 better than RCRA requirements.

    Hydrochloric acid gas levels were
 determined from preliminary teats which
 indicated the total uncontrolled HC1
 •mission rate, as calculated from the
 theoretical chlorine f«ed rate based on
 •oil analysis, would be lesa than the 4.0
 Ib/hr EPA limit. Actual stack concentra-
 tions were negligible, leas than 0.1 tt/hr.
 Hydrochloric acid gan emissions were
 not measured during the trial burn, but
 scrubber efficiency diita indicated the
 scrubber was capable of removing better
 than 99% of th* acid gas in the waste
 stream at normal input levels.
              Ttitrmal duOTX&m mat mcc*vfuOy nmmtd crtosou ad othtr
              pofynuclfor eniMiia from a»tr 9000 lota of toil.
    Sulfur dioxide waa generated by organic sulfur in the coal tars. Uncontrolled
leveb were expected to be in the 160 ppm range. Continuous emission monitoring
data during the trial bum showed concentrations to be 0 to 10 ppm, well below the
State of Mississippi limit of 500 ppm.

    Scrubber blowdown water was found to be clean, with all PAH compounds at less
than detectable levels.

    Ash testa were performed during the trial burn and on a daily basis throughout
the project. AH tests showed the ash product to ba leas than the required 100 ppm
total PAH compounds. Topically, the total PAH level was leas  than 5 ppm in 92% of
the samples, with many of the tests showing all compounds to ba less than the
detectable level.

 * RdSUlta: The entire stockpile was decontaminated by Williams in leas than a
year from the December 22,1987 contract date. Total project was performed for a
little over $1.83 million, and slightly more than 9.129 total tons were incinerated, for
an average price of about $199/lon. Thia was for "chute to chute* incineration and did
not include extensive excavation or field sampling work.

    This marks the first field remediation project involving the incineration of
creosote wastes. Experience gained by Williame is directly applicable to remediation
efforts for other coal tar by-products resulting from coal gasification or coking
operations and for petrochemical and refinery wastes. •
TFUNSPORTABLEINCINEHATOH
                                                                                                          Pag* 8 of I

-------
                                              of
   'Copyright 1999, Remedial Technologies Network L L C  All R;M,I  o      j^
   Environmental (CDE Resources, Inc ) CDE S™ I RecyciinKT^hSL  rT^- CuInninSham-Davis
   and Current Development . Process Description G™ «^                           ' **»*
   Capacity . Material Handling . Waste Streams  Onerarnr R   lnvolvement . Performance , Limitations ,
   Reliability/Maintainability .Public AccSce'  bSf*^™*^ ',Ul"itieS ' S«-UP^ear-Down ,
   Environmental (CDE) ^ ^^ISSo^^^T65 , ^^^ Cunningham-Davis


                      ~


                        ^^
  client's location or at one of CM "Salons (D^8 Y nT 5™°^     T ^ * prOCCSSed at lhe
  concrete produced by this lechnolog^fns 65% t^    ^    "^ '°    "***' "* ^P"*"
  and stabilities better than standard hot mx asohtl, £ !• * C°ntam"iated,so'1 ™d •»» °Ptimal flow rates
  Conventional co.d mix asphalt conSJSSS^iSSKSSf i r l° ' ^^ (°16398Y' * l>
  asphalt, however, is an improved cold mixasDhalt whth 1 K     f,   ! hOt mix Pavement- T^e CDE
  pound range, which is two to Ihm^lS^^J^^^^11 Stabililies in  *e 3'500 to 6-000
  4). 4. Involvement With GavaSKSSSSS^JSii? f "fl "^ (DI6398Y> P^



  Performance A pilot study was conduced wTmSsiTh^^'    ^ D'ClCS°n' CDE' 1997^ 5-
            a
toul recoverable petroleum hydrocarbons; none w£2SdXS?SSSS hydrOcarbons and
goal was to have a finished paving product with Marshal! SH^?   \    g    2° tOns ^ hour T^6
pounds compressive strength' TO! was cSSl^S^?^^^,?^"' 2'500
                                                              '            ma
                               was c,          '
 site in San Bernardino. California, owned by the Santa Fe feilroarf Zcn'-i          maintenance yard
 and diesel. lhe goal for pavement stability was 3 5TO pouS ^S ^CDE SZ C0nta™"|ed with «*' oil
 consistently greater than 3.000 pounds and «ypica lyinTe 5 OW toT^ ^  8y ^ ^ asphalt ^^
 the California STLC test resulted in no detections of comaminnnKnf    ^  fu^' Uaching tests ^^
 site was subsequent* developed into a i-^StS^SST^t^1'^' matCriaL ""le
 soil and reagents. Up to 300 tons per hour of soil was treated ThT     P^        Sed for mwmS *c
 aggregate, and 6% emulsifier and binder (55^? ?SS«2^S "" "^ ?5% SOi'' '9%
 .he cost effectiveness of the recycled product Sandy siltvTnd cobh.^ ?aracterishcs of a *>» determine
 into asphalt concrete. Converse.^ enrich soils ^'SSSS^^^S^ ^^
 So,l or rock aggregate can be used to supplement soils as needed W^vXi^F™***1?* lincr
 the vendor and has not been independently verified. 7. Feed Rate or CawcitvTlJ '^! '"f0™""*  «  from
 process 300 to 500 tons per hour (D16398Y p 3) 8 MuaM\ ESnS ?  ^ Cportable ^"'Pment can
 sometimes screened to remove oversize debris (DlLly^ ^ S^s W± sST' NCCdS ThC **< h
 information. 10, Operator Requirements No available informau^Tl M fv J ^*   aVai'ab'e
 information. 12. Set-Up/Tea^Down IteiuiiwncnBaiF h^S      «    y Retiuiremen" No available
 equipment for use with'this «S^S S ?98Y, p * T3 SS3±ISRW? ^ ^"^
avaiiable information. 14. Public Accep lance No .Vdbbic lnS22? ? ?* Jllll>*to»t«i™W««y No
Vendor literature Dl 1877O. Dickson, 1996             >ntormaUon. 15. Information Sources DI6398Y,

-------

-------
                                    EPA/540/A5-91/009
                                       January 1993
   Pilot-Scale Demonstration of a
Slurry-Phase Biological Reactor  for
    Creosote-Contaminated Soil

     Applications Analysis Report
          Risk Reduction Engineering Laboratory
           Office of Research and Development
          U.S. Environmental Protection Agency
              Cincinnati, Ohio 45268
                                 Printed on Recycled Paper

-------

-------
c/EPA
            tinned States
            Environmental Protadion
            Agency
             Office of Research and
             Development
             Washington DC 20460
 EPA/540/A5-91/009
- Jan. iry 1993
Pilot-Scale
Demonstration of a
Slurry-Phase Biological
Reactor for Creosote-
Contaminated Soil
                              >
Applications Analysis Report
                SUPERFUND INNOVATIVE
                TECHNOLOGY EVALUATION

-------

-------
                                                Section 1
                                        Executive Summary
 Introduction

 IT Corporation (IT) in conjunction with ECOVA Corpora-
 tion (ECOVA) evaluated ECOVA's slurry-phase bioreme-
 diation technology under  U.S. Environmental Protection
 Agency's (EPA) Superfund Innovative Technology Evalu-
 ation (SITE) program. The technology demonstration was
 conducted at EPA's Test and Evaluation (T&E) Facility in
 Cincinnati, OH, from May 8 through July 31,1991.

  In this process, the soil is suspended in water to obtain a
 pumpable slurry, then pumped into a 64-L, continuously
 stirred tank reactor (CSTR).  The CSTR can be  supple-
 mented with air, nutrients, or as was the case in this demon-
 stration, an  inoculum  of microorganisms to enhance the
 biodegradation process. This treatment method has several
 advantages because an optimal environment for biodegra-
 dation of the organic contaminants can be maintained with
 a high degree of reliability. Biological reactions can pro-
 ceed at accelerated rates in a slurry system because limiting
 nutrients can be supplied and contact between  contami-
 nants and microorganisms  can be increased by  effective
 mixing and maintenance of high bacterial populations.

The objectives of the technology demonstration were:

  1.  Evaluate the ability of slurry-phase bioreactor to de-
     grade polynuclear  aromatic hydrocarbons (PAHs)
     present incieosote-contaminaiedsoil from the Burlington
     Northern (BN) Superfund site in Brainerd. MN.

  2.  Evaluate the performance of the slurry-phase bioreac-
     tor process, its removal efficiencies for PAHs. and the
     overall effect on soil toxknty.

  3.  Determine the air emissions resulting from ihe volatil-
     ization of the reactor contents during treatment.

 4. Provide technical data to assist EPA in establishing best
    demonstrated available technology (BOAT) standards
    for the level of treatment required before land disposal.

 5. Develop information on capital and operating costs for
    the full-scale treatment system.
  The purpose of this report is to present information from the
  SITE demonstration and from three case studies to evaluate
  the technical and economic applicability of slurry-phase biore-
  mediation technology to the remediation of soil- and sludge-
  bound hazardous contaminants.   Section 2 of this report
  presents an overview of the SITE program.  Section 3 dis-
  cusses information relevant to the technology's application
  including site characteristics, waste characteristics, operation'
  and  maintenance requirements, materials handling require-
  ments, personnel requirements, potential community expo-
  sures, and potentially applicable environmental regulations
  Section 4 summarizes the costs associated  with implement-
  ing the technology.  Appendices A through C include-  a
  description of treatment technology, SITE demonstration re-
  sults, and three case studies.


  Overview of the SITE Demonstration

 The slurry-phase demonstration technology was developed
 and tested by ECOVA Corporation at the bench-scale level
 at ECpVA's laboratories in Redmond. WA.  IT, working
 with  ECOVA. developed materials handling and scaleup
 parameters during the pilot-scale SITE demonstration.

 Five  64-L (working  volume) EIMCO Biolifl1* reactors
 operated in batch  mode, were used to test  the degradation
 of soil-bound PAHs in a biologically active soil slurry.

 Creosote-contaminated soil from  the BN site was passed
 through a 1/2-in. screen to remove oversized material. Af-
 ter screening, the soil was mixed with water to form a 30%
 slurry. The slurry was then poured into a ball mill, milled
 I°»   ^,e ?C P3"*16 size' and  *re«ed on exit from the
 ball mill through a No. 8 sieve  to produce a slurry with a
 grain size distribution suitable for charging EIMCO Biolift™
 reactors. Following milling, 66 L of the  soil slurry was
 transferred into each of the five reactors.

 After the reactors were charged with the soil slurry, a concen-
trated inoculum of indigenous bacteria was added to each of
ihe reactors. For optimal microbial activity, nutrient amend-
ments, including ammonia, phosphate, magnesium, calcium
iron, and ammonium molybdatc. were added to the reactors.

-------
Sampling and analysis activities performed during the pilot-
scale demonstration involved collecting composite samples
from each of the reactors for pre- and posureatment analyses
and sampling throughout the demonstration to monitor sys-
tem  operation.  During the demonstration, soil-bound and
liquid-phase PAHs. total petroleum hydrocarbons (TPHs).
nutrients, pH. dissolved oxygen (DO), temperature, toxicily.
mJcrobial phenotypes, and microbia! activity were moni-
tored.  Composite samples were collected from three sam-
pling ports located along the side of each reactor at different
vertical locations.  Soil-slurry samples were taken from the
reactors over a 12-wk period. In the ninth week of operation.
four of the bioreactors were reinoculaled with an additional 125
mL of the inoculum lo stimulate the PAH degradation process.
Results of the SITE Demonstration

The pilot-scale demonstration  achieved significantly re-
duced PAH •concentrations in the soil matrix.  Results
indicate thai an average of greater than 87% of total PAHs
were removed overall five operating reactors after the 12th
week of the  demonstration period.  Air samples taken
continuously during the first 5 days and thereafter periodi-
cally through the ninth week of the demonstration show
that volatilization of organics was initially significant.
Semivolatile emissions peaked at 38.9 mg/m* on the first
day of operation.  By the fifth day of operation, volatiliza-
tion of organic chemicals decreased to near or below detec-
tion limits. Microtox™ analysis, performed over the course
of the study to monitor toxiciry levels of the slurried soil.
showed  that toxicily  also decreased to low levels during
slurry-phase biological treatment.
Results from the Case Studies

Information on the technology's performance at three addi-
tional hazardous waste sites was evaluated to provide addi-
tional performance data.

RETEC Corporation performed a 56-day, 1-million-gallon
slurry-phase tank demonstration for a major Gulf Coast
refinery.   The concentration of most PAH species was
reduced by greater than 90% in 56 days of treatment.

A Radian Corporation  pilot-scale remediation  study on
petrochemical waste-contaminated soils and sludges at a
Texas site employed four 10.000-L CSTRs. At HRTs of
17.5 and 42 days of treatment more than 80% removal was
observed for most compounds; removals of many  com-
pounds approached 100%.

The French Limited Task Group, Inc. (FLTG)  has imple-
mented  in-situ, slurry-phase bioremediation at  the French
Limited Superfund site in Crosby, TX. Preliminary results
indicate that constituents of interest are being reduced and
that treatment objectives will be achieved if not exceeded.
Economics

Economic analysts of this technology is based on cost
information  provided by ECOVA and case study costs
provided by RETEC and FLTG.  (At the lime of writing,
cost information for the study performed by Radian was not
available.) Conclusions of the economic analysis are:

  • Costs are site-specific.

  • Costs range typically from $5010 $250/yd3.

  • Labor costs associated with  materials handling and
    operation can account for more than half of the cost
    incurred.'
Conclusions

Slurry-phase bioremedtaiion technology may be broadly
applicable for treating soils and sludges contaminated with
organic, biodegradable hazardous wastes, and it is a cost-
effective alternative to cumbersome and often less-effec-
live treatment methods.  Advantages include onsite treat-
ment and, in some cases, in-situ treatment, thus minimizing
materials handling activities. Also, slurry-phase bioreme-
diation can be implemented on sites with complex mixtures
of organic wastes.  The cost of slurry-phase implementa-
tion ranges from about $50 to 5250/yd3; the cost depends
largely on site/waste characteristics and remediation goals.
Because the fate of recalcitrant organics biodegraded in the
slurry-phase technology is largely unknown, future studies
should include the fate of degradation products and lexico-
logical evaluation of bioremediated soils and sludges.

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            Appendix B
SITE Demonstration  Results
   Introduction

   IT Corporation in conjunction with ECOVA Corporation
   evaluated ECOVA's slurry-phase bioremediation lechnoloev
   under U-S-EPA's SITE program.  The technology demon-
   stration was conducted at the EPA's T&E Facility in Cincin-
   nati, OH, dunng May through July, 1991. In this 12-wk
  study, creosote-contaminated soil  from the BN Superfund
  site in Brainerd. MN. was used to  test the slurry-phase pro-
  cess. This appendix briefly describes the BN Superfund site
  and summarizes the SITE demonstration activities and dem-
  onstration results.


  Site Description

  The BN Superfund Site is located on the border between
     f ?^ Brainerd- MN.  State Highway 371 is approxi-
  mately 800 to 1000 ft north of the site, and the MisSpi
  River flows about 3000 ft east of the plant Residential
  areas are located within 1000 feet to the  northeast and
  southeast of the site.  BN has owned and operated the
  railroad tie treatment plant on this site since 1907   The
  plant uses creosote mixtures to preserve railroad ties  Dur-
  ing the 1950s, BN began blending creosote with No ~5 fuel
 oil in a 1:1 ratio. At some undetermined time, this mixture
 was changed to creosote and coal tar, which are currently
 being used at the plant in the ratio of 7:3.

 Historically, wastewater generated from the wood-treatine
 process was sent to shallow, unlined surface impound-
 ments for disposal. The first impoundment, which covered
 an area of approximately 60.000 ft', eventually became
 Filled with sludge, and in ihe  1930s, it was  buried under
              cond, newer impoundment was used until
           2, when a wastewater pretreatment plant was
 completed.  The discharge of wastewater to the disposal
 ponds generated a sludge and  leachate that coniaminated
 both the soil and groundwater beneath both ponds  As a
 result,  the site was.included  on the proposed National
 Priorities List issued by the EPA in  December 1982  Fie-
 ure3-1 is a map of the BN Superfund Site.       '

The Record of Decision (ROD) for the BN Superfund Site
                     was signed by the Regional Administrator on June 4. 1986
                     JS2? D%?lf[es ^ on]y v«ibly contaminated soils and
                                      Mijwas characterized as being heavily
                                       to black in color- visiWy °ily. and
                     usually havuig a pronounced creosote odor. The second
                     impoundment from which wastewater and creosotfwTre
                     52? SK? ? estimattd «*» yd3 of «"SS
                     sou and 1000 yd' of contaminated sludge.  The first im
                     poundmem which was closed in the 1930s,
                     additional 2500 yd' of contaminated soil.  Toge
                                                          95°°
                    Waste Characteristics
                                         Ihe
                                                   constituents of con-
                          i               yclic compounds, and phenols.
                    Concentrations of these contaminants ranged from 34,388
                    nig/kg total PAHs and heterocyclics and I 16 mg/kg total
                    PAHC, !?•.       'mP°undmeni to 134.044 mg^cg total
                                                    monitori"B ««*•

                   coniaminated soils were excavated from'the lagoon areas
                   which
                   wnich
                	— « •••iv* dunu^ aOli, OI
     > gram size between 0.1 and 0.4 mm in
     ill has a relatively low moisture content
    t value below 500 Btu/lb.

  1989. IT sent a sampling team to ihc BN site
  Ml for treatability studies. Soil was removed

°ft rJl .*.*"? ?hced in 55"gaJ dmms-  "n*
    rr.tr,. .. ongjnaj excavation was stored at
           one year.  In  October  1990. IT
                                         tion-. Wor to collection of the
                                                          ihcdrums
                                                    °H' ^ "* " "*
               29

-------
                    "BuwB-i. Burlington Northern Supcrfund she, Bralnerd  MN
                      -
 Process Description

 The pilot-scale demonstration of slurry-phase bioremedia-
 wn was performed from May 8 through July 31, 1991 at
   JP  S T&E FacUi|yin Cincinnati. OH. In this 12-wlc
 auoy. creosoieH»ntam>natcd soD from the BN Supsrfund
 Site in Brainerd, MN, was used to test the slurry-phase
 morein^ediaiion process.  During  the demonstration, five
 M-L EIMCO Brolift™ reactors were used.  Figure B-2
 contains a photograph of the experimental setup.

 The normal operational volume of the EIMCO Biolifi™
 reactor is 60 L. Because of the large volumes of slurry to be
removed for analytical sampling at the initial time point, it
was concluded that each reactor should initially be loaded
   .c            " ™s volume wa* ^mediately de-
 creased after collecting the first sample set; this allowed for
 the maximum loadmg of the batch slurry reactor. Quanti-
 ^« rnh ^ a"d in-°culum added to ^h «actor at the
 start of the demonstrate were calculated on the basis of a
 66-L initial reactor volume at 30% slurry.

 Before initiating the pilot-scale slurry-phase demonstration

 bL*±Z±±! Sa ***£*M32KS
 been transported from the BN she) and passed through a 1/2-
 m. screen to remove sversued material. As received, the soil
was brown-to.black.fine-io-medium-grainedsand with some
minor gravel content, and somewhat resilient and greasy
Follow,ngm,uai screening, the soil was mixed with wau^o
form a 30% slurry (W/V). The slurry was then poured into a
                                                30

-------
                               Figure B-2.  Demonstration reactor setup.
ball mill to reduce the panicle size and continuously screened
with a No. 8 sieve at the outlet of the mill to produce a slurry
with a grain size distribution  suitable for charging to the
EIMCO Biolift™ reactors. Following milling, 66 L of the
soil slurry was transferred into each of the five reactors.

After the reactors were charged with the soil slurry, 66 mL
of a concentrated inoculum of indigenous bacteria (Pseudo-
monns itutzeri, Pseudomonasfluorescens, and Pseudomonos
stuizeri strain FLN-1) was added to each of the reactors.
Based on the litre of bacteria present in the inoculum, a total
of 1.98 x 1012 colony forming units (CPU) was added per
reactor.  Furthermore, because the amount of free nitrogen.
measured as ammonia nitrogen, needed for optimal microbial
activity was quite low. ammonia supplementation was deemed
necessary. Nutrient amendments added to the reactors in-
cluded ammonia, phosphate, and trace amendments of mag-
nesium, calcium, iron, and ammonium molybdatc.

Sampling and analysis activities performed during the pi-
lot-scale demonstration  involved collection of composite
samples from each of the reactors for pre- and posureat-
ment analyses and sampling throughout the demonstration
to monitor system operation.  During the demonstration,
soil-bound and liquid-phase PAHs. TPHs. nutrients. pH.
DO. temperature, toxicity, and microbial populations were
monitored.  Composite  samples were collected from the
three sampling ports located along the side of each reactor
at three different vertical locations. All parameters of the
demonstration were monitored in accordance with the sam-
pling and analysis plan prepared for the project.  Soil-slurry
samples were taken from the reactors over a 12-wlc period.
In the ninth week of operation, four of the bioreactors were
reinoculated with an additional 125 mL of the inoculum to
stimulate the PAH degradation process.  Results of the
demonstration are summarized below.
Results of Pretreatment and
Posttreatment Soil Samples Analyzed by
GC/MS Method
The pre- and ppsitreatment soil and liquid samples were
analyzed for critical contaminants (PAHs) and TPH.  The
air  samples  were analyzed for volatile and semivolatile
organics and total hydrocarbons (THCs).  All the PAH
analyses on soil and liquid samples were performed by the
EPA-approved GC/MS method (SW-846. Method 82703).

The pretreatment samples were collected at the start of
testing (Week T,) to determine the baseline concentration
of the critical semivolatile contaminants in the soil treat-
ment. The posureatment samples were collected 9  weeks
(T,) and 12 weeks (T,,) after the start of testing  to deter-
mine the levels of the critical contaminants remaining in
the  soil after treatment.

The concentrations of the PAH contaminants in  the pre-
treatment soil samples ranged from 5.5 to 840 mg/kg. The
concentrations of total. 2- and 3-ring, and 4- through  6-ring
PAH level and the degradation rates determined by GC/MS
are  given in Tables B-1 and B-2. The concentrations of the
PAHs in posttreaunent sample; indicated a significant re-
                                                    31

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    Table EM.  Concentrations of Total, 2- and 3-rlng, and 4- through 6-Rlng PAH Levels In
                        Soil Samples, Determined by GC/MS, mg/kg

2- and 3-Ring PAHs
Reactor 1
Reactor 2
Reactor 4
Reactor 5
Reactor 6
Total
RoactoM
Reactor 2
Reactor 4
Reactor 5
Reactor 6
__ Total
Reactor 1
Reactor 2
Reactor 4
Reactors
Reactor 6


0
2299
1418
390.5
2644
718.6
1410
775
288
1836
502
962.2
3709
2193
678.S
4480
1220.6


9
<31.4
S.5
<32.3
31.5
	 J8 	
<273.7
<65.2
<357.9
<308.9
182.3
<237.6
<305.1
<70.7
<390.2
<340.4
	 200.3 	


	 	 12 	 	
<49.5
<23.8
8.1
<46.3
316.4
<267.S
<91.3
404.6
	 <291.8 .
<365.9
<291.3
c99.4
<450.9
308.8
Table B-2. Percent Degradation of Total, 2- and 3-rlng, and 4- through 6-R.ng PAH Levels In
                          Soil Samples, Determined by GC/MS
    Raactor                       ~
   """"•^^^^^^^B^^^H
    2- and 3-Ring PAH Degradation Rate
   Reactor 1
   Reactor 2
   Reactor 4
   Reactors
_.. Reactors
     Mean Percent
                                  >98.63
                                   99.61
                                  >91.73
                                    7.so
  4- through 6-Ring PAH Degradation Rate
  Reactor 2
  Reactor 4
  Reactors
  Reaclor 6
    Mean Percent	
Total PAH Degradation Rate
  Reactor 1
  Reaclor 2
  Reactor 4
  Reactor 5
  Reactor 6
                                 >91.S9
                                 ,..243
                                  63.69
                                 >91.77
                                 >96.77
                                 >42.50
                                 >92.40
                                  83.59
                                                   Week
                                                                 12

                                                               >97.B5
                                                               >98.32
                                                                97.93
                                                               >98.25
                                                               >93.78
                                                                77.56
                                                               >65.48
                                                               >68.30
                                                                77.96
                                                               >90.10
                                                               >B6.72
                                                               >85.35
                                                               >89.94
                                                               >72.43
                                                               >87.43
                                         32

-------
duction of PAHs in the soil matrix. The percent reduction of
loial PAH for Week T,, samples for the five reactors ranged
from >72% to >90%.  Results indicate that an average of
>g7% of total PAHs were degraded over all five operating
reactors after the 12th week of the demonstration period.

Initial levels of the hazardous component of creosote PAHs
were 2460 mgAg. as determined by GQMS. After twelve
weeks of treatment, the concentration of the easily-de-
graded 2- and 3-ring compounds had declined  by >9B%
from N90 mg/kg 10 <35 mg/kg. The concentration of the
much more intractable 4-. 5- and 6-ring compounds de-
clined >72% from 960 mg/kg to <270 mg/kg.

The more complete degradation of the tower molecular-
wcighi PAHs reflects, in part, the higher bioavailabilily of
2- and 3-ring PAHs than •*- through 6-ring PAHs.  Four-
and higher-ring  PAHs are considerably less soluble than
simpler-ring PAHs.

The degradation  rates of the different PAHs varied apprecia-
bly during the course of the study and reflect changes in the
reactor environments. After nine weeks of testing. Reactors 2
and 4 were inoculated with fresh bacterial populations, and
Reactors 5 and 6 were both reinoculated and amended with
the surfactant Tween 80. Reactor 1 was not amended in any
way. Results &om Week 12 indicate that additional spiking
during Week 9 did not assist in further degradation of the
complex PAHs.  On the contrary, the level of contamination
due to the presence of the more complex PAHs was greater in
Week 12 than in  Week 9. The lower level of PAH contami-
nation in Week 9 soil samples may have resulted from labora-
tory procedures.  To extract PAHs. the analytical  laboratory
used asonicauon method (EPA Method 3550) that calls fora
2-minute sonicaiion period. This may not have been enough
time for the entire soil sample to intimately contact the ex-
traction solvents and may have led to  some inconsistent
results for higher ring PAHs.

IT monitored TPH by infrared spectroscopy analysis over
the course of the study.  The data for soil-bound  TPH
indicate that, as  with the PAH data, variations occurred in
TPH levels in the  slurry (Table B-3). As with the PAHs,
the greatest decline in TPH occurred in the first 2 wk of the
study. A rise in the levels of TPH occurred at Week T».
however, this is 2 wk after total PAHs rose in the slurries.
This delay could reflect the actual production of TPH com-
pounds as metabolic products of the biodegradation of the
PAHs.   It could also reflect a simple  rise in extraction
efficiency resulting from soil panicle comminution.
CC/MS Analytical Results of
Pretreatment and Posttreatment Liquid
Samples

The concentrations of the PAH contaminants in the pre-
ueatmeni liquid samples ranged from 0.006 to 18 mg/L
The concentrations for the majority of PAHs in the post-
treatment samples were below the established MDLs for
the instruments.  After 9 wk of treatment, only the more
recalcitrant, complex PAHs remained in the liquid matrix.
These contaminants ranged in concentration from 0.013 to
0.14 mg/L.  Results from Week  12  indicated a further
reduction in liquid phase contaminants as the levels of
PAHs in the soil were further diminished, and the MDLs
for the contaminants from Week 12 were lower than those
for Week ft
Results of Pretreatment and
Posttreatment Soil Samples Analyzed by
High Performance Liquid
Chromatography (HPLC) Method

In addition to IT's sampling and analyses. ECOVA per-
formed PAH analyses on soil samples. IT analyzed samples
from Weeks T* T» and Tu for PAHs; ECOVA. from
Weeks T.. T,. T2. T,, T., T.. T,. Tle. Tn. and TI2. The
ECOVA Laboratory in Redmond employed HPLC (mod-
ified EPA SW-846. Method 8310) to analyze for PAHs.

The baseline soil (Week T,) characterization showed thai
naphthalene, acenaphthene. and fluoranthene.were the con-
stituents present at the highest levels (range of 2170 ± 250
ppm). followed by fluorene and benzo(a)anihraccne (range
           Table B-3.  Concentrations of Total Petroleum Hydrocarbons (TPH) In Soil, mg/kg

                                                      Week
Reactor
i
2
4
5
6
0
35000
17500
13000
16000
19500
2
7200
2600
2700
3600
2400
4
1800
1800
1600
2300
2400
6
3100
2300
2100
2900
3600
9
1800
3200
1800
1700
2200
11
1900
1700
1700
3700
4900
12
1700
1800
1900
2700
2700
                                                   33

-------
of 960 ± 8 ppm). Total PAH levels in these soils were
determined to be 10.970 ppm.  The.2- and 3-ring PAHs
constituted 5890 ppm of the total, and the 4- through 6-ring
PAHs accounted for 5080 ppm.

The PAH degradation rates over all five operating reactors
during the 12-wk study are presented in Table B-4. As sees
in Table B-4, after the initial 2 wk of slurry-phase treat-
menu 90% of the total PAHs were degraded. Degradation
rates (mg/kg/wk) for 2- and 3-ring PAHs were somewhat
higher at 2 wfc (96%) than they were for 4- through 6-ring
PAHs (8356).  The final levels at Week Tu were 653.5 mg/
kg for total PAHs, 152.1 mg/kg for 2- and 3-ring PAHs,
and 501.4 mg/kg for 4- through 6-ring PAHs.
Comparison of Analytical Results
Obtained by GC/MS and HPLC Methods

The GC/MS results indicate total PAHs were degraded by
more  than 87% for all reactors during  a  12-wk study.
Degradation rates for 2- and 3-ring PAHs (over 98%) were
much higher than they were for 4- through 6-ring PAHs
(72%). These observations agreed in proportion (although
not in absolute concentration) with those obtained in the
ECOVA HPLC study. The HPLC results show 94% reduc-
tion of total PAHs, 97% reduction of 2- and 3-ring PAHs
and 90% reduction of 4- through 6-ring PAHs. Figures B-
3 and B-4 compare the total mean PAH concentration at
Weeks T0. T,. and T,j, as determined by GC/MS and HPLC.
Results of Air Monitoring

Air monitoring of total hydrocarbons (THCs). semi volatile
organic compounds (SVOCs). and volatile organic com-
pounds (VOCs) were performed continuously for the first
few days of the demonstration.  The VOCs and SVOCs
were monitored periodically through the 9th week. THC
emissions data show high emissions the first two days of
process operation, followed by a steady decline to baseline
recordings by the fifth day of operation. The VOC volatil-
ization was high the first two days of operation, decreasing
to near analytical detection limits by the third day of opera-
tion. The SVOC emissions (naphthalene. 2-methylnaph-
thalene, acenaphthylene,  acenaphthene. dibenzofuraa,
fluorene. phenanthrene. and anthracene) were detectable
during the first four days of sampling.  Beginning the sixth
day of operation, very small quantities (at or below detec-
tion) of semivolatites were found.
       Table B-4. Percent Total, 2- and 3-Rlng, and 4- through 6-Rlng PAH Degradation Rates In
                                   Soil Samples Analyzed by HPLC*
Week
Reactor
2- and 3-Ring PAH
Reactor 1
Reactor 2
Reactor 4
Reactor 5
Reactor 6
Mean Percent
1
98.53
84.25
56.64
81.62
88.79

2
92.87
97.39
97.17
95.52
96.40
96.14
3
99.14
99.10
99.38
97.74
98.29

4
84.41
95.98
97.76
90.43
97.15

6
99.28
96.54
95.02
98.16 .
99.39

9
98.5$
98.11
98.15
97.74
97.83
98.06
10
98.71
98.82
95.41
-91.54
99.22

11
86.28
92.00
91.77
97.87
99.50

12
98.21
98.4S
98.43
93.36
97.25
97.42
4- through 6-Ring PAH
Reactor 1
Reactor 2
Raacior 4
Reactor 5
Reactor 6
Mean Percent
Total PAH
Reactor 1
Reactor 2
Reactor 4
Reactor 5
Reactor 6
Mean Percent
35.54
34.10
-79.11
28.65
47.60


61.86
60.15
-10.75
56.72
71.34

70.41
83.46
87.28
80.83
85.90
82.89

82.86
90.70
92.26
88.58
91.95
90.00
87.37
91.56
93.79
33.36
83.35


93.89
95.48
96.61
90.95
91.96

50.80
77.56
90.22
60.76
83.35


69.42
87.13
94.02
76.43
91.30

88.15
80.13
72.28
64.95
93.53


94.31
88.65
83.73
82.48
96.91

93.23
91.86
93.19
83.65
95.59
92.22

96.18
95.10
95.69
91.09
96.88
95.35
86.65
90.30
92.37
86.64
91.99


93.33
94.73
93.90
89.23
96.16

85.11
91.16
92.72
80.54
88.50


85.76
91.60
92.24
89.69
94.84

86.16
92.41
94.32
82.34
90.07
90.13

92.83
35.55
96.39
88.16
94.21
94.04
  aHPLC - High performance liquid chromatography.
                                                  34

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                                                   Reactor 1
                                                   Reactor 2
                                                   Reactor 4
                                                   Reactor 5
                                                  Reactor 6
                                                    10
                                                              12
Figure B-3.  Total PAH tevete In
                            reactor sol, sa.mp.es as determ^ by GC/MS
                                               Reactor 1
                                               Reactor 2
                                               Reactor 4
                                               Reactor 5
                                               Reactor $
                                                          12
                                          as determined by HPLC.

-------

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Above, water collected in the clay lined bioremediation cell is pumped to a lined storage pond for quality
testing before disposal to the storm sewer. If required, the water is filtered through a bed of granular
actived carbon, below, to remove PAH and TPH residuals and then passed to the clean water pond for
final test before discharge.
           Landfarming
     bioremediation
 is  viable  solution
 at  Lake  Erie  MGP
By Brian R Herner, Steven M. Goldberg,
and Owen R Ward. Ph.D.

          ore than 40,000 cubic meters of polycyclic
          aromatic hydrocarbons (PAHs)
          contaminated soil have been treated
          using landfarming bioremediation in a
          series of multiple lifts placed in a clay-
          lined biopad. The experience gained to
date has enabled the development of a cost effective
remedial process and a better understanding of the
process through field monitoring and laboratory
biofeasibilitv studies.
Background of the site
 The Village of Port Stanley. Ontario, is located on the
north shore of Lake Erie, about midway through the
Great Lakes navigation system. From the 1920s to the
1950s, an oil gasification plant, producing a tar-like
material as a byproduct, UMS operated about 1.5 km
north of the shore. This oil tar was stored in on-site
open pits which were filled in with dredged harbor
sediment in 1970. The soil within the pit areas
generally consisted of fine sand to clay-like material.
                       Continues on page 12-»

      Soil & Groundwafer Cleanup June 1998 11

-------
Figure   : Percent removal of PAHs in treated soil boxes after 90 days of 1
.-.	I  |njtja|  ,  .:          i
    Treatmeni
      number
                   incl. naphth excl. naphth
   Lake Erie, from page 11

   influenced by the near shore, lake bottom fill.
   In the late 1980s, a voluntary cleanup program was
   initiated using landfarming bioremediation.
   Conestoga-Rovers and Associates (CRA), an
   environmental consulting engineering firm in
   Waterloo, Ontario, was retained by the site owner to
   provide engineering services, technical supervision
   performance monitoring and compliance verification
    Model 200  GeoFlo®
    Computerized Heat-Pulse
     Groundwater Flowmeter

    • Groundwater velocity & direction
           simultaneous measurements
    • On-site information
                Sc continual monitoring
    • Very high sensitivity

    • Tested & used on Superfund sites
    http://www.kva-equipment.com
          KVA it Madibet Place B12/13
          766 Falmouth R
-------
                                                              20      40      60     80      100
                                                                       Time (days)
Figure 3: Removal rates of PAH and B(a)P in Lift 13
Days of sampling
July 26, 1996
Aug. 15, 1996
Sept. 3, 1996
Sept. 26, 1996
Days of
treatment
on biopad
0
20
40
63"
PAH concentration
in mg/kg
(% removed)
705
213(70%)
142 (80%)
112(84%)
B(a)P concentration
in mg/kg
(% removed)
15.8
15.9 (nil)
13.5(15%)
8.9 (44%)
monitoring is also
conducted at the site
during excavation and
treatment periods to
monitor for PAH and
BTEX emissions.

Biofeasibiiity tests
 Biorem Technologies
Inc., Guelph, Ontario,
began a three month
soil box study using
soil samples obtained
in December 1994. The
scope of the work included soil preparation and
mixing to homogeneity, amendment of soil boxes with
various combinations of treatment including abiotic
control, variation of amendment frequencies, moisture
maintenance and time course monitoring of PAH and
bacteria levels in soil.
 Fourteen treatment combinations were evaluated,
including daily and monthly inoculum addition, daily
and monthly nutrient addition, daily and monthly
biosurfactant addition,  daily and monthly inoculum
and nutrient addition, daily and monthly inoculum
and surfactant addition, daily and monthly nutrient
and surfactant addition, biotic controls or no additives,
and abiotic control or mercuric chloride poisoning.
  Five kilograms of soil  were used for each treatment
combination. The average temperature maintained
throughout the lest was 25° C and the  soil moisture
was maintained at 14 percent for all treatments. Soils
were tilled three to four times a week throughout the
entire depth of the soil box.
  Chemical analyses for PAHs were performed by
 Biorem using GC/FID. Confirmatory analyses were
 carried out by an independent certified laboratory for
 QA/QC using GC/MS analyses. Although no attempt
 was made to measure mineralization and
 volatilization, it is assumed that due to the volatile
 nature of naphthalene, it would be removed by
 volatilization in the soil box test. This  was confirmed
                            Continues on page 14 •»
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                                                          Soli & Groundwoter Cleanup lune 1998 13

-------
  Lake Erie, from page 13

  by observing the naphthalene removal rates in the
  abiotic control compared to the unamended control.
  Figure 1, page 12, shows,the percent removal of PAHs
  for each of the treatments after 90 days.
  Significant findings*of the biofeasibility study
  included:
  • The highest amount of PAH reduction obtained in
  90 days was in amended soils.
  • The use of amendments yielded PAH reduction of
  more than 80 percent compared with less than 60
 percent reduction for the unamended biotic control
 box.
  • The best amendment systems were nutrient alone,
 inoculum alone or nutrient and inoculum together. The
 combination of nutrients and inoculum was not
 significantly better than either supplement alone.
  • The monthly addition of amendments for the better
 performing treatments equaled or bettered a daily
 addition.
  Microbial counts were monitored during the study
 and generally increased tenfold during the test period.
 The natural soils began with a count of 1 to 30 x 105
 cfu/g and increased to 1 to 50 x 106 cfu/g. The bacteria
 counts in the soil associated with the  daily inoculum
 treatments were not consistently higher than those
 associated with the monthly treatments.
  Indigenous bacteria were as effective as external
 inoculum in the degradation  of the PAHs.
 Biostimulation could be achieved through the use of
 nutrient amendment alone, with monthly addition
 being adequate. The use of surfactants was not
 contributory to more effective biodegradation of
 PAHs.

 implementation in the field
  Full scale treatment of the soils using a modified
 regimen based on the biofeasibility test results began
 in Fall 1995 with Lift 11. The modified treatment
 consisted of discontinuation of the inoculum addition,
 monthly addition of nutrient based on analytical
 results and tilling twice a week. Soils  applied in both
 Lift 11 and Lift 12 were taken from areas of the site
 with low level contamination. Nullification followed
 by a short three week tilling regimen was sufficient to
 reach the site specific cleanup criteria.
  Lift 13 provided the first opportunity to examine the
 performance of the modified treatment process and
 compare full-scale operation with  the biofeasibility
 results. The lift was placed on the biopad on July 26,
 1996, with an average starting PAH level of 705
 mg/kg. The B(a)P level was reported  to be 15.8 mg/kg,
 well above the criteria of 10 mg/kg. By Aug. 15,1996,
 the PAH concentration had been reduced to about 213
 mg/kg, a 70 percent reduction in 20 days. These results
compared very favorably with the biofeasibility study
as shown in Figure 2, page 13.

 14 June 199" Soil & Groundwoter Cleanup
   Lessons learned
     • PAHs can be rapidly and economically
    biodegraded by landfarming making it a viable
    process for remediation of contaminated soils at
    MGP sites.
     • Indigenous PAH degrading bacteria that can.
    be stimulated to provide accelerated
    bioremediation will develop in contaminated soils.
     • The use of a comprehensive biofeasibility
    study is mandatory to develop a cost-effective
    bioremediation program. The benefits of process
    improvement will provide short term payback.
     • Specific high molecular weight, five and six
    ring PAH compounds such as B(a)P biodegrade
    significantly more slowly than  the total PAH level
    in soil.
     • Further process investigation and study of
    factors that accelerate the biodegradation of
    B(a)P and other five and six ring compounds will
    further enhance the use of bioremediation at MGP
    sites.
  In contrast to the rapid reduction of the total PAH
 level, after 20 days of treatment the B(a)P level was
 virtually unchanged, exhibiting recalcitrant
 characteristics that had not been previously observed.
 On September 3,40 days after the beginning of the lift,
 the B(a)P had still reduced only marginally, or about 10
 percent, to 13.5 mg/kg while the PAHs were now well
 below the criteria at 142 mg/kg, a reduction of about
 80 percent. See Figure 3, page 13.
  It was suspected that the apparent slow degradation
 of B(a)P showed up in Lift 13 due to the relatively
 short time required for degradation of the total PAH
 and the high starting levels of B(a)P. An attempt was
 made to increase the rilling frequency of the soils, to
 improve bioavailability and accelerate the B(a)P
 degradation. This was nearly impossible, since
 September 1996 had 3.5 times the normal rainfall for
 the month. To address this, a backhoe was used to turn
 the soils over to improve oxygen availability and
 improve bioavailability of the B(a)P when the tilling
 equipment could not be used.
 Other operating parameters of this lift were carefully
reviewed, including nutrient addition frequency,
oxygen content, pH and bacteria levels of the soil to
ensure that no parameters were overlooked. Samples
 taken about three weeks later revealed B(a)P levels of
8.9 mg/kg, indicating a completed remediation cycle
of 63 days. Since the higher molecular weight PAHs
are more difficult to degrade, it was suspected that the
B(a)P would degrade sequentially to the total PAHs,
with compounds having a lower number of rings
degrading first.

-------
Recently at the site
 Lift H was placed on the biopad
in November 1996 and was tilled
for two weeks before terminating
operations for the winter.
Treatment recommenced in Spring
1997. Initial samples collected on
May 5,1997, revealed PAH and
B(a)P levels of 425 mg/kg and 16.1
mg/kg. Sampling completed
during the summer months
demonstrated that the PAH level
again dropped below the 200
mg/kg criteria in about eight weeks
with a PAH level of 140 mg/kg
reported on July 17.
 The B(a)P levels had decreased to
12 mg/kg and continued a slow
decline to 11.8 mg/kg by August
13. In this instance, the slow
degradation of B(a)P was causing a
significant delay in completion of
the lift and called for further
investigation into the degradation
characteristics of B(a)P.


B(a)P biodegradation
characteristics
 The slow biodegradation of 5 and
6 ring PAH compounds  is generally
conceded to be proportional to
water solubility. B(a)P has one of
the lowest solubilities of PAHs at
.004 mg/1. In addition, it has been
shown that B(a)P itself does not
support the growth of aerobic
bacteria and the biodegradation of
B(a)P requires a cometabolic
process in which enzymes
produced by bacteria in the
biodegradation of another chemical
will break down the  B(a)P to a form
which is then directly
biodegradable. One such
cometabolic substrate for the break
down of B(a)P is another PAH,
phenanthrene.
  To examine possible influences on
B(a)P reduction in the full-scale
remediation program, degradation
data taken from Lifts 13 and 14
were examined to determine if
there was a relationship between
the concentration of phenanthrene
and the rate of degradation of
      . No significant correlation
was found and further
investigation will be required to
examine the applicability of this
phenomenon to the site soils.
 In spite of the prolonged'
treatment period required for B(a)P
degradation, the cost for the
treatment of the soils using the
modified process has been
significantly reduced. The current
cost is in the range of S35 per cubic
meter. The objectives of improved
        efficiency of PAH degradation have
        been achieved through design and
        implementation of a remedial
        process based on laboratory
        development. Further
        achievements can be realized with
        new techniques for the acceleration
        of B(a)P,degradation.I
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                                                         Soil & Groundwater Cleanup June 1998 15

-------
Copyright 1999. Remedial Technologies Network, L L C., All Rights Reserved.

BetzDearborn Bioremediation Technologies

Daramend™

Abstract

Daramend™ is an organic amendment-enhanced bioremediation technology designed to degrade organic
compounds in industrial soils and sediments, either in situ or ex situ. This method is based on adding solid-phase
organic soil amendments of specific particle size distribution and nutrient content. The organic soil amendments
increase the rate of bioremediation by improving environmental conditions, including nutrient status, biologically
available water, surfaces for microbial adhesion, and interfacial contact between the target compounds and
microorganisms that degrade them.

The Daramend™ bioremediation technology is applicable for treating soils and dewatered sediments
contaminated with heavy oils, chlorinated phenols, polynuclear aromatic hydrocarbons (tAHsf, phthalates,
organochlorine pesticides, and nitroaromatics.

The Daramend™ amendments transiently bind contaminants, thereby reducing the acute toxicity of the media.
This allows microorganisms to survive in soils containing very high concentrations of toxic contaminants.
Previous studies have indicated that soils containing pentachlorophenol (PCP) concentrations greater than
300-400 milligrams per kilogram (mg/kg) may be to toxic for direct bioremediation, requiring preliminary
treatments such as soil washing. Daramend ™, however, has been shown in laboratory studies to be effective in
soils with up  to 2,170 mg/kg, with post- treatment concentrations as low as 0.7 mg/kg. Treat ment time depends
upon the soil  characteristics and contaminant types and concentrations and can take from 90 days to over 200
days.

BetzDearborn Bioremediation Technologies (a division of W.R. Grace & Co.) has further developed the
Daramend™ technology for biodegradation of soils and sediments contaminated with chlorinated pesticides and
nitroaromatics. This "second generation" Daramend ™ technology works by imposing, in cycles, oxic and
anoxic conditions enhanced by proprietary soil amendments.

Ex situ remediation is generally done by landfarming. This involves placing the contaminated media in a
treatment cell and regularly tilling it and monitoring water content. In situ is much the same, only there is no
treatment cell.

-------
Copyright 1999, Remedial Technologies Network, L L C., All Rights Reserved.

BetzDearborn Bioremediation Technologies

Daramend™

Technology Description


Introduction . History and Current Development. Process Description . Government Involvement. Performance .
Limitations . Capacity . Material Handling . Waste Streams . Operator Requirements . Utilities .
Set-Up/Tear-Down . Reliability/Maintainability . Public Acceptance . Information Sources

1. Introduction

Daramend™ is an organic amendment-enhanced bioremediation technology designed to degrade organic
compounds in industrial soils and sediments, either in situ or ex situ. This method is based on the addition of
solid-phase organic soil amendments of specific particle size distribution and nutrient content. These
amendments increase the ability of the soil matrix to supply water and nutrients to the microorganisms that
degrade the hazardous compounds. Also, the amendments can transiently bind contaminants, thereby reducing the
acute toxicity of the soil aqueous phase to the microorganisms. This allows microorganisms to survive in soils
containing very high concentrations of toxic contaminants.

The Daramend™ bioremediation technology is applicable for treating soils and dewatered sediments
contaminated with heavy oils, chlorinated phenols, polynuclear aromatic hydrocarbons (PAHs), phthalates,
organochlorine pesticides, and nitroaromatics (D16985B, p. 1).

2. History and Stage of Development

Previous studies have indicated that soils containing more than 300-400 milligrams per kilogram (mg/kg)
pentachlorophenol (PCP) may be to toxic for direct bioremediation, requiring preliminary treatments such as soil
washing. Daramend™ eliminates these pretreatment needs. Laboratory studies have proven Daramend ™ to be
effective in treating soils containing up to 2,170 mg/kg. Residual concentrations can be as low as 0.7 mg/kg
PCP.

Developmental work on this technology began in 1988, and was completed in 1992. The development of
Daramend71* was sponsored by the Government of Canada, who is also the owner of the technology.
BetzDearborn Bioremediation Technologies (a division of WJL Grace & Co.), from whom the technology is
commercially available, has acquired the license for worldwide application of Daramend ™ (D12294B, p.5). The
technology has been demonstrated in pilot scale and full scale studies, and is commercially available (Dl 1937J,
Dl 1946K). A "second generation" Daramend™ technology was also developed which can treat additional
contaminants. It is used for the treatment of chlorinated pesticides and nitroaromatics. It was patented in the
United States (U.S. Patent numbers 5,411,664 and 5,480,579) in May, 1995 and in January, 1996 (D16985B,
P-2).

 3. Process Description

The Daramend™ process is characterized by the use of solid-phase biodegradable organic amendments that have
 been prepared to a specific particle size range and nutrient profile. It also involves low-intensity tillage of the
 soil/sediment and maintenance of an optimal soil/sediment water content. The specific application rates and
 composition are considered by the developer to be proprietary information, 'hough application rates typically
 range from 0.5% to 5% by weight (D169828, p.2).

 The organic soil amendments increase the rate of bioremediation by improving environmental conditions

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(nutrient status, biologically available water, surfaces for microbial adhesion, and interfacial contact between the
target compounds and microorganisms that degrade them)(Dl 1946K). Also, the amendments can transiently bind
contaminants, thereby reducing the acute toxicity of the soil's aqueous phase. This allows microorganisms to
survive in soils containing very high concentrations of toxic compounds (Dl 15151).

Ex situ applications involve the construction of a treatment cell to contain the contaminated media. This
technique is often called landfarming. For in situ applications,  the soil must be cleared and tilled to reduce soil
compaction. After the soil has been pretreated (see the Material Handling and Pretreatment Needs section), the
Daramend™ soil amendment is incorporated, usually at 1 to 5 % ratio by weight, followed by regular tilling and
irrigating. The tilling reduces variation in soil properties and contaminant concentrations, while also
incorporating the required amendments and helping to deliver oxygen to the contaminant-degrading
microorganisms (D107131).

Equipment needed to implement the technology includes a rotary tiller, irrigation equipment, and excavation and
screening equipment (D 107131).

An irrigation  system is used to maintain soil moisture in the desired range. Leachate or surface runoff caused by
heavy precipitation is collected and reapplied to the soil as needed, but often a waterproof cover is constructed to
avoid the need to collect runoff.

BetzDearbom Bioremediation Technologies has further developed the Daramend ™ technology for
biodegradation of soils and sediments contaminated with chlorinated pesticides and nitroaromatics.  This "second
generation" Daramend™ technology works by imposing, in cycles, oxic and anoxic conditions enhanced by
proprietary soil amendments (D16985B, p. 2).

4. Involvement with Government Programs/Regulatory Acceptance

The technology was accepted into the U.S. Environmental Protection Agency (EPA)  Superfund  Innovative
Technology Evaluation (SITE) Demonstration Program in spring 193. The ex situ application of this technology
was demonstrated from fall  1993 to summer 1994 at the Domtar Wood Preserving facility  in Trenton, Ontario,
Canada (D 107131). The development of Daramend ™ was sponsored by the Government of Canada, who is also
the owner of  the technology.

5. Performance

Daramend™ is designed to degrade chlorinated phenols, including PCP, ^nspsqtes,rand petroleum hydrocarbons
in industrial soils and sediments (Dl 15151). According to the vendor, concentrations of PAHs and PCP have
been effectively reduced from starting levels of about 25,000 mg/kg and 2,000 mg/kg, respectively.
Concentrations of PCP and total carcinogenic PAHs are consistently reduced to less than 5 mg/kg and 50 mg/kg,
respectively (D16985B, p.l). The time to remediate depends upon the concentration and type of contaminants.
See Table 1,  at the end of this section, for examples.

According to the vendor, feasibility studies have been conducted using the new Daramend™ technology on
North American soils containing Metolachior, 2,4-D and 2,4,5-T; and chlorinated pesticides (including DDT,
DDD, DDE,  dieldrin, toxaphene, and chlordane). In these studies, toxaphene concentrations were reduced 82%
and DDT concentrations were reduced 25% in 151 days (3 anoxic/oxic cycles). In a separate test, TNT and
amino concentrations were reduced 99.8% in 6 cycles over 113 days (D16985B, pp. 2,4).

6. Limitations

Like  many other bioremediation technologies, Daramend™can be limited by low temperatures, which slow or
stop biological activity. Other limiting factors include the structure, reactivity, and concentration(s) of the
contaminants, their interactions with other compounds in the soil, and the physical, chemical, and biological
characteristics of the soil (D13095A, p.30).

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7. Feed Rate or Treatment Capacity

Treatment capacity is determined by the amount of space available for treatment.

8. Material Handling and Pretreatment Needs

The soil must be pretreated. In situ treatment involves breaking up the soils with excavation equipment to reduce
compaction and aid in the removal of debris, such as rocks or metal. Ex situ treatment involves excavating and
screening the contaminated soil. Sediments undergoing treatment must be dewatered. All media must be tilled
with a rotary tiller to reduce the variation in soil properties and contaminant concentrations. Tiling depth is
generally approximately 0.45 meter.

A treatability study must be performed to determine the most effective amendments. Water holding capacities are
also assessed to determine optimum levels of water content. An irrigation system is installed to maintain this
level (D11946K).

9. Process Waste Streams

If contaminated oversized debris is removed before the soil is treated, this material becomes the process waste
stream.

10. Operator Requirements

Operators must be able to operate tilling devices and periodically monitor water concentration in the soil.

II. Utility Requirements

No available information.

12. Set-up/Tear-down Requirements

For landfarming using this technology, a containment cell must be constructed. A liner is constructed to keep
contaminants from leaching into the soil. An example site was constructed with two successive layers of sand
and high-density polyethylene, and  then a steel and polythylene cover was installed to prevent precipitation or
evaporation from disrupting the required control of media water content. An irrigation system must be installed
to maintain the optimum level of water content (Dl 1937J).

No information was available on tear-down requirements.

13. Technology Reliability/Maintainability

Soil must be tilled regularly, approximately once every 2 weeks, and the treatment can take from 90 days to over
200 days. Soil moisture content must be monitored weekly, and moisture must be maintained within a specific
range, determined by the water-holding capacity of the soil.

14. Public Acceptance

No available information.

15. Information Sources

D107131, EPA, SITE Technology Profile, 1995

Dl 1494D, The Hazardous Waste Consultant, 1995

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Dl 15151, EPA, SITE Technology Profile, 1993




D11937J, Seech etal, 1993



D11946K, Seech etal, 1993



D16985B, Grace Dearborn, Inc., 1996




D169828, Grace Dearborn, Inc., 1994
Table 1. Results From Ex Situ Bioremediation Applications1
Contaminant
Chrysene
DDT
Fluoranthene
PAHs2
Pentachlorophenol
Phthalates
Total Petroleum
Hydrocarbon
Initial
Concentration
(mg/kg)
170
680
410
659
2,170
4,350
8,700
Final
Concentration
(mg/kg)
2
1.9
2.9
106
11
"26
34
Remediation
Time
(days)
207
147
207
295
280
130
182
Footnotes:  ',



1 Source: The Hazardous Waste Consultant, 1995 (Dl 1494D)



2 PAHs s polycyclic aromatic hydrocarbons

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Copyright 1999, Remedial Technologies Network, L L C. All Rights Reserved.

BetzDearborn Bioremediation Technologies

Daramend™

Technology Cost

The cost of the Daramend™ process can range from $30 to $ 150 per ton ($27 to $ 140 per metric ton) and
depends upon the type and amount of contaminants present, the soil type, and the cleanup levels required
(Dl 1494D). According to the vendor, the costs associated with second-generation Daramend ™ treatment will be
slightly higher - between $90 and $195 per ton depending on project specifics (D16985B, p.6).

Information Sources

Dl 1494D, The Hazardous Waste Consultant, 1995

D16985B, Grace Dearborn, Inc., 1996

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Copyright 1999. Remedial Technologies Network, L L C., All Rights Reserved.

BetzDearbom Bioremediation Technologies

Daramend™

Case Study Overview

DaramenJM has been applied to over 50 soils with varying physical/chemical characteristics (Dl 1513Z) Since 19-
bioremediation technology has been used at 5 wood-preserving sites in Canada and the United States (D16985B, p

An ex situ application was conducted under the U.S. Environmental Protection Agency (EPA) Superfund Innovatr
Evaluation (SITE) Demonstration Program at the Domtar Wood Preserving facility in Trenton Ontario, Canada ir
of 1993 Polycyclic aromatic hydrocarbon (PAH) concentrations were reduced by 94 % (1,170 milligrams per kilo
chlorophenols were reduced by 96 % (352 ing/kg to 13.6 mg/kg); and ictal petroleum hydrocarbons were reduced
achieved in 254 days, including days when no activity occurred due to freezing temperatures (D107131). Refer to •
information.

Several successful pilot-scale demonstrations have been conducted at industrial sites. During one such demonstrati
was reduced 99.5%, from 7,000 mg/kg to 34 mg/kg in 182 days of treatment. 1,500 metric tons of this soil was late
remediation, with similar results (D16984A, pp. 1,3).

 From 1992 to 1994, Grace Bioremediation Te
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Copyright 1999, Remedial Technologies Network, L. L. C., All Rights Reserved.

SteamTech, Inc. and Integrated Water Technologies, Inc.

In Situ Hydrous Pyrolysis/Oxidation (HPO)

Abstract

Hydrous pyrolysis/oxidation (HPO) is an in situ thermal remediation technology that uses hot, oxygenated
ground water to mineralize organic compounds such as chlorinated solvents and refractory hydrocarbons such as
creosote. HPO works on the principle that in the presence of oxidants (oxygenated water or soil minerals),
organic chlorinated compounds will readily oxidize to carbon dioxide and chlorine ions when heated to the
boiling point of water. HPO is a rapid, in situ remediation technique that destroys subsurface contaminants, such
as dense non-aqueous phase liquids (DNAPLs) and dissolved organic components, without the need for
extraction.

HPO utilizes the technology of Dynamic Underground Stripping (DUS) to inject steam and oxygen into the
subsurface. When injection stops, the steam condenses, and contaminated ground water returns to the heated
zone. Chlorinated contaminants in the ground water mix with the oxygen and condensate and, with the presence
of heat, rapidly oxidize into carbon dioxide and chloride. HPO is able to destroy the residual DNAPL
components not readily removed by the DUS process. The in situ nature of the process reduces the overall cost of
cleanup and decreases the cleanup time to months instead of decades.

HPO was developed by Lawrence Livermore National Laboratory (LLNL) and the University of California. It is
currently licenced to SteamTech, Inc. and Integrated Water Technologies, Inc. The technology has been
commercially available since 1998.

According to the researchers, advantages of HPO include the following:

- Significantly increases reaction rates and  decreases remediation time

- Increased mobilization of viscous contaminants

- Avoids problems of mixing common in other in situ oxidation processes
    *
- Can be applied to large volumes

- Steam injection efficiently treats contaminants at depths of over 100 feet

- Economical alternative to excavation and pump-and-treat.

The primary limitation of HPO technology is the composition of the subsurface. HPO is most effective in sandy
soils and does not work well in stratigraphies with interbedded clay layers, which impede steam flow.

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  Copyright 1999. Remedial Technologies Network, L L. C., All Rights Reserved.

  SteamTech, Inc. and Integrated Water Technologies, Inc.

  In Situ Hydrous Pyrolysis/Oxidation (HPO)

  Technology Description


             . History and Current Development . Process Description  Government Involve.™^  Performance
                                                                                                  ~'
                                                                                  .
 .Limitations , Capacity , Material Handling . Waste Streams . Operator Requirements . Utilities
 Set-Up/Tear-Down . Reliability/Maintainability . Public Acceptance . Information Sources
 1. Introduction
 Hydrous pyrolysis/oxidation (HPO) is an in situ thermal remediation technology that uses hot, oxygenated
 ground water to mineralize organic compounds such as chlorinated solvents and refractory hydrocarbons such as
 creosote (D18879I, pg. 1; D18877G, pg. 1). HPO works on the principle that in the presence of oxidants
 (oxygenated water or soil minerals), chlorinated organic compounds will readily oxidize to carbon dioxide and
 chlorine ions when heated to the boiling point of water.

 Today, the principal treatment methods for chlorinated solvent- and PAH-contaminated soil are removal to
 landfills and incineration. HPO is a rapid, in situ remediation technique that destroys subsurface contaminants
 such as dense non-aqueous phase liquids (DNAPLs) and dissolved organic compounds, without the need for '
 extraction. This technique injects steam and oxygen below "the water table, building a heated, oxygenated zone in
 tne subsurface. The heat and oxygen accelerate the rate of remediation compared to in situ bioremediation.

 HPO utilizes the technology of Dynamic Underground Stripping (DUS) to inject steam and oxygen into large
 volumes of subsurface. The DUS technology is discussed in detail in the RIMS library/database  HPO is able to
 destroy the residual DNAPL components not readily removed by the steam stripping alone. Target contaminants
 are chemically converted into benign compounds, without the need for additional surface treatment The in situ
 nature of the process reduces the overall cost of cleanup and decreases the cleanup time to months instead of
 decades.

 2. History and Stage of Development                                                                  »

HPO was developed by Lawrence Livermore National Laboratory (LLNL) and the University of California,
Berkeley. It is currently licenced to SteamTech, Inc. and Integrated Water Technologies, Inc. (D18878H) The
technology is based on Dynamic Underground Stripping (DUS) and utilizes the same technique of heating and
steam injection. The technology has been commercially available since 1998.

HPO was first demonstrated by LLNL and Southern California Edison Company in FY97 at the Visalia Commerci
Creosote Site (Power Pole Preservation Facility) in Visalia, California. In one year, the process recovered 80 000
        v         ' Due l° *e success- me operator selected this technology for full-scale remediation of the site
        .
 iooov
(18878H).
In FY98, HPO was implemented at a non-Department of Energy (DOE) site in Visalia, California. Southern
                                        1 aquitard 75 to i02 feet "*" *e original site °f *" creosote
FY9S', HPO was deployed at the Portsmouth Gaseous Diffusion Plant X-701B site in Piketon, OH (D18878H).

3. Process Description

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 Hydrous pyrolysis/oxidation is used simultaneously with DUS. DUS is capable of providing fast removal of
 liquid, dissolved, and vapor phase contaminants. The technology uses steam to physically transport contaminants
 to the surface where they can be destroyed. A detailed discussion of DUS is included in the RIMS
 library/database. HPO is capable of destroying contaminants not readily removed by the DUS process. HPO is a
 thermally accelerated oxidation process which converts hazardous solvents to carbon dioxide, chloride ions, and
 water.
 HPO processing eliminates the need for long-term treatment facilities by destroying the residual contaminant
 remaining after DUS and mobilizing other contaminants to facilitate destruction or removal. The technique is
 applicable to some dense non-aqueous phase liquids (DNAPLs) and dissolved organic compounds. This
 technology can be used when tritium is present as long as there is sufficient overburden to shield personnel. In
 addition, HPO may be able to treat radioactively-contaminated sites where ground water cannot be extracted
 (D17601M, p. 2).

 Steam and oxygen are injected in parallel pipes, building a heated, oxygenated zone in the subsurface (D18431Q,
 p. 7). When injection stops, the steam condenses; thereby returning contaminated ground water to the heated zone
 The contaminated water mixes with the condensate and oxygen to destroy dissolved contaminants and form
 products ranging from partially oxidized intermediates, such as phenols and benzoic acid, to fully oxidized
 carbon dioxide (D188791, p. 1). The steam condensation step is essential because it facilitates mixing of the
 contaminant and the oxidant.

 HPO improves the rate and efficiency of remediation by injecting steam and oxygen into the subsurface. The end
 result is  that hazardous contaminants are converted into benign products. The rate of degradation depends on the
 thermodynamic properties of the  contaminant (e.g., solubility, air-water partitioning constants, etc.) and the
 temperature of the subsurface. For example, at 90 degrees Celsius, trichloroethylene (TCE) degrades  in a few
 weeks; however, at 120 degrees Celsius, degradation occurs in several hours (D18785D, p. 39).

 According to the researchers, advantages of HPO include the following:

 - Significantly increases reaction  rates

 - Decreases remediation time

 - Most contaminants  degraded in  situ

 - Increases mobilization of viscous contaminants

 - Avoids problems of mixing common in other in situ oxidation processes

 - Can be applied to large volumes

 - Steam injection efficiently treats contaminants at depths of over 100 feet

 - Economical alternative to excavation and pump-and-treat (D18878H; I7601M, p. 2; D175977).

4. Involvement with Government Programs / Regulatory Acceptance

This technology was  first developed in 1992 through the U.S. DOE's Subsurface Contaminants Focus Area (SCFA
HPO is based on the DUS process which has undergone an independent post-demonstration sampling program
conducted by the U.S. Environmental Protection Agency's (EPA) Superfund Innovative Technology Evaluation
(SITE) program, and  has been documented in the DOE Innovative Technology Summary (or "Green Book"). For a
information on DUS, refer to the RIMS library/database.

5. Performance

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  In treatability studies using soil from the Visalia Pole Yard, DUS and HPO reduced

  Sm0 i  S:T s? r ^^ ^ to 39 mg/kg- representin* a »•<» ^
  soil, the total hydrocarbon concentration was reduced from 6870 mg/kg to 19 mg/kg Thi
  These stud.es demonstrated a significant reduction of the KO^ctL^^Z
  fluorene, phenanthrene, anthracene, fluoranthene, pyrene, benzo [a] anthracene, chrys'ene. a?d I ben™      a] flue

  At the Southern California Edison site, the rate of removal was about 5,000 times faster than the rate of a pump-an

  6. Limitations

  The technology works best in stratigraphies with no interbedded clay layers to impede steam flow Field tests have
  sandy sorls. It ,s apphcable at all DOE sites in unconsolidated sediments with 20 or more St of ove burden SoiH
  of contarmnant removal. Increased subsurface heterogeneity can have a detrimental impact M«^TpSSt£?(I

  The technology is unable to remove metallic or medical waste (D18880B, p. 2).

 7. Feed Rate or Treatment Capacity


      !>4F °n*S ^frati°n ? ^ Vifia Commercial Creosote Site, HPO removed over 540,000 pounds (245 met,
      84F. p. 3). The rate of removal wi.I depend on many site-specific factors including sutariE
 8. Material Handling and Pretreatment Needs

 This is an in situ process that does not involve material handling.

 9. Process Waste Streams


 The HPO process is expected to mineralize chlorinated organic compounds to benign products such as carbon diox
 onAe contarmnant, the waste stream may contain partially oxidized intermediates Sch as phenols b^"c Tcfd, a


 10. Operator Requirements


 Operation of a steam injection system will require the bojler to be operated and manned continuously during the in.

 1 1 . Utility Requirements
                                                       '
12. Set-Up / Tear-Down Requirements
The placement of steam injection and extraction wells is critical to the efficiency of the remediation system (D175-

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 13. Technology Reliability / Maintainability



 No available information.




 14. Public Acceptance




 No available information.



 15. Information Sources




 D17601M, U.S. DOE




 D17602N, SteamTech, Undated vendor web page



 D175977, Davis, 1998




 Dl88791, Leifetal., 1998



 D18877G, U.S. DOE, 1998




 D18878H, Technology Summary Sheet Preview, undated we page




 D18431Q, Science and Technology Review, 1998



 D18785D, U.S. EPA, 1998




D18880B, Gibbs, Undated



D120956, Udell et al., 1996



D18884F, U.S. DOE, 1998

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Copyright 1999, Remedial Technologies Network, L L C., All Rights Reserved.

SteamTech, Inc. and Integrated Water Technologies, Inc.

In Situ Hydrous Pyrolysis/Oxidation (HPO)

Technology Cost

Hydrous pyrolysis/oxidation (HPO) treatment is relatively simple and can be applied to large volumes of earth. Re,
heating soil to the boiling point by steam of $1.50/cubic yard makes it feasible to consider HPO as a potential large
(D17601M,p.2).

HPO is an in situ process capable of treating both soil and ground water. In situ treatment can dramatically decreas
surface treatment and reducing the costs of handling and disposal. Large-scale cleanup using HPO may cost as littl
(D18431Q,p.2).

Remediation costs are most affected by the subsurface geologic matrix and the depth, type, and quantity of contain

Information Sources

D17601M, U.S. DOE, Undated website

Dl 75977, Davis, 1998

D18431Q, Science and Technology Review, 1998

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 Copyright 2999, Remedial Technologies Network, L. L. C, All Rights Reserved

 SteamTech, Inc. and Integrated Water Technologies, Inc.

 In Situ Hydrous Pyrolysis/Oxidation (HPO)

 Case Study Overview

 In FY97, In Situ Hydrous Pyrolysis/Oxidation (HPO) was demonstrated at the Lawrence Livennore National Labo
 FoUowmg the laboratory demonstration, there was a demonstration at the Visalia Commercial oSole Site (powe
 The Visaha sue was contermnated with a mixture of dense non-aqueous phase liquids (DNAPLs) and an o«-£ed
 and oxygen were injected into the subsurface and remediation was monitored from ground water monSnngweHs
               H         '           '          ' -nd anthr°ne)- decreased °W™ levels,      mopc
          of oxidauve destructton of creosote (D18879I, p. 1). For additional information, refer to Case Sn£> Ml
 In January 1999, HPO was applied in coordination with DUS at the Portsmouth Gaseous Diffusion Plant (X-701B
 conmrnmauon at the Portsmouth site is the X-701B holding pond, an unlined 200 foot by 50 foot pond used for the
 waste water, solvent-contaminated solutions, and acidic waste water (D18877G). The she contains a small
                                         (D18884F- p- 14: DI8883E)-
Information Sources

D188791, Leifetal., 1998

D18877G,U.S. DOE, 1998

D18884F, U.S. DOE, 1998

D18883E, U.S. DOE, 1998

D189199, U.S. DOE, 1999

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                                                   UCRk-JC-129933
                                                   PREPRINT
             In Situ Hydrothermal Oxidative Destruction
             of DNAPLS in a Creosote Contaminated Site
                 R. N. Leif, M. Chiarappa, R. D. Aines, R. L. Newmark,
                           K. G. Knauss, and C Eaker
                      This paper was prepared for submittal to the
             The First International Conference on Remediation of Chlorinated
                            and Recalcitrant Compounds
                                  Monterey, CA
                                 May 18-21,1998
                                February 27,1998
                                e ««3Ubk wltti ttu
d«n««Uinj gut b wfll aot W cited ernpmfaoRl wttout dw pcmtia^iMi of tfu

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                            DISCLAIMER

^?. ^C^^at *^ P™?**1« *» «»>u>« of work sponsored by an agency of
the United Stales Government.  Neither the United States Covernmentnorthe
Unhrofty of California nor any of their employees, makes any warranty, express
or Implied, or assumes any legal liability or responsibility for the accuracy
coMpleteness, or usefulness  of my Information, apparatus, product or process
dtelosed.w represents that its use would not infringe privately owned lights.
Reference j*reta to any specific commercial product process, or service by trade
name, trademark, manufacturer, or otherwise, does not necessarily constitute or
bnply Its endorsement, recommendation, or favoring by the  United Sutes
Covemniemorihe University of California. The views and opinions of authors
expressed herein dp not necessarily state or reflect those of the United Sates
Government or the University of California, and shall not be used for •dvmhtr«
or produce endorsement puposa.

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     IN SITU HYDROTHERMAL OXIDATIVE DESTRUCTION OF
          DNAPLS IN A CREOSOTE CONTAMINATED SITE
   Roald N. Le^. Marina Chiarappa, Roger D. Aines, Robin L. Newmark and
   Kevin G. Knauss, Lawrence Livermore National Laboratory, Uvermore CA
   USA and Craig Eaker, Southern California Edison Company, Rosemead] CA!
                                  U jA

 ABSTRACT: Hydrous Pyrolysis / Oxidation (HPO)  is  an  in situ  thermal
 remediaiiOD technology  that  uses  hot, oxygenated groundwater  to  completely
 mineralize a wide range of organic pollutants. (A fieT3 demonstration oTHPO was
 performed  at a creosote contaminated site during the summer  of 1997   The
 groundwater was heated by steam injections and oxygen was added by coinjection
 of compressed air.  The remediation was monitored from multiple groundwater
 monitoring wells. Dissolved organic carbon levels increased in response to steam
 injections as a result of the enhanced dissolution and mobilization of the creosote
 into the heated groundwater. Elevated concentrations of partially  oxidized  organic
 compounds (i.e.   phenols,  benzoic  acid,  fluorenone,   anthrone  and  910- 1
 anthracenedione), decreased levels of dissolved oxygen and isotopic shifts in' the '
 dissolved inorganic pool were indicators of partial to complete oxidative destruction f
 of the creosote in the heated aquifer as a result of the HPO process.               j

 INTRODUCTION
       The  4.3 acre Southern California Edison  Pole Yard located in Visalia.
 California was in operation for 80 years as a wood preservation treatment facility
 As a result of this operation, this site has become contaminated with  a DNAPL
 mixture composed of pole-treating creosote and an oil-based carrier fluid  containing
 pentachlorophenol. Placed on the EPA Superfund list in 1977,  pump and treat
 technology was deployed to reduce and contain the contaminant  plume  Over a
 period of nearly 20 years an estimated 10,000 Ibs.  of contaminant were removed
 from the soil and groundwater.
       In the summer of 1997 Southern California Edison began the application of
 two thermally enhanced remediation technologies to accelerate the clean-up  The
 first method, Dynamic Underground Stripping (DUS). involves  steam injection
 coupled with vacuum extraction to enhance the mobilization and  removal of free
 product (Newmark and Aines, 1995). The second method. Hydrous Pyrolysis /
 Oxidation (HPO). is a novel fa situ thermal remediation technology that uses hot
 oxygenated  groundwater to destroy organic contaminants fay completely oxidizing
 the organic pollutants to carbon dioxide.  The supplemental oxygen is delivered in"
 the form of injected air.  HPO is  needed to destroy  the residual DNAPL
 components not readily removed by the DUS process.
.u- uJ?^ kkof^-fcsed feasibility experiments were conducted to investigate
the HPO of actual DNAPL material with excess dissolved O, under conditions
similar to those achievable during thermal remediation (Knauss et aL, 1998- Leif et
al., 1998). These experiments demonstrated mat dissolved  O, readily reacts with
the compounds making up the DNAPL creosote mixture to form products ranging
from partially oxidized intermediates, such as phenols and benzoic acid fFieure 1 >
to the folly oxidized product COjCRgure 2).
       Field implementation of HPO remediation at the Southern California Edifon
Pole Yard site was initiated in May. 1997 using 11 steam injection wells encircling

                 -                         -              8rouild

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Oxidative Destruction of Aqueous Creosote Components
   7000 •••• n ^—^—	
"a,  "ft  •
      O2 Consumption and COa Generation During HPO


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  ANALYTICAL METHODS
  ,euc\ P^iority PoBukQts were extracted and concentrated by solid phase extraction
  <£«!) prior to analysis by gas chromatography - mass spectrometry (GC-MS)
  Typically a water sample ranging in volume from 1  to 4  liters was flowed bv
  positive pressure through  an SPE cartridge packed with  200 me of  ENV+
  (International Sorbent Technology), a  highly crosslinked styrene-divtoylbenzenl
  resin suitable for extraction of nonpolar and polar compounds from water   After
  sample extraction, the  SPE  tubes were dried and eluted  with 4.5  ml of  a
  dicMcromethane / isopropanol eluent (1:1).  The extracts were spiked with a six
  component .internal standard mix and volumes adjusted to 5 mL.  Bottles were
  extracted wiuYadjcnloomethane / isopropanol solvent mix (1:1) to extract organic

  Sl^fif^ t0?fhglaSSr *"* T*15 WCrc sP*ed *** a s« concern
  ffitemal standard mix and the volumes adjusted to 5 mL. GC-MS analyses of me
  SPfa extracts were performed on a Hewlett-Packard 6890 gas chromatoeraph
  equipped with a 30 m  x 0.25 mm i.d.  HP-5ms (5% phenyl  metfaylsuS)
  capillary column  (0.25 fun film thickness) coupled to a Hewlett-Packard 6890
  Senes Mass Selective Detector operated in electron impact mode (70eV) over the
 mass range 35-450 dalton with a cycle time of 1.1 s.   The GC oven lanperature
 was programmed at isothermal for 2 min. at 50*C. ramped at 8'C/min. toSOO^C
 and isoftennal for 6.75 min.,  with the injector at 250'C^d neliurTas telJriS
 gas.  The MS data were processed using Hewlett-Packard Chemstation software
 RESULTS  AND  DISCUSSION
       The creosote-derived groundwater contaminants present in the intermediate!
 aquifer of the Southern Cabfornja Edison Poleyard exhibited  large vaSS to]
 both compound distributions and contaminant amounts depending  on  when and/
 where the water samples were taken.  Observations consistent wito the process off
 DUS were the increased concentrations of dissolved organic compounds followintr
 increases m groundwater temperature as a result of the steam injections.  This is
 represented by the'etevaied levels in the aqueous concentrations polycyclic aromatic
 hydrocarbons (PAH) following the injections of steam (RgnnVS).  The rclatm
 abundances of the higher molecular weight PAH (i.e. fiuoranthene, pyrene anc
 cnrysene) were also observed to increase as a result of the steam injections
       One result from  the  HPO process  was  the rise in ite groundwata
 concentrauons of partially oxidized  organic compounds.   These oxyeenated
 compounds (LC. low molecular weight phenols, benzole acid, fluorenone, Enthrone
 and 9,10-anthracenedione) represent the partially oxidized intermediates formed
 during the HPO  of a complex  creosote mixture.   Kg.  3 shows how the \
 concentrations of these oxygenates changed in response to the steam  injections. \
 The levels of total oxygenates maximized following both steaming events and weir I
 presence is consistent  with the  aqueous phase oxidations expected under these  '
 conditions.                                                               j
       The measurement of dissolved  oxygen also aided in the evaluation of the
 HPO process. A knowledge of the dissolved oxygen level hi die groundwater was
 cntic^ during the application of HPO because the fundamental principle of HPO is •
 theaWity of hot, oxygenaled water to completely mineralize oigWiompounds  to
carbon dioxide. The aqueous phase oxidation will occur as long as sufficient
 dissolved  oxygen is present  Figure  4  is a plot  of  the dissolved oxygen
 measuremente in fee  aquifer as a function of time during the field test.  A steady
 decrease m the level ofdissolved oxygen was observed during die field test and is
consistent with the HPO chemistry where the  dissolved  oxygen is feoribm
during the chemical oxidation of the aqueous organic species.            w«u-™

-------
                  Levels of Total Oxygenates and total PAH
                      In the Intermediate Aquifer / S-13
            I   I   I   I  I  I  I   M
    FIGURE 3.  Concentrations of total oxygenates and total PAH
    (polycycllc aromatic hydrocarbons, EPA Method 8270C) In the
  aquifer during the HPO test period.  Elevated PAH concentrations
 reflect enhanced mobilization due to DUS.  Oxygenate increases are
       consistent with partial hydrocarbon oxidation by HPO.
            Dissolved Oxygen Levels in the Intermediate Aquifer
FIGURE 4.  Coneentrauon of dissolved oxygen as a function of time
     during the HPO demonstration.  Average dissolved oxyeen
  concentrations (open circles) were calculated using the combined
values from threei different analytical techniques. Dissolved oxygen
   levels dropped from 4.4 ppm to 1.7 ppm daring the test period!

-------
 Another analytical tool used for evaluating the progress of the HPO remediation
 process was the measurement of carbon isotope abundances (I2C. UC and MQ of
 the dissolved inorganic casbon. Because both "C/'C and WC/"C values of the
 creosote are distinct relative to the groundwater, these measurements were used to
 trace carbon derived from the oxidation of the creosote compounds   Figure 5
 shows the variations in MC versus S13C values of dissolved inorganic carbon in the
 groundwater. The groundwater end-member value was the isotopic signature prior
 to steaming.  The dissolved inorganic carbon became  "older", after steaming
 consistent with the production of dissolved inorganic carbon by the oxidation of
 "dead" creosote carbon.
                  Variations in 14C versus 513C values
                      In the Intermediate Aquifer
              I  '"
              £
            ("c
               . • mo. i
                •» '
                               14C (PMC)
    FIGURE 5.  Variations in "C versus 6 °C values of dissolved
   inorganic carbon (DIC) in groundwater.  The groundwater end-
 member value was the isotopic signature prior to steaming  The DIC
 became "older**  after steaming, consistent  with the production of DIC
              by  the oxidation of "dead" creosote carbon.


CONCLUSIONS
   It is clear from the Visalia Field Test at the Southern California Edison Pole
Yard that the combined applications of two m situ thermal remediation technologies
Dynamic Underground Stripping and Hydrous Pyrolysis / Oxidation, have greatly
accelerated the remediation of this creosote-contaminated site.  The application of
DUS to the site accelerated the mobilization and  removal of creosote.  ^The"
application of HPO to the Southern California Edison Pole Yard has *™-Hmfd me
site remediation by oxidizing creosote components.  Observations consistent with
fce process of HPO were increases in groundwater oxygenate concentrations
decreases m dissolved oxygen levels and shifts in carbon isotope abundances hi the
inorganic carbon pool.

-------
 ACKNOWLEDGMENTS
       The authors thank Allen Elsholz and Ben Johnson for field. We also thank
 the employees of Visalia Southern California Edison Co. and the employees  of
 SteamTech Environmental Services for expert assistance at the site  This work was
 performed under the auspices of the U.S. Department of Energy by the Lawrence
 Livermorc National Laboratory under Contract W-7405-Eng-48.  Partial support
 provided by the Southern California Edison Company was greatly appreciated.

 REFERENCES
 Knauss K. G., M. J. Dibley, R. N. Leif, D. A,  Mew and R. D. Aines  1998 -
 "Aqueous oxidation of tricbloroethylene (TCE) : A kinetic analysis."  Geochini
 Cosmocnim. Acta (submitted).

 Leif R. R, R. D. Aines and K. G.  Knauss. 1998.  Hydrous Pyrolysis of Pole
 Treating Chemicals:  A) Initial Measurement of Hydrous Pyrolysis  Rates for
Naphthalene and Pentachlorophenol; B) Solubility of Flourene at Temperatures up
 to 150°C. Lawrence Livennore National Laboratory, Report

Newmark R. L.  and R. D. Aines. 1995.  Summary of the LLNL gasoline spill
demonstraiwn - Dynamic Underground Stripping Project.  Lawrence Livennore
National Laboratory. UCRL-ID-120416.

-------
                                  I-fIst:ory
                                  nincf     Soil    w/itihi
                                   m    Injection
                                                   Searching fora soil remediation tech-
                                                   nology often leads to a lineup thai
                                                   includes many of the following: soil
                                           washing, low temperature thermal desorption.
                                           bioremediotkm and over excavauon. The search
                                           also inevitably takes a turn to investigate the
                                           critical elements of cost, liability and efficiency.
                                              low temperature thermal desponion tech-
                                           nology uses ait. pressure, heat and/or mechani-
                                           cal agitation as the driving force for volatilizing
                                           «ad removing contaminants from soil into an
                                           air stream for further treatment Separating
                                           contaminants from soil simplifies the final ireat-

           «fflaeiatiiikPra;l>iidt»DiijlH u
                                          ment of contaminants. Csing soil washing tech-
                                          niques, contaminants are washed from the
                                          exavated soil into a chemical solvent. Thr liquid
                                          is treated 10 remove and dtsirot contaminant.
                                                                                                             •Kenneth MetU*j]
                                                                                            Soil Remediation Technolorj, UC '
  and ihe solver: is reused. Biological treauaeat.
  includes composting, in which contaminated
  material is mixed with bulking agents (e.g.. I
  sawdust, wood chips) and placed in reactoci
  »ess>ets or piles.  Aeration, temperature toi,
  nutrient levels are controlled to encourage* j
  microbial growth.  Microorganisms then meob-.j
  olize contaminants, breaking them down lolol
  less harmful materials.

                Problem              |
    A recent site closure in Pcvungion. NJ. rrqmred ,
  a soil remediation solution for chorinuied f^dro- |
                carbons and aromanc sofvena. !
                The contamination, otiginatint
                from a storage tank and drua
                storage pad. consisted of ten>
                chloroethvfcne, chJorobesjtne.
                ethylbenzene and toluene in
                teveis over 1.000 ppm. To tep
                the soil on site. 7TO tons of
                contaminated material had to
                be cleaned to below ! ppnx ty •
                permit from the New Jersey
                Department of Environmental
                Protection <.NTDEP).
                  1\»q technologies »*« con-
               sidered for the project. Tbe
               first was orer excavation, a
               meciod that excavates all coffl-
               ammated soil and disposes of
               it off-site, typically in a iandfifl
               or permitted thermal facility-
               The primary disadvantages to
               this method are cost and liabil-
               it}-. The process, including
               transportation, dispel. e.\ca-
               ration and back fill, costs
about S295 per ion. It also creates liabuiy for ihe
generator—liability of transportation and future
liability of an off-siic facilm. over which the gen-
erator has linlc conlrul.
64  tnvnonmtntjl TKHNOtOCY • Seplerabtr/Cklobtr 1?97

-------
 i  CaseHisiory



                               Solution
   The technology chosen for the project—led by Dan Raviv & Associates. Millburn.
 NJ. with work performed by Soil Remediation Technology. I1C, Bndgeion. NJ	used
 machines that performed steam injection and vapor extraction. The primary advan-
 tages to these machines, which have been used in ex-situ cleaning of soils containing
 petroleum hydrocarbons since 1989. include a small foot print (jO-by-tO feel), mini-
 mal noise, product recovery and cost efficiency. .Air permits are also easily obtained.
  Older permit from NJDEP.  the soil was excavated and stockpiled in small volumes.
jbout 80 tons at a time, for treatment. The soil at the site was tight red clay, shale, sand
and CRI  quarry blend (3/ contamination remained when the soil u-as removed This produced an effective yield
£•. the Site limited its potential liability due to off-site -;:>?osal of soil in a landfill.
?em carbon was regenerated, and the product \»is reacted.
 for more information, contact Kenneth Meettns. Soil 3?mediation Tecl>HoIo   I
               Tel: (SOS) 539-3002  • F«c (50«153»-3S661
             CIRCLE 246 OH CARD FOX FREE MFC.
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-------
 Copyright 7999. Remedial Technologies Network, L. L. C., All Rights Reserved.

 Western Research Institute

 Contained Recovery of Oily Wastes (CROW ™)

 Abstract

 The Contained Recovery of Oily Wastes (CROW™) process is a commercially available, in situ technology
 used to recover oily wastes from saturated and unsaturated soil. The technology uses steam and hot water
 displacement to move accumulated oily wastes to production wells for aboveground treatment (D106605, p.
 346). In situ bioremediation processes treat contaminant residuals. Operating CROW ™ and bioremediation in
 sequence should provide complete remediation of organic hydrocarbons.

 Dense organic liquids such as chlorinated hydrocarbons, coal tars, and heavy petroleum products can be heavier
 than water and immiscible with water, resulting in their downward migration through the saturated zone. CROW
 ™ removes large portions of oily waste, stops the downward migration of organic contaminants, immobilizes
 residual oily waste, and reduces the volume, mobility, and toxicity of oily waste. The process can be used for
 shallow or deep contamination, and uses mobile equipment.

 According to the technology developer, CROW™ can be used to displace both light and dense nonaqueous
 jphase liquids (LNAPLs and DNAPLs) including pentachlorophenol (PCP) solutions, chlorinated solvents,
t&reosQJEetfand petroleum byproducts. CROW ™  does not substantially reduce contaminant levels in soils that do
 not contain free product.

-------
Copyright 1999, Remedial Technologies Network, L L. C., All Rights Reserved.

Western Research Institute

Contained Recovery of Oily Wastes (CROW ™)

Technology Description


Introduction. History and Current Development . Process Description . Government Involvement. Performance .
Limitations . Capacity. Material Handling .Waste Streams . Operator Requirements . Utilities .
Set-Up/Tear-Down . Reliability/Maintainability . Public Acceptance . Information Sources

1. Introduction

The Contained Recovery of Oily Wastes (CROW ™) process is a commercially available, in situ technology
used to recover oily wastes from saturated and unsaturated soil. The technology uses steam and hot water
displacement to move accumulated oily wastes to production wells for aboveground treatment (D106605, p.
346). In situ bioremediation processes treat contaminant residuals. Operating CROW ™ and bioremediation in
sequence should provide complete remediation of organic hydrocarbons (D14390I, p. 344).

Dense organic liquids such as chlorinated hydrocarbons, coal tars, and heavy petroleum products can be heavier
than water and immiscible with water, resulting in their downward migration through the saturated zone. CROW
™ removes large portions of oily waste, stops the downward migration of organic contaminants, immobilizes
residual oily waste, and reduces the volume, mobility, and toxicity of oily waste. The process can be used for
shallow or deep contamination, and uses mobile equipment (D 14388O; D106605, p. 347).

According to the technology developer, CROW™ can be used to displace both light and dense nonaqueous
phase liquids (LNAPLs and DNAPLs) including pentachlorophenol solutions, chlorinated solvents, creosote, and
petroleum byproducts (D 11691G).

2. History and Current Stage of Development

CROW™ was developed from applications used in the petroleum industry for secondary petroleum recovery
(Dl 1691G). Western Research Institute was granted a patent for the process in 1989 (U.S. patent 4,848,460)
(D14394M). It is commercially available and has been used at the Bell Lumber and Pole Company Superfund
site in Minnesota. Pennsylvania Power and Light has selected it to remediate the Columbia Superfund site and
used it at the Brodhead Creek site.

3. Process Description

The CROW process recovers oily wastes from the ground by adapting a technology used for secondary
petroleum recovery and primary production of heavy oil and tar sand bitumen. Steam and hot water displacement
move accumulated oily wastes and water to production wells for above ground treatment.

Injection and production wells are first installed in soil contaminated with oily wastes. Low-quality steam is then
injected below the waste. The steam condenses, causing rising hot water to dislodge the waste upward into the
more permeable soil regions. Hot water is injected above the impermeable soil regions to heat and mobilize the
oil waste accumulations, which are recovered by hot water displacement (D 106605, p. 346).

The displaced oily wastes form an oil bank that the hot water injection displaces to the production wells. Behind
the oil bank, the oil saturation becomes immobile in the subsurface pore space. The oil and water are treated for
reuse or discharge (D106605, p. 346).

-------
In situ biological treatment may follow the displacement and is continued until ground water contaminants are no
longer detected. During treatment, all mobilized organic liquids and water-soluble contaminants are contained
within the original boundaries of the oily waste. Hazardous materials are contained laterally by ground water
isolation and vertically by organic liquid flotation. Excess water is treated in compliance with discharge
regulations (D106605, p. 346). For a schematic of the overall CROW ™ process, see Figure 1 in U.S. Patent
4,848,460 (D14394M. p. I).

Mobility control polymers may be added to enhance recovery. Also, chemical additives may be used to extract
specific compounds that pose immediate environmental concern or which resist microbial degradation
(D14394M,sec.5-6).

4. Involvement With Government Programs/Regulatory Acceptance

CROW™ has been tested at both the laboratory and pilot scale under the U.S. Environmental  Protection Agency
(EPA) Superfund Innovative Technology Evaluation (SITE) Emerging Technology Program. Based on the results
of the Emerging Technology Program, Western Research Institute was invited to participate in the SITE
Demonstration program. The technology was demonstrated at the Pennsylvania Power and Light (PP&L)
Brodhead Creek site in Stroudsburg, Pennsylvania, in 1995 and 1996. Other sponsors, in addition to EPA and
PP&L, are the Gas Research Institute, the Electric Power Research Institute, and the U.S. Department of Energy
(D106605, p. 347).

5. Performance

In preliminary bench-scale testing the CROW™ process removed more than 60-weight-percent (wt %) of
manufactured gas plant coal tars at 156 degrees Fahrenheit; and more than 80 wt % of creosote-wood treatment
waste at a temperature of 120 degrees Fahrenheit from contaminated soils. Bioremediation implemented after
CROW™ lowered contaminant levels even more - polynuclear aromatic hydrocarbons (PAHs) were reduced to
4 milligrams per kilogram (mg/kg) with the dual approach (D 143901, p. 357).

In a pilot-scale test at an aquifer contaminated with creosote and pentachlorophenol (PCP), the CROW ™
process proved practical as a choice for full-scale remediation. Hot-water injection displaced 70 to 80% of the
non-aqueous phase liquid (NAPL) in the soil, and PCP concentrations were reduced from 2,100 mg/kg.to 3.6
mg/kg after flushing with 20 pore volumes of water (D14393L, pp. 12 & 15). See Case Study  1 for more
information.

6. Limitations

CROW™ does not substantially reduce contaminant levels in soils that do not contain free product (D 143901, p.
344).

7. Feed Rate or Capacity

During pilot scale testing, hot water injection rates averaged 4.5 gallons per minute. The fluid production rate
averaged 6.5  gallons per minute (D 14393L, p. 6).

8. Material Handling and Pretreatment Needs

No pretreatment is necessary.

9. Process Waste Streams

Recovered water is treated in an above ground treatment train. Suspended oils and solids are removed first, i.e. by
gravity separation or chemical flocculation. The water is then treated by biological oxidation or by a combination
of physical-chemical treatment (D14394M, sec. 8).

-------
10. Operator Requirements



No available information.



1 i. Utility Requirements



No available information.



12. Set-Up/Tear-Down Requirements




No available information.




13. Technology Reliability/Maintainability




No available information.



14. Public Acceptance



No available information.




15. Information Sources



DI4394M, Johnson, et al.. 1989



DI4393L, Fahy, ct al., October 1992



D106605, EPA, October 1995



Dl 43901, Calabrese & Kostecki, 1992



D14388O, Western Research Institute, Date Unknown



Dl 1691G, Ground Water Monitor. April 1995

-------
Copyright 1999, Remedial Technologies Network, L L. C., All Rights Reserved,

Western Research Institute

Contained Recovery of Oily Wastes (CROW ™)

Technology Cost

The cost of applying CROW™ technology is largely dependent upon site characteristics and size, as well as the
extent of the process monitoring required. According to the vendor, the larger the site, the lower the cost per
cubic yard (yd3) of contaminated soil. For example, a 2.6 acre site has a projected cost of $30/yd  3, while a 0.2
acre site has a projected cost of S250/yd 3. Both sites have a 20 to 30 foot thick contaminated zone within a
highly permeable aquifer (D14389P).

In 1995, CROW™ technology was anticipated to cost from $50 to $ 125 per yd 3 of soil treated (D12467E,  p.
72).

At the Brodhead Superfund site in Stroudsburg, Pennsylvania, using the CROW ™ technology cost at least $1.3
million less than the projected cost of excavation and disposal. The estimated price tag at the time (1990) was
$3.3 to $6.8 million, depending on the ultimate disposal of the excavated material (landfilling or incineration).
The CROW demonstration will cost approximately $2 million (D14391J).

Information Sources

D12467E, Udell and Sitar. 1995

D14389P, Johnson, December 1996

D14391J, Villaume, June, 1996

-------
Copyright 1999, Remedial Technologies Network, L L C., All Rights Reserved.

Western Research Institute

Contained Recovery of Oily Wastes (CROW ™)

Case Study Overview

In a pilot-scale test at an aquifer contaminated with creosote and pentachlorophenol (PCP). the CROW ™
process proved practical as a choice for full-scale remediation. Hot-water injection displaced 70 to 80% of the
non-aqueous phase liquid (NAPL) in the soil, and PCP concentrations were reduced from 2,100 mg/kg to 3.6
mg/kg after flushing with 20 pore volumes of water (D14393L, pp. 12 & 15). See Case Study 1 for more
information. A full-scale remediation using CROW™ was conducted at the Bell Lumber and Pole Company
Superfund site. Results are not yet available (D14392K).

CROW™ is being used for a full-scale remediation at the Brodhead Creek Superfund Site in Stroudsburg,
Pennsylvania to mobilize and displace coal tars, pentachlorophenol, creosote, and petroleum by-products. Hot
water is injected through six wells at the site to dislodge contaminants in the soil matrix. The wells were placed
at a depth of 27 feet to 35 feet and hot water was injected at a total rate of 100 gallons per minute (D14392K, p.
4).

Information Sources

D14392K, EPA. April 1995

D14393L, Fahy, et al, October 1992

-------
  IN SITU THERMAL

  DESORPTION
  A new two-fold process uses thermal blankets to
  vaporize soil contaminants and
  a. vacuum to draw gases out of the ground
  ByJudeR. Rolfes
      > hell's in ritu thermal dcsorption
       technology it i revolutionary ip-
      Iprotch to handling difficult soil
       contamination  problemi in  •
 cost-effective manner. Far certain type*
 of dangerous and environmentally unac-
 ceptable chemicals, it provide! t solution
 dur, previously did not edit.
   Although TerraTherrn Environmental
 Service* Inc..  an affiliate of Shell Oil
   J.. waj formed In: year oj develop and
 utilize thermal desorprion. the process
 itself 11 hardly new. TerraTherm has ap-
 plied drrsrfo of Shell's research and st-
 pcricnce in oil field technologies to dlis
 environmental issue.
   The technology Is unique became of
 in in titu nature, which allows it to re-
 mediate an entire lite without moving
 «ny toil. The proceu desorbs and de-
 stroyi the  contaminants. The dcstruc-
 tion of the contaminants occur* directly
 in the wiL which is heated to tempera.
 cure* ranging to 1,000 degrees Centi-
 grade within • doted lyroem.
  Currently, there arc  two applications
 ofTui sit* thermal desorpdon. The ther-
 mal blanket works on soil contamina-
 tion at the  surface, like a powerful elec-
 tric blanket combined with a vacuum
 cleaner, while thermal wells clean the .soil
 at greater depths, making me of hearing
 dements placed in wellborn.
  There arc two components to the in-
 tegrated system. Thermal b'.inkets or
 thermal wells are ajed to heat the soil
 and destroy the contaminants while a
 separate vapor treatment system handles
  e ofTgascs.
  fa >itu thermal dcsorpdon can be ap- >
plied to  a  wide range of volatile and

* i HovlnwunennJ PROTECTION
 serai-volatile organic contaminants, in-
 cluding chlorinated solvents, polycblori-
 nated biphenyls (PC3s), pestiddes and
- petroleum wuccj in soils varying from
 low permeability days to beteropceous
 soil compositions. The process cu dean
 a'tei that were once deemed uneconom-
 ical for cleanup.
   Man-made chemicals like PCBs are
 very stable compound! that don't decay
 by nature. They won't go away. Bioreme-
 diation won't work In the past, treat-
 ment methods  required digging up die
 soil and kaulinj it away for incineration
 or co « land/Hi for hazardous waste in
      The process reduces

       Hie contaminants

     in the soil to very low

      levels—lower than

      EPA requirement!.

 compliance with the Resource Conser-
 vation and Recovery Act (RCRA) regula-
 tions. With iu new technology, Terra-
 Therm has the capability to destroy
 PCSs on site, eliminating these compli-
 cations and additional expense.
  The process reduces die contaminants
 in the soil to very low Icvcli—loww than
 U.S. Environmental Protection Agency
 requirements. Destruction is essentially
 complete.  Nothing u carried ofFsite,
 condensed or produced on the surface.
 Due to the nature of the proeeaj, it is
very low-profile, with low impact on a
 neighborhood where t site is located.
 There ii virtually no odor or dust result-
 ing from the remediation process.
   Unique to TcrraTherm's synem is thai
 it provides tailor-made solutions for indi-
 vidual problems. The technology is espe-
 cially effective  in  handling  difficult
 cleanup problems that occur  in the
 chemical *nd refining industries, pipe-
 lines; and distribution processes, utilities;
 railroads and military installations. TKe
 «i situ nature of the syjcm nuke* it most
 appropriate for these fuulitics.
  Remediating pesticides at a chemical
 plant or cleaning the complex mix found
 In a wosre pit at a refinery are ideal uses
 for this technology.
  In the utility industry,  PCBs were
 used as insulation  and coolant oil in
 transformers and large electric motors
 and capacitors over a 30-year period, h
 titu thermal dcsorpdon u especially use-
 rul in cleaning up sires where this equip-
 ment was manufactured, stored or ser-
 viced. The simc is true for mantifacoircd
gas plants (MGPs), which were in oper-
ation a hundred years ago in the eastern
and midweitern United Sates, and left

-------
 behind tar residues and o&cr cardno-
 Cenic compounds.
   Rulrouu pravide another good tam-
 plc of dili technology* flexibility. la the
 Northeast, where railroads hire been
 electrified for many yean, diere arc sig-
 nificant FCB problem! in rail-yard shops
 that overhaul engines.  In tint thermal
 detotptian can be uied » remediate tbs
 •oil without moving tncki or thutting
 do-wn the rail yard,
   TerrxTherra has rut this new technol-
 ogy to the :«t «t »'ff arouad the coun-
 try, «nd hat proven It so ae i£ccnve and
 safe, la 1995. thermal blanxcti were ap-
 plied u in upstate New York Superfusd
 lite where FCB contamination wts as
 hirii as 5,000 pan* per million (pprrj.
 After treatment, soil targe: levels of leu
 than  2 ppm PCBi were met. and air
 emis»toru were well below New York and
 EPA regulatory liroiti.
  AcTUxlly, in not thermal derarpcicui Had
 fa inception to the oil £elds of California.
Since 1959. SKdl hai been doing thermal
 enhanced recovery in Jo oil fields dicre.
 SaendJM «t Shell'* Hovuron. Tecu. re-
search center begin developing a remedi-
  •don proccM using dteae tune prindplei
  in 1988. hi rit* thermxl deaotpdoa wu
  the mult. On. Huold J. Vinegtt Gcoige
  L. Soegemcier *ad Eric DeFouffigrtic tre
  credited ts being die key developen of
  this breakthrough technology;..  •
    Thermal wells deliver heat Txdow the
  surface tiling heating dements placed in
  wellfaotci drilled on a regular pattern.
  The typical well sptdngi can be 7 to JO
  feet. At die heat from die well* viporixa
  the «oil conomiaanu, a vacuum applied
  to the tame wells drawn the contamj-
  nanti out of die ground.  Dr. Vlnejzr hai
  observed that the wells can be drilled
  vertically to the contaminated tone, pos-
  sibly as deep as several hundred feet, and
  can reach horizontally under obstacles.
    Thermal blankets. 8-foot-by-20-foot
  rectangular steel boxes, can be used side-
  by-iide in remediating lurrace eonrzmi-
  nation. Shell's simulations suggest die;
  will wort to a depth of approximately J
  feet. With blarjcets pUccd over die are*.
  contaminant!  are vaporized by heating
  the loiL Healing element* in each blan-
  ket can reach 800 to 1,000 degrees Cea-
  trigrade at die sur&ce. As the heat front
  moves through the roil, contaminants
  are vaporized and a vacuum  system
  drawi the vapors toward and through
  the blankets. Most contaminants are de-
 stroyed in the soil near the beat source.
   The vapor treatment system i* tine
 tecond major component  of the tech-
 nology, treating contaminated vapors-
 drawn out of the toil. Any remaining
 vapors not destroyed by the thermal
 wells  or thermal blankets are  drawn
 through thii closed system. Effluent va-
 pors are processed using a cyclone sepa-
 rator  la capture parrJcuIates while a
 flameles* thermal oxidize* destroys or-
 ganic*, and activated carbon adsorber*
 pravide both -fuul jjotithing and a sig-
 nificant margin of safety. As a result.
 carbon dioxide and water are virtually
 the only air emissions. The lite is then
 ready for immediate revegetarion.
   Individual remediation activity U de-
 signed through the  aid of sophudeared
 computer simulations. Temperature* arc
 monitored throughout the remediation
 process, and soQ samples are ulccn pre-
 and post-treatment.                El

Judt R. Haifa it she prtrident anJdntftx-
 rcutive officer of Ttri&berm  Envirtn-
 menulServianlitclmHSSften, Texas.

 For more information, circle 44 on card.

         Eavinnmcatal PROTECTION J U
                                                                                                                         II

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              Destroying     PCBs      in      Soil
             at   a   Dragstrip-ln   Situ
                                      Removal oforganic contaminants is an important
                                      environmental issue, yet unfavorable economics
                                      has delayed or prevented many cleanups. Ex-
                              situ techniques (such as excavation and transport to
                              incineration facilities or landfills) are expensive and dis-
                              ruptive and have been increasingly displaced by multistage
                              processes (such as soil washing) and in-situ technologies
                              as they have developed. Some in sini technologies gaining
                              in use are soil vapor extraction, bforemediaiton and ther-
                              mal desorption. Regarding the latter, heat greatly assists
                                                           the desorption of
                                                         - any organic mate-
                                                           rial and on speed
                                                           removal times a
                                                           thousand-fold
                                                          compared    to
                                                          removal at ambi-
                                                          ent temperatures.
                                                          The difficulty of
                                                          (he past has been
                                                          applying heat cost
                                                          effectively to large
                                                          sites, the .case
                                                          histories   pre-
                                                          sented here dis-
                                                          cuss ihe use of a
                                                          new thermal des-
                                                          orption technol-
                                                          ogy  that  has
                                                          recently become
                                                         commercially
                                                         available for in
                            situ treatment. The technology was demonstrated recently
                            in a series of soil remediation projects where contamina-
                            tion consists of high concentrations of recalcitrant organ-
                            ics such as polychlorinated biphenyls (PCBs). petroleum
                            hydrocarbons and chlorinated solvents.

                                            Problem
                              X dragswip in Glen Falls. NY. became hearth contami-
                            nated in the late 1970s when waste oil containing PCBs
m Na> Kid a »rf » ettvfefed Mtnfe
                                                                                                           Mike Attaway
                                                                                      TerraTherm Environmental Services
  (predominantly Aroclor 1242) was sprayed on the
  dragstrip for dust control PCBs are particularly difficult to
  extract from soils because they are insoluble in water and
  haw i high boiling point (>300'C). The site had an aver-
  age PCB concentration over 500 ppm with some concen-
  traBoos ranging beyond 5,000 ppm.

                  Solution
    Soil tests showed the PCB contamination to be greatest
  within the first six inches of soil depth. As such, the site
  was ideal for testing and demonstrating a new in situ ther-
  mal and vacuum technology that applies heat direcuy to
  the soiL the technology was introduced in 1994 by Ter-
  raTherm Environmental Services, of Houston, TX. The
  results of the demonstration, completed in late 1996,
  were pan of a process for TerraTherm to obtain a nation-
  wide Toxic Substances Control Act (TSCO permit for the
  remediation of surfidal soils containing PCBs and other
  contaminants.
   Hie job was the first major project using the company's
 ttchnology. which is called In Situ Thermal Desorption.
 The technology combines die use of an electrically heated,
 impermeable blanket placed directly on the affected soil
 with vapor collection equipment. Each •blanket" is actu-
 ally constructed of a steel frame from which is suspenced
 a layer of stainless steel  webbing. Heating rods are
 threaded through the webbing to transfer the heat into the
 soil below the blanket. The structure is placed directly on
 the surface of the soil to be treated. After placement over
 the soil, the blankets are covered with a fiberglass rein-
 forced silicon rubber sheet and sealed at the edges to pre-
 vent vapor escape. PCBs and other organics and water in
 the soil are vaporized as the blanket is heated up to
 l.IOO'C. Vapors are then drawn out of the soil and
 through ;he blanket by a vacuum system. Virtually all of
 the contaminants (typically more than 90 percent) are
 oxidized by the blanket near the soil surface. Any remain-
 ing vapors  are fed to a trailer-mounted treatment system.
The treatment system incorporates a cyclone separator to
capture paniculates and a flameless thermal oxidizer.
which convens the remaining hydrocarbons into carbon
66  environmental TECHNOLOGY • September/October 1997

-------
   CaseHistory
dioxide and water. The oxidizer exhaus is then cooled 10 between 110° and
180'C before passing through a granular activated carbon adsorption unit and
vented to (he atmosphere.
   Several blankets set up side-bv-side increase the total area to be treated at
one Ume. The Glen Falls project was conducted on an area of 4.800 square
feet. Five thermal blankets, each covering 160 square feet, were used to ireat
800-square-fooi sections at a time. The soil is sandy with a porosity of 35 per-
cent and a dry density of about I." grams per cubic centimeter.
   While PCBs were found primarily in the top six indies of soil across the site.
the project was designed 10 remove PCBs down to 12 indies below the surface.
   Besides PCB concentration in die remediated soil, parameters monitored to
hdp gauge (he efficiency of the technology included soil temperatures during
the lest period, oxidizer temperature, suck emissions of PCBs and dioxins.
carbon monoxide in the effluent, flow rate through the system and vapor tem-
perature at the carbon bed inlet. In addition, at the request of the EPA. soil
samples were analyzed to verify thai lateral and vertical migration did not
occur as a result of treatment.
   Because of soil moisture, the soil temperature rises slowly ai first, to about
100'C and stabilizes temporarily, then nses further as water is boiled off.

                           Results
   The thermal blanket was operated at temperatures ranging from 815' to
925*C. It took about 10 hours for the blanket heaters to reach their top oper-
inng temperature, and about 20 to 1* hours for the soil at a depth of about six
inches to reach 200*C which was sufficient to reduce PCB concentrations to
the objective levels. Before heating the soil, the highest average  PCB concen-
tration in  any of 18 samples was 68" ppm ai depths up to three inches and
100 ppm at depths from  three to six inches. Post-heating soil samples indi-
cated that PCB concentrations were reduced to well below the cleanup target
of 2 ppm on all but one sample, and the average was below 2 ppm. with many
concentrations as low as 0.03 ppm.
  The cost of treatment by this technology at large commercial sites (> 15
acres) to a depth of sis inches was shown to be about $150 per ton of soil
seated for this project. The cost can be affected by high  moisture of the mate-
Dais to be treated. While it would not preclude the use of the technology, the
energy cost to remediate a site rises with the amount of water that must be
vaporized during treatment. This problem can be circumvented in some pro-
jects by use of dewatering pumps or drainage ditches and other means of
teping uater from returning -o the area being treated

                            Encore
  Since completing the drag strip project using thermal blankets, TerraThertn
bualso begun using of a reined technology, thermal wells, which can be
red to treai organic contaminants in situ a greater depths. In thermal wells,
                                           the heating elements are
                                           placed in vacuum welt-
                                           bores drilled  :nto the sod
                                           in a  regular  pattern. As
                                           the heat from  the well
                                          vaporizes the soil conta-
                                          minants,  a  vacuum
                                          applied  to  the  wells
                                          draws lh<; contaminants
                                          out of the ground As with
                                          the thermal blanket sys-
                                          tem, destruction of anr
.&? <** fc» fakes af cleanttf soil M Chi Farts, NY
;x5**r***«* *f»*n ind contrasts with adjacent otl-
       * Trt l» be nmdiited. UK soil lux turned red
       ttt iron i« th« soi his uxfiiai b ib fej+ state.
             the sol B ready faraannal mtfUiee
                                          remaining organic conta-
                                          minants is completed in a
                                          flameless thermal oxi-
                                          dizcr.
                                            The  ihernul  wells
                                                                                   OIL/ WATER SEPARATORS
                                                                               REMOVES GROSS & FINE Oil DROPLETS FROM WATEft
                                                                         UJ
                                                                         UJ
                                                                         c:
                                                                                  COMPACT SUAVITY 1YPJ COALESCING SYS1EMS
                                                                                   MANY SMNOARO MCOOS TO CHOOSE FROM
                                                                                  f WRGIASS OR CAflBON STEEL CONSTRUCTION
                                                                                INCLINED PLATE CLARIFIED
                                                                                   REMOVES METALS » SUSPENDED SOLIDS
                                                                                                                            m
                                        O
                                        rn
                                                                                   COOBCL
                                                                                   CUMT
                                                                                                           C3IWWON (VUNiHOC
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                                                                        NATIONWIDE VIDEOTAPE PROGRAM

                                                                        MASTER OF SCIENCE IN HAZARDOUS
                                                                        AND WASTE MATERIALS MANAGEMENT

                                                                        • Developed in cooperation wiih the EPA. business.
                                                                         and industry.
                                                                        • Emphasis on management and
                                                                         technical issues in treatment.
                                                                         elimination, handling, regu-
                                                                         lation, and compliance.
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                                                                       FOK MORI INFORMATION
                                                                       Mike Kirkpatrick
                                                                       Phone: 2I-* 768-1452
                                                                       cax: ZH 768-3845

                                                                       E-mail: rmk@seas.smu.edu
School of Engineering and Applied Science
Southern Methodist University
Dallas. Texas
                                                                                   naltitftal itr rtbnte nrtgim. ir.T. agt. or tlttattiltlr
                                                                               CAU JOO-817-1S8  USE fASTFM J2490997
                                                                              AND/OR C1K.U 249*ON CARD FOR FREE INFO.

-------
      CaseHistory
   were  used in a soil remediation project this
   spring in Cape Girardeau, MO There, al a six-
   acre site and former location of a motor and
   transformer repair and sales business, PCB Aro-
   cior I>60 concentrations registered as high as
   19.900 ppm.
     For the project. electncaJ heating and vacuum
   were applied to an array of 12 wells spaced five
   feet apart. Heating was applied through electrical
   heaters to  a depth of 12 feet for a period of 42
  Ilieraul wells have tttt developed to trail soils!« site to deptks
  equal to aiqr weBs can tx drilled. The tcdinoto0, «faick uses keafinz
  ttenerts placed « mOntrx onOed o* t ngubr (wtiera, it anwrtfr
  w ise U remediate »3 caoUminated witt dUoriutcd sotvotft to a
  dcntt of aHeeibefcxr Un arhce to Portfand. PC
 days. Soil temperatures were monitored through-
 out the period and soil samples were uken with a
 Geoprcbe coring unii io verify contamiaint con-
 centrations before and after heating. Tells operat-.
 ing at temperatures up to iigO'C (on average)
 produced temperatures between 480° and 535°C
 in the soil between wells, reducing PCB concen-
 trations to non-detect levels (< 33 ppb. by EPA
 Method 8080) in the center of the test area and
 below > ppm throughout the test site.
  Except for dewatering, soil treated by thermal
wells or thermal blankets will not be structurally
altered, even when operating temperatures
        approach I.OOO°C Immediately after
        treatment, the soil is sterile, but experi-
        ence shows the recovery is rapid. If
        soil is disked, fertilized and seeded fol-
        lowing normal revegeuiion sequences.
        regrowth should match that of other
        soils.
          *Me the sod can be readily revege-
       lated. the drying nature of the technol-
       ogy does change some characteristics
       of the soil. For instance,  at the Cape
       Girardeau project, the treated cla> lost
       some of its plasticity and became ven.
       dry; dense and fine grained. L'pon
       rehydntion the treated clay's plastic-
       ity  appeared to be lost and the soil
       behaved as a clay-size sand.
           What's Next?  "*
   Thermal wells technology is ajj^
 being demonstrated at a sue in Con
 where an industrial area is contamins
 dichloroethylene. DCE contamination i
 390 to 480 ppb at a depth of six i
 650 ppb at a depdi of 10 to u feu .„
 of the demonstration is to reduce DCE <
 tions to less than 80 ppb Fifteen ther
 were drilled to a depth of U feet ResulBj^JT
 preliminary, but the; indicate reduction to ItZ
 of I to 3 ppb DCE in all but one test area, aid fee
 area exhibiting a level of 9 ppb.         ••,£•.,
   Pesticides and fuel oils are examples ofc4w"
 contaminants that can be desorbed thenaifl. :
 field demonstratkMis also are planned fwcofco- j
 tion and capture of low boiling point meuls, ttdt i
 as mercury.                         ^c£
   For more information, contact MUtAO- •'
atray, TerraTberm £nrironmentalSenitf£;[
 (281) 296-1000: (800) 100-5288. TerraJtitm"'
is a subsidiary of Shell Technology Versltm'',
Inc.. trbich developed the heating tecbnalotr'"';
asparlof Us oil rffOrery efforts.         \
 Reader Rating. Pica*: circtt '.lit appropriate
 number on tltr RtoJtr Strwct Card to indicate
 your leml of interest in this article/topic.
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68  environmental TECHNOLOGY •  Sepierte«aobfr 1997
                                        FREE CATALOG
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                                       Sampling Equipment  for ;ne Pollution
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-------

-------
           Environmental Protection
           Agancy
             Development
             (RD 681}
February 1992
&EPA
BioTrol Soil Washing
System for Treatment of a
Wood Preserving Site

Applications Analysis Report
                •••••aHBVy ••• I^^BV 4lHMtd*i«HB

                SUPERFUND umAr.tE
                TECHNOLOGY EVALUATION

-------

-------
                                      EPA/540/A5-91/003
                                         February 1992
BioTrol Soil Washing System
      for Treatment of a
    Wood Preserving Site

 Applications Analysis Report
  Risk Reduction Engineering Laboratory
  Office of Research and Development
  U.S. Environmental Protection Agency
        Cincinnati, OH 45268
                                Printed on Recycled Paper

-------

-------
                                Abstract
     This project was an evaluation of the BjoTrol, Inc. Soil Cashing System (BS WS),
 consisting of a proprietary mechanical soil washerand separation system, a Slurry fiio
 Reactor (SBR) provided by EIMCO Process Equipment Co., and fiioTrol's propri-
 etary Aqueous Treatment System (BATS), a Fixed-film, aerobic biological treatment
 process. In this study, both biological processes use bacterial populations selected to
 specifically degrade pentachlorophcnol (penta).

     This report summarizes and analyzes the results of the Superfund Innovative
 Technology Evaluation (SITE) Program's demonstration at the MacGillis and Gibbs
 Company wood preserving  site in New Brighton, MN during the Fall of  1989.
 Extensive sampling and analysts were carried out to establish a data base against which
 the vendor's claims for the technology could be evaluated  reliably. Data from other
 investigations by BioTroI are included to support the demonstration results. Conclu-
 sions were reached concerning the technological effectiveness and economics of the
 process and its suitability for use at other sites.

     The primary conclusions from the demonstration study are:

     (1)  The Soil Washer effectively segregates the local soil into a coarse, relatively
 uncontaminated fraction constituting the largest output portion, smaller fractions of
 coarse and fine woody debris, and a contaminated fine fraction accounting for about
 10% of the input solids weight.

     (2)  Starting with soils containing either 130 mg/kg or 680 mg/kg of penta, the
 removal efficiency for penta in the Soil Washer, defined as the change in contaminant
 concentration (weighted average) between the feed soil and the washed soil output
 stream, ranged between 89% and 87%. Removal efficiencies for polynuclear aromatic
 hydrocarbons were slightly lower. 83% and 88%. in tests  with two soils. Concern
 about the efficiency of the extraction step during analysis of the feed soil, leading to
 low penta and PAH values, suggests that these values may be biased low. The vendor
 claims a 90% removal efficiency.

     (3)  Based on the demonstration study, 27.5% to 33.5% of the pentachlorophenol
 mass is concentrated in the fine panicle cake fraction (as-is weight basis), between 18
 and 28% is found in the coarse and fine oversize, and 34% to 39% is found in the
 processing water. The washed soil retains only about 9%. Thus, while washing or
 extraction of pentachlorophenol takes place, the predominant effect of the soil
 processing was segregation of coarse and fine particles. Similar distribution occurs
 with PAHs except that extraction into the aqueous fraction is much smaller due to the
 much lower solubilities.

    (4) While steady-state operation was not achieved in the anticipated acclimation
 tune (one week), the Slurry Bio-Reactor did achieve pentachlorophenol removals as
 high as93% and, based on extrapolation of the data, may well be capableof even higher
removal levels.

    (5)  The BATS successfully degraded between 91 and  94% of the pentachloro-
phenol in the aqueous process liquor, the Combined Dewatering Effluent (CDE).

    (6)  Combined capital and operating costs for the integrated system are estimated
at S168/ton of feed soil, based on the  MacGillis and Gibbs site. The Soil Washer
accounts for about 90% of the cost, followed by slurry biodegradation of the fine
panicle slurry (about 2%) and treatment of the aqueous stream (about 1 %). Unassigned
                                 IV

-------
 costs contribute about 5% to the total cost. Incineration of the woody debris found in
 the soU is a major component of the Soil Washer costs, contributing about 80% of the


     C7) On an individual unit basis, costs for the process were:

          SoilWasher    $185/metrictonor$154/shorttonofsoilor$197/yd3
                         (including incineration)

          SBR          $9.22/1000 L or $34.39/1000 gal of 20% slurry

          BATS         $0.44/1000 Lor $1.65/1000 gal of water treated


     Secondary conclusions that have been reached on the basis of the demonstration
 study ana other data provided by the vendor include:

     (1) The Soil Washer also separates highly contaminated coarse oversize (wood
 chips) and fine oversize (sawdust) factions, typical of wood preserving facilities.
 These fractions may be incinerated.

     (2) Thenatureof the soil has a significant effect on the efficiency of soil washing
 and/or the segregation into coarse and fine fractions that can be achieved.  The soil
 character (e.g.. particle size) must be considered in evaluating the applicability of the
 Soil Washing System.

     (3)  Depending on the nature and concentration of contaminants of concern
 acclimation of the Slurry Bio-Reactor may lake considerably longer than the expected
 one week. Laboratory scale experiments would be needed in each case to establish the
 acclimation period. This may be important in scheduling and integrating units for a
 particular site.

    (4) The system is not without mechanical problems and complexities that still
 need to be resolved. For example, clogging in the soil feed system forced a reduction
 in Soil Washer operating rates, and foaming in the BATS, probably due to thickening
 agent added for dewatering of the fines, created operational problems.

    (5) The  units evaluated in the demonstration study may not be appropriately-
 sized for integrated operation. Similarly,  for a full scale system, calculations have
indicated that a BATS capacity of about 300 gpm would be needed for the proposed
20ton/hoursoilprocessingrate. However, as discussed in the report, reuse of at least
a portion of the process water without treatment may be possible.

-------
                                                 Section 1
                                          Executive Summary
Introduction

    One configuration of BioTrol, Inc.'s Soil Washing Sys-
tem (BSWS) has been used to treat pentachlorophenol-con-
taminated soil at a site on the Superfund National Priorities
List Operational and cost data were collected for that inves-
tigation and serve as the primary basis for an evaluation of
the utility of this sequence of processes for remediation of
other sites across the Nation. Supporting data from other
studies and evaluation of one or more of the processes at
other sites are discussed in Appendix D.


Conclusions
    Based on the results of the SITE demonstration project
at the MacGillis and Gibbs site in New Brighton, MN and
information concerning other studies provided by the ven-
dor. BioTrol, Inc., for different wastes at other sites, several
conclusions can be drawn.

    •   The Soil Washer is capable of segregating a penta-
        contaminated feed soil (FS) into a major fraction of
        washed soil (WS) retaining Hale (-10% by weight)
        of the penta; smaller coarse and fine oversized (CO,
        FO) fractions retaining contamination (-20-30%).
        probably as woody debris; a Tine  particles (FPC)
        fraction retaining  the bulk  of the contamination
        (-30%) in a small mass; and a penta-contaminated
        (~30%)  aqueous stream called the Combined De-
        watering Effluent (CDE).

    •   Removal efficiencies for penta removal, defined as
        the change in concentration from the feed soil to the
        washed  soil output stream  (1-WS/FS). averaged
        89% in the soil washer test for a soil with a low
        penta concentration (130 mg/kg) and 87% in the
        test with the high penta (680 mg/kg) soil. These
        values are only slightly less than the vendor's claim
        for a 90% removal efficiency. The removal effi-
        ciencies for total  polynuclear aromatic hydrocar-
        bons (PAHs) were slightly lower, 83% and 88% in
        the two tests.

    •    Once acclimated,  the Slurry  Bio-Reactor  (SBR)
        should be capable of biologically  degrading over
        90% of the penta contamination in the fine panicle
        fraction. Concentrations of polynuclear aromatic
 hydrocarbons are also extensively reduced (>70%).
 Because of longer-than-anticipated acclimation at-
 tributed to very high penta concentration in the
 slurry, the system was not at steady-state for much
 of the 14 day test. Consequently, the removal achiev-
 able under steady-state operation could not be de-
 termined.

 The fixed-film biological treatment system (BATS)
 is capable of destroying at least 91% of the penta-
 chlorophenol in the process  water from the soil
 washer after acclimation with a penta-specific bac-
 terium. Because of low influent concentrations and
 high detection levels, removal of PAHs could not
 be determined.

 The removal of PAHs from the bulk of the soil and
 concentration in the fines fraction appears to paral-
 lel the  behavior of the pentachlorophenol, except
 that little is found in  the process water, the Com-
 bined Dewatering Effluent, probably due to lower
 solubility.

 Other constituents commonly encountered at  such
 sites, including oils and heavy metals, were re-
 moved  from  the washed soil to varying degrees
 (removal efficiency: oil: 80-90%; copper, chromium,
 and arsenic: 50-70%).

 Predicting operating costs for other sites is difficult
 since one or more of the three processes may not be
 needed  (or the most  attractive alternative) for a
particular site. Sizing of each process unit also must
be considered within a particular scenario and will
be dependent on  time constraints for a cleanup,
volume/characteristics of soil, etc.

On the basis of an assumed 30.000 yd1 of soil to be
processed in a commercial  system at the MacGillis
and Gibbs site using a 20 ton/hr Soil Washer coupled
with appropriately sized Slurry Bioreactor (23 gpm)
and BATS (three 100 gpm) units, the cost (amor-
tized capital plus operating), based primarily on the
demonstration study, is  estimated at S168/ton of
feed soil.
                                                      1

-------
         The Soil Washer accounts for 90% of the total cost,
         with incineration of the woody debris contributing
         about 80% to the calculated Soil Washer cost. Slurry
         biodegradation accounts for 2% of cost and aqueous
         treatment accounts for 1% of the cost. Unassigned
         costs contribute the remaining 5%.

         Since alt three unit operations may not be necessary
         for a site, the following unit costs were also devel-
         oped:

         Soil Washer       S154/ton or S197/yd3
         Slurry BioReactor  $34.39/1000 gal of 20% slurry
         BATS             $1.65/1000 gal of process water

         Operating labor was a major operating cost factor
         for all three units.
                /
         A major contributor to the cost for the Slurry Bio-
         Reactor is the volume or mass of fines produced per
         unit mass of feed soil, which translates directly into
         the volume of slurry that will need  to be treated.
         The developer indicates that the Soil Washer Sys-
         tem is effective with soils containing  less than 25%
         fines.

         While contaminant concentrations and flow rate
         attainable would be major contributors to the oper-
         ating cost of the BATS, these factors are not major
         considerations in the overall economics, assuming
         that regulatory requirements for return of the washed
         soil to the site can be satisfied.

         One advantage of the Slurry Bio-Reactor and the
         BATS processes over other biological treatment
         processes is that they generate minimal quantities
         of sludge that would require solids separation and
         disposal.

         Auxiliary equipment needed to support this process
         is comparable to that for other aboveground treat-
         ment systems, such as excavation  and prescreening
         of soil to remove oversized material and debris, oil/
         water separators and clarifiers for pretreatment of
         process water going to the BATS, and polishing
         filters, carbon adsorbers, etc. that may be needed
         for the effluent to meet local discharge  require-
         ments.
Discussion of Conclusions
    The mobile pilot system  tested at the MacGillis and
Gibbs site consisted of a Soil Washer (SW) with a nominal
capacity of 500 Ib/hr wet (as is), a Slurry Bio-Reactor (SBR)
with a throughput capacity of about 0.024 L/min (0.38 gal/
hr) as a 2-10% slurry, and a pilot scale  BioTrol Aqueous
Treatment System (BATS) with a nominal hydraulic capac-
ity of about 10 gpm. All units can be transported to a site for
use in an evaluation.

    Extensive data were collected over various segments of
a six week  period  to assess the ability  of the system  to
concentrate and then degrade pentachlorophenol and poly-
nuclear aromatic hydrocarbons from the soil at the site; to
establish the operational requirements of the system and its
individual components; and to arrive at the costs of opera-
tion in such a manner that future decisions could be made as
to the viability of one or all of the units for other sites. The
data from this study serve as the primary basis  for  the
foregoing conclusions. Additional supporting evidence was
provided from other studies by BioTrol.

    An extensive  Quality  Assurance  (QA) program was
conducted by SAIC  under the supervision of EPA's QA
program, including audits and data review along with correc-
tive action procedures and special studies to resolve specific
data quality problems. These programs are the basis for the
quality of the data derived from the SITE project. Discussion
of the QA program and the results of audits, data reviews.
and special studies can be found in the Technology Evalua-
tion Report

    Two feed soils, containing different penta concentra-
tions, were prepared  from the available soil for the study.
The "low penta" concentration soil was prepared by mixing
slightly contaminated soil  from a former penta processing
area with a more highly contaminated soil previously exca-
vated at the site by BioTrol. The "high  penta" soil was used
as excavated. The primary variables studied were:

    A. In the Soil Washer
        a. input and output stream flow rates and totals
        b. penta concentration of input and output streams
        c. PAH concentrations of input and output streams
        d. soil characteristics
    B. In the Slurry Bio-Reactor:
        a. overall penta concentration
        b..penta distribution between solids and liquid
        c. PAH distribution
    C. In the BATS:
        a. penta concentration
        b. effect of metals, oil, etc.
    The results of the SITE project demonstrated that the
soil washing process successfully segregated coarse soil
(major fraction) from fine clay and silt (small fraction).
While the bulk of the mass remains in the coarse soil, the
bulk of the  penta and PAHs are in the fines fraction. In
addition, woody debris  was removed as coarse and fine
oversize fractions, and an aqueous stream containing consid-
erable penta but little PAHs was generated. Of these, the key
product streams were the washed soil and the fine particle
cake (clay/silt), although the coarse oversize  fraction also
retained a significant mass of penta, probably in woody
debris.

    While one option may be off-site disposal  of the highly
contaminated but small volume and weight of fine panicle
material, a more attractive option may be treatment of that
material on-sile in equipment such as the Slurry Bio-Reac-
tor. This unit was tested on a small portion of the fine
panicle output stream. Over 90% of the pentachlorophenol
and over 70% of the PAHs were removed in the SBR when

-------
  the system had been stabilized. leaving a fine particle slurry
  with minimal contamination.

     j^r lyStf^Lis a net consum« of water, absorbing about
       of the 1200-1500 gallons introduced to transport and
  process each  ton of soil. Municipal water, treated effluent
  tram the BATS, and a dewaiering polymer stream fed to the
  thickener provide this water. Dewatering of the solid frac-
  tions produces wastewater (Combined Dewatering Effluent
  CDE) contaminated with the pollutants of concern,  in this
  case penta and PAHs. The penta concentrations in the aque-
  ™U?HTT',.UP l° its  solubility Iim» of 80 ppm in the test
  with tfie high penta soil,  appear to validate BioTrol's claim
  that the soil is washed or extracted as well as segregated by
  panicle sizes.                                         3

     BioTrol's fixed-film aerobic reactor (BATS) success-
 fully treated this wastewater {at 3 gpm). degrading over 90%
 of the penta and producing an effluent suitable for recycle or
 discharge at the MacGillis  and Gibbs site. In retrospect
 there is some question whether there is a need to or benefit
 from treating all of this water before recycle. Losses  to the
 various soil fractions,  replaced by uncontaminated munici-
 pal water, may avoid buildup of pent* (and perhaps metals)
 One option may be to treat a blowdown of the  wastewater
 before recycle to assure that penta and other contaminants do
 not affect the quality of the washed soil product.  Obviously
 considering the capital cost for the  BATS at $250.000 for
 300 gpm capacity, this could  lead to considerable savings.
           the primary factor in the evaluation of the system
is the amount of penta on particular fractions of the soil  a
second cnucal factor is the concentration of key pollutants
that can be tolerated in the feed to the SBR and Uie BATS At
least on a small scaJe, this study demonstrated that the Slurry
Bio-Reactor is capable of tolerating up to 5500 ppm of penta
(dry weight basis) on the incoming fines in the slurrV >U
such a level, the solid surfaces  may be inhibitory or toxic to
  penta-degrading bacteria. Nevertheless, the fine solids mav
  serve as a reservoir of penta for the liquid phase until the
  adsorbed film finally reaches a concentration amenable to
  biodegradation on the surface. The dispersed bacterial ponu
  lauon would only see and degrade the soluble penta (under
  100 ppm). which  is much more tolerable based on BATS
  results obtained by BioTrol in odier studies.

     Secondary pollutants such as oil and metals (includine
  copper, chromium, and arsenic from current CCA wood
  treatment) did not appear to interfere with any of the three
  processes, at least not at the concentrations present in the
  soils (20^0 ppm each for arsenic, copper, and chromium in
  the high penta soil test) and the duration of the tests during
  the demonstration. If necessary, oil removal could be incor-
  porated into the soil washing sequence or into the  BATS
 The centrifuge used to separate the fine particle cake from
 water can also separate oil if present While there was some
 indication that metals were building up as the wastewater
 was recycled from BATS to soil washing, the short duration
 of this investigation did not make it possible to establish if
 an inhibitory effect might be observed in continuous opera-
 tion. Clearly, such problems are surmountable  as by  the
 incorporation of metal  precipitauon, but overall treatment
 cost would increase accordingly and additional hazardous
 wastes would have to be managed.

     Several of the polychlorinated dioxins and furans were
 found in the soil and in some of the output streams at widely
 varying but low concentrations.  Of these, the octachloro
 dioxm was the major isomer and the cnucal isomer 2378-
 TCDD. was not detected. While concern over these po'llut-
 ants as byproducts from the manufacture of penia has  to
 date, delayed disposal of the wastes from the demonstration
 their presence is not expected to affect large scale remediation
once safe disposal levels are established and approved dis-
posal routes are designated

-------

-------
PHYTOREMEDIATION CAN
BE  DESIGNED FOR MGP
    SITE CONTAMINANTS
            i<™  ,.  •  j
                       for specialized sites
                       Evei7 MGP site presents a unique combination of

           f     .
           Of CUirent
remediation methods







 Combustion rernedH may require landfilling of soUds
containing hazardous compounds that are not
converted. Recycling involves strict requirements on
MGP residuals during transport to recycling facilities
and on resulting commercial products. Und disposal is
                       PhytoWorks and head of the genetics department at the
                       University of Georgia, has genetically-engineered several
                       common plant species with patented genes to remove








                           ' * "** •*** "*"* ^^

Georael- BOV»n«n *», n - ^- , - ' -


(www.phytoworks.eom)            "

1 6 June 1998 Soil & Groundwoter Cleanup
                      «,,  ,  .   . '
                      tnephyW SOlUtWH
                       Phytoremediation solutions can replace or






                      costs and eliminate exposure pathways associated with
                      excavation. Phytoremediation can also complement hot


                      cosi eirecnve.
                      Phytoremediation also stabilizes MGP sites by

-------
preventing surface erosion and, depending on site
requirements and system design, controlling
subsurface contaminant migration.
 Phvtoremediation technologies are permanent
treatments in that destroy organic contaminants and
recover heavy metals. Upfront capital costs for phyto
are minimal because there is no new equipment to be
purchased and installed. Implementation is
inexpensive as it uses basic agricultural techniques.
Operating costs are significantly reduced by plants'
unique ability to harness the sun's free energy and
their negligible O&M requirements.l
                   Write in 720
Commentary, from page 4

remediated to date. It is believed that this level of
progress is indicative of the complex nature of the site,
the difficulty associated with fully characterizing the
nature and extent of site contamination, and the lack of
remedial technologies that can cost-effectively return
the sites to pristine, background environmental
conditions.
 To date, very few MGP sites have been identified as
posing imminent risks to the environment or public
health. Instead, the remediation of these sites has been
driven primarily by non-environmental factors such as
the redevelopment and sale of urban or brownfield
properties. These situations have afforded the utility
industry the time to prudently manage these sites given
changing regulatory conditions, the need to seek cost
recovery from other involved parties, and the desire to
identify and use innovative technologies to permit cost-
effective remediation of the sites.

Regulatory developments
 .MGP sites, for the most part, have not been managed
under federal environmental regulations. As of 1996,
only nine of the 1500 to 2000 MGP sites had been
placed on the National Priority List (N'PL) of the
L'SEPA and designated for management under
CERCLA. These figures support the fact that observed
releases and imminent environmental risks are not
typically present at MGP sites. At the same time, the
Resource Conservation and Recovery Act (RCRA) of
the USEPA did not substantially affect MGP sites
during the initial years of investigation. This was a
result of the Bevill Amendment that excluded MGP site
hydrocarbons from the definition of solid waste and,
hence, from potential classification as a hazardous
waste.
 This exclusion was eliminated around the end of 1989,
leaving MGP sites subject to selected requirements of
RCRA. The most recent RCRA treatment requirements
that are applicable to MGP site residuals are the Phase
                           Continues on page 18 -»
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                                                        Soil & Groundwater Cleanup June 1998 17

-------
 Commentary, from page 17

 IV Land Disposal Restrictions 
-------
effective treatment strategy, especially when the source
of the groundwater contamination could not be entirely
removed.
 The observations were being made by such
organizations as the NRC as well as USEPA. In fact, the
USEPA issued technical guidance in September 1993 for
evaluating the technical impracticability of
groundwater remediation in the presence of heavy
hydrocarbons in the subsurface.
 At the same time, the examination of organic-
contaminated groundwater plumes at field sites
revealed that there are instances where the actions of
the natural environment resulted in the removal of
organic contaminants from groundwater, providing
that  the rate of release of the contaminants from the
source was sufficiently reduced as a result of the partial
removal, treatment, or natural aging of the source in the
environment. The occurrence of natural attenuation of
contaminated groundwater at MGP sites has been
documented at a site in New York and is being
investigated at several sites in Georgia.
 These developments are indicative of the types of
technological innovations that have evolved since the
presence of MGP sites was first recognized. Their
evolution has provided MGP site managers with
remedial options that were not available to them 10
years ago and that now allow for more cost-effective
site management.

Evolution of the risk-based paradigm

for MGP site management
 Over the last several years, it has become increasingly
evident that there are not enough technical and financial
resources in the United States to remediate all
contaminated sites to background concentrations or
pristine conditions. The alternative is to focus the
resources on the conditions that represent the greatest
risk to human health and the environment. This
approach is known as the risk-based approach to site
management and is based upon the classic risk
paradigm that states that the risk associated with a site
is a  product of the toxicity of the contaminants that are
present and the exposure of receptors to these
contaminants. As such, the management of the risk can
be achieved by reducing either the toxicity or the
exposure, or both.
  Viewed from this perspective, many MGP sites do not
 require extensive, and in some cases any, remedial
 action. This is not because there is no contamination
 present on the site; rather, it is because there is limited or
 no exposure of the contaminants to ecological or human
 receptors. For example, at many MGP sites, the
 contaminants have not moved offsite even though they
 have been present onsite for tens of years. This
 observation is attributed to the nature of MGP site
 contaminants, their location on the sites, and their
 interactions with the soil and groundwater environment.
 Most of the more concentrated hydrocarbon
contamination is located in the subsurface environment
where it is not accessible to ecological or human
receptors and where it has become sequestered or
bound to the soil, making only a portion of it available
to the groundwater. The more mobile hydrocarbon
contaminants may also have limited or no
environmental impacts since these compounds can
undergo natural attenuation in the surrounding
environment following their release from the source
material. As for the inorganic compounds, cyanide has
demonstrated some mobility in groundwater; however,
it exists as complex metal cyanides that are not toxic to
human or ecological receptors.
 Recognizing these aspects of MGP site contamination,
it is understood that it is not necessary to achieve
complete removal of the source to fully remediate the
site. Rather, it is necessary to ensure that the risk at a
site is managed using a combination of techniques that
involve limited source removal and exposure
management. For example, DNAPLs that have
migrated to depth and sit on a geological confining
layer may not be an issue since direct contact with
human and ecological receptors is unlikely and
contaminant release to groundwater may be sufficiently
slow to be controlled by natural chemical and biological
processes.
 Similarly, the offsite movement of cyanide in MGP site
groundwater may also not be an issue since the
chemical species of cyanide that are present at MGP
sites are dominated by the non-toxic, complexed metal
cyanides.


What lies ahead?
  Moving ahead with the risk-based management of
MGP sites, it is envisioned that evaluations should not
focus on the total concentration of soil-bound
contaminants but in those fractions that are available
and toxic to the receptors of concern. Of particular
interest will be:
  •  Identification of complete exposure pathways for the
receptors of concern;
  •  An assessment of the fraction of the contaminants
that are available for uptake by the receptors and the
form and toxicity of the available contaminants;
  •  The effect of treatment of the available fraction of the
soil-bound contaminants, and;
  •  The effects of natural processes on the offsite
movement of the available, onsite contaminants.
  To apply this approach requires methods to measure
 the available fraction of soil-bound contaminants to
groundwater, ecological receptors, and human
 receptors. Some of these methods currently exist; others
are just now being developed. As these methods are
 applied to MGP sites, it is believed that cost-effective
 remediation can be accomplished while still being
 protective of human health and environment.l

         Soil & Groundwater Cleanup June 1998 19

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Copyright 1999, Remedial Technologies Network, L L C., All Rights Reserved.

Charbon Consultants

HCZyme

Abstract

HCZyme is a commercially available aqueous biostimulation agent composed of bacterial growth enhancing
agents, extracellular enzymes and surfactants. HCZyme is designed to enhance the in situ bioremediation of
numerous petroleum-based contaminants in soil and water by stimulating indigenous microbes to degrade them.
Specifically, HCZyme produces the following results:

- Increases the number of petroleum-degrading microbes,

- Provides extracellular enzymes that initiate the breakdown of petroleum hydrocarbons, enhancing
bioremediation,

- Maintains the microbial population so even low concentrations of

contaminant can be treated, and

- Contains surfactants to desorb petroleum from soil panicles and to assist in moving petroleum and nutrients
through die soil more easily.

HCZyme has been demonstrated in bench-scale tests and at field remediations to be effective on benzene,
toluene, ethylene, and xylene (BTEX), PAH, trichloroethylene (TCE), dichloroethylene (DCE), mineral spirits,
fuel oils, motor oils, and hydraulic fluids. The ve ndor claims that HCZyme has been tested and used on over two
million tons of petroleum contaminated soils, and is effective in breaking down petroleum hydrocarbons,
polychlorinated biphenyls (PCBs), WeOsott, sludges, waste oils, free product, tank bottoms, and other chlorinated
compounds (D18208L, p. 15).     ' •  -    	

The major limitations of this technology are those factors that affect bacterial growth, including temperature, pH,
and presence of other contaminants detrimental to bacteria life. Other factors that may affect speed and
completion of contaminant breakdown include moisture level, soil properties and microbe mobility.

-------
Copyright 1999, Remedial Technologies Network, L L C., All Rights Reserved.

Charbon Consultants

HCZyme

Technology Description


Introduction . History and Current Development. Process Description . Government Involvement. Performance.
Limitations. Capacity . Material Handling . Waste Streams . Operator Requirements . Utilities .
Set-Up/Tear-Down . Reliability/Maintainability . Public Acceptance . Information Sources

1. Introduction

HCZyme is a commercially available aqueous biostimulation agent composed of bacterial growth enhancing
agents, extracellular enzymes and surfactants. HCZyme is designed to enhance the in situ bioremediation of
numerous petroleum-based contaminants in soil and water by stimulating indigenous microbes to degrade them.
Specifically, HCZyme produces the following results:

• Increases the number of petroleum-degrading microbes,

- Provides extracellular enzymes that initiate the breakdown of petroleum hydrocarbons, enhancing
bioremediation.

- Maintains the microbial population so even low concentrations of

contaminant can be treated, and

- Contains surfactants to desorb petroleum from soil particles and to assist in moving petroleum and nutrients
through the soil more easily (Dl 15355, pg. 410; D15846X, pp. 4).

2. History and Stage of Development

HCZyme is a proprietary product developed by International Enzymes and marketed by Ecology Technologies,
Inc. (ETI) under the trademarked name FyreZyme™. the manufacturing rights for the proprietary blend were
purchased in'-Qctober, 1996 by Charbon Consultants of Tustin, California. The technology is currently
commercially available from Charbon Consultants as HCZyme. The technology has been applied under field
conditions and in the laboratory since 1990. HCZyme has been used and tested under several different product
names, including Bactozyme and FyreZyme™ (Personal Communication: Bret Braden, Charbon Consultants,
April 1997; Dl 15355, pg. 410; D15846X, p. 8).

HCZyme has been toxicity tested and shown to be safe to humans, wildlife, and the environment in intended
field uses. A number of in situ field programs have been performed and are in progress to support HCZyme as a
natural bioremediation solution. Currently,  this technology is used in full-scale field demonstrations on
petroleum-contaminated soils and in ground water (ex situ and in situ). Full-scale field trials have reported rapid
reductions in petroleum contamination (Dl 15355, pg. 410; D15846X, p. 8).

3. Process Description

There are many factors affecting the speed and completion of the breakdown of petroleum hydrocarbons in soil
and water. The acceleration of the naturally occurring microorganic metabolic and enzyme production process is
accomplished by creating an optimal environment and food source. The various components necessary to this
process include: bacteria and bacterial mobility within the matrix; oxygen in sufficient quantity to support

-------
metabolism; moisture content control; temperature control; and pH control. Environmental factors must be
continually monitored throughout the treatment process to create the optimal breakdown proces.s (D15846X, p.
6).

While microbes are capable of utilizing petroleum hydrocarbons as an energy source, they generally prefer
simple sugars (glucose) for rapid growth and energy. Other growth factors required by some microbes include
amino acids, purines and pyrimidines. HCZyme works by providing these food sources for petroleum degrading
microbes. Once customary food supplies are exhausted, microbes capable of degrading petroleum are favored
and their numbers increase preferentially. Periodic application of HCZyme results in periods of microbial growth
which is followed by periods of petroleum consumption by the microbial population. However, periodic
application of HCZyme should  also be followed by monitoring of oxygen, water and microbial activity
(D15846X, p. 4).

HCZyme provides a mixture of extracellular enzymes capable of initiating and catalyzing the breakdown of a
wide variety of petroleum hydrocarbons leading to enhanced biodegradation. Certain extracellular enzymes
initiate the oxidation process for biodegradation of petroleum products. In the first step of such oxidation, these
enzymes break  off two-carbon units from saturated hydrocarbon chains (typical of most petroleum compounds).
The transformed petroleum molecule is then released from the enzyme, allowing the enzyme to react with
petroleum molecules. The two-carbon units  from the breakdown of petroleum molecules are transferred into the
microbe for its own metabolic use. The microbe then alters its own enzyme production to attack the contaminant
directly as a food source (D15846X, p. 4)

HCZyme contains organic surfactants to desorb petroleum from soil particles. This allows the hydrocarbons to
move more freely through the soil pores where less mobile microbes live. The surfactants break down
macroscopic clumps of petroleum into smaller units which-increase the surface area for biodegradation to take
place(D15846X,p.5).

To use HCZyme effectively, engineering studies must be performed in order to determine, the proper application
of HCZyme. Generally, however, HCZyme  is provided in a concentrated form. One gallon (3.79 liters) of the
concentrate is used to totally remediate approximately 8 cubic yards (6 cubic meters) of petroleum contaminated
soil. If contamination is deep, and if conditions are anaerobic, a combination of HCZyme, oxygenated water and
other sources of oxygen can be injected. A 6% solution of HCZyme (1 gallon or 3.79 liters, per 16 gallons or 61
liters of water),  is applied to the contaminated soil in weekly applications.  Between applications, the moisture
level of the remediation bed is maintained at 60%  to 80% field capacity (D15846X, pp. 6-7).

4. Involvement  with Government Programs/Regulatory Acceptance

HCZyme has been approved by the EPA for use in surface water, ground water, and soil remediation (D15805O
p. 34).

5. Performance

HCZyme has been demonstrated in bench-scale tests and at field remediations to be effective on
benzene-to!uene-«hyl-xylene (BTEX), PAH, trichloroethylene (TCE), dichloroethylene (DCE), mineral spirits,
fuel oils, motor oils, and hydraulic  fluids. Concentrations are reduced to below the regulatory levels (Dl 15355,
pg. 410-416). The vendor claims that HCZyme has been tested and used on over two million tons of petroleum
contaminated soils, and is effective in breaking down petroleum hydrocarbons, polychlorinated biphenyls
(PCBs), creosote, sludges, waste oils, free product, tank bottoms, and other chlorinated compounds (D18208L, p.
15).

Bench scale, full-scale, and pilot scale studies have been performed using the HCZyme technology to
bioremediate soil impacted by oil company flare pits, service station disposal pits, leaking underground storage
tanks, refineries, and chemical plants (Dl 15355, pg. 411 to 413; D123615). Vendor-supplied performance data
are summarized in Table 1.

-------
6. Limitations

The major limitations of this technology are those factors that affect bacterial growth, including temperature, pH,
and presence of other contaminants detrimental to bacteria life. Other factors that may affect speed and
completion of contaminant breakdown include moisture level, soil properties and microbe mobility (D123615,
Section II)

7. Feed Rate or Treatment Capacity

One gallon (3.79 liters) of the concentrate is used to totally remediate approximately 8 cubic yards (6 cubic
meters) of petroleum contaminated soil. If contamination is deep in the soil to be remediated and if conditions
are anaerobic, a combination of HCZyme oxygenated water and other sources of oxygen can be injected
(D15846X.pp.6-7).

8. Material Handling and Pretreatment

According to the vendor, the most time and cost effective method of treatment is to spread the contaminated
media on the surface (ex situ) in single layer 14-inch lifts, allowing treatment under ideal aerobic conditions.
When used in situ (where anaerobic conditions exist), injection wells, injection galleries or sparging systems
must be engineered to take into account unique site-specific conditions (D15846X, p. 7).

HCZyme was subjected to toxicity tests which found that HCZyme is harmless to humans, animals, marine life
and the environment. No special handling is required since HCZyme is non-hazardous and non-toxic to humans
(D123615;D15846X,p.8).

9. Process Waste Stream

No available information.

10. Operator Requirements

No available information.

11. Utility Requirements

No information available.

12. Set-UpATear-Down Requirements

No available information.

13. Technology Reliability/Maintainability

No available information.

14. Public Acceptance

No information available.

15. Information Sources

D123615, Ecology Technologies, Inc., Date Unknown

D115355, Meaders, 1994

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   D15846X, Charbon Consultants, Date Unknown



   D15805O, Braden & Ryckman, 1997




   D18209M. Braden & Ryckman. 1997



   D18210F, Remtech Engineers, 1997




  D18208L, Pollution Engineering, 1997
Table 1. Summary of HCZyme Vendor-Supplied Quantitative Performance Data
Site and Soil Volume
Bench scale (gasoline
in soil), 1 yd 3
Oil company flare
pit, 1 yd3
Closed service
station, 30 yd3
Leaking underground
storage tank, 400 yd 3
Chemical company
blending site - two
piles totaling 6,500
yd3
Days
21
21
14
21


14
Contaminant
TPH
benzene
ethylbenzene
total xylenes
TPH
various PAHs
TPH
TPH
TPH
perchloroethylene
dichloroethylene
Initial
Concentration
72,000 ppm
2,000,000 ppb
1 5,000 ppb
1 10,000 ppb
60,000 ppm
620 to 15,000
ppb
700 ppm
approximately
340 ppm
approximately
1225 ppm
approximately
200 ppb
approximately
110 ppb
Final
Concentration
56 ppm
10 ppb
10 ppb
10 ppb
400 ppm
nondetectable
<10 ppm
approximately 10
ppm
nondetectable
nondetectable
nondetectable
Adapted from D123615



yd3 = cubic yard




ppm as parts per million



ppb = parts per billion

-------
TPH = total petroleum hydrocarbons




PAHs = po.lycyclic aromatic hydrocarbons

-------
Copyright 1999, Remedial Technologies Network, L L. C.. All Rights Reserved.

Charbon Consultants

HCZyme

Technology Cost

One gallon of the HCZyme concentrate will clean about eight cubic yards of contaminated media, and cost $55
in 1997, or approximately $7 per cubic yard. This estimate does not include engineering and other associated
costs such as excavation, permits and treatment of residuals. According to the vendor, chemical costs are
approximately $7 per cubic yard, and total treatment costs range from approximately $15 to $50 per cubic yard
(D15846X, pp. 6,9; D1821IG, p. 1).

Information Sources

D15846X, Charbon Consultants, Date Unknown

D18211G, Remtech Engineers, 1997

-------
Copyright 1999, Remedial Technologies Network, L L C., All Rights Reserved.

Charbon Consultants

HCZyme

Case Study Overview

Bench scale, full-scale, and pilot scale studies have been performed using HCZyme (formerly FyreZyme ™ - see
Section 2 of Technology Description) to remediate soil impacted by oil company flare pits, service station
disposal pits, leaking underground storage tanks, refineries, and chemical plants. This technology has also been
used to increase oil production by reducing paraffin build-up in oil wells (D18210F, p. 3).

Pilot-Scale: Petroleum Hydrocarbons

In a pilot-scale study, TPH levels were evaluated in barrels of sludge, soil, and water mix from a refinery site.
One 200-liter barrel was opened and an amount of FyreZyme ™ solution equal to 4% by volume of the barrel
contents was applied. Then the barrel was recapped. An untreated, opened, then closed barrel was used as the
control. After 60 days, TPH levels were measured in the treated barrel, Levels were reduced from 250,000
milligrams per kilogram to 3,500 milligrams per kilogram. In addition percent solids were reduced from 65
percent in the control barrel to about 15 percent in the treated barrel (Dl 15355, pg. 414).

Full-Scale: Petroleum Hydrocarbons

One full-scale study conducted at a closed service station involved a disposal pit containing motor oil, hydraulic
fluids, and brake fluid. A FyreZyme™ solution was applied on days 1 and 7. By the end of the 14th day, TPH
dropped from 700 milligrams per kilogram to less than 10 milligrams per kilogram. A second full-scale study
involved the excavation of a leaking underground storage tank. About 400 cubic yards (360 cubic meters) of soil
were placed in lined berms 14 inches deep. FyreZyme ™ solution was applied on days 1, 14, and 21. The bottom
of the pit was used as the control. The levels of TPH, benzene, and xylene remained essentially the same in the
control area, while levels in the treated area were below regulatory limits after 21 days (Dl 15355, pp. 412,413).

Full-Scale: Diesel Fuel

An estimated 227,000 liters of diesel fuel migrated through the soil and entered the ground water system through
sinkholes following a pipeline break. Remtech Engineers of Marietta, Georgia was engaged to remediate
approximately one-half hectare of sandy clay loam saturated with fuel from 1 to 2.5 meters in depth. Several
technologies were evaluated, and HCZyme was selected as the most cost-effective alternative. A multi-layered
horizontal aeration injection/extraction manifold was placed in the soil with an integrated water/enzyme
application system to treat the soil  in situ. The site was then covered with black plastic. Heated injection air was
obtained from the heat of compression from regenerative blowers alternating between positive and negative
pressure modes (D15805O, pp. 35-36).

The preliminary site design calls for using the soil treatment system as an infiltration gallery for enzymes and
water to treat vadose zone soils and attack trapped free product Air and enzyme injection through an existing
free product monitoring well network will accelerate bioremediation of the saturated zone. A three week pilot
test was conducted on soil and ground water samples extracted from the site. After one week of treatment,
heterotrophic populations in the soil increased fro 1,500,000 to 150,000,000 colony-forming units (CPU) per
gram. Initial TPH concentrations in the soil dropped from  1,543 ppm to 562 ppm after two weeks, and to 280
ppm after three weeks of treatment. In the saturated zone, free product thickness was reduced from 72
millimeters (mm) to 9 mm after two weeks. Initial true product TPH concentrations were reduced from
1,028,000 ppm to 205,200 ppm after two weeks, to 40,600 ppm after three weeks of treatment (D15805O, p.
36).

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Pilot-Scale: Oilfield and Tar Seeps

From mid-1997 through mid-1998, HCZyme was used in a five-acre pilot test as a bioremediation accellerant.
Heavy crudes, tar seeps, oil wastes, and oilfield production wastes were degraded from over 70,000 ppm - C  28*
to below 500 ppm in nine weeks. Lighter petroleum hydrocarbons (shorter chain, 
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      WORKSHOP ON PHYTOREMEDIATION OF ORGANIC

                                 CONTAMINANTS

                                    Ramada Plaza Hotel
                                     Fort Worth, Texas
                                    December 18-19, 1996

 WEDNESDAY. December 18. 1996

 WELCOME AND BACKGROUND

 Walter Kovalick, Jr., Director of the U.S. EPA's Technology Innovation Office (TIO), welcomed the
 participants and thanked them for attending. He explained that the goal of the meeting was to share
 information on current phytoremediation projects in the field and laboratory and to gauge attendees'
 interest in further joint activities in the future. Kovalick said that the first scheduled speaker, Jirn
 Matthews, Deputy Assistant Administrator for OSWER, had become ill and would not be able to
 attend. Kovalick assured the participants that EPA is dedicated to public-private partnering, which he
 described as a viable option for structuring future joint activities.

 Kovalick noted that TIO monitors the use of innovative technologies at  Superfund sites, and presented
 preliminary data summarizing the types of source control technologies selected for Superfund remedial
 actions through FY95. Established technologies, such as incineration and solidification/stabilization
 have been selected for 390 (57 percent) remedial actions. Innovative technologies have been selected
 for 300 (43 percent) remedial actions. Selected innovative technologies include soil vapor extraction,
 thermal desorption, ex situ bioremediation,  in situ bioremediation, in situ flushing, soil washing,
 solvent extraction,  and dechlorination. The most commonly selected innovative technologies were soil
 vapor extraction (selected 20 percent of the time), thermal desorption (selected seven percent of the
 time) and ex situ bioremediation (selected six percent of the time).

 Kovalick also presented data summarizing the types of technologies selected for groundwater
 remediation through FY95. Pump-and-treat remedies were selected for 562 (93 percent) remedies.
 Pump-and-treat combined with an in situ treatment technology (for example, air sparging,
 bioremediation, and passive treatment walls) were selected for 32 (five percent) remedies. In situ
 treatment technologies without pump- and-treat were selected for only nine remedies.

 Kovalick announced a soon-to-be released publication from TIO entitled Recent Developments for In
 Situ Treatment of Metal Contaminated Soils. The publication will describe the use of electrokinetics,
 phytoremediation, soil flushing, and solidification/stabilization for remediating metals in soils. Kovalick
 invited participants to take copies of the TIO publications at the back of the room and to view
 demonstrations of TIO's Clean-Up Information (CLU-IN) World Wide Web site (http://clu-in.org),
 the Vendor Information System for Innovative Treatment Technologies (VISITT), and the Vendor
 Field Analytical and Characterization Technologies System (VendorFACTS).

 Kovalick provided a brief history of the Remediation Technology Development Forum (RTDF). In
 1992, Fortune 500 problem-site owners expressed an interest to EPA's Administrator in working with
EPA and other federal agencies to identify solutions to complex remediation problems. Under the
RTDF, groups with common interests and needs form "Action Teams." The mechanisms of the Action

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 Teams are custom tailored to the members' needs with the objective of identifying mutual needs in
 order to reach a common goal as quickly as possible. Action Teams have been formed to address
 organics and metals contamination in soils and groundwater. Operating RTDF Action Teams include
 the LasagnaTM Consortium (dealing with a new in situ soils remediation process), Bioremediation of
 Chlorinated Solvents Consortium, Permeable Barriers Action Team, In-Place Inactivation and Natural
 Ecological Restoration (IINERT) Soil-Metals

 Action Team, and Sediments Remediation Action Team. Kovalick emphasized that EPA's role in these
 Action Teams is simply to empower others to work together.

 Kovalick expressed his hope that the conference would result in agreements among participants for
 working together—as an RTDF Action Team or in another form—in addition to exchanging
 information on phytoremediation research, development, and demonstrations.

 CONFERENCE OBJECTIVES

 Phil Sayre (EPA Technology Innovative Office) thanked participants for  attending and noted that
 there was a good turnout for the previous day's site visit to a Carswell Air Force Base
 phytoremediation project. Sayre said the first day of the meeting would be dedicated to getting
 participants caught up on others' work and the state-of-the-art in phytoremediation through
 presentations by participants. The second day, he explained,  would be dedicated to working in groups
 to try to answer questions about how to advance the use of phytoremediation: 1) what are the key
 questions that need to be answered before phytoremediation can be used  broadly; 2) how should these
 questions be attacked, for example, through research or regulatory changes; 3) who are the parties
 that can best answer the questions; and 4) what are the best mechanisms for communication between
 users and developers of phytoremediation technologies (for example, RTDF Action Teams, annual
 meetings, teleconferences, WWW sites, or validation of field testing). Sayre said that a summary of the
 conference, including a list of attendees' addresses, phone numbers, and e-mail addresses, will be
 distributed  to participants.

 REMEDIATION TECHNOLOGY DEVELOPMENT FORUM

 Bill Berti (DuPont) described the history and operation of the Remediation Technology Development
 Forum. Berti noted that he co-chairs the IINERT Soil-Metals Action Team along with Jim Ryan from
 EPA's Cincinnati laboratory. The RTDF began in 1992 with a discussion between Monsanto and EPA
 on how to foster collaboration between government and industry, discuss common problems, and
 develop innovative solutions to difficult contamination problems. The RTDF was created to advance
 the development of more permanent, cost-effective technologies for the remediation of hazardous
wastes. Berti noted that RTDF members are free to form any type of alliance that brings members
together to work on priority issues. Formal consortia can be formed where there is a need to protect
proprietary information, workgroups can be formed to coordinate scientific programs and gain public
acceptance for new technologies, and information sharing activities can be formed to periodically
exchange information when interest is high.

Berti said that there are a number of advantages for businesses involved with the RTDF.  The
government shares costs, technologies, and expertise, and cooperates on addressing site-specific
problems. Industry manages the projects, thereby providing "sweat equity." The RTDF can help shape
national policy and develop better technologies through leveraging of national resources. EPA can
help other government agencies, such as the Department of Energy, network with businesses.

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  An important lesson learned for RTDF participants is that there needs to be a sponsor—someone who
  has the problems to drive the program. There also needs to be substantial resources available.
  Technical and legal discussions should be conducted on parallel paths. It is a large leap from
  agreement in principle to final contractual language—no agreement is perfectly complete or
  protective. Working on public acceptance of new technologies is vital. If the right ingredients are in
  place, exceptional achievements are possible.

  Berti then briefly described the IINERT technologies, which are intended to eliminate the hazards of
  metals in soils. IINERT technologies chemically and physically inactivate metals in soils by
  incorporating chemicals (phosphates, mineral fertilizers, limestone, and other materials) that change
  the molecular species of metals, thereby reducing their solubility and bioavailability.  These changes
  may increase the fertility of soils, making plant cover an attractive option for stabilizing the soil.
  Before DuPont was willing to move forward with development of this technology, the company
  wanted  to see a comparison of costs for various treatment technologies. Treating a 10-acre site with
  off-site  solidification/stabilization would cost $12 million, treating with soil washing would cost $6
  million,  an asphalt cap would cost $650,000, a soil cap would cost $600,000, and  IINERT would cost
  3)250,000.

 In response to  a question about the role of the sponsor, Berti said a sponsor is needed to plan ahead
 and move the process along. Kovalick noted that Cooperative Research and Development Agreements
 (CRADAs) can be signed to allow federal laboratories to provide facilities and support. With
 government involvement in joint partnerships, businesses also avoid potential anti-trust issues from
 their joint meetings.

 PHYTOREMEDIATION  OF ORGANIC COMPOUNDS: MECHANISMS OF ACTION AND
 TARGET CONTAMINANTS

 Steve  Rock (EPA National Risk Management Research Laboratory in Cincinnati, Ohio) said that most
 of the people working on phytoremediation are present at the conference. Phytoremediation is defined
 as a set of processes that use plants to clean contamination in soil, groundwater, surface water,
 sediment, and air. The goals of phytoremediation research are to answer questions about the
 technology's ability to lower contaminant concentrations and its mechanisms of action. The questions
 to be addressed differ depending on the specific media and contaminants.

 Mechanisms of phytoremediation include enhanced rhizosphere biodegradation, phytoextraction,
 phytodegradation, and volatilization. Enhanced rhizosphere biodegradation takes place in the soil
 surrounding plant roots. Natural substances released by plant roots supply nutrients to
 microorganisms, which enhances their ability to biodegrade hazardous materials. Plant roots also
 loosen the soil and then die,  leaving paths for transport of water and aeration. This  process tends to
 pull water to the surface zone and dry the lower saturated zones.

 Phytoextraction is the uptake of contaminants by plant roots and the translocation of contaminants
 into plant shoots and leaves.  Where contaminants are stored in plant shoots and leaves, the plants can
 be harvested and disposed of. Some plant species have demonstrated the ability to store metals in
 roots. Although roots generally cannot be harvested in a natural environment, a process called
 rhizofiltration can be used where plants are raised in greenhouses and transplanted to  sites to filter
metals  from wastewaters. As the roots become saturated with metal contaminants, they then can be
harvested and disposed of. Plants also have been  used to concentrate radionuclides in the Ukraine and

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 Ashtabula, Ohio.

 Phytodegradation is the metabolism of contaminants within plant tissues. Plants produce enzymes,
 such as dehalogenase and oxygenase, that help catalyze degradation.

 Physical effects include volatilization, which occurs as plants take up water containing organic
 contaminants and release the contaminants into the air through plant leaves. Researchers are not sure
 how much contamination is being transpired into the air. Data on transpiration is still at a preliminary
 stage. The Cincinnati laboratory is building chambers to monitor the amount of organic contaminants
 released into the air. Another physical effect of phytoremediation is the hydraulic control of
 contaminated plumes that can be exerted by trees. Poplars, cottonwoods, and willows, can use up to
 200 gallons of water per day  and prevent  contaminated plumes from flowing past tree roots.

 Phytoremediation can be used as a polishing step after the removal of contaminant hot spots for
 widespread, shallow to medium-depth contamination. The advantages of phytoremediation are: I) it is
 in situ, 2) passive, and solar driven; 3) costs only 10 to 20 percent of mechanical treatments; 4) is
 faster than natural attenuation; and 5) has high public acceptance. Phytoremediation has been selected
 as part of the remediation process at at least one Superfund site and several private sites; however,
 most of the field work using phytoremediation is at the testing and demonstration stage. The EPA
 Cincinnati  laboratory currently is compiling information on phytoremediation and intends to provide
 guidance in five years on how to use the technology.

 In response to a question on whether transpiration of organic contaminants has been documented,
 Jerry Schnoor (University of Iowa) said that transpiration has been documented in the laboratory, but
 no one is sure to what degree this happens in the field.

 PHYTOREMEDIATION OF ORGANIC COMPOUNDS: VALIDATION APPROACHES
 FOR FIELD TESTING AND RESEARCH NEEDS

 Steve McCutcheon (National  Exposure Research Laboratory in Athens, Georgia) presented an
 overview of the benefits and limitations of phytoremediation and described research and research gaps
 related to phytodegradation. McCutcheon described seven areas where phytoremediation is being
 investigated for environmental management: 1) phytoaccumulation of metals and organics; 2)
 rhizofiltration of metals and organics from streams and wastewaters; 3) phytodegradation of organics;
 4) phytovplatilization of selenium, mercury, and volatile organics;  5) control of leaching from landfills;
 6) microbial stimulation in the rhizosphere; and 7) removal of organics from the air.  Some of the
benefits of using plants are that they are aesthetically pleasing, control water balance, have highly
evolved enzyme  systems, can be self- sustaining in nutrients, can achieve complete breakdown of
hazardous materials, and are relatively inexpensive.

McCutcheon noted that there  are a number of limitations to phytoremediation:

      It is limited to shallow soils, streams, and groundwater.
      High concentrations of hazardous materials can be toxic to plants.
      It involves the same mass transfer limitations as other biotreatments.
      It is slower than other treatments, particularly in cold weather.
      It can transfer contamination across media.
      It is not effective for strongly sorted (e.g., PCBs) and weakly sorbed contaminants.
      The toxicity and bioavailability of biodegradation products is not always known.

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    • Products may be mobilized into groundwater or bioaccumulated in animals.
    • It is still on the frontier of science.
    • It is unfamiliar to regulators.

 McCutcheon said that EPA's Athens laboratory has developed monoclonal antibodies for at least one
 of the following three  plant enzymes involved in phytoremediation: nitroreductases, dehalogenases,.
 and nitrilase. These antibodies allow one to identify plants that produce these enzymes. Other research
 conducted by the laboratory includes investigating the pathways of compound degradation and
 comparing munitions degradation by vascular plants and microorganisms.  Plant enzymes can degrade
 explosives, solvents, nitriles, pesticides, and phenols. Plant enzymes useful for engineering applications
 include nitroreductases for munitions remediation, dehalogenases for degradation of chlorinated
 compounds, nitrilase for herbicide treatments, phosphatases (which have not yet been isolated) for
 treatment of organophosphates, lactase for the oxidative step in munitions degradation, and
 peroxidase for the destruction of phenols. The Athens laboratory also has worked with the Army on
 field demonstrations of phytoremediation of munitions at the Iowa Army Ammunition Plant,
 Volunteer Army Ammunition  Plant, and Milan Army Ammunition Plant.

 In summary, McCutcheon said that using natural plant processes for phytoremediation is effective for
 some compounds. However, rigorous science and engineering are required to demonstrate the
 effectiveness of phytoremediation at particular sites. Mass balances and pathway  analysis are the keys
 to proving the applicability of phytoremediation. In addition, the toxicity and bioavailability of specific
 compounds must be defined.

 PANEL DISCUSSION ON THE USE OF PHYTOREMEDIATION TO CLEAN UP
 PETROLEUM HYDROCARBON SPILLS

 Phil Sayre, the moderator for the Panel Discussion on the Use of Phytoremediation to Clean Up
 Petroleum Hydrocarbon Spills, introduced the panelists: Dr. Evelyn Drake, Exxon;  Dr. Sheldon
 Nelson, Chevron; and Dr. Alonzo Lawrence, Gas Research Institute.

 Phytoremediation of Petroleum Hydrocarbons

 Evelyn Drake (Exxon) described her company's research on the bioremediation of aged hydrocarbons
 in surface soils. Bioremediation can be difficult because of complex soil matrices and the fact that
 hydrocarbon contaminants are partitioned into solid, water, and air phases of the soil. Despite this
 complexity, bioremediation works. Exxon is looking into the factors that effect the  rate and extent of
 remediation, including the specific compounds, soil type, moisture level, microorganisms, oxygen
 availability, nutrient type and amount, temperature, and soil pH. They have found that inoculating soils
with special microorganisms is more effective at degrading TPHs than stimulating naturally occurring
microorganisms with nutrients.

Exxon has conducted laboratory studies of PAH biodegradability in aged refinery soil. Researchers
have investigated the typical composition of aged refining hydrocarbons, and found that many of the
more toxic compounds were soluble enough to be affected by plants, while the total petroleum
hydrocarbon concentrations in soils may not be lowered beyond a certain point by phytoremediation.
The removal of PAHs is strongly affected by the amount of nutrients added, although nutrient levels
can be increased to the point of being toxic to microorganisms. More nutrients must be added in a
bioremediation application, such as landfarming, as compared to a phytoremediation application.

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  Exxon is a member of the Petroleum Environmental Research Forum (PERF), a consortium of 10
  companies that contributed $142,000 to conduct laboratory studies of phytoremediation of
  hydrocarbons. The laboratory study compared biodegradation of soils contaminated with aged crude
  oil and gas plant sludge using phytoremediation, surface tilling, and a control. This study is being
  completed, but the specific results cannot be disclosed at this point. In general, the addition of plants
  to a biodegradation system appears to increase degradation rates. Also, the cost of phytoremediation
  is about half that of microbial bioremediation.

  Phytoremediation is a promising technology because of its low cost, low impact, visual attractiveness,
  ability to reduce contaminant levels to same levels achieved by bioremediation and tilling, and
  opportunities for plant breeding and genetic engineering. The limitations of phytoremediation are that
  contamination must be shallow, the site must be a large enough to apply agronomic techniques, there
  must be sufficient remedial time, and its effectiveness is affected by contaminant variability, weather
  variability, animal and insect damage, and the presence of toxic  chemicals and salt. Drake emphasized
  that mechanisms of action need to be studied to differentiate between microbial and plant effects.

  In response to a question from Steve McCutcheon, Drake said that the PERF consortium is a group of
  petroleum companies that have been meeting regularly since 1990. Walt Kovalick noted that the
 consortium was created under provisions of a 1986 statute, which allows companies to conduct joint
 research projects and avoid potential anti-trust issues. He then noted that research results, such as
 those for phytoremediation projects, are not readily made available to the public. However, Amoco
 has created a PERF Home Page (http://perf.vs.com) that describes its environmental research projects.

 Use of Trees for Hydraulic Control of Groundwater Plumes

 Sheldon Nelson (Chevron) described a field research project in Ogden, Utah,  being conducted to study
 the ability of poplars to act as a hydraulic barrier to solute  transport in groundwater. Soils at the  site
 are of low permeability, and the weather is good for transpiration. Gasoline and diesel components are
 dissolved in the groundwater, which is eight feet below the surface. Three rows of poplars were
 planted six feet apart and perpendicular to the groundwater flow. A lot of effort was exerted to make
 sure the tree roots reached the groundwater. Monitoring wells were installed upgradient, within,  and
 downgradtent of the trees.

 Even though the trees were very young, having been planted in 1995 and 1996, it appeared that the
 trees were lowering the water level by V/2 to 2 inches. Using simple geohydrological calculations and
 treating the trees like low-flow pumping wells, Nelson calculated that the trees were using 13 gallons
 of water per day per tree. He then calculated the pumping rate required to achieve hydraulic control of
 the groundwater at the site, and estimated a pumping rate of 25-30 gallons of water per day per tree.
 The conclusion is that it would theoretically be possible to  use trees to contain groundwater at the
 Ogden site. Ari Feiro (Phytokinetics) said that a summer uptake  rate of 40 gallons per day has been
 calculated for a five-year-old poplar.

 Gas Research Institute Projects

 Alonzo  Lawrence (Gas Research Institute, Chicago) said that he was standing in for Tom Hayes,  who
 manages CRTs waste program. Lawrence said that there are 260,000 gas wells in the contiguous
 United States; 40,000 of which have produced water pits from glycol dehydrations. There also are 700
gas processing plants in the country. GRI is interested in remediation techniques for BTEX, alkanes,

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amines, glycols, and other chemicals used to treat natural gas. They are investigating bioventing, land
farming, and, more recently, phytoremediation. GRI will soon be starting an Environmentally
Acceptable Endpoints Project to study the mobility of petroleum hydrocarbons in soils. Another
project that soon will be starting is a Manufactured Gas Plant Remediation Project to investigate
remedial technologies for phenols, PAHs, and cyanides that could be present at the country's 1,500-
2,000 coal gasification plants. Lawrence noted that GRI also contributed money and helped manage
the PERF consortium's research project.

PANEL DISCUSSION ON THE USE OF PHYTOREMEDIATION TO CLEAN UP
PESTICIDES, WOOD PRESERVATIVES, CHLORINATED SOLVENTS, MUNITION
WASTE, AND MIXED WASTE

Bob Olexsey (EPA National Risk Management Research Laboratory in Cincinnati, Ohio), the
moderator for the Panel Discussion on the Use of Phytoremediation to Clean Up Pesticides, Wood
Preservatives, Chlorinated Solvents, Munition  Waste, and Mixed Waste, introduced the panelists:
Dick Woodward, Sierra Environmental Services, Inc.; John Fletcher, University of Oklahoma; Joan
Brackin, Monsanto; Tom Wong, Union Carbide Corporation; James Duffy, Occidental Chemical
Corporation; Tom White, Ciba-Geigy; Greg Harvey, Air Force; and Terry Mclntyre, Environment
Canada.

Passive Gradient Control

Dick Woodward (Sierra Environmental Services, Inc.) said that he was standing in for Dick Sloan
(Arco Chemical Co.). He discussed the use of plants to maintain passive gradient control for post-
closure at the French Limited Superfund site in Florida. Objectives of the project were to use non-
riparian phreatophytes to maintain an inward groiindwater gradient toward the center of a former
disposal lagoon area. Woodward explained that non-riparian phreatophytes are water loving plants
that frequently have deep roots to absorb water from the capillary fringe zone of the phreatic surface
(water table). This would avoid the migration of contaminants into surrounding aquifers and enhance
natural flushing and intrinsic bioremediation.

Conditions that impact phreatophytes at the French Limited site include high temperature and humidity
(which lower transpiration rates), brackish water, a water table 20-25 feet below the surface, and
DNAPLs. Underground utilities, wells, and compact back fill divert tree roots  and result in differential
growth. There is a significant volume of low-level contaminated groundwater with low migration rates
and low remediation rates. Run-off and run-on are controlled. Bioremediation  is the selected remedy
for the lagoon.

For the study, a number of phreatophytes were evaluated to identify species that would use 200-800
gallons of water per day and are suited to the conditions at the French Limited site. Alders, ash, aspen,
river birch, and poplar all grow fast but have a low salt tolerance. Cottonwoods and willows have
shallow roots. Mesquite and salt cedar tolerate salt but are difficult to control.  Bald cypress prefers^—
hot humid climates but its roots form knees. Eucalyptus grows very fast but has a low cold tolerance
and is disease prone. Greasewood prefers cold or dry climates. Woodward emphasized that   /
conducting a plant species evaluation early in a phytoremediation project is critical.           /
                                                                                    I
Phase 1 of the project included planting and watering bald cypress and river birch. Results wereipoor
primarily because of salt impacts. Therefore, a second phase was implemented the following year using -
a wider variety of plants. A specific planting cycle was instituted and a drip irrigation system was

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 installed to help establish the plants and encourage deeper root growth. Phase 2 efforts resulted in
 establishment of an inward gradient. Good control of the groundwater gradient was established during
 the growing season, but control was poor when the trees dropped their leaves.

 The advantages of using phytoremediation were that hydraulic control was established, channeling
 could be avoided, clay soils were loosened, costs are low, and it is synergistic with the site closure
 plan. Woodward noted that a plant breeding program is needed to develop specific species. Desired
 characteristics include frost hardiness, fast growth, deep feeder roots, upright growth habit, salt
 tolerance, chemical tolerance, disease and insect resistance, and an ability to grow on poor alkaline
 soils. In addition, the plants should be native to a particular area, evergreen for winter control, and
 available from local vendors.

 Walt Kovalick asked what would be done to maintain control after the growing season ends.
 Woodward said they are looking for broad leaf evergreens, such as water oak. Sheldon Nelson asked
 how the salt tolerance problem was addressed. Woodward replied that they initially used a deeper
 water source to get the plants established.

 Summary of Screening Studies

 John Fletcher (University of Oklahoma) summarized plant screening studies conducted by the
 University. The work was started with the perspective that there are bacteria that degrade PCBs using
 biphenyl as a cometabolite.  They looked for naturally occurring substances produced by plants that
 could replace biphenyl as the cometabolite. Some flavonoid, coumarin, and other compounds were
 discovered that could serve as a substrate. They then looked for plant species that synthesize these
 compounds in large enough amounts to help degrade PCS. Seventeen perennial plant species grown
 throughout the country were evaluated. The three most promising species were crabapple, osage
 orange, and mulberry. The compounds are released at the end of the growing season,  which is
 consistent with the time of death of some roots. Root death is an important factor because it provides
 channels in the soil and releases flavonoids, coumarins, and other compounds.

 Fletcher noted that most of these species can benefit from the sugars and ammo acids released by most
 plants. A single gram of soil contains 10,000 different bacterial species. The challenge is to develop
 plant species that release compounds that promote the PCB degraders over the other 10,000 bacterial
 species.

Fletcher said that computer imaging technology was developed to simulate root growth and death. In
nature, 1-5 percent of the soil is roots; 30 percent of these are fine roots. One percent of the total soil
volume is in contact with dying fine roots. If the rhizosphere is included, seven percent of the total soil
volume is affected. In order to affect the total soil volume using phytoremediation, you would need a
 15-20 year project. To study this process, a contaminated site with established vegetation could be
examined. The rate of phytoremediation could be increased by using an electromagnetic field to move
water containing contaminants back and forth through the same rhizosphere, and therefore expand the
zone of influence of the rhizosphere.

Overview of Lasagna Technology

Joan Brackin (Monsanto) said that Monsanto  is forming a new life science company that will look at
phytoremediation. Monsanto has potential field sites and will investigate the feasibility of coupling
phytoremediation with their LasagnaTM technology. The LasagnaTM process combines

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 electroosmosis with treatment zones that are installed directly in contaminated soils to form an
 integrated in sitv remedial process. Contaminants within pore waters are moved into the treatment
 zones with an electromagnetic field. The process can be used to move groundwater into plant root
 zones. By reversing polarity, groundwater can be moved back and forth through the root zone. In
 response to a question from Evelyn Drake, Brackin said that the range of water movement is about
 one centimeter per day. In response to another question, Brackin said that the process works best in
 saturated conditions, but water can be moved into the vadose zone to some extent.

 The Living Cap

 Tom Wong (Union Carbide Corporation) described a waste impoundment site that illustrates the
 concept of a "living cap,"  or use of plants to remediate a site and provide a closure pathway for the
 site. The one- acre facility includes four former impoundments, one of which (Basin 6) was drained of
 water 20 years ago exposing highly toxic sludge  with the consistency of axle grease that contained
 PAHs and other mixed waste. Basin 6 now supports a diverse plant community, including grasses,
 shrubs, and a 65-75 percent tree cover, including mulberry and hackberry.  Wong noted that mulberry
 is not a common plant in the area and that the closest mulberry tree is a half mile away from the site.
 In fact, he believes that plant to be the seed source for the mulberry trees growing  on the site. The
 oldest of the mulberry trees germinated 18 years  ago, only two  years after the impoundment was
 drained. Wong noted that  mulberries release flavonoids and coumarins that support PAH degrading
 bacteria.

 A portion of Basin 6 was excavated to a depth of 40 inches. The upper two to three feet of sludge in
 Basin 6 looks like top soil  and has no chemical odor. The vegetation has dewatered the upper zone
 and strengthened and stabilized the sludge to the  point that it could support a drill rig.  Roots
 penetrated to a depth of two to three feet. There  is a strong demarcation between the upper layers and
 the deeper sludge,  which was saturated with water. Analysis of samples down to three feet found  high
 concentrations of PAHs (with concentrations increasing with depth), according to the EPA Appendix
 9 procedures. However, TCLP analysis showed nondetectable levels of PAHs in the same soils. Gas
 chromatography showed a very low number of PAH peaks at shallow soil depths.

 Advantages of the living cap concept are: sludge  can be converted to soil; evapotranspiration
 minimizes water infiltration through sludge; vegetation minimizes exposure to contaminants; the plants
 are aesthetically pleasing and self sustaining; and the toxicity and mobility of contaminants are
 reduced. A living cap does as well  or better than a clay cap in preventing infiltration of rainwater.  In
 addition, run-off from a living cap does not have to be treated as you would have to with a clay cap
 The cost of a living cap is often less than a conventional cap.

 In response to a question from Evelyn Drake, Tom Wong said that nothing was planted at the site and
 no nutrients were added. In response to other questions, Wong said that they have not  analyzed
 samples from the deeper sludge and the plants have not been analyzed to determine contaminant
concentrations. Evelyn Drake said that Exxon has a similar site in New Jersey, where golden rod and
phragmites are growing into a contaminated area  from the edges. The plants have lowered
contaminant concentrations at the edges by a factor of five to ten. Jerry Schnoor said that vegetation
caps have been approved by RCRA in lieu of a RCRA cap because studies have shown that seepage
through the vegetation is less than through a conventional cap. He noted one capped 13-acre site as an
example.

Field Experiment Using Poplar Trees to Treat  Trichloroethylene

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 James Duffy (Occidental Chemical Corporation) described a field experiment to investigate
 remediation of TCE contaminated groundwater by poplars. Phytoremediation is being considered
 primarily for non-active sites where the time for remediation is not critical. Early laboratory
 experimentation showed that poplars will take up TCE and can tolerate reasonable levels of the
 contaminant. Occidental received permission by the State of Washington to conduct field experiments
 using introduced TCE.

 A two-year controlled field experiment to evaluate the uptake, metabolism, and transfer of TCE from
 groundwater by hybrid poplars was completed in November, 1996. Four meter by six meter cells were
 constructed to a depth of 1 !/2 meters and lined with a double wall polyethylene liner. Sand and gravel
 were placed in the bottom of the cells, which were then filled with soils native to the site. Water was
 injected into the cells at a rate to maintain a residence time of one week. Once established, the plants
 were exposed to 15 ppm concentrations of TCE and extracted water was analyzed. Data from the
 second year shows that 65-70 percent of the introduced TCE was recovered from  control cells that
 did not contain trees but very little TCE was recovered from the cells with trees. Bag and FTIR
 measurements  of air samples found negligible transpiration of TCE in the second year of growth.
 Continuing activities include analyzing the trees, determining the fate of the TCE, and verifying
 laboratory experiments. Analysis of data from the field experiment will be completed in three to five
 months.

 Steve McCutcheon noted that a laboratory mass balance study showed high transpiration of TCE by
 poplars. Duffy  said that the field experiment could have been designed better to determine mass
 balances. In response to a question about evidence of chloroform and vinyl chloride production, Duffy
 said that small amounts of vinyl chloride were detected.

 Phytoremediation of Contaminated Sites

 Tom White (Ciba-Geigy) said that Ciba-Geigy may have an interest in applying phytoremediation to
 cleanup their sites; they are currently evaluating several candidate technologies for their utility. White
 then described three contaminated sites that could be candidates for phytoremediation. The first site,
 Tom's River, is contaminated with chlorinated and non-chlorinated solvents in the vadose and
 saturated zones. Specific contaminants include TCE, toluene, anthracene, and naphthalene. A pump-
 and-treat system is in place, with packed carbon treatment and discharge to surface waters. It is a
 CERCLA site with northern and southern groundwater plumes. Depth to groundwater is 10 feet. The
 subsurface is sandy with clay stringers that may contain perched groundwater and DNAPLs.
 Researchers are looking at 1-15 years of active in situ bioremediation, followed by semi-passive
 remediation, then intrinsic remediation.

The Macintosh, Alabama, site is located in a flood plain that is contaminated with pesticides, including
DDT. It is a 10-15 acre CERCLA site with surface contamination over a large area. Portions of the
site are forested with bald cypress, but there are other portions that are flooded in the winter with no
vegetation. Contaminant concentrations do not exceed 1,000 ppm, and the DDT is bioavailable.

Another site in Elkton, Maryland, is a RCRA site contaminated with pesticides. Pesticide formulation
at the site resulted in contamination of the top 18 inches of soils with DDT, toxaphene, and lindane at
levels of approximately 50 ppm. When the facility was in operation, the site was primarily clear fields.
It is now covered with trees and shrubs and seems to be an ideal site for phytoremediation.

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  Problems with using phytoremediation at these sites include bioavailability of residuals that are not
  leachable, the ultimate fate of residues, limitations on VOC releases, cleanup levels, and where the
  point of compliance takes place. If the point of compliance is the source area rather than discharge to
 ^surface water, phytoremediation probably will not be feasible. White said that there are numerous
 'opportunities for research, including bioavailability, semi-analytical models, and phytoremediation
  process development.

 Demonstration of Remediation of Shallow TCE using Coltonwood Trees

 Greg Harvey (U.S. Air Force) said that the Air Force is conducting a field study to demonstrate
 whether planted eastern cottonwood trees can help remediate shallow TCE-contaminated
 groundwater. Air Force Bases typically have an enormous extent of TCE contaminated groundwater
 plumes, and cottonwoods are found throughout the world. The best niche for phytoremediation is
 between bioventing and intrinsic bioremediation. The Air Force has established a Technical Advisory
 Committee to help direct phytoremediation demonstrations.

 A phytoremediation demonstration is being conducted at the Naval Air Station in Fort Worth, Texas,
 where there are good conditions for plant growth. The Base is underlain by a shallow, thin aerobic
 aquifer, with a depth to groundwater of 6-10 feet. Impermeable bedrock is beneath the aquifer. Rows
 of cottonwood trees have been planted perpendicular to groundwater flow to intercept a TCE plume
 Up- gradient controls and 20 monitoring wells up- and down-gradient have been installed. They are
 looking to see how fast the tree roots reach the water table. Phytoremediation could be cost effective
 if the roots grow fast. During a drought year, liberal irrigation was used to keep the trees alive. So far,
 the trees have grown very fast. The Air Force plans to analyze TCE, vinyl chloride, and haioacetic
 acids to see how concentrations change over time.

 John Fletcher asked whether existing trees would be monitored, and Harvey said that they will be
 looking at enzymes and other factors in existing trees. In response to a question about the rate of
 natural attenuation at the site, Harvey said they have found some biodegradation by bacteria.

 Canadian Experience with Phytoremediation

 Terry Mclntyre (Environment Canada) said that he is excited about the potential for phytoremediation
 as an innovative environmental solution for recalcitrant compounds, heavy metals, and radionuclides.
 The estimated cost for  toxic metal reduction in Canada is $6 billion, and in the United States is $35
 billion just for heavy metals. Environment Canada conducted a series of focus group meetings to
 gauge the awareness and support for phytoremediation by the public. Preliminary data show a public
 support rate of 82 percent. There probably is a similar level of support for phytoremediation in the
 United States—people  understand plants. Mclntyre cautioned  that the public must be kept informed as
 work on phytoremediation moves forward.

 The advantages of using trees for remediation are that they can create effective barriers, require low
 levels of maintenance, are inexpensive, and can be used at many sites simultaneously. Limitations of
 phytoremediation include a slower growth period, nutrient and water requirements, and a need for
 more research. Tree species being considered by Environment Canada include alder, hybrid poplar,
black locus, sweetgum,  loblolly pine, and juniper.

Environment Canada has developed a preliminary research strategy, and will convene a group of

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 scientists from Environment Canada, other government agencies, and the private sector in February.
 Five major areas of research have been identified, including mechanisms of uptake, transport, and
 accumulation; genetic evaluation of hyperaccumulators; rhizosphere interactions; field validation and
 evaluation; and clarification of regulatory oversight. Other research needs are determining how
 selective plants are and what to do with mixed wastes. There is a lot of enthusiasm in Canada's
 goverriment agencies and a lot of valuable information already is available.

 PANEL DISCUSSION ON SUCCESSES AND BARRIERS TO COMMERCIALIZING
 PHYTOREMEDIATION

 Steve Rock, the moderator for the Panel Discussion on Successes and Barriers to Commercializing
 Phytoremediation, introduced the panelists: Dr. Jerald Schnoor, University of Iowa; Dr. Kathy Banks,
 Kansas State University; Dr. Ari Ferro, Phytokinetics; and Dr. Paul Thomas, Thomas Consultants.

 Research at the  University of Iowa/Limitations to Phytoremediation

 Jerry Schnoor (University of Iowa) began his presentation by posing questions that regulators ask
 most often before allowing phytoremediation to be used at a site:

    • What are the ultimate end-products?
    • Are the chemicals volatilized?
    • Have we created a toxic product in the vegetation?
    • Is the site toxic to vegetation?
    • Does phytoremediation work in the lab, greenhouse, and, most importantly, the field?

 Schnoor then noted that due  to underbudgeting at voluntary cleanup sites, efficacy and mass balance
 have not been demonstrated very well in the field. He added that it is difficult in some cases to predict
 which contaminants will  be taken up by plants. The rule of thumb  is that those with a log Kow of one
 to three can be taken up. However, some chemicals with a log Kow of 0.2 are absorbed by plants.

 Next, Schnoor discussed phytoremediation lab studies that have been conducted at the University of
 Iowa. The first study was a reproduction of a Brigg's (1982) plot where phytoremediation was used to
 address approximately 20 contaminants. Some of the contaminants—atrazine, alachlor, TCE, BTEX,
 chlorobenzene, benzo(a)pyrene, BEHP, chlordane, nitrobenzene, aniline, TNT, RDX, and 1,4-
 dioxane—were examined for uptake, volatilization, and soil mineralization. Analysis has shown that
 innocuous end-products have been found using 14C-compounds for atrazine and TCE in vegetables
 and poplars. Tests in the Midwest on atrazine showed that 138 ppm soil concentrations were
 decreased to 20 ppm atrazine after two growing seasons, with atrazine ring cleavage products
 detected within 80 days (results soon to be published in Environmental Science and Technology). In
 Iowa, an ammunition plant had soils contaminated with TNT. During phytoremediation of this site,
 some of the RDX was translocated into leaf tissue, while TNT was not translocated, but degraded in
 the root zone.

 University of Iowa researchers have teamed up with consultants who have expertise in design,
 irrigation techniques, and tree planting to further their work in the area of phytoremediation. Both
pilot- and full- scale demonstrations have been performed for pesticides, nutrients, TNT, and RDX (in
process), BTEX, and TCE contaminated soils.

Schnoor next discussed the limitations of phytoremediation technology. He explained that

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 phytoremediation is most applicable at shallow contaminated sites with moderately hydrophobic
 contaminants. He then noted that it is difficult to establish vigorously growing vegetation at many sites
 due to soil contamination, especially from metals. In addition, damage to vegetation from deer
 browsing, voles, beavers, damaging frosts, and disease, should be considered before choosing
 phytoremediation as part of a cleanup decision. Schnoor then noted that in order for phytoremediation
 to be successful as a commercial technology, fate studies need to be performed in the lab and
 greenhouse to understand entry into the environment of parent compounds and metabolites.

 Schnoor then presented the group with a list of the research needs that should be identified before
 phytoremediation can be  considered a successful technology:

    • Long-term field studies to show the presumed efficacy of phytoremediation (some historical
      sites "remediated" with phytoremediation could be candidate sites for post audits).
    • Screening test methods for determining the optimum plant species for each site.
    • Models for fate and transport of soil and groundwater contaminants under the influence of
      phytoremediation (the HELP, PRZM, and EPIC models have been utilized but were not
      developed for phytoremediation applications so new models developed specifically for
      phytoremediation would be helpful).
    • A better understanding  of the ecology of the system, such as myccorhizae, bacteria, and plant
      interrelationships and functions.
    • Transgenic plants for potential future applications.
    • The ability to degrade common contaminants, such as TCE and BTEX.
    • More feeding studies to determine the bioavailability and toxicity of contaminant metabolites in
      the soil following phytoremediation.

Phytoremediation Work in Cooperation with EPA's Region 7/8 Hazardous Waste Substance Center
(HSRC) and  Two Industry Partners       •

Kathy Banks  (Kansas State University) discussed phytoremediation  work she has been conducting in
cooperation with EPA's Region 7/8 Hazardous Substance Research Center (HSRC) and two industry
partners. The first site she described was a Gulf Coast site that is contaminated with crude oil that has
leaked into an agricultural area. Here, plots have been seeded and overseeded with rye and St.
Augustine grasses, and sorghum. After 21 months, researchers were able to determine enhanced
microbial activity on the vegetated plots, which appeared to result in TPH degradation. In addition,
they found that the rye and St. Augustine grasses performed better than the sorghum and the
unvegetated control plot.  Banks noted that this may have occurred because rye and St. Augustine
roots are more fibrous than sorghum roots and provide more surface area for microbial activity.

Banks next described her work at an old refinery site contaminated with petroleum hydrocarbons on
the West Coast. Here, plots include an unvegetated control, a tall fescue plot, a native California
fescue plot, and a grass and legume mixture plot. Preliminary results indicate that the mixed species
plot at this site appears to be more effective at remediating the contamination than the single species
plots.

A new research project began last summer at a naval facility in Norfolk, VA,  where bioremediation
cells are being used to implement phytoremediation. The species used at this site include Bermuda
grass with annual rye, tall fescue, and white clover. Researchers are hopeful that phytoremediation will
work at this site because of the significant growth they have already seen in the plants and observed
TPH degradation. However, only time will tell the extent of the technology's  effectiveness at this site.

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  Banks then presented the group with some conclusions she has been able to make from her research:

        The rate of degradation depends on plant species.
        Optimization of fertilization is an important issue.
        Optimization of irrigation techniques to spread roots is crucial.
        Degradation rates in mixtures of contaminants need to be determined.
        Microorganisms appear to degrade compounds.
        BIOLOG analyses of microorganisms associated with plants showed a higher microbial diversity
        associated with the rhizospheres of plants that degraded petroleum most efficiently.

  Phytokinetics, Inc./SITE Program Project

  An Ferro (Phytokinetics, Inc.) discussed a phytoremediation project to remediate soils containing 75-
  400 ppm PCP and PAHs  at an old wood preserving site in Portland, OR. This project was the first
  phytoremediation technology accepted into EPA's SITE Program.

  The project was conducted in two phases—a greenhouse study (Phase I) and a small field-scale study
  (Phase H}—to compare the rates of contaminant removal in both planted and unplanted samples. For
  Phase I, soil samples, which were very acidic and only had the basic level of nutrients, were collected
  from the McCormick & Baxter Superfund site where significant PCP and PAH contamination exists
 These samples were then put into four columns: two planted with perennial rye grass and two
 unplanted. Data shows that the nutrient status remained the same in the four treatments, but
 contaminant removal rates increased in the planted samples. Phase II was conducted at a small plot on
 the McCormick & Baxter Superfund site. Here, four plots—two unplanted and two planted with
 perennial rye grass—were developed in a 50 x 50 foot area where there was light PCP and PAH
 contamination. Ferro said data from both phases indicate that a full-scale phytoremediation field study
 may be successful to remediate the contamination at the site.

 Phytoremediation and Commercialization

 Paul Thomas (Thomas Consultants) discussed  phytoremediation as it pertains to commercialization.
 He explained that detailed information is needed to determine the  kinds of soil that should be used for
 field- scale phytoremediation projects.  Water movement, reductive oxygen concentrations,-root
 growth, and root structures all affect future growth of plants and should be considered when
 implementing phytoremediation.

 Thomas then noted that the success of phytoremediation  by trees is often determined by root growth
 and that it is difficult to determine the direction roots will grow in  the field. One way to do this
 however, is to influence root growth patterns by digging a trench around the existing roots using a
 pressure washer to uncover the roots, and covering them up again. Thomas then said that it is
 important to know the source of any contamination before deciding to use phytoremediation He
 added that  a full site characterization is needed if vadose zone soils are contaminated.

Thomas said that most owners of contaminated sites don't want to fond research on their sites, but
seem t6 be willing to fund phytoremediation. In addition,  there seems to be no incentive for
researchers who implement phytoremediation projects to return  to these sites to collect data to
determine if the technology is working. Thomas said that all phytoremediation projects should include
a pre-plan" to ensure that  data will be collected at sites in the future.

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  Thomas then showed slides of a LUST site where phytoremediation is being used to remediate
  petroleum contammat.on. Two rows of hybrid poplars were planted on the site in trenches and a

     mt         WaS r ^ threC ff ' dOW" gradiem fr°m the trees- Next sPrin& ^searchers plan to use
                sampling to see if the technology is working.
  THURSDAY, December 19, 1996

  PANEL DISCUSSION ON REGULATORS' PERSPECTIVES ON PHYTOREMEDIATION

  Jim Cummings  the Panel Moderator, led the Panel Discussion. He explained that this session was
  being held to address the relationship between regulation and remediation. The three most important
  programs that have a remediation component are CERCLA, RCRA, and TSCA CERCLA via the
  National Conttngency Plan has a remediation (versus regulatory) thrust. The statute itself provides
  rehef from permit requirements (section 121(e)). RCRA and TSCA have regulatory requirements
  which impose duties and potential sanctions on researchers, technology developers and remediation
   rl^nern^Lamilianty W'th aPPr°Priate Provisions of RCRA (for RCRA hazardous wastes) and
       (tor V CB wastes) is recommended before commencing treatment activities
 Cummings noted that to date there have been few, if any situations where potential application of
 RCRA requirements to a phytoremediation project has arisen. Most projects to date appear to involve
 voluntary cleanup programs not involving wastes subject to RCRA. There are some unresolved policy
 issues regarding the extent to which phytoremediation may be subject to RCRA The Technology
 Innovation Office has initiated discussion with the Office of General Counsel and the Office of Solid


 Cummings noted that discussions with federal and state regulators indicated a general receptivity to
 phytoremediation, i.e. , there did not appear to be any inherent bias against phytoremediation
 approaches.

 Nevertheless, regulators tended to voice a recurring set of concerns. These concerns tended to be
 practical in nature (rather than narrow issues of regulatory requirements which regulators are
 sometimes accused of being hung up on), for example:

    • At present, how does the science compare with the practice of this technology? Are the two in
      some appropriate balance?
    . How can we evaluate potential efficacy? [clean-up timeframes and ability to reach desired
      cleanup levels]
    • How long will the technology take before contaminant levels begin to decrease? Is the
      proponent  simply "stalling" in proposing/applying this technology, since "time is money" and
      phytoremediation is so cheap?
    • Is there potential for production of harmful daughter products and/or release  of sequestered
      contaminants via transpiration?
    • Overall, the regulators seemed to be looking for rules of thumb to be able to determine whether
      there is an appropriate match between the site and the proposed approach

Curnmings then introduced the panelists for this session. Lisa Marie Price,  U  S  EPA-Region 6
PpT^!? k£jexas Natural Resource Conservation Commission (TNRCC); Harry Comptor^ U.S.
EPA-ERTC, Edison, NJ; and Thomas Wilson, U.S. EPA-Region 10 who provided  some perspectives

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 based on their site-specific experiences and their general experience as regulators.

 U.S. EPA-Region 6 Phytoremediation Projects

 Lisa Marie Price (U.S. EPA-Region 6) presented the group with her experience at three sites where
 phytoremediation either has been considered or implemented. The first site is an old munitions site
 where phytoremediation was considered to remove TNT product. Price noted that researchers
 continue to monitor the phytoremediation/natural degradation that appears to be occurring with the
 standing pines on the site.

 The next site is an old pesticide plant in East Texas where portions of the site have been closed by a
 state order. Residual contamination has been found in the neighborhoods adjoining the site. Price
 explained that phytoremediation was considered as a remedy for the arsenic at the site, but EPA didn't
 choose the technology because the site was being addressed as a time critical removal action in order
 to prevent recontamination of the neighborhood.

 The third site, the Red River Army Depot, is a military vehicle refurbishing installation where
 phytoremediation is being considered as an option for treatment. Phytoremediation is being proposed
 by the Army to address chlorinated solvent contamination in ground water; however, because the
 installation is being realigned under the Base Realignment and Closure (BRAC) program, creating
 clean-up time constraints, and because there is an inadequate understanding of the extent of the
 problem, EPA is hesitant to fully endorse phytoremediation as an integral part of the site's remedy.

 Phytoremediation and TNRCC

 Richard Clarke (TNRCC) said that TNRCC has little experience with phytoremediation and is
 concerned about this technology's application at sites where time constraints and  risk reduction rules
 are an issue. He noted that phytoremediation may be a partial option for treatment, but under state
 rules, TNRCC has to approve all rules  and is unsure how to permit phytoremediation projects.

 Phytoremediation at Aberdeen Proving Ground

 Harry Compton (U.S. EPA-ERTC, New Jersey) discussed a phytoremediation project being
 implemented on a historic bombing range at Aberdeen Proving Ground (APG) in  Maryland. The site
 has old toxic burning pits where munitions were burned, causing groundwater contamination with
 PCA, tetrachlorine, TCE, and chlorinated solvents eight feet under ground.

 Compton noted that APG prefers the use of state policy to provide alternatives to cleanup and restore
 the aquifer. Compton added that researchers have considered a variety of technologies for cleanup, but
 most were ruled out because of the presence of UXO on the site. There are no clean-up time
 constraints for the site. Compton said the Army was willing to spend money to do phytoremediation,
 but wanted to refer to as a "revegetation study" until EPA and the Army can prove that the technology
 can work.

 The site was planted with hybrid poplars and a trench was built to ensure that the  trees would be
taking up groundwater instead of rain water. Researchers were concerned about predator and frost
 problems, but the trees flourished and have already grown to 1-3 inches in diameter. Compton said
that the Army has used three pairs of lysimeters,  which were is nested at two different depths, to
investigate vadose pore water and has monitored the leaves, stems, and roots of the plants on the site.

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 In addition, the Army and EPA plan to perform bag studies to measure VOCs in the air. Investigations
 show that PCA has been taken up by the plant roots but may not be translocated in the plant.

 The Army is hopeful that the technology will work, but no direct evidence data currently has been
 collected from the site to determine if phytoremediation is being effective. According to Comptoa
 there are plans to examine whether VOCs are present in both woody and animal tissue. A short video
 has been developed for this project. For a copy, contact Compton at (908) 321 -6751.

 Phytoremediation and Regulation

 Thomas Wilson (U.S. EPA-Region 10) explained that the regulatory community can make technology
 commercialization difficult. For example, while some regulators are willing to support field trials
 needed to advance a new technology, others prefer to wait until the technology is proven by someone
 else. And even after all studies are done, spreading the word among the many federal,  state, and local
 regulators can present a daunting challenge.

 Wilson then noted that some people may view phytoremediation as a ploy to give problem-site owners
 more time for cleaning their sites. Some (hopefully few) even argue that high cleanup costs are
 punishment for polluters, and that phytoremediation should thus not be used to lower those
 "punishment" costs.

 Wilson then noted the absence of environmental groups at the meeting. He stressed their importance in
 achieving both public and regulatory acceptance of this new technology. Wilson then urged meeting
 attendees to actively seek opportunities to educate environmental and citizens' groups on
 phytoremediation.

 OPEN DISCUSSION

 Stuart Strand said regulators should be committed to ensuring that adequate data comes out of
 phytoremediation projects. John Fletcher noted that the only way to get phytoremediation
 commercialized is to obtain data from naturally occurring  ecosystems where plants appear to have
 success in naturally remediating contamination that occurred in the past. He added that the success for
 phytoremediation is dependent on increased funding and that the government should be committed to
 providing funds to move the technology forward.

 Steve McCutcheon noted that rigorous investigation is needed to determine the successful application
 of phytoremediation. He then expressed his concern that phytoremediation may end up being used at
 sites prematurely before scientists truly understand the  state-of-the-science of this technology. Walt
Kovalick said there should be a greater effort to gather data on phytoremediation, but didn't think this
 applied work would likely get done with research grants. Instead, it will probably need to be funded
through partnerships and alliances.

Tom Wilson said EPA has not acknowledged phytoremediation as a technology that has applications
beyond just cleanup. Terry Mclntyre said considerations need to be made for source material and
disposal of spent biomass when addressing phytoremediation.

Jerry Schnoor said regulators should be involved early in the technology selection process. He then
noted that fate data should be collected for both laboratory and greenhouse studies. He added that
geochronology of intrinsic bioremediation sites should be investigated.

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  Thomas Wilson said research in the area of phytoremediation is very fragmented and isolated data
  points won't give us the data we need to move forward. What we need are funding sources that can be
  accessed to integrate the data that has already been collected. John Fletcher said despite limited
  funding, available data from laboratory experiments can be used to determine what will happen in the
  field. He then noted that a holistic approach needs to be developed for risk analysis for toxics in
  ecosystems. Tom Wong agreed, but said that research should move forward at sites where
  phytoremediation makes sense.

  Joseph Keflemarian (TNRCC) said that phytoremediation regulations, which include time constraints
  and require containment technology, should be in place before phytoremediation is used. This poses a
  dilemma, however, that would require support from the regulatory community and development of
  quick guidance on this issue by the states. Richard Clarke agreed, noting that once risk is contained,
  long-term solutions can be developed to determine if phytoremediation is working.

  John Fletcher said enough is currently known to estimate evapotranspiration by plants and determine
  rainfall in certain areas. In addition, it is known that water run-off from sites needs to be collected for
  treatment by other methods. With this knowledge, there is no harm in initiating phytoremediation
 projects now. Stuart Strand responded that  knowledge of seasonal variations and buffers for plume
 migration should be built into phytoremediation systems. He added that agronomic knowledge is very
 important to determine whether phytoremediation projects will be successful.

 BREAKOUT GROUP REPORT-OUTS

 After some discussion, the attendees decided to breakout  into two groups: one to discuss chlorinated
 solvents and the other to discuss petroleum and pesticides. Each breakout group was charged to
 answer the following questions:

 1) What are the important questions, which, if answered, will allow broad application of
 phytoremediation?

 2) How shall these questions be addressed (e.g. laboratory, field, research and development
 demonstrations)?

 3) Who are the interested parties?

 4) How shall we proceed (e.g., meeting summary, teleconferences, electronic means,  form a group like
 andRTDF)?                                                                    .

 Petroleum/Pesticides Breakout Group

Phil Sayre, TIO, presented the attendees with his breakout group's findings. The following list includes
the issues (noted by underlining) that the group identified to answer the first Question above: What
are the important questions,  which, if answered, will allow broad application of phytoremediation?
Text under each of the underlined items addresses the second Question noted above: How shall these
questions be addressed (e.g.  laboratory, field, research and development, demonstrations?

1) Develop Fate and Transport Models for certain contaminants within plants.

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  The group acknowledged that existing ground water models can be used to a limited extent in
  phytoremediation applications, but that more integration of plant effects on groundwater need to be
  added to these models such as transpiration rates and their effects on groundwater. Also, models need
  to be developed that integrate plant effects on contaminants and water availability in the unsaturated
  zone. AS part of thus integration of plants into existing groundwater and vadose zone models -further
  work needs to be done to model the fate of contaminants within the plant tissues: distributions of
  metabolites in  different plant tissues (stem, root, leaf) are difficult to predict,  as well as transpiration
  rates tor water and contaminants such as volatile organics.

  2) Establish toxicity-driven regulatory endpoints that would apply to phytoremediation.

  The group discussed ways for determining whether phytoremediation residuals are toxic They agreed
  that phytoremediation tests should include toxicity assays for the end-products of phytoremediation
  including tissue metabolites and remaining chemicals present in soils/sediments following
  phytoremediation  The findings of the toxicity tests should be incorporated  into the fate and models so
  that the total time for remediation of a site could be made based on toxicity of relevant compounds
  fate and transport models could focus on those plant metabolites which pose the greatest risk  etc  '
  tttorts should be made by those interested in pursuing toxicity testing, as it relates to
  phytoremediation, to become active in the Petroleum Environmental Research Foundation/Gas
  Research Institute (PERF/GRI) efforts in the area of toxicity testing. Members of the group also
  thought that since a significant portion of the PERF/GRI effort is focussed on earthworm tests as an
  indicator of the toxicity of soils/sediments during the remediation process, fertilizer toxicity to
  earthworms should be examined.

 3) Determine the bioavailability/mobility of phytoremediation residuals in soil

 Linked with the issue of the toxicity of residual chemicals in soils following phytoremediation is the
 ability of these chemicals to become bioavailable to target organisms or move offsite. Some residuals
 regardless of their toxicity, may be so tightly bound to soil that they cannot cause toxicity to
 ST* °T!T fr°m thC remediation site to other locations due to  their inability to partition to the
 liquid phase. Further tests were recommended on remediation with grasses in which PAH and TPH
 concentrations are compared over time. After such long-term studies are done, is there binding of
 petroleum wastes to soils/sediments which decreases the mobility and/or toxicity of the wastes? Are
 there other plant species which should also be considered for such testing?

 4) Identify federal funding vehicles for forensic studies of wastes.

 The group discussed which agencies should be responsible for funding projects which would examine
 the decreased toxicity at sites which have become overgrown with plants as part of the natural
 ecological progression that occurs (so-called forensic studies of contaminated sites) As an example of
 SUh KP*J TA   Presentation «iven by Mr. Tom Wong at this meeting. There is a need to identify
 which Federal Agency would fond such work and  whether efforts should be focussed on lab or field
 studies. The group agreed that data would need  to be obtained from existing industrial sites and that
 regulators would need to ease restraints on site owners to gather more data. The group also discussed
the extent to which small pipeline spills need to be cleaned up and which plant species occur at these
sites which could be planted in similar locations.

5) Develop screening models that can identify whether phytoremediation will work at a site,  and which

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  treatability tests need to be conducted.

  Such a minimum data set would aid decisionmakers involved in assessing the utility of

  phytoremediation at a site.

  6) Determine the minimum data set that would be needed to show that phytoremediation has been
  efficacious at a site.

  Such a minimum data set would also aid decisionmakers involved in assessing the utility of

  phytoremediation at a site.

  7) Development of a database that would indicate which plant species/cultivars are capable of assisting
  in the remediation of agricultural chemicals and petroleum hydrocarbons.

  The group believed such a database could be begun by gathering existing data first from

  the literature, and from some private companies which have begun this effort already.

  Sayre next presented a list of the interested parties who should be involved in phytoremediation which
 was responsive to the third Question posed to the break out Group: Who are the interested parties?

     •  Environmental Groups
     •  Landscape Architects and Process Developers
     •  Small and Medium Size Companies that Own Problem Sites
     •  Other Larger Companies
  USDA
      Venture Capitalists
      Regulators (to provide a clarification of the regulations)
      Forestry Division (To provide information on large-scale monocultures)
      Soil Conservation Service
      Environmental Remediation Equipment Developers
      Plant Pathologists
      Department of Transportation (for advice on grass establishment)

•NOAA

    • Environmental Toxicologists
    • Large Environmental Remediation Companies
    • Local Agriculture Extension Services
    • Ecologists

Finally, Sayre then described different avenues the group identified for continuing the discussion on
phytoremediation, in response to the final Question posed: How shall -we proceed (e.g., meeting
summary, teleconferences, electronic means, form a group like and RTDF?

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 1) An electronic meeting place (i.e., WWW site or electronic bulletin board system) should be
 developed for at least two purposes: to provide a database of the results of phytoremediation tests
 which have been conducted, and to serve as a question-and-answer forum.

 2) There should be a participant follow-up conversation on partnering in three-months.

 3) The list of interested parties noted above should be prioritized in order to focus in on

 those most likely to be of assistance.

 4) A second meeting should be held to further discuss phytoremediation. This meeting could be held in
 conjunction with Batelle's "Fourth International Symposium on In Situ and On-Site Bioremediation,"
 which is being held in April in New Orleans and will likely attract the most participants from the Ft.
 Worth meeting. Alternatively, a meeting could be arranged in conjunction with the B3C
 Phytoremediation Meeting, which is being held in Seattle this June.

 5) A minimum data set should be developed by Industry and the U.S. and Canadian Federal
 Governments that would be provided by those who clean up a waste site that would provide
 convincing evidence that the site has been remediated.

 6) The issues of phytoremediation should be tied into an existing RTDF since funding is already
 available for such an effort. (Walt Kovalick noted that an RTDF can be developed without funding
 commitments. He added that the initial success of an RTDF is not so much determined by funding as it
 is by the travel and time commitments each member is able to give.)

 Chlorinated  Solvents Breakout Group

 Steve McCutcheon presented the Chlorinated Solvents Breakout Group's findings. The following list
 includes the issues the group identified to answer What are the important questions, which, if
answered, will allow broad application of phytoremediation?

   • Plant mass balance, uptake, breakdown, transport, and transpiration
   • Dose response and pharmacokinetics models for plants
   • Fate and transport models
   • Field sampling protocols, demonstration end points, key questions, important risks, risk
      assessments
   • Guidelines on phytoremediation for regulators and decision makers

McCutcheon then noted that the group agreed that a solid research and development strategy is
needed. This strategy could include the following:

      One or more field demonstrations.
      Directed lab research to support field demonstrations.
      Intrinsic Remediation and Phytoremediation Protocol (Design Guidance).
      Paleoecology and forensic toxicology data on sites which have been revegetated.
      Technical Evaluation Panel for vendors  (such a group would be critical for ensuring that
      vendors are qualified in remediation; not just planting grass.)

-------
  McCutcheon then presented some consensus points developed by the group:

     • An RTDF Action Team is needed for general networking and communication, which could
       include teleconferences and e-mails.
     • The Interested Parties who need to be included at the table are:

  - Air Force, Army, Navy, and other components in the Department of Defense

       Department of Energy
       Chemical Manufacturers' Association, Gas Research Institute, and Electric Power Research
       Institute
       Insurance Companies
       DuPont, Union Carbide, Ciba-Geigy, Monsanto, Dow Chemical, and Occidental Chemical
       Other groups that support RTDF groups.          *

 • Funding could be provided by:

     •  Department of Defense
     •  Department of Energy

 - EPA

      National Science Foundation
      Industry
      Private Foundations
      Venture Capitalists
      Technology Developers

  Technology developers who should be involved include:

      U.S. Department of Agriculture
      Agronomists
      Botanists
      Ecologists
      Biotechnology Firms

- ASTM

• Other groups who should be involved in the phytoremediation discussion include.

- Regulators; the Interstate Technology and Regulatory Cooperation Workgroup (ITRC)
    •  Environmental Groups
    •  Citizens' Groups
McCutcheon then noted that the group agreed that chlorinated solvents behave differently than
petroleum hydrocarbons and should be covered by a separate partnering group. John Fletcher said he
couldn't agree more,.noting that a distinction between soluble versus insoluble compounds should be

-------
  made when discussing implementation of phytoremediation because insoluble compounds involve
  different processes, including bacterial degradation.


  CLOSING REMARKS
                 hpp                   i" e'mail °Ut the attendees list to a" attendees

 cTuld i,!    " h *     ™? CXf °re thC ideS °f establishing a web s*e for phytoremediation that

 establi S± * ' R™Frf°0mI   ShanT8 idCaS °n PMonsnedtation. EPA also will explore the idea of
 establishing an RTDF for phytoremediat.on. He then noted that TIO is willing to act as a

 clearinghouse of information on phytoremediation.
 we    r       1" TSf ^"T? & ""**** °n PMoremediation, possibly in conjunction
 Tn rf STi       f       f 1C ^y10^^'^" meetings. Tom Wong noted that TNRCC plans to
 hold it. large conference at the same time of the New Orleans meeting, which would exclude
                                                              ,

             wA ^Chc eTloyees if New Orleans was chosen as the        pace-  ova<
 ,tn I H            ,   u e Wlhng l° SCt Up a series of teleconferences to discuss phytoremediation
 until a decision is made when to hold the meeting.                                  «i,cuwuon
The meeting adjourned.




Back to Publications




http://www.epa.gov/swertiol/downioad/minutes/phytominhtm
Page last modified: August 14, 1997

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                           COVINGTON  &  BURLING
                             I2OI PENNSYLVANIA AVENUE. N. W.
                                     P.O. BOX 7566
                              WASHINGTON. D.C. aOO44-7566
                                    (2031 663-6OOO
THEODORE L. GARRETT
    OIMCCT DIAL NUMBER
    (2O2I eO2-S3CB
    10arrittOcov.com
                                   FACSIMILE: (2O3) 662-6291
June 25, 1999
    LECONFIELO HOUSE

    CURZON STREET

    LONDON WtY GAS

      ENGLAND

 TELEPHONE 4-4-I7I-4O5-S65S

 FACSIMILE: 44-I7I-4OS-3IOI


KUNSTLAAN *A AVENUE OES ARTS

  BRUSSELS IO4O BELGIUM

 TELEPHONE 3Z-E-S49-S23O

 FACSIMILE: 32-2-3O2- ISOB
        BY HAND

        Mr. Richard Puvogel
        Project Manager
        U.S. Environmental Protection Agency
        19th Floor
        290 Broadway
        New York, New York 10007-1866

                    Re:    Federal Creosote Site. Manville. N.J.

        Dear Mr. Puvogel:

                 We are submitting herewith, in accordance with the extension of the
        public comment period, our client's supplemental comments on the EPA Proposed
        Plan for the Federal Creosote Site. These comments augment the comments
        submitted to you on June 1, 1999. They are the result of a review of the three
        boxes of raw data and the administrative record file that you made available last
        week in the EPA Region II office.

                 The May 3, 1999, comments by the National Remedy Review Board
        (NRRB) raise many of the concerns discussed in our initial comments.1 The
        enclosed supplemental comments further emphasize the serious flaws in the EEPA
        Proposed Plan.

                 •  The NRRB comments urge EPA to complete the ongoing  site-wide
                 RI/FS and develop a cleanup strategy for the entire development before
                 actual removal of any source material. For example, should additional
                 homes be bought out,  on site treatment options may become more
                 practicable.

                 •  The EPA Proposed Plan is also premature in that it relies  on only a
                 limited set of data to identify the alternative. EPA should await the
                 compilation and evaluation of the larger body of data currently being
       1 The NRRB comments were not in the Manville public record that we reviewed and copied, and
       thus we could not discuss the NRRB comments in our June 1 submission.

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COVINGTON & BURLING

        June 25, 1999
        Page 2
                 generated as part of a site-wide RI/FS.  There is no public health
                 justification for a piecemeal approach to the site, based on the findings of
                 ATSDR.

                 • The NRRB comments state that EPA  should have developed,
                 considered and documented alternatives that reflect the scope and
                 complexity of site problems being addressed. EPA's rationale for
                 proposing only one alternative and excluding other alternatives from
                 consideration, such as thermal desorption, is unsupported.

        EPA should have expected to receive comments from NRRB based on EPA's
        meeting with NRRB, which is referenced in the May 3 NRRB letter.  However, the
        Proposed Plan was issued by EPA without awaiting receipt of the NRRB comments.
        This is an important deviation in procedure warranting reconsideration of the
        Proposed Plan by EPA.

                 Please contact me if you have any questions concerning the enclosed
        comments.

                                        Sincerely yours,
                                        Theodore L Garpett

       Enclosure

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TABLE OF CONTENTS
           ATTACHMENT 1

               National Remedy Review Board Recommendations for the Federal
               Creosote Site, Bruce K. Means, Chair, National Remedy Review
               Board, to Richard L. Caspe, Director, Emergency and Remedial
               Response Division, EPA Region 2, (Noted as signed by BK Means on
               May 3,1999).

           ATTACHMENT2

               The National Remedy Review Board Progress Report: Fiscal Year
               1996. What Does the Board Look At When It Reviews A Decision? USEPA
               Memorandum December 18,1997. Review of Non-Time Critical
               Removal Actions by the National Remedy Review Board.

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                    SUPPLEMENTAL COMMENTS
                                ON THE
                   SUPERFUND PROPOSED PLAN
                      FEDERAL CREOSOTE SITE
                      MANVILLE, NEW JERSEY

 This document presents supplemental comments on the EPA Proposed Plan for
 the Federal Creosote Site (the "Site") in Manville, New Jersey. Our June 1,1999,
 comments expressed concerns that EPA's process of selecting a preferred
 alternative was biased and overlooked other remedial alternatives that could
 remedy the Site at significantly lower cost. Since those comments were
 submitted, we reviewed comments by the National Remedy Review Board
 (NRRB) and three boxes of data not previously made available in the public
 record. This new information underscores our prior concerns and raises several
 new issues:

          • The NRRB comments highlight EPA's need to complete the ongoing
          Site-wide RI/FS and develop a cleanup strategy for the entire
          development before actual removal of any source material. They also
          demonstrate why the EPA Proposed Plan is premature in that it relies
          on only a limited set of data to identify the alternative. EPA should
          have developed, considered and documented alternatives that reflect
          the scope and complexity of Site problems being addressed.

          • The additional technical data made available show that the
          analytical data relied on by EPA are suspect. In addition, the reliance
          on visual contamination in developing and implementing EPA's
          Proposed Plan is inappropriate due to the presence of diesel fuel in the
          samples. Finally, there are insufficient data to support the conclusion
          that the lagoons and canals are continuing sources of contamination.

These concerns are discussed in more detail below.
1.  The EPA Proposed Plan is premature in the absence of a completed Site-wide,
   Remedial Investigation and feasibility Study (RI/FS).

The EPA Proposed Plan is premature, particularly in light of the fact that
environmental data are still being developed as part of an ongoing RI/FS. Hence,
it is inappropriate to move forward with the preferred alternative in the EPA

-------
 Proposed Plan until a full comparative analysis of remedial alternatives, as
 contemplated in the National Contingency Plan (NCP), is completed.1

 Our contention is supported by the NRRB as stated in the memorandum found
 in the administrative record in EPA's Region 2 office.2 The NRRB states that the
 EPA Proposed Plan considered only a single cleanup alternative; it emphasizes
 the need to complete a Site-wide RI/FS; and recommends that on-site treatment
 alternatives be considered as part of a Site-wide RI/FS.

 2.  There is uncertainty about Site conditions that could impact waste treatment
    and/or disposal options.

 The Agency for Toxic Substances and Disease Registry (ATSDR) has determined
 there is neither an immediate nor short-term health threat under existing
 conditions. Therefore, the more prudent course of action is to await completion
 of the ongoing sampling and RI/FS as referenced in the EPA Proposed Plan.
 Then, a baseline risk assessment can be completed to develop Site-specific soil
 cleanup objectives so appropriate response actions can be considered.

 The NRRB memorandum states that the EPA selected its preferred alternative
 without the benefit of fully understanding Site conditions. As a result, the EPA
 Proposed Plan did not consider an appropriate range of remedial alternatives
 that adequately took into account these considerations. The NRRB memorandum
 points out that the appropriate handling of any excavated material or decision on
 land-use options should be based on a more thorough cleanup strategy.

 A more thorough cleanup strategy should focus on on-site, ex  situ and in situ
 remedial alternatives, as well as off-site ex situ treatment/disposal options other
 than incineration. As stated in our prior comments, there are on-site, in situ and
 ex-situ, treatment options that are equally protective and more cost effective than
 the preferred alternative in the EPA Proposed Plan. They should have been part
 of the range of alternatives considered in developing the EPA Proposed Plan.
 Additionally, as we previously commented, off-site facilities exist that can accept
 the material for thermal treatment (New Jersey), recycling or land disposal
 (Canada). As noted by the NRRB, on-site treatment options may become more
 practicable following completion of a Site-wide RI/FS. The range of in situ and
 ex situ remedial alternatives that we identified in our prior comments have been
1 National Oil and Hazardous Substance Pollution Contingency Plan. 40 CFR Part 300, section
300.430 (e) (2) (iii), (ii),(9), (ii) March 8,1990 (revised September 14,1994).
? National Remedy Review Board Recommendations for the Federal Creosote Site. Bruce K.
Means, Chair, National Remedy Review Board, to Richard L. Caspe, Director, Emergency and
Remedial Response Division, EPA Region 2, (Noted as signed by BK Means on May 3,1999)

-------
  employed at other similar CERCLA sites and are far more cost-effective than the
  preferred alternative in the EPA Proposed Plan.

  3. EPA failed to develop and consider a full range of remedial alternatives.

  The EPA Proposed Plan considered only a single alternative. To ensure
  consistency with the NCP, a more comprehensive evaluation of alternatives
  needs to be documented before acceptance of the EPA Proposed Plan and
  issuance of a ROD. This evaluation is properly done at the conclusion of the.
  ongoing RI/FS. The considered alternatives should include biological and
  thermal treatment options as outlined in our prior comments. Only then will
 EPA be able to demonstrate they are controlling response costs while promoting
 a consistent and cost-effective decision.

 Because EPA considered only a single alternative, the NRRB was unable to
 achieve one of its key objectives; investigating whether other approaches to
 achieve cleanup had been evaluated. This is one of the subjects that the NRRB is
 tasked to complete when it reviews a cleanup strategy for consistency with the
 NCP. 3

 4.  The failure to use cleanup techniques set forth in SW-846 adversely affected
    the accuracy of reported concentrations and elevated the sample detection
    limits.

 EPA made available the raw data from approximately 300 samples that were
 collected as part of the lagoon and canal delineation for review during this
 extended comment period. The data are predominately from soil samples that
 were analyzed for polynuclear aromatic hydrocarbons (PAHs).  The quality
 assurance information from selected random samples identified problems
 associated with surrogate recoveries, and matrix and matrix spike duplicate
 (MS/MSD) analyses. These problems were identified and addressed by the EPA
 contractor's validators.

 Detection limits were elevated in many of the samples reviewed, primarily due
 to high concentrations of both target PAHs and non-target heterocyclic PAHs, as
 indicated in the tentatively identified compound (TIC) data included in the
 validation reports. Neither of the two laboratories that analyzed the samples
 used any of the clean-up techniques presented in SW-846 to improve detection
 limits or bring MS/MSD analyses into control by removing the heterocyclic
3 The National Remedy Review Board Progress Report: Fiscal Year 1996. What Does the Board Look
At When It Reviews A Decision ?

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 In not following the prescribed procedures set forth in SW-846, much of the
 reported concentrations relied upon to develop EPA's Proposed Plan were
 biased high. Consequently, any calculated exposure point concentrations, like
 benzo(a)pyrene (BaP) equivalents, are overstated. An inaccurate assessment and
 communication of potential risks will result if biased high data is relied upon to
 characterize risks.

 5.  The reliance on visual contamination in developing and implementing EPA's
    preferred alternative is inappropriate due to the presence of diesel fuel in the
    samples.

 The EPA Proposed Plan states that a subjective criterion, visible contamination,
 was used for the cleanup criterion and resultant cost and volume estimates. If
 relied upon during implementation of the remedy, the presence of diesel fuel
 will distort the scope of the excavation and likely result in unnecessary removal
 and treatment of soil.

 The diesel fuel was identified in the PAH gas chromatographs (GC) as a series of
 symmetric peaks at a retention times of approximately 18 to 22 minutes. The
 corresponding mass spectra from late eluting PAHs, such as
 benzo(g,h,i)perylene, show alkyl fragmentation patterns not characteristic of the
 parent PAH, confirming the presence of the diesel fuel.

 6. There are insufficient data to support the conclusion that the lagoons and
   canals are active sources of contamination.

 As a result of reviewing the additional documents provided by EPA during the
 extended comment period, we have concluded there are insufficient data to
 show that the lagoon and canal areas are active source areas. Hence, the EPA
 should await completion of the Site-wide RI/FS so that a comprehensive
 remedial strategy can be developed that addresses all contamination in a cost-
 effective and protective manner.

The groundwater data and physical conditions encountered beneath Lagoon A
 suggest the PAHs are not migrating. Specifically, the Technical Memorandum
prepared in November 1998 indicates that there is a dense silt layer, which could
not be penetrated beneath Lagoon A.  If continuous, this layer would serve to
inhibit downward migration from the lagoon. With the exception of one
geoprobe sample believed to be water from within Lagoon B, groundwater
sampling, conducted at various locations around the development, did not detect
any constituents above MCLs. Additionally, many of the soil samples collected
from the lagoons had percent solids concentrations of greater than 90 percent,

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suggesting the material has a consistency similar to asphalt. As the PAHs also
have extremely low aqueous solubilities, there is no basis for EPA's rationale for
characterizing these as major sources of soil and ground water contamination.

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                                                        Attachment 1
National Remedy Review Board Recommendations for the Federal Creosote Site.
Bruce K. Means, Chair, National Remedy Review Board, to Richard L. Caspe,
Director, Emergency and Remedial Response Division, EPA Region 2, (Noted as
signed by BK Means on May 3, 1 999)

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            UNITED  STATES ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON,  D.C.  20460
                      Signed by  BK Means  on 5/3/99
                           Original with Region
                                                                     OFFICE OF
                                                                  SOLID HASTE AND
                                                                     EMERGENCY

                                                                     RESPONSE
MEMORANDUM

SUBJECT:   National Remedy Review Board Recommendations for the Federal Creosote
     Superfund Site

FROM:      Bruce K. Means, Chair
            National Remedy Review Board

TO:         Richard L Caspe, Director
           Emergency and Remedial Response Division
            EPA Region 2

Purpose

      The National Remedy Review Board (NRRB) has completed its review of the proposed
remedial action for the Federal Creosote Superfund Site in Manville, New Jersey. This
memorandum documents the NRRB's advisory recommendations.

Context for NRRB Review

      As you recall, the Administrator announced the NRRB as one of the October 1995
Superfund Administrative Reforms to help control response costs and promote consistent and
cost-effective decisions. The NRRB furthers these goals by providing a cross-regional,
management-level, "real time" review of high cost proposed response actions. The board
reviews all proposed cleanup actions that exceed its established cost-based review criteria.

      The NRRB review evaluates the proposed actions for consistency with the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP) and relevant Superfund policy
and guidance.  It focuses on the nature and complexity of the site; health and environmental
                                                                   10.00030

-------
 risks; the range of alternatives that address site risks; the quality and reasonableness of the
 cost estimates for alternatives; regional, state/tribal, and other stakeholder opinions on the
 proposed actions, and any other relevant factors.

       Generally, the NRRB makes "advisory recommendations" to the appropriate regional
 decision maker before the region issues the proposed response action for public comment.
 The region will then include these recommendations in the Administrative Record for the site.
 While the region is expected to give the board's recommendations substantial weight, other
 important factors, such as subsequent public comment or technical analyses of response
 options, may influence the final regional decision. It is important to remember that the NRRB
 does not change the Agency's current delegations or alter in any way the public's role in site
 decisions.
NRRB Advisory Recommendations

       The NRRB reviewed the informational package for the proposed remedial action at the
Federal Creosote Site and discussed related issues with EPA project manager Rich Puvogel
on March 10, 1999. Based on this review and discussion, the NRRB offers the following
comments.

       The regional proposal considered only a single cleanup alternative that would buy and
     demolish homes above subsurface contaminant source materials. These source
     materials would then be excavated and incinerated off site. The board supports the
     need forjjction at this site, as well as the region's plan to buy and demolish about a
     dozen homes. Such work will be necessary to address the hjghlyjrontamiru^^
     material under any. circumstance.  However, prior to.thejclgjaUemovaTjirf any source
     material, the board believes that the Region should complete the ongoing site-wide
     RI/FS and develop a cleanup strategy for the entire housing development.  This strategy
     should identify the full extent and magnitude of soil contamination in the area,
     appropriate response actions to address this contamination, site-specific soil cleanup
     objectives, appropriate disposition of any excavated material, and resulting land use
     options.

       The region should work closely with the community to determine how best to preserve
     the integrity of the existing residential community given the apparent need to demolish
     the homes. However, given the stated uncertainty about the potential contamination not
     addressed by this proposed action, the site-wide cleanup strategy mentioned above
     should also describe the criteria or circumstances that would lead to the buy out of
     additional homes, or the entire development, and, in addition, the effect such decisions
     would have on waste treatment and/or disposal options. That is, should a more
     extensive buy out be required, on-site treatment options may become more practicable.
     Thus, the board recommends that the region include an assessment of on-site treatment
     alternatives (e.g.,  soil washing,  in situ chemical oxidation (ISCO)) as part of the site-wide
     RI/FS.

••      The site package provided little discussion of the range of alternatives considered
     against the NCR's nine criteria in addressing the subsurface contamination problems.
                                                                        10.00031

-------
     However, the presentation to the board made it clear that additional alternatives were
     evaluated.  The NCR (FR Vol. 55, No. 46, March 8,1990, p.8704) encourages early
     actions "prior to or concurrent with conduct of an RI/FS as information sufficient to
     support remedy selection" is developed, but also indicates that the alternatives
     evaluation and documentation "reflect the scope and complexity of the site problems
     being addressed." Accordingly, since the proposed early action involves relatively
     complex remedy selection issues (e.g., permanent/temporary relocation, costly off-site
     treatment, phasing of site study and actions), the board recommends that an appropriate
     supporting analysis addressing these issues, and the other waste management options
     considered, be included in both the proposed plan and ROD.

       The region plans to use sheet piling as soil retaining walls during excavation. Given
     the limited excavation depths expected in some areas, the board believes the region can
     save money by using less expensive engineering methods (e.g., simple graded slope) in
     lieu of sheet piling where feasible.

       The NRRB appreciates the region's efforts to work closely with the state and
community groups at this site.  The board members also express their appreciation to the
region for its participation in the review process. We encourage Region 2 management and
staff to work with their regional NRRB representative and the Region 2/6 Accelerated
Response Center in the Office of Emergency and Remedial Response to discuss any
appropriate follow-up actions.

       Please do not hesitate to give me a call if you have any questions at 703-603-8815.

cc:     S. Luftig
       T. Fields
       B. Breen
       J. Woolford
       C. Hooks
       R. Hall
       OERR Center Directors
                                                                            10.00032

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                                                      Attachment 2

The National Remedy Review Board Prop-ess Report: Fiscal Year 1996. What
Does the Board look At When It Reviews A Decision? USEPA Memorandum
December 18,1997. Review of Non-Time Critical Removal Actions by the
National Remedy Review Board

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•j NRRB Annual Report Introduction                                        http://www.epa.gov/superfund/programs/nrrb/rem_rev/intro.htm
i
                  vvEPA
                   The National Remedy Review Board
                                    Progress  Report:
                                    Fiscal Year 1996
                  Introduction

                  EPA created the National Remedy Review Board (the Board) in January 1996
                  as part of a comprehensive package of reforms designed to make the Superfund
                  program faster, fairer, and more efficient. This report highlights the Board's
                  significant accomplishments in its first year of operation. It also presents
                  information intended to help those interested in the Board's work learn more
                  about the review process, its contribution to the Superfund program, and how
                  interested parties can contribute to review efforts.

                  In the next section we describe the Superfund reform initiative and explain how
                  the Board contributes to its goals. The following sections present information
                  on the Board's first year of operation, its effect on Superfund cleanups, and
                  resource issues. Included as attachments to this report are several EPA
                  documents and memoranda that provide detailed information about Board
                  operating procedures, cleanup decision reviews, and other issues.
                 EPA's Superfund Reforms

                 The Superfund program is one of our country's most ambitious and complex
                 environmental programs. It arose out of the need to protect citizens from the
                 dangers posed by abandoned or uncontrolled hazardous waste sites. When
                 CERCLA (the Superfund law) was enacted, the challenge of cleaning up what
                 was assumed to be a few hundred discrete, land-based cleanups appeared
                 relatively straightforward. However, the problem of neglected hazardous waste
                 sites has revealed itself to be far more complicated and widespread than anyone
                 at first realized.

                 We now recognize that the number and complexity of hazardous waste sites
                 across the nation dwarf original estimates. To date, EPA has identified more
                 than 41,000 sites and assessed more than 39,000 of them. Almost 1,400 of
                                                                                       S/lg/99 6:49 PM

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i  NRRB'Ajmual Report Introd.--lion                                 ,            http://www.cpa.gov/superft,nd/programs/nrrt)/rcm_rev/intro.htm

I  '
                     these sites have been considered a serious enough threat to be designated a
                     Federal priority for cleanup on the National Priorities List (NPL). EPA has
                     completed construction of all cleanup activity at about thirty percent (410) of
                     these. The vast majority of the remaining NPL sites are either under study or
                     being cleaned up.

                     In addition, Superfund has conducted emergency responses and prompt removal
                     actions to attack the most immediate threats of toxic exposure at more than
                     3,000 sites in communities across the country. Through these "emergency
                     response" actions, EPA continues to protect public health and the environment
                     from immediate risks.

                     As a logical outgrowth of EPA's experience in managing the Superfund
                     program, EPA has put in place a series of Superfund reforms. These reforms
                     substantively change the way the Superfund program handles its cleanup
                     responsibilities within existing laws. They are aimed at accelerating the pace and
                     reducing the cost of cleanups, streamlining remedy selection, increasing fairness,
                     promoting economic redevelopment, and better integrating Federal and State
                     cleanup programs. Within these changes, however, remedies are preferred that
                     incorporate treatment technologies and provide long-term reliability for site
                     cleanup. The Agency believes these reforms will save cleanup dollars without
                     sacrificing public health or environmental protection. In October 1995, EPA
                     announced its final round of reforms. One of the principal reforms in this final
                     round is the National Remedy Review Board.


                      Superfund is authorized by the Comprehensive Environmental Response, Compensation, and
                     Liability Act (CERCLA), as amended. 42 U.S.C. §9601 et. seq. The program's principal
                     implementing regulation is the National Oil and Hazardous Substances Pollution Contingency
                     Plan, also known as the NCP, 40 CFR Part 300.
                     The National Remedy Review Board

                     Assistant Administrator Elliott Laws announced the Board's formation in a
                     November 28, 1995, memorandum to Regional Waste Management Division
                     Directors (attachment 1). As stated in the memorandum, the Board's goals are
                     to promote cost-effectiveness and national consistency in remedy selection at
                     Superfund sites. To accomplish this, EPA staffed the Board with technical
                     experts and senior managers from each EPA Region and several EPA
                     Headquarters offices. This group of experienced personnel provides a unique
                     and impartial audience with which to discuss cleanup strategies, issues of
                     national consistency, and the cost-effectiveness of cleanup actions. The Board
                     analyzes proposed site-specific cleanup strategies in "real time" to ensure that
                     they are consistent with the Superfund law, regulations, and relevant agency
                     guidance. Attachment 2 presents a list of Board members.

                     The Board reviews all proposed cleanup decisions where (1) the proposed
                     action costs more than $30 million; or (2) the proposed action costs more than


  2 of 9                                                                                             5/18/99 6:49 PM

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•- NRRB'Annual Report Introduction
http://www.epa.gov/superfund/programs/nrrb/rem_rev/intro.htm
                     $10 million and this cost isj50% greater than that of the least-costly, protective
                     cleanup alternative that also complies with other laws or regulations that are
                     "applicable" or "relevant and appropriate" to a site decision or action.

                     The Board plans to review sites early in the remedy selection process, before
                     the Region releases the proposed plan for public comment. Occasionally,
                     however, a post-proposed plan site may benefit from Board review. For
                     example, remedy changes in response to public comment may increase the total
                     remedy costs. Where these additional cleanup costs exceed 20 percent of the
                     original cost estimate and trigger normal Board review criteria, the Board may
                     review the draft remedy. Please see attachment 3 for a depiction of the various
                     steps in the Superfund remedial process and where Board review occurs. After
                     its review, the Board issues advisory recommendations as to how or whether a
                     potential Superfund site remedy decision can be improved. The
                    recommendations are not binding, but EPA Regional decision makers give them
                     substantial consideration. Although this effort is a valuable enhancement to the
                    current decision making process, it is important to remember that this reform
                    does not change current delegation of authorities or diminish in any way the
                    public's current role in site cleanup decisions. Please refer to attachment 4 of
                    this document for a more detailed explanation of the role of interested parties in
                    the review process.
                    The National Remedy Review Board Process

                       • The EPA remedial project manager (RPM) in charge of the site develops
                         an informational site package that forms the basis of Board review. The
                         package presents basic site information as well as technical information
                         on exposure and risk assessment scenarios, cleanup goals, and cost
                         estimates for various cleanup alternatives.

                       • The Region consults with key State/Tribe decision makers to guarantee
                         State/Tribe concerns are conveyed accurately and completely  in the
                         package.

                       • The RPM also solicits  information from PRPs who conduct remedial
                         investigation/feasibility studies (RI/FS) and community representatives.
                         Their submissions are included as attachments to the informational site
                         package.

                       • Each site decision discussion is divided into two phases: an information
                         sharing phase, to which State/Tribe representatives are routinely invited,
                         and a deliberative phase. The Board will invite the State/Tribe to
                         participate in the deliberative discussion for State/Tribe-lead
                         Fund-financed decisions/and for State/Tribe enforcement-lead decisions
                         where the State/Trive seeks EPA concurrence. Otherwise, the Board
                         limits its deliberative discussions to EPA personnel.
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   NRRB'Annual Report Introduction                                            http://www.epa.gov/superfund/programs/nrrb/rcm_rev/intro.htnn
                           Shortly after each review, the Board sends any advisory
                           recommendations to the appropriate Regional Division Director in a brief
                           memorandum.
                     Summary of Fiscal Year 1996 Accomplishments

                     Fiscal year 1996 has been a challenging but very productive year. Below are
                     some of the Board's significant accomplishments in its initial year of operation.

                        • Developed the Board's mission, identified key technical experts and
                          managers, and began deliberative operations within eight weeks of the
                          formal announcement from Assistant Administrator Elliott Laws.

                        • Held deliberative meetings in January, March, May, June, and August.

                        • Reviewed each of 12 proposed Regional Superfund decisions that
                          triggered Board review criteria.

                        • Issued  substantive or technical recommendations for nine of the 12
                          decisions reviewed. These recommendations are expected to increase the
                          cost effectiveness of the decision by strengthening overall cleanup
                          strategies. The Board supported without substantive comment three of
                          the proposed actions.

                        • Contributed to improved national consistency in Superfund remedy
                          selection.

                        • Recommended analyses that may ultimately  reduce total cleanup costs for
                          all sites reviewed in fiscal year 1996 by as much as $15 million to  $30
                          million (please see next page for further explanation).

                        • Contributed to an enhanced role in Superfund remedy selection for
                          States/Tribes, private parties, and communities at high stakes sites.

                        • Confirmed that, overall, the Superfund program is making sound,  cost
                          effective, remedy decisions that are consistent with the Superfund  law, its
                          regulations, and guidance.
.                   Board Reviews

                    Of the 12 proposed cleanup decisions submitted by EPA Regional offices for
                    review, the Board fully supported three decisions with only minor
                    recommendations. Of the remaining nine, the Board generally supported, with


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                   technical recommendations, another three decisions. For six decisions, the
                   Board offered more substantive recommendations. In all cases, the Regions will
                   conduct analyses to decide whether and to what extent the reviews may
                   ultimately affect their cleanup approaches. For a summary of characteristics for
                   all decisions reviewed in 1996 see Table 1.

                   Although several Regions are still considering Board comments on proposed
                   decisions, already the Agency is encouraged by the range of benefits observed
                   from the review process, including improved national consistency, clarity of
                   decisions, and cross-Regional communication on key remedy selection issues. In
                   some cases review recommendations have contributed to  much lower site
                   cleanup costs. For example, in Region 8, Board advisory recommendations
                   regarding management of low-level threats at the Petrochem/Ecotek site
                   contributed to an estimated reduction in total cleanup costs of approximately $8
                   million.

                   At the Jack's Creek site in Region 3, Board discussion of principal threats may
                   ultimately reduce soil cleanup costs at the site by as much as $10 million to $15
                   million. EPA expects additional cost reductions in the future from other fiscal
                   year 1996 reviews. Overall, the Board members indicate potential cost
                   reductions in the range of $15 million to $30 million in total site cleanup costs
                   from reviews conducted this fiscal year.

                   Of course, cost reductions are only part of the story. By targeting sites for
                   review early in the Superfund process — in most cases before proposed plan
                   issuance — important sites benefit from the Board's expertise and discussion
                   before EPA site managers make key decisions in the final remedy, reducing the
                   potential for revising the cleanup strategies later in the process. Moreover, cost
                   reductions do not reflect the value of benefits that  come from a general increase
                   in scrutiny of cleanup costs, increased national consistency in remedy selection,
                   improved technical analysis of promising cleanup strategies, better-articulated
                   decision rationale at high stakes sites, and increased confidence of Agency staff
                   and stakeholders in the final remedy.

                   In addition, the review process has stimulated cross-Regional dialogue on a
                   broad range of issues that  affect sites other than the high-cost sites. For
                   example, the Jack's Creek review exposed the fact  that although most EPA
                   Regions used a particular model to assist in calculating adult lead exposure,
                   several did not. Because the Board members communicate the lessons learned
                   from their reviews within and across the Regions, project managers at a site in
                  Dallas, Texas, realized that they might also use the model. As a result, they
                  were able to adjust lead cleanup goals and potentially save a significant amount
                  of money while improving overall program consistency.

                  Attachment 5 provides the full text of publicly available Board
                  recommendations as of November 1,  1996.
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NRRBAnr al Report Introduction                                             http://www.epa.gov/superfund/programs/nrrb/rero_rev/intro.htn


                   What Does the Board Look At When It Reviews a

                   Site Decision?

                   The Board analyzes the cleanup strategy to ensure that it is consistent with the
                   Superfund law and the National Oil and Hazardous Substances Pollution
                   Contingency Plan (or NCP). The NCP is the Federal regulation that details
                   procedures for responding to oil or hazardous substances releases. The Board
                   also considers relevant EPA cleanup guidance.

                   When they review a site, the Board members ask many questions about the
                   proposed cleanup strategy.  Site-specific circumstances nearly always influence
                   the nature of the discussion. Among others, Board members investigate subjects
                   like these below:

                      • What are the site characteristics that present a threat to human health and
                        the environment?
                        What is the rationale behind exposure scenarios and risk assumptions?
                        What are the details of the Regional proposal for site cleanup?
                        Are the cleanup goals appropriate and attainable?
                        Have other approaches to achieve the cleanup goals been evaluated?
                        Are the cost estimates reasonable?
                        What are the concerns of the States/Tribes, PRPs, and communities?
                        Is the strategy consistent with other Agency decisions?
                   Year-End Assessment

                   To assess its overall performance in fiscal year 1996, the Board conducted an
                   in-depth analysis of its effect on individual site decisions. In interviews with
                   Regional staff who participated in the reviews, Board members addressed
                   subjects such as the effects of the reviews on site cleanups; how the reviews
                   affected management involvement in site decisions; and whether the reviews
                   improved remedy consistency, remedy protectiveness, or cost effectiveness.
                   They also discussed ways to improve the review process.

                   Overall, participants found the experience a positive and worthwhile
                   contribution to the remedy selection process for their respective sites.
                   Generally, these Regional staff believe the process improves national
                   consistency on  important issues, adds credibility to Regional decisions, and can
                   identify money-saving alternatives the initial Regional analyses did not consider.
                   On the other hand, Regional staff expressed some frustration with the workload
                   the review process places on them. They also raised concerns about the
                   potential for delays in cases where reviews raise fundamental questions.
                   Summarized below are responses from the Regional review participants to
                   general questions about the Board's effect on the cleanup decisions.
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                     •  The reviews did not affect the cleanup schedules for most of the proposed
                        decisions.

                     •  Overall, the prospect of Board review increased Regional management
                        involvement in the proposed decisions. It also resulted, in some cases, in
                        management interest at an earlier point in the decision making process
                        than would have occurred otherwise.

                     •  Some participants see a benefit for the Regions  in that Board reviews and
                        subsequent advisory recommendations add credibility to final Regional
                        decisions since these decisions will have had the added benefit of
                        additional independent technical review.
                  Operating Improvements

                  EPA recognizes that the Board's operating protocol need to reflect a meaningful
                  role for parties with a stake in the review process. With this in mind the Board
                  made a substantial investment early on to work with interested parties and
                  understand their concerns. For example, States/Tribes felt strongly that since
                  they work closely with EPA in developing proposed cleanup strategies the
                  Board discussions would benefit from the State perspective. The Board agreed,
                  and has adopted procedures to ensure significant State/Tribe involvement in the
                  review process. In addition, PRPs and community advocates sought to
                  guarantee that their interests would be accurately and completely conveyed in
                  materials reviewed by the Board. In response to this concern the Board decided
                  to solicit written technical comments from key PRPs and community groups.
                  Attachment 4 describes in greater detail the role of interested parties in the
                  review process.

                  As a result of the Board's dialogue with interested parties EPA issued a
                  September 26, 1996, memorandum titled "National Superfund Remedy Review
                 Board" that formalizes refinements in  the Board's operating protocol (see
                 Attachment 6). These refinements reflect the concerns of interested parties as
                 well as EPA Regional project managers. Among other things, they will ensure.
                  1) timely review of proposed site decisions prior to the issuance of the proposed
                 plans; 2) prompt notification of key private sector stakeholders, States/Tribes,
                 recognized community groups and technical assistance grantees, and other
                 Federal agencies; 3) thorough consideration of stakeholder concerns in the
                 review discussions; and 4) a continuing dialogue with interested parties to
                 assure that the Board process is agreeable and fair to all involved.
                 FY96 Operating Costs and FY97 Cost Projections
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 NRP^ Arajual Report Introduction                                            http://www.epa.gov/superfiind/programs/nrrb/rem_rev/intro.htm


                   EPA estimates that fiscal year 1996 Board activities cost approximately
                   $523,250. These estimates include salary and expense monies for Board
                   members, Board support staff, and Regional management/RPMs; travel to and
                   from the Board meetings; and incidental costs (e.g., fees for meeting rooms).
                   These costs average out to approximately $43,600 per decision reviewed by the
                   Board.

                   In fiscal year 1997 the Board will likely review between  10 and 20 sites. Based
                   on the 1996 average of approximately $43,600 per decision and a five percent
                   inflation rate, the Board will require between $450,000 to $900,000 for salaries,
                   expenses, and travel.
                   Conclusion

                   This past fiscal year was a challenging one for the entire Agency. Government
                   shutdowns and funding uncertainty disrupted site cleanups and increased the
                   workload on both Headquarters and Regional EPA staff. Even so, the National
                   Remedy Review Board accomplished a great deal.  The hard work of the Board
                   members and strong support of Regional management and staff has paid off in
                   significant cost savings, improved national consistency, more robust decision
                   analysis, and an enhanced role in the remedy selection process for States/Tribes,
                   private parties, and communities at high stakes sites.

                   Overall, the Board believes its reviews confirm that the Superfund program is
                   making sound, cost effective, remedy decisions that are protecting public health
                   and the environment consistent with CERCLA, its  regulations, and guidance. At
                   the same time, the experience of the past year has shown that there are instances
                   in which the management level, cross-Regional Board discussions can save
                   money and add value both to proposed cleanup strategies and to program
                   decision making as a whole. As the Superfund program continues its work in
                   the coming years, it remains important for EPA to provide both the public and
                   Congress the assurance that Superfund remedies are both cost effective and
                   protective of public health and the environment. The Board believes it has made
                   important contributions to these goals in fiscal year 1996 and looks forward to
                   similar success in the coming year.
                  Attachments:

                     1.  11/28/95 EPA Memorandum: "Formation of the National Superfund
                        Remedy Review Board"
                     2.  National Remedy Review Board Members
                     3.  Chart Depicting Board Review Timing for High Cost Cleanups in the
                        Superfund Site Remediation Process


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                     4.  Role of Interested Parties in the Review Process
                     5.  Full Text of Publicly Available National Remedy Review Board Advisory
                        Recommendations
                     6.  9/26/96 EPA Memorandum: "National Superfund Remedy Review
                        Board"
                                         Progress Report FV96 - Table of Contents
                                 f EPA Home I OSWER Home I Superfund Home 1
                           t Search EPA I Search Superfund I What's New [Contact Us T

                      URL: http.7/www.epa.gov/superfiind/prograrns/nrrb/rem_rev/intro.htm
                                   This page last updated on October 6, 1998
                      Web Page maintained by Office of Emergency and Remedial Response
                                     Comments: superfund. mfofci:.epa.
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I Attachment 1                                                 http://www.epa.gov/saperfond/programs/ruTb/rem_rev/anachl.htm
i
I
                 4? EPA
                                    ATTACHMENT  1

                            Formation of the National Superfund
                                      Remedy Review Board
                 MEMORANDUM

                 SUBJECT:

                      Formation of National Superfund Remedy Review Board

                 FROM:
                      Elliott P.  Laws
                      Assistant Administrator
                 TO:
                      Director, Office of Site Remediation and  Restoration - Region I
                      Director, Emergency and Remedial Response Division - Region II
                      Director, Hazardous Waste Management Division - Regions III, IX
                      Director, Waste Management Division - Region IV
                      Director, Superfund Division - Regions V, VI, VII
                      Assistant Regional Administrator,  Office  of Ecosystems Protection
                           and' Remediation - Region VIII
                      Director, Environmental Cleanup Office -  Region X

                 DATE STAMPED:

                      NOV  28 1995
                   1. Purpose
                   2. Backaround
                   3. Discussion
                   4. Implementation
                   5. Attachment A
                   6. Attachment B


                PURPOSE

                This memorandum requests your assistance in establishing the National Superfund
                Remedy Review board recently announced by the Administrator as one of the key



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 Attachment 1                                                         http://www.epa.gov/superfiind/programs/nirb/rem_rev/attachl.htm
 •      .

                    Superfimd Administrative Reforms. This Review Board is intended to help control
                    remedy costs and to promote both consistent and cost-effective decisions at Superfund
                    sites, including federal facilities.


                    BACKGROUND

                    As you all know, cost plays an important role in Superfund response decisions. The
                    statute, in fact, mandates that, in addition to being protective, all remedies must be
                    cost-effective. This mandate is built into the remedy selection process established under
                    the National Contingency Plan (NCP), and expanded upon in a number of related
                    program guidances. In this year of greatly reduced budgets, it is even more important for
                    us to focus on this criterion in our decision making. On October 2, 1995, EPA
                    Administrator Carol Browner announced a collection of Administrative Reforms
                    intended to help our program achieve significant cost savings without compromising a
                    remedy's protection of human health or the environment or reliability. Today, as one of
                    these Reforms, I am announcing the formation of the National Superfund Remedy
                    Review Board.


                    0ISCUSSION

                    By establishing this Board, I intend to help control remedy costs by providing a
                    cross-Regional management-level review of high  cost (and thus, potentially
                    controversial) decisions in "real time" on a site-specific basis.

                    Board Structure and Function

                    This national Review Board will be comprised of senior Agency managers or experts on
                    remedy selection, cost effectiveness, and program implementation from both the Regions
                    and Headquarters. Each Region  will have one management-level representative on the
                   Board. Headquarters representatives will include national experts from the Federal
                   Facilities Restoration and Reuse Office, the Technology Innovation Office, the Office of
                    General Counsel, ORD's National Risk Management Research Laboratory, and the
                    Office of Emergency and Remedial Response (OERR). Other Offices may be requested
                   to participate as the need arises.  The Board will be chaired by Bruce Means, Senior
                   Process Manager for Response Decisions in OERR.

                   All proposed cleanup actions at sites where: (1) estimated costs for the preferred
                   alternative are over $30M; or (2) proposed remedy costs are over $10M and 50%
                   greater than the costs of the least-costly, protective, ARAR-compliant remedy will be
                   subject to the Board's review. As other cost control "rules of thumb" are developed
                   (under a separate Administrative Reform), these "guides" may also be used to signal the
                   need for this Board's review. My overall expectation, based on previous ROD history, is
                   that this program should result in Board review of approximately 10% of FY96 actions.

                   The Review Board will consider the nature of the site, the risks posed by the site,
                   regional and state/tribal opinions on proposed actions, the quality and  reasonableness of
                   the cost estimates, and any other relevant factors or program guidances in making
                   "advisory recommendations" to the Regional Administrator regarding EPA's preferred
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  remedy before a proposed plan is issued for public comment. The overall goal of the
  reviews will be to ensure sound decision making consistent with current law, regulations,
  and guidance. The Board's reviews will be performed quickly but will require advanced
  planning by the Region to account for the added review time. Remedies subject to Board
  review should be brought to the Board's attention as soon as the Region has identified
  them as likely 'preferred alternatives,1 but in any case before the proposed plan is
  announced for public comment. Regions are encouraged to coordinate with OERR
  Regional Service Center Coordinators as early as possible in the process.

  Especially since we are operating under a greatly reduced budget this year, I am sensitive
  to the likely increase in workload for you and your staff. This new Board will require
  additional work for us all and may briefly delay release of a small number of proposed
  plans by about two months. For these reasons, the Board will work to establish a review
  process that requires a minimum of travel and effort for Board participants. The Board is
  likely to form standing subgroups, based upon geography, expertise or workload.
 Reviews are likely to involve the faxing of relevant materials to subgroups for discussion
 by conference call after a brief review period. Details will be developed further as part of
 the Board's initial organizing discussions.

 The Board is expected to be fully operational by January 1996. However, proposed
 remedies planned for issuance in the first quarter of FY '96 which meet the screening
 criteria noted  above should also be discussed with my office.

 Key Messages

 By establishing this Board, I want to encourage decision makers to think even harder
 about the costs of response actions at every Superfund site.

 However, this effort does not change the Agency's delegation authorities or alter in any
 way the public's current role in site decisions. This current effort is intended to facilitate
 the application of our national program's extensive experience to a select number of "high
 stakes" and thus, potentially controversial site decisions.


 IMPLEMENTATION

 If you have not already done so, please send your nominations for Board membership by
 December 8, to Bruce Means at (703) 603-8815; FAX: (703) 603-9103; Mail code
 (5204G). We have already welcomed the nominations of Walter Graham (Region 3)
 Wendy Carney (Region 5), Bill Honker (Region 6), and Wayne Pierre (Region 10). '
 Bruce will be contacting your representatives shortly to schedule an introductory
 conference call later this month. For your information, Attachments A and B present an
 overview of the Board's tentative start up schedule and member- ship, respectively. I
 expect the Board to be up and running by the beginning of January 1996.

I recognize that this additional review for the sites that exceed these cost control triggers
may briefly delay the release of proposed plans. However, it is critically important to the
Agency that we provide both the public and Congress the necessary assurances that
Superfund dollars are being well spent. This Board will do much to provide those
assurances.
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                                                       http://www.epa.gov/superfund/programs/nrrb/rem_rev/atuch 1 .htni
                Thank you for your prompt attention to this important matter.                         ^~
                                                                                       w
                 Attachments

                 cc:  Regional Administrators
                     Steve Herman, OECA
                     Bob Huggett, ORD
                     Jon Cannon, OGC
                     Romona Trovato, ORIA
                                      Attachment A

                        National Super fund Remedy Review Board
                                 Tentative Start-Up Schedule
                                            (11/20/95)
                October/November

                - Analyze past RODs meeting trigger criteria to examine trends.

                - Issue memorandum to Regions announcing the Board kickoff.

                - Complete membership list.

                December

                - Initial meeting/conference call to introduce concepts, discuss possible charter,
                operations/workflow models, roles.

                - Develop/revise charter; determine need for additional Regional/HQ members/contacts.

                January

                - Fully operational.




                                      Attachment  B
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  AttachmeijJ 1                                                  http://www.cpa.gov/superfiind/programs/niTb/rein_rev/attach 1 .htm


                          National Superfund Remedy Review Board
                                       Proposed Membership
                                               (11/20/95)
                  Region 1 -- TBD
                  Region 2 — John Frisco
                  Region 3 — Walter Graham
                  Region 4 — TBD
                  Region 5 — Wendy Carney
                  Region 6 — Bill Honker
                  Region 7 — TBD
                  Region 8 -- TBD
                  Region 9 — TBD
                  Region 10 — Wayne Pierre

                  OERR  - Bruce Means
                  ORD/National Risk  Management Research Lab - TBD
                  FFRRO -  Jim Woolford
                  OSC - TBD
                  OSWER/TIO -  TBD
                  Other Offices may  be invited to participate as needed.
                                         Progress Report FYQ6 Table of Content's
                                  I EPA Home I OSWER Home I Superfund Home 1
                             I Search EPA I Search Suoerfund I What's New IContact Us 1
                       URL: http://www.epa.gov/superfund/programs/nrrb/rem_rev/attachl .htm
                                   This page last updated on October 6, 1998
                        Web Page maintained by Office of Emergency and Remedial Response
                                     Comments: suverfund, hifof&epa.gov
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